MIORO BUSINESS ETHICS POLICY

 

PL.05| Publication Date:20.12.2017 | R.02 | Last Revised Date: 23.12.2024

Introduction

At Mioro, we are dedicated to conducting our business in an ethical, responsible, and sustainable manner. This Business Ethics Policy aligns with the Local laws, the Responsible Jewellery Council (RJC) Code of Practices (COP), the Signet Responsible Sourcing Protocol (SRSP), and the global ethical standards and best practices, ensuring compliance with the highest ethical, environmental, and human rights standards, supporting responsible supply chains and corporate governance.

1. Compliance with Laws and Industry Standards

Mioro complies with all applicable local, national, international, and international laws and regulations, including but not limited to:

Labor, human rights, and anti-corruption laws: Ensuring compliance with internationally recognized human rights frameworks.
Environmental regulations: Adhering to international environmental reporting frameworks and sustainability goals.
Responsible sourcing: Meeting RJC COP and SRSP standards for conflict-free sourcing, and adhering to internationally recognized standards for conflict minerals.

2. Ethical and Conflict-Free Sourcing

Mioro ensures that all precious metals, including gold and silver, are sourced responsibly and ethically from verified suppliers. To meet international standards, our sourcing practices include:

Conflict-Free Material: All precious metals are sourced exclusively by LBMA Good Delivery members. This ensures full compliance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.

Traceability Systems: Robust tracking mechanisms ensure full traceability of materials throughout the supply chain, minimizing risks of conflict-related or unethical sourcing.

Annex 2: OECD Due Diligence Guidance Steps
To ensure compliance with the OECD Due Diligence Guidance, Mioro adheres to the following five-step framework:
a-Establish Strong Company Management Systems
b-Identify and Assess Risks in the Supply Chain
c-Design and Implement a Strategy to Respond to Identified Risks
d-Carry Out Independent Third-Party Audits

e-Report Annually on Supply Chain Due Diligence Efforts

  1. Anti-Corruption and Bribery

    Mioro adopts a zero-tolerance policy toward corruption and bribery. We ensure compliance with MASAK directives on anti-money laundering (AML) and anti-corruption, including:

    Ethical Business Conduct: Prohibiting bribery, kickbacks, and facilitation payments in all operations.

AML Compliance: Adhering to the MASAK Anti-Money Laundering Directive by conducting Know Your Customer (KYC) and supplier due diligence checks.

Whistleblower Protection: Providing secure, confidential reporting channels for employees and stakeholders to report unethical practices, in line with the EU Whistleblower Protection Directive.

4. Human Rights and Labor Standards

Mioro is committed to respecting human rights and labor standards, ensuring compliance with local and international frameworks, including:

Prohibition of Forced and Child Labor: Strict adherence to the ILO Conventions and EU Human Rights Due Diligence legislation.
Diversity and Inclusion: Promoting non-discrimination and equal opportunities in the workplace.
Safe Working Conditions: Providing employees with a safe and healthy working environment, in line with ISO 45001 Occupational Safety and Health (OSH) standards.

  1. Environmental Responsibility

    Mioro actively minimizes its environmental footprint by aligning with the local and EU’s sustainability goals, including:

    Carbon Emissions Reduction: Setting targets to achieve net-zero emissions in line with global sustainability goals.
    Sustainable Resource Use: Ensuring responsible management of natural resources and compliance with international Waste Framework Directive.
    Environmental Reporting: Providing transparency through regular reporting in line with ISO 14001 standards and audit reports.

    6. Supply Chain Transparency

    Mioro ensures full transparency in its supply chain, incorporating:

    Supplier Code of Conduct: Requiring suppliers to adhere to Mioro’s ethical standards, including compliance with the EU Conflict Minerals Regulation and OECD due diligence guidelines.
    Audits and Monitoring: Conducting regular audits to verify supplier practices and address any risks.
    Digital Traceability Tools: Leveraging Customs and logistics ERP technology to track and report material flows across the supply chain.

    7. Product Integrity

    Mioro guarantees the authenticity and quality of its products by ensuring:

    Accurate Labeling: Adhering to RJC-COP disclosure requirements and providing clear, honest product information to consumers.
    Hallmarking Standards: Complying with international and EU hallmarking regulations.

  2. Whistleblower Protection

    Mioro encourages the reporting of unethical conduct through:

    Secure Reporting Mechanisms: Confidential online ethics hotline channels for employees and stakeholders to report concerns.

Non-Retaliation Policy: Guaranteeing protection for whistleblowers in accordance with international best practices for whistleblower protection.

9. Monitoring and Continuous Improvement

Mioro continuously evaluates and improves its practices by:

Internal and External Audits: Conducting regular compliance audits.
Stakeholder Engagement: Consulting with stakeholders to address concerns and enhance operations.
Annual Reporting: Publishing detailed reports in alignment with  RJC Annual reporting standards.

10. Governance and Accountability

The implementation of this policy is overseen by Mioro’s Ethics and Compliance Team, reporting to senior management. The team ensures adherence to local regulations, international standards, and internal guidelines.

Conclusion:

Mioro is unwavering in its commitment to ethical and sustainable practices. This policy reflects our dedication to transparency, integrity, and responsibility in all operations. For further guidance or inquiries, please contact the Ethics and Compliance Team at Mioro.
Last Revised Date: 23.12.2024

                                                                                                                         APPROVED BY THE BOARD OF DIRECTORS

Mioro Hediyelik Eşya San. Ve  Tic. A.Ş.