SUPPLIER CODE OF CONDUCT
Sophie Bille Brahe ApS is committed to running a responsible & sustainable business. Ensuring that our products are produced under responsible conditions, stands at the core of this commitment, and in fulfilment of our ambition. We expect all our partners, suppliers, subcontractors, agents, and other business partners – to operate responsibly and act with integrity and fairness in all aspects of their business.
Sophie Bille Brahe is committed to avoiding and addressing adverse impacts on the basic principles for social, environmental, and economic development that we cause, contribute, or are linked to via our business relationships.
Therefore, we seek to ensure that our own company as well as our suppliers operate in accordance with the requirements of the enclosed Code of Conduct and thereby work towards alignment with the internationally recognised principles for sustainable development.
We recognise that establishing the required processes outlined in this Code of Conduct requires both time and resources, especially in the initial phases. We are implementing and maintaining similar processes in our operations. This Code of Conduct should therefore be understood as a tool for cooperation and dialogue about improving systems to manage adverse impacts on human rights, including labour rights, the environment, and anti-corruption.
We focus on our suppliers' ability and willingness to demonstrate continuous improvements in meeting the requirements of this Code of Conduct. We feel confident that cooperation and dialogue can result in a more efficient partnership, from which both parties will benefit.
All suppliers are expected to comply with national legislation, regulations and applicable practices and industry standards relevant to their business.
Please refer to the enclosed Code of Conduct for more information about the specific requirements. If you have any questions regarding this letter, our Code of Conduct, or our responsible supply chain management programme in general, please do not hesitate to contact our offices.
Kind regards,
Sophie Bille Brahe ApS
Anne Sofie Møller, CEO
Introduction
The purpose of this Code of Conduct (Code) is to ensure that our suppliers demonstrate responsible business conduct. The Code is aligned with internationally recognised frameworks, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the UN Guiding Principles on Business and Human Rights, and jewellery industry standards such as the Kimberley Process Certification Scheme. We expect our suppliers to manage adverse impacts on:
Human rights, incl. labour rights;
The environment, including climate and biodiversity;
Anti-corruption
Diversity, Equity & Inclusion
Community Development;
Product disclosure and material traceability; and
Security of workers, products, and information.
The scope of minimum requirements is based on OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The required management of potential and actual adverse impacts on the scope is aligned with the UN Guiding Principles on Business and Human Rights (the UNGPs). Compliance with these frameworks requires suppliers to:
(a) establish management systems to identify risks;
(b) design and implement strategies to respond to identified risks;
(c) carry out independent third-party audits of supply chain due diligence;
(d) report annually on supply chain due diligence efforts; and
(e) maintain documentation, demonstrating compliance. Managing adverse impacts is distinct from legal compliance. As a precondition, suppliers are expected to comply with national law.
We are committed to ensure responsible and ethical production of our products. An important part of this work includes audits conducted by a third-party company and engaging with our suppliers on the audit results to continually improve. All first-tier suppliers must on a yearly basis present and provide us with an updated audit report performed by a validated third-party auditor in accordance with any one of the following recognised standards: Sedex Smeta (Sedex Members Ethical Trade Audit), Amfori BSCI (Business Social Compliance Initiative), or SA8000 (SAI Social Accountability International). Suppliers may select the standard that best aligns with their existing compliance programmes, and a valid audit under any one of these standards shall satisfy this requirement.
Process Requirements
We expect all suppliers to develop and implement the following:
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Adopt Policy Statement:
Which must:
Be approved by the most senior level of the supplier.
Be informed by qualified experts (such as legal counsel, certified sustainability professionals, or recognised non-governmental organisations with relevant subject matter expertise) on human rights including labour rights, environmental, and anti-corruption principles.
Stipulate the supplier's expectations of employees and business relations on human rights, including labour rights, environment, and anti-corruption.
Be publicly available (for example, published on the supplier's website or made available upon reasonable request) and communicate both internally to employees and externally to relevant stakeholders through appropriate channels.
Be reflected in other operational policies and procedures necessary to embed the policy statement throughout the supplier's operations.
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Carry through Due Diligence:
That – as a minimum – includes the following elements:
Identification: At least annually, and whenever there is a material change in business operations or supply chain, the supplier must conduct a formal risk assessment to identify potential and actual adverse impacts on human rights including labour rights, environmental, and anti-corruption principles. Such assessments shall be documented and shall consider factors including the supplier's geographic locations, industry sector, and specific business activities.
Prevention and mitigation: When potential or actual adverse impacts are identified, suppliers must develop and implement a documented corrective action plan within thirty (30) calendar days of identification, specifying the actions to be taken, the parties responsible, and target completion dates.
Accounting: Actions to prevent or mitigate identified adverse impacts must be tracked through documented progress reviews conducted at least quarterly, with measurable indicators of effectiveness. Suppliers are expected to communicate their findings, actions, and tracking status to relevant stakeholders including Sophie Bille Brahe on an annual basis, or more frequently upon request.
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Provide for access to remedy:
Where the supplier identifies that it causes or contributes to actual adverse impacts on human rights including labour rights, environmental, and anti-corruption principles, the supplier must enable access to remedy for those affected and/or inform relevant authorities. The supplier shall notify Sophie Bille Brahe in writing within five (5) business days of identifying any such adverse impact and shall propose a remediation plan within fifteen (15) calendar days of identification.
The supplier must provide access to remedy through legitimate grievance mechanisms. For the purposes of this Code, "legitimate grievance mechanisms" means processes that are:
(a) accessible to all affected stakeholders without barriers such as language, cost, or fear of retaliation;
(b) predictable, with clear timeframes for each stage (acknowledgement of complaint within five (5) business days, investigation within thirty (30) calendar days, and resolution within sixty (60) calendar days unless extended by mutual agreement);
(c) equitable, ensuring affected parties have reasonable access to information and advice necessary to engage fairly;
(d) transparent, providing clear communication to complainants about the status and outcome of their grievance; and
(e) rights-compatible, ensuring outcomes are consistent with internationally recognised human rights standards.
If the supplier is merely linked to actual adverse impacts, the supplier must use its leverage to make the causing or contributing entity address the impacts.
Sustainability Requirements
Through the establishment of the processes outlined above, the principles that we expect suppliers to manage adverse impacts upon are described in the eight following subsections:
1. Human rights, including labour rights
Suppliers should – as a minimum - manage their adverse impacts on the human rights stated in the International Bill of Human Rights that includes the core labour rights from the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work. Specifically, suppliers must:
(a) prohibit the use of forced, bonded, or compulsory labour;
(b) prohibit child labour and ensure workers are at least 15 years old or the local legal minimum age, whichever is higher;
(c) pay at least the applicable legal minimum wage and provide legally mandated benefits;
(d) not exceed maximum working hours permitted by local law and provide at least one rest day per seven-day period;
(e) provide a safe and healthy workplace, including adequate ventilation, lighting, and sanitation;
(f) respect workers' rights to freedom of association and collective bargaining where permitted by law; and
(g) prohibit discrimination in hiring, compensation, or treatment based on race, gender, religion, age, disability, or other protected characteristics.
2. Environmental principles
Suppliers should manage all significant potential and actual impacts on the external environment in relation to the areas of impacts addressed by the principles in the Rio Declaration on Environment and Development. Specifically, suppliers must:
(a) obtain and maintain all required environmental permits and licences;
(b) identify and assess potential impacts on biodiversity arising from their operations or sourcing practices;
(c) implement waste reduction, recycling, and proper disposal procedures for all waste streams;
(d) monitor and work to reduce greenhouse gas emissions and energy consumption;
(e) properly handle, store, label, and dispose of hazardous materials in accordance with applicable regulations;
(f) implement water conservation measures and ensure wastewater is treated before discharge;
(g) take measures to prevent pollution of air, water, and soil; and
(h) where applicable, source materials responsibly and avoid contributing to deforestation or biodiversity loss.
3. Anti-corruption principles
Suppliers should establish adequate processes to counter corrupt practices. Such processes should address the scope outlined by the United Nations Convention against Corruption. Specifically, suppliers must:
(a) prohibit all forms of bribery, including facilitation payments, to public officials or private parties;
(b) maintain accurate books, records, and accounts that fairly reflect all transactions;
(c) implement clear policies on gifts, hospitality, and entertainment that prohibit anything intended to improperly influence business decisions;
(d) establish procedures to identify and manage conflicts of interest;
(e) conduct appropriate due diligence on third parties acting on the supplier's behalf;
(f) provide a confidential reporting channel for employees to report suspected corruption without fear of retaliation;
(g) implement Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures in accordance with applicable laws; and (h) maintain financial accounts of all business transactions in accordance with applicable law and national or international accounting standards.
4. Diversity, Equity & Inclusion
Suppliers shall promote diversity, equity, and inclusion throughout their operations and business relationships. Suppliers must ensure that all individuals are treated with dignity and respect and that no person is subjected to discrimination, harassment, or exclusion. Specifically, suppliers must:
(a) establish and maintain policies and procedures that promote equal opportunities for all workers, including in recruitment, training, promotion, and compensation;
(b) prohibit discrimination based on gender, age, ethnicity, religion, disability, sexual orientation, gender identity, political opinion, or any other protected characteristic;
(c) take reasonable steps to identify and remove barriers that may hinder equal access to employment opportunities or fair treatment in the workplace;
(d) foster an inclusive work environment in which workers feel safe to raise concerns without fear of retaliation;
(e) provide appropriate training to managers and employees to ensure understanding of diversity, equity, and inclusion principles and their integration into daily operations; and
(f) work towards continuous improvement in promoting diversity, equity, and inclusion, including through engagement with workers and relevant stakeholders.
5. Community Development
Suppliers should make every effort to proactively engage with and support development in the local communities where their operations and supply chains are located. Specifically, suppliers are encouraged to:
(a) prioritise local employment and procurement where practicable;
(b) support initiatives that benefit local communities; and
(c) consider the social and economic impact of their operations on surrounding communities.
6. Product Disclosure
All disclosures on the nature and quality of materials and products sold to Sophie Bille Brahe must be accurately communicated. This includes but is not limited to: location of origin; weight; colour and clarity of gemstones; any treatments applied to gemstones; the standard of fineness of precious metals; and other matters as required by applicable laws and in accordance with internationally accepted jewellery industry product disclosure standards. Suppliers of diamonds shall take appropriate measures to mitigate the risk of undisclosed synthetic diamonds entering Sophie Bille Brahe's supply chain.
Suppliers shall ensure that all claims, statements, and representations made about materials, products, or responsible business practices are accurate, verifiable, and not misleading. Specifically, suppliers must:
(a) maintain documentation to substantiate any claims related to product characteristics, sourcing practices, environmental performance, or social responsibility;
(b) ensure that marketing materials, invoices, and communications do not contain false, exaggerated, or unsubstantiated statements;
(c) implement internal controls to review and approve claims prior to publication or disclosure; and
(d) comply with all applicable laws and internationally recognised standards relating to product claims and responsible marketing.
7. Jewellery Industry Requirements
In addition to the general requirements of this Code, suppliers of jewellery materials shall comply with the following industry-specific requirements:
Kimberley Process and World Diamond Council: Sophie Bille Brahe supports the Kimberley Process Certification Scheme. All suppliers involved in the sale or trade of diamonds, whether rough, polished, or set in jewellery, shall adhere to the World Diamond Council System of Warranties and, where relevant, the Kimberley Process Certification Scheme, and have systems to ensure that all relevant invoices contain the required warranty statement.
Responsible Jewellery Council (RJC): Suppliers engaged in the sourcing, processing, or manufacturing of gold, diamonds, gemstones, or jewellery components must be members of the Responsible Jewellery Council (RJC) and maintain valid certification under the RJC Code of Practices. Suppliers shall ensure that all relevant facilities are included within the scope of their certification and shall provide documentation of their membership and certification status upon request. Suppliers must promptly notify Sophie Bille Brahe in writing of any suspension, withdrawal, or lapse of RJC membership or certification.
Material Sourcing Standards: Suppliers of precious metals shall provide accurate reporting on the annual percentage of mined, pre-consumer, and post-consumer recycled precious metals from their smelting and refining suppliers. Suppliers are encouraged, where applicable, to complete Reasonable Country of Origin Inquiries for materials entering the recycled market.
8. Security
Suppliers shall take measures to ensure the safety and security of their workers, contractors, and visitors. This includes:
(a) assessing security risks and implementing measures to protect against product theft and loss during manufacturing and transport of goods;
(b) protecting intellectual property and confidential information;
(c) implementing appropriate measures to protect employee and customer data; and
(d) ensuring that human rights are protected in all aspects of security operations, including interactions among security personnel, workers, and visitors.
Implementation and Collaboration
1. Scope of Application
This Code applies to our first-tier suppliers. Suppliers are encouraged to use commercially reasonable efforts to promote responsible practices among their own suppliers, where practicable and within their sphere of influence. To support this objective, suppliers should consider the following:
Where appropriate, communicate the principles outlined in this Code to their key suppliers and encourage adoption of similar standards.
If adverse impacts are discovered, use reasonable efforts to encourage their suppliers to address such impacts; and
Take reasonable steps, commensurate with their degree of influence and the nature of the business relationship, to promote alignment with the principles of this Code among their suppliers.
2. Supply Chain Transparency
In addition to promoting responsible practices among their suppliers, first-tier suppliers shall provide Sophie Bille Brahe with transparency regarding their supply chain. Specifically, suppliers must:
Upon request, and no less frequently than annually, disclose the names, locations, and nature of business of key sub-suppliers directly involved in the production of goods or services supplied to Sophie Bille Brahe;
Maintain a current supply chain map identifying, at minimum, first-tier suppliers and, where reasonably known, second-tier suppliers, and make such map available to Sophie Bille Brahe upon reasonable request;
Promptly notify Sophie Bille Brahe, in writing and within fifteen (15) calendar days of any material changes to their supply chain that may affect compliance with this Code, including changes in manufacturing locations or the addition of new sub-suppliers for key production processes;
Cooperate with reasonable requests for information regarding the origin and traceability of materials and components, particularly for high-risk materials such as precious metals and gemstones; and
Where applicable, provide documentation or certifications demonstrating responsible sourcing of materials (e.g., chain of custody documentation, conflict-free certifications, or equivalent assurances).
3. Records & Documentation
Suppliers must maintain appropriate records to demonstrate compliance with the requirements of this Code. All records shall be retained for a minimum period of seven (7) years from the date of creation, or longer if required by applicable law. Records shall be maintained in a format that is legible, organised, and readily retrievable for inspection upon request. Suppliers shall implement appropriate technical and organisational measures to protect the confidentiality, integrity, and security of all documentation, particularly where it contains personal data or commercially sensitive information. Appropriate records include, but are not limited to:
Policy Commitment(s), including version history and evidence of board or senior management approval;
Documentation of due diligence processes, including impact assessments, risk registers, and records from the tracking process on specific corrective actions taken;
Information on grievance mechanisms, including records of complaints received and actions taken to address them (subject to appropriate anonymisation where necessary to protect complainants); and
Records relating to the handling, storage, and sharing of confidential or personal data in accordance with applicable data protection laws.
4. Continuous Collaboration & Monitoring
The aim of this Code is to form the basis for collaboration between us and our suppliers for continuous improvements in managing adverse impacts on principles for sustainable development.
An open and transparent dialogue on the standards of this Code of Conduct is essential for the relationship with all our suppliers.
We expect all suppliers at any time to be able to declare in writing their stage of implementation in relation to the requirements contained in this Code. Suppliers shall cooperate in answering further questions, self-assessments, and if deemed necessary cooperate with us in improving management systems and addressing specific impacts. If necessary, suppliers must accommodate visits from us to verify compliance, subject to the following conditions:
(a) Sophie Bille Brahe shall provide at least ten (10) business days' prior written notice of any proposed visit, except where there are reasonable grounds to believe an imminent risk of serious harm exists;
(b) visits shall be conducted during normal business hours and shall be limited to no more than two (2) visits per calendar year, unless material non-compliance has been identified;
(c) the scope of any visit shall be limited to verifying compliance with this Code;
(d) all representatives conducting visits, including independent third parties, shall be bound by confidentiality obligations; and
(e) visits shall be conducted in a manner that minimises disruption to the supplier's operations.
We trust that our suppliers will embrace the requirements of this Code, and we believe that achieving good social and environmental standards is a process, and we are committed to working together with our suppliers in their efforts.
In addition, all suppliers are required to complete an annual supplier survey, typically distributed in January each year. This survey is designed to help us understand how environmental, social, and ethical topics are managed across our supply chain and to identify potential gaps or risks. Completion of the survey forms part of our commitment as a participant of the United Nations Global Compact (UNGC).
The survey does not constitute an audit. Where gaps or risks are identified, our objective is to engage in constructive dialogue and collaborate with suppliers over time to strengthen management practices and contribute to positive social and environmental impact.
In the event of non-compliance with this Code, the supplier shall be notified in writing and must submit a corrective action plan within fourteen (14) calendar days and complete self-correction within sixty (60) calendar days of notification, unless an extended timeline is mutually agreed upon in writing. Sophie Bille Brahe may terminate the business relationship immediately upon written notice if:
(a) the supplier fails to submit a corrective action plan within the specified timeframe;
(b) the supplier fails to complete self-correction within the agreed period;
(c) the supplier demonstrates an unwillingness to improve systems or address identified adverse impacts as evidenced by repeated non-compliance or refusal to engage in good faith; or
(d) the non-compliance involves serious violations including, but not limited to, use of forced or child labour, bribery or corruption, or actions posing imminent risk to human health or safety. Prior to termination under subsections (a), (b) or (c), Sophie Bille Brahe shall provide the supplier with written notice of the intended termination and a reasonable opportunity (not less than seven (7) calendar days) to respond.
If you have any questions about the Code of Conduct, please feel free to contact Sophie Bille Brahe at esg@sophiebillebrahe.com.
