Introduction

ALine GmbH is a gemstone trading company from Switzerland. We pride ourselves on honesty, integrity and excellence and we hold our suppliers and clients to the same high standards.

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Our Code of Practices (“COP”) sets general principles and requirements applicable to us and our business partners. We intend to do business with partners already committed to these principles and in relentless pursuit of improvement.

ALine GmbH is committed to applying our code across all aspects of our operations, including raw material suppliers and clients around the world, and prioritizes commitment to ongoing continuous improvement. We require our suppliers and customers to share our commitment to human rights, fair and safe labor practices, environmental protection and ethical business conduct. We expect our business partners to fully comply with all applicable laws, rules, and regulations and ask them to go beyond legal compliance and strive to meet internationally recognized standards for the advancement of human rights, business ethics, and social and environmental responsibility wherever possible.

While we recognize there are different legal and cultural environments in which partners operate, we reserve the right to terminate business with suppliers and clients who do not fully meet our requirements. We prefer to work collaboratively and in good faith to address the root causes and support sustained improvements. To this end, full transparency from all parties involved is a minimum expectation. We believe that partnerships based on transparency and collaboration are the only way to promote responsible and sustainable practices that benefit workers and the environment.

 

For inquiries, feedback or complaints please contact us at cop@alinecollection.ch
ALine GmbH maintains a confidential and accessible grievance mechanism for employees and external stakeholders. Complaints can be raised without fear of retaliation and are handled promptly and fairly.

 

Alexander Leuenberger

Chief Execution Officer, ALine GmbH

 

Code of Practices, Version 2.0, 24.07.2026

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General Requirements​​

COP 1: Legal compliance

ALine GmbH commits to practice in compliance with Swiss law and foreign law of countries where we are active.

 

Regarding data protection and confidentiality:

ALine GmbH protects personal data in accordance with applicable data protection laws and ensures confidentiality of business information.

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COP 2: Policy and Implementation

As an RJC member, we commit to operating our business in accordance with the RJC Code of Practices. We commit to integrating ethical, human rights, social and environmental considerations into our day-to-day operations, business planning activities and decision-making processes.

Our Code of Practices is publicly available on our website, www.alinecollection.ch, and we strive to improve our best practices continuously. This is the first version of the document and will frequently be updated. Main stakeholders will be informed of any changes. Detailed descriptions of our processes are always available in our handbook for all employees and can be shared with close business partners upon request.

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COP 3: Reporting

ALine GmbH publishes its reporting on the company website. 

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COP 4: Financial accounts

ALine GmbH maintains financial accounts for all business transactions in accordance to the Swiss law and the Swiss accounting standards.

 

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Responsible Supply Chains and Human Rights

COP 5: Business partners

ALine GmbH accepts its role in the global market and commits to using best endeavors to promote and verify responsible business practices amongst all our business partners. ALine GmbH promises to support all business partners in their continuous adjustments of their systems.

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COP 6: Human Rights

ALine GmbH is committed to respecting all human rights in our own operations and business relationships in accordance with the Universal Declaration of Human Rights (UDHR), the UN Guiding Principles on Business and Human Rights and relevant conventions of the International Labor Organization (ILO). Our human rights policy covers the following key commitments:

 

• All forms of violence and harassment in the workplace are prohibited. This includes but is not limited to corporal punishment; harsh or degrading treatment; sexual or physical harassment; mental, physical, verbal or sexual abuse; retaliation; coercion; and intimidation. Both direct and indirect harassment in any form is not acceptable in workplace facilities. We commit to ensuring that our employees are not subjected to harassment or violence, or threatened with these towards themselves, their family or colleagues.

• To never engage in or knowingly support child labor (including the worst forms of child labor) as defined by International Labor Organization (ILO) conventions 138 and 182.

• To never engage in or knowingly support forced labor as defined by International Labor Organization (ILO) convention 29, including bonded labor, deceptive recruitment, human trafficking and indentured or involuntary prison labor.

• To provide a safe and healthy working environment for all employees.

• To treat employees with dignity and respect, which includes

  • Ensuring fair and transparent discipline and grievance procedures.

  • Recognizing and respecting the right of all employees to associate freely and enter collective bargaining.

  • To provide all employees with fair terms of employment and legally mandated benefits.

  • To prohibit all forms of discrimination, including but not limited to discrimination based on race, color, ethnicity, caste, national origin, religion, disability or genetic information, gender, sexual orientation, union membership, political affiliation, marital status, parental or pregnancy status, physical appearance, HIV status, age or any other personal characteristic unrelated to the inherent requirements of the work.

 

• To promote human rights in our dealings with business partners and other relevant stakeholders.

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ALine GmbH expects all its employees, suppliers and sub-contractors to take steps to ensure that this policy is adhered to

 

COP 7: Due diligence for responsible sourcing from

Conflict-Affected and High-Risk Areas (CAHRA)

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ALine GmbH confirms their commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

 

ALine GmbH is a member of the Responsible Jewellery council (RJC). As such, we commit to proving, through an independent third-party verification, that we:

• respect human rights according to the Universal Declaration of Human Rights and International Labor Organization Declaration on Fundamental Principles and Rights at Work.

• do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism.

• support transparency of government payments and rights-compatible security forces in the extractives industry.

• do not provide direct or indirect support to illegal armed groups.

• enable stakeholders to voice concerns about the jewellery supply chain.

• are implementing the OECD five-step framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

 

ALine GmbH commits to using our influence to prevent abuses by others.

 

• Regarding serious abuse associated with the extraction, transport or trade of minerals:

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

• torture, cruel, inhuman and degrading treatment

• forced or compulsory labor

• the worst forms of child labor

• human rights violations and abuses

• war crimes, violations of international humanitarian law, crimes against humanity or genocide.

 

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described above or are sourcing from, or linked to, any party committing these abuses.

 

• Regarding direct or indirect support to non-state armed groups:

• control mine sites, transportation routes, points where diamonds are traded and upstream actors in the supply chain

• tax or extorting money or diamonds at mine sites, along transportation routes or at points where diamonds are traded, or from intermediaries, export companies or international traders.

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We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described above.

 

• Regarding public or private security forces:

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment, and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described under abuse, or that act illegally as described under support to non-state armed groups.

 

• Regarding bribery and fraudulent misrepresentation of the origin of colored gemstones:

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of colored gemstones or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of colored gemstones.

 

• Regarding money laundering:

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of minerals.

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COP 8: Artisanal and small-scale mining (ASM)

ALine GmbH accepts its role in the global market and commits to using best endeavors to promote and verify the health and well-being of miners and their families. Particularly for the gemstone market, ASM is the most important source of material. We rely on our suppliers to promote our standard further. Please refer to COP 9 for our own initiative regarding our efforts to support ASM.

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COP 10: Community development

ALine GmbH actively works towards an upstream approach that tries to get direct connections with ASM through local partners. The aim is to develop sustainable collaborations for the benefit of all involved parties.

ALine GmbH finances and actively participates in the development of a sustainable development project under the FULL CIRCLE INTIATIVE founded by ALine GmbH’s CEO Alexander Leuenberger.

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COP 11: Bribery and facilitation payments

ALine GmbH prohibits bribery and corruption in all business practices and transactions carried out by its employees and by agents acting on its behalf. For this policy, bribery is defined as giving, offering or receiving any undue advantage from

• A public or government official

• A political candidate, party or official

• Any private sector employees, directors or officers or their agents or representatives.

 

All employees of ALine GmbH are protected from any penalty or adverse consequences for identifying concerns related to suspected bribery, for refusing to participate in bribery or refusing to pay a facilitation payment where such payments are prohibited.

The acceptance or offering of gifts by employees and/or agents must be done so within the criteria and approval procedures set by ALine GmbH.

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COP 12: KYC, Money laundering and finance of terrorism

ALine GmbH commits to not engaging in or contributing to money laundering or the finance of terrorism and is fully compliant with applicable anti-money laundering laws and regulations.

 

ALine GmbH has implemented Know Your Counterparty (KYC) procedures to:

• Establish the identity of all counterparties,

• Verify that counterparties and, if applicable, beneficial owners are not named on relevant government lists for individuals or organizations implicated in money laundering, fraud or involvement with prohibited organizations and/or those financing conflicts,

• Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties and

Monitor transactions for unusual or suspicious activity

 

COP 13: Security

ALine GmbH attaches great importance to security and the measures associated with it. We hold the security of all employees and visitors as one of our highest priorities.

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Labor Rights and Working conditions

COP 15: General employment terms

ALine GmbH ensures that employment terms regarding wages, working hours and other employment conditions are communicated to the employees in a written employment contract, in an understandable language, before employment starts. Employees have the right to negotiate collectively, and to create or join labor organizations of their choice without any sanction, discrimination or harassment.

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COP 16: Working hours

ALine GmbH commits to complying with all applicable labor laws on employee working hours and overtime.

The normal working week for employees, not including overtime, shall not exceed 48 hours. Overtime is worked on a voluntary basis and the sum of the normal working week, and overtime hours shall not exceed 60 hours in a week.

COP 17: Remuneration

Wages are paid on a regular basis and no less than monthly according to the employment contract. Wages are in accordance with Swiss and industry average. Included in the wages are social security contributions according to Swiss law.

 

ALine assures that neither gender, ethnicity, age, or any other demographic element influence the paid wages.

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COP 18: Harassment, Discipline, Grievance Procedures and Non-Retaliation

• Regarding harassment

Our company is committed to maintaining a workplace free from harassment, bullying, intimidation, and any form of abusive or disrespectful behavior. We do not tolerate harassment based on race, color, ethnicity, nationality, religion, gender, gender identity, sexual orientation, age, disability, or any other protected characteristic. All employees, contractors, suppliers, and business partners are expected to treat one another with dignity and respect. Any reports of harassment will be taken seriously, investigated promptly, and addressed through appropriate corrective actions.

• Regarding disciplinary measures:

ALine GmbH prohibits all forms of harsh, inhumane, or degrading disciplinary practices. Employees shall not be subjected to corporal punishment, mental or physical coercion, verbal abuse, harassment, intimidation, or any other form of disciplinary action that violates human dignity. Any disciplinary measures applied by the Company shall be fair, proportionate, documented, and conducted in accordance with applicable laws and the Responsible Jewellery Council (RJC) Code of Practices.

• Regarding grievance mechanism:

ALine GmbH maintains a confidential and accessible grievance mechanism for employees and external stakeholders. Complaints can be raised without fear of retaliation and are handled promptly and fairly.

• Regarding no retaliation:

ALine GmbH maintains a zero-tolerance policy toward retaliation. No employee or stakeholder shall suffer harassment, discrimination, intimidation, adverse employment consequences, or any other form of retaliation for reporting concerns or participating in investigations in good faith. Any act of retaliation will result in appropriate disciplinary action.

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COP 19: Child Labor

The Company strictly prohibits the use of child labor in any of its operations or supply chains. No person shall be employed below the minimum legal working age or the age for completion of compulsory education, whichever is higher. The Company is committed to complying with all applicable child labor laws and the Responsible Jewellery Council (RJC) Code of Practices (COP). Where young workers are employed, the Company will ensure that their work is lawful, does not interfere with their education, and does not expose them to hazardous, unsafe, or harmful conditions. Any instance of child labor identified will be addressed immediately through appropriate remediation measures that prioritize the best interests of the child.

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COP 20: Forced Labor

The Company strictly prohibits all forms of forced, bonded, indentured, trafficked, prison, or involuntary labor. Employment must be freely chosen, and all workers shall have the right to enter and terminate employment voluntarily, subject to reasonable notice as required by law. The Company will not retain original identity documents, require deposits as a condition of employment, or restrict workers’ freedom of movement. All workers must be treated with dignity and respect and must not be subjected to coercion, threats, intimidation, debt bondage, or any form of modern slavery. The Company is committed to preventing, identifying, and addressing forced labor risks within its operations and supply chain in accordance with applicable laws.

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COP 21: Freedom of Association and Collective Bargaining

ALine GmbH respects and supports the rights of employees to freely associate, organize, join or not join trade unions, and engage in collective bargaining in accordance with applicable laws and the Responsible Jewellery Council (RJC) Code of Practices (COP 21). Employees shall be free to exercise these rights without fear of discrimination, harassment, intimidation, retaliation, or interference. Where the right to freedom of association and collective bargaining is restricted by law, the Company will support lawful alternative means of worker representation and dialogue. The Company is committed to maintaining open communication and constructive engagement between management and employees to promote fair and respectful working conditions.

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COP 22: Non-Discrimination

We are committed to providing a workplace free from discrimination and ensuring equal opportunity in all aspects of employment. Employment-related decisions, including recruitment, hiring, training, promotion, compensation, benefits, discipline, and termination, shall be based on an individual’s qualifications, skills, experience, and performance. The Company prohibits discrimination based on race, color, ethnicity, nationality, religion, age, gender, gender identity, sexual orientation, marital status, pregnancy, disability, political opinion, union membership, social origin, or any other characteristic protected by applicable law. We are committed to fostering a respectful, fair, and inclusive working environment.

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COP 23: Diversity, Equity and Inclusivity

ALine GmbH is committed to fostering a diverse, equitable, and inclusive workplace where all individuals are treated with dignity, respect, and fairness. We value the unique backgrounds, perspectives, experiences, and contributions of our employees and strive to create an environment in which everyone has equal access to opportunities, resources, development, and advancement. The Company promotes diversity in its workforce, supports equitable employment practices, and fosters an inclusive culture free from discrimination, harassment, and bias.

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Health, Safety and Environment​

COP 24: Health and safety

ALine GmbH ensures safe and healthy working conditions for employees and visitors.

 

This is achieved through the following steps:

• Meeting all minimum health and safety requirements as stipulated by applicable law.

• Providing all staff with a safe and healthy working environment.

• Providing safe and hygienic facilities, including toilets, eating areas and first aid.

• Implementing processes for identifying workplace hazards and controlling risks.

 

COP 25: Environmental management

ALine GmbH commits to managing its environmental impacts responsibly and acknowledges climate change. The company seeks to reduce energy use, emissions from transport and business travel where feasible.

This includes, but is not limited to:

• The responsible management of all wastes and emissions to air, water and land.

• Establishing energy and water efficiency measures.

• Seeking to ensure the responsible and efficient use of other natural resources.

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Gold, Silver, PGM, Diamond and Colored Gemstone Prodcuts

COP 29: Product disclosure

ALine GmbH will not make any untruthful, misleading or deceptive representation, or make any material omission in the selling, advertising or marketing gemstones. We further commit to disclosing information on the physical characteristics of our gemstones in accordance with the Responsible Jewellery Council (RJC) Code of Practices Standard..​

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