Quality Policy Statement

E. Gluck Corporation is committed to designing, manufacturing, and delivering quality timepieces that satisfy the needs and expectations of our customers. Our goal is to provide consumers with quality products by assuring their performance, consistency, safety and value. E. Gluck Corporation strives to continue to improve and monitor the effectiveness of its Quality Management System to better serve its customers.

Supplier Code of Conduct

The Supplier code of conduct is E. Gluck Corporation’s fundamental expectations from its suppliers related to social and environmental conditions.  We will not tolerate any supplier that directly or indirectly violates the laws of the country where our merchandise is manufactured. This Supplier code of conduct outlines the minimum standards to ensure that our merchandise is produced in workplaces that are free of abusive, exploitative, or unsafe working conditions. We will only do business with suppliers who obey the laws of the country in which they operate and the principles expressed in this Supplier code of conduct.

Signed agreements, acceptance of E. Gluck Corporation purchase orders, and shipment of merchandise to E. Gluck Corporation represent continuing affirmation of compliance.

Human rights work E. Gluck Corporation believes the protection of human rights throughout our supply chain is a critical part of our mission.  We are guided by the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.  At a minimum, we expect you to uphold these standards:

Forced labor, Slavery and Human Trafficking All labor must be voluntary. There shall be no use of forced labor including prison labor, indentured labor, bonded labor, slave labor, or other forms of forced labor. All forms of forced labor, slavery and human trafficking are prohibited throughout the supply chain.

Child labor No person shall be employed under the age of 15 years of age, or 14 years of age where local law allows. Young employees under the age of 18 shall not work at night, in hazardous conditions or in work that interferes with schooling.

Freedom of association, Right to Organize, and Collective Bargaining
Suppliers must recognize and respect the rights of employees to freedom of association and collective bargaining.

Anti-discrimination and fair treatment Suppliers must treat employees with respect.  There will be no unlawful discrimination, harassment or abuse of any kind.

Wages and benefits Suppliers will provide employees with compensation that includes wages, overtime pay, and benefits that meet or exceed the legal minimum standards.  Employees will be paid in a timely fashion.

Work hours and overtime Suppliers shall ensure that work schedules and overtime are consistent with all applicable laws, including maximum hour and rest period laws.

Health and safety Ensuring health and safety is of upmost importance to E. Gluck Corporation.  We require that Suppliers provide employees with a safe, clean and healthy work environment.  Suppliers are responsible for integrating comprehensive health and safety management practices and job-specific safety training. Employees will have the right to refuse and report unsafe or unhealthy working conditions. Suppliers must full comply with all applicable workplace conditions, safety and environmental laws.

Environment E. Gluck Corporation is committed to protecting the environment. Suppliers shall develop and maintain environmentally responsible business practices and are responsible for compliance with all applicable environmental laws.

Business integrity Doing the right thing all the time is a core part of E. Gluck Corporation culture.  We do not tolerate corruption in any form and we expect the same from our Suppliers.  You must operate with the highest standards for business integrity and comply with all anti-corruption and anti-bribery laws. Suppliers cannot offer or accept any bribe, kickback, favor or use any improper influence when dealing with government officials or in any business arrangements. As a supplier, you will also respect our corporate policies around business conduct, such as conflicts of interest, gifts and entertainment, and confidentiality.

Anti-retaliationSuppliers shall prohibit unlawful retaliation against employees who report a compliance or ethical issue learned during the course of work performed for E. Gluck Corporation, or who cooperate in good faith with the investigation of a complaint.

Compliance Suppliers must fully comply with all applicable national and/or local laws and regulations, including but not limited to those related to labor, immigration, health and safety, and the environment.

C-TPAT

E. Gluck Corporation is a proud validated member of the CTPAT program-Customs Trade Partnership Against Terrorism.

This is a joint partnership between E. Gluck Corporation and the Customs Board of Protection. We take the security of our supply chain very seriously and procedures are in place that must be adhered to, by both our suppliers and our employees.

Interested parties can report concerns or ask questions regarding this policy by sending an email to Trade.compliance@egluck.com

E. GLUCK CORPORATION CONFLICT MINERALS POLICY

E. Gluck Corporation is committed to developing, carrying out and promoting a policy that prohibits the use of “conflict minerals” (*) mined in the Democratic Republic of the Congo (“DRC”) and the adjoining countries (“covered countries”) named in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protections Act (“The Act”), which aims to prevent the use of certain minerals that directly or indirectly finance or benefit armed groups in the DRC and covered countries.

E. Gluck Corporation recognizes that the extraction, trade, handling and export of conflict minerals from the DRC and adjoining countries supports the financing of individuals and organizations engaged in human rights violations and/or injustices.  E. Gluck Corporation has no intention of taking part in any actions or activities that violate human rights or contribute to injustice.   Therefore, E. Gluck Corporation does not directly purchase any raw conflict minerals for products that it sells, and E. Gluck Corporation will not do business with any supplier that directly or indirectly extracts, trades, handles or imports conflict minerals.

E. Gluck Corporation has officers and executives of the company in place to implement this conflict minerals policy, and E. Gluck Corporation reserves the right to request from any supplier at any time such information, certifications and documentation as it shall deem necessary to monitor or assess compliance with this policy.

*Conflict minerals include Gold; Casseterite, the metal ore from which Tin is extracted; Columbite-Tantalite also known as Coltan, the metal ore from which Tantalum is extracted; Wolframite, the metal ore from which Tungsten is extracted; or each of their derivatives.; and any other mineral or derivatives determined by the United States Secretary of State to be financing conflict in the DRC or a covered country.

Updated June 2020