Ethics

Where our Welsh gold comes from and how it was mined

Where does your Welsh gold come from?

The Welsh gold that goes into every piece of Clogau jewellery and every watch comes from a stockpile that was mined by ourselves during the late 1990s.

Why do you only include a small amount of Welsh gold?

Gold mining no longer takes place in Wales, making Welsh gold one of the rarest in the world. For this reason, we can only include a small amount of this exclusive gold in each piece. This allows our jewellery to be not only unique but also affordable to those who wish to own a piece of Welsh history of their own. It also ensures the longevity of our supplies.

Our fragrances are created with Arran Aromatics Ltd

Statement from our trusted partners Arran Aromatics Limited, in association with Clogau for our Compose by Clogau® scent.

Arran Aromatics Limited share the public’s concern that animals should not be used to test cosmetics and toiletries products. It is Arran Aromatics Limited’s policy to ensure that animal are not used to develop and test out products. None of our finished products have ever been tested on animals, nor have we ever commissioned out suppliers or any other company to carry out animal testing on our behalf.

Arran Aromatics Limited suppliers provide positive confirmation that they comply with our 1998 fixed cut-off date policy on animal testing for cosmetic purpose on all ingredients utilised in our cosmetics and toiletries products.

We produce all collections in-house on Arran, so have the flexibility to tailor products to meet our client’s individual requirements.

Our jewellery is consistently hand-finished to the highest standard using conflict-free diamonds, ethically mined gold and a 7-stage quality control process.

Where Clogau jewellery is hand-finished

Originally, all Clogau jewellery was manufactured in North Wales, but in 2005 the decision was made to move production overseas in an attempt to fulfil customer demands for shorter manufacturing and delivery times, and to sustain the growth of the brand.

The change has meant that the costs to both customer and company have been reduced, and customers now receive their jewellery within 2-3 working days, instead of several weeks. It has also meant that we can keep up with the demand for Clogau jewellery on the high street and, increasingly, internationally.

The majority of Clogau jewellery is made up of multiple components due to the addition of Welsh gold (usually in the rose gold detailing), thus complicating the manufacturing process. A team of dedicated employees are responsible for creating jewellery of the utmost beauty and quality.

The quality and cut of our diamonds

The quality of Clogau diamonds are typically:

• In silver items where the diamond is 0.49ct or under: SI1 (slightly included) clarity and G-H colour (near colourless)
• In gold items where the diamond is 0.49ct or under: VS2-SI1 (very slightly to slightly included) clarity and G-H colour (near colourless)
• Any diamond 0.5ct or more set in gold or silver: VS1 (very slight inclusions, not visible to the unaided eye) clarity and G-H colour (near colourless)

Clogau typically uses one of two cuts: the round "brilliant cut" which has been perfected to generate the maximum radiance possible and the most important cut of the modern era, the square "princess cut".

Our gold is ethically mined

Gold from the Clogau St David’s Mine, and other Welsh gold, has been mined in an ethically sound manner. Within the majority of our jewellery, however, Welsh gold is combined with globally sourced gold.

As members of the Responsible Jewellery Council, we are committed to completing the compulsory member certification against the Code of Practices and the voluntary Chain of Custody standard, which is currently under development. The RJC aims to improve the transparency of the full jewellery supply chain; from mine to retail.

We use a 7-stage quality control process

“A trusted technique, hand-in-hand with an organised approach to the supply chain ensures that product quality is consistently high and low fault rates are maintained.”
Ben Roberts, Managing Director.

The quality of construction, finish and methods used are under constant review and improvement, and are written into the Service Level Agreement for suppliers. The agreement covers manufacturing requirements such as high quality alloys to be used in the anti-tarnish casting grain and chain sourced from the UK.

A stringent 7-stage quality-control process is in place:

1. Porosity check on cast “tree”

2. 1st stage component 1 surface finish check

3. 1st stage component 2 surface finish check

4. Solder/laser check & pre-polish

5. Final surface polish check

6. Construction & size check

7. Final check

Improving logistics

Clogau is continuously striving to improve the logistical operations it undertakes. Recent developments have enabled international jewellery orders to travel on average 80% less distance to their destination, compared with the original journey.

Policies

We conform to the Kimberley Process and use conflict-free diamonds.

Kimberley Process

Clogau operates a zero-tolerance diamond policy and insists on written assurance from each diamond supplier that the diamonds supplied have been sourced from conflict-free countries and conforms to the terms of the Kimberley Process Certification Scheme.

Set up by governments, the international diamond industry and civil society organisations, the KPCS aims to stop the trade in "conflict diamonds" and ensure that diamond purchases do not fund violence.

Clogau warrants that with regards to any product fabricated from rough diamonds mined from 01/01/2003 onwards, that the diamonds have been purchased from legitimate sources not involved in funding conflict and are in compliance with United Nations Resolutions.

We guarantee that these diamonds are conflict-free, based on personal knowledge and/or written guarantees provided by the supplier of our diamonds.

For any product fabricated from rough diamonds mined prior to 01/01/2003, we warrant that conflict diamonds will not be knowingly sold and that, to the best of our ability, we will undertake reasonable measures to help prevent the sale of conflict diamonds in this country.

Nickel Policy

Clogau declares that all carat gold items we supply, and will continue to supply, conform to the ‘Dangerous Substances and Preparations (Nickel) (Safety) Regulations 2005'.

Human Rights Policy

 Clogau Gold of Wales Limited (Clogau) recognise our responsibility to operate with respect to human rights. Everybody deserves to be treated equally, and
with respect and dignity.

Modern slavery is a crime and a violation of fundamental human rights. Clogau have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including agents, contractors, third-party representatives and business
partners, and is in addition to our Vendor Supplier Code of Conduct.

Human Rights

Our suppliers in all parts of its supply chain must comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work from time to time in force.

Slavery, human trafficking and child labour

Our suppliers must comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015 in all part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.

Working environment

All our suppliers shall provide a safe, healthy and sanitary working environment and comply with UK health and safety laws and any other relevant laws which are in force where they operate. This includes, but is not limited to, implementing procedures and safeguards to prevent workplace hazards and work-related accidents and injuries.

Wages and remuneration

Our suppliers must compensate all workers with wages and benefits which at a minimum meet the higher of:

a)     The minimum wage and benefits established by applicable law;

b)     any collective agreements;

c)     industry standards; and

d)     an amount sufficient to cover basic living requirements.

The prevention, detection and reporting of modern slavery and a breach of human rights in any part of our business or supply chains is the responsibility of all those working for us or under our control.

We expect our suppliers to avoid any activity that might lead to, or suggest, a breach of this policy. Any failure to adhere to any corrective actions
issued by Clogau could lead to a termination of our business arrangement.

Supply Chain and Responsible Sourcing Policy

Corporate integrity and responsible sourcing are of paramount importance to Clogau Gold of Wales Limited (Clogau).  These core principles are reflected in this policy, which establishes the minimum standards that must be met by any supplier or entity that forms part of our supply chain.

Responsible Sourcing

We have the responsibility to respect human rights and not contribute to conflict through our mineral purchasing decisions and practices, therefore we commit to not sourcing minerals from conflict affected and high-risk areas. This policy is consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas

Materials sourced by Clogau are silver, gold, natural stones, leather, glass and a small number of man-made stones are used in our products. All our jewellery comes from certified responsible manufacturers in line with our supplier service level agreements and according to the Responsible Jewellery Council.

We take the responsibility for mitigating risks in our supply chain very seriously and ensure that our manufacturers adhere to Clogau’s Vendor Code of Conduct which is reviewed annually as part of our external audit completed by the Edinburgh Assay Office.

We are committed to using 100% GIA certified diamonds for our engagement rings. We also ensure that our suppliers are either RJC certified or transparent in relation to their metal/gemstone supply chain.

Environmental Responsibility

We assess our suppliers and subcontractors to ensure:

a) compliance with all applicable environmental laws;

b) the goods it manufactures (including the inputs and components that it incorporates into its goods) comply with all applicable environmental laws and treaties; and

c) it only uses packaging materials that comply with all applicable environmental laws and treaties.

Bribery and Corruption

We conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.

We shall ensure our suppliers comply with all applicable laws, statutes, codes and regulations relating to the prevention of bribery and corruption (including but not limited to the Bribery Act 2010). To that end, our suppliers or subcontractors shall not accept, offer, promise, pay, permit or authorise:

a) bribes, facilitation payments, kickbacks or illegal political contributions;

b) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or

c) any other unlawful or improper payments or benefits.

Any component of our supply chain must notify Clogau in writing if it becomes aware of any breach of these provisions relating to the prevention of bribery and corruption.

Unfair business practices

Our suppliers must comply with all applicable competition laws (including but not limited to the Competition Act 1998), including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.

Due diligence

In upholding our corporate integrity and as part of our responsible souring obligations we undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. In doing so:

a) new suppliers are required to sign a service level agreement, where they agree to adhere to our ethical trading standards;

b) we monitor compliance by means of factory audits and inspections conducted by trained Clogau employees. National account customers of Clogau may also be required to visit supplier factories to ensure that certain practices are maintained such as environmental and the non-use of child labour is followed. Our suppliers are requested to provide Clogau with full access to their production facilities and to any documents pertinent to legal employment or environmental practices. Any supplier found to be in violation of the vendor code of conduct will be notified of corrective action required to avoid termination of our business relationship;

c) sanctions will be imposed against suppliers that fail to improve their performance in line with an action plan or seriously violate our vendor code of conduct, including the termination of the business relationship.

We are members of several highly esteemed associations that guarantee the quality of our jewellery

Responsible Jewellery Council

“RJC Members are committed to promoting responsible, ethical, human rights, social and environmental practices throughout the industry in a transparent and accountable manner, from mine to retail. Their commitment aims to reinforce consumer and stakeholder confidence in jewellery products.” RJC

Clogau is a member of the Responsible Jewellery Council, an international, not-for-profit organisation established to reinforce consumer confidence in the jewellery industry.

In association with the RJC, we are continuously defining and implementing responsible jewellery practices throughout our diamond and gold jewellery supply chain in order to further establish the RJC’s vision of a ‘community of confidence.

National Association of Jewellers

The National Association of Jewellers are the leading voice for the UK Jewellery industry, shaping the way for our 2,000 member companies employing 24,000 people. We protect, promote and prepare our members to make them Fit for the Future.

The Association was formed in 2015 through the unification of the British Jewellers' Association (BJA) and National Association of Goldsmiths (NAG). The Institute of Registered Valuers is also part of the NAJ family, comprised of around 100 professional valuers with formal qualifications and substantial experience. Every NAJ member is required to abide by the NAJ's Code of Conduct - based on honesty, integrity and professionalism.

Jewellery Distributors' Association

The Jewellery Distributors' Association is a non-profit-making trade body specialising in supporting the activities of those who wholesale, distribute, import and export precious and fashion jewellery. The JDA assist and advise Clogau on various aspects of business such as legislation.

Tax Free World Association

As a supplier of prestige products to the Duty Free and Travel Retail industry, Clogau benefits from a specialist recruitment service, industry research reports and news offered by the Tax Free World Association.

Institute of Direct Marketing

The Institute of Direct Marketing is internationally recognised as the leading professional body for the development of direct, data and digital marketing. An educational trust and registered charity, the IDM aids Clogau employees with lifelong learning and encourages business performance.

Institute of Directors

The Institute of Directors provides Clogau and its employees with business information, support and advice in order to raise standards at management level.

Wales Quality Centre

The Wales Quality Centre is a not-for-profit, membership organisation helping organisations across all sectors of the Welsh economy to develop, improve and grow their business through training and advisory services.

With the help of WQC, Clogau has been able to drive key business areas such as sustainability, creativity and new product development via a renewed focus on the need to promote innovation and business excellence.