Ethics & Compliance
Repossi and its employees are committed to the highest ethical and compliance conducts, values and principles which serve as the foundation of Repossi’s global corporate culture at each level.
At Repossi, we believe in transparency, integrity, and accountability, ensuring that our employees can trust in our commitment to act in the right way. The ethics and compliance values and principles define our organization and promote a culture of integrity and responsibility. Repossi truly encourages the ethics and compliance values and principles diffusion within its companies.
To this regard, Repossi has defined ethics and compliance policies designed to prevent, detect and correct violations and misconducts within its organization.
Repossi, being part of the LVMH group, adhere to the following codes, policies, and alert line system which constitute the Repossi’s main ethics and compliance standards:
> Find out more about the LVMH Alert Line
> Access Suppliers Code of Conduct
> UK Modern Slavery Act 2015 - 2021 & 2022 Statement
Responsible Purchasing Policy
1) The Maison REPOSSI is one of the jewellery Houses of the LVMH Group. This policy confirms REPOSSI's commitment:
(a) to respect human rights,
(b) to avoid contributing to the financing of conflicts,
(c) to comply with all relevant United Nations sanctions, resolutions and law,
(d) to combat money laundering in situations where we identify a reasonable risk.
2) Maison REPOSSI is a certified member of the Responsible Jewellery Council (RJC). As such, we are committed to proving, through independent third party verification, that we :
(a) Respect human rights under the Universal Declaration of Human Rights and the International Labor Organization Declaration on Fundamental Principles and Rights at Work;
(b) Do not participate in or tolerate any form of corruption, money laundering or financing of terrorism;
(c) Support the transparency of payments from governments and security forces in the extractive industries that comply with rights;
(d) Do not provide any direct or indirect support to illegal armed groups;
(e) Allow third parties involved in the process to express their concerns about the supply chain in the jewellery sector via our email address ethic-compliance@repossi.com on our website www.repossi.com.
(f) Only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme;
(g) Implement the OECD's five-step framework as a management process to conduct risk-based due diligence to ensure responsible supply chains for gold, silver, precious metals from platinum mines, diamonds and colored stones from high-risk conflict areas (CAHRA).
3) Concerning gross violations in the extraction, transport or trade of gold, silver and platinum mine metals, diamonds and colored stones:
We will not tolerate, assist or facilitate in any way the commission of the following acts, nor will we benefit from or contribute to them:
(a) Torture or cruel, inhuman and degrading treatment;
(b) Forced or compulsory labor;
(c) The worst forms of child labor;
(d) Violations and abuses of human rights or fundamental freedoms; or
(e) War crimes, other flagrant violations of international humanitarian law, crimes against humanity or genocide.
We will cease all relationships with upstream suppliers if we identify a risk that reasonably indicates that they are engaged in, are sourcing from, or are associated with the violations referred to in paragraph 3.
4) Concerning direct or indirect support to non-state armed groups (NSAGs):
We will not tolerate any direct or indirect support to NSAGs or their affiliated entities - including through the provision of gold, diamonds or precious stones, the payment of money, or the provision of logistical, material or other assistance - illegally engaged in the following activities:
(a) Illegal control of mine sites or transport routes, diamond or mineral trading points and actors upstream in the supply chain.
(b) The legal taxation or extortion of silver, gold, diamonds or precious stones at mine sites, transport routes or trading points or against intermediaries, exporting companies or international traders.
We will immediately cease all relationships with upstream suppliers if we identify a reasonable risk that they are sourcing from or are linked to third parties directly or indirectly supporting NSAGs such as those referred to in paragraph 4.
5) Concerning public or private security forces:
We affirm that the role of public or private security forces is to ensure the security of workers, facilities, equipment and property in accordance with the rule of law, including legislation that guarantees human rights. We will not provide any direct or indirect support to public or private security forces that commit the abuses described in paragraph 3 or act unlawfully as described in paragraph 4.
6) With regard to bribes and misrepresentation of the origin of gold, silver, platinum mine metals, diamonds and colored stones :
We shall refrain from offering, promising or giving bribes for the purpose of concealing or disguising the origin of materials, making false statements concerning taxes, duties and royalties paid to governments for the extraction, trade, processing, transportation and export of gold, silver, platinum mined metals, diamonds and colored stones.
7) Concerning money laundering :
Money laundering is the process of concealing the nature and source of money or other property related to criminal activity, such as drug trafficking, terrorism, corruption or bribery, by integrating illicit money or property into the flow of trade so that it appears legitimate or so that its true source or owner cannot be identified.
Those involved in criminal activity try to hide the proceeds of their crimes or make them appear legitimate by 'laundering' them through legitimate businesses. Similarly, terrorism can be financed by legitimate funds, sometimes called "blackmailing" because a legitimate business is used to finance criminal activity.
We will support efforts to contribute to the elimination of money laundering in situations where we identify a reasonable risk of money laundering resulting from or related to the extraction, trade, processing, transportation or export of gold, silver, platinum mined metals, diamonds and colored stones.
The money laundering process is generally a three-step process, in separate or distinct phases, which may involve numerous transactions. Any one of these transactions or steps could involve a company or its employees:
(a) The first step is the investment of funds in the economy. This is a means by which material proceeds from illegal activities are physically disposed of in the market. This is usually done through the purchase of goods, through deposits in financial institutions, through the creation of "ghost" enterprises, etc. The second step is the investment of funds in the economy.
(b) The second step is to separate the illicit proceeds from their sources (the layering) by creating complex layers of financial transactions designed to conceal the audit trail and ensure anonymity. This step will generally depend on the steps or activities carried out during the placement stage. For example, after making a deposit to a bank account during the investment stage, a money launderer could make several transfers and transactions to move the deposited funds to conceal the initial deposit. The investment and overlay is usually done through a third party.
(c) The third step is to try to make the proceeds of the illegal activities fully legitimate (reintegration). If the reintegration process has been successful, integration systems return the laundered proceeds to the economy in such a way that they appear to be legitimate funds for the financial system. For example, the proceeds of crime could be used to buy a third-party business, which carefully follows the regulations, and the profits of the business are then transferred to the criminal enterprise in a way that appears legitimate.
We will support efforts to help eliminate money laundering in situations where we identify a reasonable risk of money laundering resulting from or related to the extraction, trade, processing, transportation or export of gold, silver, platinum mine metals, diamonds and colored stones.
