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Humans Rights Watch says Pandora stands out for disclosing human rights risks identified during audits


Pandora Ranking by HRW – Moderate

Pandora is a publicly-traded company founded in 1982. Its 2016 revenue was approximately $3 billion. Pandora sells its jewelry in more than 100 countries through over 8,000 points of sale and 2,100 stores. In 2016, the company crafted more than 122 million pieces of jewelry. Its main markets are the US, UK, Australia, Italy, and France.

It has over 22,000 employees; 13,000 are employed in Pandora’s manufacturing facilities in Thailand.

Pandora 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.

Pandora works with suppliers to achieve compliance with its standards and requires suppliers to be RJC-certified. It also conducts additional audits of suppliers on an occasional basis and publishes information on areas of noncompliance. However, it does not reveal its suppliers and Human Rights Watch considers the company to be overly-reliant on the RJC for its due diligence. On the basis of available information, Human Rights Watch considers Pandora to have made moderate efforts to ensure human rights due diligence.

Supply chain policy: Pandora’s Supplier’s Code of Conduct is part of all contracts with suppliers, and addresses human rights, labor rights, environmental protection, and business ethics.

The Supplier Code of Conduct does not apply to the suppliers’ full supply chain, but only to suppliers’ subcontractors involved in production and manufacturing. Pandora also has a Responsible Supplier Policy. Pandora requires each of its suppliers to be RJC-certified, and diamond suppliers to comply with the Kimberley Process and World Diamond Council System of Warranties. Unlike many other jewelry companies, Pandora has integrated manufacturing into its own operations, thus exerting direct control over working conditions in manufacturing and shortening the supply chain.

Chain of custody: While Pandora jewelry is most often made with silver, gemstones, and a range of other material, the company also sells jewelry made with gold or diamonds. Pandora states that in 2016, 91 percent of the gold it purchased was recycled; the rest was newly mined. Since late 2016, the company has only used recycled gold which helps minimize human rights risks in its gold supply chain. However, the company states that it may resume purchases of newly mined gold in the future. Any newly mined gold must be certified against the London Bullion Market Association (LBMA) or the RJC’s Chain-of-Custody Standard.

Between 2012 and 2016, all of Pandora’s diamonds were recycled from discontinued Pandora jewelry. When it sources new diamonds, Pandora requires invoices for each batch of diamonds to confirm compliance with the Kimberley Process and World Diamond Council System of Warranties. It does not trace diamonds to mines of origin, but says it is investigating the possibility of direct sourcing with full traceability.

Assessment of human rights risks: New suppliers are expected to conduct self-assessments on a broad range of criteria. Furthermore, Pandora visits suppliers’ production sites before entering into a contract.

Pandora also relies on the RJC certification and audit process to identify risks in the supply chain.
Response to human rights risks: When audits reveal areas of noncompliance, Pandora says it works with suppliers to implement corrective actions. If the supplier is not willing or able to meet expectations, Pandora says it may end its contract with the supplier.

Third-party verification: Pandora is certified against the RJC Code of Practices. Its gold and diamond suppliers are certified against the RJC’s Code of Practice. In addition to RJC audits, Pandora conducts additional audits of suppliers on an occasional basis.

Auditing generally extends only to production sites, not to mines, and visits are announced in advance. Pandora representatives also visit mine sites where “red flags” are identified or in relation to “new responsible business opportunities or support to fair mining programs.”

Report annually: Pandora publishes an annual ethics report that includes information on its sourcing of gold and diamonds and an overview of noncompliance issues identified at audited suppliers.

Publish suppliers: Pandora will not share information regarding its suppliers, citing nondisclosure agreements.

Support for artisanal and small-scale mining: Pandora says it is exploring the possibility of sourcing gold from artisanal and small-scale mines.


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