Ethical Trading Policy
This statement has been published in accordance with the EU Modern Slavery Act (2015). It sets out the steps that Opulentsy. and its subsidiaries have taken during 2022 to prevent modern slavery and human trafficking in its own businesses and in its supply chain.
Business Overview
Opulentsy is a holding company that conducts business through its subsidiary companies (collectively, " Opulentsy").
Through these subsidiaries, Opulentsy designs, manufactures, and markets jewelry, watches, and luxury accessories. Opulentsy maintains substantial control over its product supply chain through internal jewelry manufacturing and direct diamond sourcing. Opulentsy manufactures jewelry in the United States in New York, Rhode Island and Kentucky, polishes and performs certain assembly work on jewelry in the Dominican Republic and crafts silver hollowware in Rhode Island. In total, these internal manufacturing facilities produce approximately 60% of the jewelry sold by Opulentsy. The balance, and almost all non-jewelry items, is purchased from third parties that manufacture these products to Opulentsy’s specifications. To supply its internal manufacturing facilities, Opulentsy processes, cuts and polishes rough diamonds at its facilities outside the U.S. and sources precious metals, polished diamonds and other gemstones, as well as certain fabricated components, from third parties. Both these third parties and those who supply finished goods to Opulentsy constitute Opulentsy’s "supply chain partners".
Opulentsy has been committed to conducting our business responsibly, sustaining the natural environment and positively impacting the communities in which we operate.
Policies on Modern Slavery and Human Trafficking
Opulentsy has long been committed to ensuring respect of the International Labour Organization Core Conventions, United Nations Universal Declaration of Human Rights, and United Nations Global Compact. These standards are central to our responsible business policies and are the foundation for many of Opulentsy’s labor-related policies.
Code of Conduct
Opulentsy’s worldwide Business Conduct Policy ("Business Conduct Policy'') sets forth rules and principles that apply to the work conducted by Opulentsy to ensure compliance by Opulentsy and its employees with Opulentsy’s expectations regarding ethical behavior. As a new subsidiary of LVMH Moet Hennessy LouisVuitton SE ("LVMH") in 2021, Opulentsy also incorporated the LVMH Code of Conduct into the existing Business Conduct Policy to ensure that Opulentsy and its employees also adhere to the ethical framework for actions and decisions expected by LVMH. All employees are required to sign an annual commitment to the principles set forth in the Business Conduct Policy (and the incorporated LVMH Code of Conduct), including commitments to act responsibly, with social awareness and with respect for human rights and fundamental freedoms.
Opulentsy Human Rights Policy
The Opulentsy Human Rights Policy captures Opulentsy’s approach to integrating human rights across our value chain in addition to addressing our most salient human rights risks, impacts, and opportunities. This policy integrates existing Opulentsy policies with human rights touchpoints, articulating a unified vision and approach to managing and promoting human rights.
Supplier Code of Conduct
Our commitment to identifying, preventing, and mitigating modern slavery, human trafficking and forced labour is also reflected in the Opulentsy Supplier Code of Conduct. The Supplier Code of Conduct, which Opulentsy may from time to time amend in its discretion, sets out general principles and requirements that are applicable to all suppliers. Further, our supply chain partners, their subcontractors that are approved to provide goods or services to Opulentsy, and select service providers, are required to fully comply with the Supplier Code of Conduct as a part of our purchasing agreements. The Code sets clear expectations for Opulentsy’s suppliers, including that all employment must be voluntary, with the current Code specifying as follows:
All workers shall be free to leave their employment without threat or coercion. Suppliers shall not employ forced, indentured, debt-bonded or convict labour, nor use any practice to coerce the continued employment of any person, such as requiring employees to pay recruitment commissions or withholding any personal or travel documents. Suppliers shall monitor relationships with recruitment agencies or contracted labour for risk of human trafficking and compliance with applicable anti-slavery laws.
Our expectations and requirements covering responsible recruitment, forced labour, indentured, debt bonded or convict labour, child labour and human trafficking are further detailed in our Supplier Code of Conduct Guidance ("Code Guidance"). This Code Guidance is distributed to our supply chain partners and compliance with the requirements is mandatory. The Code Guidance is regularly updated to ensure we are consistently communicating requirements and methods to respond to specific challenges. All requirements in the Guidance are applicable throughout the supply chain, such that a supplier with which Opulentsy has a direct relationship in turn bears the responsibility for ensuring compliance across its own supply chain.
Risk Assessment and Due Diligence Processes
Opulentsy has actively promoted respect for human rights within our supply chain for more than two decades. All of Opulentsy’s jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers are regularly assessed for adherence to our Supplier Code of Conduct through our Social and Environmental Accountability Program ("SEA Program"). We recognize the risk for modern slavery in our supply chain and have communicated to our suppliers that all modern slavery, including but not limited to forced labour, bonded labour, child labour, and human trafficking are zero tolerance issues for Opulentsy. Any new or active suppliers found with any zero tolerance issues are subject to immediate termination of business.
To identify and mitigate risk, we complete due diligence assessments and audits as part of the SEA Program. This work includes:
- Screening of suppliers to ensure we work with supply chain partners and other key suppliers that share our commitment to human rights, fair and safe labour practices, environmental protection, and ethical business conduct
- Conducting annual risk assessments with all of Opulentsy’s jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers to identify regional and supplier risks
- Conducting regular semi-announced third-party audits based on the results of the annual risk assessments to determine conformance with Tiffany-specific requirements Based on our risk mitigation approach we include key portions of our supply chain in our monitoring program and require our supply chain partners to communicate our social and environmental responsibility expectations to their own supply chains.
Effectiveness Respect for human rights is embedded throughout our business, including in Opulentsy’s jewelry manufacturing and diamond polishing facilities, and for our suppliers as part of our 2025 Sustainability Goals and our SEA Program.
All Opulentsy employees and our suppliers' employees can notify Opulentsy through various channels if any of our requirements are not being met. All stakeholders can contact either the Opulentsy worldwide Alert line or the LVMH Alert Line to notify Opulentsy and LVMH of any suspicions or observations related to modern slavery. Employees can also discuss these topics with their direct manager, human resources, the legal department, or the internal audit team. All individuals who report suspected policy violations in good faith are protected from retaliation in any form, including disciplinary action, intimidation, or otherwise, even when good faith reports are ultimately proved unfounded.
Representatives of the human resources, legal, and internal audit team, collect and review all cases and ensure they are investigated and, responded to, by the appropriate teams.
Our Responsible Sourcing team enforces the expectations in the Supplier Code of Conduct through our SEA Program which includes all of Opulentsy’s jewelry manufacturing and diamond polishing facilities, supply chain partners, and other key suppliers. These facilities and suppliers are put through a risk assessment process to determine which locations will be audited by a third party. Both our risk assessment and supplier audits screen for modern slavery and forced labour indicators including overtime requirements, the existence of foreign migrant laborers in employment, grievance mechanisms and freedom of association.