We strive to conduct our business activities in an environmental and socially responsible manner that promotes respect for people and the planet.

We are committed to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes. 

Human and Labour Rights

We are committed to respecting all human rights in our own operations and business relationships in accordance with the Universal Declaration of Human Rights (UDHR), the UN Guiding Principles on Business and Human Rights and relevant conventions of the International Labour Organization (ILO). Our human rights policy covers the following key commitments:

All forms of violence and harassment are prohibited, including but not limited to corporal punishment; harsh or degrading treatment; sexual or physical harassment; mental, physical, verbal or sexual abuse; retaliation; coercion; and intimidation.

To never engage in or knowingly support child labour (including the worst forms of child labour) as defined by International Labour Organization (ILO) conventions 138 and 182;

To never engage in or knowingly support forced labour as defined by International Labour Organization (ILO) convention 29, including bonded labour, deceptive recruitment, human trafficking and indentured or involuntary prison labour.

To prohibit all forms of discrimination, including but not limited to discrimination based on race, color, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation, union membership, political affiliation, marital status, parental or pregnancy status, physical appearance, HIV status, age or any other personal characteristic unrelated to the inherent requirements of the work.

To promote human rights in our dealings with business partners and other relevant stakeholders.

Bribery and Corruption

We prohibit bribery and corruption in all business practices and transactions carried out by employees and by agents acting on our behalf. For the purpose of this policy, bribery is defined as giving, offering or receiving any undue advantage to or from:

A public or government official;

A political candidate, party or official; or

Any private sector employees, directors or officers, or their agents or representatives.

Anti-Money Laundering and Finance of Terrorism

We commit to not engaging in or contributing to money laundering or the finance of terrorism. Emily P. Wheeler, LLC has implemented Anti-Money Laundering (AML) and Know Your Counterparty (KYC) procedures to:

Establish the identify of all counterparties;

Verify that counterparties and, if applicable, beneficial owners are not named on relevant government lists for individuals or organization implicated in money laundering, fraud or involvement with prohibited organization and/or those financing conflict;

Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties and;

Monitor transactions for unusual or suspicious activity.

Environmental Management

We commit to reducing and managing the environmental impacts of our business operations through the implementation of an Environmental Management System (EMS). This includes:

The responsible management of all wastes and emissions to air, water and land.

Establishing energy and water efficiency measures.

Seeking to ensure the responsible and efficient use of other natural resources, where applicable.

Product Disclosure

We will not knowingly make any untruthful, misleading or deceptive representation, or make any material omission in the selling, advertising or marketing of jewelry products and materials. We further commit to disclosing information on the physical characteristics of jewelry products and materials in accordance with the Responsible Jewelry Council (RJC) Code of Practices Standard.

Conflict Diamonds

We will not knowingly buy or sell Conflict Diamonds and ask that all of our suppliers of diamonds comply with the requirements of the Kimberly Process Certification Scheme (KPCS) and World Diamond Council System of Warranties (SoW).

Supply Chain Policy – Conflict-Affected and High-Risk Areas

This policy confirms our commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

We respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;

do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;

support transparency of government payments and rights-compatible security forces in the extractives industry;

do not provide direct or indirect support to illegal armed groups;

enable stakeholders to voice concerns about the jewelry supply chain; and

are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

We also commit to using our influence to prevent abuses by others.

Regarding serious abuses associated with the extraction, transport or trade of gold, silver, platinum group metals, diamonds and colored gemstones: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

torture, cruel, inhuman and degrading treatment;

forced or compulsory labour;

the worst forms of child labour;

human rights violations and abuses; or

war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.

Regarding direct or indirect support to non-state armed groups: We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold, silver, platinum group metals, diamonds and colored gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

control mine sites, transportation routes, points where gold, silver, platinum group metals, diamonds and colored gemstones are traded and upstream actors in the supply chain; or

tax or extort money, or minerals at mine sites, along transportation routes or at points where gold, silver, platinum group metals, diamonds and colored gemstones are traded, or from intermediaries, export companies or international traders.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4, or that act illegally as described in paragraph 6.

Regarding bribery and fraudulent misrepresentation of the origin of gold, silver, platinum group metals, diamonds and colored gemstones: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, silver, platinum groups metals, diamonds and colored gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold, silver, platinum groups metals, diamonds and colored gemstones.

Regarding money laundering: We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of gold, silver, platinum group metals, diamonds and colored gemstones.

Supplier Code of Conduct

Emily P. Wheeler, LLC has developed a Supplier Code of Conduct to ensure that suppliers are able to demonstrate a shared commitment to responsible and ethical business conduct. Emily P. Wheeler, LLC is currently rolling out implementing of the code to its major suppliers and the code will become mandatory for all existing and new suppliers from 2022.

Grievance procedure

Emily P. Wheeler, LLC has established this procedure to hear any concerns or complaints from interested parties and stakeholders regarding its supply chain and business practices. 

Concerns can be raised by interested parties via email using the following contact information:

Name: Emily P. Wheeler

Email: info@emilypwheeler.com

On receiving a complaint, we will aim to:

• contact you as soon as possible to gather more information regarding your grievance, where applicable;

• decide who is the appropriate person internally to handle the grievance, or help redirect you to another entity, such as a relevant company, industry body or other organization;

• identify any actions we should take (if any), or monitor the situation;

• advise you of any decisions or outcomes; and;

• keep records on grievances received and the internal process followed to address such grievances, for at least five years.

Sustainability progress and actions

The list below provides a summary of some of the specific actions and steps we have taken to integrate sustainability and ethical business practices into our day-to-day operations:

Working with trusted suppliers

We undertake due diligence on all of our business partners and work with a small number of suppliers and jewelry manufacturers that we know and trust. We will offer support and guidance to ensure that these companies are able to commit to the principles outlined in our Supplier Code of Conduct.

Reduce, reuse, recycle

We reuse shipping supplies and packaging wherever possible and strive to source packaging materials made from recyclable materials. Paper used by the company originates from recycled sources.

Philanthropy

We donate a minimum of $30,000 worth of jewelry to various 401C3 non-profits per year for fundraising efforts.

The above policy commitments are endorsed by:

Name: Emily P. Wheeler

Position: Owner

Date: March 2021

The principles of trust, transparency and ethical business practices are highly valued by Emily P. Wheeler and as such we ask that all of our suppliers and manufacturing partners (hereon referred to as “suppliers”) commit to implementing the requirements outlined in this document.

We believe in a continuous improvement approach, and while we reserve the right to terminate business relationships with suppliers that do not meet our minimum expectations, we are also committed to working collaboratively with suppliers that are able to demonstrate good faith efforts with regards to improving their performance against this Code of Conduct over time.

Implementation of the Code of Conduct is being rolled out during 2021. During this time, Emily P. Wheeler, LLC will work with its suppliers to ensure that they are able to meet all requirements of the code. Adoption of the code will become mandatory for all suppliers and manufacturing partners from 2022.

Requirements

Legal Compliance

Suppliers shall comply with all minimum legal requirements that are applicable to their direct business operations which include, but are not limited to, legal requirements concerning human and labour rights, anti-corruption and anti-money laundering, environmental management, non-use of child labour and non-use of forced labour, workplace health & safety, employee working hours and renumeration.

Child and forced labour

Suppliers shall not employ anyone (either directly or indirectly) under the age of 15 and shall not employee anyone under the age of 18 engaged in hazardous work as defined by applicable conventions of the International Labour Organization (ILO). 

Suppliers shall not engage in any form of forced labour including bonded labour, deceptive recruitment, human trafficking and indentured or involuntary prison labour.

Working hours and remuneration

Suppliers will not require employees to work excessive hours that exceed 48 hours per week for a normal working week or 60 hours per week for a normal working week plus overtime. Overtime hours shall be voluntary for all employees.

Suppliers will ensure that all employees receive at least the legally mandated minimum wage and shall also comply with the law with regards to payment of overtime and other legally mandated benefits.

Harassment and discrimination

Suppliers will adopt a zero-tolerance policy to all forms of violence and harassment in the workplace. Suppliers will not discriminate against employees on the basis of race, color, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation, union membership, political affiliation, marital status, parental or pregnancy status, physical appearance, HIV status, age or any other personal characteristic unrelated to the inherent requirements of the work.

Working conditions, health and safety

Suppliers will provide all employees with safe and healthy working conditions in accordance with applicable law and relevant industry health and safety standards.

Anti-bribery and money laundering

Suppliers commit to not engaging in any form of bribery or money laundering and will have systems in place to ensure that this policy is adhered to by all of its employees and agents that act on its behalf.

Product disclosure

Suppliers will not make any untruthful, misleading or deceptive representation, or make any material omission regarding jewelry materials and/or products supplied to Emily P. Wheeler. This includes, but is not limited to, information regarding size, cut, carat weight, clarity, color, treatments of precious stones and the origin (where known) of precious stones and precious metals. 

Emily P. Wheeler reserves the right to request additional information from suppliers as required.

Diamond warranty statements

Suppliers will provide the following warranty statements on all invoices issued to Emily P. Wheeler for diamonds or diamond containing jewelry products:

“The diamonds and/or diamonds set in jewelry herein invoiced are exclusively of natural origin based on 100% testing of all diamonds supplied using appropriate diamond verification equipment. The seller agrees to provide evidence of test results when requested.” 

“The diamonds and/or diamonds set in jewelry herein invoiced have been {sourced} purchased from legitimate sources not involved in the funding of conflict, in compliance with United Nations Resolutions and corresponding national laws {where the invoice is generated}. The seller hereby guarantees that these diamonds are conflict free and confirms adherence to the World Diamond Council (WDC) System of Warranties (SoW) Guidelines.”

Respect for the environment

Suppliers shall implement a system to identify and address environmental impacts caused by their own direct business operations. This will include identifying opportunities to improve environmental performance.

Supply chain due diligence, transparency and traceability

Suppliers will conduct due diligence on their own supply chain to identify the geographical origin of jewelry materials (where possible) and any actual or potential human rights risks associated with the extraction, transport or trade of these materials. When requested, suppliers will share information with Emily P. Wheeler in relation to their own business practices, the results of any due diligence assessments and the origin of jewelry materials supplied (subject to respect for commercial confidentiality). 

Acknowledgment

I understand and commit to complying with the above requirements:

Name: Emily P. Wheeler

Position: owner

Company: Emily P. Wheeler, LLC

Date: August 25, 2021

UPDATES - October 2023

- By June 2024, all of our jewelry will be made with Single Mine Origin gold.

- Our new packaging is recycled and recyclable.

- By January 2024, 100% of our shipping will be carbon neutral through the purchase of carbon offsets.

EPW SUSTAINABILITY STATEMENT 2022

During 2020 and early 2021, EPW began a process of embedding sustainable and responsible business practices into its day-to-day operations. We have developed a range of policies and procedures to ensure our ongoing compliance with standards we have set for ourselves.

We are also committed to developing and nurturing strong relationships with suppliers and other business partners to promote responsible business practices throughout our supply chain. This includes taking steps to identify and, where applicable, mitigate negative social and environmental impacts with a particular focus on addressing issues related to human rights, child labour and forced labour.

To achieve this, we carry out due diligence on all of our suppliers in alignment with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). In 2020 we took the following initial steps on this journey:

Adopted a supply chain policy in alignment with the OECD Guidance which is available on our website here.

Developed internal control systems and processes for collecting and recording information on the origin of jewelry materials supplied to us and, where available, information relating to due diligence carried out by suppliers.

Reached out to all of our suppliers to communicate our requirements and to request information.

Developed a system for identifying risks in our supply chain and ´red-flag locations’.

To understand the potential and/or actual human rights risks that might be present in our upstream supply chain, we asked all of our suppliers and manufacturing partners to complete a survey questionnaire. This questionnaire asked suppliers to provide information on their legal compliance, labour practices, controls to manage child and forced labour risks, how they manage their impacts to the environment, the controls they have in place to ensure adequate workplace health & safety and the due diligence processes they have in place to address risks related to minerals originating from Conflict-Affected and High-Risk Areas (CAHRAs). This process has allowed us to identify areas where some of our suppliers may need further support to strengthen their business practices and in other cases, we have taken the decision to end business relationships with certain suppliers.

We will continue to work with our supply chain throughout 2022 to build on these efforts which will include, where applicable, steps to appropriately manage identified risks in alignment with our policies. As part of our efforts to encourage our supply chain to adopt responsible business practices, we are rolling out our own Supplier Code of Conduct in 2022 with the objective of ensuring that all of our suppliers and manufacturing partners are able to meet the requirements of our code.

In addition to the above we have also implemented processes and controls to manage the environmental impacts of our direct business operations. This has included implementing measure to minimize waste, increase recycling of paper and the use of recycled paper in our packaging materials, and implementing energy efficiency measures. During 2023 we will continue to seek opportunities to improve our environmental performance.