rev.1

Introduction and Purpose

Vieri spa was founded in 1977. We manufacture and sell gold products, in particular bracelets and necklaces.

Our registered office is in Via Ippodromo 23/A, Sandrigo (VI). Our factory is situated in Via Monte Asolon 67, Cassola (VI). Two wholesale local units are located in Via dei Frassini 35, Vicenza and at The Tarì Goldsmith Center in Marcianise. Our company has more than 80 wage employees and 3 managing partners. Our company is a Responsible Jewellery Council member.

RJC is a standards body which was established to improve environmental, social, ethical and human rights procedures throughout the entire jewellery supply chain, with regard to gold, silver, platinoids, diamonds and coloured gemstones.

RJC has developed a standard for the jewellery supply chain and trustworthy ways of checking that companies work in compliance with responsible business practices through third-party bodies. As a RJC member, we are committed to performing our activities in compliance with the RJC Code of Practices. We are committed to integrating our daily activities, business planning and decision-making processes with ethical, social, environmental and human rights reflections.

This policy shows our commitment to respect human rights, to avoid actions which could promote armed conflicts, and accept UN sanctions and laws.

Annual reviews:

• We annually review working practices and have not encountered any events or incidents adverse to RJC principles and human rights, within our company or among our business partners.

RJC Policy

This policy describes the ethical and social principles and values which inspire Vieri’s company policy. The recipients are employees, partners, clients, suppliers and all interested parties.

Human Rights

Vieri spa is committed to recognizing, mitigating and preventing – when possible – potential human rights violations connected to its activities.

In order to achieve this, Vieri spa is committed to:

• Protecting human rights and fundamental freedoms in compliance with the Universal Declaration of Human Rights adopted in 1948 and the following international covenants on human rights.
• Acknowledging and respecting the principles of the ILO – International Labour Organization – Conventions, in particular freedom of association to join trade unions, prohibition of forced and child labour by accepting only employment relationships regulated by Italian collective labour agreement CCNL, prohibition of discrimination on the basis of gender, age, ethnicity, religion, political party and union membership, sexual orientation and gender identity, language, disability, and existing laws on labour rights.
• Not using corporal punishment or inflicting degrading treatment, abuse, coercion, or any forms of intimidation.
• Not stocking up on materials which come from areas where armed conflicts, widespread violence or possible human rights violations are present.
• Concerning abuse in gold extraction, transport and trade: we are committed to not tolerating, profiting from, contributing to, accepting torture or cruel, inhuman or degrading treatment; forced and child labour; human rights violations and abuse; war crimes, international human rights law violations, crimes against humanity or genocide.
• Ending partnership with suppliers if there is any risk of them being involved with or stocking up from a third part committing the abuses previously mentioned.
• Confirming the role of public and private security forces is ensuring the safety of workers, plants, machinery and property, in accordance with the law. We do not support, directly or indirectly, security forces who commit any kind of abuse or do not comply with the law.

Vieri spa is committed to supporting the development of the communities in which it operates and aims to contribute to the economic and social well-being of the area.

The company promotes charitable and solidarity initiatives and supports and contributes to projects which help communities.

Anti-corruption, anti-malfeasance and anti-money laundering policy

We are committed to running our company with the utmost respect for ethical norms and guaranteeing integrity and transparency in compliance with applicable laws.

In order to achieve this, we are committed to:

• Avoiding subordination, corruption and malfeasance and contributing to fight these crimes and other unacceptable behaviours.
• Not accepting any payments, gifts, discounts, advantages, promises and/or other benefits, which could exceed normal business practices or common courtesy and could influence our independence of judgment or induce us to ensure any advantage or special treatment.
• Not making any transactions and/or operations, which could compromise the principles of fair competition or be used to try to influence business or decision-making processes.
• Not offering, promising or pocketing kickbacks and not covering up or concealing gold origin. Not making any false statements on tax returns with the purpose of extracting, transporting, trading and exporting gold.
• Avoiding conflicts of interest.
• Not tolerating money-laundering or terrorism financing. We are committed to contributing to stop money laundering connected to gold extraction, transport, trade and export.
• Not supporting, directly or indirectly, illegal and non-State armed groups, including paying, assisting or supplying equipment to non-State armed groups or affiliated members, who illegally:
  • Control mining sites, transport routes, and gold trading;
  • Extort money or gold in mining sites, along transport routes or from middlemen, export companies or international gold merchants.
  • We will immediately end partnership with suppliers if there is any risk of them stocking up from or being involved with a third part who supports, directly or indirectly, non-State armed groups as previously mentioned.
• Applying a correct due diligence, which takes account of the counterparty risk before establishing any business relationship, monitoring our supply chain closely, and doing Know Your Counterpart exercises.
• Declaring the characteristics of the precious metals we sell in a complete and detailed manner and making sure the weight, functionality, finishing touches and fineness of our products are correct by checking quality and conformity thoroughly and systematically with effective and advanced precision tools.
• Taking measures and following correct procedures to guarantee integrity and safety during shipments and prevent theft, damage and substitution.
• Respecting consumer rights by applying fair business, advertising and marketing practices and necessary measures to ensure product safety and quality.
• Respecting the principle of confidentiality and personal data protection in compliance with applicable laws.
• Ensuring payments are transparent and supporting security forces which protect the rights in the extractive industry.
• Establishing a process to let the parties involved discuss issues inside the jewellery supply chain.

Environmental policy

Vieri spa is committed to:

• Reducing environmental impact related to its activities by optimizing the use of energy resources, managing waste for every single activity correctly, and monitoring environmental aspects carefully, especially emissions to air.
• Choosing systems, materials and products which can ensure a lower environmental impact thanks to advanced technology.
• Training employees on respecting the principles of environmental and health protection and workplace safety, environmental regulations and internal procedures.
• Cooperating with relevant authorities to identify the optimal conditions for a balance between production activities and the surrounding environment.
• Assessing and re-examining risks and opportunities for improvement periodically depending on the context and requirements of interested parties.

Workplace health, safety and hygiene policy

Vieri spa supports those procedures which are necessary in order to ensure the health and safety of its workers and people who get in touch with the company and therefore is committed to:

• Respecting existing laws on workplace health, safety and hygiene.
• Training and informing its employees.
• Developing and maintaining a risk identification and management system for the health and safety of its workers.
• Determining and applying technical, organizational and operational interventions to prevent – when possible – and/or reduce risks connected to workplace health and safety of its employees.
• Ensuring and maintaining the health and well-being of its employees, visitors, clients and suppliers.

Security and privacy policy

Vieri spa is committed to protecting its own industrial property – such as trademarks, patents, distinguishing marks, designs, industrial designs, creative works, etc. – and others’.

Vieri spa has also informed its employees of the importance and need to respect the privacy and industrial property of the company and its business partners.