Extended delivery dates due to Brexit administrative changes and procedures

Due to administrative changes and procedures brought on by Brexit, we would like to inform you that current delivery delays have been extended. Our Concierge Service will contact you shortly with more information. Thank you for understanding.

RESPONSIBLE BUSINESS PRACTICES POLICY

RESPONSIBLE BUSINESS PRACTICES POLICY

Please find hereunder Responsible Business Practices Policy for ZENITH presenting:

  • The responsible supply chain Policy covering our diamonds, and coloured Gemstones’ as our gold, silver and PGM’s purchases;
  • The ZENITH human rights Policy related to our expectations in terms of Human rights, labor standards and social responsibilities; and
  • The alert line to report any violations of the present Responsible business practices Policy or of the LVMH Code of Conduct (corruption, money laundering, abuse of corporate assets, etc.).

1. RESPONSIBLE SUPPLY CHAIN POLICY

A. DIAMONDS AND COLOURED GEMSTONES

1. ZENITH, BRANCH OF LVMH SWISS MANUFACTURES S.A. is a Swiss manufacturer of luxury watches and precision chronographs.

This policy confirms ZENITH, BRANCH OF LVMH SWISS MANUFACTURES S.A.'s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

2. ZENITH, BRANCH OF LVMH SWISS MANUFACTURES S.A. is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

a. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;

b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;

c. support transparency of government payments and rights-compatible security forces in the extractives industry;

d. do not provide direct or indirect support to illegal armed groups;

e. enable stakeholders to voice concerns about the jewellery supply chain; and

f. are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

We also commit to using our influence to prevent abuses by others, by implementing the five-step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. In addition, ZENITH is committed to implementing the UN Guiding Principles on Business and Human Rights.

3. Regarding serious abuses associated with the extraction, transport or trade of minerals:

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

a. torture, cruel, inhuman and degrading treatment;

b. forced or compulsory labour;

c. the worst forms of child labour;

d. human rights violations and abuses; or

e. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.

4. Regarding direct or indirect support to non-state armed groups:

We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

a. controls mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain; or

b. tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups.

5. Regarding public or private security forces:

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally.

6. Regarding bribery and fraudulent misrepresentation of the origin of minerals:

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals.

7. Regarding money laundering:

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of minerals.

B. GOLD, SILVER AND PGM

1. ZENITH, BRANCH OF LVMH SWISS MANUFACTURES S.A. is a Swiss manufacturer of sports and luxury watches and precision chronographs. This policy confirms ZENITH, BRANCH OF LVMH SWISS MANUFACTURES S.A.'s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

2. ZENITH, BRANCH OF LVMH SWISS MANUFACTURES S.A. is a certified member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

a. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;

b. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;

c. support transparency of government payments and rights-compatible security forces in the extractives industry;

d. do not provide direct or indirect support to illegal armed groups;

e. enable stakeholders to voice concerns about the jewellery supply chain; and

f. are implementing the OECD five-step framework as a management process (and Supplement on Gold if applicable) for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

We also commit to using our influence to prevent abuses by others, by implementing the five-step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the provisions of the Supplement on Gold. In addition ZENITH is committed to implementing the UN Guiding Principles on Business and Human Rights.

3. Regarding serious abuses associated with the extraction, transport or trade of gold:

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

a. torture, cruel, inhuman and degrading treatment;

b. forced or compulsory labour;

c. the worst forms of child labour;

d. human rights violations and abuses; or

e. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.

4. Regarding direct or indirect support to non-state armed groups:

We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

a. control mine sites, transportation routes, points where gold is traded and upstream actors in the supply chain; or

b. tax or extort money, or gold at mine sites, along transportation routes or at points where gold is traded, or from intermediaries, export companies or international traders.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

5. Regarding public or private security forces:

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4, or that act illegally as described in paragraph 6.

6. Regarding bribery and fraudulent misrepresentation of the origin of gold:

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold.

7. Regarding money laundering:

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of gold.

2. ZENITH HUMAN RIGHTS POLICY

ZENITH ensures that the conduct of its businesses respects individual rights and encourages the continuous improvement of social and public health conditions, which are essential to the development and protection of individual rights.

ZENITH is committed to remaining vigilant in identifying any potential direct or indirect negative impact of its activities on society in order to prevent, or if necessary, remedy any such negative impact.

ZENITH respects and promotes the Universal Declaration of Human Rights and adheres to the principles of    the United Nations Global Compact, as well as to the United Nations Guidelines on Women’s Empowerment. Within its sphere of influence, ZENITH supports the values, freedoms and fundamental rights promoted in these texts.

A. HUMAN RIGHTS

ZENITH condemns any Human Rights Violation and takes fully in consideration:

  • Prohibition of child labor: Work by children under the age of 16 is strictly prohibited, including, in particular, the Worst Forms of Child Labour as defined by ILO Convention No.182. In countries where local laws set a higher age for child labor or set at an age for completion of compulsory education higher than 16, the highest age is applicable. Any work that is likely to jeopardize children’s physical, mental or moral health, safety or morals should not be undertaken by anyone under the age of 18.
  • Prohibition of forced/compulsory labor: Any use of forced or compulsory labor as defined by ILO Convention No.29; slavery; servitude; or human trafficking; as well as coercion to perform work; wage withholding; compulsory overtime; withholding identity papers or work permits or requiring workers to deposit a bond or the use of any other constraint, is strictly prohibited. All workers are entitled to accept or leave their employment freely.
  • Prohibition of harassment and abuse: We treat our workers, contractors and the local communities in which we operate with respect and dignity. We do not tolerate or engage in any form of corporal punishment, physical, sexual, verbal or psychological harassment, torture, cruel, inhuman and degrading treatment, or any other kind of abuse.
  • Prohibition of discrimination: We treat all workers equally and fairly. We do not engage in any kind of discrimination – in particular with regards to wages, hiring, access to training, promotion, maternity protection and dismissal – based on sex, race or ethnic origin, religion, age, disability, sexual orientation, political affiliation, union membership, nationality, gender identity, migrant status or social background.
  • Freedom of association: We respect and recognize the right of workers to negotiate collectively, and to create or join labor organizations of their choice without any sanction, discrimination or harassment.

B. LABOR STANDARDS AND SOCIAL RESPONSIBILITIES

ZENITH exhibits exemplary social responsibility in conduct of its businesses: Prohibition of illegal, clandestine and undeclared employment: We comply with all applicable regulations to prevent illegal, clandestine and undeclared employment.

  • Wages and benefits: We at minimum pay wages on a regular basis and no less than monthly, compensate workers for overtime hours at the legal rate and meet all legal requirements relating to worker benefits. If there is no legal minimum wage or rate for overtime pay in the country concerned we ensure that the wages are at least equal to the average minimum in the relevant industrial sector and that overtime pay is at least the same as the usual hourly compensation. Wage deductions shall not be used as a disciplinary measure. We guarantee that all workers receive benefits stipulated in any applicable collective bargaining agreements, company agreements and other applicable negotiated individual or collective agreements.
  • Working hours: We comply with all local laws and regulations applicable with respect to working hours, which shall not in any case exceed the maximum set by internationally recognized standards such as the International Labour Organization. We do not impose excessive overtime hours. The total number of hours worked per week including overtime may not exceed legal limits. Workers are entitled to the minimum number of days off established by applicable laws and at minimum must have at least one day off in every seven-day period.
  • Ensuring health and safety: We provide our workers with a safe and healthy workplace environment in order to avoid accidents or bodily injuries that may be caused by, related to, or result from their work, including during the operation of equipment or during work-related travel. We set up procedures and trainings to detect, avoid and mitigate as much as possible any hazards that constitute a risk to the health, hygiene and safety of staff. They are required to comply with all applicable local and international regulations and laws in this regard. These same principles are applicable to housing provided by suppliers and business partners.

ZENITH performs audits of stakeholders to better identify, assess and anticipate risks and opportunities for improvement and to ensure in-depth knowledge of its partners. These procedures allow ZENITH to verify that the performance of its partners is aligned with its requirements and respects best practices, in particular in terms of ethics, social and environmental issues and respect for human rights. Through these controls, ZENITH can also help its partners implement and apply best practices to resolve minor non-conformities. These measures and compliance with them, are stipulated in agreements between ZENITH and its partners.

3. ALERT LINE

Internal alert system:

In case you want to report any internal violation of the present Responsible business practices Policy or of any and all Ethic & Compliance violation, you can use the internal alert system set by the Group through the following link:

https://bkms-system.net/LVMH

Your manager, the Ethic & Compliance correspondent, the Internal Controller or the HR Department can also be contacted if needed in that case.

External alert system:

ZENITH is committed to adopting an open and transparent approach in managing stakeholder’s expectations. Therefore, any concerns regarding impacts that may arise from ZENITH’s direct and indirect behaviours in relation with Human Rights or with any and all Ethic & Compliance obligations can be raised either:

  • Anonymously – by submitting a description of the incident and supporting evidence;
  • Non-anonymously – by submitting name, contact details and description of the incident and supporting evidence.

Reports can be submitted as follows:

https://bkms-system.net/LVMH

In handling such reports, ZENITH will act to safeguard the reporting parties against any form of retaliation also guaranteeing the identity of the reporting parties, unless otherwise required under the law. ZENITH and the Group will keep record of grievances for at least 5 years. Personal data will be handled in accordance with the principles of current applicable data protection legislation by duly authorised personnel; data will not be disseminated and will be kept by ZENITH with the appropriate safeguard measures.

Relevant internal departments may be involved in the investigation process depending on the nature of the grievance. ZENITH reserves the right not to investigate grievances not in scope of Ethic & Compliance or without sufficient evidence.

Grievance investigation process will be managed in a timely and efficient manner and non-anonymous grievance will be informed about the outcomes of the investigation process.

Julien Tornare

CEO