Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Birks Group Inc. (“Birks Group” or the “Company”) is a leading designer of fine jewelry, timepieces and gifts and operator of luxury
jewelry stores in Canada. Birks Group operates luxury jewelry stores in all major cities across Canada under the Maison Birks retail brand. In addition to being a nationwide retailer with a strong brand identity, the Company is also highly regarded
in Canada as a designer and producer of jewelry. Birks Group distributes its Birks branded collections in the United Kingdom and Poland in addition to several jewelry retailers across North America. As a luxury jeweler, most of the Company’s
jewelry products are made of 18 karat gold, platinum or sterling silver, with or without precious gemstones, with significant emphasis on quality craftsmanship and distinctive design. In 2023, the Company manufactured and/or contracted for the
manufacture of products containing Conflict Minerals. Please refer to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, Form SD and the 1934 Act Release
No. 34-67716 for the definitions of terms used in this Form SD, unless otherwise defined herein.
Birks Group
has designed a Conflict Minerals compliance initiative to implement a consistent, company-wide compliance process which includes:
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Educating its employees and suppliers about Conflict Minerals; |
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Establishing a cross-functional management team including members of senior management and subject matter experts
from relevant functions such as supply chain, product development, merchandising, manufacturing, legal and finance responsible for implementing the Company’s Conflict Minerals compliance strategy; and |
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Reporting mechanisms for questions and concerns, including a toll-free confidential and anonymous hotline.
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The Company’s compliance program has been designed to conform, in all material respects, with the framework in The Organization of
Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition), and the related gold
supplement for Conflict Minerals.
In addition, the Company has adopted a Conflict Minerals Policy which has been communicated to the Company’s
suppliers and is included in the Company’s Merchandise Quality Manual and available under “Corporate Governance” on the “Investor Relations” webpage of the Company’s website at www.birks.com. The Birks Group
Conflict Minerals Policy indicates that suppliers who do not comply with this policy will be reviewed and evaluated accordingly for future business and sourcing decisions.
Conflict Minerals Disclosure
Birks Group conducted a
good faith reasonable country of origin inquiry using the Conflict Minerals Reporting Template (the “CMRT”) developed by the Responsible Minerals Initiative (“RMI”), formerly the Conflict-Free Sourcing Initiative. The CMRT was
developed to facilitate disclosure and communication of information regarding smelters that provide metal ore to a company’s supply chain. It includes questions regarding a company’s conflict-free policy and engagement with its direct
suppliers and requests a listing of the smelters used by the company and its suppliers. The CMRT also contains questions about the origin of Conflict Minerals included in the company’s products, as well as questions regarding supplier due
diligence.
The Company reviewed and evaluated each supplier response received against criteria developed such as completeness of responses in the CMRT,
inconsistencies within the data suppliers reported in the CMRT and smelter information, based on publicly available information, including a listing of smelters participating in the RMI to determine which smelters required further engagement with
the suppliers.
Based on the responses in the CMRT and additional information the Company received, the Company determined that it had no reason to
believe that any Conflict Minerals necessary to the functionality or production of its products may have originated in the Democratic Republic of the Congo or a country that shares an internationally recognized border with the Democratic Republic of
the Congo. The information discussed above is also publicly available under “Corporate Governance” on the “Investor Relations” webpage of the Company’s website at www.birks.com. The website and the information
accessible through it are not incorporated into this specialized disclosure report.
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