Boodles ranking by HRW – Weak

Boodles is a family-owned UK jeweler, founded in 1798. Its 2016 revenue from jewelry was approximately $57 million. The company operates nine stores in the UK and Ireland, including five in London.

Boodles 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.


Overall, Boodles shares almost no information publicly about its supply chain and human rights due diligence. Its code of conduct for suppliers is very general and does not require third-party audits. Historically, the company has relied heavily on its suppliers to address human rights risks.

On the basis of available information, Human Rights Watch considers its human rights due diligence to be weak, with few steps towards responsible sourcing. However, in its interactions with Human Rights Watch, Boodles has stated that it wishes to do more, and pledged to take important additional steps to strengthen its human rights due diligence.

Supply chain policy: Boodles has a Code of Conduct for its diamond suppliers that requires suppliers to respect fundamental human rights, prohibit discrimination and child labor, commit to “high levels” of health and safety in the workplace, and provide employees with a living wage. It also states that suppliers must adhere to the Kimberley Process and the World Diamond Council System of Warranties, and ensure that all diamonds have been purchased from “legitimate” sources that are not involved in funding conflict.

The Code is not made public. The company has pledged to develop a comprehensive code of conduct for all gold and diamond suppliers, to require suppliers to become certified under the RJC Code of Practices, and to make its code public.

Chain of custody: Boodles does not trace its gold or diamonds to mines of origin. Boodles does not purchase gold directly, but has subcontracted workshops that source gold from three suppliers it describes as “trusted.” Boodles estimates that 35 percent of its gold is recycled.

Boodles initially told Human Rights Watch that it was “satisfied with the integrity of our suppliers,” but in October 2017, informed Human Rights Watch that it recognized more needed to be done to ensure Boodles sources responsibly. The company informed Human Rights Watch that it had engaged in a conversation over the need for robust human rights due diligence with one of its diamond suppliers, and that it was intending to do the same with other diamond suppliers.

Assessment of human rights risks: Boodles began a self-assessment against the RJC Code of Practices in 2017, and has started to conduct a more thorough assessment of its suppliers’ human rights due diligence, as described above. Previously it had not conducted its own assessment of human rights risks or undertaken its own site investigations, and stated that “we rely on our trusted suppliers to identify and mitigate against human rights risks.”

Boodles shared the sourcing policies of its three gold suppliers with Human Rights Watch. The policies varied in rigor. One, for example, appeared to conduct fairly robust human rights due diligence, including audits of its mining counterparts by both the supplier and third-parties, while another supplier’s policy focused only on providing gold that is “conflict-free.”

Response to human rights risks: Boodles has relied on its suppliers to respond to human rights risks in its supply chain. It has not ended any business relationships because of human rights concerns.

In October 2017, Boodles stated that it will begin requiring regular suppliers to provide the results of third-party audits, and that areas of noncompliance will be assessed and remedied through activities such as site spot visits conducted by Boodles or a third party. It also indicated that it will work with suppliers to take corrective action, if necessary, and consider severing contracts with noncompliant suppliers.

Third-party verification: The company has not had audits to verify compliance with standards on responsible sourcing or mining. Boodles joined the RJC in 2017, and was undergoing an audit against RJC standards in January 2018. It has indicated it plans to begin requiring suppliers to become RJC members and undergo RJC audits.

Annual reporting: Boodles has not reported publicly on its human rights due diligence. It states that it will begin doing so in 2019, with support from the RJC or other actors. It plans to report on summary information of audits, areas of noncompliance, and remedial activities.

Publish suppliers: Boodles does not publish the names of its suppliers, but shared the names of its gold and diamond suppliers with Human Rights Watch on a confidential basis. It says it would be willing to publish the names of its gold suppliers with their prior consent, but for “commercial and competitive reasons,” it prefers not to publicly disclose the names of its diamond suppliers.

Support for artisanal and small-scale mining: Boodles has not sourced from artisanal mines and does not support initiatives that seek to develop responsible small-scale mines, but states that it will do so “as suitable opportunities arise and there is an identified business need.”