At Lucira Jewelry, we believe that fine jewelry is not merely an accessory; it is a celebration of life's most meaningful moments. As we design and craft the pieces our customers love, we are equally committed to making them responsibly, sustainably, and ethically.

This commitment extends across our production ecosystem—from raw material sourcing and manufacturing to branding and distribution. We aim to create a positive impact by empowering communities, fostering ethical craftsmanship, and contributing to a healthier planet.

To achieve this, we use our reach and resources to drive meaningful change, and we expect our suppliers to uphold the same standards. This Supplier Code of Conduct outlines the principles that all our partners must follow regarding human rights, fair labor practices, environmental responsibility, and ethical business conduct.

Applicability

This Code applies to all Lucira Jewelry suppliers, their affiliates, agents, subcontractors, and any other party providing goods and/or services, directly or indirectly. Suppliers must ensure this Code is understood and followed throughout their network, making its requirements known to all workers in a language they understand, including local languages as required in India.

Legal & Regulatory Compliance

All suppliers must comply with applicable Indian laws and international ethical standards, including the International Labour Organization (ILO) conventions, the United Nations Global Compact, and the Guiding Principles on Business and Human Rights. Suppliers must maintain accurate records and provide access to audits to verify compliance.

Labor & Human Rights

No Forced or Bonded Labor

Suppliers shall not engage in forced, indentured, debt-bonded, or convict labor. Retention of personal documents, withholding wages, or any form of coercion is prohibited, in compliance with the Bonded Labour System (Abolition) Act, 1976, and Prevention of Human Trafficking Act, 2013.

No Child Labor

Employment of children under 14 is strictly prohibited as per ILO Convention 138 and Indian law. Young workers (14–18) must not perform hazardous work and must be employed under legal vocational programs, per the Child Labour (Prohibition and Regulation) Act, 1986.

Fair Wages & Working Hours

Suppliers must comply with the Factories Act, 1948, ensuring statutory wages, regulated working hours, and mandatory rest days. Overtime must be voluntary and fairly compensated.

Safe & Respectful Workplace

A workplace free from harassment, abuse, discrimination, or coercion is mandatory. Compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013, and a grievance mechanism must be in place.

Non-Discrimination Policy

Employment decisions must be based on merit and job performance. Suppliers must comply with Indian anti-discrimination laws, including Article 15 & 16 of the Constitution of India.

Anti-Harassment Policy

Suppliers shall prohibit all forms of harassment, including sexual, physical, or verbal abuse. Compliance with workplace harassment laws is mandatory, and a grievance mechanism must be in place.

Environmental Responsibility

Suppliers must comply with the Environment (Protection) Act, 1986, and other relevant Indian environmental laws. They must implement sustainable practices, monitor environmental performance, and minimize their carbon footprint in accordance with the Central Pollution Control Board guidelines.

Product Quality & Safety

Product Disclosure

Suppliers must provide accurate details on materials and product quality, including compliance with Bureau of Indian Standards (BIS) and international disclosure standards. Measures must be taken to prevent undisclosed synthetic diamonds from entering Lucira Jewelry’s supply chain.

Traceability & Transparency

Traceability and transparency are key to avoiding unintended negative impacts at any stage of the jewelry-making process. Suppliers shall provide accurate traceability information related to raw materials, processing, and final assembly of all products manufactured for Lucira Jewelry. Suppliers shall implement consistent inventory controls across their supply chain to ensure sourcing data is available for all raw materials used. Suppliers are encouraged to complete Reasonable Country of Origin Inquiries (RCOI) for materials entering the recycled market and shall report the annual percentage of mined, pre-consumer, and post-consumer recycled precious metals from their suppliers in their smelting and refining processes.

Non-Mined Materials

Materials such as pearls, leather, and paper must be responsibly sourced in compliance with Indian laws and best industry practices.

Health & Safety Standards

Suppliers must ensure a workplace that meets occupational health and safety laws. Provide:

• Clean drinking water
• Adequate sanitation
• Fire safety systems
• Personal protective equipment (PPE)
• Regular safety training and emergency preparedness drills

Supply Chain Responsibility

Suppliers are accountable for ensuring that their subcontractors and business partners adhere to this Code. They must conduct due diligence to prevent human rights violations and environmental harm, aligning with the OECD Due Diligence Guidance for Responsible Supply Chains.

Monitoring & Compliance

Lucira reserves the right to conduct audits, inspections, and assessments of supplier facilities, including document reviews and employee interviews. Suppliers must cooperate fully and address compliance violations promptly.

Enforcement & Consequences

Non-compliance may result in contract termination, financial penalties, or suspension of business relations. Severe violations, particularly involving child labor, forced labor, or environmental negligence, may lead to legal action and permanent exclusion from Lucira Jewelry’s supply chain.

Acknowledgment & Agreement

Suppliers must communicate this Code to employees and ensure its adoption throughout their supply chain. Lucira Jewelry and its agents may conduct unannounced inspections. Suppliers must maintain accurate records and commit to resolving non-conformance issues within specified timelines. Lucira Jewelry reserves the right to update this Code, and suppliers must adhere to the most current version.

This Code aligns with internationally recognized principles, including the Ethical Trading Initiative, ILO Standards, UN Guiding Principles on Business and Human Rights, SA 8000, and OECD Guidelines.

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