Supply chain policy 

1. F.D. Worldwide is a vertically integrated jewelry wholesale company based in New York City. This policy confirms F.D. Worldwide’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws. 

2. F.D. Worldwide is a certified member of the Responsible Jewelry Council (RJC). As such, we commit to proving, through independent third-party verification, that we: 

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

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

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

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

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

f. 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. 

3. We also commit to using our influence to prevent abuses by others, specifically partners in our vertically integrated supply chain. We ask for RJC membership commitment and adherence to RJC CoP from our vertically integrated suppliers. The public may use the feedback/complaint messaging page on our website "Contact Us" page to reach us. 

4. Regarding serious abuses associated with the extraction, transport or trade of minerals: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of: 

a. torture, cruel, inhuman and degrading treatment; 

b. forced or compulsory Labor; 

c. the worst forms of child Labor; 

d. human rights violations and abuses; or e. war crimes, violations of international humanitarian law, crimes against humanity or genocide. 

5. 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. 

6. Regarding direct or indirect support to non-state armed groups: We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally: 

a. control mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain; or 

b. tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders. 

7. As a condition of doing business with F.D. Worldwide, each supplier agrees to work to

ensure that the gold and precious metals we purchase, subject to availability, come from

sources that meet the following human rights, social and environmental criteria at all stages in the

supply chain (mining, processing, refining, recycling, etc.). For ease of alignment, each supplier  agrees to procure gold and precious metals from LBMA Good Delivery list of refiners.

8. 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. 

9. 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. 

10. Regarding bribery and fraudulent misrepresentation of the origin of minerals: We adopt a strict zero gifting policy. We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals. 

11. 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 minerals. 

12. We will publish risk assessments findings and results on publicly on an annual basis and maintain an archive for open disclosures of our responsible business practices. 

Corinna Bhasin

Vice President/Compliance Officer

 F.D. Worldwide Merchandise Group, INC

(T) 212 286 2800 ext 5122

(F) 212 286 3400

corinna@fdworldwide.com

renewed commitment : May 2023

January 1 2022 - December 31 2022 Risk Assessment Public Report

In April 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated Alrosa on the OFAC Specially Designated Nationals list, blocking all U.S. transactions with or benefiting Alrosa. With this new regulation, FD Worldwide reached out to our suppliers to insure compliance that no new materials from Russia will be used in the production of our product as long as the current USA sanctions are in place.

There was no other concerns with risk of violation of Human Rights or Supply Chain policies.