Signet is making positive steps to responsible policies and practices

Signet Jewellers rankings by HRW – Moderate

Signet Jewellers Limited is the world’s largest retailer of diamond jewelry and the largest specialty jewelry retailer in the United States, United Kingdom, and Canada.

Signet operates approximately 3,600 stores under the name brands of Kay Jewelers, Zales, Jared, the Galleria of Jewelry, H. Samuel, Ernest Jones, Peoples Jewellers, and Piercing Pagoda. Its annual revenue is approximately $6.4 billion.

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Signet responded to Human Rights Watch’s request for information with a written, detailed letter and met with Human Rights Watch staff in person and by conference call.

Signet states that it has developed rigorous sourcing standards and is “leading the efforts to foster increasingly transparent and responsible jewelry supply chains around the world.”

Signet has responsible sourcing protocols for both gold and diamonds, but relies heavily on the RJC for its due diligence. Signet publicly identifies its key diamond suppliers, but does not reveal its gold suppliers. It does not publish the results of audits of its suppliers, or how it responds to cases of noncompliance. On the basis of available information, Human Rights Watch considers Signet to have made moderate efforts to ensure human rights due diligence.

Supply chain policy: Signet has a Supplier Code of Conduct that spells out expectations for its suppliers on human rights, labor, environmental, and other issues.

In 2012, Signet adopted a Responsible Sourcing Protocol (SRSP) for conflict-free gold, which it revised in 2016. The protocol states that Signet will only accept gold from refiners and banks that meet at least one recognized existing standard for conflict-free gold. Suppliers are required to define in detail which criteria are used to certify their gold supplies as compliant with the protocol, and are responsible for documentation, certification, and external audits. The protocol does not apply to watches and does not have requirements for human rights beyond ensuring that gold is “conflict-free.”

In 2016, Signet developed a Responsible Sourcing Protocol for Diamonds, which it revised in April 2017. It states that all suppliers are expected to join the RJC and include the Signet Protocol as a “provenance claim”—a statement about the origin of the material—for the purposes of RJC certification. Suppliers also must comply with the Kimberley Process and the World Diamond Council System of Warranties.

The Protocol requires suppliers to employ a due diligence process to identify and minimize supply chain risks, with respect to both human rights and armed conflict, and to document chain of custody for all diamonds of 30 points (approximately 1/3 carat) or larger. It does not require suppliers to trace smaller diamonds to the country and/or mine of origin, but “expects” suppliers to take steps to increase the percentage of material with identified provenance over time.

In 2016, Signet began requiring all suppliers to be members of the RJC.

Chain of custody: Signet’s Responsible Sourcing Protocol for Diamonds states that suppliers should seek as much information as possible about the original sources of the diamonds they supply to Signet. Suppliers should seek to achieve “full transparency” through their supply chains over a set period of time, and set measurable targets on an annual basis. Signet states that because this is requirement was added in 2016, it does not yet have information regarding these targets.

Signet’s Responsible Sourcing Protocol for conflict-free gold has no such requirement for progressive transparency.[232] Signet states that its priority is purchasing gold that is certified against recognized standards, such as the LBMA, “not that we know which mine it comes from.”

The Signet Responsible Sourcing Protocol for Gold requires suppliers to undertake due diligence, but only to ensure that products are “conflict-free.”

The Signet Responsible Sourcing Protocol on Diamonds is more rigorous, and states that suppliers will avoid contributing to human rights abuses through their sourcing practices, and requires suppliers to map their supply chain and employ due diligence to identify risks and take appropriate measures to mitigate any risks identified.  Signet expects its suppliers to monitor their own compliance with Signet’s Supplier Code of Conduct, and to undergo third-party audits for compliance with Signet’s responsible sourcing protocols.

Response to human rights risks: Signet states that if a supplier has difficulty with compliance, a dedicated Signet team will work with the supplier to address the issues. It states that most cases of nonconformance involve suppliers that are unable to provide sufficiently detailed information on their supply chains. It has not severed any relationships with suppliers because of noncompliance with its protocols, but has begun to sever relationships with suppliers that have not joined the RJC.

Third-party verification: Signet is certified against the RJC’s Code of Practices. Suppliers are expected to undertake an independent audit of their compliance with the protocol by a Signet-approved auditor. Signet waives these audits for RJC-certified suppliers who include a provenance claim referencing Signet’s protocols.

Signet’s audit guidance states that “The SRSP audit is a documentation audit of the suppliers’ compliance reports, to validate that these compliance reports are accurate and true. It is not an audit of the supplier’s supply chain.” Signet requires only summaries of the audits, stating whether or not the supplier is in compliance with Signet protocols. The Signet Audit Guidance indicates that audits may be conducted solely based on documentation provided by the supplier. On-site visits to facilities or mines are not required.

Report annually: In 2016, Signet published its first corporate social responsibility report. The report includes information regarding Signet’s responsible sourcing protocols and its support for projects to develop responsible artisanal mines. It does not provide any information regarding audits of suppliers, noncompliance information, or steps to address noncompliance.

Publish suppliers: Signet states that it purchases rough diamonds from De Beers, ALROSA, and Rio Tinto. It also purchases diamonds from additional suppliers that comply with the Kimberley Process. It does not publish the names of its gold suppliers.

Support for artisanal and small-scale mining: Signet is participating in a multi-stakeholder group, the Responsible Artisanal Gold Solutions Forum (RAGSF), that aims to develop a process of sourcing responsibly managed, artisanally-mined metals from conflict-affected regions. Signet states that it is committed to including gold from these projects in its supply chain in the future. Signet also supports the Diamond Development Initiative that works to help formalize and promote responsible artisanal diamond mining.

In response to the report, Signet has provided the following statement:

“Certified Responsible Jewellery Council (RJC) membership is a requirement for all Signet suppliers because it assures Signet and its customers that suppliers practice responsible sourcing. RJC membership reinforces Signet’s industry leadership position on responsible practices and requirements in the areas of human rights, health and safety, and labor practices throughout the global Signet supply chain.

“Moreover, RJC Provenance Claims provide independently certified assurance about Signet’s gold supply chain.  Since 2014, Signet has been the only jewelry company to provide independently audited “conflict-free” gold reports annually to the SEC, and will continue to do so.

“As an industry leader, Signet continues to support frequent reviews and continuous improvement in the RJC standards.  Given this worldwide recognition for RJC standards, Signet is disappointed at HRW’s inaccurate characterization and misrepresentation of the information and welcomes HRW to engage more constructively with the RJC and other participants in the jewelry industry.”

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