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On 29 October 2015, the United Kingdom Modern Slavery Act 2015 came into force as a means to prevent modern slavery from occurring in businesses’ supply chains and organisations. This law requires certain businesses to produce a statement every year setting out the steps they have taken to ensure there is no modern slavery in their own business and their supply chains.
Swarovski International Limited (“Atelier Swarovski”) is opposed to slavery and human trafficking. Atelier Swarovski conducts its business lawfully and ethically and supports the right of all individuals to be free from slavery and any kind of forced labour in the workplace.
This statement discloses our approach to preventing modern slavery in the financial year which ended in 31 December 2018. Our next statement will be published within six months of our next financial year-end.
Since 2016 Atelier Swarovski has also been a member of the Responsible Jewellery Council (“RJC”), an organisation established by the jewelry industry to advance responsible social and environmental practices. As a member, we align our business operations with the RJC Code of Practices and pledge to positively impact and influence our industry.
Sustainability within Atelier Swarovski is supported at the highest level – by our Executive Board, all of whom are descendants of our founder Daniel Swarovski. The VP of Corporate Sustainability and Social Responsibility manages our global Sustainability team, which is tasked with putting our Sustainability strategy into practice. The team collaborates with colleagues across the business, helping them to integrate sustainability into their activities by providing expertise on relevant issues and delivering projects to complement their aims and implement corrective actions.
Our Integrity Charter defines how Atelier Swarovski shall interact with its employees, its suppliers and their workers. This includes respecting the right of employees to freedom of association and collective bargaining.
Atelier Swarovski has also adopted a Supplier Code of Conduct aligned with the UN Global Compact’s Principles for human rights, labour and the environment, outlining what is expected of our suppliers and contractors. Atelier Swarovski expects suppliers to fully obey all national laws and regulations applicable in the country and other governmental authorities of any country in which they do business, and to treat the workforce fairly and with respect. The document also requires assurance that the suppliers’ employees, freelancers and sub-suppliers all follow the Supplier Code of Conduct.
The Supplier Code of Conduct explicitly states that:
Forced labour, including bonded or involuntary prison labour, must not occur. This includes withholding payment or benefits, or retaining identity documents or other personal effects of value. Work should be voluntary on the basis of a recognised employment relationship established through national law. All workers shall be provided with a written, understandable and legally binding labour contract.
To ensure suppliers respect and enforce our company standards, we include a clause in the commercial agreement governing our contractual relationship with suppliers, which stipulates that our suppliers must abide by our Supplier Code of Conduct and with all applicable laws and regulations, including national and international laws prohibiting any kind of forced and bonded labour (such as slavery and human trafficking).
In 2014, we set up the Responsible Sourcing Initiative (“RSI”), which exists to ensure suppliers respect workers’ rights and set the appropriate socio-environmental conditions at their production plants. It is a systematic, risk-based approach to assessing suppliers’ performance against our Supplier Code of Conduct.
We then monitor the selected suppliers’ approach to improving labor conditions by means of a third party audit (such as the RJC, Sedex Members Ethical Trade Audit (“SMETA”) and Social Accountability International’s SA8000 standards), or our own internal labour assessment (based on the SMETA standard), conducted by our Corporate Sustainability team. The audits may be announced or unannounced and are conducted in accordance with the respective standard’s re-audit cycle. We conduct follow-up audits in accordance with the result between 6 to 18 months after of the initial audit.
Atelier Swarovski reserves the right to terminate the business relationship if violations of the law or basic international principles related to labour standards or ethical business practice become apparent. Where concerns related to the Supplier Code of Conduct or applicable standard are identified, Atelier Swarovski will hold those suppliers accountable through dialogue and follow-up audits.
Atelier Swarovski is committed to continuously work to expand and improve its RSI with the goal of bringing all of its suppliers into the scope of RSI audits.
Creating fair partnerships also means engaging our employees, our suppliers and their operators, the communities around our production sites and NGOs.
Atelier Swarovski has created internal training material to help introduce the RSI to the relevant procurement employees. The Corporate Sustainability team provides advisory services to its suppliers in order to strengthen our relationships and build more sustainable capacities within the factories of our suppliers. This means that the degree of collaboration between Atelier Swarovski and suppliers is high and the risks of modern slavery can be proactively managed.
We will further enhance our responsible supply chain practices and our approach to preventing modern slavery within Atelier Swarovski.
This Statement is approved and signed by Nadja Swarovski, Member of the Executive Board.