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 recognized principles for sustainable development.
We recognize 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.
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 program in general, please do not hesitate to contact our offices.
Kind regards,
Sophie Bille Brahe
Anne Sofie Møller, CEO
Code of Conduct
The purpose of this Code of Conduct (Code) is to ensure that our suppliers demonstrate responsible business conduct. The Code follows globally agreed minimum standards and asks our suppliers to manage adverse impacts on:
human rights, including labour rights,
the environment,
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). Managing adverse impacts is distinct from legal compliance. As a precondition, suppliers are expected to comply with national law.
All first tier suppliers must have a yearly third part audit made, to ensure that human rights, labour rights, environmental requirements and corruption are complied. The audit report can be made by following partners: SGS, SMETA, BSCI and Responsibe Jewelry Council.   
Process Requirements
Sophie Bille Brahe expects all suppliers to develop and implement the following:
1. Adopt Policy Statement:
Which must:
  • Be approved by the most senior level of the supplier.
  • Be informed by experts 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 and communicated both internally and externally.
  • Be reflected in other operational policies and procedures necessary to embed the policy statement throughout the supplier’s operations.
2. Carry through Due Diligence:
That – as a minimum – includes the following elements:
  • Identification: On a regular basis, the supplier must identify potential and actual adverse impacts on human rights including labour rights, environmental, and anti-corruption principles.
  • Prevention and mitigation: When potential or actual adverse impacts are identified, suppliers must take action to prevent or mitigate such adverse impacts.
  • Accounting: Actions to prevent or mitigate identified adverse impacts, must be closely tracked to ensure effectiveness. Suppliers are expected to communicate their findings, actions, and tracking to relevant stakeholders including Sophie Bille Brahe.
3. 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 must provide access to remedy through legitimate processes (grievance mechanisms) to victims of actual adverse human rights impacts that the supplier causes or contributes to.
  • 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 Sophie Bille Brahe expects suppliers to manage adverse impacts upon are described in the four 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.
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.
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.
Implementation and Collaboration
1. Scope of Application
This Code applies to Sophie Bille Brahe´s first tier suppliers. Suppliers shall ensure that its first tier suppliers have adequate processes in place to manage their adverse impacts on human rights including labour rights, environmental, and anti-corruption principles. As part of this obligation, suppliers must:
Make their first tier suppliers aware of the scope and processes outlined in the Code and pose similar requirements to such suppliers as featured in this Code;
If adverse impacts are discovered, use their leverage with their suppliers in order to make such suppliers adequately address such impacts; and
Undertake reasonable efforts to ensure that their suppliers operate in accordance with this Code.
2. Records and Documentation
Suppliers must maintain appropriate records to demonstrate compliance with the requirements of this Code. Appropriate records include, but are not limited to:
Policy Commitment(s);
Documentation of due diligence processes, including impact assessments and records from the tracking process on specific actions;
Information on grievance mechanisms.
3. Continuous Collaboration
The aim of this Code is to form the basis for collaboration between Sophie Bille Brahe and suppliers for continuous improvements in managing adverse impacts on principles for sustainable development.
Sophie Bille Brahe expects 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 Sophie Bille Brahe in improving management systems and addressing specific impacts. If necessary, suppliers must accommodate visits from Sophie Bille Brahe to assert compliance, including providing for physical access to any representative from Sophie Bille Brahe or independent third parties.
By non-compliance, suppliers must self-correct within a fixed period. Failure to self-correct or if suppliers fail to demonstrate willingness to improve systems or address identified adverse impacts, Sophie Bille Brahe reserves the right to end the business relationship immediately.
Do you have any questions about the Code of Conduct? Please feel free to contact Sophie Bille Brahe at