Lucira Jewelry, a company incorporated and operating under the laws of India, reaffirms its unequivocal commitment to ethical business conduct and respect for human rights. This policy serves to formalize the brand’s zero-tolerance stance toward all forms of modern slavery, including but not limited to forced labor, bonded labor, child labor, servitude, and human trafficking, whether occurring within its own operations or in the operations of entities with which it conducts business.

This policy has been formulated in strict accordance with applicable Indian legislation and in recognition of international human rights standards, including the United Nations Guiding Principles on Business and Human Rights and the International Labour Organization (ILO) Conventions to which India is a signatory.

The Company expressly adheres to the following legislative enactments:

Bonded Labour System (Abolition) Act 1976

This renders the bonded labor system illegal and void ab initio, prohibits any form of service arising out of debt or coercion, and mandates the release and rehabilitation of individuals subjected to bonded labor practices.

Child Labour (Prohibition and Regulation) Act 1986

This prohibits the employment of children below the age of 14 in all occupations and processes, and regulates the conditions of employment of adolescents aged 14 to 18, including working hours, rest intervals, and safety requirements.

Factories Act 1948

This governs working conditions in factories, prescribes maximum working hours, mandates adequate health and safety measures, and requires proper record-keeping and periodic inspection to ensure labor welfare and workplace compliance.

Minimum Wages Act 1948

This establishes the statutory obligation to pay minimum wages for scheduled employment, thereby preventing exploitative wage practices and ensuring a basic standard of living for all workers.

Indian Penal Code 1860

Under Sections 370 and 374, criminalizes trafficking for the purpose of exploitation, including physical and sexual exploitation, slavery, and practices similar to slavery or forced labor, and prohibits unlawful compulsory labor.

Whistle Blowers Protection Act 2014

This provides a statutory mechanism for the reporting of acts of corruption or abuse of power, including labor rights violations, while ensuring the protection of whistleblowers against retaliation.

In addition to the aforementioned policies, the company undertakes comprehensive due diligence procedures to identify, mitigate, and remediate risks associated with modern slavery. These include the conduct of both scheduled and unannounced audits of suppliers, the implementation of corrective action plans in cases of non-compliance, and the inclusion of contractual termination clauses for breaches relating to labor exploitation. All new suppliers undergo a mandatory onboarding review, which includes an evaluation of labor practices and legal compliance, particularly with respect to Indian employment laws.

Lucira Jewelry engages in ongoing risk assessment activities to map its supply chain against known indicators of vulnerability to modern slavery. These assessments are informed by government labor surveys, socio-economic reports, and industry-specific risk indicators. The Company commits to partnering only with entities that are demonstrably in compliance with Indian labor laws and possess relevant certifications, such as BIS registration, where applicable.

To monitor adherence and promote accountability, the Company conducts annual compliance reviews, encourages anonymous grievance submissions through dedicated reporting channels, and ensures that all reported incidents are investigated and resolved in a timely and documented manner. All labor records are maintained in accordance with the provisions of the Factories Act, 1948, and related enactments to facilitate inspection and promote workforce welfare.

Lucira Jewelry further acknowledges that combating modern slavery is an ongoing obligation that necessitates continuous evaluation and improvement. Accordingly, this policy is reviewed annually or as necessitated by legal or operational developments. The Company also engages with civil society organizations and ethical trade initiatives, such as the India Committee of the Netherlands (ICN) and the GJEPC, to align its practices with emerging standards and to foster systemic change.

In addition, regular training sessions are conducted to educate employees and management on the identification and prevention of modern slavery risks, with specific reference to Indian labor law and the Company’s internal protocols.

This policy has been formally approved by the Founder of Lucira Jewelry and shall be deemed effective as of the date of such approval. The policy shall be publicly available and binding upon all parties associated with the company.

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