Responsible Business Practices Policy

Responsible Jewellery Council (RJC) policy

Karl Faller e.K is a member of the Responsible Jewellery Council (RJC)

The RJC is a standards-setting organisation established to advance responsible, ethical, human rights, social and environmental practices throughout the gold, silver, platinum group metals, diamond, coloured gemstone and lab-grown materials jewellery supply chain.
The RJC has developed a benchmark standard for the jewellery supply chain and credible mechanisms for verifying responsible business practices through third-party auditing.
As an RJC member, we commit to operating our business in accordance with the RJC Code of Practices (COP) Standard. We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes.
We commit to upholding the principles and intent of the RJC Code of Practices, as relevant to the scope of our business.

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 in the workplace 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. Both direct and indirect harassment in any form is unacceptable in workplace facilities. This includes violence and harassment based on:
o Race
o Colour
o Ethnicity
o Caste
o National origin
o Religion
o Social aspects, including minority status
o Migrant worker status
o Disability or genetic information
o Gende
o Sexual orientation or other LBTQ status
o Union membership
o Political affiliation
o Marital status
● To never engage in or knowingly support child labour (including the worst forms of child labour) as defined by International Labour Organisation (ILO) conventions 138 and 182;
● To never engage in or knowingly support forced labour as defined by International Labour Organisation (ILO) Convention 29, including bonded labour, deceptive recruitment, human trafficking and indentured or involuntary prison labour;
● To provide a safe and healthy working environment for employees and on-site contractors;
● To prohibit all forms of discrimination, including but not limited to discrimination based on race, colour, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation, union membership, political affiliation or partaking in a legal strike, 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.
● To promote worker diversity, equity and inclusivity at all levels of the organisation and across functions, including (but not limited to) recruitment, professional development and mobility, and equitable employment conditions.
● To respect the rights of our employees to associate freely with worker unions of their choice and to engage in collective bargaining without fear of retaliation.

Bribery and Corruption

We prohibit bribery and corruption in all our business practices and transactions, including those carried out 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, 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. Karl Faller 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 organisations implicated in money laundering, fraud or involvement with prohibited organisations 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 have established an environmental management system relevant to the scope of our business. We will take all reasonable steps to minimise and/or mitigate adverse environmental impacts associated with our direct business operations.

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 jewellery products and materials. We further commit to disclosing information on the physical characteristics of jewellery products and materials in accordance with the Responsible Jewellery Council (RJC) Code of Practices Standard.

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

1. This policy confirms our commitment to respect human rights, to avoid contributing to the financing of conflict, and to comply with all relevant UN sanctions, resolutions, and laws.
2. As a member of the Responsible Jewellery Council (RJC), we commit to proving, through independent third-party verification, that we:
a. respect human rights according to the Universal Declaration of Human Rights and the International Labour Organization Declaration on Fundamental Principles and Rights at Work;
b. do not engage in or tolerate bribery, corruption, money laundering or financing 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 jewellery supply chain; and
f. are implementing the OECD Due Diligence Guidance 5-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.
4. Regarding serious abuses associated with the extraction, transport or trade of gold, silver, platinum group metals, diamonds and coloured gemstones: 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 labour;
c. the worst forms of child labour;
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 the abuses described in paragraph 4, or sourcing from or being linked to any party committing these abuses.
6. 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 coloured + gemstones 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 gold, silver, platinum group metals, diamonds and coloured gemstones are traded and upstream actors in the supply chain; or
b. tax or extort money, or minerals at mine sites, along transportation routes, or at points where gold, silver, platinum group metals, diamonds, and coloured gemstones are traded, or from intermediaries, export companies, or international traders.
7. 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.
8. 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.
9. Regarding bribery and fraudulent misrepresentation of the origin of gold, silver, platinum group metals, diamonds and coloured 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 coloured 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 coloured gemstones.
10. 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 coloured gemstones.
 
Karl Faller e.K expects all of its employees, suppliers and, where applicable, their subcontractors, to take all steps necessary to ensure that this policy is adhered to.
 

Company Grievance Procedure

Karl Faller e.K 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: Michelle Althöfer

Email: compliance@karl-faller.de

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 the appropriate internal person is to handle the grievance, or help redirect you to another entity, such as a relevant company, industry body, or other organisation.
  • Identify any actions we should take (if any) or monitor the situation.
  • Advise you of any decisions or outcomes.
  • Keep records of grievances received and the internal process followed to address them for at least 5 years.

Anonymous concerns or complaints can be submitted in writing to: Karl Faller e.K., Alte Talstraße 36, 55743 Kirschweiler, Germany OR by email to compliance@karl-faller.de.
Karl Faller e.K operates a strict non-retaliation policy in relation to all complaints and grievances raised through this procedure. All information provided will be treated as strictly confidential and will not be shared with any external party without the prior consent of the person(s) raising the concern, unless required by law.

The above policy is endorsed by Michelle Althöfer, Director
Approved on: 12.01.2026

Environmental Policy

  1. Purpose and Scope

Karl Faller is committed to conducting its business in a way that minimises negative impacts on the environment. This policy sets out the environmental principles and practices that apply to all employees and contractors working at our premises.

This policy covers day-to-day operations, including energy and water use, waste and recycling, packaging management and collaboration with our suppliers and customers.

  1. Our Commitments

2.1 Comply with applicable environmental laws and regulations

  • Meet all obligations under German law, including packaging and waste-related requirements, where applicable.

2.2 Use resources responsibly

  • Use electricity efficiently by switching off lights, devices and equipment when not in use and avoiding unnecessary use of heating, cooling and lighting.
  • Use water responsibly by avoiding wastage, reporting leaks promptly and using only the water needed for cleaning and other activities.

2.3 Prevent pollution and manage waste responsibly

Karl Faller applies the hierarchy: avoid, reduce, reuse, recycle, and only then dispose.

  • General waste: Separate waste correctly into designated bins (residual waste, paper/cardboard, recyclables). Avoid single-use items where practical.
  • Paper & cardboard: Reuse shipping boxes and packaging where safe and appropriate. If not reusable, place clean paper and cardboard in the designated recycling bins.
  • Poly mailers, poly bags and plastic packaging: Where feasible, reuse clean poly mailers and poly bags for internal shipments. Where reuse is not feasible, place them in designated recycling streams or follow return-to-supplier schemes.
  • Supplier-generated packaging: Reuse cardboard and packaging material where possible. When reuse is not feasible, place them in designated recycling streams or follow return-to-supplier schemes.
  • Printer cartridges & toner: Store used cartridges/toners in the designated container and return them through approved supplier take-back/recycling schemes. Do not dispose of them in general waste.
  • Use of eco-friendly and sustainable FSC printing paper.
  • CO2 compensation payments for orders.
  • Use of a Hybrid plug-in vehicle and an electric car.

 

2.4 Engage suppliers and partners

  • Prefer suppliers who minimise unnecessary packaging and offer recyclable or returnable solutions.
  • Encourage retail partners and stockists to handle Karl Faller packaging responsibly.
  1. Awareness and Policy Review

This policy will be reviewed periodically and, where necessary, updated to reflect Karl Faller’s evolving operations, legal requirements and environmental objectives. If employees have any questions, suggestions or concerns related to this policy or the company’s environmental management procedures, they should contact Ann Michelle Althöfer.