This statement covers activities of both Chisholm Hunter Holdings Limited (and its subsidiary Chisholm Hunter Limited) and Barclays Diamonds Limited (the companies are referred to in this statement as “the Companies” collectively and each a “Company”).

What is Modern Slavery?

Modern slavery is a crime and a violation of fundamental human rights. It has many different forms including, for example: slavery, servitude, forced and compulsory labour and human trafficking. Ultimately it involves one person controlling another person thereby depriving them of their liberty with the aim of exploiting them for personal or commercial gain.

As part of the luxury jewellery sector, the Companies recognise they have responsibilities to take a robust approach to slavery and human trafficking—the Companies have zero tolerance to slavery and human trafficking.

Countries of Operation and Supply

The Companies currently operate wholly within the United Kingdom. The Companies source products and services through a wide range of suppliers based both in the United Kingdom and overseas, including the following countries:

• Switzerland
• Germany
• Italy
• China

The Companies are committed to improving our practices and ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Conflict Diamonds and the Kimberley Process

The Kimberley Process is a joint initiative between governments and industry to restrict the supply of ‘conflict diamonds’, which are used to finance wars. The mining and supply of conflict diamonds exploits vulnerable individuals from poverty-stricken communities. These are often child labourers and victims of war-crime, who are then exposed to unsafe and inhumane working conditions. The Companies have a clearly defined policy conforming to the non-trade of conflict diamonds. The Companies require that our suppliers of diamonds have signed up to the Kimberley Process, and ensure that they have made a statement to that effect on their invoices. Further details of the Kimberley Process can be found at kimberleyprocess.com.

Our Policies

The Companies operate a number of internal policies that underpin our commitment to ensure there is no modern slavery or human trafficking in our supply chain or in any part of our business and to ensure that the Companies are conducting business in an ethical and transparent manner. These include:

• Whistleblowing policy: The Companies encourage all their workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Companies. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

• Employee code of conduct: This code makes clear to employees the actions and behaviour expected of them when representing any of the Companies. The Companies strive to maintain the highest standards of employee conduct and ethical behaviour when operating.

• Recruitment & Selection Policy: The Companies have a stringent recruitment policy which includes checks on the right to work in the UK and full reference checks for all applicants. The Companies also only uses specified, reputable employment agencies to source labour and always verify the practices of any new agency they are using before accepting workers from that agency.

Staff Training

In addition to the policies above, in 2022 the Companies will require all staff to complete training on The Modern Slavery Act 2015. This will include the following topics:

• Various forms of modern slavery.
• The size of the problem and the risk to our organisation.
• How employees can identify the signs of slavery and human trafficking such as unrealistically low prices for products the Companies propose to purchase.
• How to escalate potential slavery or human trafficking issues to the senior managers in the Companies.
• Information about what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative.

Going Forward

The Companies commit to continually reviewing and improving the Companies’ procedures, policies and business relationships to ensure that no-one involved in our Companies or supply chains are subject to modern slavery or trafficking. During 2022/23, the Companies will undertake the following:

• Provide training for all staff on the basic principles of the Modern Slavery Act 2015.
• Conduct risk assessment/audit to assess the risk of modern slavery or trafficking occurring in each part of our business or in our supply chain. Review processes for taking on new suppliers and reviewing existing suppliers in order to assess their compliance with the principles of the Modern Slavery Act 2015.

This statement was approved by the Board of Directors on 23.03.22, who will review and update it annually. This statement was signed on behalf of the Board by Harry Brown, Managing Director of Chisholm Hunter Limited on 31.03.22.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Companies’ modern slavery and human trafficking statement for the financial year ending 31st March 2023.