CODE OF ETHICS

May 2022

1. Majoral Jewellery integrates a series of values into its internal and external relations. These values are an inalienable part of its business culture and are based on the Declaration of Human Rights. The organisation subscribes to the declaration made by the United Nations on the 10th of December 1948 and will act in consonance with these principles according to that stipulated in its code of ethics.
2. It will incorporate workers into its teams that are also aligned with these principles and who work with this same logic.
3. The workers will have the right to a dignified salary according to the job they occupy and the effort made. There will be no discrimination for reasons of gender or origin and the organisation will do everything possible to integrate all people according to their capacities. A good atmosphere at work will always be fostered and in case of conflict the corresponding protocol will always be applied. Majoral Jewellery possesses a protocol for sexual harassment. It will guarantee the right to have a job that complies with the workplace safety regulation, conciliation with the personal life and training. The workers will also periodically receive information about the commercial and financial situation of the company, future plans and guaranteed access to the taking of decisions in their sphere of work.
4. The non-negative effect on the environment will be a central priority of Majoral Jewellery. It will periodically evaluate the possible effect caused and in those cases confirmed will establish mechanisms of proportionate compensation.
5. Majoral Jewellery is within its full right to choose those sources of supply (suppliers) that respect these very principles and values described here and which comply with them in the same way as Majoral Jewellery.
6. Priority will be given to those suppliers that guarantee and inform about the origin of their products and services, as well as the social and environmental impact that they may have. The situation will also be verified of the state in which the country of origin is situated in the public list https://www.cahraslist.net/ in order to check and determine the potential risks. Majoral Jewellery applies the Due Diligence System to all its counterparts whether clients or suppliers as well as a form of KYC (Know Your Counterpart) format.
7. Those external workshops with which production contracts have been signed must also comply with the same requisites demanded of Majoral Jewellery’s own workshops, as well as all the suppliers in general, including the KYC form as a tool of verification and mutual knowledge.
8. The sale to intermediaries with the end client will be undertaken using these same principles and intermediaries will not be accepted that commit repeated infractions and without having repaired the damage caused.
9. The sale to the end client will be made informing them of the principles and values that Majoral Jewellery promotes. They will be provided with all the information necessary about the products they have purchased and details about possible social and environmental impacts.
10. In reference to the General Interest, all the legal and fiscal frameworks will be respected and as a consequence the identity of the purchasers will be verified, the ownership of the bank accounts and any element susceptible to being able to indicate an infringement of the Prevention of Money-laundering Law or any other regulation. In the case of clear evidence, the protocols of Sepblac (Commission for the Prevention of Money-Laundering and Monetary Infringements) will be followed.
11. Referring to publicity, Majoral Jewellery is committed to using it only to inform of true information about the brand, basically innovations and to be able to notify the people who are not aware of them. It may also issue opinions about real events or demonstrate its positioning in relation to events that affect society.
12. We request our suppliers and our intermediary clients to also subscribe to this code of ethics.
13. List of suppliers and intermediary clients who have subscribed to the code of ethics and who have consented to appear published in this website.

SYSTEM OF DUE DILIGENCE IN MAJORAL JEWELLERY

Introduction:

As a company that forms part of a chain of supply mainly of precious metals transformed into jewellery, Majoral Jewellery informs all its agents, whether internal or external, of the principles and values with which the organisation will be related with third parties both internally and externally.

This is the diagram we have followed according to the recommendations of the OECD.

Source: OECD Due Diligence Guidance for Responsible Business Conduct (2018)

This document is based on the OECD guide (OECD Due Diligence Guidance for Responsible Supply)

Majoral Jewellery is committed to fully include responsible business conduct in its management policies and systems. In consequence, it will identify and evaluate possible negative impacts caused in its supply chains and commercial relations it participates in so that they may be prevented, reduced or eliminated.

In the same way it will undertake a revision to check the result of the modifications or suppressions implemented, detailing the measures that are being taken to deal with these impacts and in consequence, what measures the organisation applies to repair them in those cases in which it has not been possible to avoid them.

Majoral Jewellery integrates a series of values into its internal and external relations. These values are an inalienable part of its business culture and are based on the Declaration of Human Rights. The organisation subscribes to the declaration made by the United Nations on the 10th of December 1948 and will act in consonance with these principles according to that stipulated in its code of ethics:

As a consequence of having subscribed to the declaration made by the United Nations on the 10th of December 1948 regarding Human Rights, Enric Majoral SL establishes a series of procedures to detect, avoid and correct when deemed necessary, possible impacts on Human Rights that it could have caused along its business channel.

In the same way, it guarantees compliance with the laws established in the European Union and all those regulations derived from them.

Majoral Jewellery will use the RJC toolkit to identify any situation of risk there may be throughout its chain of commercial relations.

UPSTREAM ORIGIN OF POSSIBLE IMPACTS ON HUMAN RIGHTS:

The suppliers of products and services may be authors, or also victims, of specific impacts on Human Rights and that this circumstance has transferred along the business channel. Majoral Jewellery will ALWAYS undertake the pertinent investigations to verify that the products and services it contracts will be exempt of this problem. These investigations will include an obligatory procedure for every new supplier or client (counterpart) which will also include a KYC (Know Your Counterpart) form.

1. It will verify that the country or region of origin is not included in the list of conflict-affected countries: https://www.cahraslist.net/
2. It will give priority to those suppliers that are members of a certification system that offers sufficient guarantees (Fairmined, RJC…). These guarantees may refer to the environment, child labour or any other factor that may arouse suspicions that an impact on Human Rights is being produced.
3. It will also give priority to those suppliers that explicitly state their commitment to the same values as those that guide Majoral Jewellery. Suppliers and intermediary clients that have subscribed to the Majoral Jewellery Code of Ethics.
4. It will similarly give priority to those suppliers that have been audited by recognised organisations in order to check the veracity of their statements.
5. Evidence will be required of all those suppliers that do not offer the above guarantees.

DOWNSTREAM ORIGIN OF POSSIBLE IMPACTS ON HUMAN RIGHTS:

1. Majoral Jewellery will duly identify its clients in order to avoid identity theft, deviations and negative consequences in general on Human Rights. In consequence, it must comply with all the legal procedures that figure in the Law for Prevention of Money-laundering (19/1993 of 28 December and 12/2003 of 21 May).
2. It will use renewable energy sources for any of its establishments.
3. It will use organic and compostable materials for the cases and packaging of its products and recyclable materials when there is no alternative.
4. It will ensure that all its workers have dignified psychosocial conditions and salaries.
5. It will correctly inform its end clients about the products acquired and will ask them to use them responsibly.

DILIGENCES OF REPARATION BEFORE POSSIBLE IMPACTS ON HUMAN RIGHTS:

If the circumstance arises whereby Majoral Jewellery was responsible directly or indirectly for any impact on Human Rights, it will have to repair the harm caused to those affected, proportionally according to their degree of responsibility. The reparations may be both economic and/or symbolic.

It may also take measures of informing against, punishing or taking reprisals regarding the originator of the impacts. This may take the form of termination of contracts in the case of suppliers or dismissal in the case of workers of the organisation.

It will also analyse the causes of the impact to avoid repetition in the future.

DILIGENCES OF INFORMATION IN RELATION TO HUMAN RIGHTS:

Majoral Jewellery is obliged to periodically inform, at least once a year, of incidents or absence of them that may have occurred. The notification can be made in the form of a Newsletter in the corporate web, or by e-mail to the interested parties by means of a report about its commercial policies.

DILIGENCES IN RELATION TO THE DETECTION OF POSSIBLE COMMISSIONS, GIFTS OR BRIBES:

Majoral Jewellery understands bribe in its strictest sense, that is, offering to give (as well as demand or receive) any undue advantage to (or from): public civil servants, political candidates, parties or officials, or employees, directors of officials from the private sector.

It is a form of interpersonal relation that the organisation explicitly rejects and will not tolerate under any circumstance. Neither in name of the company, or at a personal level, will advantages be offered to groups or individuals, in exchange for accepting sales contracts or of any other nature. Neither will it tolerate that a posteriori donations are made as a consequence of having been able to accept specific agreements. The same will apply in reverse. Advantages will not be requested or accepted a posteriori for having signed purchasing contracts or of any other nature.

Commissions will not be offered to agents who are members of client organisations (potential or otherwise), and in the same way it will not be tolerated for members of Majoral Jewellery to accept commissions from suppliers or agents of other organisations in exchange for accepting contracts of purchase or of any other nature.

No gifts will be given in exchange for accepting contracts of sale or similar. Neither will it be accepted that a worker of Majoral Jewellery receive any gift for the mere fact of having signed contracts with suppliers or other external agents.

This diligence has been ratified by the Management of Majoral Jewellery in the meeting held on the 30/11/2022 and is recorded in the minutes as such.

BRIBERY: SPHERES OF RISK

The heads of the purchasing departments form part of the sphere of risk susceptible to receiving offers of advantages or directly receiving advantages once they purchasing contracts have been accepted. Despite the fact the dividing line is rather blurred, we should distinguish, for example, between a Christmas present received from a supplier (increasingly less common) that is sometimes given to a specific person, and that less justified gift and which cannot be offered publicly. In the first case the gift can only be accepted if it is made in the name of all the members of the company and is shared between them, since generally speaking they are food products. Any group celebration can be used to share these gifts, which are accepted for the simple fact of being for purposes of sociability.

The heads of the sales department also form part of a sphere of risk, but in our understanding less so, since, in the case of a bribe taking place, it would have to be in the reverse order, that is, offering or giving advantages to the heads of purchasing of other organisations. This situation would already form part of a deliberate policy by the organisation and would be improbable that this infringement would originate from an individual initiative of the head of sales. Majoral Jewellery does not permit its members to offer any type of advantage to the heads of purchasing of client companies.

The company has a register of gifts and donations made.

POLICIES AND DILIGENCE REGARDING VIOLENCE IN THE WORKPLACE.

Majoral Jewellery rejects and explicitly prohibits any type of violence between its members, both inside and outside its premises and whether this violence is carried out on persons who are members or not of the organisation. This rejection and prohibition also includes violence to animals.

If any circumstance is shown in which any member of the organisation has exercised any type of violence the corresponding complaint will be processed and it will be considered a serious offence, which could be the cause of disciplinary dismissal.

POLICIES AND DILIGENCE REGARDING CHILD LABOUR

Majoral Jewellery prohibits child labour and states that it does not participate indirectly favouring or tolerating it. To avoid these situations it selects those suppliers that also prohibit this practice and can ensure their compliance. They thus comply with the resolutions of Convention 138 of the ILO and Recommendation 146 that establishes the minimum legal age at 15 with the aim that minors can complete minimum mandatory schooling.

POLICIES AND DILIGENCES REGARDING FORCED LABOUR.

Majoral Jewellery assumes and complies with the provisions of Convention 29 of the ILO regarding not participating in or favouring forced labour, including penitentiary work through obligation, contracted or involuntarily. We should pay special attention to contracting manufacturing services to companies that do not respect this convention. Especially those located in other countries.

POLICIES AND DILIGENCE REGARDING DISCRIMINATION AT WORK.

The people of the organisation cannot practice or approve any form of discrimination in the workplace, in matters related to contracts, continuity of employment, payment, overtime, Access to training, professional development, promotion, sick leave or retirement. This includes discrimination due to race, colour, ethnic origin, nationality, religion, disability or genetic information, gender, sexual orientation, trade union membership, political affiliation, civil status, parental state or pregnancy, physical appearance, HIV status, age, or any other personal characteristic not related to the inherent requisites of the job. Members must ensure that all the people “suitable for work” have the same opportunities and are not discriminated against for factors related to their capacity to undertake their duties.

POLICIES AND DILIGENCE REGARDING DANGEROUS SUBSTANCES.

No person from the company will manufacture, or use chemical products or dangerous substances that are subject to international prohibitions. The chemical substances necessary for the manufacture of jewellery are strictly regulated with indications about their degree of danger with the informative dossier about how to act in case of accident. An external company will be entrusted to verify the compliance with this regulation that enters into the sphere of health and safety at work.

POLICIES AND DILIGENCES REGARDING THE ENVIRONMENT.

Majoral Jewellery has evaluated, through a report, the risks of negative impact involved in its commercial chain, in order to establish the measures it considers necessary to reduce or eliminate these risks. When a negative impact cannot be avoided, it will have to be actively repaired.

ASSIGNATION OF RESOURCES:

The human resources will come from the different areas of responsibility:

• The head of general coordination.
• The financial head.
• The production head.
• The commercialisation head.
• The communication head.

COMMERCIAL PRACTICES 2021-2022

October 2022

Introduction

This is the first report produced by Majoral Jewellery about its commercial practices and for this reason encompasses a period of more than the calendar year.

This report is produced arising from the obligation required by being within the RJC certification and as from this year will be produced annually and updated to be published, whether on the corporate web or by e-mail to the interested parties such as workers, clients or suppliers of Majoral Jewellery.

The main elements of reference are the Sustainable Development Goals (SDG) formulated by the United Nations.

The report will explain the situation in which the commercial practices of Majoral Jewellery are situated in relation to these goals.

Majoral Jewellery also wishes to make explicit publicly that it rejects any commercial relationship that involves a violation of the United Nations Declaration of Human Rights. We will avoid contributing to the financing of armed groups and of money-laundering, as well as any relationship that involves corruption, fraud or blackmailing of any type.

Basic commercial structure of Majoral Jewellery:

Our activity consists mainly of designing, manufacturing and commercialising jewellery. Since 2013 we have also distributed metal with the Fairmined certification to other jewellery professionals.

From its beginnings, our organisation has been focused commercially on two basic client profiles:

• End client.
• Intermediary client.

By intermediary client we understand that person or organisation that also sells to the end client. The main goal of Majoral Jewellery and of its intermediary clients is to satisfy the needs of this end client.

Majoral Jewellery has six jewellery establishments of its own that enables it to attend to the clients’ needs directly, but it is clear that these are only found in some limited points of the country. Sales through intermediary clients enable the firm to extend client attention outside of this geographic sphere. Additionally, the fact that since 2003 it has had a virtual shop means it can also attend to many clients around the world.

Commercial practices of Majoral Jewellery during the period:

2021 was still a period seriously affected by the situation created by the Covid-19 pandemic. In contrast, 2022 was a period in which it appeared to see a return to normal, at least in matters of turnover.

As an organisation we believe that due to the structure we have explained before we can influence positively in the attainment of the 17 Sustainable Development Goals (SDG) in the following way:

From the points of sale we can positively affect the following goals:

• SDG 5 Gender equality.
• SDG 8 Work and economic growth.
• SDG 9 Industry, innovation and infrastructures.
• SDG 11 Sustainable cities and communities.
• SDG 12 Responsible production and consumption.
• SDG 13 Climate action.
• SDG 17 Alliances for sustainable development.

Commercial practices that influence positively:

Both in our own establishments and in the execution of the commercial guidelines of Majoral, women are the leading players. In fact, 80% of the people in the organisation are women. 40% of the management posts and 90% of posts of responsibility are women. We have 5 in-person shops and 1 virtual outlet in which we have contracted a total of 11 people (all women). All these people receive a salary above the minimum established by the Metal Commerce Collective Bargaining Agreement and they all have access to a distribution of the annual profits from a variable retribution according to agreed objectives.

Most of the products on sale are manufactured with certified metals as since 2019 the organisation has manufactured all its jewellery with certified metals, either Fairmined or RJC. The manufacture of the jewellery is done exclusively in Catalonia.

All the firm’s establishments use electricity from renewable sources commercialised by the Som Energia cooperative of which Majoral is also a partner.

The promotion and publicity campaigns are limited to a few communications throughout the year aimed mainly at the end clients. In 2021 there were 3 communications for this type of client about new collections, 5 about public events organised by Majoral, 2 promotions and 1 Christmas greeting. As regards the intermediary clients, only 5 communications were issued throughout 2021.

Another regular commercial practice, but which since 2020 we have stopped doing, is attending international fairs. Specifically, that of Couture (Las Vegas). In the period covered by the report no commercial fair has been attended but there have been in-person and virtual visits to the intermediary clients. These visits help establish ties of trust between the parties and all the latest products are explained. In no case is pressure applied to achieve a greater volume of orders, but they simply explain the acceptance that a specific collection has had amongst the clients of the shops and which space the new product aims to fill.

Tin both 2021 and 2022 a poetry competition was organised for Saint George’s Day (Catalan national day and day of the book). The 3 winners received an item of jewellery as a prize. In February 2022 there was also free cleaning campaign for Majoral jewellery items. This campaign was promoted by means of e-mail (Newsletter).

As regards the discount policy, this consists of providing the intermediary client with a discount only when the payment is made at the time or in advance. The end client is offered a loyalty card called Majoral Friends that with each purchase accumulates a percentage and that when the client decides, is applied to reduce the price of a new purchase. With this system we avoid making unjustified discounts which often would only obey the insistence of some clients.

Majoral Jewellery wants its commercial activity to have as positive an influence as possible and undertake a series of collaborative commercial actions with diverse entities. Thus, during 2021-2022 there were campaigns with the ACE Foundation for which a bracelet was designed called Instant. The profits from the sale of this item went entirely to the entity. In 2021 a donation in kind was also made to the Spanish Association against Cancer in the Balearics.

During 2021, due to the extreme situation of energy prices, we also publicised on the social media news about Majoral Jewellery’s support for the Som Energia cooperative, contributing €1,000 during the campaign the cooperative undertook to increase its capital and thus be able to overcome the crisis of electricity prices.

From our purchasing and manufacturing activities we can have a positive influence on the following goals:

• SDG 1 End of poverty.
• SDG 2 Zero hunger.
• SDG 3 Health and wellbeing.
• SDG 4 Education.
• SDG 6 Water and public healthcare.
• SDG 10 Reduction of inequalities.
• SDG 14 Underwater life.
• SDG 15 Life on the ground.
• SDG 16 Peace and social justice.
• SDG 17 Alliances for sustainable development.

Commercial practices that positively influence from our purchasing and manufacturing departments:

Our purchases of raw materials of Fairmined gold and silver contribute to reducing poverty, hunger and inequality, and increase health, wellbeing, education, public health, life on land and in the sea, as well as contributing to peace and social justice.

The Fairmined certification establishes that for every gram of gold bought in the mines, 4 US$ must be paid. This money is transferred to a specific bank account for each mine and is periodically audited. This money can only be used for improvements for the community (education, public health…) or the productive cycle (improvements in the preservation of the environment).

Majoral Jewellery produces all its metal alloys without adding any type of harmful substances or which are susceptible to causing allergies.

All the electrical energy of the Majoral Jewellery workshops comes from renewable sources.

A large number of the gems we commercialise in our jewellery, including the diamonds, have total traceability and guarantee an origin that respects both the environment and people. In this sense, Majoral Jewellery is committed to extending this type of guarantee to all its gems. Our option is that of choosing natural gems and with the least treatment possible.

Some of our campaigns are closely related to the world of culture and in this sense, some of our creations are produced by means of a direct collaboration with artists from other disciplines. This campaign is called “Creating with…”. During this period both Enric Majoral and Roc Majoral have participated in some art competitions as members of the jury.

In 2021 we published the book Enric Majoral. La Joia Expandida (Expanded Jewellery). 2022 also saw the organisation of an exhibition in the Museu de Disseny de Catalunya (HUB) named afetr the same title as the book.

Majoral Jewellery will be subject to periodical audits by third parties so that all the statements made in this document can be verified.