Responsible Business Practices

John Hardy is committed to ethical and responsible business practices. We conduct our business with respect to human rights and the environment and expect our business partners to share a similar belief. 

As such, we require all our business partners (hereafter “Contract Party”) to observe and apply the below Code of Conduct, in accordance with the current local laws and practices.

1. John Hardy’s Code of Conduct: 

Compliance with Laws and Regulations: Contract Party must comply with all applicable laws and regulations, United Nations (UN) and International Labour Organization (ILO) Convention and Recommendations, including local and national codes, rules and regulations, applicable treaties and industry standards and adopt publicly available policies, endorsed by senior management, to achieve this Code of Conduct.

Compliance with John Hardy’s Human Rights Policy: Contract Party must read and apply, at a minimum, the same level of Standards specified on John Hardy’s Human Rights Policy when conducting their business.

Environmental Compliance: Contract Party must comply with all applicable environmental laws and regulations and is encouraged to introduce appropriate management and operating systems to minimize its impact to the environment. Contract party should only dispose waste substances in compliance with Applicable law and take steps to reduce the quantity of waste/emissions produced and energy/natural resources used. Additionally, Contract Party must ensure the efficiency of their business operations in terms of consumption of natural resources including but not limited to water and energy. Contract Party should minimize the use of chemicals and/or hazardous substances wherever possible.

Bribery and Facilitation Payment: Contract Party must act against any form of bribery, consider bribery risk, and have appropriate procedures to monitor such risk. Contract Party must facilitate the reporting of potential bribery, apply sanctions for bribery/attempted bribery and implement appropriate controls to oversee all payment facilitation. There should be no penalty for voicing a concern or declining to pay a bribe under any circumstances.

Money Laundering and Finance of Terrorism: Contract Party must maintain audited financial accounts and acknowledge the identity of all organizations the Contract Party deals with. Any transaction that is of international scope may be subject to more than one regulation.

Diamonds and Stones: Contract Party must adhere to the Kimberley Process and the World Diamond Council’s System of Warranties and must not knowingly buy or sell Conflict Diamonds. Contract Party must ensure its Employees are informed and trained about these restrictions. Any material mined in Myanmar or Russia and supplied to John Hardy shall be clearly described and stated to John Hardy. 

Conflict Minerals: Contract Party must have a policy to reasonably assure any gold or silver materials does not directly or indirectly finance, or benefit armed groups causing serious human rights abuses. Contract Party must, to the best reasonable extent, ensure ethical sourcing and complete due diligence on the source and chain of custody of gold and silver, and make its due diligence measures available upon request.

Product Integrity: Contract Party must comply with any relevant and applicable trading standards legislation. Contract Party shall disclose all product physical characteristics properly, the product’s original sources wherever possible, and will not make any untruthful statement, representation or material omission. Contract Party shall disclose the fineness of gold and silver, apply the appropriate quality marks. Contract Party shall properly disclose the quality of diamonds and colored gemstones, including any treatments applied on these materials.

Updated: October, 2025 

2. Human Rights Policy

It is the policy of John Hardy[1] and our subsidiaries and affiliated companies to foster an organizational culture with respects to human rights and seek to avoid complicity in human rights abuses, in alignment with the principles contained within the International Bill of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.

This Policy applies to all employees of John Hardy entities and locations worldwide and by extension, to subcontractors working at our sites or providing products and services to us. If any employee believes that someone is violating the Human Rights Policy or the law, they are asked to report it immediately to their manager, Human Resources, Company legal counsel or grievance contact channel compliance@johnhardy.com.

John Hardy’s Human Rights Principles:

Child Labor: John Hardy prohibits employment of children younger than eighteen (18) years of age. In case local laws specify a minimum working age higher than or impose mandatory education beyond the age of eighteen (18), the local laws shall apply. John Hardy recognizes in particular the right of the child to be protected from economic exploitation and from performing any work that is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral or social development.

John Hardy complies with all their local legal requirements for young workers, particularly those pertaining to hours of work, wages, health and safety and general working conditions.

Forced Labor: John Hardy recognizes that the use of forced or involuntary labor and the restriction of employees’ freedom of movement are not permitted. Employees must be treated with dignity and respect, and any corporal punishment, threats of violence or other forms of physical, sexual, psychological, or verbal harassment must not be used against them. As for grievance procedures and investigation processes, they must be clear and clearly explained to all Employees.

Safety and Health: Workplace environment must comply with relevant applicable laws and industry standards so as to ensure a safe conduct of work. As such, John Hardy provides employees with the best possible human health and safety working conditions. John Hardy also ensures adequate and appropriate safety arrangements and hygienic conditions at the workplace. Employees must be appropriately trained as to safety and health measures. John Hardy has appropriate procedures in place, including installing alarms, establishing emergency procedures and evacuation plans, to prevent accidents, and provide access to on-site health and medical facilities. Any serious incidents should be formally investigated and documented.

Policy Against Unlawful Harassment, Discrimination, and Retaliation:  John Hardy is committed to providing a work environment that is free of unlawful harassment, discrimination, and retaliation. Further to this commitment, we strictly prohibit all forms of unlawful discrimination and harassment, which includes discrimination and harassment on the basis of race, religion, color, sex (including childbirth, breast feeding, and related medical conditions), sexual orientation, transgender status, national origin, citizenship status, uniform service member status, pregnancy, age, genetic information, disability, or any other category protected by applicable state or federal law.

This policy against unlawful harassment, discrimination, and retaliation applies to all employees of John Hardy, including supervisors and managers. It also applies to all customers, vendors, and independent contractors, as well as to unpaid interns and volunteers (all of whom are designated for purposes of this policy only as “Business Associates”). We prohibit managers, supervisors and employees from harassing subordinates or co-workers as well as our John Hardy Business Associates. Any such harassment will subject an employee to disciplinary action, up to and including immediate termination. In addition, we prohibit Business Associates from harassing our employees, unpaid interns and volunteers.

Workplace Violence Policy: John Hardy has a zero-tolerance policy for violent acts or threats of violence against our employees, applicants, customers or vendors.

We do not allow fighting, threatening words or bad conduct. No employee should commit or threaten to commit any violent act against a co-worker, applicant, customer or vendor. This includes discussions of the use of dangerous weapons, even in a joking manner.

Any employee who is subjected to or threatened with violence by a co-worker, customer or vendor, or is aware of another individual who has been subjected to or threatened with violence, is to report this information to their supervisor or manager and John Hardy People & Culture (P&C) as soon as possible. 

Working Conditions and Wage: John Hardy compensates employees for services rendered or to be rendered by providing them wages (for which payments are made on a regular and pre-determined basis by bank transfer or in cash or cheque form in a manner and location convenient to employees), including overtime hours at such premium rates, maximum hours, piece rates and other elements of compensation. Wages shall not, as a minimum standard, be lesser than those specified by national laws or current industry standards, should the latter provide better conditions for the employees; and wages shall cover a decent living. 

As such, John Hardy lays down conditions of work and wage for its employees, including appropriate and legal daily and weekly working hours, overtime work and the legal number of days of paid annual holiday leave, and weekly rest (as being part of Employee’s Right). John Hardy complies with applicable local laws and industry standards on working hours. John Hardy does not, except in special circumstances or as permitted by local law, expect employees to work more than the lesser of:

• 40 hours per week for regular working hours (excluding overtime),
• The limits on total working hours, including overtime, shall not exceed 60 hours per week in accordance with ILO standards.

Workers’ Right to Information and Consultation: John Hardy acknowledges and consents its employees or their representatives are, at the appropriate levels, guaranteed information and consultation in good time in the cases and under the conditions provided for by current domestic laws and practices.

John Hardy ensures its employees or their representatives the opportunity to be regularly and fully informed of the financial prospects of the company; Where employees’ interests would significantly be affected, including general terms of employment, information shall be given, and consultative bodies established as early as possible to ensure that proposals and viewpoints of the employees contribute to the management’s decision making process.

John Hardy’s employees have the opportunity to participate in relevant training programs to help them undertaking their respective functions. 

Right to Collective Bargaining: John Hardy recognizes employees’ right to associate, organize and bargain collectively in a lawful and peaceful manner, for the protection of their interests, without penalty or interference (as stated in the article 23 of The Universal Declaration of Human Rights and in ILO Conventions No. 87 and 98). John Hardy does not prevent collective bargaining and will adhere to collective bargaining agreements, where such agreements exist.

Security: The task of guaranteeing the security of our employees, assets, and facilities is developed with efficiency but also with total compliance with the laws and with respect to human rights. Security personnel must first try to resolve a security incident without using force. If this fails, they should only use the minimum force needed and offer help to anyone, including offenders, injured as a result. In the event of product security incident, John Hardy shall prioritize the security of employees, visitors, and other relevant business partners.

This Policy is aligned with John Hardy’s Code of Conduct, employee handbooks and company’s rules and regulations, which lay down a grievance mechanism for stakeholders to address and resolve issues or potential violations. Where we have identified that we have caused, contributed to or been linked with any adverse human rights impacts, we will take action to remediate the impacts through appropriate process.

This Policy and the RJC Human Rights Due Diligence assessments shall be annually reviewed and endorsed by the senior management and may be updated from time to time as required.

Updated: October , 2025

3. Supply Chain Policy

This policy confirms John Hardy’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

John Hardy is a certified member of the Responsible Jewelry Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

1. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Declaration on Fundamental Principles and Rights at Work;
2. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
3. support transparency of government payments and rights-compatible security forces in the extractives industry;
4. do not provide direct or indirect support to illegal armed groups;
5. enable stakeholders to voice concerns about the jewellery supply chain; and
6. are implementing the OECD five-step framework as a management process (and Supplement on Gold if applicable) for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas. 

We also commit to using our influence to prevent abuses by others.

Regarding serious abuses associated with the extraction, transport or trade of minerals and gold:

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

1. torture, cruel, inhuman and degrading treatment;
2. forced or compulsory labor;
3. the worst forms of child labor;
4. human rights violations and abuses; or
5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described above or are sourcing from, or linked to, any party committing these abuses.

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 diamonds or gold from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

1. control mine sites, transportation routes, points where gold is traded and upstream actors in the supply chain; or
2. tax or extort money, or gold at mine sites, along transportation routes or at points where gold is traded, or from intermediaries, export companies or international traders.

In alignment with the above paragraph, we only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme.

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 above.

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 above.

Regarding bribery and fraudulent misrepresentation of the origin of minerals and gold:

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals and gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals and gold.

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 minerals and gold.

Updated: October , 2025 

4. FY25 Responsible Business Practices Report

“This report covers our fiscal year from August 2024 to July 2025 and was updated on FY25.”

ISO 14001 – Environmental Management System Certification

Our Bali factory successfully passed its main certification audit again in May 2025. Meanwhile, our Bangkok factory passed its surveillance audit again in September 2024, demonstrating our ongoing commitment to compliance and operational excellence.

KPIs include full compliance with environmental regulations, ensuring 100% staff participation, proactive community engagement, and zero industrial waste to landfill.

• Waste Management – In addition to continuously applying the principle of minimizing industrial waste sent to landfill to zero, we have extended this approach to new types of waste each year. Over the past year, we explored the use of a belt press to reduce the volume of casting cement sent for disposal. Efforts have also been made to reduce landfill disposal of domestic waste, including food waste composters at Bali factory and partially at BKP. Domestic waste that is incinerated is processed into refuse-derived fuel (RDF) at JHT.

ISO 14064-1 – Greenhouse gas emissions verification

FY25, our GHG emissions for August 2024 to July 2025 were verified according to ISO 14064-1:

• Direct emissions: 156.73 tCO2e, remaining at a level similar to last year
• Energy indirect emissions
• Location based: 1,432.71 tCO2e, remaining at a level similar to last year
• Market based: zero tCO2e, decreasing 100% due to Renewable Energy Certificates (RECs) purchased and retired to match our total energy consumption.
• Other indirect emissions: 6,821.12 tCO2e, decreasing 18.62%

Supply Chain

We completed our supply chain due diligence in compliance with the RJC Code of Practices 2019, focusing on responsible sourcing and preventing adverse human rights impacts. This review covered gold, silver, diamonds, and colored gemstones.

The RJC recertification audit conducted between August and September 2024 confirmed that none of the materials purchased during the fiscal year originated from Conflict-Affected and High-Risk Areas (CAHRAs), and no human rights issues were identified.

The RJC Version 2024 and LMS audits are scheduled to take place in late 2026 (FY2026), reflecting our continued commitment to maintaining the highest standards of responsibility and compliance.

The percentage of raw material purchases from RJC members was 90.1% in FY24 and increased to 97.96% in FY25. In FY25, the company reduced the proportion of purchases from non-RJC-certified metal suppliers and increased purchases from RJC-certified suppliers accordingly.

Provenance Claim

We've long been proud of our use of reclaimed gold and silver. Visit Provenance Claim for details. As part of our commitment to this transparency, we now require all incoming invoices for gold and silver materials to include a reclaim source statement, in addition to the blanket statements we previously requested from suppliers.

Donations/Sponsorships:

About US$ 19,139 worth of donations/sponsorships were made to various organizations so far in our past fiscal year, as below:

• The Mirror Foundation: The Mirror Foundation is a Thai nonprofit organization dedicated to addressing social issues such as poverty, inequality, and human trafficking. The foundation focuses on community development, education, and humanitarian aid, working to empower underprivileged groups and promote sustainable social change across Thailand.

• JH x Silver Oak Auction: The JH x Silver Oak Auction is a collaborative charity initiative between John Hardy and Silver Oak Cellars aimed at supporting meaningful social and environmental causes. Through this auction, exclusive handcrafted jewelry pieces and fine wines are offered to raise funds that contribute to community development and sustainability projects.

• Sungai Watch: An environmental organization on a mission to stop plastic from going into the ocean in Bali Indonesia. By designing simple trash barriers and operating a collection, sorting and up-cycling system, they have created a scalable approach to tackling plastic pollution. Sungai watch is also actively engaged in community education and outreach work.

• Bali Children Foundation: The Bali Children Foundation is a nonprofit organization that provides educational opportunities to disadvantaged children in Bali and nearby islands. The foundation focuses on education, literacy, and community empowerment, helping children gain the skills and confidence needed to build better futures for themselves and their communities.

• Orphans and poor people: This local community surrounding KTI includes orphans and underprivileged families who receive ongoing support through donations and community outreach programs. The initiative aims to improve their quality of life, provide access to basic needs and education, and foster a sense of care and connection within the surrounding community.

 

[1] John Hardy’s subsidiaries include but not limited to, John Hardy USA Inc., John Hardy (HK) Limited, John Hardy (Thailand) Limited, Bangkok Kraft Productions Limited, PT. Karya Tangan Indah, PT. Kapal Bambu Perhiasan and PT. Jewelry Design Services.