California Supply Chain Transparency Act Statement
This statement has been published in accordance with the California Transparency in Supply Chains Act of 2010 (SB 657). It sets out the steps that Tiffany & Co. and its subsidiaries have taken to prevent modern slavery and human trafficking in its own businesses and in its supply chain.
Tiffany & Co. is a holding company that conducts business through its subsidiary companies (collectively, “Tiffany”).
Through these subsidiaries, Tiffany designs, manufactures, and markets jewelry, watches, and luxury accessories. Tiffany maintains substantial control over its product supply chain through internal jewelry manufacturing and direct diamond sourcing. Tiffany 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 Tiffany. The balance, and almost all non-jewelry items, is purchased from third parties that manufacture these products to Tiffany’s specifications. To supply its internal manufacturing facilities, Tiffany 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 Tiffany constitute Tiffany’s “supply chain partners”.
For over 25 years, Tiffany has been committed to conducting our business responsibly, sustaining the natural environment and positively impacting the communities in which we operate. Additional information about Tiffany’s global sustainability strategy and initiatives is available at https://www.tiffany.com/sustainability/.
Policies on Modern Slavery and Human Trafficking
Tiffany 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 Tiffany’s labor-related policies.
Code of Conduct
Tiffany’s worldwide Business Conduct Policy (“Business Conduct Policy”) sets forth rules and principles that apply to the work conducted by Tiffany to ensure compliance by Tiffany and its employees with Tiffany’s expectations regarding ethical behavior. As a new subsidiary of LVMH Moët Hennessy Louis-Vuitton SE (“LVMH”) in 2021, Tiffany also incorporated the LVMH Code of Conduct into the existing Business Conduct Policy to ensure that Tiffany 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.
Tiffany Human Rights Policy
The Tiffany Human Rights Policy captures Tiffany’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 Tiffany 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 labor is also reflected in the Tiffany Supplier Code of Conduct. The Supplier Code of Conduct, which Tiffany 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 Tiffany, 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 Tiffany’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 labor, 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 labor for risk of human trafficking and compliance with applicable anti-slavery laws.
Our expectations and requirements covering responsible recruitment, forced labor, indentured, debt-bonded or convict labor, child labor 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 Tiffany has a direct relationship in turn bears the responsibility for ensuring compliance across its own supply chain.
Risk Assessment and Due Diligence Processes
Tiffany has actively promoted respect for human rights within our supply chain for more than two decades. All of Tiffany’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 labor, bonded labor, child labor, and human trafficking are zero tolerance issues for Tiffany. 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 labor practices, environmental protection, and ethical business conduct
· Conducting annual risk assessments with all of Tiffany’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.
Respect for human rights is embedded throughout our business, including in Tiffany’s jewelry manufacturing and diamond polishing facilities, and for our suppliers as part of our 2025 Sustainability Goals and our SEA Program.
All Tiffany employees and our suppliers’ employees can notify Tiffany through various channels if any of our requirements are not being met. All stakeholders can contact either the Tiffany worldwide Alertline or the LVMH Alert Line to notify Tiffany 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 Tiffany’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 labor indicators including overtime requirements, the existence of foreign migrant laborers in employment, grievance mechanisms and freedom of association.
Training and Awareness
Tiffany provides ongoing training resources and communicates expectations related to our Supplier Code of Conduct through an online responsible sourcing education platform for our supply chain partners. In 2021, we rolled out a training webinar and an e-learning module on the Tiffany Human Rights Policy to our supply chain partners.
Beyond our assessments and training, we also work to establish lasting partnerships with our suppliers and provide them with training and development programs as well as sharing best practices. We also work jointly with industry partners, non-governmental organizations (NGOs), and local stakeholders to identify human rights-related risks and further the improvement of the most complex challenges in human rights and labor. For example, Tiffany has been working with a group of luxury brands and gemstone miners (the “Coloured Gemstone Working Group”) since 2015 to help improve the colored gemstone industry through the launch of a community platform that includes trainings, policies and support on human rights and modern slavery topics. In 2021, after years of collaboration, the Gemstones and Jewellery Community Platform was launched by the Coloured Gemstone Working Group and will be freely available to all companies who are part of the gemstone and jewellery industry, from mining through to cutting and polishing, trading and retailing. Modules on Human Rights and Equality and Labor Rights and Fair Working Conditions will educate those along the colored gemstone supply chain on risk and mitigation strategies for modern slavery and human trafficking.
Additionally, Tiffany helped launch the Initiative for Responsible Mining Assurance (IRMA) in 2006 and remains steadfast in its commitment to work with suppliers, employees, the industry at large, NGOs and other local stakeholders to foster responsible mining. IRMA published a Standard for Responsible Mining, which represents a robust, practicable and comprehensive set of requirements for responsible mining, which incorporate human rights and modern slavery, as well as other environmental, social, ethical, and transparency, considerations.
In 2021, Tiffany established an Ethics and Compliance Committee consisting of cross-functional leaders from throughout the organization, including its Chief Executive Officer and other members of its senior management team. The Committee is chaired by our Chief Compliance Officer and is responsible for leading and overseeing ethics and compliance matters at Tiffany and for ensuring compliance by Tiffany and Tiffany’s employees, including in its and their dealings with relevant third parties, with applicable legal requirements and Tiffany’s core ethical values.
Tiffany & Co. will continue to implement our human rights policy related to our supply chain risks. We will continue to improve our risk assessment process to continually improve our ability to identify, mitigate and account for risks within our supply chain and our owned operations. We will continue to ask our supply chain partners to conduct due diligence on their own and their supply chain’s operations.