PANDORA CSR Report 2011 - page 10

Finally, by training our purchasers to spot irresponsible
business practices as part of their daily contactswith our
suppliers, we find ourselves capable of identifying potential
irregularities, posing the right questions and acting accord-
ingly. In 2012wewill review this approach to see if we
could benefit from an approach that combines announced
and unannounced audits.
Step4:Corrective actions
The fourth and final step is to develop and implement
corrective actionplans ensuring that anynon-compliance
identified during daily operations, initial screenings,
dialogue during the supplier training, self-assessments
or through independent audits, are eliminatedwithin
a reasonable time frame.
Most audits reveal non-compliances of varying severity,
which result in the independent audit teampreparing adraft
corrective actionplanbasedon their CSR expertise and local
knowledgeof how fast companies and authorities canbe
expected to act on the given context.Theplan is presented
to the supplier at the endof the audit, and the supplier can
either accept it or suggest an alternativeplan,whichulti-
matelymust be acceptedbyour purchaser andGroupCSR.
Failure to complywith theCodeof Conduct code results
in an escalationof PANDORA’s efforts,whichmayultimately
result inPANDORA’sCSR committeedeciding to terminate
thebusiness relation.
InNovember 2011, PANDORA seized theopportunity to
present ourCSRSupplier Programme to theNordicNetwork
forUnitedNationsGlobal Compactmember companies.At
this event,we receivedpositive recognitionandvaluable in-
put thatwill helpus in further developing theprogramme.
During 2011, we developed and tested different audit con-
cepts, ranging from audits carriedout by PANDORA staff
only, independent thirdparty audits, and joint auditswith
the participationof both independent auditors, PANDORA’s
purchasers and our CSR teams. In 2012wewish tomove
towards amodel that relies onmore independent audits
and to start developing aCSR toolkit that will help our
suppliers integrateCSR into their company procedures.
Finally, wewill be gaining further experience in executing
our four-stepCSR Programme, enabling us to define Key
Performance Indicators on how frequentlywe should
engagewith the different supplier categories.
At PANDORA, we consider our current Code of Conduct
to fullymatch the codes issued by our peers in the global
jewellery brands. PANDORA acknowledges that many
suppliers today suffer from “CodeMania”.Thismeans that
suppliers have to complywith awide range of codes, each
with their unique, but comprehensive, requirements for
documentation.Tohelp counter this problem, and to help
advance the role of theResponsible JewelleryCouncil (RJC),
PANDORAwill work to abandon our Suppliers’ Code of
Conduct and replace it with the equally suitedRJCCode
of Practices.
In the spring of 2011PANDORAwas electedby our
peers to represent the JewelleryManufacturers inRJC’s
Standards Committee. During 2012, the RJC Standards
Committeewill workwith an external stakeholder panel
toupdate the RJCCode of Practices.Wewill use this as
our platform topersuade our peerswithin the industry to
unite behind the RJCCode of Practices.
Finally, PANDORAhas in 2011 accepted an invitation
to join the reference group for theNICECode of Conduct
for the fashion industry – the first sector-specific initiative
under theUnitedNationsGlobal Compact in its history.The
NICE codewill be launched in2012 andpromotedduring
the Rio+20 Summit.
Thegold supplychain is complex, andespeciallygoldmining
has often been criticised for harshworking conditions,
a high environmental impact, and in some cases breaches
to fundamental human rights.This has already led to in-
creased regulatory demands in theUS, andmore govern-
ments are now following suit pushing for full traceability
of gold frommine tomarket.
PANDORA’s jewellery crafting process requires a
fineness of our gold at 99.99 per cent.Thus, PANDORA
depends onhighqualitygold smelters, refiners and traders
who in turn acquire their gold from a range of sources.
Our initial inquiries into our gold supply chain indicate
that the primary source of our gold is recycling, but we are
aware that themelting processmight also contain gold from
bullion banks andmining.Todate, PANDORAhas found
no evidence or indication that our gold originates from
sources or countries known tobe associatedwith conflict
or irresponsible business practices. In 2012wewill further
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