Pandora A/S Suppliers’ Code of Conduct
1. Introduction
1.1 Background
Pandora A/S is committed to making a positive contribution to society and the environment by developing
and implementing responsible business practices that allow us to deliver financial success while conducting
our business strategy and operations in a responsible manner.
Pandora A/S is a signatory to the United Nations Global Compact, which means that we support 10
principles within four important areas: human rights, labour rights, environment and anti‐corruption.
Pandora A/S is a member of Responsible Jewellery Council and adheres to the principles and code of
practices set out by them. Responsible Jewellery Council who is a not‐for‐profit organization established to
promote responsible ethical, social and environmental practices throughout the diamond and/or gold
jewellery supply chain, from mine to retail.
1.2 Scope
This code applies to all Pandora A/S’s suppliers (hereafter "the supplier" or "suppliers"). Pandora A/S
includes Pandora A/S including all Pandora Affiliates, which means a company of which Pandora A/S
exercise control by ownership of at least 50% of its shares or voting rights.
Observance of the code is an enforced part of any agreement or contract between Pandora A/S and our
suppliers.
The provisions of the code extend to all activities and workers, including workers who are engaged
informally, on short‐term contracts, or on a part‐time basis. Suppliers must ensure that the Code of
Conduct is also observed by subcontractors involved in production processes of final manufacturing stages
carried out on behalf of Pandora A/S, which includes responsibility for communicating the content and
ensuring that all measures are implemented accordingly.
By signing PANDORA’s Suppliers Code of Conduct, suppliers confirm that the supplier will take action if they
observe any failure to comply with the principles and standards in the Code of Conduct and its appendixes
among its sub‐contractors. In addition, the supplier will notify PANDORA immediately.
1.3 Compliance
Suppliers must, in addition to meeting the provisions of this code, comply with all national laws and
regulations. Should there be differences between the content of this code and national laws, suppliers
must adhere to the more stringent requirements. Conflicts between the provisions of this code and
national laws or other applicable standards will be evaluated by Pandora A/S in cooperation with the
supplier. Suppliers must be able to document their compliance, and if any conflicts are detected, suppliers
must inform Pandora A/S immediately.
Pandora A/S is entitled to conduct (announced) audits at the suppliers’ sites either by themselves or
through 3rd parties in order to verify compliance with this Code.
In the event of non‐compliance, we require our suppliers to be committed and engaged in remedying the
non‐compliance issues within the time schedule set out in the corrective action plan. Pandora A/S seeks to
continuously improve together with our suppliers and help them achieve compliance with the provisions of
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this code, while reserving the right to terminate any agreements should a supplier decide that compliance
with the requirements of the code is impossible to obtain or the supplier shows repeated and/or serious
disregard for the code. If no solution can be agreed upon and implemented within a reasonable amount of
time, Pandora A/S may choose to terminate the business relationship and/or suspend future contracts with
a non‐compliant supplier.
2. Business Ethics
2.1 Bribery, gifts and entertainment
Suppliers shall not engage in any form of bribery, corruption, extortion or embezzlement in any business
practices and transactions carried out by them or on their behalf by business partners. They will not offer,
accept or countenance any payments, gifts in kind, hospitality, expenses or promises as such that may
compromise the principles of fair competition or constitute an attempt to obtain or retain business from
any person or to influence the course of the business or governmental decision‐making process.
The Supplier shall also refrain from offering funding, donations, lavish gifts and extravagant entertainment
to any employee of Pandora A/S or any other counterparts in Pandora A/S in an attempt to influence
business decisions.
2.2 Money Laundering and Finance of Terrorism
Suppliers must maintain financial accounts of all business transactions where required by applicable law
and in accordance with national or international accounting standards.
2.3 Kimberley Process
Suppliers must not knowingly buy or sell Conflict diamonds or assist others to do so.
Suppliers, where involved with the international trade of rough diamonds must apply the rough diamond
export and import verification system and controls as laid out by the Kimberley Process Certification
Scheme and relevant national legislation. Suppliers must keep records of Kimberley Process Certificates for
rough diamonds. Kimberley Process certificates must be independently audited and reconciled by the
suppliers own independent auditor on an annual basis
Suppliers, where involved in buying and selling diamonds, whether rough, polished or set in jewellery, must
fully adhere to the principles of the “World Diamond Council Resolution on Industry Self‐Regulation”.
Suppliers are required to have systems in place so that all invoices for diamonds, whether rough, polished
or set in Jewellery, either bought or sold, contain the World Diamond Council warranty statement1.
Suppliers must have systems in place so that they do not purchase from sources that do not provide the
World Diamond Council warranty statement on their invoices.
2.4 Extractive Industries Transparency Initiative
Suppliers with mining facilities will commit to and support implementation of the Extractive Industries
Transparency Initiative (EI TI).
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World Diamond Council warranty statement – “The Diamonds herein invoiced have been purchased from legitimate
sources not involved in the funding of conflict and in conformance with United Nations Resolutions. The seller hereby
guarantees that these Diamonds are conflict free, based on personal knowledge and/or written guarantees provided
by the Supplier of these Diamonds.”
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3. Human Rights and Working Conditions
3.1 Human Rights
Suppliers will at all times respect the fundamental human rights and the dignity of the individual, according
to the United Nations Universal Declaration of Human Rights.
3.2 Discrimination
Suppliers will not practice or condone any form of discrimination in the workplace in terms of hiring,
remuneration, overtime, access to training, promotion, termination or retirement based on race, ethnicity,
caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation,
marital status, pregnancy status, physical appearance, HIV status, or age, or any other applicable prohibited
basis, such that all individuals who are “Fit for Work” are accorded equal opportunities and are not
discriminated against on the basis of factors unrelated to their ability to perform their job. Suppliers will
ensure that employees are not subjected to harsh or degrading treatment, sexual or physical harassment,
mental, physical or verbal abuse, coercion or intimidation in any circumstances
3.3 Child Labour and Young Persons
The supplier shall not engage in or benefit from the use of child labour.
The minimum age for fulltime employment shall not be less than the age of completion of compulsory
schooling and, in any case, shall not be less than 15 years (or 14 years where established by local laws in
accordance with the ILO developing‐country exception).
The supplier shall refrain from hiring workers under the age of 18 for positions that require hazardous work
that could jeopardise their health, safety or morals.
If any children are found to be in employment below the minimum age, suppliers will provide adequate
support to enable them to attend and remain in school until no longer a child. Child labour remediation
processes will include steps for the continued welfare of the child and consider the financial situation of the
child’s family.
3.4 Prohibition of Forced and compulsory Labour and Disciplinary Measures
All forms of forced labour, such as lodging deposits or the retention of identity documents from personnel
upon commencing employment, are forbidden as is prisoner labour that violates basic human rights.
Neither the company nor any entity supplying labour to the company shall withhold any part of any
personnel’s salary, benefits, property, or documents in order to force such personnel to continue working
for the company. Personnel shall have the right to leave the workplace premises after completing the
standard workday, and be free to terminate their employment provided that they give reasonable notice to
their employer.
3.5 Freedom of Association and Collective Bargaining
Suppliers will not prevent employees from associating freely. Where laws prohibit these freedoms,
suppliers will support parallel means for independent and free association and bargaining.
Suppliers will not prevent collective bargaining and will adhere to collective bargaining agreements, where
such agreements exist.
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3.6 Working Hours
The supplier shall comply with applicable national laws on working hours and public holidays. The
maximum allowable working hours in a week are as defined by national law but shall not on a regular basis
exceed 48 hours and the maximum allowable overtime hours in a week shall not exceed 12 hours. An
employee is entitled to at least one free day following six consecutive days worked
Suppliers will provide employees with all legally mandated leave, including maternity and paternity,
compassionate and paid annual leave.
3.7 Wages and benefits
Suppliers will pay all employees a wage based on the higher of either the applicable legal minimum wage
plus associated statutory benefits, or the prevailing industry standards. Suppliers will make payment to the
employee on a regular and pre‐determined basis and will accompany all payments by a wage slip which
clearly details wage rates, benefits and deductions where applicable.
3.8 General Employment Terms
All workers shall be provided with a written, understandable and legally binding labour contract. Provisions
for non‐permanent and seasonal workers shall be no less favourable than for permanent workers.
Suppliers will maintain appropriate employee records, including records of piece rate and wage payments
as well as working hours, for all staff employed, whether on a full time, part time or seasonal basis.
3.9 Health & Safety
Suppliers will provide safe and healthy working conditions for all employees in accordance with applicable
law and other relevant industry standards, including, but not limited to, protection against fire, accidents
and toxic substances.
The supplier shall also formulate and maintain health and safety plans that clearly set out the measures to
be taken to safeguard employees and others affected by its activities. The supplier shall be expected to
progressively identify and eliminate or control hazards that present a risk to employees and other persons
present on its sites and to the environment.
The supplier shall provide a suitable, clean and sanitary infrastructure, including access to toilets and
potable water, which meets the needs of its employees and is adequate for its employee numbers.
Accommodation, if provided by the supplier, shall satisfy the same requirements, including the general
provisions on health and safety listed above.
Suppliers will provide employees with the necessary health and safety training and/or education and will
secure that adequate systems to detect and avoid potential threats and to help continuously improving
health and safety are put in place.
Appropriate procedures must be in place to prevent accidents and injury to health arising from, or linked to,
the course of work‐related activities and operations at a facility. Suppliers will establish emergency
procedures and evacuation plans for all reasonably foreseeable emergencies. Suppliers will ensure that the
procedures and plans are accessible or clearly displayed throughout their facilities.
The supplier shall provide its employees with the protective equipment and training necessary to perform
their tasks safely. The supplier shall develop and maintain effective systems for informing and consulting
employees on relevant health and safety matters. Through these systems the supplier shall keep accurate
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records of accidents, injuries and known exposure to health and safety risks at work according to local
legislation.
4. Environmental Performance
4.1 Environmental Protection
The supplier shall comply with all relevant national environmental legislation. The supplier shall maintain
awareness of current environmental legislative requirements relevant to the environmental impacts of its
activities, products and services, and ensure legal compliance through training, awareness, operational
control and monitoring.
Suppliers will, wherever appropriate, introduce management and operating systems to minimise the
detrimental environmental impacts of its business practices.
4.2 Hazardous Substances
Suppliers will not manufacture, trade, and/or use chemicals and hazardous substances subject to
international bans due to their high toxicity to living organisms, environmental persistence, potential for
bioaccumulation, or potential for depletion of the ozone layer.
4.3 Waste and Emissions
Suppliers will dispose of waste substances in compliance with applicable law. Where applicable law does
not exist, prevailing international standards will be adopted. Suppliers will seek to decrease emissions to air,
water and land relative to production output.
4.4 Use of Energy and Natural Resources
Suppliers will seek to ensure the efficiency of their business operations in terms of consumption of natural
resources including, but not limited to, water and energy.
5. Signature
By signing this document the Supplier confirm that they as a business have read, understood and will
respect and act to fulfil this code of conduct:
Date and Place:
Signature:
Name and title of signatory in capitals:
Company name in capitals:
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