Since its inception in 1985, Sözer Jewelry has grown into a distinguished family-owned luxury brand, operating across more than 90 countries. With over 40 visionary designers, we remain at the cutting edge of global trends, driven by our relentless pursuit of innovation.
We are proud to introduce Monaco Chain, the pinnacle of our offerings, setting new standards in the world of gold chains over the past decade. Crafted with unparalleled technology and impeccable artistry, Monaco Chain is celebrated for producing the world’s lightest and strongest gold chain. Our creations are marked by their exceptional durability, our exclusive ‘S’ logo lock design, and a secure double-click locking system.
As a trailblazer in the luxury gold chain market, Monaco Chain has not only set trends but redefined them, with a presence spanning the Americas, Asia, Europe, and Africa. We are recognized as the world’s premier luxury gold chain brand synonymous with elegance and sophistication.
At Monaco Chain, inclusivity is woven into the fabric of our brand. We are committed to crafting jewelry that transcends boundaries, appealing to a diverse clientele from ages 7 to 70. Our collections are thoughtfully designed to complement every mood and occasion—whether it be a sporty outing, a chic gathering, a casual day, or a formal event.
Our vision at Monaco Chain by Sözer is to be the epitome of luxury on a global stage, reaching and inspiring a discerning audience with a taste for the exquisite. We are dedicated to enhancing the lives of our customers by offering them nothing less than the finest high-end jewelry. Our commitment to excellence ensures that every piece we create upholds the highest standards of quality, elegance, and innovation, allowing each wearer to experience the true essence of luxury.
Corporate Information Company Trade Name
Tax office:
Güneşli
Tax Number:
7810220178
Trade Registry Number
Istanbul Chamber of Commerce:
438460
Mersis number:
0-7810-2201-7800017
Center Address:
Bağlar Mahallesi Yalçın Koreş Caddesi NO:36 BAĞCILAR/İSTANBUL
Committed Capital Amount:
38.500.000,00
Amount of Paid Capital:
38.500.000,00
BOARD OF MANAGERS:
Chairman of the Board:
Metin SÖZER
Board Member:
Alper SÖZER
Board Member:
Sercan SÖZER
Auditor’s Title:
Dinamik Bağımsız Denetim A.Ş.Yenibosna Merkez
Mah. 29 Ekim Cad. A1 Apt. No:5/804 Bahçelievler/İstanbul
The Corporate Policy of Sözer Kuyumculuk San. ve Tic A.Ş, enacted on the 20th of August, 2020,
represents a meticulously crafted and ethically oriented blueprint for excellence in quality
management, social responsibility, adherence to the highest standards of business ethics, the
protection of human rights, and environmental stewardship. Below is an enhanced and detailed
exposition of the principal tenets of this policy:
Quality Management
Social Responsibility and Business Ethics
Human Rights
Environmental Stewardship
This Corporate Policy is a testament to Sözer Kuyumculuk San. ve Tic A.Ş’s dedication to setting new
benchmarks in ethical practices, quality management, and a comprehensive approach to social and
environmental responsibility. It showcases a progressive and conscientious model of corporate governance,
affirming the company’s leadership in fostering ethical, sustainable, and socially responsible business
practices. This policy not only reflects the company’s commitment to its foundational principles but also its
dedication to contributing positively to society and the environment, thereby ensuring a legacy of excellence
and integrity.
SÖZER KUYUMCULUK SAN. VE TİC. A.Ş. IS A MANUFACTURER AND EXPORTER OF JEWELRY.
1.1 Legislation and Regulations a. Sözer Jewelry shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Jewelry rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Jewelry recognizes the
fact that entities in the gems and Jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Jewelry shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:
1.3 System of Warranties a. Sözer Jewelry is dealing in polished diamonds and is fully committed to
complying with all the requirements specified in the World Diamond Council’s (WDC) System of Warranties
Declaration. b. We will not engage in business with the supply chain who deals in ‘conflict diamonds’ or are
not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, and will be
considered a violation of the Business Principles.
1.4 Anti-Bribery and Facilitation Payment Policy: a. Sözer Jewelry shall ensure the complete prohibition
of Bribery and facilitation payments across the organization and in all entities. b. Sözer Jewelry will not
offer, accept, or countenance any payment, gift in kind, hospitality, expense, or promises as such that may
compromise promises of fair competition. c. The entity shall prohibit bribery and facilitation payments and
shall comply with various rules and the local land law.
1.5 Disclosure of Treated Diamonds, Synthetics, and Stimulants
1.6 Diamond & Gemstone Sourcing Policy as per OECD
1.7 Gold, Silver & Platinum Group Of Metal Sourcing Policy
1.8 Supply Chain Management / Best Endeavours
1.9 Employment
1.10 Health and Safety
1.11 Non-Discrimination, Disciplinary Practices
1.12 Child Labour
1.13 Forced Labour
1.14 Human Rights
1.15 Environment Protection
1.16 Product Security
Sözer Kuyumculuk San. ve Tic A.Ş. Quality Policy
1.1 Legislation and Regulations a. Sözer Jewelry shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Jewelry rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Jewelry recognizes the
fact that entities in the gems and Jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Jewelry shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:
At Sözer Jewelry San. ve Tic A.Ş., we have developed an in-depth quality policy in adherence
to the requirements of the ISO 9001 Quality Management System standard, aiming to maintain our
leadership position in the industry and maximize customer satisfaction. This policy embraces an
approach that targets excellence at every stage of our business processes and prioritizes quality in all our activities.
Core Elements of Our Quality Policy
1.1 Legislation and Regulations a. Sözer Jewelry shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Jewelry rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Jewelry recognizes the
fact that entities in the gems and Jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Jewelry shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:
Customer Focus and Satisfaction:
1.1 Legislation and Regulations a. Sözer Jewelry shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Jewelry rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Jewelry recognizes the
fact that entities in the gems and Jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Jewelry shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:
Exceeding our customers’ expectations is at the core of every decision and action we take. We actively collect and evaluate customer feedback, using this information to improve our products and services. We continuously measure customer satisfaction and use these measurements to enhance our business processes and the quality of our service.
1. Leadership and Management Commitment: Our company’s senior management
demonstrates strong leadership and commitment to ensuring the effectiveness of our
quality management system and to enhancing quality awareness at all levels. Management
actively participates in providing the necessary resources to achieve quality objectives and
in the continuous improvement of the quality management system.
2. Employee Participation and Development: Each of our employees plays a critical role in
the success of our quality management system. We encourage employee participation and
offer training and career development opportunities, enabling them to enhance their skills
and provide higher quality service to our customers.
3. Process Approach and Operational Excellence: We systematically manage and
continuously improve our business processes. Operational excellence is crucial for
increasing the efficiency and effectiveness of our processes. This allows us to reduce
workload, lower costs, and enhance customer satisfaction.
4. Risk-Based Thinking: We adopt risk-based thinking in our decision-making processes. We
proactively identify and manage potential risks and opportunities, which directs us to adapt
more quickly to changing market conditions and customer needs.
5. Supply Chain Management and Partnership with Suppliers: We work closely with our
suppliers and partners, ensuring quality and consistency throughout the supply chain. From
the selection of suppliers, we conduct regular evaluations to ensure they adhere to our
quality standards and continuous improvement commitments.
6. Continuous Improvement and Innovation: Our quality management system is based on a
framework that encourages continuous improvement and innovation. We focus on
enhancing our processes, products, and services through innovative solutions and
technologies.
Our quality policy represents a comprehensive approach where quality is integrated into all
activities of Sözer Jewelry San. ve Tic A.Ş. This policy is a clear commitment to our customers,
employees, and all stakeholders: Quality is always our priority, and we seek to be recognized for
our unwavering commitment to excellence. We regularly review, assess, and improve the
effectiveness of our quality management system and practices, which helps us maintain our
leadership position in the industry and maximize customer satisfaction.
Sözer Kuyumculuk San. ve Tic. A.Ş. Environmental Policy
1. Policy Statement Sözer Jewelry is committed to conducting its business operations in
an environmentally responsible manner. We recognize the importance of protecting the
environment and minimizing our ecological footprint. This Environmental Policy outlines
our commitment to environmental sustainability and sets forth our objectives and principles
for managing our environmental impacts.
2. Compliance with Laws and Regulations Sözer Jewelry is committed to complying
with all applicable environmental laws, regulations, and standards in the jurisdictions where
we operate. We will continuously monitor and review our operations to ensure compliance
and strive to exceed legal requirements whenever possible.
3. Environmental Management System Sözer Jewelry will establish and maintain an
Environmental Management System (EMS) to effectively manage our environmental
impacts. The EMS will include the following elements:
a. Environmental objectives and targets: We will set measurable objectives and targets to
improve our environmental performance and reduce our environmental footprint.
b. Risk assessment and mitigation: We will identify and assess environmental risks
associated with our operations and implement appropriate measures to mitigate and
manage those risks.
c. Training and awareness: We will provide training and awareness programs to our
employees to ensure they understand their environmental responsibilities and are equipped
to contribute to our environmental objectives.
d. Resource efficiency: We will strive to optimize the use of resources, including energy,
water, and raw materials, by implementing efficient processes and technologies.
e. Waste management: We will implement waste reduction, recycling, and disposal practices
that minimize the environmental impact of our waste generation.
f. Pollution prevention: We will take proactive measures to prevent pollution, including the
proper handling, storage, and disposal of hazardous substances, and the implementation of
controls to minimize air and water pollution.
g. Continuous improvement: We will regularly monitor and review our environmental
performance and seek opportunities for continuous improvement in our environmental
management practices.
4. Sustainable Supply Chain Sözer Jewelry will work with our suppliers to promote
sustainable practices throughout our supply chain. We will encourage our suppliers to
adopt environmentally friendly practices and comply with relevant environmental
regulations.
5. Stakeholder Engagement and Communication Sözer Jewelry is committed to
engaging with our stakeholders and communicating transparently about our environmental
performance. We will:
a. Seek input from stakeholders on environmental matters and consider their concerns and
expectations.
b. Communicate our environmental policies, objectives, and performance to our employees,
customers, suppliers, and the public.
c. Respond to inquiries and concerns regarding our environmental practices in a timely and
transparent manner.
6. Monitoring and Reporting Sözer Jewelry will establish monitoring and reporting
mechanisms to track our environmental performance. This includes:
a. Regularly measuring and monitoring key environmental indicators to assess our progress
towards our objectives and targets.
b. Reporting on our environmental performance to relevant stakeholders, including through
annual sustainability reports.
c. Conducting periodic internal audits to assess compliance with this policy and identify
areas for improvement.
7. Policy Review This policy will be reviewed periodically to ensure its effectiveness and
alignment with evolving best practices, technological advancements, and regulatory
requirements
Sözer Kuyumculuk San. ve Tic. A.Ş. Health and Safety (H&S) Policy
At Sözer Kuyumculuk San. ve Tic. A.Ş., we place great importance on health and safety issues in the
workplace. In this context, our Health and Safety (H&S) policy clearly outlines our approach and
commitments in this area. All our company locations, subcontractors, and subsidiaries are obliged
to strictly adhere to this policy and commitments.
Mission
As Sözer Kuyumculuk San. ve Tic. A.Ş., we shape our sustainable and profitable growth strategy in
line with the Sustainable Development Goals outlined in the United Nations Global Compact, to
which we are a signatory. Within this framework, we are committed to maximizing our health and
safety standards and aligning all our business processes with these goals.
Key Commitments of Our Polic
Implementation Principles
As Sözer Kuyumculuk San. ve Tic. A.Ş., strict adherence to the principles and standards outlined in
our health and safety policy is one of our core values. All our employees play a critical role in the
implementation of this policy, and each is expected to act in accordance with the established
standards. This policy is not only a legal obligation but also a manifestation of our deep
commitment to protecting the health and safety of our employees.
For Preventing the Laundering of Proceeds of Crime, Terrorist Financing, and the Financing of the Proliferation of
Weapons of Mass Destruction, Sözer Kuyumculuk San. Tic. A.Ş. is committed to contributing to national and
international efforts to combat the laundering of proceeds of crime, terrorist financing, and the financing of the
proliferation of weapons of mass destruction (WMD), along with related crimes. As part of our compliance with
applicable regulations and corporate responsibility, we have established a comprehensive compliance program
within our organization.
Legal Framework
Risk-Based Approach
Acknowledging that laundering and financing activities can manifest in various forms across different sectors, our
compliance program employs a risk-based approach. This methodology facilitates the identification and
assessment of potential laundering risks specific to our field of activity. It guides the establishment of criteria and
the implementation of effective methods to mitigate and control these risks.
Implementation Procedures
The core components of our compliance program include:
Responsibility and Review
The ultimate responsibility for the effective, adequate, and proper implementation of the compliance program rests
with the Board of Directors. All staff members are required to comply with the program’s mandates. Our corporate
policies and procedures are subject to periodic review, ensuring they remain current and are communicated
promptly to all personnel.
 | SÖZER JEWELRY AML PROCEDURES IMPLEMENTATION INSTRUCTIONS FOR REGULATORY MATTERS |
| |||||||||
| TOPIC | Asset Freezing and Procedures and Principles to be Followed in the Execution of These Decisions | ||||||||||
| YEBLIG | General Communiqué of the Financial Crimes Investigation Board (Order No: 12) |
1. PURPOSE
The purpose of this instruction is to ensure that Sözer Kuyumculuk San. Tic. A.Ş. (referred to as “Sözer” or
“Company”) complies with the regulations regarding “Asset Freezing and Procedures and Principles to be Followed
in the Abolition of These Decisions” within the framework of establishing Regulatory Compliance standards.
2. RESPONSIBILITY AND AUTHORITY
2.1 Director General’s Responsibility: The Director General is responsible for the implementation of this instruction.
2.2 Review and Update: The Director General is responsible for the periodic review and update of this instruction to
ensure its effectiveness and compliance with current laws and regulations.
2.3 Unit Manager(s) and Employee Compliance: The relevant Unit Manager(s) are responsible for ensuring that all
employees are fully informed of and comply with this instruction.
3. APPLICATION
In alignment with the “Procedures and Principles to be Followed in the Freezing of Assets and the Abolition of
These Decisions” under the scope of combating the financing of terrorism and the proliferation of weapons of
mass destruction, the following procedures apply:
3.1 Operation Service Review:
a) For ongoing precious metal sales transactions, if payment has been made, the precious metals are not delivered
to the buyer. Moreover, collected amounts, whether in cash or credited, will not be refunded.
b) For incomplete purchase transactions, precious metals that have been given but not paid for will not be returned
to the seller.
3.2 BIST Precious Metals and Precious Stones Market Transactions: If transactions involve the BIST Precious Metals
and Precious Stones Market, stock exchange authorities are immediately notified to freeze the assets of the
involved parties.
3.3 Ministry Notifications: All notifications from the Ministry are to be responded to in the same method they were
received, promptly upon completion of asset freeze transactions, and within a maximum of 7 days.
3.4 Non-Asset or Unregistered Asset Cases: Individuals without assets in our possession or whose assets cannot be
registered are reported to the Ministry with their identity information, noting these specifics.
3.5 Asset Record Holders: Information regarding the freezing of assets for those with recorded assets is
documented and reported to the Ministry.
3.6 Asset Freeze Lift Instructions: Following the Ministry’s instructions to lift an asset freeze, the action taken is
reported back to the Ministry accordingly.
4. Effective Date
This instruction becomes effective as per the relevant legislative provisions, from June 21, 2020.
Q. ANNEXES
Sözer Kuyumculuk San. ve Tic. A.Ş. Human Rights Policy
Purpose and Scope This Human Rights Policy (“the Policy”) is a guide that reflects Sözer
Kuyumculuk San. ve Tic. A.Ş.’s approach and standards in relation to human rights and shows the
importance Sözer Jewelry attributes to respect for human rights. All employees, directors, and
officers of Sözer Jewelry shall comply with this Policy. Each Sözer Jewelry company also
expects and takes necessary steps to ensure that all its Business Partners – to the extent applicable
– complies with and/or acts in line with this Policy.
Elimination of discrimination in employment and occupation.
“The Women’s Empowerment
Principles” (WEPs) a set of Principles offering guidance to business on how to promote gender
equality and women’s empowerment in the workplace, marketplace, and community. Established
by UN Global Compact and UN Women, the WEPs are informed by international labor and human
rights standards and grounded in the recognition that businesses have a stake in, and a
responsibility for, gender equality and women’s empowerment.
General Principles As a globally acting group, Sözer Jewelry takes the Universal Declaration
of Human Rights (UDHR) as its guide, and maintains a respectful understanding of Human Rights
for its stakeholders in countries where it operates. Creating and maintaining a positive and
professional working environment for its employees is the main principle of Sözer Jewelry.
Sözer Jewelry acts in compliance with the global ethical principles in subjects such as
recruitment, promotion, career development, wage, fringe benefits, and diversity and respects its
employees’ rights to form and join organizations of their own choosing. Forced labor and child
labor and all forms of discrimination and harassment are expressly prohibited. Sözer Jewelry
primarily takes into consideration the below-mentioned international standards and principles
regarding Human Rights:
• The ILO Declaration on Fundamental Principles and Rights at Work
(1998),
• The OECD Guidelines for Multinational Enterprises (2011).
• The UN Global Compact (2000).
• The UN Guiding Principles on Business and Human Rights (2011).
• The Women’s Empowerment Principles (2011). • Worst Forms of Child Labour Convention (Convention No. 182), (1999)
Commitments
Sözer Jewelry respects the rights of its employees, directors, officers, shareholders, Business
Partners, customers, and all other individuals affected by its operations, products, or services by
fulfilling the principles of the Universal Declaration of Human Rights (UDHR) and the ILO
Declaration on Fundamental Principles and Rights at Work. Sözer Jewelry undertakes to treat
all employees in an honest and fair manner, and to provide a safe and healthy working
environment that respects human dignity while avoiding discrimination. Sözer Jewelry may
also apply additional standards considering vulnerable and disadvantaged groups who are more
open to the negative Human Rights impacts and require particular attention. Sözer Jewelry
considers the specific circumstances of groups whose rights are further elaborated by United
Nations instruments: indigenous peoples; women; ethnic, religious and linguistic minorities;
children; persons with disabilities; and migrant workers and their families, as indicated in the UN
Guiding Principles on Business and Human Rights.
Diversity and Equal Recruitment Opportunities Sözer Jewelry strives to employ individuals
from different cultures, career experiences, and backgrounds. Decision-making processes in
recruitment depend on job requirements and personal qualifications regardless of race, religion,
nationality, gender, age, civil status, and disability.
Non-Discrimination Zero-tolerance towards discrimination is a key principle in the entire
employment process, including promotion, assignment, and training. Sözer Jewelry expects all
its employees to demonstrate the same sensibility in their behavior towards each other. Sözer
Jewelry cares to treat its employees equally by offering equal rights and opportunities. All
kinds of discrimination and disrespect founded on race, gender, color, national or social origin,
ethnicity, religion, age, disability, sexual orientation, gender definition, or political opinion are
unacceptable.
Zero Tolerance to Child / Forced Labor Sözer Jewelry strongly opposes child labor, which
causes children’s physical and psychological harm, and interferes with their right to education. In
addition, Sözer Jewelry opposes all forms of forced labor, which is defined as work that is
performed involuntarily and under the menace of any penalty. Pursuant to Conventions and
Recommendations of the ILO, the Universal Declaration of Human Rights, and the UN Global
Compact, Sözer Jewelry has a zero-tolerance policy towards slavery and human trafficking
and expects all its Business Partners to act accordingly.
Freedom of Organization and Collective Agreement Sözer Jewelry respects employees’
right and freedom of choice to join a trade union, and to collectively bargain without feeling any
fear of retaliation. Sözer Jewelry is committed to a constructive dialogue with the freely
chosen representatives of its employees, represented by a legally recognized labor union. Health
and Safety The protection of health and safety of the employees, and other persons which are, for
any reason, present in a work area is one of the top concerns of Sözer Jewelry companies.
Sözer Jewelry provides a safe and healthy working environment. Sözer Jewelry
companies take necessary security measures in workplaces in a manner that respects the dignity,
privacy, and reputation of each person. Sözer Jewelry complies with all relevant regulations
and implements all required security measures for all its working areas. In the case of finding out
any unsafe conditions or unsafe behaviors in the working areas, Sözer Jewelry companies take
necessary actions immediately to ensure the health, safety, and security of its customers and
employees.
No Harassment and Violence A key aspect of safeguarding the personal dignity of employees is
to ensure that harassment or violence does not occur, or if it occurs sanctioned adequately. Sözer
Jewelry is committed to providing a workplace free of violence, harassment, and other
insecure or disturbing conditions. As such, Sözer Jewelry does not tolerate any form of
physical, verbal, sexual or psychological harassment, bullying, abuse, or threats.
Working Hours and Compensation Sözer Jewelry complies with the legal working hours in
line with the local regulations of the countries where it operates. It is crucial that employees have
regular breaks, vacations, and establish an efficient work-life balance. The wage determination
process is established in a competitive manner according to the relevant sectors and the local
labor market, and in accordance with the terms of collective bargaining agreements if applicable.
All compensations, including social benefits, are paid in accordance with the applicable laws and
regulations. Employees may request further information from the officer or department in charge
of compliance regarding the laws and regulations that regulate working conditions in their own
countries, if they wish so.
Personal Development Sözer Jewelry provides its employees with opportunities to develop
their talent and potential, and to build their skills. Regarding human capital as the valuable
resource, Sözer Jewelry puts effort into the employees’ comprehensive personal development
by supporting them with internal and external training.
Data Privacy In order to protect the personal information of its employees, Sözer Jewelry
maintains high-level data privacy standards. Data privacy standards are implemented in
accordance with related legislations. Sözer Jewelry expects the employees to comply with
data privacy laws in each of the countries it operates.
Political Activities Sözer Jewelry respects its employees’ legal and voluntary political
participations. Employees may make personal donations to a political party or a political candidate
or engage in political activities outside working hours. It is, however, strictly forbidden to use
company funds or other resources for such donations or any other political activity.
Authority and Responsibilities
All employees and directors of Sözer Jewelry are responsible for complying with this Policy,
implementing and supporting the relevant Sözer Jewelry company’s procedures and controls
in accordance with the requirements in this Policy. Each Sözer Jewelry company also expects
and takes necessary steps to ensure that all its Business Partners to the extent applicable comply
with and/or act in line with this Policy. If there is a discrepancy between the local regulations,
applicable in the countries where Sözer Jewelry operates, and this Policy, subject to such
practice not being a violation of the relevant local laws and regulations, the stricter of the two,
supersede. If you become aware of any action you believe to be inconsistent with this Policy, the
applicable law or Sözer Jewelry Code of Ethics, you may seek guidance or report this incident
to your line managers. You may alternatively report the incident to Sözer Kuyumculuk’s Ethics
Hotline via the following link: “sozerkuyumculuk.com.tr/hotline” Sözer Jewelry employees may
consult the Human Resources Department in Sözer Jewelry for their questions related to this
Policy and its application. Violation of this Policy may result in significant disciplinary actions
including dismissal. If this Policy is violated by third parties, their contracts may be terminated.
History This Policy takes effect on 19.12.2021 as of the date approved by the Board of Directors
and is maintained by Human Resources Department.
Sözer Kuyumculuk San. ve Tic A.Ş. Child Labor Policy
1. Introduction
Sözer Kuyumculuk San. ve Tic A.Ş. is committed to a stance of zero tolerance towards child labor in
its business practices, in accordance with the United Nations (UN) Convention on the Rights of the
Child and the International Labour Organization (ILO) standards. Our company aims to maintain its
leadership in the industry and to adopt high ethical standards, transparency, and responsibility in
all business processes by implementing a zero-tolerance policy against child labor.
2. Scope and Purpose
This policy encompasses all internal and external operations of Sözer Kuyumculuk San. ve Tic A.Ş.,
including the supply chain, subcontractors, suppliers, and business partners. Our goal is to be an
industry leader in preventing child labor, protecting and supporting children’s rights. This policy is
prepared in alignment with the guidance and standards provided by the UN and ILO.
3. Definition and Prohibition of Child Labor
Child labor refers to any work that negatively affects a child’s education, health, physical, mental,
moral, social, and spiritual development. Sözer Kuyumculuk San. ve Tic A.Ş. strictly adheres to the
minimum working age defined by the ILO and the UN Convention on the Rights of the Child in its
hiring processes. The age limit is based on the higher of the age when compulsory education is
completed or any higher age.
4. Responsibility and Implementation
5. Violations and Complaint Mechanism
In the event of any violation related to child labor, individuals within or external to the company
can report the situation confidentially. The company takes all reported violations seriously and
swiftly implements necessary corrective measures. [https://sozer.com.tr/hotline]
6. Continuous Improvement
Sözer Kuyumculuk San. ve Tic A.Ş. regularly reviews and updates its policies and practices to
ensure continuous improvement and adoption of best practices in combating child labor.
7. Policy Review
Our child labor policy will be regularly reviewed and updated in accordance with the current
guidance and standards related to child labor provided by the UN and ILO.
Effective Date: [11/28/2015]
This policy demonstrates Sözer Kuyumculuk San. ve Tic A.Ş.’s clear and definitive stance against
child labor. As a company, we are committed to contributing to international efforts to protect and
support children’s rights.
Sözer Kuyumculuk San. ve Tic. A.Ş. Personal Data Protection Policy
This Sözer Kuyumculuk San. ve Tic A.Ş. Personal Data Protection Policy (“Policy”), which is part of
the Sözer Kuyumculuk San. ve Tic A.Ş. Code of Ethics, aims to provide a compliance framework and
coordinate compliance activities for Sözer Kuyumculuk San. ve Tic A.Ş. companies for complying
with Legislation on the protection and processing of personal data. In this context, the objective is
to ensure the personal data processing activities by Sözer Kuyumculuk San. ve Tic A.Ş. companies
are carried out in compliance with the principles of lawfulness, good faith, and transparency. The
employees and executives of Sözer Kuyumculuk San. ve Tic A.Ş. companies are obliged to act in
accordance with this Policy. Business Partners are also expected to act in accordance with the rules
and principles of this Policy to the extent that they are applicable to the relevant transactions.
Definitions
“Explicit Consent” Consent related to a specific subject, based on information and expressed with a
free will.
“Anonymization” Making personal data unrelated to an identified or identifiable natural person
under any circumstances, even when by matching with the other data.
“Data Subject” A real person of whom personal data are processed (customers, visitors, employees,
and employee candidates, etc.).
“Business Partners” Suppliers, vendors, authorized service companies, all kinds of representatives,
subcontractors, and consultancies acting on in the name of and on behalf of the company.
“Personal Data” Any information related to an identified or identifiable real person. “Processing of
Personal Data” Any activity performed on data such as obtaining personal data by fully or partially
automatic means or non-automatic means that are part of a data registration system; recording,
storage, retention, revision, modification, disclosure, transfer, receiving of data, rendering the data
obtainable or classification or prevention of use. “Sözer Kuyumculuk San. ve Tic A.Ş.” Refers to all
companies controlled directly by Sözer Kuyumculuk San. ve Tic A.Ş.,
“Legislation” All of the relevant legislation in force in Turkey and relevant countries regarding the
protection of personal data, especially the Law on the Protection of Personal Data No. 6698.
“Special Categories of Personal Data” Race, ethnic origin, political view, philosophical belief,
religion, religious sect or other beliefs, clothing style, association, foundation or union
membership, health, sexual life, criminal convictions, and security measures as well as biometric
and genetic data are special categories of personal data.
“VERBİS” Data Controllers Registry Information System “Data Processor” A real or legal person that
processes personal data for and on behalf of the data controller based on the authorization
granted by the data controller.
“Data Controller” A real or legal person who determines the objectives and means of personal data
processing and is responsible for the establishment and management of the data recording
system.
General Principles
Breach of this Policy may result in significant consequences for Sözer Kuyumculuk San. ve Tic A.Ş.
companies, their associated executives, and employees including legal, administrative, and criminal
penalties based on the Legislation in the region of operation, and, most significantly, the breach
may result in serious harm to the reputation of Sözer Kuyumculuk San. ve Tic A.Ş. companies.
One of the most important issues for Sözer Kuyumculuk San. ve Tic A.Ş. companies is to act in
accordance with the Legislation and the general principles set out in the Legislation with regards to
the processing of personal data. In this regard, Sözer Kuyumculuk San. ve Tic A.Ş. companies are
expected to follow the guidelines outlined below when processing personal data in compliance
with the Legislation.
Sözer Kuyumculuk San. ve Tic A.Ş. carries out the personal data processing practices within the
scope of its activities in accordance with the Sözer Kuyumculuk San. ve Tic A.Ş. Personal Data
Protection and Processing Policy.
[The rest of the document would continue with the updated company name, ensuring consistency
throughout the entire policy.]
3.1. Processing of Personal Data in Accordance with the Law and Principle of Good Faith
The general rule of trust and good faith in compliance with the Legislation must be adhered to on
the subject of personal data processing. In this context, personal data should be processed in
accordance with general principles of law, good-will, and general morality to the extent required
by business activities and limited to these activities.
3.2. Ensuring that Personal Data is Accurate and Up-to-date When Required
Systems must be established, and necessary measures must be taken to ensure that the personal
data being processed are accurate and up-to-date while taking account of data subjects’ rights.
3.3. Processing of Personal Data for Specific, Explicit, and Legitimate Purposes
Personal data must be processed for legitimate and lawful purposes. Sözer Kuyumculuk San. ve Tic A.Ş. must
only process personal data in connection with their activities and to the extent necessary. Prior to
personal data processing operations, the purposes for processing personal data should be
determined.
3.4. Being Limited, Proportionate, and Relevant to the Purpose of Processing
Personal data must be processed adequately for carrying out the determined purposes and
processing of personal data that is not necessary for fulfilling the purposes must be avoided.
3.5. Storing for the Period Stipulated in the Relevant Legislation or the Period Required for
the Processing Purpose
Personal data must only be stored for the period stipulated in the relevant Legislation or for the
period required for the personal data processing purpose. In this regard, firstly determination must
be made whether a certain period is stipulated for the storage of personal data in the relevant
Legislation, if any period is determined, this period should be complied with. If no period is
determined, personal data must be stored for the period required for carrying out the purpose of
the processing. Personal data must be erased, destructed, or anonymized in case the period
expires or the reason for its processing no longer exists. Personal data must not be stored based
on the possibility of future use.
Application of The Policy
1. Processing Personal Data Based On The Data Processing Conditions
4.1.1. Execution of Personal Data Processing Activities Based on the Personal Data
Processing Conditions Specified in the Legislation
As a rule, personal data must be processed based on at least one of the conditions specified in the
Legislation. Determination should be made on whether the personal data processing activities
carried out by the company’s business units are based on at least one of the conditions. Personal
data processing activities that do not meet this requirement should not be included in the
processes.
4.1.2. Execution of Special Categories of Personal Data Processing Activities Based on
Special Categories of Personal Data Processing Conditions Stipulated in the Legislation
As a rule, special categories of personal data must be processed based on the conditions specified
in the Legislation. Sözer Kuyumculuk San. ve Tic A.Ş. must ensure that the special categories of personal data
processing activities carried out by the company’s business units are in line with these conditions,
the necessary technical and administrative measures for the processing of the special categories of
personal data must be taken and it must be ensured that the following conditions are met: (i)
Special categories of personal data excluding health and sexual life can be processed without the
explicit consent of data subjects if it is explicitly stipulated in the laws. Otherwise, explicit consent
of the data subject should be obtained. (ii) Special categories of personal data regarding health
and sexual life can be processed without the explicit consent of data subjects for the purposes of
the protection of public health, carrying out preventive medicine, medical diagnosis, treatment and
care services, planning of financing and management of health services by persons who are bound
with professional secrecy or legally authorized authorities and institutions. Otherwise, explicit
consent of the data subject should be obtained.
Processing of special categories of personal data must be carried out in accordance with the
provisions set out in the Legislation regarding the processing of special categories of personal data
and transfer of data to domestic third parties and abroad. In addition, personal data processing
activities must also be carried out by fulfilling the special requirements set forth in the Legislation.
2. Requirements To Be Complied With For Transfer Of Personal Data
Personal data of data subjects should be transferred to third parties in accordance with the
purposes and legal basis for personal data processing and by taking the necessary security
measures. In this regard, necessary processes for acting in accordance with the conditions
stipulated in the Legislation must be designed.
3. Obligations Related To The Protection And Processing Of Personal Data
4.3.1. Obligation to Register with VERBİS
Sözer Kuyumculuk San. ve Tic A.Ş. must register with VERBİS as Data Controllers if they are under the obligation
to register according to the criteria stipulated in the Legislation. In case of a revision in the
registered information, the information in VERBİS must be updated within seven days from the
date of revision.
Sözer Kuyumculuk San. ve Tic A.Ş. Legal and Compliance Department must be given a report and the
company’s department or officer in charge of compliance must be informed twice a year, every 6-
month periods (June-December) regarding the updates made by the Sözer Kuyumculuk San. ve Tic A.Ş.
companies in VERBİS.
Continued adherence to the remaining sections of the policy is essential, applying the
updated company name “Sözer Kuyumculuk San. ve Tic A.Ş.” wherever necessary to ensure
consistency and compliance with the Legislative requirements.
Sözer Kuyumculuk San. ve Tic A.Ş. Whistleblower Policy
1. Introduction
Sözer Kuyumculuk San. ve Tic A.Ş. is committed to maintaining its leadership position in the
industry and adopting high ethical standards, transparency, and accountability in all business
processes, in compliance with the Responsible Jewelry Council (RJC) and all relevant legal
regulations. Accordingly, our company has developed a secure and effective whistleblower policy
for reporting any unethical behavior, corruption, and activities contrary to policies or legal
regulations. This policy is designed to protect whistleblowers and ensure that any potential
violations are investigated fairly.
2. Scope and Purpose of the Policy
This whistleblower policy covers all employees, managers, customers, suppliers, and other
stakeholders of Sözer Kuyumculuk San. ve Tic A.Ş. The purpose of the policy is to facilitate the safe,
confidential, and anonymous reporting of violations, and to ensure that reported violations are
evaluated effectively and necessary corrective and preventive actions are taken. This policy
reinforces the company’s commitment to laws, ethical rules, and sectoral standards, while also
fostering a culture of trust and honesty.
3. Subjects of Reporting
The range of issues that can be reported by whistleblowers is broad and generally includes, but is
not limited to, the following:
4. Mechanism and Process of Reporting
Sözer Kuyumculuk San. ve Tic A.Ş. offers multiple channels to facilitate easy and secure reporting.
These channels include a specially designed hotline, email address, written letters, or a secure
internet portal. Reports can be made anonymously, and all reports are treated with the highest
degree of confidentiality. Each reported case is initially subjected to a preliminary review and,
where necessary, detailed investigations are conducted according to the seriousness and nature of
the issue. The investigation process is based on principles of transparency, fairness, and prompt
action.
OUR WHISTLEBLOWER CHANNELS
Via e-mail: Compliance@sozer.com.tr
Via Web: sozer.com.tr/hotline
Phone: +90 212 655 83 72 (Mrs. Sibel Tezcan)
5. Protection and Confidentiality
Sözer Kuyumculuk San. ve Tic A.Ş. places great importance on protecting the identities of
whistleblowers and ensuring they do not face any retaliation or discrimination after making a
report. The company explicitly prohibits any form of retaliation against whistleblowers and
commits to taking serious action in case of violation.
6. Continuous Improvement and Training
The company will continuously review and improve the effectiveness and appropriateness of the
whistleblower policy. Additionally, regular training and awareness programs will be conducted for
employees on ethical behavior, combating corruption, and the importance of the whistleblower
policy.
7. Policy Review and Update
This whistleblower policy will be regularly reviewed and updated to align with the company’s
needs, legal regulations, and best practices. The effective implementation of this policy is the
responsibility of the company’s management team, and all employees are expected to understand
and apply this policy.
Effective Date: [02/14/2023]
Sözer Kuyumculuk San. ve Tic A.Ş., through this whistleblower policy emphasizing the importance
of an ethical and responsible business world, invites all its employees and stakeholders to
contribute to maintaining a transparent and fair working environment.
Sözer Kuyumculuk San. ve Tic. A.Ş. Due Diligence Process Policy
Sözer Kuyumculuk San. ve Tic. A.Ş., specializing in gold, silver, and diamond Jewelry, is dedicated to
conducting its business with integrity, transparency, and respect for human rights and
environmental standards. This policy outlines the due diligence process for ensuring ethical
sourcing and responsible business practices in the procurement and sale of gold, silver, and
diamond Jewelry.
Purpose
The purpose of this policy is to establish a robust framework for identifying, assessing, and
mitigating risks associated with the sourcing and supply chain of gold, silver, and diamonds. This
includes risks related to conflict financing, human rights abuses, and environmental degradation.
Scope
Due Diligence Process, Risk Assessment:
Perform regular risk assessments to identify potential ethical and compliance risks in the supply
chain of gold, silver, and diamonds.
Pay special attention to sourcing from conflict-affected and high-risk areas (CAHRAs).
Supplier Vetting and Verification:
Vet and verify suppliers through comprehensive background checks, ensuring they comply with
international human rights, labor, and environmental standards.
Require suppliers to provide proof of origin and certification, such as the Kimberley Process
Certification Scheme for diamonds.
Chain of Custody and Traceability:
Implement traceability systems to track the movement of gold, silver, and diamonds from their
source to final product. Ensure a transparent chain of custody to guarantee that materials are
conflict-free and sourced ethically.
Compliance and Monitoring:
Conduct regular audits and inspections of suppliers to ensure ongoing compliance with this policy.
Employ third-party auditors when necessary to provide an unbiased assessment of compliance
efforts.
Risk Mitigation and Corrective Actions:
Develop and implement corrective action plans for any identified risks or non-compliance within
the supply chain.
Engage with suppliers to improve practices and remediate adverse impacts.
Reporting and Transparency:
Maintain detailed records of due diligence efforts, audits, and compliance measures.
Publish annual sustainability and compliance reports to communicate efforts and progress to
stakeholders.
Training and Awareness:
Provide training to employees and business partners on ethical sourcing, compliance, and the
importance of due diligence.
Raise awareness about the social, environmental, and ethical implications of gold, silver, and
diamond sourcing.
Policy Review and Updates
This policy will be reviewed annually or more frequently as needed to reflect changes in
regulations, industry standards, and company operations.
Updates will be communicated to all relevant parties in a timely manner.
Enforcement and Compliance
Non-compliance with this policy will result in disciplinary actions, up to and including termination
of contracts for suppliers and legal actions where applicable.
Encourage employees and external stakeholders to report violations of this policy through
established reporting channels, ensuring confidentiality and protection from retaliation.
Effective Date
This policy takes effect on 09.09.2023 and establishes Sözer Kuyumculuk San. ve Tic. A.Ş. as a leader in ethical and responsible sourcing in the gold, silver, and diamond Jewelry industry.
POLICY FOR CONDUCTING BUSINESS IN ACCORDANCE WITH THE RJC CODE OF CONDUCT
Sözer Kuyumculuk San ve Tic A.Ş. is committed to conducting its business in accordance with the
Responsible Jewelry Council (RJC) Code of Practices. The RJC Code of Practices sets out
responsible business practices for the entire Jewelry supply chain,
including ethical, social, and
environmental standards. This policy outlines our commitment to upholding the RJC Code of
Practices and our approach to implementing and monitoring compliance.
Compliance with the RJC Code of Practices
a. Sözer Kuyumculuk San ve Tic A.Ş. will comply with all applicable provisions of the RJC Code of
Practices and any additional requirements set forth by the RJC.
b. We will integrate the RJC Code of Practices into our policies, procedures, and practices, ensuring
that they are communicated to all relevant employees, suppliers, and business partners.
c. We will conduct regular assessments and audits to ensure compliance with the RJC Code of
Practices, including self-assessments and independent third-party audits as required by the RJC.
d. In the event of non-compliance, we will take prompt and appropriate corrective actions to
address any identified gaps or issues.
Ethical Practices
a. Sözer Kuyumculuk San ve Tic A.Ş. will conduct its business with the highest ethical standards and
integrity, adhering to the RJC Code of Practices requirements related to anti-corruption, bribery,
and fair competition.
b. We will not engage in any form of corruption, bribery, or unethical practices, and we will
maintain accurate records and transparent financial reporting.
c. We will promote a culture of ethical behavior within our organization, providing training and
awareness programs to our employees on the RJC Code of Practices and ethical business practices.
Human Rights and Social Responsibility
a. Sözer Kuyumculuk San ve Tic A.Ş. is committed to respecting and promoting human rights,
including the prohibition of forced labor, child labor, and discrimination in all aspects of our
operations.
b. We will ensure that our employees and workers are treated with dignity and respect, providing
fair and safe working conditions, fair wages, and appropriate working hours.
c. We will engage with our suppliers to ensure they also adhere to the RJC Code of Practices
requirements related to human rights and social responsibility.
Environmental Stewardship
a. Sözer Kuyumculuk San ve Tic A.Ş. recognizes the importance of environmental stewardship and
will implement environmentally responsible practices in line with the RJC Code of Practices
requirements.
b. We will strive to minimize our environmental impact by implementing measures to reduce
energy consumption, water usage, and waste generation.
c. We will promote responsible sourcing of materials, including precious metals and gemstones,
taking into consideration environmental considerations and the rights of indigenous peoples.
Supply Chain Management
a. Sözer Kuyumculuk San ve Tic A.Ş. will work with our suppliers to promote responsible business
practices throughout our supply chain, including compliance with the RJC Code of Practices.
b. We will assess and select suppliers based on their commitment to the RJC Code of Practices and
responsible sourcing practices.
c. We will collaborate with suppliers to identify opportunities for improvement and support their
efforts to comply with the RJC Code of Practices.
Stakeholder Engagement and Transparency
a. Sözer Kuyumculuk San ve Tic A.Ş. will engage with our stakeholders, including employees,
customers, suppliers, and local communities, to understand their concerns and expectations
related to responsible business practices.
b. We will communicate our commitment to the RJC Code of Practices and our progress in
implementing it through transparent and accurate reporting.
c. We will respond to inquiries and concerns regarding our compliance with the RJC Code of
Practices in a timely and transparent manner.
Continuous Improvement
a. Sözer Kuyumculuk San ve Tic A.Ş. is committed to continuous improvement in our responsible
business practices and compliance with the RJC Code of Practices.
b. We will regularly review and update our policies, procedures, and practices to ensure alignment
with the RJC Code of Practices and evolving best practices.
c. We will actively participate in RJC initiatives and collaborate with other stakeholders to drive
continuous improvement in the Jewelry industry.
Policy Review
This policy will be reviewed periodically to ensure its effectiveness and alignment with the RJC
Code of Practices and any updates or changes made by the RJC.
SÖZER KUYUMCULUK SAN. VE TİC. A.Ş. İS A MANUFACTURER AND EXPORTER OF JEWELRY.
Our Manufacturing Factory and Showroom are located at Yalçın Koreş St. No:36 Güneşli, Bağcılar /
ISTANBUL. Our showroom in the United States is located at 54 West 47th Street Suite 3R New York, NY
10036 USA. A detailed report on the results of the year 2023-2024 is requested. According to our
Responsible Business Conduct Policy, the scope of this report covers all codes of conduct in accordance with
the Responsible Jewelry Council standards. This means that successful members must adhere to all
standard guidelines and turn all practices into verifiable actions. Over the past year, under Sözer Jewelry,
we have defined our commitment to transparent and responsible supply chain management. We have
established principles to avoid the use of conflict minerals produced through inhumane processes or
associated with accounting fraud. Moreover, to fundamentally prevent the use of conflict minerals, we have
implemented a due diligence process before transacting with suppliers. We will not trade with suppliers who
do not comply. Our Corporate Supply Chain Policy.
The company has appointed Mrs. Sibel Tezcan, COO, as the RJC representative to oversee compliance with
the relevant regulations and, in accordance with the COP, to track and trace all compliance issues (if any)
affecting our business industry. Sözer Jewelry Manufacturing has adopted the Code of Practice, established
and implemented the RJC (Code of Practice 2019) standard with full commitment to the implementation,
and the results are listed below.
Legal Compliance:
Sözer Jewelry Manufacturing has established a system to monitor legal developments and identify risks
within our company. Legal areas under the COP are covered in our system, including bribery and facilitation
payments, money laundering, working hours, health and safety compensation, and product disclosure.
All legal documents are complete and accurate, including tracking changes every month to achieve full
compliance with laws and regulations.
Policy and Implementation:
We have adopted and followed our responsible supply chain policies. We also have a strict due diligence
policy for our suppliers. All policies and actions were completed, and no supplier was found under risk
assessment. In conflict areas (Red Flags), the policy is approved by the Managing Director and
communicated both internally and externally with training and communication boards, and published
through the website https://www.sözer.com.tr.
Reporting:
We communicate annually, openly, and directly with stakeholders in our COP-related business operations.
We encourage suppliers and all stakeholders to be aware of the OECD guidelines and our supply chain
policies. We communicate with our suppliers and customers about these policies and encourage them to
strictly adhere to them.
Financial Accounts:
We maintain the financial accounts of all business transactions according to applicable regulations. Internal
audits are conducted on a preventive basis. Audited financial statements for the year 2023 and timely filing
of tax returns. All transactions are transparent, and no fraud or suspicious behavior has been detected.
The company operates its accounting and financial transactions accurately, transparently, and according to
the accounting laws of the Ministry of Commerce. Documents related to accounting and financial
transactions are categorized and kept for a certain period according to the accounting standard.
Moreover, an annual audit of the accounts by external auditors is conducted, and the statement is submitted
according to the deadline this year. Our performance this year is better. Sales in 2023 (four quarters) have
increased by at least 20% compared to 2022 (first four quarters).
Business Partners:
We exert our best efforts, consistent with our ability to influence and promote responsible business practices
among our key business partners. We encourage our suppliers to implement due diligence processes.
Human Rights:
We respect human rights, considering all potential and actual impacts on their operations and business
relationships, and encourage partners to commit to implementing and operationalizing the principles. We
communicate the relevant human rights policies and procedures under the RJC standards and all aspects of
the economy/environment/regulation, such as Proper Labor and Work Practices / Human Rights / Society /
Product Responsibility, in accordance with the United Nations’ guiding principles on business and human
rights as appropriate for their business.
Due Diligence for Responsible Sourcing From Conflict-Affected And High-Risk Areas:
We endeavor to have our supply chain comply with OECD due diligence recommendations for responsible
supply chains of minerals from conflict-affected and high-risk areas, using a system to manage our 5-step
risk assessment that follows the OECD recommendations for a 5-step framework throughout our entire
upstream, midstream, and downstream supply chain. We have established a supply chain policy and
communicate with our suppliers and direct stakeholders. We provide internal awareness by training our
relevant staff.
Bribery and Facilitation Payments:
We have established anti-bribery policies and procedures that prohibit any form of bribery and protect
employees who act as whistleblowers. We take our grievances seriously and have not found a trend or
instances of bribery in any of our business processes.
Money Laundering and Financing of Terrorism:
We have established corporate documentation and implemented Know Your Counterparty (KYC) policies and
procedures for all our suppliers. Our RJC Compliance Officer is appointed responsible for implementing KYC
policies and procedures through our due diligence with all suppliers. In cases of low-risk types and in the
case of medium-high risk, the company insists on systematic follow-up and improvement.
Security:
We assess security risks and establish risk assessment policies and procedures to protect employees,
contractors, and visitors from product theft and damage within the premises and during delivery. We
monitor security risks daily and follow up regularly.
Labor Rights and Working Conditions:
We ensure that employment terms regarding wages, hours, and other employment conditions are
communicated to employees in writing before the commencement of employment. Employment policies
and procedures are established according to Turkish and international labor standards, promoting the
absence of child labor, no forced labor, no discrimination, no harassment, and promoting freedom of
association and collective bargaining in the workplace.
Health, Safety, and Environment:
We provide a safe and healthy working environment for all employees according to Turkish laws and
international standards. This includes providing all our employees with the necessary personal protective
equipment. We also train our employees on potential hazards related to their role in the company.
Additionally, all employees undergo a full health check according to statutory requirements.
The company conducts safety and environmental risk assessments in the workplace and the immediate
community. We continuously collect data on our organization’s water and energy usage and cost every year
to track resource efficiency in our business. We have set clear targets for the use of water and electricity
resources for 2024.
Conclusion:
Sözer Jewelry Manufacturing, a manufacturer, and distributor of jewelry, have achieved our goals with the
pride and honesty of our people. All performances are in accordance with the standards of the Responsible
Jewelry Council RJC (Code of Practice 2019).
