ANNUAL REPORT

In 2024, AGUILAR DE DIOS has reaffirmed its commitment to sustainability and social responsibility by maintaining its membership in the Responsible Jewellery Council (RJC) and further strengthening its efforts to obtain certification for responsible business practices. We have consistently worked to enhance our policies and procedures, adapting them to meet industry demands and aligning them with the highest standards of ethics, human rights, and environmental management.

We have continued to prioritize strong and lasting relationships with our business partners to promote these responsible practices.

These are the actions we have carried out throughout the year:

  • We have adopted a policy for our supply chain based on the OECD principles:
  • To understand the potential and/or actual human rights risks that may exist in our upstream supply chain, we contacted all our suppliers to request the necessary information via KYC forms. This questionnaire covered, among other things: their tax information, business licenses, official identification documents, shareholder composition, key markets, etc. We established a system for managing, processing, and maintaining this information. We conducted a review of the countries where each supplier operates, cross-checking them against the CAHRAs and FATF lists to ensure we avoid engaging with regions associated with conflict financing or money laundering.
  • We made them aware of our anti-money laundering policy.
  • We collected all relevant information regarding the origin of the materials supplied to us (gold, stones, diamonds, and pearls) and requested the appropriate certificates where applicable.
  • We established a protocol for identifying and responding to the detection of “red flag” risks.

Conclusion and Future Commitment:

After this analysis, we can confirm that no deviations from the guidelines of OECD Annex II have been detected, and no human rights risks have been identified. All transactions are low-risk, conducted via bank transfers, and the controls in place comply with RJC principles.

Thanks to the efforts made throughout 2024, AGUILAR DE DIOS reaffirms its commitment to sustainability and good business practices, continuing the RJC certification process. In 2025, we will continue working on improving our policies and procedures, and strengthen our relationships with key stakeholders in the supply chain to ensure that our business practices remain a model of social responsibility and ethics in the industry.

CODE OF PRACTICES

At AGUILAR DE DIOS, we are committed to excellence in the manufacturing of jewelry, valuing integrity and ethics in all our operations. This Code of Practices sets out the standards of conduct expected from all employees and business partners of our company. Our goal is to ensure that our actions reflect the highest ethical and social values.

AGUILAR DE DIOS is a member of the Responsible Jewellery Council (RJC). The RJC is an organization that sets standards to foster responsible social and environmental practices and respect for human rights throughout the supply chain for gold, silver, platinum group metals, diamonds, and coloured gemstones.

The RJC has developed a benchmark standard for the jewelry supply chain and reliable mechanisms for verifying responsible business practices through external auditing. As a certified RJC member, we are committed to operating our business in accordance with the RJC Code of Practices. We pledge to integrate ethical, human rights, social, and environmental considerations into our daily operations, business planning activities, and decision-making processes.

This code of conduct will be reviewed annually, and measures will be implemented to address any deficiencies that may arise. It will also be communicated both publicly and directly with stakeholders.

 

LEGAL COMPLIANCE

At AGUILAR DE DIOS, we are committed to staying up to date with current laws, supported by qualified professionals in various areas of law who provide specialized advice. This ensures that we comply with all applicable laws and regulations in all our operations and business transactions. Additionally, we will maintain honest and ethical business relationships with our customers, suppliers, and business partners.

We will respect and protect the confidentiality of the company’s information, as well as that of our employees and customers. We will comply with all applicable data protection laws.

At AGUILAR DE DIOS, we have the appropriate tools to effectively implement each measure and verify compliance. Furthermore, the company has several communication channels, including email, postal mail, website, WhatsApp, among others, to facilitate efficient communication with our business partners and employees.

 

HUMAN RIGHTS

At AGUILAR DE DIOS we are committed to respecting, protecting, and promoting human rights in all our operations and business relationships. We recognize the fundamental importance of human rights as guiding principles in our business performance and commit to integrating them into all our activities and decisions.

Our company is committed to:

  • Respecting the right to life, liberty, and equality in all our operations.
  • Guaranteeing fair working conditions and respecting the right to work. This includes guaranteeing the right to association and effective recognition of the right to negotiate.
  • Promoting equal opportunities and treating all employees with dignity and respect.
  • Protecting the right to health and safety of our employees and communities.
  • Ensuring access to education and professional development for our team.
  • Protecting and respecting the privacy and confidentiality of employee and customer information.
  • Avoiding discrimination in any form and promoting diversity and inclusion.
  • Ensuring transparency and integrity in all our business operations.
  • Promoting ethical and responsible business practices throughout our supply chain.

By using our reporting channel (accessible via email, web, or our on-site mailbox), any employee can anonymously, or otherwise, report a situation that may have violated human rights.

Upon receiving such notification, an investigation process is initiated, and appropriate measures are taken as soon as possible.

 

GENERAL EMPLOYMENT CONDITIONS

At AGUILAR DE DIOS we are committed to establishing and maintaining fair, ethical, and legally compliant labour practices that promote a safe, respectful, and collaborative work environment for all our employees. This applies to all employees of AGUILAR DE DIOS, regardless of their position or hierarchical level.

We emphasize the following aspects of our employees’ working conditions:

  • Work Schedule: We will respect the established working hours according to Spanish labour law and the Cordoba Metalworkers’ Agreement.
  • Overtime: Overtime will be appropriately compensated according to the law and the Metalworkers’ Agreement, while also respecting the overtime limits established by the agreement.
  • Fair Salary: We will ensure that all employees receive fair and competitive compensation for their work, complying with minimum wage standards established by law and the Metalworkers’ Agreement.
  • Timely Payments: We commit to making timely and consistent salary payments, in accordance with current labour regulations.
  • Safe Work Environment: We will maintain a safe and healthy work environment by providing personal protective equipment (PPE) and safety training as needed. We are committed to ensuring the comprehensive safety of our facilities to safeguard both our employees and assets. Our facilities are equipped with all necessary safety measures to comply with the industry’s highest standards and applicable government regulations.
  • Non-Discrimination: We will not tolerate discrimination based on gender, age, race, religion, sexual orientation, or any other characteristic. We ensure that all “fit-for-work” individuals have equal opportunities and are not discriminated against for reasons unrelated to their ability to perform their job.
  • Workplace Harassment: We prohibit workplace harassment in all forms and commit to investigating and addressing any harassment complaints quickly and effectively. The company has its own harassment protocol, which outlines how to handle these situations.
  • Complaint Reception Mechanisms: We will establish confidential and accessible communication channels (in person, by phone, email, complaint box, WhatsApp, our web-based communication channel) for employees to file complaints or report unfair labour conditions or inappropriate practices, anonymously or not, if necessary.
  • No Retaliation: We will protect employees who file complaints or reports from retaliation or adverse actions as a result of doing so.
  • Child Labour: We are committed to protecting children’s rights and firmly oppose child labour in all its forms. We recognize that child labour is a serious violation of human rights and can have devastating consequences for children’s physical, mental, and emotional development. We ensure compliance with all laws and regulations related to the hiring and employment of personnel.

BRIBERY AND FACILITATION PAYMENTS

At AGUILAR DE DIOS we are firmly against any form of bribery or facilitation payments in our business operations. We recognize that these acts go against our core values of integrity, ethics, and transparency, and represent a violation of the trust placed in us by our customers, business partners, and community.

We are committed to complying with all applicable laws and regulations related to preventing bribery and corruption.

We establish secure and confidential mechanisms for employees to report any suspicious activity of bribery or corruption safely and without fear of retaliation.

ANTI-MONEY LAUNDERING AND KNOW YOUR COUNTERPART (KYC) POLICY

This policy confirms AGUILAR DE DIOS’s commitment to preventing money laundering and terrorist financing in its business practices and transactions. Money laundering is the process of disguising financial gains obtained from criminal activities to conceal their illegal origin. Terrorist financing is any form of financial support to those attempting to foster, plan, or participate in terrorist activities.

AGUILAR DE DIOS has established “Know Your Counterpart” (KYC) procedures to combat money laundering and terrorist financing. These procedures allow us to identify all organizations we deal with, understand the legitimacy of our business relationships, and identify and react to unusual or suspicious activities.

To support our KYC policy and procedures, AGUILAR DE DIOS has developed a KYC form that we send to all our counterparts (including our business partners: suppliers and customers) to collect relevant business information and identify money laundering risks.

By collecting and reviewing the information in the completed KYC forms, AGUILAR DE DIOS commits to:

  • Establish the identity of our counterparts.
  • Verify that our counterparts are not considered high-risk (this includes checking if they are located in high-risk jurisdictions according to the FATF, if they appear on government-sponsored watch lists or international sanctions lists (such as those of the UN), or if they source from conflict-affected and high-risk areas (CAHRAs).
  • Maintain an understanding of the nature and legitimacy of all our counterparts’ businesses.
  • Keep KYC records for at least five years.
  • Keep records of all transactions and not accept or make cash payments exceeding €1,000.
  • Monitor transactions for unusual or suspicious activity – such activities will render the counterpart high-risk.

If counterparts are deemed high-risk for any reason (for example, appearing on a sanctions list or engaging in unusual activities), we may:

  • Cease trading with the counterpart.
  • Identify the beneficial owners of the counterpart and verify if they appear on watch lists or sanctions lists.

SUPPLY CHAIN

At AGUILAR DE DIOS EXPORTACIÓN, we believe it is crucial to ensure that all agents involved in our supply chain respect and share our values of ethical and social responsibility. Therefore, we always strive to personally know our customers and suppliers to forge long-lasting relationships based on mutual trust.

Thus, we are committed to:

  • Completing due diligence before entering new business relationships: knowing the origin of the materials, ensuring that we reject purchases in cases where they come from high-risk areas or may be contributing to conflict financing (CAHRAs), supporting child labour, human rights abuses, poor mining practices, and other environmental risks.
  • Using only gold from responsible suppliers who comply with human rights and the strictest safety measures and who also hold certifications verifying their ethical, sustainable origin and compliance with OECD principles.
  • Dealing only with diamonds that fully comply with the Kimberley Process Certification Scheme. We will reject any material we believe was obtained through serious human rights violations or that benefited or supported armed rebels or terrorist groups through illegal financing or other activities.
  • Ensuring the proper functioning of the complaint’s mechanism through the communication channel, which not only allows stakeholders to express concerns but also guarantees their participation in maintaining ethical standards within the supply chain.

 

ENVIRONMENTAL POLICIES

  1. a) Environmental Management
    Environmental measures must be considered throughout the production chain, from the source to the final consumer, at the local, regional, and global levels. AGUILAR DE DIOS is committed to minimizing its environmental impact and promoting sustainable business practices. This is achieved by sourcing recycled or ethically obtained materials whenever possible, ensuring the careful handling of toxic substances, and continuously striving to reduce negative environmental impacts. This also includes collaborating in raising awareness about the responsible use of resources.
  2. b) Hazardous Substances
    At AGUILAR DE DIOS EXPORTACIÓN SA, we are committed to implementing and maintaining a hazardous substances management system to protect the health and safety of our employees, customers, communities, and the environment, in compliance with all applicable laws and regulations. We also pledge to avoid the use of internationally prohibited hazardous substances.

This management system applies to all activities and operations at AGUILAR DE DIOS that involve the handling, storage, transport, and disposal of hazardous substances.

Principles:

  • Identification of Hazardous Substances: We will identify and clasify all hazardous chemicals and materials used in our production processes.
  • Risk Assessment: We will carry out risk assessments to identify and mitigate the hazards associated with handling hazardous substances.
  • Incident Prevention: We will implement control measures and safety procedures to prevent exposure to hazardous substances and minimize the risk of accidents.
  • Safe Storage: We will store hazardous substances safely and properly, following best practices and applicable regulations.
  • Safe Handling and Transport: We will implement safe handling and transport practices for hazardous substances, including the use of personal protective equipment and emergency procedures.
  • Communication and Awareness: We will clearly communicate the risks associated with hazardous substances and promote safety awareness among all employees and stakeholders.

Regarding emissions produced during our operations, we will promote the principles of reducing, reusing, recycling, and recovering to minimize the company’s environmental impact. Additionally, we will submit an annual report documenting the liquids and quantities delivered to different waste management companies. These records will specify the type of toxic substance and the quantity delivered. Reusing, recycling, and reducing are not only morally but also economically advantageous for the company, which is why we carefully monitor and ensure the responsible use of these substances.

Our products and their components fully comply with European Union Regulation EC No. 1907/2006 of the European Parliament and Council of 18 December 2006 concerning REACH. Our products do not contain any SVHCs (Substances of Very High Concern) above the concentrations specified in Annex XVII numbers 23, 27, and 63.

 

PRODUCT INFORMATION

At AGUILAR DE DIOS EXPORTACIÓN SA, we are committed to maintaining the highest standards of integrity and transparency in all our business operations related to the sale, advertising, and marketing of our jewellery items, truthfully informing about the diamonds, coloured gemstones, synthetic stones, or pearls they contain.
We will provide accurate and transparent information about the materials, manufacturing methods, and prices of our products.
We commit to not making any false, incorrect, or misleading statements, nor omitting any material information in our commercial communications. Additionally, we will ensure that internationally accepted standards are applied in all our activities related to these materials and products.

 

REPORTS AND COMPLAINTS

We will establish procedures for employees to report violations of this Code of Practices confidentially and without fear of retaliation (Whistleblower Law – See our complaint box installed at our facilities, on our website, or via our corporate email add@aguilardedios.com).

COMPLIANCE AND CONSEQUENCES

At AGUILAR DE DIOS, we are fully aware of the challenges of immediately complying with every requirement of this code; however, they must be taken into account and addressed as promptly as possible. If any business partner repeatedly violates the provisions of this code, AGUILAR DE DIOS will be compelled to take appropriate disciplinary measures.

CONCLUSION

At AGUILAR DE DIOS we all share the responsibility of upholding and promoting the ethical and social standards set out in this Code of Practices. This code reflects our core values and our commitment to integrity and ethics in all our operations.
We are committed to continuously monitoring our performance in relation to these commitments and to taking corrective action if any violation of human rights is identified. We promote a corporate culture based on respect, responsibility, and a commitment to social justice and human rights across all areas of our business.
This policy is communicated to all employees and relevant stakeholders and is publicly available through our communication channels.