California Supply Chain Transparency Act Statement

This statement has been published in accordance with the California Transparency in Supply Chains Act of 2010 (SB 657). It sets out the steps that Gm-tech2 have taken to prevent modern slavery and human trafficking in its own businesses and in its supply chain.



Business Overview

Gm-tech2 is a brand website specializing in jewelry. (collectively, “Gm-tech2”).


Gm-tech2 maintains substantial control over its product supply chain through internal jewelry manufacturing and direct diamond sourcing. In total, these internal manufacturing facilities produce approximately 60% of the jewelry sold by Gm-tech2.  The balance, and almost all non-jewelry items, is purchased from third parties that manufacture these products to Gm-tech2 specifications.  To supply its internal manufacturing facilities, Gm-tech2 processes, cuts and polishes rough diamonds at its facilities outside the U.S. and sources precious metals, polished diamonds and other gemstones, as well as certain fabricated components, from third parties.  Both these third parties and those who supply finished goods to Gm-tech2 constitute Gm-tech2 “supply chain partners”.


Gm-tech2 has been committed to conducting our business responsibly, sustaining the natural environment and positively impacting the communities in which we operate.


Policies on Modern Slavery and Human Trafficking


Gm-tech2 has long been committed to ensuring respect of the International Labour Organization Core Conventions, United Nations Universal Declaration of Human Rights, and United Nations Global Compact.  These standards are central to our responsible business policies and are the foundation for many of Gm-tech2 labor-related policies.


Code of Conduct


Gm-tech2 worldwide Business Conduct Policy (“Business Conduct Policy”) sets forth rules and principles that apply to the work conducted by Gm-tech2 to ensure compliance by Gm-tech2 and its employees with Gm-tech2 expectations regarding ethical behavior. All employees are required to sign an annual commitment to the principles set forth in the Business Conduct Policy, including commitments to act responsibly, with social awareness and with respect for human rights and fundamental freedoms.


Gm-tech2 Human Rights Policy


The Gm-tech2 Human Rights Policy captures Gm-tech2 approach to integrating human rights across our value chain in addition to addressing our most salient human rights risks, impacts, and opportunities. This policy integrates existing Gm-tech2 policies with human rights touchpoints, articulating a unified vision and approach to managing and promoting human rights.


Supplier Code of Conduct


The Supplier Code, which Gm-tech2 may from time to time amend in its discretion, sets out general principles and requirements that are applicable to all suppliers.  Further, our supply chain partners, their subcontractors that are approved to provide goods or services to Gm-tech2, and select service providers, are required to fully comply with the Supplier Code as a part of our purchasing agreements. The Supplier Code sets clear expectations for Gm-tech2 suppliers, including that all employment must be voluntary, with the current Supplier Code specifying as follows:


The Gm-tech2 does not tolerate any form of abusive or illegal labor in its supply chain such as forced labor or human trafficking.  All forms of forced labor, slavery, servitude or trafficking in human beings by Suppliers, as well as withholding identity papers or work permits or requiring workers to deposit a bond or the use of any other constraint, is strictly prohibited.  All workers are entitled to accept or leave their employment freely. Suppliers must respect workers freedom of movement. Suppliers cannot require workers to work to repay a debt to them or to a third party.


Our expectations and requirements covering responsible recruitment, forced labor, indentured, debt-bonded or convict labor, child labor and human trafficking are further detailed in our Supplier Code of Conduct Guidance (“Code Guidance”).  This Code Guidance is distributed to our supply chain partners and compliance with the requirements is mandatory.  The Code Guidance is regularly updated to ensure we are consistently communicating requirements and methods to respond to specific challenges.  All requirements in the Code Guidance are applicable throughout the supply chain, such that a supplier with which Gm-tech2 has a direct relationship in turn bears the responsibility for ensuring compliance across its own supply chain.



Training and Awareness


Gm-tech2 provides ongoing training resources and communicates expectations related to our Supplier Code through an online responsible sourcing education platform for our supply chain partners. Training webinars and e-learning modules on the Supplier Code, Gm-tech2 Human Rights Policy and on Forced Labor Prevention are available to our supply chain partners year-round.


Beyond our assessments and training, we also work to establish lasting partnerships with our suppliers and provide them with training and development programs as well as sharing best practices.  We also work jointly with industry partners, non-governmental organizations (NGOs), and local stakeholders to identify human rights-related risks and further the improvement of the most complex challenges in human rights and labor. Modules on Human Rights and Equality and Labor Rights and Fair Working Conditions will educate those along the colored gemstone supply chain on risk and mitigation strategies for modern slavery and human trafficking.




Gm-tech2 Ethics and Compliance Committee consists of cross-functional leaders from throughout the organization, including its Chief Executive Officer and other members of its senior management team.  The Committee is chaired by our Chief Compliance Officer and is responsible for leading and overseeing ethics and compliance matters at Gm-tech2 and for ensuring compliance by Gm-tech2 and Gm-tech2 employees, including in its and their dealings with relevant third parties, with applicable legal requirements and Gm-tech2 core ethical values.


Next Steps

Gm-tech2 will continue to implement our human rights policy related to our supply chain risks. We will continue to improve our risk assessment processes to continually improve our ability to identify, mitigate and account for risks within our supply chain and our owned operations. We will continue to ask our supply chain partners to conduct due diligence on their own and their supply chain’s operations.