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Hockley Mint Ltd

Human Rights and Supply Sourcing Policy

1. This policy confirms Hockley Mint Ltd.'s commitment to ethical and responsible sourcing. We pledge to respect human rights, avoid contributing to the finance of conflict, comply with all relevant UN sanctions, resolutions, and laws, and uphold the highest environmental, social, and governance (ESG) standards.

2. Hockley Mint Ltd. is a certified member of the Responsible Jewellery Council (RJC). Through independent third-party verification, we demonstrate that we:

a. Respect human rights in accordance with the Universal Declaration of Human Rights and International Labour Organization (ILO) 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 in government payments and ensure security forces act in compliance with human rights standards;
d. Do not provide direct or indirect support to illegal armed groups;
e. Enable stakeholders to raise concerns regarding the jewellery supply chain;
f. Implement the OECD five-step framework as a risk-based due diligence process for responsible mineral supply chains in conflict-affected and high-risk areas.

3. Hockley Mint Ltd. is committed to ethical gold sourcing and actively supports Fairtrade and Fairmined Gold initiatives. We ensure that:

a. Small-scale and artisanal miners receive fair wages and safe working conditions;
b. Our gold supply chain promotes social development and environmental protection;
c. Certified Fairtrade and Fairmined Gold is traceable, ensuring transparency and ethical practices.

4. As part of our sustainability strategy, we integrate ESG principles into our business operations. This includes:

a. Using 100% recycled gold for our wedding rings;
b. Striving for carbon neutrality by 2030;
c. Reducing waste and energy consumption through innovative manufacturing techniques; d. Supporting local communities and fostering a diverse, inclusive workplace;
e. Encouraging responsible sourcing practices throughout our supply chain.

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

6. Regarding serious abuses associated with the extraction, transport or trade of minerals: 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.

7. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 6 or are sourcing from, or linked to, any party committing these abuses.

8. Regarding direct or indirect support to non-state armed groups: We only buy or sell diamonds that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds 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 diamonds are traded and upstream actors in the supply chain; or
b. tax or extort money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.

9. 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.

10. Regarding public or private security forces: We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 6 or that act illegally as described in paragraph 8.

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

12. 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.

13. Our diamonds are purchased from legitimate sources not involved in the funding of conflict, in compliance with United Nations Resolutions and corresponding national laws. The seller hereby guarantees that these diamonds are conflict-free and confirms adherence to the WCO SoW Guidelines. Our diamonds are exclusively of natural origin and untreated, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.

14. Grievance process: Hockley Mint Ltd. 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: Gary Wroe
Email: gary.wroe@hockleymint.co.uk

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 is the appropriate person internally 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; and;
• Keep records on grievances received and the internal process followed to address such grievances, for at least five years.

Name: Gary Wroe
Position: Managing Director
Date: 19th March 2025
Review date 21
st April 2029