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All that glitters is not gold

Dec 22

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22/12/2017 10:10  RssIcon

New report: Modern Slavery Reporting in the Jewellery Sector. Guest blog from Colleen Theron, Director, Ardea International. 

Our organisation, Ardea international, have recently published a report analysing the impact of the Modern Slavery Act (MSA) in the UK jewellery sector. The results were mixed to say the least with half of companies surveyed failing to meet the minimum standards set out in the legislation.

Under the new UK Modern Slavery legislation there is a requirement that companies of a certain size that supply goods in the UK produce an annual modern slavery statement setting out the steps they are tacking to tackle modern slavery. 


Image: Jewellery


Modern slavery and human trafficking is a global issue. The Walk Free Foundation estimates that there are 45.8 million people caught in slavery today. There is evidence that it affects almost every sector of the economy and that long and complex supply chains that rely on sub-contractors impede traceability making it challenging to verify that goods and services bought and sold are free from slavery. 

We were interested to see whether jewellery companies in the UK that are required to produce a modern slavery statement met the legal requirements of the MSA.

Did they have a statement published on their website?

Did they have a statement approved by the Board of Directors and signed by a Director? 

The UK Guidance for the Modern Slavery Act requires that the statement should set out what steps the companies have taken during the financial year to ensure that slavery and human trafficking is not taking place. As part of our research we examined their disclosures to see steps are being taken to address modern slavery issues? 

The role of certification schemes

We also examined the role of third party certification systems and industry regulatory systems (the Responsible Jewellery Council and the Kimberley Process) to understand their impact in addressing modern slavery in supply chains. The RJC has over 1000 members and creates a certification scheme. 

Compliance with the RJC Code of Practice means that members for the RJC are certified to show evidence of good practice in supply chains and must follow their provisions on different issues. The Kimber Process is an industry regulation scheme, an initiative of governments, industry and civil society to ensure conflict minerals do not enter the global diamond industry. 


Which jewellers did the report cover?

The report focused on eight of the major jewellers in the UK, namely the Signet Group (and the companies under its control), Tiffany & CO, Goldsmiths, Links, F. Hinds, Beaverbrooks, Boodles and Cartier.

We found that half of the eight jewellery companies investigated failed to publish a modern slavery statements on their website homepage, and only three fully met the disclosure requirements of the MSA. 

Our findings are backed up by recent research by the Business and Human Rights Research Centre  and CORE who found that across industry only 14% of statements released under the MSA are fully compliant with Section 54 of the MSA.

The history of the jewellery sector is tainted by human rights abuses. We have seen an increase in the number of children involved in child labour reported by the ILO, the vast majority of them being in Africa and 12% involved in mining.

As such, the likelihood that many businesses in this sector have either knowingly or unknowingly supported practices linked with human rights abuses at some point in their supply chains. Not many statements reflected these risks. 


Findings of companies included in the report

Here is a snapshot of our findings in relation to the legal compliance aspects of the MSA. 


Do they have a statement? 

Boodles have financial years beginning in April, and thus had until September 2017, to report under the MSA, when the report was released they had not done so. 


Is the statement published on their website? 




Do they have a statement?

Since the report was released Beaverbrooks have published their statement on their homepage and provided us with an official comment for the report stating that: 

Beaverbrooks, which has been a member of the Responsible Jewellery Council since 2009, is fully compliant with the requirements of the Modern Slavery Act and its statement is published on ‘ 

Is the statement published on their website? 




Do they have a statement? 

Cartier’s parent company, Richemont, has published a modern slavery statement. No link to the modern slavery statement is provided on the Cartier homepage so unless consumers/stakeholders are aware of the company structure, they would not be in a position
to review the statement.

Is the Statement published on their website? 

Cartier does not appear to have a statement on their homepage. However, Cartier’s parent company, Richemont, has published a modern slavery statement

Links of London

Does the company have a statement? 

Links also, at the time of the report going out for comment, did have a modern slavery statement published on their homepage, however, their parent company Folli Follie has published one. 

Is the statement published on their homepage? 

Since the report has been published, Links have updated their homepage with a link to the Folli Follie statement. It is however, not that easy to find. 



Do they have a statement? 

F. Hinds meets the MSA disclosure requirements as the statement is published on the homepage, is approved by the Board of Directors and is signed by a Director. In relation to the Signet Group’s subsidiary companies, most of them link to the Signet Group’s statement, but they do not have their own modern slavery statement. 

Is it on their homepage? 


The Signet Group ( this excludes all their subsideries) 

Do they have a statement? 


Is it on their homepage? 

The Signet Group’s modern slavery statement is published on the homepage of their website under the drop down ‘Responsible Sourcing’.  It does not address all its subsidiaries independently in the statement.



Do they have a statement? 


Is the statement published on their homepage? 

Goldsmiths have published their modern slavery statement on its homepage. 



Our conclusions

We recognise that companies with global supply chains have a challenge in ensuring that their practices are transparent, and that issues such as modern slavery and forced labour cannot be resolved overnight. 

However overall failure by the majority of the companies to be compliant with the requirements of the Modern Slavery Act raises many questions. Is it because there is a failure to enforce the requirements of the Act with financial or criminal penalties? Or, is the failure a result of a lack of understanding of the different reporting requirement of the MSA and the California Transparency in Supply Chains Act? Or, is the failure to disclose a result of risk averse lawyers writing the statements? 

The Kimberly process and Responsible Jewellery Council

Our findings also call into question the role and impact of the Responsible Jewellery Council and the Kimberly Process, and their impact on the disclosure practices of these companies.  

Whilst we recognise the role that the RJC and Kimberly Process play in addressing a number of the issues concerning the impact of human rights abuses, the loopholes in these organisations protocols and practices do not provide for complete supply chain transparency. The RJC is currently updating its Code of Practice so it will interesting to see any developments and whether they will address ongoing concerns about the limitations on audits as a sole mechanism to address modern slavery risk. 

Download and read the full report









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