Ethical Charter
The Maison Lepage embodies a tradition of excellence, a family craftsmanship passed down from generation to generation since 1922, which is reflected in our ethical, social, and environmental business practices.
This ethical charter formalizes the company’s commitments to our customers and the ethical principles outlined in the RJC Code of Practices, which must guide the actions and behaviors of all company members.
As an RJC member since 2019 and certified since 2021, we are committed to conducting our business in accordance with the latest RJC Code of Practices. We integrate ethical, social, and environmental values into our daily operations, decision-making processes, each of our creations, and our entire supply chain.
Our policy applies to all our products, professions, and supply chain, particularly our suppliers.
I. ETHICAL AND SOCIAL COMMITMENT
This code of conduct reflects our commitment to human rights, our fight against the financing of conflicts, and our compliance with all sanctions, resolutions, and laws issued by the United Nations.
1. Commitment to the Company’s Image
As a certified RJC member, we undergo audits of our practices by an independent firm and commit to demonstrating that we:
• Respect human rights as outlined in the Universal Declaration of Human Rights, the European Convention on Human Rights, the Declaration of the Rights of Man and of the Citizen, and the UN Guiding Principles on Business and Human Rights.
• Comply with various International Labour Organization (ILO) conventions, including the Fundamental Principles and Rights at Work and ILO conventions on occupational health and safety.
• Condemn and pledge never to tolerate, benefit from, participate in, or support any abuse related to the extraction and transportation of goods in the supply chain, including:
• Torture, cruel, inhuman, and degrading treatment
• Forced or compulsory labor and the worst forms of child labor
• Human rights violations, war crimes, violations of international humanitarian law, crimes against humanity, or genocide
a. Business Ethics
To uphold ethical standards and ensure the company’s reputation, we commit to maintaining trust within the jewelry, fine jewelry, and watchmaking industry. Therefore, we declare that we:
• Will remain vigilant against operations that may involve coercion, corruption, money laundering, or terrorism financing, and will never engage in such activities.
• Will not participate in any form of corruption, money laundering, or terrorism financing and will not tolerate such activities.
• Support transparency in payments from governments and security forces within extractive industries.
• Will not provide direct or indirect support to illegal armed groups.
• Will ensure due diligence in selecting our business partners.
• Will not engage in corruption, bribery, or facilitation payments (kickbacks).
• Will refrain from offering, promising, or granting bribes and will resist any solicitation of bribes to conceal the origin of minerals, misrepresent taxes, duties, and fees paid to governments for mineral extraction, trade, processing, transport, and export.
• Support efforts to eliminate money laundering risks in mineral supply chains where we identify reasonable risks.
• Will only reimburse expenses for business trips or training strictly necessary for professional duties.
• Will not accept gifts from business partners exceeding €300.
• Will not accept cash payments exceeding €1,000, in accordance with French regulations.
• Will exercise diligence in transactions to detect anomalies that may indicate money laundering.
b. Responsible Supply Chain
We commit to using our influence to prevent potential violations by other parties.
We implement the OECD’s Five-Step Framework as a risk management process to ensure responsible mineral supply chains from conflict-affected and high-risk areas.
Severe Violations in Mineral Extraction, Transport, or Trade
We will not tolerate, assist, or facilitate any of the following acts, nor will we profit from or contribute to them:
• Torture, cruel, inhuman, and degrading treatment
• Forced or compulsory labor
• The worst forms of child labor
• Violations and abuses of human rights
• War crimes, other gross violations of international humanitarian law, crimes against humanity, or genocide
Direct or Indirect Support to Non-State Armed Groups
We only buy and sell diamonds fully compliant with the Kimberley Process Certification Scheme. As such, we will not tolerate any direct or indirect support to non-state armed groups or their affiliates, including:
• Illegal control of mining sites, transport routes, diamond and gold trading points, or upstream supply chain actors
• Illegal taxation or extortion at mining sites, transport routes, or trading points
Termination of Partnerships
We will terminate relationships with upstream suppliers if we identify:
• A reasonable risk that they are involved in the aforementioned violations or sourcing from those committing these violations.
• A reasonable risk that they are sourcing from entities directly or indirectly supporting non-state armed groups.
Public or Private Security Forces
We affirm that the role of public or private security forces is to ensure the safety of workers, facilities, equipment, and property while respecting the rule of law and human rights.
We will not provide any direct or indirect support to security forces that commit the above-mentioned violations.
II. COMMITMENT TO EMPLOYEES
We provide a working environment that respects human rights and French labor laws, ensuring compliance with environmental, health, and safety regulations.
• We do not tolerate discrimination or workplace harassment.
• We do not engage in or tolerate child labor or forced labor.
• We ensure daily attention to workplace safety and awareness of job-related risks.
• We strive to maintain the highest hygiene and safety standards.
• We guarantee data protection and confidentiality for employees and partners.
• We encourage employees to report suspected violations of human rights, the OECD’s Due Diligence Five-Step Framework, or other ethical principles outlined in this charter.
No one will face demotion, sanctions, or retaliation for reporting a suspected violation, even if it results in the loss of a client.
III. COMMITMENT TO CUSTOMERS
We ensure that our goods and services meet quality and safety expectations while guaranteeing the transparency of the information provided to our clients.
• We fight against illicit trade linked to armed groups.
• We allow stakeholders to express concerns about the jewelry supply chain.
• We ensure transparency in our supplier relationships and product origins, including compliance with the Kimberley Process and the World Diamond Council Guarantee.
• We implement supply chain control systems to prevent sourcing from conflict-affected or high-risk areas.
• We provide accurate descriptions of gemstones and products (4C diamond characteristics) to ensure the highest quality for our customers.
• We certify all diamonds over 0.3 carats in our Lepage collection.
• We verify the natural origin of all diamonds purchased for our Lepage collection.
IV. RESPONSIBLE ENVIRONMENTAL COMMITMENT
We strive to minimize our environmental impact by:
• Raising employee awareness of energy conservation, paper waste reduction, and waste management.
• Implementing the 3R approach: Reduce, Reuse, Recycle.
• Using as much recycled gold as possible from customer buybacks.
We fully comply with applicable laws and the 2019 RJC Code of Practices.
This code of conduct reflects our company’s values and commitments. All employees acknowledge it and commit to upholding it daily.
Suspected violations should be reported anonymously if desired via:
📍 Mail: Bijouterie Lepage, 30 rue des Carmes, 76000 Rouen, France
📧 Email: flefrancois@lepage.fr
No one will face retaliation for reporting a suspected violation.