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TABLE OF CONTENTS

I/CODE OF CONDUCT
II/RJC CERTIFICATION (RESPONSIBLE JEWELLERY COUNCIL)
III/KIMBERLEY PROCESSUS
IV/UK MODERN SLAVERY ACT 2015 STATEMENT

 


I/FRED CODE OF CONDUCT

1. FOREWARD

The LVMH Group (“LVMH”) aims to be the undisputed leader of the luxury goods sector. Its growth and long-term future are based on values and principles which are part of its culture and which should inspire and guide everyone’s actions.

This ambition is backed up by the five fundamental values shared by everyone involved in LVMH:

• Innovation and creativity: because our future success will come from the renewal of our product offering while respecting the roots of our Houses.
• Excellence of products and services: because we embody what is most noble and accomplished in the artisan world.
• Brand image enhancement: because our brands represent an extraordinary asset, a source of dreams and ambitions.
• Entrepreneurship: because this guarantees our ability to react and our motivation to create and seize opportunities.
• Leadership–Be the best: because it is through continually excelling that we accomplish the best and achieve the best results.

First and foremost LVMH is a galaxy of brands which share the same culture of excellence and creative spirit, serving the aspirations of our customers.
The brands are structured around larger entities, category business groups, where a spirit of friendly competition fosters an exchange of ideas and experiences. In accordance with the principle of subsidiarity, LVMH asserts the primary position of the brands in the organization and recognizes the richness and diversity of the models developed by each of them. It respects their unique character and lines of development, and acts as the leader of a creative community where knowledge is shared.
The principles set out in the following Code of Conduct constitute an ethical and practical framework within which LVMH employees are invited to act and exchange in order to realize the passion that binds them.
Respect for national and international laws, regulations and rulings, notably in the area of social and environmental legislation, is a prerequisite for the credibility of our procedures. LVMH invites its employees to use in a responsible way, the values and principles hereby stated.
This Code of Conduct is at the same time inspired by the values of  LVMH, of FRED, as well as the principles of the Universal Declaration of Human Rights, the Global Compact and the OECD Guidelines for Multinational Enterprises, and the principles of the Responsible Jewellery Council.
It provides the foundation on which our approach is based. More specific areas are covered in the Environmental Charter and the Suppliers’ Code of Conduct.
Finally, this Code of Conduct unites the fundamental principles which represent our shared commitment and serves as a guide for our professional conduct on a daily basis. It evokes the principles of conduct that drive us.
 

2. PRINCIPLES

2.1- VALUING TALENTS

Enriching its talent pool

FRED encourages a diversity of profiles and backgrounds in order to promote its international image and to combine creative energy within its teams.
FRED recognizes the richness of talents and know-how of the men and women in the Group. It is careful to ensure equality for all its employees in the area of employment and development, providing equal opportunities on objective criteria. Gender equality is a key aspect of its equal opportunity policy. All forms of discrimination are prohibited.

Encouraging personal development

FRED offers its employees a fulfilling working environment in order to encourage trusting and collaborative relationships. FRED, therefore, specifically:
• encourages loyalty and mutual respect in professional relationships;
• does not accept any form of discrimination or harassment;
• does not accept any form of physical violence, or verbal or psychological harassment;
• respects employees’ private lives.
FRED promotes for all employees the respect of a good balance between personal and professional life.

Encouraging initiative

FRED encourages individual responsibility in its employees, which goes hand in hand with the creativity and initiative expected from individuals. To this end, FRED values:
• a high level of impartiality in inter-personal relationships;
• management by example;
• that employees demand of themselves the highest levels of quality in the execution of their work;
• a good balance between initiative and the limits of professional expertise and responsibilities.

Between employees concerned by a same event, function or mission, as well as towards hierarchy, FRED prohibits any deliberate indiscretion, withholding of information, denigration or refusal to collaborate.

Developing employment

FRED encourages the movement of its employees within the Group, ongoing training and personal development.
FRED develops category-specific know-how through training initiatives.
FRED promotes the development of young talent within the Group, notably through education, integration, training and mentoring.

FRED complies with national regulations and legislation in the area of employment for the disabled and participates in initiatives which encourage their integration into the workplace.

Respecting fundamental rights and principles in the workplace

FRED respects and defends the principles of the Global Compact in relation to fundamental rights and principles in the workplace, namely:
• elimination of professional and employment discrimination;
• freedom of association and effective recognition of the right to collective bargaining;
• elimination of any form of forced or bonded labor;
• effective abolition of child labor.

Promoting dialogue with employee representatives

FRED encourages quality dialogue and consultation with employee representatives as well as the respect and consideration for employee representatives in each of the countries where it has a presence.

Looking after health and safety in the workplace
FRED cares about the health and safety of all its employees, makes sure that all its activities respect current health and safety legislation and regulations and pays particular attention to implement best practice with regard to safety in the workplace.

 

2.2- WINNING THE TRUST OF CUSTOMERS

Sustaining the quality and safety of products

FRED is continuously looking to offer its customers products of the highest quality, through improvement and innovation and the highest of standards in the selection of materials and the implementation of expertise in its activities.

FRED cares about the health and safety of its customers, notably in accordance with the precautionary principle, in the design and manufacture of its products.

Respecting customers

FRED is committed to supplying its customers with sincere and clear information and to not making any misleading statements concerning its products and their methods of production.

FRED is careful that personal information submitted by its customers is treated with confidentiality.

Responsible communication

FRED is aware of the impact on society of its products and their image. LVMH is therefore committed to the highest levels of vigilance in the advertising of its brands by implementing responsible communication which encourages its customers to use its products in an appropriate and reasonable manner.

 

2.3- COMMITMENT TO THE PRESERVATION OF THE ENVIRONMENT

Promoting collective commitment

FRED, through all of its brands, employees and partners, is committed to continuously improving its practices with a view to maintaining the highest level of environmental performance.

Preserving natural resources and integrating the environmental dimension into products
FRED recognizes that the long-term future of its brands and products is based on a constant desire to preserve and respect natural resources, the main raw materials of a large number of its products.

Anticipating environmental risks

Through scrupulous monitoring and the application of the precautionary approach, LVMH is careful to manage its environmental risks through strict respect of the best practices.

 

2.4- IMPLEMENTING AND PROMOTING A RESPONSIBLE APPROACH

Responsible behavior towards partners

FRED is committed to maintaining equitable and loyal relationships with its partners (suppliers, distributors, subcontractors, etc.).

FRED will inform all of its commercial partners of its ethical principles and expectations. FRED asks its suppliers to comply with the principles set out in the Suppliers’ Code of Conduct. This code specifies the demands in the areas of social issues (forced labor, child labor, harassment, discrimination, pay, working time, freedom of unions, and health and safety), environmental and operational issues (legality, custom tariffs, safety, subcontracting and corruption).

Fighting against corruption

FRED prohibits any form of corruption. Any payment must reflect a service and legitimate price as described in the contracts and agreements.
FRED only authorizes gifts and invitations in the usual social and commercial situations.

FRED is committed to operating independently in public life. FRED prohibits the payment of money to political parties, trade unions or cultural organizations in an attempt to promote a particular interest or obtain or maintain an advantage. Employees are invited to voice any situation they consider as a risk of corruption.  Employees must also be aware that they will not suffer demotion, penalty or other adverse consequences for voicing a corruption, or refusing to pay a bribe or facilitation payment even if this action may result in the company losing business.

Respecting competition

FRED is concerned about preserving fair competition respecting laws and practices in force, without any interference with competition rules.

FRED prohibits any unlawful agreements, notably through understandings, projects, arrangements or behaviors which have been coordinated between competitors concerning prices, territories, market shares or customers.

Preventing conflicts of interest

All employees can find themselves confronted with situations in which their personal interest, or that of private individuals or corporations with whom they are linked or close to, can come into conflict with the interests of FRED. Employees must, when taking stakes in other companies and in their activities outside the Group, do everything possible to avoid finding themselves in situations of conflicting interests with FRED or any other linked company.

In this matter, it will be the employee’s responsibility to determine a course of action in all honesty and taking into account their duty of loyalty towards FRED, and if in doubt to consult their line manager. The employee must notify all conflicts of interest in writing.

 

2.5- ACTING AS A SOCIALY AWARE COMPANY

FRED adheres to the principles of the Global Compact and supports the Millennium Development Objectives. FRED believes that in order to succeed a company must show responsibility in relation to the major challenges of its human environment and must translate this success into useful and constructive commitments.

Respecting and supporting human rights

FRED respects and promotes human rights and makes sure that its activities do not encourage human rights abuses. FRED intends to reflect its attachment to human rights through exemplary behavior in the operation of its business and to encourage, within its sphere of influence, the improvement of social conditions which constitute an essential factor in economic development.

Enhancing the local economic fabric

FRED is committed to participating, through the location of its production sites, in the economic and social dynamics of regions. FRED notably contributes to the development of employment in the regions where the Group has a presence.

 

2.6- WINNING THE TRUST OF SHAREHOLDERS

Respecting shareholders

The rights of FRED shareholders are protected by law and the principles of corporate governance which govern the way the Group operates. The LVMH Board of Directors has a Charter which specifies, among other things, its composition, missions, operations and responsibilities.

Ensuring the transparency of financial information

FRED is committed to ensuring the simultaneous, effective and complete dissemination of financial information which is relevant, accurate, true and fair, disseminated in a timely fashion, and consistent with previous publications.

Only designated personnel are authorized to give information to the financial market.

FRED is committed to accurately reflect its operations in its accounts.

 

Preventing insider trading

Any employee who, due to their professional activity, has access to privileged information which could influence the Group’s share price or that of another company is bound by absolute confidentiality and is prohibited from buying or selling shares in this company (or any financial instruments that are linked to it) or from doing so through a third party so long as this information is not in the public domain.

Maintaining the Group’s heritage

FRED ensures that each employee uses the company’s resources appropriately. These resources include notably FRED’s intellectual property, equipment, goods and financial resources.
 
FRED is careful to protect any confidential information, within or outside the company and the Group.

FRED defends its heritage and know-how by combating counterfeit. FRED does everything in its power to protect its intellectual property rights using a strategy to fight counterfeit which is focused on prevention, information and communication. In addition to these initiatives, it is the responsibility of each employee to defend FRED’s heritage.


3. IMPLEMENTATION & COMPLIANCE

Principles of implementation

This Code of Conduct aims to ensure the effectiveness and fairness of FRED’s operations. This Code, distributed throughout the Group, must be understood, accepted and applied consistently within the category business groups and the brands.

This Code and its principles, which should not be considered exhaustive, must be respected by each employee.
The FRED Code of Conduct serves as a basis for the development of codes of conduct of FRED in France and abroad. Thus the principles of this Code can, when appropriate, be developed or specified in relation to local regulations and legislation, and, when they exist, locally applied charters or codes.

Resources to support implementation

The Management Committee of FRED, will ensure the support the brands in the implementation of the Code of Conduct with a view to a consistent and uniform application of its principles in France and abroad.

Responsibility for implementation

The executive management team of each operational and legal entity is responsible for compliance with the principles of this Code.
Any employee who notices a non-conformity to one of the principles stipulated within the code should inform his or her hierarchy. Employees are aware that they will not suffer demotion, penalty or other adverse consequences for voicing a concern, or refusing to pay a bribe or facilitation payment even if this action may result in the company losing business.

Verification of implementation

Verification of compliance with the Code of Conduct is incorporated into the internal control mechanism existing within LVMH and follows the procedures in force in the Group.

 

II/RJC CERTIFICATION (RESPONSIBLE JEWELLERY COUNCIL)


Member of the RJC since 2005, FRED became in 2011 the 29th certified member.

The Responsible Jewellery Council (RJC) announced that FRED, the French jewellery house, has achieved certification meeting the ethical, human rights, social and environmental standards as established by the RJC’s Member Certification System.

About RJC

The Responsible Jewellery Council is an international not-for-profit organisation bringing together more than 300 member companies committed to promoting responsible ethical, human rights, social and environmental practices in a transparent and accountable manner throughout the jewellery industry from mine to retail. Their commitment aims to reinforce consumer and stakeholder confidence in diamond, gold and platinum metals jewellery products. The Council has developed the RJC Member Certification System, a certification system – which will apply to all Members’ businesses that contribute to the diamond, gold and platinum metals jewellery supply chain. All Commercial Members of the RJC are required to be audited by accredited, third party auditors to verify their conformance with the RJC’s Code of Practices and become certified under the RJC Member Certification System. A full list of its Members can be found on the web at www.responsiblejewellery.com

-> Find out more about the RJC
http://www.responsiblejewellery.com/

 

III/THE KIMBERLEY PROCESS

What is the Kimberley Process?

The Kimberley Process is a joint governments, civil society and industry initiative to stem the flow of conflict diamonds – rough diamonds used by rebel movements to finance wars against legitimate governments.

For several decades, the illegal trade in these stones has fueled devastating conflicts in countries such as angola, The Ivory coast (Côte d’Ivoire), the Democratic Republic of congo and/or Sierra Leone.
The Kimberley Process Certification Scheme imposes on its members many conditions in order to certify that the trade of rough diamonds is not used to finance armed conflicts.
Since September 2007, the Kimberley Process has 48 participants representing 74 countries, the European Union and its Member States counting as single participant.

Website: http://www.kimberleyprocess.com

What are the implications for FRED?

Vis-à-vis the suppliers:
All invoices of diamond purchases include a statement certifying that the stones purchased are not from armed conflict:
“The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance cith United Nations resolutions. The seller herby guarantees based on personal knowledge and/or written guarantees provided by the supplier of these diamnonds, that these diamonds are legitimate and are not used to finance armed conflict.”

Vis-à-vis clients:
The certificate of authenticity distributed for each product includes this note on page 7.
The general sales conditions that are on the back of bills were amended accordingly a,d have the same reference.

 


IV/UK MODERN SLAVERY ACT 2015 STATEMENT

INTRODUCTION

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps FRED PARIS (“FRED”) has taken during its financial year ending 31 December 2016 to ensure that slavery, servitude, forced or compulsory labour, and human trafficking (collectively, "Modern Slavery") is not taking place in any part of its business or in its supply chains.

BUSINESS

FRED PARIS is closely linked to the LVMH Moët Hennessy Louis-Vuitton SE (“LVMH”) Group.
FRED designs, manufactures, sells and distributes high-quality watches and jewelry under the internationally renowned luxury brand FRED (hereinafter the “Products”).
FRED purchases:
(i) gems and stones, semi-finished and/or finished Products from suppliers located essentially in Italy, France, Germany, Spain & Switzerland; and
(ii) marketing, packaging and Point of Sale Material from suppliers located in various European and overseas countries.

POLICIES AND PRACTICES

FRED’s commitment is to act with integrity in all its business dealings and to promote ethical conduct, to enhance compliance with applicable laws and to provide guidance with respect to business conduct.  It has a number of policies that are relevant to this commitment, which set out what FRED expects from its employees, internal business and its external suppliers.
Key Policies are:

  • 1. FRED Suppliers' Code of Conduct ("Suppliers' Code of Conduct") available upon request

FRED expects its suppliers to share its commitments and act in full compliance with the relevant laws, including all national, local and international laws relating to the management of their businesses.
FRED requires its suppliers to seek approval before subcontracting any part of their supply chain process and FRED’s approval is subject to acceptance by the subcontractor of the Suppliers' Code of Conduct and all other applicable conditions that FRED determines.
FRED reiterates the LVMH Code of Conduct and commitment to act to the highest standards of integrity, respect and engagement in their behaviours and in the way that they conduct business every day, everywhere. This code further states that the group companies will inform all its commercial partners of its ethical principles and expectations and will ask its suppliers to comply with the principles set out in the Suppliers' Code of Conduct.

In particular, this code specifies compliance with social issues to abide, respect and adhere to the company moral and ethical values in the management of the company concerning Human Rights, working Conditions and environmental issues.

  • 2. Responsible Jewellery Council Certification 

The Responsible Jewellery Council (RJC) is a not-for-profit organisation that has been established to promote responsible ethical, social and environmental practices, which respect human rights, throughout the Diamond, Gold and Platinum Group Metals Jewellery supply chain, from mine to retail. FRED is a RJC Member since 2011.

RJC Members commit to and are independently audited against the RJC Code of Practices – an international standard on responsible business practices for diamonds, gold and platinum group metals. The Code of Practices addresses human rights, labour rights, environmental impact, mining practices, product disclosure and many more important topics in the jewellery supply chain.

The RJC Code of Conduct is available at:
https://www.responsiblejewellery.com/files/RJC_Code_of_Practices_2013_V.2_eng.pdf

SUPPLIER AND CONTRACTOR DUE DILIGENCE

FRED ensure that its new suppliers are carefully chosen and that, prior to entering into any new contractual relationship with a supplier or a contractor, suppliers and contractors are complying with FRED’s Code of Conduct. FRED requests its contractors and suppliers to comply with FRED’s Code of Conduct at all times during their commercial relationship.

TRAINING AND AWARENESS

FRED conducts regular training for its employees to ensure legal and human compliance across FRED. The training enables FRED to reduce business risk of non-compliance through efficient processes and reliable data and reporting. 
FRED’s aim is to eliminate any risk of Modern Slavery in its business operations and in its supply chains.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes FRED’s slavery and human trafficking statement for the financial year ending 31 December 2016.
The Board of Directors of FRED has approved this statement and it has been duly signed by the following Director:
Rachel Marouani
Olivier Carrive
Philippe Colin
Caroline Mezan de Malartic

Modern Slavery Act Transparency Statement