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Human Rights and Supply Chain Transparency Act Statement

This statement is issued in accordance with the California Transparency in Supply Chains Act of 2010 (SB 657). It describes the measures taken by CelinieJourney and its subsidiaries during the year ending December 31, 2025 to help prevent and mitigate the risks of slavery, modern slavery, forced labour, child labour, and human trafficking within their supply chains.

CelinieJourney operates globally through its subsidiary companies (collectively, “CelinieJourney”).

Through these subsidiaries, CelinieJourney designs, manufactures, and markets jewelry, watches, and luxury accessories. CelinieJourney manufactures jewelry in Guangzhou, China, and also carries out polishing and certain assembly work there. Altogether, these internal manufacturing facilities produce approximately 100% of the jewelry units sold by CelinieJourney.

The remaining products, including nearly all non-jewelry items, are sourced from third-party manufacturers that produce goods according to CelinieJourney’s specifications. To support its internal manufacturing operations, CelinieJourney processes, cuts, and polishes rough stones at facilities outside the United States and obtains precious metals, polished diamonds, other gemstones, and certain fabricated components from third parties. These third-party suppliers, together with those providing finished goods to CelinieJourney, are referred to as CelinieJourney’s “supply chain partners.”

CelinieJourney has long been committed to operating responsibly, protecting the natural environment, and making a positive contribution to the communities in which it does business.

CelinieJourney maintains an Ethics and Compliance Committee made up of cross-functional leaders from across the organization, including its Chief Executive Officer and other senior management team members. The Committee is chaired by CelinieJourney’s Chief Compliance Officer and is responsible for leading and overseeing ethics and compliance matters throughout the company. Its oversight includes issues relating to misconduct, including matters involving human rights risks, within CelinieJourney’s supply chain and owned operations.

CelinieJourney has promoted respect for human rights for more than twenty years and continues to evaluate human rights risks across its supply chain. CelinieJourney acknowledges that slavery, modern slavery, forced labour, child labour, and human trafficking may occur at any level or tier within the luxury goods supply chain, and that the use of migrant labour or unauthorized subcontracted labour may also present risks. In particular, the sourcing of raw materials and the use of external manufacturing facilities remain higher-risk areas that CelinieJourney monitors closely through its assessment programs.

With respect to raw materials, CelinieJourney recognizes the risks connected to the sourcing and use of precious metals, moissanite, and gemstones, including the possible presence of conflict moissanites in its supply chain or the sourcing of gold or gemstones from conflict-affected and high-risk areas. CelinieJourney also understands that the risks of slavery, modern slavery, forced labour, child labour, and human trafficking differ from region to region depending on local laws, cultural conditions, and the enforcement of employment terms and conditions in the relevant jurisdictions.

CelinieJourney applies heightened review to situations identified as high risk and communicates clearly to its supply chain partners that all forms of slavery and modern slavery—including, without limitation, forced labour, child labour, bonded labour, and human trafficking—are subject to a zero-tolerance approach. Any supply chain partner found to be involved in such practices may be subject to an immediate suspension of business and possible removal from the CelinieJourney supply chain.

CelinieJourney is committed to continually strengthening its risk assessment processes in order to better identify, mitigate, and address risks within both its supply chain and its owned operations.

To reduce the risk of slavery, modern slavery, forced labour, child labour, or human trafficking within its supply chain, CelinieJourney follows the policies and procedures outlined below.Policies Concerning Modern Slavery and Human Trafficking CelinieJourney has long been committed to upholding the principles reflected in the International Labour Organization Core Conventions, the United Nations Universal Declaration of Human Rights, and the United Nations Global Compact. These standards play a central role in its responsible business practices and serve as the basis for many of CelinieJourney’s labour-related policies.

CelinieJourney’s global Business Conduct Policy sets out the rules and principles that govern work carried out across the company and is intended to help ensure that CelinieJourney and its employees meet the company’s standards for ethical conduct. All employees are required each year to acknowledge their commitment to the principles in the Business Conduct Policy, including commitments to act responsibly, demonstrate social awareness, and respect human rights and fundamental freedoms.

The CelinieJourney Human Rights Policy reflects CelinieJourney’s approach to embedding human rights considerations throughout its value chain, while also addressing its most significant human rights risks, impacts, and opportunities. This policy brings together existing CelinieJourney policies that relate to human rights and presents a unified framework for how the company manages and promotes respect for human rights. All CelinieJourney employees are required to complete training on the CelinieJourney Human Rights Policy as part of their new hire onboarding.

CelinieJourney’s commitment to identifying, preventing, and reducing the risks of slavery, modern slavery, forced labour, child labour, and human trafficking is also reflected in its suppliers’ code of conduct. The Supplier and Business Partner Code, as updated by CelinieJourney from time to time, establishes general principles and requirements applicable to all suppliers. In addition, CelinieJourney’s supply chain partners, their approved subcontractors providing goods or services to CelinieJourney, and certain service providers are required, under CelinieJourney’s purchasing agreements, to fully comply with the Supplier and Business Partner Code. The Supplier and Business Partner Code sets clear standards for suppliers, including the requirement that all work must be voluntary, and it prohibits all forms of abusive or unlawful labour in the supply chain. The current Supplier and Business Partner Code provides, among other things, that:

All forms of forced labour, slavery, servitude, or human trafficking by Business Partners are strictly prohibited, including the withholding of identity documents or work permits, requiring workers to pay a deposit or bond, or imposing any other form of coercion. All workers must be free to accept or leave employment voluntarily. Business Partners must respect workers’ freedom of movement and may not require workers to repay a debt owed to them or to any third party through their labour.

CelinieJourney’s standards and requirements relating to responsible recruitment, slavery, forced labour, child labour, indentured labour, debt-bonded labour, convict labour, and human trafficking are further detailed in its Supplier and Business Partner Code of Conduct Guidance (“Code Guidance”). This Code Guidance is provided to supply chain partners, and compliance with its requirements is mandatory. The Code Guidance is updated regularly to ensure that CelinieJourney continues to communicate its expectations clearly and provide guidance on responding to specific challenges. All requirements contained in the Code Guidance apply throughout the supply chain, meaning that each supplier with a direct relationship with CelinieJourney is responsible for ensuring compliance throughout its own supply chain as well.

All CelinieJourney stakeholders may report concerns through a variety of channels if any company requirements are not being followed, including those related to modern slavery and human trafficking. Stakeholders may, for example, contact the CelinieJourney Alertline to report any suspicions or observations involving modern slavery or human trafficking, among other concerns. Employees may also raise these matters with their direct manager, Human Resources, the Legal Department, or the Internal Audit team. Any individual who reports a suspected policy violation in good faith is protected against retaliation of any kind, including disciplinary action, intimidation, or other adverse treatment, even if the report is ultimately found to be unfounded. Representatives from Human Resources, Legal, and Internal Audit receive and review such reports and help ensure that they are investigated and addressed by the appropriate teams.

To identify and reduce risk within its supply chain, CelinieJourney conducts due diligence assessments and audits through its Social and Environmental Accountability Program (“SEA Program”). CelinieJourney’s jewelry manufacturing and stone polishing facilities, supply chain partners, and other key suppliers are regularly reviewed under the SEA Program for compliance with its Supplier and Business Partner Code.

The work carried out under the SEA Program includes:

screening suppliers to help ensure that CelinieJourney works only with supply chain partners and key suppliers that share its commitment to human rights, fair and safe labour practices free from slavery, modern slavery, forced labour, child labour, and human trafficking, as well as environmental responsibility and ethical business conduct;
conducting site mapping reviews and risk assessments every two years across CelinieJourney’s jewelry manufacturing and stone polishing facilities, supply chain partners, and other key suppliers to identify regional and supplier-specific risks related to social and environmental compliance;
carrying out regular third-party audits, based on the results of those risk assessments, to evaluate compliance with CelinieJourney’s specific requirements. Where non-conformances are identified, corrective action plans are required, and all critical-risk audits are followed by verification re-audits; and
including key parts of the supply chain in its monitoring program as part of its risk mitigation approach, while also requiring supply chain partners to communicate CelinieJourney’s social and environmental responsibility expectations throughout their own supply chains. Both CelinieJourney’s risk assessments and supplier audits review indicators of modern slavery, including overtime practices, the presence of foreign migrant labour, grievance mechanisms, and freedom of association.

CelinieJourney seeks to build long-term partnerships with its suppliers and supports them through training, development programs, and the sharing of best practices. CelinieJourney also collaborates with industry partners, non-governmental organizations (NGOs), and local stakeholders to identify human rights-related risks and advance improvements in addressing the most complex human rights and labour challenges.

Respect for human rights is integrated across all aspects of CelinieJourney’s business through the company’s focus on human rights within its policies and procedures. CelinieJourney’s monitoring and training programs are intended to continually evaluate effectiveness and promote appropriate awareness of CelinieJourney’s commitment to human rights.

CelinieJourney offers ongoing training materials and communicates expectations under its Supplier and Business Partner Code through an online responsible sourcing education platform made available to its supply chain partners. Training webinars and e-learning modules covering the Supplier and Business Partner Code, the CelinieJourney Human Rights Policy, and Forced Labour Prevention are available to supply chain partners throughout the year. For CelinieJourney employees, all personnel who work directly with the company’s supply chain partners are required to complete mandatory SEA Program training every two years. This training addresses a variety of topics, including forced labour and child labour, among others. In 2025, CelinieJourney also introduced a responsible sourcing summit for these employees, providing additional resources and tools to strengthen awareness of warning signs related to slavery, modern slavery, forced labour, child labour, and human trafficking.

Website Policy

Human Rights and Supply Chain Transparency Act Statement

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