At Swarovski Crystal Business (SCB) we are fully committed to respecting and promoting human rights across all parts of our chain of activities. This includes our own workforce, workers in the value chain, and stakeholders downstream of our operations. We recognize the global challenge of modern slavery that comes in many forms and its adverse impacts on affected stakeholders.
We are dedicated to ensuring that modern slavery has no place within our chain of activities. Our approach is rooted in transparency, vigilance, and continuous improvement. We conduct thorough due diligence to identify and address risks related to forced labor, human trafficking, and exploitation. We work closely with our suppliers to ensure they adhere to the same high ethical standards and comply with all relevant laws and regulations.
Our workers are not charged fees associated with their recruitment and ongoing employment. We prohibit all tiers of our suppliers as well as recruitment agencies from charging workers, including migrant, temporary, or subcontracted workers, any fees, or deposits for recruitment or ongoing employment.
We have grievance mechanism Speak Up in place that we encourage our workers and suppliers to use to report any suspected or actual violations. We regularly review and improve our policies and procedures to ensure proactive risk-based approach to identifying, preventing, and addressing modern slavery across our entire chain of activities.
To provide transparency to our stakeholders and maintain our compliance with the existing and emerging regulatory requirements, including but not limited to California Transparency in Supply Chains Act (SB 657) 2010 enforced in 2012, the UK Modern Slavery Act (MSA 2015), Australian Modern Slavery Act 2018 (NSW) we have prepared the following statement:
The California Transparency in Supply Chains Act (SB 657) 2010 enforced in 2012, the UK Modern Slavery Act (MSA 2015), and Australian Modern Slavery Act 2018 (NSW) address issues of servitude, slavery, forced or compulsory labor, and human trafficking. They are designed to ensure that businesses identify, prevent, and address actual and potential adverse impacts of modern slavery on people in the value chains.
Swarovski Crystal Business (Swarovski) is opposed to slavery and human trafficking and defines its basic principles to conduct business in a lawful and ethical manner and to support the right of all individuals to be free from slavery and any kind of forced labor in the workplace. Swarovski will continue to take decisive action to safeguard the dignity and rights of all individuals connected to our business.
POLICIES AND SYSTEMS, incl. GRIEVANCE AND REMEDY
In 2024, Swarovski adopted Code of Business Conduct and updated its Supplier Code of Conduct, aligning these policies with the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the United Nations Global Compact, the United Nations Women’s Empowerment Principles and the principles set out in the conventions of the International Labour Organization.
Additionally, Swarovski incorporated Speak Up channel into both its Code of Business Conduct and Supplier Code of Conduct. We also promoted supplier speak up on Swarovski Supplier webpage
Swarovski_Speak_Up_Policy_Final.pdf
Swarovski Supplier Code of Conduct with speak up (supplier webpage)
Speak_Up_Channel_Privacy_Policy.pdf (swarovski.com)
It is a third-party managed independent, confidential, and non-retaliatory whistleblower mechanism through which we encourage our stakeholders to report any suspected or actual violations. Operational accountability is with the Chief Legal and Compliance Officer, ultimate accountability with Ethics and Compliance Committee, with Board oversight.
In 2024, we adopted company-wide sustainability due diligence (SDD) approach that governs environmental and human rights management in our chain of activities. The objective is to roll out one SDD framework across the SCB, in line with the 6-step OECD Guidance and other applicable frameworks. It ensures cross-functional integration and oversight with monthly operational and bimonthly steering group meetings and report to the executive management and the board. Initial priority focus is on external suppliers and our own manufacturing sites.
PERIODIC IMPACT ASSESSMENT
Swarovski follows a risk-based approach in respecting and promoting human rights across our entire chain of activities. In 2024, we conducted our first human rights saliency assessment. It draws on our 2024 double materiality assessment conducted in accordance with the ESRS standards. Among salient (relevant) human rights issues we have identified for external suppliers: child labor, conflict minerals, environmental rights, forced labor, health and safety, wages and benefits, working hours; and for our own manufacturing sites: wages and benefits, working hours, health and safety, discrimination and harassment.
Annual high-level risk scan allows to systematically identify, assess, and address salient issues. It is based on SEDEX radar that provides a compound risk score and enables assessing suppliers and own sites based on geography, economic activity, commodity.
Additional sources of information about risks include but are not limited to: (1) internal company reports: Speak Up, self-assessments by suppliers, audit reports, among others; (2) reports of industry associations, trade unions, NGOs, and other similar organizations, (3) stakeholder engagement: insights on likely impacts on people (channels are detailed in our annual sustainability report).
We currently are developing in-house human rights impact assessment methodology that can be applied to areas of heightened risk in upstream and own operations as flagged through risk assessment, stakeholder engagement, and other channels.
For our suppliers, we require as a minimum to accept Swarovski Supplier Code of Conduct and to observe all applicable laws and regulations, including national and international laws prohibiting any kind of forced and bonded labor (such as slavery and human trafficking). As part of our Responsible Sourcing Initiative we conduct annual high-level risk scan using SEDEX radar tool for country risk and our classification on procurement category risk to identify medium- and high-risk suppliers High-risk suppliers are subject to annual third-party audit against the internation audit standards such as SEDEX Members Ethical Trade Audit (‘SMETA’) and Social Accountability International’s SA8000 standards, or our own internal labor assessment (based on the SMETA standard).
For our own operations, we conduct annual high-level risk scan using SEDEX radar to pinpoint hotspots. All our own manufacturing sites are covered by regular social audit particular SMETA and the performance area of forced labor is assessed. In 2024, we started information sessions and site-specific human rights saliency assessments to strengthen our approach to impacts on people.
IMPACT MANAGEMENT
When actual or potential impacts are identified, our first step is to determine attribution e.g. directly caused / contributed to / linked to our business activity. Next step is the development of preventative or mitigation action plan that is implemented jointly with suppliers for upstream or our relevant departments for own operations. Action plans include but are not limited to corrective action plans (CAPs) following audits. Ultimate objective of such plans is to remediate the issue and prevent its reoccurrence – disengagement with supplier is viewed as last resort for cases of critical breach without being resolved in a reasonable timeline. The detail of critical breach is outlined on the Responsible Sourcing Initiative internal guideline for critical breach.
TRACKING AND CONTINUOUS IMPROVEMENT
As outlined in the OECD Guidance, tracking and continuous improvement involves regularly monitoring the effectiveness of measures taken to address human rights risks. This step ensures ongoing compliance, identifies gaps, and drives improvements by refining processes, engaging stakeholders, and adapting to emerging challenges in human rights.
COMMUNICATION AND DISCLOSURE
Business Code of Conduct / Supplier Code of Conduct and Speak Up channel are proactively communicated to our entire workforce and to suppliers. Annual Business Code of Conduct trainings are launched since 2024. The latest Supplier Code of Conduct and Speak Up channel was communicated to suppliers during the Supplier Summit organized by procurement team. Further implementation including suppliers’ official acknowledgment has been taken place from 2024 onwards,
Swarovski’s annual sustainability report provides a transparent platform to disclose the company's efforts to identify, prevent, and address human rights issues, including forced labor and modern slavery. It is an externally facing communications channel that fosters accountability, informs stakeholders, and demonstrates our commitment to ethical practices and compliance.
This statement was approved by the Managing Director of Swarovski UK Ltd. : Ash Craig