CA SUPPLY CHAIN ACT
Handiora Store LLC (“Handiora Store” or the “Company”) is firmly and unconditionally committed to responsible sourcing, ethical business practices, and the protection of human rights throughout all of its operations and supply chains. We are equally committed to protecting against modern slavery in all of its various forms, including forced labor, child labor, debt bondage, and human trafficking.
This statement is designed to meet the Company’s disclosure obligations under the California Transparency in Supply Chains Act of 2010 (SB 657). This disclosure covers the steps taken by Handiora Store during the financial year ended December 31, 2025, to identify, assess, and mitigate these risks within our operations and supply chains.
The fine jewelry and luxury accessories industry, which depends upon the global sourcing of precious metals, diamonds, and gemstones, carries an inherent exposure to human rights risks — particularly in regions where regulatory oversight is limited and small-scale mining is prevalent. Handiora Store acknowledges these risks and is dedicated to implementing policies and practices that reflect our commitment to ethical and responsible sourcing.
I. Structure, Activities, and Supply Chains
Company Overview
Handiora Store LLC is a United States-based luxury jewelry and accessories company organized under the laws of the State of [Your State] and headquartered in [Your City, State]. Founded with a deep passion for fine craftsmanship and artistic design, Handiora Store offers a curated collection of luxury jewelry, fine accessories, and exclusive lifestyle pieces available through our website at www.handiorastore.com and through our retail store location.
Our collections are designed to reflect the highest standards of quality, artistry, and refinement. Each piece in the Handiora Store collection is crafted from premium materials, including precious metals, diamonds, and natural and lab-created gemstones, sourced from a network of trusted and vetted suppliers located in the United States and internationally.
Our Products and Materials
Handiora Store’s product offerings consist primarily of:
- Fine jewelry crafted from precious metals including gold, sterling silver, and platinum
- Pieces incorporating diamonds, sapphires, rubies, emeralds, and other precious and semi-precious gemstones
- Luxury fashion accessories and lifestyle products
Our products are designed domestically and manufactured by a select network of suppliers and artisan partners in the United States and abroad. Raw materials used in the production of our jewelry are sourced from suppliers around the world, including major jewelry production centers in the United States, Italy, Thailand, and India.
Our Supply Chain
The Company’s supply chain includes:
- Finished goods suppliers and jewelry manufacturers located in the United States and internationally
- Raw material suppliers providing precious metals, diamonds, and gemstones
- Component suppliers providing settings, findings, and packaging materials
- Third-party logistics and fulfillment partners
The Company maintains direct relationships with its primary finished goods suppliers and component vendors, which enables us to conduct meaningful due diligence and enforce our standards throughout our direct supply chain. We recognize that the further upstream a supply chain extends — particularly toward artisanal and small-scale mining — the greater the potential exposure to human rights risks, and we account for this in our risk assessment and due diligence processes.
II. Our Commitment to Human Rights
Handiora Store’s commitment to human rights is foundational to our identity as a company. We believe that the beauty of fine jewelry must never come at the cost of human dignity. We are committed to ensuring that every product we offer has been created in a manner that respects the rights, wellbeing, and dignity of every person involved in its production — from the miners who extract raw materials to the artisans who craft each finished piece.
This commitment is reflected in our internal policies, vendor agreements, and ongoing due diligence practices. We hold ourselves and all of our business partners to the highest ethical standards, and we take swift and decisive action when those standards are not met.
As part of our broader commitment to responsible business, Handiora Store is actively pursuing membership and certification with recognized industry standards bodies, including the Responsible Jewellery Council (RJC) — the world’s leading standard-setting and certification organization for ethical and responsible practices in the jewelry and watch industry. Our goal is to achieve RJC certification and to partner exclusively with RJC-certified suppliers wherever practicable.
III.Policies and Due Diligence Processes
The California Transparency in Supply Chains Act requires covered businesses to disclose the specific actions they have taken with respect to the following five areas of supply chain risk management. Handiora Store’s practices with respect to each required disclosure area are set forth below.
3.1 Verification — Supply Chain Risk Assessment
Handiora Store engages in ongoing risk assessment of its supply chains to evaluate and address the risk of human trafficking and forced labor. Our verification process includes the following elements:
Risk-Based Approach
We apply a risk-based approach to supply chain assessment, prioritizing enhanced due diligence for product categories and geographic regions with a higher inherent risk of exposure to labor rights violations. The sourcing of gemstones — particularly from regions with limited regulatory infrastructure and a prevalence of artisanal and small-scale mining — is identified as a higher-risk category and is subject to heightened scrutiny and documentation requirements.
Geographic and Sector Risk Profiling
We assess geographic risk by reviewing publicly available data, international reports, and industry intelligence regarding labor rights practices in the countries from which our raw materials and finished goods are sourced. We consider country-level risk ratings published by organizations such as the U.S. Department of Labor, the International Labour Organization (ILO), and non-governmental organizations with expertise in supply chain human rights.
Supplier Risk Categorization
All suppliers are categorized based on a combination of geographic risk, product type, depth in the supply chain, and the quality of their own due diligence practices. Higher-risk suppliers are subject to more rigorous onboarding requirements, more frequent monitoring, and enhanced disclosure obligations. Lower-risk suppliers — particularly those operating in well-regulated jurisdictions or holding recognized third-party certifications — are subject to streamlined but still meaningful verification procedures.
Third-Party Verification
Where appropriate, the Company engages or relies upon independent third-party auditors and certification bodies to verify supplier compliance with applicable labor rights standards. Suppliers holding current certification from the Responsible Jewellery Council (RJC) or equivalent recognized bodies are given strong preference as a result of the rigorous independent audit process associated with such certifications.
3.2 Auditing — Supplier Compliance Audits
Handiora Store conducts and facilitates supplier compliance audits to assess and verify adherence to our Supplier Code of Conduct and applicable legal requirements with respect to labor rights, working conditions, and human rights.
Audit Rights
As a condition of doing business with Handiora Store, all finished goods suppliers and component manufacturers must contractually agree to allow the Company — or a designated third-party auditor acting on our behalf — to conduct on-site visits and inspections of their manufacturing and production facilities. Such visits may be conducted on either a scheduled or an unannounced basis, at the Company’s sole discretion.
Worker Access
During any site visit or audit, Handiora Store or its designated auditor must be permitted to have open, private, and unobstructed access to all workers employed at the facility for the purpose of conducting confidential interviews regarding working conditions, compensation, hours of work, and any concerns about labor practices. Workers must not be subject to supervision, coaching, or intimidation by management during such interviews.
Third-Party Audits
For suppliers operating in higher-risk geographies, the Company may require independent third-party social compliance audits conducted by recognized audit firms or certification bodies as a condition of continued engagement. Audit reports are reviewed by Company management and any identified deficiencies are subject to mandatory corrective action plans with defined timelines.
Unannounced Inspections
Handiora Store reserves the right to conduct unannounced inspections of supplier facilities at any time. Suppliers who refuse, obstruct, or fail to facilitate any scheduled or unannounced inspection are subject to immediate suspension and potential termination of their business relationship with the Company.
3.3 Certification — Supplier Commitments and Representations
As a condition of entering into any business relationship with Handiora Store, all suppliers are required to execute and comply with the Handiora Store Supplier Code of Conduct (“Supplier Code”), which sets forth our minimum standards for ethical business conduct, labor rights, and supply chain transparency.
Supplier Code of Conduct — Key Requirements
The Handiora Store Supplier Code of Conduct expressly requires all suppliers and their subcontractors to:
- Comply with all applicable local, national, and international laws and regulations governing labor and employment, including minimum wage, working hours, overtime, and worker benefits
- Strictly prohibit the use of child labor in any form, and maintain documentation of the date of birth of each person employed in their facilities
- Prohibit all forms of forced or compulsory labor, including debt bondage, prison labor, indentured labor, and any labor obtained through trafficking
- Provide a safe, healthy, and respectful working environment free from harassment, abuse, discrimination, and retaliation
- Respect workers’ rights to freedom of association and collective bargaining to the extent permitted by applicable law
- Maintain accurate employment records and never misrepresent working conditions or labor practices to the Company or to any auditor
- Conduct their own due diligence of their supply chains to identify and manage risks of child labor, forced labor, and human rights violations
- Immediately disclose to Handiora Store any known or suspected violations of the Supplier Code within their own operations or supply chain
Responsible Sourcing Certification
Suppliers of diamonds and gemstones are additionally required to certify their compliance with applicable conflict mineral regulations, including the Kimberley Process Certification Scheme (KPCS) for diamonds. Gemstone suppliers are required to identify the furthest upstream point in their supply chain that they can verify and submit evidence of the steps taken to assess risk at those upstream points, including copies of risk assessments, audits, or responsible sourcing program documentation.
Annual Recertification
Supplier compliance with the Handiora Store Supplier Code of Conduct is not a one-time obligation. All suppliers are required to renew and reconfirm their compliance on an annual basis, or more frequently if material changes occur in their operations or supply chain. The Company reserves the right to require supplemental certifications or disclosures at any time in response to identified risks or concerns.
3.4 Internal Accountability — Standards and Enforcement
Handiora Store maintains a comprehensive framework of internal accountability measures designed to ensure that both our employees and our suppliers uphold the Company’s commitment to ethical and responsible business practices.
Employee Standards of Conduct
All Handiora Store employees are required to conduct themselves in full compliance with applicable laws and Company policies, including our Code of Business Ethics and Conduct. Our Code requires all employees to act with integrity, treat others with dignity and respect, and promptly report any actual or suspected violations of Company policy, applicable law, or ethical standards. Failure to comply may result in disciplinary action, up to and including immediate termination of employment.
Supply Chain Accountability
Employees with responsibility for supplier selection, vendor management, and supply chain oversight are held to the highest standards of diligence and are responsible for ensuring that all supplier relationships are established and maintained in accordance with the Supplier Code of Conduct. These employees are expected to exercise independent judgment in identifying, escalating, and addressing supply chain risks, and to prioritize ethical considerations in all sourcing decisions.
Supplier Remediation and Termination
In the event that Handiora Store identifies a violation of its Supplier Code of Conduct — including any instance of child labor, forced labor, or human trafficking — the Company is committed to promptly and decisively addressing the situation. Our response protocol includes:
- Immediate notification to senior management and, where applicable, legal counsel
- Suspension of all purchase orders with the relevant supplier pending investigation
- A thorough and documented investigation of the nature, scope, and root cause of the violation
- Where remediation is appropriate and feasible, a mandatory corrective action plan with defined milestones and timelines, subject to independent verification
- Where remediation is not feasible or the supplier fails to comply, immediate termination of the supplier relationship and pursuit of all available legal remedies
Grievance Reporting Mechanism
Handiora Store maintains a confidential grievance reporting mechanism through which employees, suppliers, workers in our supply chain, and other stakeholders may report concerns regarding violations of our Supplier Code of Conduct, suspected human rights abuses, or any other unethical or illegal practices. Reports may be submitted by email to compliance@handiorastore.com. All reports are reviewed and investigated promptly, and reporters may submit reports anonymously where applicable law permits.
3.5 Training — Employee Education and Awareness
Handiora Store is committed to ensuring that employees with responsibility for supply chain management and vendor relationships have the knowledge and awareness necessary to identify, assess, and respond effectively to the risks of human trafficking, forced labor, and child labor.
Supply Chain Management Personnel
Employees directly responsible for supplier selection, procurement, sourcing, and vendor relationship management receive targeted training on the following topics:
- The requirements of the California Transparency in Supply Chains Act and applicable human rights laws and regulations
- Identifying red flags and risk indicators for forced labor, child labor, and human trafficking in supply chains
- The Company’s Supplier Code of Conduct and due diligence procedures
- Conducting effective supplier due diligence and interpreting audit reports and third-party assessments
- Escalation procedures and reporting obligations when risks or violations are identified
- Responsible sourcing standards in the fine jewelry industry, including RJC standards and Kimberley Process requirements
General Employee Awareness
All Handiora Store employees receive general awareness training as part of their onboarding process covering the Company’s core values, ethical business standards, and commitment to human rights. This includes an overview of the risks of modern slavery and human trafficking in global supply chains.
Ongoing Training Commitment
The Company reviews and updates its training materials on an annual basis and tracks training completion across relevant employee groups to ensure consistent coverage and awareness.
IV. Responsible Sourcing Initiatives
In addition to the specific measures described above, Handiora Store participates in and draws upon a range of industry initiatives and frameworks designed to promote responsible sourcing and combat human rights abuses in global jewelry supply chains.
Responsible Jewellery Council (RJC)
Handiora Store is actively pursuing RJC membership and certification. The RJC is the world’s leading standard-setting and certification organization for responsible business practices in the jewelry, gold, and diamond industries. RJC certification requires compliance with a comprehensive Code of Practices covering human rights, labor rights, environmental impact, and business ethics throughout the supply chain, verified through a rigorous independent third-party audit.
Kimberley Process Certification Scheme (KPCS)
All diamond suppliers engaged by Handiora Store are required to comply with the Kimberley Process Certification Scheme, an international governmental certification initiative that requires participants to certify that shipments of rough diamonds are free from conflict diamonds. We require our diamond suppliers to provide KPCS-compliant documentation certifying that the diamonds they supply are sourced from conflict-free origins.
OECD Due Diligence Guidance
Handiora Store’s responsible sourcing policy is aligned with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. We are engaged in an ongoing initiative to increase transparency and traceability in our supply chain in a manner consistent with the OECD’s five-step due diligence framework.
Supplier Partnership Philosophy
Handiora Store is deeply committed to building long-term relationships with suppliers who share our values and our commitment to responsible business practices. We view our supplier relationships as genuine partnerships and work collaboratively with suppliers to identify and address risks, sharing best practices and providing guidance to drive meaningful, sustained improvement in supply chain human rights performance.
V. Vendor Due Diligence Process
Handiora Store employs a structured and documented vendor due diligence process that applies to all new and existing suppliers. This process is designed to identify, assess, and manage supply chain risks before and during the course of any supplier relationship.
New Supplier Onboarding
All prospective suppliers must complete a comprehensive onboarding process prior to being approved as a Handiora Store vendor. This process includes:
- Submission of a completed Supplier Due Diligence Questionnaire covering ownership structure, manufacturing locations, labor practices, environmental compliance, and existing human rights policies
- Execution of the Handiora Store Supplier Code of Conduct
- Provision of documentation evidencing the supplier’s own supply chain due diligence practices, including any relevant audits, certifications, or third-party assessments
- For diamond and gemstone suppliers: identification of the furthest upstream verified point in the supply chain and submission of supporting documentation
- Review and approval by Handiora Store’s sourcing and compliance team
Suppliers who are unable or unwilling to provide the required documentation or to execute our Supplier Code of Conduct will not be approved as Handiora Store vendors, regardless of commercial considerations.
Ongoing Supplier Monitoring
Approved suppliers are subject to ongoing monitoring throughout the course of their relationship with the Company, including:
- Annual recertification of compliance with the Supplier Code of Conduct
- Periodic review of third-party audit reports and certification status
- Monitoring of publicly available information regarding supplier labor practices and compliance history
- Review of any supplier-disclosed issues, red flags, or material changes in operations or supply chain
- Scheduled and unannounced site visits as appropriate
The intensity and frequency of monitoring is calibrated to the risk profile of each supplier. Higher-risk suppliers are subject to more frequent and more intensive monitoring activities.
Red Flag Identification and Escalation
Indicators that trigger heightened scrutiny or escalation include, but are not limited to:
- Suppliers operating in high-risk geographies or sourcing materials from conflict-affected or high-risk areas
- Suppliers with a history of labor rights violations or adverse audit findings
- Suppliers whose pricing appears inconsistent with the cost of compliant labor practices
- Suppliers who are unwilling to disclose their own supply chain sourcing or to allow site visits
- Reports from workers, NGOs, media, or other sources suggesting potential labor rights violations
All red flags are documented and reviewed by the Company’s compliance function. Where a red flag cannot be resolved through the supplier’s remediation efforts, the Company will take appropriate action including, where necessary, termination of the supplier relationship.
VI. Remediation and Corrective Action
Handiora Store is committed to taking swift and effective remedial action whenever it identifies or becomes aware of actual or potential human rights violations in its operations or supply chain. Our approach to remediation is guided by the principle that the primary objective is to address the harm to affected individuals while also preventing recurrence.
Remediation Framework
Upon confirmation of a supplier violation of the Company’s Supplier Code of Conduct relating to labor rights or human rights:
- The Company will immediately notify the supplier of the identified violation and require a written response within a defined timeframe
- Where the violation is capable of remediation, the supplier will be required to develop and implement a corrective action plan (CAP) with specific, measurable, time-bound targets
- The Company will monitor the supplier’s implementation of the CAP, including through follow-up site visits or third-party verification where appropriate
- If the supplier fails to implement the CAP to the Company’s satisfaction, the Company will suspend and ultimately terminate the supplier relationship
- In cases of severe violations — including confirmed use of child labor, forced labor, or human trafficking — the Company reserves the right to immediately terminate the supplier relationship and report the violation to appropriate authorities
Current Status
As of the date of this disclosure, Handiora Store is not aware of any confirmed instances of child labor, forced labor, human trafficking, or other material human rights violations in its direct operations or supply chain. The Company has not been required to initiate any supplier terminations or corrective action plans on the basis of human rights violations during the reporting period. We acknowledge that the absence of identified violations does not necessarily mean the absence of risk, and we remain committed to continuously strengthening our due diligence practices.
VII. Assessing Effectiveness
Handiora Store takes its responsibilities under the California Transparency in Supply Chains Act and its broader commitment to human rights with the utmost seriousness. We recognize that supply chain due diligence is not a static exercise but an ongoing and evolving process that requires continuous investment, improvement, and adaptation.
To assess the effectiveness of our supply chain risk management practices, Handiora Store monitors and evaluates the following indicators on an ongoing basis:
- The percentage of our direct suppliers that have executed our Supplier Code of Conduct
- The percentage of our higher-risk suppliers that hold current third-party certifications from recognized bodies such as the RJC
- The number and resolution status of red flags identified through our due diligence processes
- The number, nature, and resolution of grievances submitted through our reporting mechanism
- The completion rate of supply chain compliance training among relevant employee groups
- Findings from scheduled and unannounced supplier site visits and audits
We are committed to reporting honestly and transparently on our progress, including the challenges we face, and to continuously raising our standards in line with evolving best practices and regulatory requirements.
VIII. Contact and Further Information
Handiora Store welcomes questions, feedback, and reports from all stakeholders — including customers, suppliers, workers, investors, and members of the public — regarding our supply chain practices and our commitment to human rights and responsible sourcing.
If you have a question about this disclosure, wish to report a concern regarding our supply chain, or would like to learn more about our responsible sourcing initiatives, please contact us:
Compliance Email compliance@handiorastore.com
Customer Care customercare@handiorastore.com
Phone [Your Phone Number]
Address Handiora Store LLC, [Your Full Business Address]
Website www.handiorastore.com



