Jewelry runs in the blood of Lalla and Davide Busatti, third-generation jewelers whose family history dates back to 1947 with their grandfather Antonio and their father Luigi. To liberally express their passion, vision, and expertise, the siblings branched out on their own, founding Busatti 1947, a new project based in Milan. Enhanced by their enthusiasm and unique hands-on experience gained over the years, Lalla and Davide are driven by their father’s motto, “Go your way and follow your instinct fearlessly.” Forged on their idea of uniqueness, Busatti1947 creates one-off pieces that blend handmade in Italy virtuosity and artistry, creativity with wearability. The siblings have lived and breathed jewelry since an early age. They would travel to exotic, remote countries with their father, Luigi Busatti, soaking in and adapting to the traditions of each culture. From Japan to India, from Indonesia to Thailand, under Luigi’s wing, they learned the tricks of the métier: how to use the early morning light to perceive the color and quality of the stones, how to listen to the sound of pearls by spinning them in their hands, and how to carry out endless negotiations while building solid relationships. This forged their unrivaled know-how based on competence and instinct.

With a yin-and-yang synergy, the underlying DNA of Busatti 1947 is defined by Lalla’s creativity and Davide’s ability to find beautiful yet unconventional stones that offer a unique starting point. When sourcing the stones, Davide still follows his dad’s precious advice: buy a stone if it speaks to you, if you feel it, even if it doesn’t meet the classic standards.

Balancing tradition and innovation, technology and artisanship, Busatti 1947 is defined by a harmonious mix of the expected and unexpected, by classics revisited with a contemporary twist. No matter how intricate, each piece is imagined to be worn daily and unabashedly for whatever is on your agenda–work, a stroll, or a black-tie event. This commitment to enhancing a woman’s beauty and self-confidence with a feel-good vibe is what sets Busatti1947 apart.

Ethical Code of Busatti 1947

The Ethics of Busatti 1947 (BST s.r.l.) is based on a Code of Conduct that outlines the ethical principles to be followed by all company employees and collaborators. This document represents a shared commitment to exemplary behavior, with a particular focus on respecting national and international laws, regulations, and best practices in ethical, social, and environmental matters. The company emphasizes the importance of credibility and its image, which are built on a responsible approach and adherence to high ethical standards. The values and principles of the Code are inspired by significant international documents such as the OECD Guidelines for Multinational Enterprises, the UN Women’s Empowerment Principles, the United Nations Global Compact, and the Universal Declaration of Human Rights. This Code forms the foundation of the work carried out at Busatti 1947, translating these principles into concrete and responsible behaviors.

Respect for Fundamentals Human Rights

Busatti 1947 respects Human Rights and adheres to the UN Guiding Principles on Business and Human Rights in a manner appropriate to the size of the company, its operations, and the circumstances. The company adopts a Corporate Social Responsibility Policy that clearly includes the commitment to:

• Operate in respect of Human Rights and comply with the UN Guiding Principles on Business and Human Rights;
• Operate in compliance with applicable mandatory regulations and any other signed agreements (national and international laws, ILO Conventions) regarding the respect of workers’ rights (freedom of association, compliance with working hours, fair wages, prevention of discrimination, prevention of human trafficking);
• Regularly review the policy with a focus on continuous improvement, taking into account legislative changes, updates to the Code of Conduct, and any other corporate requirements;
• Work towards the continuous improvement of working conditions to ensure employee satisfaction and meet the expectations of key stakeholders;
• Involve and raise awareness among suppliers about their availability for monitoring activities across the entire supply chain;
• Ensure employee satisfaction and pay attention to requests from stakeholders;
• Promote adequate training activities with the ultimate goal of protecting worker safety;
• Support community development in the areas where the company operates;
• Ensure that the policy is effectively documented, applied, maintained, communicated, and accessible to all personnel, including administrators, executives, managers, supervisors, and staff;
• Make the policy publicly available to stakeholders upon request.

Child Labor, Forced Labor, and Discrimination

Child Labor

Busatti 1947 commits to not using child labor and to respecting the minimum working age as stated by Italian law. To this end, Management, in collaboration with the Personnel Manager, carries out strict checks to ensure compliance with the criteria established by Busatti 1947 for hiring. Respect for fundamental human rights is central to the company’s ethos. Specifically, Busatti 1947 ensures that copies of workers’ identity documents, birth certificates, etc., verify that they are older than the age defined for a child. In the case of employing young workers, the company keeps records of wages paid, demonstrating that there is no exploitation of these workers.

Busatti 1947 has developed a remediation plan to propose to suppliers/subcontractors who employ children or young workers; for the latter, the previously mentioned procedures apply, while for children, the following remediation actions are evaluated:

• Notification to Social Services to facilitate immediate remedial action;
• Consider the possibility of employing a family member of the child in their place;
• Consider the possibility of connecting the child with a tutoring association (child protection associations, NGOs, etc.);
• Ensure the child’s school attendance, covering costs related to educational materials, school fees, etc.

Additionally, Busatti 1947 is open to signing apprenticeship and internship contracts with student-workers, guaranteeing them fundamental rights to promote their entry into the workforce. In this case, the company commits to ensuring, through checks conducted by Management, that the young worker is not assigned purely manual tasks and receives the necessary training to become a qualified worker.

Management has documented its commitment to avoiding child labor in its social responsibility policy; this policy includes the sharing of this commitment with suppliers and has been communicated to all interested parties (both internal and external).

Should the company become aware of a supplier violating this commitment, Management ensures that the matter is reported to the Labor Inspectorate and Social Services in the relevant area. In any case, within the limits of its commercial-contractual power and with a view to maintaining service continuity, Management guarantees to explore the possibility of terminating the supply relationship. By not employing anyone under the age of 18, the company ensures that neither children nor young workers are exposed to dangerous, risky, or harmful situations, either inside or outside the workplace.

Forced Labor

The company does not use forced labor as a source of income or labor but eradicates the use of forced or compulsory labor in any form. Upon hiring, it does not require workers to leave deposits or original identity documents (to avoid withholding original identity documents necessary for employment, the company accepts photocopies and self-certifications, as required by current laws). Management has documented its commitment to eliminating forced labor in its social responsibility policy; this policy includes the sharing of this commitment with suppliers and has been communicated to all interested parties (both internal and external).

To this end, the company commits to:

• Comply with the Workers’ Statute;
• Request copies of identity documents from workers, which are archived at Busatti 1947, without retaining originals;
• Refrain from requiring workers, at the start of employment, to leave monetary “deposits” that could limit their freedom;
• Refrain from charging recruitment fees or commissions, whether fully or partially borne by the workers.
• Recognize the employees’ right to leave the workplace at the end of the workday and to terminate their employment, with reasonable notice to the employer.
• Specify the role and specific tasks of any security personnel employed by the company in the relevant employment contract.
• Provide evidence of the voluntary nature of employment through the presence of a signed individual employment contract.
• Organize meetings with management to inform workers about the rules regarding notice of termination necessary to receive final wages and the procedures for resigning from employment.

As with child labor, if management becomes aware of behavior by a supplier that is contrary to these commitments, they will report the findings to the appropriate authorities.

Discrimination

To comply with the above, Busatti 1947 adheres to the provisions of the Constitution of the Italian Republic and the Workers’ Statute, ensuring:

• That payroll records over the years do not reveal discrepancies for individuals performing similar tasks.
• That during the hiring process, no discriminatory criteria are applied.
• That there is no discrimination in terms of salary, promotion, or training opportunities.
• That accounting documents confirm workers are treated in accordance with their seniority, type of tasks performed, and professional skills.
• That employees performing the same functions and tasks are offered equal training opportunities (as documented in training records).
• That female employees, performing the same function and tasks, receive the same salary, allowances, and benefits as male employees.
• That for female employees, the payment of legally established maternity benefits is recorded.
• That employees of different religious beliefs are allowed to observe their religious holidays.

Any behavior and/or activity and/or language that can be traced to:

• Threats;
• Offenses;
• Coercion;
• Exploitation of any kind,

is reported to management. Such discriminatory behavior, activities, or language is handled in accordance with applicable regulations (according to the National Collective Labor Contract (CCNL) and relevant legal documentation) with respect to the implementation of disciplinary procedures. These incidents are also recorded as issues concerning the social responsibility system and resolved through corrective and/or remedial actions. Busatti 1947 does not, under any circumstances, subject female employees to pregnancy tests. The Company Doctor monitors the health of pregnant employees as required by current regulations.

Freedom of Association and Collective Bargaining

Busatti 1947 guarantees and respects the right of employees to form or join unions of their choice and the right to collective bargaining, as provided by Article 39 of the Italian Constitution and governed by Law 300 of 1970 (Workers’ Statute).

Compliance with these rights and their exercise by employees is demonstrated by the presence, where applicable, of workers registered with various unions, and the union representative performing their role. To facilitate the exercise of these rights, Management ensures that a room is made available to employees for union activities, upon written request. Management guarantees that the union representative will not face discrimination within the company and will have the ability to communicate with the company’s workers. Employees, as provided by current legislation, have the opportunity to attend off-site union meetings.

Human Trafficking

Busatti 1947 guarantees that it neither supports nor engages in human trafficking as defined in the company policy.

Corruption and Facilitation Payments

Busatti 1947 is committed to ensuring compliance with applicable laws against extortion and corruption. It is essential to carefully examine and respect anti-corruption principles for the following reasons:

• Act in accordance with the company’s values;
• Protect the company’s reputation;
• Demonstrate the company’s commitment to the communities in which it operates;
• Ensure compliance with all anti-corruption laws applicable to the company;
• Strengthen the international application and awareness of anti-corruption laws.

Corruption includes requesting or receiving anything of value or any benefit, either directly or indirectly, from any person, with the intent or consequence that a certain function or activity will be improperly performed, either by you or someone else.

A bribe can be financial or in another form and may include giving or receiving money, loans, contributions or donations, travel, job offers, reimbursements, discounts, goods, services, or anything else of value. In certain circumstances, gifts or entertainment expenses may be interpreted as forms of corruption. A bribe can also take the form of a “reward” paid in exchange for the improper performance of a related task or duty.

Corruption is also defined as offering, promising, or giving anything of value or any benefit to anyone in order to induce improper performance. It is also considered corruption to request or accept anything of value or any benefit from anyone in exchange for granting an improper business advantage to that person.

Gifts, Meals, and Entertainment

It is often customary to exchange gifts, meals, and entertainment with clients, suppliers, and other business partners. The purpose of such exchanges is to maintain a fair relationship between the parties. It is important to avoid excessive or extravagant gifts, meals, or entertainment that could give the impression of attempting to improperly influence someone. It is always advisable to consider whether the gift, meal, or entertainment you intend to give or receive could be perceived as excessive or inappropriate or could create an obligation.

Receiving Gifts, Meals, or Entertainment

You should not accept gifts, meals, or entertainment in exchange for doing, or promising to do, something for a client, supplier, or other business partner. You should not request gifts, meals, or entertainment from a client, supplier, or other business partner. You should not accept gifts in the form of cash or cash equivalents, such as gift cards, under any circumstances. You should not accept any gift, meal, or entertainment that is excessive. This is an area where your judgment is crucial. For example, a modest holiday gift from a supplier in line with local customs, aimed at fostering a legitimate business relationship, is generally acceptable. However, an expensive weekend getaway is not. It can be difficult to define “excessive,” and what is customary and appropriate can differ from country to country. In some cases, modest personal gifts may be deemed excessive due to their total value and the specific circumstances. If in doubt, always seek prior written approval from the Legal Compliance Officer. Symbolic gifts, such as trophies or plaques engraved to commemorate a business relationship, may be accepted.

If you are offered a gift, meal, or entertainment that exceeds these guidelines, politely decline and explain the company’s policies. If returning the gift would offend the giver, or if the circumstances make it impossible to return, you must report it to the Compliance Officer, who will evaluate whether to donate the item to charity or distribute it via a lottery among a broader group of employees.

Offering Gifts, Meals, or Entertainment

Gifts and entertainment for clients, potential clients, or suppliers must support the legitimate business interests of the company and should be reasonable and appropriate based on the circumstances. Always be mindful of the rules governing the acceptance of gifts and entertainment by our clients and suppliers. If in doubt, always seek prior written approval from the Legal Compliance Officer. Cash or cash equivalents should never be offered as gifts. You must keep all receipts and documentation related to such expenses.

Exclusive Events

Bringing a client, supplier, or other business partner to an exclusive event is allowed as long as there is no intent to induce that person to act unfairly or perform their work improperly. For example, inviting a client to an exclusive event as part of a public relations activity to build rapport or raise the company’s profile is acceptable.

Management of Promotional Gifts

Gifts provided to the recipient must be selected solely for the purpose of promoting the company’s image to the recipient’s organization. The type of item or service provided should primarily be promotional in nature, with a unit value not exceeding €100.00. If gift-giving activities are included in the company’s strategic plans for a given year, they must be planned through the allocation of an annual budget. Any additional activities not anticipated during the annual planning phase may be included later, provided the associated costs do not exceed the available amounts in the budget. In such cases, substitutions with already planned activities may be necessary if required. The requesting department must submit a request to management to initiate the procedure for acquiring and delivering the item or service to the identified recipient.

Sponsorships

Sponsorship activities are undertaken solely to promote the company’s image and services. When the company is involved in sponsorship initiatives, the following steps must be completed:

• Evaluation of the Project/Proposal assess the sponsorship project or proposal, paying special attention to the sponsorship amount relative to the characteristics of the initiative being sponsored.
• Approval: The sponsorship project/proposal must be approved by the management.
• Contractual Formalities: Proper contractual agreements must be used, potentially reviewed by legal counsel, which should include provisions that prohibit the beneficiary of the sponsorship initiative from assigning the credit or giving mandates for collection. Additionally, the payment of invoices must adhere to the principle of banking domiciliation exclusively in the beneficiary’s country of residence/legal headquarters, unless there is a specific request for domiciliation in another country. The signing of contracts and approval of any variations or integrations is the sole responsibility of the administrator.
• Formalizing Relationships with External Parties any relationships with external entities (consultants, third parties, representatives, etc.) tasked with supporting the company in sponsorship efforts must be formalized and include a specific clause requiring them to comply with the principles outlined in the “Code of Ethics.”
• Traceability each phase of the process must be documented to allow for the reconstruction of responsibilities and the rationale behind decisions. Any deviations from the above principles must be authorized by the CEO.

Public Contributions and Charitable Donations

Public contributions, charitable donations, and preferential financing are generally tied to public tenders issued by governmental, community, territorial, or other public entities, aimed at fostering or rewarding company development. The process for handling these contributions typically follows a similar path:

• Selection and Identification Identify available tenders of interest to the company.
• Verification of Requirements: Identify and verify any necessary prerequisites for applying.
• Submission: Submit the application according to the tender requirements, along with any necessary documentation attesting to the required qualifications and/or declarations.
• Follow-up: Manage any additional requests from the public entity.
• Activity Verification: In case of approval, verify the completion of the activities for which the contribution was granted.
• Inspections: Manage inspections or audits by the public entity.

The control system is based on the traceability of documents. Once contributions are received, the administration must verify that the activities or benefits for which the contribution was granted have been carried out and must document the details of such activities. When external entities (consultants, third-party representatives, etc.) are hired to assist the company in submitting the request, the relationship must be formalized, and the contracts should include a specific clause requiring them to adhere to the ethical principles adopted by the company.

Conduct with Public Administration

Both employees and external collaborators have a duty to report to management any violations or suspicions of violations concerning conduct with public administration officials. Reports concerning violations or risky behaviors must be submitted exclusively in a non-anonymous form. The company is committed to protecting the whistleblower from any detrimental consequences that may arise from the report. Each department head is required to report at-risk behaviors learned either directly or from their collaborators. They must also report official news from law enforcement authorities concerning unlawful acts or crimes that could impact the company. Any contact with Public Authorities (PA) on behalf of the company must be managed with maximum transparency, ensuring traceability of information flows towards the PA. If an external party is appointed to represent the company with the PA, the assignment must be formalized and include a clause binding them to comply with company principles.

In the event of attempted extortion by a public official or individuals presenting themselves as representatives of the PA to an employee or collaborator, the following actions must be taken:

• Do not comply with the request;
• Immediately inform your Supervisor;
• The Supervisor must formally notify the management.

Below are practices to avoid, even in indirect dealings with PA representatives through third-party agents:

• Monetary payments for non-institutional purposes;
• Granting of “privileged solutions” (e.g., hiring relatives or friends);
• Unjustified representation expenses, not intended for corporate promotion;
• Promises or improper granting of goods or services (e.g., private building renovations);
• Gifts of significant value;
• Disclosure of confidential information or documents;
• Favoritism in purchasing (e.g., assigning suppliers or contracts requested by the PA).

Prohibited Actions with the PA

• Presenting false or altered documents/data;
• Deceptive conduct that could influence the PA’s economic or technical evaluation of products/services;
• Omitting relevant information to sway PA decisions in one’s favor;
• Allocating public contributions for purposes other than those for which they were obtained;
• Unauthorized access to PA’s information systems, to obtain or modify information for the company’s benefit.

Money Laundering and Terrorism Financing

Busatti 1947 applies KYC (Know Your Customer) principles to verify business partners, suppliers, and clients, especially regarding the trade of diamonds, gold, and platinum, in order to prevent money laundering and terrorism financing. Identity Verification and Risk Assessment

• Establishes the identity of the ultimate beneficial owner and the owners/clients of suppliers or customers based on risk assessment or applicable law.
• Ensures an up-to-date understanding of the nature of the business activity.
• Monitors transactions to detect unusual or suspicious activities and reports any suspicions of money laundering or terrorism financing to the competent authority.
• Maintains records of all cash transactions or similar that equal or exceed €3,000 and, if necessary, reports to the competent authority.

Whenever a transaction occurs, the customer must be identified. The obligation of identification entails obtaining the necessary information to verify the identity of the individual executing the transaction. The verification of the customer’s identity and the acquisition of their identifying data is conducted exclusively through direct acquisition in the presence of the customer, with the request for a valid identification document that is not expired.

Additionally, it is necessary to ask the customer whether they are performing the transaction on their own behalf or if there is a different ultimate beneficial owner, meaning whether the individual executing the transaction is doing so on behalf of a legal entity (company) or on behalf of another individual. If this is the case, the customer must indicate that there is an ultimate beneficial owner different from themselves, and that ultimate beneficial owner must also be identified.

Security Measures

Busatti 1947 evaluates the risks related to product security and establishes protective measures against theft, damage, or replacement of products at its premises and during transport. These security measures primarily consider the protection of employees, contractors, visitors, and the staff of business partners. The company premises are equipped with all necessary security measures to protect against thefts, robberies, damage, or replacement of products on-site and during transport, such as cameras, reinforced doors, turnstiles for personnel passage, safes, connections with operational centers, vaults, etc.

Declaration of Provenance

Busatti 1947 only markets products that are equipped with valid Declarations of Provenance based on substantiating data. All documentation related to the products is kept in administration by the responsible party in the onsite archive.