Annual Report on Human Rights Due Diligence
Imperial-Deltah Inc.
2024
Summary
This report outlines the activities undertaken by Imperial-Deltah Inc. in 2024 to implement human rights due diligence processes in line with international standards. As a responsible jewelry manufacturer, we recognize the importance of ensuring that our operations, supply chain, and business activities respect human rights. This annual review highlights our progress in monitoring and addressing human rights risks, implementing corrective measures, and fostering a culture of responsibility throughout our operations.
Introduction
Human rights due diligence is a critical component of our business strategy and sustainability efforts. It involves identifying, preventing, and addressing any adverse human rights impacts across our value chain. This report covers the key actions, policies, and outcomes related to human rights due diligence in the areas of sourcing, production and employment practices
Human Rights Due Diligence Framework
Our due diligence framework is built upon the OECD Guidelines for Multinational Enterprises and the Kimberly Process Certification Scheme (KCPS), World Diamond Council System of Warranties (WDC SoW), and focuses on:
- Risk Assessment: Identifying potential human rights risks in the supply chain and production facilities.
- Prevention and Mitigation: Developing policies and processes to prevent and mitigate negative human rights impacts.
- Monitoring and Review: Regularly monitoring and reviewing the effectiveness of our human rights initiatives.
- Remediation: Ensuring that any adverse impacts are addressed through appropriate corrective actions.
- Engagement: Collaborating with employees and suppliers to understand and address human rights concerns.
Key Human Rights Risks Identified
In 2024, Imperial-Deltah Inc. focused on identifying and mitigating the following key human rights risks across our operations and supply chain:
- Child Labor and Forced Labor: A thorough review of suppliers was conducted to ensure compliance with labor laws and ethical practices, particularly in regions where these risks are higher.
- Health and Safety Risks: Given the nature of jewelry manufacturing, ensuring safe working conditions in factories is a priority.
- Worker Rights and Conditions: Imperial-Deltah, Inc. continues to review workers’ rights, including fair wages, working hours, freedom of association, and non-discrimination in hiring practices.
- Environmental Impacts: The potential human rights impact of environmental practices, particularly in the elimination of hazardous materials, is monitored to ensure respect for local communities.
Due Diligence Activities
- Supply Chain Audits and Assessments
In 2024, we conducted comprehensive audits across our jewelry manufacturing suppliers. This included several on-site visits and quarterly remote supplier assessments on all approved suppliers for the following information
- Updated Know Your Supplier Form
- Quarterly check on suppliers appearing on the Office of Foreign Assets Control (OFAC) Sanctions List
- Quarterly checks of SOW information present on supplier invoices
We also review the following to obtain information about the areas in which our suppliers operate.
- Quarterly review of The Conflict Effected and High Risk Affected Areas report
- Quarterly review of the International Crisis Group website
- Yearly review of Amnesty International Report: The State of the World’s Human Rights
- Yearly review of US Department of State Annual Country Report on Human Rights
- Worker Training
- Imperial-Deltah Inc continuously maintains training where needed for our employees and posts fair employment policies including fair wages, anti-discrimination practices, health and safety regulations and knowledge of their rights while employed with Imperial-Deltah, Inc
3. Grievance Mechanisms
- Imperial-Deltah Inc. maintains a grievance mechanism for both employees and suppliers, enabling workers and suppliers to report concerns related to human rights violations anonymously and without fear of retaliation.
Progress and Impact
Our human rights due diligence efforts in 2024 have led to several positive outcomes:
- Improved Supplier Compliance All current suppliers are considered LOW RISK according to our Approved Supplier List policy
- Enhanced Worker Safety: The number of workplace accidents is 0 (2023)
- Empowered Workforce: 0 grievance reports filed (2023)
Challenges and Areas for Improvement
Despite the positive developments, there are areas where improvements are still needed:
- Supply Chain Transparency: Although high level of supplier communication has been maintained, improvements and quickness in response to and from suppliers is needed.
- Employee Feedback and Input: While no employee grievances were submitted, more feedback from employees is needed
Goals for 2025
To further enhance our human rights due diligence efforts in 2025, we have set the following goals:
- Strengthen Supply Chain Transparency: Schedule site visits with local suppliers
- Enhanced Worker feedback and input: Implement an annual workers satisfaction survey.
Conclusion
Imperial-Deltah, Inc. remains committed to upholding the highest standards of human rights across all aspects of our operations. While Imperial-Deltah, Inc. has solid footing in several key areas, we recognize that ongoing diligence and continuous improvement are essential to minimizing risks and ensuring that we are a responsible business that contributes positively to the global jewelry industry. We will continue to enhance our human rights due diligence activities and work collaboratively with suppliers and employees to achieve our goals in the year ahead.
Prepared by:
Imperial-Deltah, Inc.
Date: January 7, 2025