Lucira Jewellers Modern Slavery and Human Trafficking Policy

Introduction

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. Globally, modern slavery is thought to affect close to 50 million people. Human trafficking describes when a person arranges or facilitates the travel of another person with a view to that person being exploited.

The purpose of this policy is to make it explicitly clear that Lucira Jewellers ("Lucira Jewellers") shall prevent and eliminate Modern Slavery and Human Trafficking in its operations, value chain, and other business relationships.

This policy applies to every individual working for, with, and on behalf of Lucira Jewellers, including all employees, suppliers, contractors, and other business partners.

This policy is not part of Lucira Jewellers’ employment contract with any employee, and it may be subject to review and amendment at any time.

Definitions

Modern slavery encompasses slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking. Modern slavery is a crime and a violation of fundamental human rights.

Slavery: In accordance with international conventions, slavery is the status or condition of a person over whom powers typically attached to ownership are exercised. Since legal ownership is not possible, the key element of slavery is the behaviour of the offender as if they owned the person, thereby depriving the victim of their freedom.
Servitude: Servitude refers to the obligation to provide services imposed by coercion, including the obligation for a "serf" to live on another person’s property, and the inability to change one’s condition.
Forced or compulsory labour (including bonded labour): Forced or compulsory labour is work or service exacted from any person under threat of penalty, and for which the person has not offered themselves voluntarily. This includes the practices of bonded labour, a common form of exploitation in many industries.
Child labour: Child labour is defined as any work that deprives children of their childhood, their potential, and their dignity, and is harmful to their physical and mental development. International standards prohibit the use of children in work that harms them, including slavery-like practices such as trafficking and forced labour.
Human trafficking: Human trafficking involves the arrangement or facilitation of the movement of a person for the purpose of exploitation. The act of human trafficking may involve deceit, coercion, or exploitation of victims, particularly for sexual exploitation or forced labour.

Legal and Policy Framework

This section highlights the laws, protocols, and conventions guiding this policy as well as relevant internal policies.

Indian Penal Code, 1860 (Section 370 and 370A): Criminalises trafficking of persons for commercial sexual exploitation, forced labour, and slavery.
The Bonded Labour System (Abolition) Act, 1976: Prohibits bonded labour in India.
The Child and Adolescent Labour (Prohibition) Act, 1986: Prohibits child labour and sets guidelines for the employment of adolescents.
The Juvenile Justice (Care and Protection of Children) Act, 2015: Addresses child trafficking and child rights.
UN Protocol to Prevent, Suppress and Punish Trafficking in Persons: International framework for addressing human trafficking.
Lucira Jewellers’ Modern Slavery and Human Trafficking Policy
Lucira Jewellers’ Supplier Code of Conduct
Accountability
The Board: The Board of Directors is responsible for corporate governance and managing significant risks that may arise while achieving the company’s objectives.
The Steering Committee: Responsible for day-to-day operations and reviewing corporate policies.
SVP, People Operations: Ensures all human resources matters are handled, policies are developed to reinforce Lucira Jewellers’ core values, and responds to concerns raised through the Whistleblowing Policy.
SVP, General Counsel: Responsible for ensuring compliance with applicable laws and regulations, and oversees associated training in partnership with other departments.
VP, Sustainability: Responsible for evaluating key third-party partners and developing the Supplier Code of Conduct, ensuring that Lucira Jewellers’ supply chain is free from modern slavery and human trafficking practices.
Management: Responsible for ensuring their teams are aware of, understand, and comply with this policy.
Employees: All employees are personally responsible for the way their conduct impacts human rights, modern slavery, and human trafficking. Employees should raise any concerns of modern slavery with their manager or through the Whistleblowing Policy.

Guidance on Modern Slavery

Lucira Jewellers strictly prohibits Modern Slavery and Human Trafficking in its operations and supply chain. The company values integrity and uses this as a guiding principle to ensure personal freedom throughout all its operations.

To prevent modern slavery, Lucira Jewellers will establish systems to monitor and assess risks within its operations and supply chain. The company’s primary risks are identified in the supply chain, particularly in sourcing raw materials and product manufacturing. Additionally, risk is identified with contractors, such as cleaning and security providers. Regular reviews of the risks related to modern slavery and human trafficking will be conducted and communicated to stakeholders.

Lucira Jewellers commits to conducting thorough due diligence in selecting suppliers. Suppliers will be assessed for their adherence to Lucira Jewellers’ Supplier Code of Conduct, which strictly prohibits forced labour, bonded labour, child labour, and human trafficking. Any supplier found violating this policy or the Supplier Code of Conduct will have their business relationship terminated.

Lucira Jewellers requires all suppliers, contractors, and business partners to uphold the same zero-tolerance standard for modern slavery and human trafficking. Suppliers are also expected to extend these requirements to their suppliers.

Compliance

All employees must read and comply with this policy. Those working for Lucira Jewellers are responsible for ensuring the successful implementation of this policy. Any suspected incidents of non-compliance with this policy must be reported.

If an individual suspects that this policy, or any supporting policies, has been violated, they are required to report it under Lucira Jewellers’ Whistleblowing Procedure, which ensures anonymous reporting through a third-party hotline and escalation to senior management.

All concerns raised will be addressed confidentially and reviewed within 30 days, except in exceptional cases.

Individuals who report concerns in good faith will not face any retaliation, including professional setbacks, disciplinary action, or termination.

Grievances and Breaches

If a breach of this policy occurs, Lucira Jewellers will conduct a thorough investigation to assess the impact of the breach and whether it is appropriate to escalate the matter to the relevant authorities. The company reserves the right to terminate any relationship with a supplier or partner found in violation of this policy.

Accessing this Policy

This policy will be communicated to employees during the onboarding process and regularly reviewed through ongoing training facilitated by the Human Resources team at Lucira Jewellers.

This Modern Slavery and Human Trafficking Policy demonstrates Lucira Jewellers’ ongoing commitment to eliminating modern slavery and human trafficking from its operations and supply chain.