This document presents Orest Group corporate responsibility policy.
This policy is shared with all our Employees and is available to our clients, shareholders, partners and all of our stakeholders.

Scope
Our policy applies to :

♦ every Employee of Orest Group and each entity of the firm of any size, activity or localization.

♦ the whole value stream, from suppliers to partners, participating in the company’s activity.

In order to achieve its objective of maximal conformity with all the principles of this policy, Orest Group commits to implement a continual improvement approach, internally and with its partners, on business ethics, and social and environmental performance.


OUR RESPONSIBILITY

For more than 40 years, Orest Group, a marriage jewellery designer, has brought its competences of “made in France” manufacturer for its own collections as well as those of the most important jewellers. The company intends to be both a business and a craft industry. It is an innovative society gathering 300 employees. Along the years, the company has been able to combine contemporary creation and traditional manufacturing. Orest has acquired state-of-the-art high tech equipment to supplement the professionalism of their craftsmen.

Orest is aware of the economics, ethics and environmental stakes related to its jewellery activity. Therefore, the company is strongly committed to ensuring the quality of its products and the respect and welfare of its employees. In order to reconcile these stakes, Orest has engaged a long time ago an integrated management approach for quality, security and environment, combined with an innovative human resources policy, quite demanding for its size.

In order remain at the cutting edge in its sector in terms of corporate responsibility, and apply demanding practices in social and environmental performance and business ethics, Orest joined the Responsible Jewellery Council (RJC, www.responsiblejewellery.com) in 2010.
The principles described in the following policy are broadly based on those of the RJC, and are organised around three main topics :
♦ business ethics
♦ social performance
♦ environmental performance


BUSINESS ETHICS

1. Orest will commit to conducting its businesses in a high ethical standard, and to ensuring integrity, transparency and conformance with Applicable Laws and regulations.

Orest will comply with laws and regulations which are applicable to its activities and to the countries where it operates.

This policy will be communicated within the company and its partners. A continuous improvement approach will be engaged internally as well and with its partners, in order to promote high ethical standards on the supply chain and the whole company value stream.


2. Orest will not engage in bribery and/or corruption, and will not contribute nor tolerate money laundering and/or financing of terrorism.

Orest will prohibit corruption in all business transactions that are carried out by the company or on its behalf, and any act that could constitute an attempt to obtain or retain business for or with, or direct business to, any person; to influence the course of the business or governmental decision-making process.

Orest will comply with local and national laws, and, if need be, international or transnational laws concerning money laundering, financing of terrorism, fraud, and other illegal practices.

Orest will maintain financial accounts of all business transactions in accordance with national and international accounting standards. These accounts will be independently certified and audited by two independent auditors.

The provisions regarding the fight against corruption and money laundering will be described in the company internal control policy. Practices in terms of accepting gifts and/or invitations will be controlled and strictly defined in this same document. Employees will be aware of this policy, their rights and duties, and the legislation evolutions concerning the fight against corruption and money laundering.


3. Orest will adhere to the Kimberly Process Certification System and the World Diamond Council voluntary System of Warranties, implemented in order to stop the trade of blood diamonds.

Orest will continuously ensure its conformity with the Kimberly Process Certification System which is internationally recognised as an efficient mechanism against the trade of Conflict Diamonds, and as a main instrument to prevent conflicts.

Thus, Orest will not knowingly buy or sell conflict diamonds and will not assist others to do so.

Orest will ensure that its diamonds suppliers conform to the Kimberly Process Certification System, and a warranty will be asked to the seller for every invoice addressed to Orest relatively to diamonds buying.
Orest will suspend its business with any supplier who is suspected of being involved in trading Conflict Diamonds, as long as he cannot provide the necessary warranties stating that such a transaction has not taken place, or that it happened without his knowledge and that it has taken measures in order to stop this type of transactions.

Orest will make sure that all Employees that buy or sell diamonds are aware of the Kimberley Process Certification Schemes, government restrictions on the trade of Conflict Diamonds, and their duties to comply with the policy requirements, and their knowledge on this subject will be regularly updated.

Orest will support the systems and procedures elaborated jointly by the international diamond industry, governments and civil society organisations in order to stem the flow of Conflict Diamonds. Orest will promote any similar initiative, including for precious metals and coloured stones. Orest will contribute as much as needed to defining and promoting adequate measures on that subject.


4. Orest will fully and accurately disclose the material characteristics of the products that it sells.

Orest will comply with relevant trading standards and legislations, and national and international regulations applicable to jewellery products.

Orest is careful about the quality and security of its products, as well as a relationship of trust with its clients. Therefore, Orest will properly disclose to its clients and potential clients all relevant information on the physical characteristics, such as mass/weight, cut, colour, clarity or fineness of a gemstone, or the content of precious metals in its alloys, in accordance with the national and international principles.

Orest will not make any untruthful, misleading or deceptive statement, representation or material omission in the promotion or advertising of its products.

Orest will provide appropriate training to its Employees in order for all of them to be able to offer reliable information to clients and potential clients.


5. Orest will maintain fair and balanced relationships with its business partners.

Orest will maintain fair and balanced relationships with its business partners.
In particular, Orest will ensure, to the extent of its capabilities, appropriate conditions for them to achieve service delivery, including an appropriate notice for order planning and benefits paid within a reasonable and agreed timeframe.

Orest will be open and transparent with its business partners on the warranties expected concerning their observance of ethical, social and environmental principles. In particular, Orest will strive to joinly undertake a continual improvement approach regarding these subjects.


SOCIAL PERFORMANCE

6. Orest will respect the Human Rights.

Orest believes in the fundamental human rights and the dignity of the individual, according to the United Nations Universal Declaration of Human Rights. Orest will respect the Declaration of Human Rights on its sites and with business partners.
Orest will implement a continual improvement approach within its supply chain regarding social performance, and strives, as much as possible, to align its purchase policy with its social commitments.


7. Orest will not tolerate the use of Child Labour.

Orest will not tolerate the use of Child Labour, and does not employ any child whatever the country. Orest will only employ younger than 18 and older than 15-year-old children in the defined framework of professional training (particularly to maintain Orest expertise and know-how, for instance in jewellery) and in accordance with the law in force.

We will demand that our business partners, whether they provide products or services, adhere to the rules of the Responsible Jewellery Council regarding children and young people employment.


8. Orest will respect the social rights of workers, and in particular, will not use any forced or bonded labour, nor tolerate corporal punishment, and will not prevent workers from associating freely and bargaining collectively.

Orest will comply with all duties imposed by the French Labour Code, by prevailing industry standards and by fundamental human rights specified by the World Trade Organisation.
Thus :

♦ Orest will not tolerate forced labour nor restrict the freedom of movement of its Employees and their dependants.

♦ Orest will make sure that all works and services carried out on site and/or on his behalf occur under a legitimate working contract. Orest will not retain original copies of Employee personal documentation, such as identity papers, nor require any form of deposit, recruitment fee, or equipment advance from Employees in return for their recruitment.

♦ Orest will apply normal working hours and wages that comply with Applicable Law and prevailing industry standards. Orest will ensure that working hours are compliant with national regulation and that they will not exceed, on a regular basis, a maximum of 48 hours per working week.

♦ Orest will provide all Employees at least one rest day per week and an annual paid leave, in line with Applicable Law and prevailing industry standards. All legal provisions concerning absence, such as maternity or paternity leave, and family-related leave (where the law of the country applies), will be respected.

♦ Orest will not prevent Employees from associating freely and will adhere to Applicable Law and collective bargaining agreements, where such agreements exist. Where laws prohibit these freedoms, we will support Employee collective representation and genuine dialogue between Manager and Employee.

♦ Orest will ensure that all Employees is paid in accordance with prevailing industry standards, and at least based on the applicable legal minimum wage plus associated statutory benefits. We will ensure that the frequency, means of payment and payment documentation (wage slip) comply with Applicable Law. We will not make deductions from wages for disciplinary reasons without following Applicable Law and Regulations.

♦ Orest will not use corporal punishment under any circumstances, and will ensure that Employees are not subjected to harsh or degrading treatment, harassment, abuse, coercion or intimidation in any form. We will clearly communicate the business’ disciplinary process, and related standards on appropriate disciplinary procedures and Employee treatment.


9. Orest will not discriminate on any factor.

Orest will not practice or condone any form of discrimination in the workplace based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, marital status, physical appearance, or age, or any other applicable prohibited basis.

Orest will make reasonable efforts to respect Employee freedom in terms of religious or cultural customs and practices.

On a continual basis, Orest will provide Employees with training to acquire, maintain and develop skills in order to leverage career opportunities.


10. Orest will commit to high standards of health and safety in its operations.

Orest will take all reasonable measures in order to ensure the physical integrity and the security of Employees and product shipments.

Orest will provide safe and healthy working conditions for all Employees in accordance with Applicable Law and other relevant industry standards. The company will take appropriate measures to prevent accidents, injuries and health issues arising from, or linked to, the course of work-related activities and operations at a facility.

Health and safety issues will be regularly monitored and problems will be identified and solved. Orest will take adequate measures to minimize Employees contact with toxic substances, by providing protection equipment and material, adequate and appropriate labelling and storage, and displaying appropriate safety requirements.

Orest will not use any illegal substance according to national or international standards, due to their harmful impact on health and environment.
Orest will provide work stations that are designed as appropriate to the task performed and in compliance with standards in force (adequate lighting, ventilation and air quality; safe noise levels and temperatures).

Orest will make information and training about Health and Safety available to Employees and external providers working on its facilities, concerning the specific risks and hazards associated to their function, the means to protect themselves and appropriate actions to take in the event of an accident. We will provide Employees with a mechanism by which they can raise and discuss Health and Safety issues with management.

In terms of security, Orest will take all reasonable measures to ensure physical integrity and security of Employees operating valuables (components, semi-finished and finished products) on site, or during transportation from or towards a facility.

Orest will ensure that all security personnel respect the human rights and dignity of all people and use the minimum force proportionate to the threat.


ENVIRONMENTAL PERFORMANCE

11. Orest will actively engage in preventing pollution and eliminating hazardous materials.

Orest will promote an integrated environmental management system and facility management in compliance with applicable environmental regulation (in particular, the legislation on Installations Classified for the Protection of the Environment (ICPE)). Thus, we will ensure that facilities comply with Application Law, and environmental standards and regulations regarding our activities, and we will implement appropriate systems to ensure key executives and employees up to date knowledge on these issues.

Orest will ensure that precious metals are treated in compliance with Applicable Environmental standards, including, but not limited to, the European regulation REACH preventing the use of some hazardous substances.

Orest will seek and implement practices to minimize the use of substances that are harmful for the environmental, and the use of toxic products in productions. When it is technically feasible and possible, we will use alternatives.

Orest will continuously train and inform Employees about practices to implement. In particular, we will make sure that department or zone managers are aware of the specific risks of pollution, appropriate means of prevention and measures to implement in the event of an incident.


12. Orest will optimise waste disposal, encourage reduction of waste generation, and waste collection and recycling.

Orest will seek production efficiency and all waste will be responsibly managed.
Thus, Orest will take steps to reduce the quantity of waste produced from their operations, in particular the production of toxic waste.

Orest will dispose of waste substances including, but not limited to, toxic waste, in compliance with Applicable Law and regulations, in order to prevent earth, water and air pollution.


13. Orest will ensure conservation of energy and resources, and promote environmental initiatives, whether individual or collective, from its employees.

Orest will take measures to reduce on-site consumption of natural resources including, but not limited to, water and energy. We will measure our consumptions to supply a monitoring and/or reducing continual program.

Orest will favour, as much as possible, purchasing low environmental footprint materials, pieces and products.

Orest will promote Employee initiatives, whether they tackle the extension of waste sorting or the implementation of car-pooling.


A CONTINUAL IMPROVEMENT APPROACH

For all the principles and commitments defined above, Orest commits to implementing an integrated management system for performance and quality, in a continual improvement approach.

A reporting on key indicators will be conducted, in order to monitor the progresses.
Orest Employees will benefit from information, training and awareness campaign concerning Orest’s commitments in terms of corporate responsibility.

Orest will cooperate with business partners in order to share progressively the same level of standards concerning these stakes.

Finally, Orest will follow up the evolution of regulation and good practice on the jewellery sector, in order to continuously adapt its practices and processes.


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