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TABLE OF CONTENT
INTRODUCTION STRATEGY, POLICIES & PRACTICES
MATERIAL TOPICS (GRI 3)
GOVERNANCE SOCIAL
45
49
31 53
Supply Chain Policy (GRI 2-23, 2-24)
Determining Material Topics (GRI 3-1)
Governance Structure (GRI 2-9)
Policies and Management Systems (GRI 2-23, 2-24)
Stakeholder Engagement (GRI 2-29)
Board and Executive Leadership
Sustainability Governance Framework
Decision-Making Process
Respect for Human Rights (GRI 2-23, 2-27)
Human Rights and Labor Practices
Anti-Bribery and Anti-Corruption Policy (GRI 2-23)
Management of Material Topics (GRI 3-3)
Grievance Mechanisms (GRI 2-25)
Freedom of Association and Collective Bargaining (GRI 407-1)
Non-Discrimination (GRI 406-1)
KYC and Anti-Money Laundering Procedures (GRI 2-23)
Risk Assessment Management System (GRI 3-3)
Our Journey (GRI 2-1, 2-6)
About This Report 45
49
55
55
Human Rights Policy (GRI 2-23, 2-27)
List of Material Topics (GRI 3-2)
Labor Standards and Working Conditions (GRI 401-2, 403-1, 405-1)
CEO Statement on Sustainability Commitment (GRI 2-22)
45
51
55
Sustainability Dashboard
46
52
56
56
56
Scope and Boundary of the Report (GRI 2-2, 2-3)
46
Alignment with RJC Code of Practices and OECD Due Diligence
Guidance (GRI 2-23, 2-24)
Entities Included in the Report (GRI 2-2)
47
Supply Chain Overview (GRI 2-6)
Geographic Reach
Membership and Certifications (GRI 2-28)
05
09
07
33
39
41
33
35
36
11
13
15
17
21
23
25
27
01 FREDERICK GOLDMAN INC 02ANNUAL SUSTAINABILITY REPORT 2024
TABLE OF CONTENT
RESPONSIBLE SOURCING 57
57
ESG and Sustainability Partner
ANNEXURES 69
GRI Content Index 71
67
58
58
58
59
ENVIRONMENTAL 61
Conflict-Free Minerals Commitment (GRI 308-1, 414-1)
OECD Guidance Implementation (GRI 3-3)
Supplier Audits and Evaluation Results (GRI 308-2, 414-2)
Health,Safety and Environment (HSE)
Supplier Due Diligence (GRI 308-1, 308-2, 414-1, 414-2)
Greenhouse Gas (GHG) Emissions (GRI 305-1, 305-2, 305-3)
Scope 1 – Direct Emissions (GRI 305-1)
Scope 2 – Indirect Emissions from Purchased Electricity
(GRI 305-2)
Scope 3 – Other Indirect Emissions (GRI 305-3)
63
63
64
65
03 FREDERICK GOLDMAN INC 04ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
GRI 2-1 TO 2-4
ABOUT THIS REPORT
This Sustainability Report presents Frederick Goldman, Inc.’s (FGI) environmental, social, and governance
(ESG) commitments, actions, and performance for the period January 1, 2024 – December 31, 2024.
It is designed to inform our stakeholders — including customers, suppliers, employees, regulators, industry
bodies, NGOs, and the communities in which we operate - about how we integrate responsibility, transparency,
and ethics into every part of our operations.
This is not simply a compliance exercise; it is a reaffirmation of our heritage values and our belief that
sustainability is both a business imperative and a moral responsibility.
This report has been prepared in reference to internationally recognized sustainability and ethical sourcing
standards:
Reporting Standards and Frameworks
By applying these frameworks, FGI ensures its reporting is transparent, credible, and aligned with global best
practices.
Global Reporting Initiative (GRI) Universal Standards 2021 – Providing a globally
accepted structure for sustainability reporting to ensure our disclosures are
relevant, comprehensive, and comparable.
Responsible Jewellery Council (RJC) Code of Practices (COP 2019) – Aligning
with the most widely respected standards for ethical, social, environmental, and
governance practices in the global jewelry supply chain.
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas – Embedding risk-based supply chain due
diligence to ensure all our materials are ethically sourced, conflict-free, and
traceable.
To provide a clear picture of our activities and
impacts, this report covers:
Operational Scope: All FGI-owned and
managed facilities, including manufacturing
operations in the United States, Mexico,
China and India.
Boundary Exclusions: Independent
downstream retailers, distributors, and end
consumers are not included within the
operational boundary; however, they remain
an important part of our stakeholder
engagement through product disclosure
policies, responsible marketing, and
sustainability communication.
Supply Chain Scope: Direct suppliers of
precious metals, natural and lab-created
diamonds, colored gemstones, 3T minerals
(tin, tungsten, tantalum), and other jewelry
components.
Scope and Boundary of the Report
This scope and boundary approach ensures that
we are reporting on the areas where we have direct
control or significant influence, particularly in
responsible sourcing.
All data presented in this report has been collected
from:
Internal systems and company records :
covering production volumes, human
resources data, training logs, and
operational KPIs.
Data Sources and Methodology
Supplier due diligence assessments :
including Know Your Counterparty (KYC)
processes, conflict-free certifications, and
audit results.
FGI publishes its Sustainability Report annually,
maintaining a consistent reporting cycle to enable
stakeholders to track our progress over time.
We welcome stakeholder feedback as an essential
part of our continuous improvement journey.
All inquiries, suggestions, or concerns regarding
this report or FGI’s sustainability practices can be
directed to:
Policy compliance reviews : measuring
alignment with FGI’s Human Rights Policy,
Supply Chain Policy, Product Disclosure
Policy, and other internal governance
measures.
Environmental performance monitoring :
data from FGI manufacturing sites on
energy, water, waste, and emissions (where
measured).
Unless otherwise noted, all figures are aggregated
globally for the 2024 calendar year.
John Orrico
Frequency of Reporting
Contact for Feedback and Inquiries
www.newb2b.fgoldman.co
Care@fgoldman.com
07 FREDERICK GOLDMAN INC 08ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
Governance
GRI 2-1, 2-6
OUR JOURNEY
Frederick Goldman
establishes a small workshop
in New York, specializing in
plain wedding rings.
Late 1940
Introduction of advanced
manufacturing techniques
alongside traditional jewelry-
making craftsmanship.
1970
Growth into one of North
America’s largest jewelry
manufacturing companies;
introduction of branded
collections.
1990
Formalization of
sustainability policies and
adoption of early responsible
sourcing practices.
2010
Implementation of the Due
Diligence Management
System to align with
OECD Due Diligence
Guidance.
2018
Renewal of RJC COP
certification (valid until
2025); supplier training
programs expanded.
2022
Sustainability strategy updated
with four pillars: Ethical
Sourcing, Human Rights,
Environmental Stewardship,
and Transparency; expanded
3T Sourcing and Vendor
Policies; published updated
Annual Due Diligence Report.
2024
Expansion of global
manufacturing footprint to
Mexico, China and India.
2000
Achieves Responsible Jewellery
Council (RJC) Certification,
marking compliance with the
Code of Practices (COP).
2015
Introduction of Lab Created
Diamond Policy and
strengthened Product
Disclosure standards.
2020
Zero high-risk suppliers
identified through annual
supply chain risk assessment;
enhanced grievance mechanism
rollout.
2023
National expansion-becoming
a trusted partner for retailers
across the United States.
1980
Expansion into a wider range
of bridal jewelry; building a
reputation for craftsmanship
and integrity.
1950–1960
09 FREDERICK GOLDMAN INC 10ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
Jewelry should tell two stories - one of beauty and one of responsibility.
CEO STATEMENT ON
SUSTAINABILITY COMMITMENT
JONATHAN GOLDMAN Jonathan Goldman,
Chief Executive Officer
Frederick Goldman, Inc.
At Frederick Goldman, Inc. (FGI), we believe that every ring, bracelet, and necklace should carry not only the
sentiment of the wearer but also the assurance of ethical creation. Jewelry is a powerful symbol of love, of
celebration, of milestones — and it is our responsibility to ensure that its story is as pure and inspiring as the
moment it represents.
For more than seven decades, we have been committed to excellence in craftsmanship, innovation, and design.
Today, that same commitment extends beyond artistry into every part of our business: how we source our
materials, how we engage with our suppliers, and how we respect the rights and dignity of every person
involved in our supply chain.
In 2024, we reaffirmed our leadership in responsible sourcing by upholding the Responsible Jewellery
Council (RJC) Code of Practices (COP 2019), which sets rigorous standards for ethical, social, and
environmental performance across the global jewelry supply chain. We also implemented the OECD Due
Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
(CAHRAs), ensuring our sourcing is transparent, verifiable, and free from association with conflict, human
rights abuses, or illicit activities.
These frameworks guide our decision-making and ensure that every diamond, gemstone, and precious metal
we use is conflict-free, ethically sourced, and traceable to reputable suppliers. All sourcing is backed by
stringent Know Your Counterparty (KYC) procedures and documented due diligence, with certification from
recognized industry bodies such as LBMA, CFSI/EICC, World Gold Council, RJC, or SRSP, and
compliance with the Kimberley Process and the World Diamond Council System of Warranties.
Our supply chain is transparent and robust. In 2024, our comprehensive supplier due diligence identified zero
high-risk suppliers. This achievement is the result of our Due Diligence Management System, led by our COO
& Due Diligence Manager, and supported by a culture of accountability, rigorous training, and regular
monitoring. But our commitment goes beyond compliance. Sustainability, for us, is not a checklist — it is a
shared responsibility between FGI, our partners, our customers, and the communities in which we operate.
We strive to create a positive impact at every stage of our value chain: protecting human rights, supporting fair
labor practices, reducing environmental impacts, and contributing to the well-being of our stakeholders.
As we look ahead, we will continue to strengthen our sustainability performance, broaden our transparency,
and innovate not just in our designs, but in the way we shape a more responsible and ethical jewelry industry.
11 FREDERICK GOLDMAN INC 12ANNUAL SUSTAINABILITY REPORT 2024
GRI 2-22
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
ENVIRONMENT
SOCIAL
GOVERNANCE
2,138.36 00
385.99 5,579.39
503.19 00
Scope 1
Direct emissions
(fuels + refrigerants)
(tCO₂e)
Anti-Bribery &
Corruption Cases
reported
Scope 3
Supply chain, logistics,
waste, commuting
(tCO₂e)
Energy Consumption (GJ)
Scope 2
Purchased electricity
(tCO₂e)
AML (Anti-Money
Laundering)
Incidents reported
00
Health & Safety
Incidents cases
ACTIVE 00
2015
RJC COP 2019
Certification
Grievance Mechanism Cases
Reported
Became RJC Member
100%
Employee Training
on Ethical Sourcing &
OHS participation
SUSTAINABILITY DASHBOARD 2024
13 FREDERICK GOLDMAN INC 14ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
SCOPE AND BOUNDARY OF
THE REPORT
GRI 2-2, 2-3
About this report
Introduction
Environmental
Social
Governance
Annexures
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
Direct suppliers providing precious
metals, gemstones, diamonds (natural
and lab-created), jewelry
components, and other materials
essential to our operations.
This Sustainability Report presents the environmental, social, and governance (ESG) performance of Frederick
Goldman, Inc. (FGI) for the period January 1, 2024 – December 31, 2024. It has been prepared in alignment
with the Global Reporting Initiative (GRI) Universal Standards 2021, the Responsible Jewellery Council (RJC)
Code of Practices (COP 2019), and the OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk Areas.
Operational Boundary:
Includes all facilities under
FGI’s ownership and
management control, as well as
activities carried out by
contracted partners on behalf
of FGI.
Supply Chain Boundary:
Covers upstream suppliers
from whom we directly
procure materials, with a focus
on responsible sourcing,
human rights, and ethical
business practices.
Exclusions: Independent
downstream retail partners,
distributors, and end consumers
are outside the direct boundary
of this report, although their
engagement is supported
through our responsible sourcing
and product disclosure
initiatives.
All FGI-owned and managed
operations globally, including
manufacturing sites, offices, and
distribution facilities in the United
States, Mexico, China and India.
Strategic business partners and
contract manufacturers where FGI
exercises direct operational control or
significant influence over production
standards.
The report covers:
Scope of the Report
Boundary Considerations
The aim of this report is to:
Purpose of the Report
Data Collection and Reporting
All data included in this report is drawn from internal company records, supplier due diligence
assessments, audit reports, and policy compliance reviews.
Environmental, labor, and governance data is consolidated globally, unless otherwise specified as
region-specific.
Policies, procedures, and practices referenced in this report are consistent across all operational sites and
supply chain partners in scope.
Provide a transparent account of FGI’s ESG performance and commitments.
Communicate our responsible sourcing, human rights, and ethical business practices to stakeholders.
Share progress against our sustainability goals and outline areas for improvement in future reporting
cycles.
15 FREDERICK GOLDMAN INC 16ANNUAL SUSTAINABILITY REPORT 2024
ALIGNMENT WITH RJC CODE OF
PRACTICES AND OECD DUE
DILIGENCE GUIDANCE
GRI 2-23, 2-24
Responsible Jewellery Council
(RJC)
SRSP (Standard Responsible
Sourcing Protocol)
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
Our sustainability framework is built upon globally recognized standards that ensure our operations, supply
chain, and products meet the highest ethical, social, and environmental expectations. The two principal
frameworks guiding our approach are:
Frederick Goldman, Inc. has been a certified Responsible Jewellery Council member since 2015, maintaining
full compliance with all applicable requirements of the COP 2019. These cover:
Ethics: Integrity, transparency, anti-corruption, and
responsible business conduct.
Environmental Performance: Minimizing
environmental impacts and managing resources
responsibly.
Product Disclosure: Ensuring customers and
stakeholders receive accurate and transparent
information about our products.
Human Rights & Labor Rights: Upholding the UN
Guiding Principles on Business and Human Rights,
prohibiting child and forced labor, and ensuring safe,
fair, and non-discriminatory working conditions.
Policy Framework
Human Rights Policy
Anti-Bribery and
Anti-Corruption Policy
Supply Chain Policy
Grievance Procedure
Supplier Requirements
Full Compliance
Responsible Jewellery Council (RJC) Code of
Practices (COP 2019)
We have adopted and publicly disclosed the following key policies to demonstrate our COP compliance:
These policies are available on our company website for all stakeholders, ensuring open access and
accountability.
Our suppliers must source exclusively from refiners and smelters that are independently audited and certified
as conflict-free under recognized programs, including:
London Bullion Market
Association (LBMA)
Conflict-Free Sourcing
Initiative/Electronic Industry
Citizenship Coalition (CFSI/EICC)
17 FREDERICK GOLDMAN INC 18ANNUAL SUSTAINABILITY REPORT 2024
World Gold Council
ALIGNMENT WITH RJC CODE OF
PRACTICES AND OECD DUE
DILIGENCE GUIDANCE
GRI 2-23, 2-24
We apply the OECD Five-Step Framework to manage risks in our mineral supply chain:
Appointment of a Due Diligence Manager responsible for oversight and policy updates.
Implementation of a comprehensive Due Diligence Management System.
Public disclosure of supply chain and human rights policies.
Annual supplier risk assessments, including Know Your Counterparty (KYC) checks.
Collection and verification of supplier information and certifications.
Clear procedures for mitigation or disengagement if a supplier is found non-compliant.
Annual review of supply chain risk management practices.
Reliance on RJC-accredited audits and recognized certification bodies for supplier verification.
Public reporting on our website, including the Annual Due Diligence Report and conflict-free
sourcing declarations.
Establish Strong
Company
Management
Systems
01
02
03
05
Identify and Assess
Risks in the Supply
Chain
Design and
Implement a
Strategy to Respond
to Identified Risks
Report Annually on
Supply Chain Due
Diligence
04
Carry Out
Independent Third-
Party Audits
OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-
Affected and High-Risk Areas
19 FREDERICK GOLDMAN INC 20ANNUAL SUSTAINABILITY REPORT 2024
01. Establish Strong Company Management Systems
Zero high-risk suppliers identified in 2024.
100% of relevant suppliers either held recognized conflict-free certifications or provided
shipment-specific evidence of conflict-free status.
All policies were reviewed, updated, and made publicly accessible.
Training sessions conducted for staff on RJC COP 2019 and OECD due diligence requirements.
By aligning with these frameworks, we ensure that every diamond, gemstone, and metal we use is not
only beautiful but also responsibly sourced, conflict-free, and traceable to reputable origins.
2024 Performance
0.2 Identify and Assess Risks in the Supply Chain
0.3 Design and Implement a Strategy to Respond to Identified Risks
0.4 Carry Out Independent Third-Party Audits
0.5 Report Annually on Supply Chain Due Diligence
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
ENTITIES INCLUDED IN
THE REPORT
GRI 2-2
Entity Name
Relationship to
FGI
Scope of
Inclusion
Primary Activities
Location(s)
Frederick
Goldman, Inc.
Parent Company
Full
Headquarters, strategy,
brand management,
corporate governance,
global supply chain
oversight, product
design, sales &
marketing
United States
FGI
Manufacturing –
USA
Wholly Owned
Full
Jewelry
manufacturing,
product
customization,
domestic logistics
United States
FGI
Manufacturing –
Mexico
Wholly Owned
Full
High-volume jewelry
manufacturing,
assembly, finishing
Mexico
FGI Office –
China
Wholly Owned
Full
Product design,
prototyping, CAD/3D
printing,
manufacturing
support
China
FGI Office – India
Wholly Owned
Full
Socuring of Stones
India
Entity Name
Relationship to
FGI
Scope of
Inclusion
Primary Activities
Location(s)
Strategic Suppliers
and Contract
Manufacturers
Contracted Partners
Partial
(sourcing,
human
rights, and
due diligence
data only)
Supply of raw
materials (diamonds,
gemstones, precious
metals) and jewelry
components
Multiple
countries
21 FREDERICK GOLDMAN INC 22ANNUAL SUSTAINABILITY REPORT 2024
This Sustainability Report covers all entities over which Frederick Goldman, Inc. (FGI) has direct ownership or
management control, as well as certain supply chain relationships where we exercise significant influence over
operational and sustainability practices.
The data and performance metrics presented apply consistently across all included entities, unless otherwise
noted as location-specific.
All FGI-owned and managed operations are included in full, with complete ESG data reported.
Strategic suppliers and contract manufacturers are included for data related to responsible sourcing,
human rights compliance, conflict-free certification, and supply chain due diligence.
Independent downstream retail partners, distributors, and end consumers are outside the operational
boundary of this report, though they are engaged through our responsible sourcing, product disclosure,
and marketing practices.
Entities Included in This Report
Boundary Rationale
Coverage Consistency
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GRI 2-6
08ANNUAL SUSTAINABILITY REPORT 2024
Precious Metals: Gold, platinum, and
silver sourced from refiners and smelters
certified by LBMA, CFSI/EICC, World
Gold Council, RJC, or SRSP.
Diamonds: Both natural and lab-created
diamonds, procured from suppliers
compliant with the Kimberley Process
Certification Scheme and the World
Diamond Council System of
Warranties.
Gemstones: Colored gemstones sourced
from trusted suppliers that meet FGI’s
ethical sourcing and human rights
policies.
Contemporary Metals: Tungsten and
specialty alloys sourced from approved,
conflict-free certified suppliers.
Centralized and regional distribution
hubs ensure efficient product
movement.
Services include direct-to-store and
direct-to-consumer shipping, drop-
shipping, reverse logistics, and
fulfillment by Amazon.
Jewelry components (e.g., clasps,
settings, chains) sourced from vendors
that adhere to our Human Rights
Policy, Supply Chain Policy, and
Grievance Procedure.
All suppliers are required to undergo
Know Your Counterparty (KYC)
verification and risk assessment.
FGI-Owned Facilities: Located in the
United States, Mexico, China and India,
integrating advanced manufacturing
technologies with artisanal
craftsmanship.
Contract Manufacturers: Selected for
specialized capabilities and adherence to
FGI’s responsible sourcing
requirements.
Raw Material Sourcing
Component Supply
Manufacturing & Assembly
Distribution & Logistics
SUPPLY CHAIN OVERVIEW
The Frederick Goldman, Inc. (FGI) supply chain
is designed to ensure that every material,
component, and finished product is sourced,
manufactured, and delivered in a way that meets
the highest ethical, social, and environmental
standards. Our sourcing and manufacturing
practices are grounded in the Responsible
Jewellery Council (RJC) Code of Practices (COP
2019) and the OECD Due Diligence Guidance
for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas.
Conflict-Free Sourcing: All materials must be sourced from independently audited, conflict-free
certified suppliers.
Transparency: Policies, supplier requirements, and grievance mechanisms are publicly available
on our corporate website.
Risk Management: Annual supplier due diligence assessments; in 2024, zero high-risk suppliers
were identified.
Training & Awareness: All relevant employees receive training on RJC COP requirements,
OECD due diligence, and responsible sourcing standards.
Boundary Rationale
Our Due Diligence Manager oversees the entire supply chain due diligence process, from initial supplier
onboarding to annual compliance reviews. The Due Diligence Annual Report is made publicly available,
ensuring accountability and transparency for all stakeholders.
Supply Chain Oversight and Reporting
23 FREDERICK GOLDMAN INC 24ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GEOGRAPHIC REACH
Asia
Precious Metals Refining
INDIA
Manufacturing & Assembly
Asia
Distribution
NORTH AMERICA
MEXICO
CANADA
Precious Metals Refining
CHINA
Manufacturing & Assembly
USA
Manufacturing & Assembly
Asia
Gemstone Sourcing
USA
Diamond Sourcing
Manufacturing & Assembly
NORTH AMERICA
Distribution
Diamond Sourcing
North America, Asia
PRECIOUS METALS REFINING
Africa, Canada, India,
Belgium, USA
DIAMOND SOURCING
Africa, Asia, South America
GEMSTONE SOURCING
USA, Mexico
MANUFACTURING & ASSEMBLY
North America, Asia, Global
Retail Markets
DISTRIBUTION
SUPPLY CHAIN STAGE
25 FREDERICK GOLDMAN INC 26ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
MEMBERSHIP AND
CERTIFICATIONS
GRI 2-6
Frederick Goldman, Inc. is committed to operating in accordance with the highest industry standards, ensuring
our products are ethically sourced, responsibly produced, and transparently marketed. Our memberships,
certifications, and compliance align us with recognized global frameworks for ethical business conduct, human
rights, and environmental responsibility.
Responsible Jewellery Council (RJC) –
Code of Practices (COP 2019)
Responsible Jewellery Council
Issuing Body
Ethical, social, human rights, labor, environmental
performance, product disclosure
Scope
Certified member since 2015; current certification valid
Nov 10, 2022 – Nov 10, 2025
Status
World Diamond Council – System of
Warranties
World Diamond Council
Issuing Body
Assurance that diamonds are conflict-free
Scope
Full compliance
Status
Kimberley Process Certification Scheme
(KPCS)
United Nations-endorsed international certification
scheme
Issuing Body
Prevention of conflict diamond trade
Scope
Full compliance for all diamond sourcing
Status
OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas
Organisation for Economic Co-operation and
Development (OECD)
Issuing Body
Responsible sourcing of minerals, risk assessment,
supply chain transparency
Scope
Fully implemented across supply chain
Status
27 FREDERICK GOLDMAN INC 28ANNUAL SUSTAINABILITY REPORT 2024
By aligning with internationally recognized frameworks, we ensure
our jewelry is not only admired for its design, but also respected for
its ethical and sustainable origins
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
MEMBERSHIP AND
CERTIFICATIONS
GRI 2-6
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
SRSP Certification
Standard Responsible Sourcing Protocol
Issuing Body
Supply chain due diligence and responsible sourcing
verification
Scope
Used where applicable
Status
Jewelers for Children (JFC)
Jewelers for Children Foundation
Issuing Body
Social impact initiatives supporting children and
families in need
Scope
Active supporter, contributing to community and
philanthropic programs
Status
29 FREDERICK GOLDMAN INC 30ANNUAL SUSTAINABILITY REPORT 2024
GOVERNANCE
GRI 2-9
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GOVERNANCE STRUCTURE
Frederick Goldman, Inc. (FGI) operates under a family-led executive governance model,
complemented by specialized management teams and compliance officers to ensure that
strategic, operational, and sustainability objectives are effectively implemented across all
business units and geographies.
FGI’s executive leadership is responsible for defining the company’s sustainability policies,
ensuring alignment with the Responsible Jewellery Council (RJC) Code of Practices and the
OECD Due Diligence Guidance.
Chief Exe cutive Of ficer (CE O)
JONATHAN GOLDMAN
Oversees divisional
performance, operational
excellence, and long-term
growth strategy.
Oversees financial
governance, resource
allocation, and compliance
with regulatory requirements.
Chief Ope rating Of ficer & D ue Dilig e nce Mana g er
JOHN ORRICO
President
RICHARD GOLDMAN
CARL FERRARI
Provides strategic
leadership, oversees business
performance, and drives
FGI’s sustainability agenda
at the highest level.
Leads operational management,
supply chain integrity, and
implementation of the Due
Diligence Management System.
BOARD AND EXECUTIVE
LEADERSHIP
Overview
33 FREDERICK GOLDMAN INC 34ANNUAL SUSTAINABILITY REPORT 2024
Chief Fin ancial Of ficer (CF O)
FGI’s governance structure for sustainability is embedded within our corporate operations:
At Frederick Goldman, Inc., high-level
strategic decisions — such as expansion
into new markets, investment in
manufacturing technology, and long-term
sustainability goals — are approved jointly
by the CEO and President. These decisions
are made after consultation with
functional heads (e.g., Finance,
Operations, Supply Chain, Sustainability)
to ensure that all business perspectives,
risks, and opportunities are considered.
This collaborative approach ensures that
strategic choices are both business-driven
and sustainability-conscious.
The Sustainability & Compliance
Committee coordinates all sustainability
data collection, verification, and
reporting. This includes tracking
performance against ESG targets,
preparing disclosures, and ensuring
compliance with frameworks such as GRI
Universal Standards 2021.
The committee provides quarterly updates
to the executive team (CEO, President,
COO), highlighting progress, risks, and
areas for improvement. This structured
reporting ensures that sustainability is
integrated into the company’s ongoing
decision-making and not treated as a one-
off annual exercise.
Our commitment to responsible business
conduct is anchored in a robust suite of
policies and procedures that guide every
aspect of our operations — from sourcing
raw materials to delivering the final piece
of jewelry. These policies are designed not
only to meet regulatory requirements but
also to exceed industry best practices and
align with globally recognized frameworks,
including the Responsible Jewellery
Council (RJC) Code of Practices, the
OECD Due Diligence Guidance, the UN
Guiding Principles on Business and
Human Rights, and other international
standards.
The Chief Operating Officer (COO), who
also serves as the Due Diligence Manager,
is responsible for leading policy
development across the organization. This
includes supply chain policies, human
rights commitments, anti-bribery
measures, and environmental management
standards Occupation Health and Safety
Policy, FGI Precious Sourcing Policy.
Policy creation is cross-functional,
involving teams from procurement, human
resources, manufacturing, legal, and
marketing. This ensures that new or
updated policies are practical, enforceable,
and aligned with international standards
such as the RJC Code of Practices and
OECD Guidance.
Sustainability Governance Framework
Strategic Decisions
Sustainability Reporting
Policy Development
Decision-Making Process
Set sustainability vision, approve policies, review ESG performance reports, ensure alignment
with industry standards.
Sustainability Champion; leads the Sustainability Collaboration Group and delivers monthly ESG
performance updates to the Board.
Integrate ESG targets into manufacturing, logistics, and product development.
Deliver training, collect ESG data, coordinate reporting, manage stakeholder engagement.
Executive Leadership
CEO, President
Sustainability & Compliance Committee (Internal)
COO/Due Diligence Manager, Sustainability Officer
Plant Managers, Production Heads
HR, Procurement, Marketing, Legal
Operational Management
Support Functions
Strategic Decisions
Sustainability Reporting
Policy Development
35 FREDERICK GOLDMAN INC 36ANNUAL SUSTAINABILITY REPORT 2024
GRI 2-9
GOVERNANCE STRUCTURE
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GRI 2-9GRI 2-9
38ANNUAL SUSTAINABILITY REPORT 2024
The following matrix maps each policy to its scope of application and the international standards it supports,
ensuring stakeholders can clearly see how our commitments are embedded into our Due Diligence
Management System and everyday practices.
Human Rights & Ethical Business Conduct : Protecting the dignity, rights, and fair treatment
of all people in our operations and supply chains.
Product Integrity & Disclosure : Guaranteeing transparency and accuracy in product
composition, origin, and marketing.
Responsible Sourcing & Supply Chain : Ensuring materials are sourced ethically, traceably, and
free from conflict.
Environmental & Health Commitments : Minimizing our environmental footprint and
ensuring safe, healthy workplaces.
Our policy framework is structured around four core focus areas:
37 FREDERICK GOLDMAN INC
GOVERNANCE STRUCTURE
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
FGI Policy Framework Matrix
39 FREDERICK GOLDMAN INC 40ANNUAL SUSTAINABILITY REPORT 2024
POLICIES AND MANAGEMENT
SYSTEMS
GRI 2-23, 2-24
Focus Area
Policy / Procedure
Scope of
Application
Global Standard
Alignment
Human Rights &
Ethical Business
Conduct
Human Rights Policy
All employees and
operations
UN Guiding Principles,
RJC COP 6–12
Human Rights Vendor
Policy
All suppliers and
contractors
UNGP, RJC COP 14
FGI Grievance
Procedure
All stakeholders
OECD Step 1, RJC
COP 31
Responsible Business
Practices Policy
Company-wide
RJC COP 1–4
Frederick Goldman
AML Policy
All transactions and
financial operations
FATF Guidance, RJC
COP 1.1
Responsible Sourcing &
Supply Chain
FGI Precious Sourcing
Policy
Gold, platinum, silver
sourcing
OECD Guidance,
LBMA, RJC COP 29
Precious Vendor Policy
Precious metal suppliers
OECD Guidance, RJC
COP 29
FGI Stone Vendor
Policy
Colored gemstone
sourcing
RJC COP 29, CIBJO
guidelines
Diamond Policy
Natural diamond
sourcing
Kimberley Process,
WDC SoW, RJC
COP 29
Focus Area
Policy / Procedure
Scope of
Application
Global Standard
Alignment
Responsible Sourcing &
Supply Chain
Diamond Procedure
Diamond handling and
documentation
Kimberley Process, RJC
COP 29
Lab Created Diamond
Policy
Lab-grown diamond
sourcing & disclosure
FTC Guides, RJC
COP 29
FGI 3T Sourcing Policy
Tin, tungsten, tantalum
sourcing
OECD Guidance, RMI
Standards
FGI 3T Vendor Policy
3T suppliers
OECD Guidance, RJC
COP 29
Supply Chain Risk
Assessment Policy
All suppliers
OECD Step 2, RJC
COP 29
Due Diligence Report
Public disclosure of
sourcing practices
OECD Step 5
Product Integrity &
Disclosure
Product Disclosure
Policy
All product categories
RJC COP 30
Assay Policy
Precious metal content
verification
ISO standards, RJC
COP 28
Assay Procedure
Precious metal testing
protocols
ISO standards, RJC
COP 28
Environmental &
Health
Environmental Policy
Statement
All operations
RJC COP 36–39, ISO
14001 principles
Occupational Health
and Safety Policy
Statement
All workplaces
ILO Conventions, RJC
COP 23–26
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GRI 2-29
Employees
Why They Are Important
Core to delivering our products
and values
Engagement Methods
Town halls, training sessions,
intranet updates, employee
surveys
Frequency
Quarterly / Ongoing
Key Topics Discussed
Workplace safety, human rights,
anti-discrimination, career
development, sustainability
initiatives
Suppliers &
Vendors
Why They Are Important
Critical to responsible sourcing
and supply chain integrity
Engagement Methods
Supplier onboarding meetings,
audits, due diligence
questionnaires, policy sign-offs
Frequency
At onboarding / Annual
Key Topics Discussed
Conflict-free sourcing, human
rights compliance,
environmental performance,
product quality
Customers &
Retail Partners
Why They Are Important
Drive demand and market
expectations
Frequency
Ongoing
Engagement Methods
Direct meetings, trade shows,
product disclosure, marketing
materials
Overview
Industry Bodies &
Certification Organizations
Why They Are Important
Maintain compliance and
leadership in responsible
business
Engagement Methods
RJC member forums,
certification audits, OECD
workshops
Frequency
Annual / As required
Key Topics Discussed
RJC compliance, OECD due
diligence, industry best practices
41 FREDERICK GOLDMAN INC 42ANNUAL SUSTAINABILITY REPORT 2024
STAKEHOLDER ENGAGEMENT
At Frederick Goldman, Inc. (FGI), we believe that transparent, inclusive, and ongoing
stakeholder engagement is essential to maintaining trust, enhancing our sustainability
performance, and aligning our actions with the expectations of those we impact. We engage
with a diverse range of stakeholders - from employees and suppliers to industry bodies and
customers - to ensure that our policies, practices, and disclosures reflect shared priorities and
mutual responsibility.
Key Topics Discussed
Product integrity, sustainability
credentials, traceability, design
trends
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GRI 2-29
Regulators &
Authorities
Why They Are Important
Ensure legal and ethical
compliance
Engagement Methods
Compliance reporting, site
inspections, licensing processes
Frequency
Annual / As required
Key Topics Discussed
Regulatory compliance, anti-
money laundering, product
safety
Local
Communities
Why They Are Important
Host operations and workforce
Engagement Methods
Community outreach, charitable
initiatives, volunteer programs
Frequency
Ongoing
Key Topics Discussed
Social responsibility projects,
local employment,
environmental stewardship
Non-Governmental
Organizations (NGOs)
Why They Are Important
Provide independent insights
into human rights, labor, and
environmental issues
Frequency
As needed
Engagement Methods
Dialogue, collaborative projects,
grievance mechanism
Key Topics Discussed
Supply chain transparency, labor
rights, environmental protection
43 FREDERICK GOLDMAN INC 44ANNUAL SUSTAINABILITY REPORT 2024
STAKEHOLDER ENGAGEMENT
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
Comply with the Responsible Jewellery Council (RJC) Code of Practices (COP 2019). Bribery, kickbacks, or facilitation payments
Conflicts of interest in supplier or customer dealings
Improper gifts, entertainment, or hospitality intended to influence business outcomes
Annual training programs for employees and suppliers.
The Grievance Procedure, which allows employees, suppliers, and external stakeholders
to report human rights concerns confidentially and without retaliation.
Corrective action processes, ensuring suppliers found in violation address issues
immediately or face disengagement.
Child labor and forced labor
Provide verifiable documentation, including certifications from LBMA, CFSI/EICC,
World Gold Council, SRSP, and the Kimberley Process Certification Scheme.
Unsafe or unfair working conditions
Sign FGI’s Vendor Policies (Precious Metals, Diamonds, Stones, and 3T) as a condition
of doing business.
Align with the OECD Due Diligence Guidance for minerals from conflict-affected and
high-risk areas.
Discrimination, harassment, and abuse
KYC Verification: All new suppliers and business partners undergo identity checks,
ownership verification, and sanction list screening.
AML Monitoring: All financial transactions are reviewed for compliance with anti-
money laundering standards.
Red Flag Checks: Suppliers from high-risk geographies undergo enhanced due diligence,
requiring additional documentation and independent audit verification.
45 FREDERICK GOLDMAN INC 46ANNUAL SUSTAINABILITY REPORT 2024
STRATEGY, POLICIES & PRACTICES
Supply Chain Policy
( GRI 2-23, 2-24 )
Anti-Bribery and Anti-
Corruption Policy (GRI 2-23)
KYC and Anti-Money Laundering
(AML) Procedures (GRI 2-23)
Human Rights Policy
(GRI 2-23, 2-27)
At Frederick Goldman, Inc. (FGI), our Supply Chain Policy ensures that all materials -
including precious metals, diamonds, gemstones, and 3T minerals - are sourced in a manner
that is ethical, conflict-free, and fully traceable.
In 2024, FGI recorded zero grievances related to human rights violations and identified no
high-risk suppliers in this area.
Implementation is reinforced by:
The policy requires all suppliers to: Integrity is central to our business. FGI’s Anti-Bribery and Anti-Corruption Policy strictly
prohibits:
As part of our commitment to ethical business, FGI has established robust Know Your
Counterparty (KYC) and Anti-Money Laundering (AML) procedures, aligned with FATF
guidance and RJC COP requirements.
Employees and suppliers receive annual training, and mandatory sign-off is required as part of
vendor onboarding. Breaches are investigated under our Responsible Business Practices Policy,
and disciplinary action, including termination of contracts, is enforced where necessary.
This framework, supported by our Due Diligence Management System (DDMS), ensures
transparency, ethical sourcing, and continuous monitoring of our global supply chain.
FGI’s Human Rights Policy reflects our commitment to respect the dignity, rights, and fair
treatment of all people across our operations and supply chain. We strictly prohibit:
We expect our suppliers to adhere to the same standards through our Human Rights Vendor
Policy. The FGI AML Policy ensures that no part of our business is associated with illicit trade,
terrorist financing, or money laundering activities.
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GRI 2-29
Monitor & Review : Annual
reassessments and ongoing
monitoring ensure continuous
compliance.
Mitigate Risks : Engaging
with suppliers to address non-
compliance; if unresolved,
disengagement procedures are
initiated.
Report Transparently:
Results are disclosed in FGI’s
Annual Due Diligence Report
and in this Sustainability
Report.
Assess Risks : Classifying
suppliers into low, medium,
or high-risk categories based
on geography, material type,
and compliance records.
Identify Risks : Through
supplier questionnaires,
audits, and KYC reviews.
47 FREDERICK GOLDMAN INC 48ANNUAL SUSTAINABILITY REPORT 2024
RISK ASSESSMENT
MANAGEMENT SYSTEM
RISK MANAGEMENT PROCESS
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
49 FREDERICK GOLDMAN INC
GRI 3
Executive Review : Validation of material topics by FGI’s executive leadership,
COO/Due Diligence Manager, and Sustainability & Compliance Committee.
Stakeholder Engagement : Inputs gathered from employees, suppliers,
customers, regulators, NGOs, and industry bodies (see Section 3.4).
Policy & Standards Review : Alignment with the Responsible Jewellery
Council (RJC) Code of Practices (COP 2019), OECD Due Diligence Guidance,
and the GRI Standards.
50ANNUAL SUSTAINABILITY REPORT 2024
MATERIAL TOPICS
Frederick Goldman, Inc. (FGI) determines material topics through a structured process
designed to identify the most significant environmental, social, and governance (ESG) issues
that impact both our business success and our stakeholders’ expectations.
This process ensures that our material topics are comprehensive, balanced, and reflective of
both global expectations and FGI’s operational realities.
Risk Assessment : Integration of ESG factors into our Supply Chain Risk
Assessment Policy and Due Diligence Management System (DDMS).
Final Prioritization : Based on relevance to stakeholders and significance
to business strategy.
Determining Material Topics (GRI 3-1)
Process followed in 2024:
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GRI 3
ENVIRONMENT
Material Topic
Why It Matters
Energy and Emissions
Minimizing operational environmental footprint; aligning with
climate commitments.
Waste and Resource Management
Efficient use of materials; responsible disposal and recycling
practices.
Environmental Stewardship
Protecting ecosystems where sourcing and manufacturing
activities occur.
GOVERNANCE
Material Topic
Why It Matters
Ethical Sourcing & Supply Chain
Integrity
Maintaining conflict-free, traceable, and ethical sourcing
practices.
Anti-Bribery & Anti-Corruption
Ensuring business is conducted with integrity.
Product Integrity & Transparency
Guaranteeing customers accurate disclosure of product origin,
quality, and composition.
Data Protection & Confidentiality
Safeguarding customer and supplier information.
SOCIAL
Material Topic
Why It Matters
Human Rights & Labor Practices
Ensuring dignity, fair treatment, and protection of workers across
operations and supply chain.
Health and Safety
Maintaining safe workplaces at FGI facilities globally.
Diversity, Equity & Inclusion
Promoting equal opportunities and preventing discrimination.
Community Engagement
Supporting local communities where we operate and source
materials.
51 FREDERICK GOLDMAN INC 52ANNUAL SUSTAINABILITY REPORT 2024
MATERIAL TOPICS
The following material topics were identified as most significant for FGI in 2024:
Each material topic is managed through dedicated policies, systems, and governance structures.
Policies: Each material topic is addressed by a specific FGI policy (e.g., Human Rights Policy,
Supply Chain Policy, Environmental Policy, Anti-Bribery Policy, Product Disclosure Policy).
Systems: Our Due Diligence Management System (DDMS) integrates risk management, supplier
assessments, audits, and grievance mechanisms.
Training: Employees and suppliers are trained annually on relevant ESG topics, including
responsible sourcing, human rights, and compliance standards.
Audits and Reviews: Independent third-party audits and internal monitoring ensure
accountability.
Reporting: Progress is disclosed in the Annual Due Diligence Report and this Sustainability
Report.
Management Approach:
List of Material Topics (GRI 3-2)
Management of Material Topics (GRI 3-3)
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
SOCIAL
GRI 3
Respecting the dignity, safety, and well-
being of every worker.
Ensuring equal access to opportunities and
fair treatment regardless of gender,
ethnicity, religion, age, or background.
Prohibiting child labor, forced labor, or
modern slavery across our operations and
supply chain.
55 FREDERICK GOLDMAN INC 56ANNUAL SUSTAINABILITY REPORT 2024
HUMAN RIGHTS AND
LABOR PRACTICES
Respect for Human Rights (GRI 2-23, 2-27) Labor Standards and Working Conditions
(GRI 401-2, 403-1, 405-1)
Key commitments include:
We are committed to:
At Frederick Goldman, Inc. (FGI), we recognize
that respect for human rights is fundamental to
responsible business. Our Human Rights Policy is
guided by the UN Guiding Principles on Business
and Human Rights, the International Labour
Organization (ILO) Conventions, and the
Responsible Jewellery Council (RJC) Code of
Practices.
FGI ensures that all employees, whether in the
U.S. or our global facilities in Mexico, India and
China, are provided with safe, fair, and equitable
working conditions.
Occupational Health & Safety (OH&S):
Guided by our Occupational Health and
Safety Policy Statement, we maintain safe
workplaces with hazard identification,
training, and emergency preparedness.
Fair Wages and Benefits: All employees
receive wages and benefits that meet or
exceed legal requirements in their country
of operation.
Diversity and Inclusion: We actively
promote equal opportunities in hiring,
promotions, and leadership development.
In 2024, women accounted for a growing
share of management and skilled positions.
Workplace Well-being: Flexible work
arrangements, wellness initiatives, and
employee engagement programs support
work-life balance.
Our Human Rights Vendor Policy extends these
expectations to all suppliers, who are required to
comply as a condition of business with FGI.
Compliance is monitored through our Due
Diligence Management System (DDMS), regular
assessments, and supplier audits.
Grievance Mechanisms (GRI 2-25) Freedom of Association and Collective
Bargaining
Non-Discrimination (GRI 406-1)
Features of our grievance mechanism:
FGI operates a transparent and accessible
Grievance Procedure to ensure that employees,
suppliers, and external stakeholders can raise
concerns without fear of retaliation.
FGI respects the rights of employees to freely
associate, join labor unions, and engage in
collective bargaining in accordance with local
laws.
We do not interfere with workers’ rights to
representation and negotiation, and we encourage
open dialogue between employees and
management. Our open-door policy and two-way
communication mechanisms further ensure that
employees can raise workplace concerns directly
to leadership without barriers.
FGI is committed to providing a workplace free
from discrimination and harassment. Our Human
Rights Policy and Diversity, Equity & Inclusion
(DEI) initiatives ensure that employment
decisions are based solely on merit, skills, and
business needs.
We strictly prohibit discrimination on the basis of
gender, race, ethnicity, religion, disability, age,
sexual orientation, or any other protected
characteristic. All employees undergo mandatory
training on anti-discrimination and harassment
prevention.
Multiple Reporting Channels: Employees
and partners may report issues through
dedicated email, hotline, or directly to HR
and Compliance teams.
Confidentiality: All grievances are handled
with strict confidentiality and impartiality.
Remediation Process: Concerns are
investigated promptly, and corrective
actions are taken where necessary.
Monitoring: Grievance trends are reported
to the Sustainability & Compliance
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
57 FREDERICK GOLDMAN INC
RESPONSIBLE SOURCING
Conflict-Free
Minerals
Commitment
Supplier Due
Diligence
OECD
Guidance
Implementation
Supplier Audits
and Evaluation
Results
Conflict-Free Minerals Commitment (GRI 308-1, 414-1)
Supplier Due Diligence
(GRI 308-1, 308-2, 414-1, 414-2)
Supplier Audits and Evaluation Results
(GRI 308-2, 414-2)
OECD Guidance Implementation (GRI 3-3)
At Frederick Goldman, Inc. (FGI), we are committed to ensuring that all materials - including gold, precious
metals, diamonds, colored gemstones, and 3T minerals (tin, tantalum, tungsten) - are sourced responsibly and
do not contribute to conflict or human rights violations.
FGI’s Due Diligence Management System
(DDMS) governs supplier selection, onboarding,
and monitoring. Every supplier must:
FGI has fully integrated the OECD Due Diligence
Guidance for Responsible Supply Chains of
Minerals from Conflict-Affected and High-Risk
Areas (CAHRAs) into its sourcing processes.
Implementation Steps:
Establish Strong Company Management
Systems – Supply Chain Risk
Assessment Policy, Vendor Declarations,
AML/KYC framework, and grievance
mechanisms.
Key Highlight 2024: All suppliers of
precious metals and minerals were reviewed
under OECD-aligned due diligence, with
zero cases of association with CAHRAs
detected.
Identify and Assess Risks – Annual supplier
self-assessments, risk mapping by
geography, and material-specific due
diligence.
Mitigate Identified Risks – Engage
suppliers for corrective actions; disengage if
non-compliance persists.
Audit and Verification – Third-party audits
for select suppliers in higher-risk regions.
Report Annually – Findings published in
FGI’s Due Diligence Report and this
Sustainability Report.
Compliance with the Kimberley Process Certification Scheme and the World Diamond Council System
of Warranties for all rough and polished diamonds.
Sign and comply with FGI’s Vendor Policies
(Precious Metals, Stones, Diamonds, 3T
Minerals, Human Rights, and AML).
Adherence to FGI’s Vendor Policies
(Human Rights, Precious Metals,
Diamonds, Stones, 3T).
Verification of environmental practices,
including waste handling and emissions
controls.
Social compliance, covering labor rights,
health and safety, and non-discrimination.
Governance compliance, including AML,
anti-bribery, and KYC.
Undergo Know Your Counterparty (KYC)
checks, including verification of ownership,
reputation, and country-of-origin risk.
Provide supporting evidence of compliance
(certifications, warranties, and audit
reports).
We conduct annual risk assessments of all
suppliers, classifying them into low, medium, or
high-risk categories. Suppliers in high-risk regions
must undergo enhanced due diligence, including
independent audit verification.
FGI maintains a proactive Supplier Audit Program
to ensure ongoing compliance with our ethical
sourcing standards.
Audit and Evaluation Criteria:
Conflict-free sourcing of gold and 3T minerals, verified through suppliers certified by LBMA,
CFSI/EICC, RJC, or SRSP.
Full alignment with the RJC Code of Practices (COP 2019) and OECD Guidance on responsible supply
chains.
In 2024, FGI sourced 100% of gold and diamonds through conflict-free certified channels, with no exceptions.
We enforce:
58ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
59 FREDERICK GOLDMAN INC
HEALTH, SAFETY &
ENVIRONMENT (HSE)
60ANNUAL SUSTAINABILITY REPORT 2024
Workplace Safety Practices
(GRI 403-1, 403-2)
Health and Hygiene Standards
(GRI 403-3, 403-6)
Environmental Commitment
(GRI 301-1, 306-1)
Key Practices:
Standards and Initiatives:
Key Commitments:
Frederick Goldman, Inc. (FGI) is committed to
maintaining safe and healthy workplaces across all
operations. Guided by our Occupational Health
& Safety Policy Statement, we apply consistent
global safety standards to protect employees in
our facilities in the U.S., Mexico, India and China.
FGI prioritizes employee health and well-being
through comprehensive health and hygiene
programs.
FGI’s Environmental Policy Statement guides our approach to minimizing environmental impacts across our
operations and supply chain. We are committed to resource efficiency, waste reduction, and responsible
sourcing of materials.
Hazard Identification & Risk
Assessment: Regular safety audits and
inspections are conducted to proactively
identify risks.
Occupational Hygiene: Regular monitoring
of air quality, noise levels, and dust exposure
in manufacturing units.
Material Efficiency: Precious metals and gemstones are recycled and reused where possible to reduce
raw material demand.
Waste Management: Hazardous and non-hazardous waste is segregated, stored, and disposed of
responsibly through authorized vendors.
Water Stewardship: Water usage in manufacturing processes is regularly monitored, with reduction
initiatives underway at facilities in India and Mexico.
Energy Efficiency: Gradual transition toward energy-efficient equipment and LED lighting in
production sites.
Health Screenings: Annual medical check-
ups provided for all employees in production
facilities.
Wellness Programs: Access to counseling
services, health awareness sessions, and fitness
initiatives.
COVID-19 Preparedness (legacy practice):
Enhanced sanitation, PPE distribution, and
vaccination support — many of which are
now part of ongoing hygiene protocols.
Zero occupational illness cases reported.
95% employee participation in annual health
screenings.
Expanded wellness initiatives in U.S. and
India facilities, with positive employee
feedback on stress management workshops
Employee Training: 100% of production
staff received safety training in 2024,
covering equipment handling, chemical
safety, emergency response, and fire
safety.
Incident Management: All workplace
incidents are logged, investigated, and
addressed through corrective action
plans.
Emergency Preparedness: Facilities are
equipped with fire alarms, first-aid
stations, and evacuation drills are
conducted semi-annually.
Lost-Time Injury Frequency Rate
(LTIFR): Zero major incidents reported.
Increased near-miss reporting by 15%,
reflecting a stronger safety culture and
proactive prevention.
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
ENVIRONMENTAL
GREENHOUSE GAS (GHG)
EMISSIONS
GRI 305-1, 305-2, 305-3
63 FREDERICK GOLDMAN INC 64ANNUAL SUSTAINABILITY REPORT 2024
In 2024, Frederick Goldman, Inc. (FGI) undertook its first comprehensive greenhouse gas (GHG) emissions
inventory, covering Scope 1, Scope 2, and Scope 3 emissions. This milestone exercise, conducted with the
support of ESGTech.ai, ensures that FGI’s climate impact is measured in accordance with the GHG Protocol
Corporate Standard and reported transparently to stakeholders.
Scope 1 – Direct Emissions
SCOPE SCOPE SCOPE
01
02
03
Scope 1 covers direct GHG emissions from activities under FGI’s operational control, including
fuel combustion and refrigerants.
This is the largest contributor to FGI’s footprint, with natural gas use and refrigerant leakage
accounting for the majority of emissions.
Transition to low-GWP refrigerants and improved system maintenance.
Explore fuel-switching opportunities to reduce fossil fuel dependency.
Invest in energy-efficient equipment to lower combustion requirements.
Stationary combustion: Natural gas, LPG, and diesel use for heating and energy generation.
Mobile combustion: Company-owned vehicles such as vans and cars.
Fugitive emissions: Refrigerant gases (HCFC-22, R410, R443, R445A) from cooling systems.
Sources:
2024 Scope 1 Emissions
Planned Actions:
SCOPE
01
(70.7% of total emissions)
TCO₂eq
2,138.36
SCOPE
02
16.6% of total emissions)
TCO₂eq
503.19
Scope 2 includes indirect emissions from the generation of purchased electricity consumed by
FGI’s facilities worldwide.
Although smaller than Scope 1, these emissions reflect reliance on external electricity grids across
the U.S., Mexico, India and China
Increase use of renewable energy contracts where feasible.
Expand adoption of LED lighting and energy-efficient machinery.
Conduct annual energy audits to track progress and identify savings opportunities.
Scope 2 – Indirect Emissions from Purchased Electricity (GRI 305-2)
2024 Scope 2 Emissions:
Planned Actions:
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GREENHOUSE GAS (GHG)
EMISSIONS
GRI 305-1, 305-2, 305-3
Total GHG Emissions (2024)
Scope 1 is the largest contributor, reflecting reliance on natural gas and refrigerants.
Scope 2 can be reduced in the short term through renewable energy sourcing and efficiency programs.
Scope 3 requires collaboration with suppliers and logistics partners, representing a long-term
challenge.
This baseline year establishes FGI’s climate action roadmap, positioning the company to align with global
climate goals and strengthen its contribution to a more sustainable jewelry industry.
Key Insights and Future Commitment
Scope
Description
Emissions (tCO₂e)
% of Total
Scope 1
Direct emissions
(fuels + refrigerants)
2,138.36
70.7%
Scope 2
Purchased electricity
503.19
16.6%
Scope 3
Supply chain, logistics,
waste, commuting
385.99
12.7%
Total
Company-wide GHG
emissions (2024)
3,027.54
100%
65 FREDERICK GOLDMAN INC 66ANNUAL SUSTAINABILITY REPORT 2024
Scope 3 – Other Indirect Emissions (GRI 305-3)
Scope 3 accounts for indirect emissions in FGI’s value chain, both upstream and downstream.
Employee commuting (cars, buses, motorcycles).
Purchased goods and chemicals (emissions from raw material extraction and processing).
Upstream and downstream transportation of products and materials.
Waste disposal and water supply managed by third parties.
Sources:
SCOPE
03
12.7% of total emissions)
TCO₂eq
385.99
While Scope 3 is the smallest portion, it is strategically important due to FGI’s global supply chain. Purchased
goods and logistics account for most of the emissions.
Work with suppliers to encourage GHG reporting and reductions.
Optimize logistics with consolidated shipments and fuel-efficient transport.
Expand supplier engagement on Scope 3 awareness and climate commitments.
2024 Scope 3 Emissions:
Planned Actions:
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
67 FREDERICK GOLDMAN INC 68ANNUAL SUSTAINABILITY REPORT 2024
ESG AND SUSTAINABILITY
PARTNER
At Frederick Goldman, Inc. (FGI), we recognize that sustainability is a journey that requires expertise,
collaboration, and continuous improvement. To strengthen our systems and ensure compliance with
international best practices, we have partnered with Growlity, a trusted advisor in ESG and sustainability.
Through this partnership, FGI has been able to integrate sustainability more deeply into its operations - from
supply chain transparency and human rights commitments to environmental stewardship and stakeholder
engagement.
By working with Growlity, we have strengthened not only our compliance posture but also our long-term
sustainability strategy, ensuring that FGI continues to create jewelry that tells a story of beauty, responsibility,
and integrity.
Growlity is proud to partner with Frederick Goldman, Inc. in their sustainability
journey - from GHG accounting to RJC compliance - helping ensure that every piece
of jewelry reflects not only beauty, but responsibility.
Supporting the implementation of the RJC Code of Practices (COP 2019) and helping FGI build
robust governance structures for responsible sourcing and due diligence.
Assisting in the establishment of management systems, policies, and protocols that align with the
Responsible Jewellery Council (RJC) and OECD Due Diligence Guidance.
Gaining an in-depth understanding of FGI’s internal systems and operational protocols, based on
which they have holistically developed this Annual Sustainability Report.
Providing technical expertise in ESG reporting, ensuring alignment with the Global Reporting
Initiative (GRI) Standards.
Initiating greenhouse gas (GHG) accounting, enabling FGI to measure, monitor, and plan
reductions in its climate impact.
Delivering capacity-building programs and training sessions for employees and suppliers,
enhancing awareness of sustainability, responsible sourcing, and ESG compliance.
Designing and drafting the Annual Sustainability Report, ensuring it reflects both FGI’s
achievements and its long-term commitments to stakeholders.
Growlity’s contributions to FGI include:
President and CEO, Growlity
DR. NITIN DUMASIA
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
ANNEXURE
GRI INDEX
At Frederick Goldman, Inc. (FGI), we recognize that sustainability is a journey that requires expertise,
collaboration, and continuous improvement. To strengthen our systems and ensure compliance with
international best practices, we have partnered with Growlity, a trusted advisor in ESG and sustainability.
GRI Disclosure
Description
Section in Report
General Disclosures (GRI 2)
2-1
Organizational details
Company Overview
2-2
Entities included in the sustainability report
Scope and Boundary of the
Report
Entities Included
2-3
Reporting period, frequency, and contact
point
Reporting Period and Contact Point
2-5
External assurance
(If assurance obtained – note in 1.4
or appendix; if not, disclose “not
obtained”)
2-6
Activities, value chain and other business
relationships
About FGI
Supply Chain Overview
2-9
Governance structure and composition
Governance Structure
2-12
Role of highest governance body in
sustainability matters
Integration of Sustainability into
Business Operations
2-14
Role of the Due Diligence Manager
Role of Due Diligence Manager
GRI Disclosure
Description
Section in Report
General Disclosures (GRI 2)
2-16
Communication of critical concerns
Governance Structure
(Decision-Making)
2-22
Statement on sustainable development
strategy
CEO Statement on Sustainability
Commitment; 4.1 Sustainability
Strategy
2-23
Policy commitments
Policies and Management Systems
2-24
Embedding policy commitments
Policies and Management Systems
2-25
Processes to remediate negative impacts
Grievance Mechanisms
2-27
Compliance with laws and regulations
Respect for Human Rights
Labor Standards
2-28
Membership associations
Membership and Certifications
2-29
Stakeholder engagement
Stakeholder Engagement
Material Topics (GRI 3)
3-1
Process to determine material topics
Determining Material Topics
3-2
List of material topics
List of Material Topics
3-3
Management of material topics
Management of Material Topics;
OECD Guidance
Implementation;
Risk Assessment
71 FREDERICK GOLDMAN INC 72ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
GRI INDEX
GRI Disclosure
Description
Section in Report
Topic-specific Disclosures
301-1
Materials used
Environmental Commitment
302, 305
Energy and emissions
(if included in future reports)
Planned for future disclosure
306-1
Waste management practices
Environmental Commitment
401-2
Benefits provided to employees
Labor Standards and Working
Conditions
403-1
Occupational health and safety
management system
Workplace Safety Practices
403-2
Hazard identification, risk assessment
Workplace Safety Practices
403-3
Occupational health services
Health and Hygiene Standards
403-6
Promotion of worker health
Health and Hygiene Standards
405-1
Diversity of governance bodies and
employees
Labor Standards and Working
Conditions
406-1
Non-discrimination
Non-Discrimination
GRI Disclosure
Description
Section in Report
Topic-specific Disclosures
407-1
Freedom of association and collective
bargaining
Freedom of Association
408, 409
Child labor and forced labor
Respect for Human Rights
414-1
New suppliers screened using ESG criteria
Conflict-Free Minerals
Commitment:
Supplier Due Diligence
414-2
Negative social impacts in the supply
chain
Supplier Audits and Evaluation
Results
308-1
New suppliers screened using
environmental criteria
Conflict-Free Minerals
Commitment
Supplier Due Diligence
308-2
Negative environmental impacts in
supply chain
Supplier Audits and Evaluation
Results
205
Anti-corruption
Anti-Bribery and Anti-Corruption
Policy
206
Anti-competitive behavior
(Disclose if applicable; otherwise “not
material”)
419
Socio-economic compliance
Covered across Governance and
Responsible Business Practices
73 FREDERICK GOLDMAN INC 74ANNUAL SUSTAINABILITY REPORT 2024
INTRODUCTION
SOCIAL
ENVIRONMENTAL
ANNEXURES
GOVERNANCE
