Our RJC Policy


ARMANDO LUCCHETTA S.r.l. complies with the laws in force and the technical standards relevant to its sector, ensuring constant information on updates and their timely implementation.
We are committed to complying with the RJC Principles and Rules of Procedure by informing our stakeholders (employees, collaborators, suppliers and customers) of the principles contained therein through disclosure.
We carefully assess our risks, including risks to our business from our business partners, analyze the most sensitive situations and implement appropriate procedures and controls that respect human rights, social principles and the environment.
Suppliers and contractors play a key role in improving the company’s overall competitiveness.
The Company’s relationships with suppliers and external collaborators are characterized by fairness, impartiality and respect for equal opportunities for all parties involved, in the pursuit of maximum competitive advantage.
ARMANDO LUCCHETTA S.r.l. requires its suppliers and external collaborators to comply with the principles and requirements set forth in this RJC Policy.
This policy is posted at the operational, commercial and administrative headquarters in Via Pio La Torre 26, 36061 Bassano del Grappa (VI).
We do not tolerate bribery of public officials or any other party in any form or manner in any jurisdiction, even where such activities have been permitted, tolerated or not prosecuted in practice.
The payment or acceptance of bribes is prohibited.
We do not tolerate money laundering and/or the financing of terrorist activities.
We will engage in know-your-customer and know-your-supplier activities and exercise the utmost vigilance over our supply chain, particularly for the supply of gold, silver, diamonds and precious stones.
We are committed to sourcing diamonds from supply chains that comply with WDC (World Diamond Council) guidelines and LBMA certified gold.
We are committed to ensuring product security measures within our facilities and during transportation to prevent theft, damage or substitution.
We are committed to maintaining the safety and well-being of employees, visitors and other relevant stakeholders who visit our company.
We are committed to full and thorough disclosure of the characteristics of the products we sell.
We are committed to the principles of confidentiality and the protection of confidential information.
We are committed to maintaining the safety and well-being of employees, visitors and other relevant business partners.
We believe in and are committed to respecting fundamental human rights and the dignity of the individual in accordance with the United Nations Universal Declaration of Human Rights.
We will not tolerate the use of child labor.
We pledge not to use any form of forced, bonded, indentured or prison labor and not to restrict the freedom of movement of employees and subordinate workers.
We are committed to ensuring high standards of health and safety at our headquarters and operations, including through the cooperation of the Occupational Safety Officer and the Workers’ Safety Representative.
We are committed to non-discrimination on the basis of race, ethnicity, caste, country of origin, religion, disability, gender, sexual orientation, union membership, pregnancy, political affiliation, marital status, physical appearance, age, or any other restriction not permitted in the workplace, so that all “Fit to Work” individuals are afforded equal opportunity without discrimination on the basis of factors unrelated to their ability to perform the intended job.
We pledge not to use corporal punishment under any circumstances and to prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form.
We agree to establish a procedure for handling disciplinary disputes regarding conduct that is inappropriate with respect to COP standards.
We agree to comply with applicable laws regarding working hours and compensation and, in the absence of such laws, to adopt applicable industry standards.
We are committed to protecting the environment:
• Eliminate and, where not possible, reduce the use of toxic substances in our manufacturing operations;
• Minimize the negative impact of our operations on the environment.
• By disposing of waste responsibly.
• Reducing paper, water and energy consumption.
With respect to serious abuses associated with the mining, transportation and trade of gold.
We do not intend to condone, benefit from, contribute to, support or facilitate:
• Torture, cruel, inhuman or degrading treatment;
• Forced or compulsory labor;
• the worst forms of child labor;
• human rights violations and abuses;
• war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately cease doing business with upstream suppliers in the supply chain if we determine that there is a reasonable risk that they are engaged in, are sourcing from, or are linked to a counterparty that engages in the abuses listed above.
With respect to direct or indirect support for non-governmental armed groups, we do not intend to tolerate direct or indirect support for non-governmental armed groups, including but not limited to procuring gold, making payments, or providing support or equipment to non-governmental armed groups or their affiliates that illegally control
• control mining sites, transport routes, gold marketing points and upstream actors in the supply chain; and/or
• Taxing or extorting money or gold at mining sites, along transportation routes, at gold marketing points, or from intermediaries, exporters, or international traders.
We will immediately cease all engagement with upstream suppliers in the supply chain if we identify a reasonable risk that they are sourcing from, or are associated with, a counterparty that provides direct or indirect support to non-state armed groups.

Legal Representative
Massimo Lucchetta

Rev. 3 – September 2023

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