CODE OF CONDUCT & OUR POLICIES

INTRODUCTION

The Palmiero Code of Conduct represents a shared framework of principles, values, and responsibilities that define the company’s identity and guide all business activities. It reflects Palmiero Carlo S.r.l.’s commitment to conducting operations with the highest standards of ethics, integrity, social responsibility, and environmental respect.

This Code serves as an essential reference for employees, managers, collaborators, suppliers, contractors, and business partners. It establishes clear expectations for responsible conduct and ensures that Palmiero’s distinctive identity is consistently expressed through transparent, sustainable, and accountable behavior.

Palmiero’s growth objectives are deeply rooted in its intellectual and cultural heritage. The company is built upon two fundamental pillars:

  1. Product Innovation

    Palmiero is distinguished by its ability to create unique jewelry pieces that reflect the brand’s characteristic aesthetic and artisanal expertise. Innovation is central to the company’s philosophy, driving the continuous development of original designs and refined production techniques that reinterpret the concept of artisanal luxury.

  2. High Quality

    Meticulous attention to detail and the constant pursuit of excellence define the essence of the brand. Every creation embodies uncompromising quality standards and preserves the tradition of fine jewelry craftsmanship.

These pillars are sustained by a broader commitment to ethical governance, human rights, environmental sustainability, and responsible sourcing.

RESPECT FOR HUMAN RIGHTS AND SOLIDARITY STANDARDS

Palmiero fully respects and supports internationally recognized human rights principles, including those expressed in the Universal Declaration of Human Rights.

All company actions are conducted with respect for human dignity, equality, and individual freedom. Palmiero actively promotes continuous improvement in social and occupational health conditions, recognizing that fairness, well-being, and safety are essential to fostering equality and opportunity.

The company strictly prohibits:

  1. Child labor
  2. Forced, bonded, or involuntary labor
  3. Human exploitation in any form

Employment relationships are based on voluntary engagement, transparent contractual terms, and compliance with applicable labor legislation.

Palmiero encourages responsible conduct in relationships with collaborators and suppliers, fostering awareness and accountability toward the principles outlined in this Code. Suppliers and business partners are expected to uphold equivalent standards throughout the production and commercial chain.

HUMAN RESOURCES DEVELOPMENT

Palmiero recognizes that employees and collaborators are fundamental to the company’s success. Their commitment, expertise, and motivation are key factors in ensuring that every product and service meets the highest quality standards.

The company invests in professional development, continuous training, and knowledge transfer to strengthen competencies and preserve artisanal excellence. By supporting employee growth and well-being, Palmiero reinforces the foundations of long-term sustainability and operational excellence.

The company also promotes the inclusion of young talents through collaborations with professional institutes, universities, and local organizations, contributing to the preservation of artisanal traditions and the evolution of innovation in the luxury jewelry sector.

COMMITMENT TO DIVERSITY AND INCLUSION

Palmiero embraces diversity in all its forms, recognizing similarities and differences among individuals in terms of age, culture, background, abilities, needs, race, religion, gender, and identity.

The company ensures equal opportunity in recruitment, hiring, compensation, training, and career progression. Employment decisions are based exclusively on merit, competence, qualifications, and professional performance.

Palmiero guarantees equal treatment between men and women in terms of remuneration and social benefits, in compliance with applicable labor regulations. The significant presence of women within the organization, including in technical and administrative roles, reflects the company’s commitment to gender inclusion within the traditionally craft-based jewelry sector.

Any form of discrimination, harassment, intimidation, or abusive conduct is strictly prohibited. Confidential grievance mechanisms are available to allow employees to report concerns without fear of retaliation.

Palmiero’s inclusive and diverse approach represents a strategic asset, contributing to sustainable success and the ability to attract and retain top talent.

PROFESSIONAL RECOGNITION AND FAIR LABOR PRACTICES

Palmiero is committed to maintaining a fair, inclusive, and respectful working environment founded on transparency and equality.

Employees receive fair wages in accordance with national legislation and industry standards. Working hours comply with applicable legal requirements.

The company promotes professional recognition and encourages individual potential, ensuring that every employee can contribute to collective success within a supportive and merit-based organizational structure.

HEALTH AND SAFETY AT WORK

Workplace safety is a core responsibility and an essential element of Palmiero’s operational management.

The company conducts regular risk assessments to identify potential hazards and adopts preventive and protective measures at every stage of work. Exposure to hazardous substances is strictly controlled, and all materials potentially harmful to health are stored and handled in accordance with safety regulations and best industry standards.

Palmiero invests in continuous staff training to promote a culture of safety awareness and responsibility. Protecting the physical and psychological well-being of employees is considered fundamental to sustainable performance.

ENVIRONMENTAL RESPONSIBILITY AND SUSTAINABILITY

“Responsible Sourcing Toward Sustainable Luxury”

As a family-owned company, Palmiero is fully aware of the environmental and social challenges facing the jewelry sector. Since its foundation, the company has committed to operating in harmony with the ecosystem, recognizing that each raw material carries a specific environmental and social impact.

Palmiero integrates environmental responsibility into its governance framework and production processes.

  1. Climate and Energy

    In 2024, Palmiero installed photovoltaic solar panels at its main headquarters, increasing reliance on renewable energy sources and reducing dependence on non-renewable electricity. Electric vehicle charging stations were introduced to support sustainable mobility.

    Energy consumption is continuously monitored to identify opportunities for efficiency improvements and measurable environmental impact reduction.

    Waste management practices and production process optimization are implemented to minimize environmental impact and resource waste.

  2. Responsible Sourcing and Supply Chain Due Diligence

    Palmiero promotes responsible sourcing through collaboration with carefully selected suppliers and continuous monitoring of the production chain.

    The company conducts supply chain due diligence in alignment with internationally recognized frameworks, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

    Suppliers are evaluated based on reliability, traceability, transparency, and ethical conduct. Where necessary, additional documentation and declarations are requested to ensure compliance.

  3. Conflict-Affected and High-Risk Areas (CAHRAs)

    Palmiero exercises particular caution when sourcing from Conflict-Affected and High-Risk Areas (CAHRAs). The company assesses potential risks related to:

    1. Human rights abuses
    2. Corruption
    3. Direct or indirect support to armed groups
    4. Conflict financing

    In cases where credible evidence of serious violations emerges, Palmiero adopts appropriate measures, which may include enhanced due diligence or termination of business relationships.

    The company is committed to preventing any direct or indirect contribution to conflict or illegal activities through its sourcing practices.

  4. Diamonds: Kimberley Process and System of Warranties

    Responsible diamond sourcing is central to Palmiero’s sustainability commitment.

    All diamonds used by Palmiero originate from legitimate sources and comply with the Kimberley Process Certification Scheme (KPCS), which aims to prevent the trade of conflict diamonds.

    In addition, Palmiero adheres to the World Diamond Council System of Warranties. Under this system, every invoice for the sale of natural diamonds includes a written declaration confirming that the diamonds are conflict-free, purchased from legitimate sources, and compliant with United Nations resolutions and the Kimberley Process.

    Palmiero maintains appropriate documentation and records to ensure traceability and verification throughout the supply chain.

  5. Gold and Precious Metals

    Gold and precious metals are sourced from certified and traceable suppliers in accordance with Responsible Jewellery Council (RJC) standards. Where applicable, materials are managed under RJC Chain of Custody (CoC) requirements to ensure traceability throughout the supply chain.

    Palmiero promotes the use of recycled gold and supports responsible material management practices aimed at reducing environmental impact and minimizing the need for new extraction.

    This approach ensures transparency, traceability, and compliance with internationally recognized industry standards.

  6. Colored Gemstones

    Recognizing the complexity of colored gemstone supply chains, Palmiero collaborates with suppliers committed to ethical standards and regulatory compliance.

    The company promotes transparency and traceability throughout the gemstone supply chain, ensuring that each stone is sourced responsibly and in accordance with international regulations.

TRANSPARENCY AND STAKEHOLDER ENGAGEMENT

Transparency is central to Palmiero’s governance philosophy.

The company promotes open and constructive dialogue with employees, clients, suppliers, authorities, and local communities. Palmiero is committed to providing accurate and truthful information regarding its sourcing practices, sustainability initiatives, and compliance systems.

Documentation is maintained to ensure traceability and to support audit and verification processes. Stakeholders are encouraged to raise concerns or request clarification, and the company is committed to addressing such matters responsibly and promptly.

COMPLIANCE AND REPORTING

Palmiero operates in full compliance with applicable national and international laws and industry standards.

Internal reporting mechanisms allow employees and stakeholders to report potential violations of this Code confidentially and without fear of retaliation.

Ethical conduct, transparency, and accountability are shared responsibilities and fundamental conditions for long-term trust and sustainable success.

OUR POLICIES

Health & Security

HR Policy

Anti-Money Laundering and Anti-Corruption Policy

Whistleblowing Policy