About Rolex - 2023 Sustainability report - Governance

Our strategic commitments

— Support changes in the way that the company operates to improve transparency.
— Integrate sustainability criteria into corporate governance.
— Allocate the resources needed to fulfil the commitments made and achieve the targets set.

Sustainability governance

Structuring the approach and commitments

In 2020, Rolex launched an ‘Impact and Sustainability’ initiative to formalize its commitment to social and environmental responsibility. The aim was to develop and implement a sustainability strategy. This initiative has helped to define its approach and strengthen its governance. Supported at the highest levels of the company, sustainability is now integrated across the board to ensure the transparent management of business activities in response to the challenges of sustainable development, both in terms of ethics and integrity, and compliance with standards, laws and regulations.

Organization

Rolex has organized itself at every level to meet the challenges of sustainable development, from decision- making bodies to operational departments. In this context, the company has also set up an Impact and Sustainability Department along with dedicated committees to steer the company’s sustainability strategy and activities. The Chief Executive Officer, Jean-Frédéric Dufour, champions and embodies the brand’s sustainability vision among management and members of the Board of Directors.

Rolex's sustainability governance structure, detailing key committees and operational areas.

Responsibilities

Board of Directors
Composed of seven independent members, the Board of Directors approves the strategy of Rolex SA and ensures its implementation.

Chief Executive Officer
The management of the company’s business affairs is delegated to the Chief Executive Officer, who reports on his management to the Board of Directors, particularly with regard to sustainability.

Sustainability Strategy Committee
Created in 2020 by the Chief Executive Officer, the aim of the Sustainability Strategy Committee is to approve and lead Rolex’s sustainability strategy. Led by the Head of Sustainability and the Chief Executive Officer, the seven-member committee meets on a quarterly basis.

Sustainability Advisory Council
Made up of experts from outside the company, the Sustainability Advisory Council was set up to advise Rolex on sustainable development challenges affecting the watchmaking sector, such as the traceability of raw materials, human rights and all environmental topics (including climate change, biodiversity and water management).

Impact and Sustainability Department
Reporting to the Chief Executive Officer, the Impact and Sustainability Department is tasked with coordinating the company’s sustainability strategy and supporting its rollout, both in Switzerland and abroad, ensuring dialogue with internal and external stakeholders and driving change within the company. It is also responsible for measuring and improving Rolex’s actions in non-financial fields.

Sustainability Steering Committee
Comprising one or more representatives from each division of Rolex SA and from Manufacture des Montres Rolex SA, the Sustainability Steering Committee has some 15 members and meets four times a month. It oversees the rollout of the sustainability strategy and the implementation of the related action plan. The Committee also includes a member from the TUDOR brand to ensure that industrial and commercial best practices are shared with this entity.

Sustainability Operations Committees
The 10 existing Sustainability Operations Committees are tasked with rolling out the company’s road map within the scope of their activities.

Ethics and compliance governance

Dedicated supervisory bodies

The Rolex group is structured to address ethical and compliance topics both in terms of strategy and the steering and monitoring of its activities. It has also introduced measures to detect and manage the risks associated with its various supply chains in order to limit its environmental and social impact. To this end, the group maintains close relationships with its partners, suppliers and retailers, accompanying and supporting them in their initiatives to promote sustainable development. In the same way, it assures its customers – and its employees – that it is doing everything in its power to guarantee responsible production and sustainable products.

To strengthen its responsibility in terms of its business conduct, Rolex has been developing a reference framework and internal guidelines over many years, which it continuously adapts to respond to the latest developments in the legislative and regulatory environment. Rolex’s new Responsible Purchasing Policy, for example, formalizes the entry into force of the Swiss Ordinance on due diligence and transparency (ODiTr) and Regulation 2017/821 of the European Parliament and of the Council. It is also based on the principles of the Organisation for Economic Co-operation and Development’s (OECD’s) guide to due diligence related to supply chains of minerals from conflict-affected or high-risk areas (2016/third edition). These principles include the application of due diligence obligations and also concern stakeholder collaboration, innovation, continuous improvement, equal opportunities, and monitoring and evaluation.

These steps institutionalize Rolex’s voluntary commitment, which stems from its core values. It has also given Rolex the opportunity to structure its processes and checks to ensure rigorous risk management in a wide range of areas, including child labour, the sourcing of minerals and metals from conflict-affected and high-risk areas, respect for human rights, the impact of its activities on communities, social initiatives, preventing environmental risks, reducing greenhouse gases, waste management, raw material traceability, business ethics and deontology.

This diagram presents the governance structure for ethics and compliance at Rolex. The Board of Directors oversees the Ethics and Compliance Strategy Committee, which works in tandem with the Ethics and Compliance Steering Committee and the Internal Audit function. The Ethics and Compliance Team manages daily operations and reports to the Steering Committee. Dedicated purchasing teams in Geneva, Bienne, and TUDOR ensure ethics and compliance are upheld across all Rolex entities, supporting the company’s commitment to integrity, regulatory compliance, and responsible business practices. — Rolex's ethics and compliance governance framework, outlining key committees and functions.

Organization

Ethics and compliance governance applies to all the value chains of Rolex entities that are subject to legal due diligence and transparency obligations. Guided by an Ethics and Compliance Charter, its aim is to steer, roll out and improve the entire due diligence system, including the due diligence strategy, disseminating and applying guidelines, overseeing the risk management system, managing an alert system, coordinating external audits and the due diligence report, as well as overseeing compliance training and regulatory, geopolitical and media monitoring.

Its remit also includes defining the ethical, social and environmental risks for each external stakeholder, implementing and monitoring risk mitigation plans and updating the Responsible Purchasing Policy and Sustainable Development Charter.

Responsibilities

Ethics and Compliance Strategy Committee
The Ethics and Compliance Strategy Committee comprises, at a minimum, the Director of the Purchasing, Support and Infrastructure (PSI) Division, the Head of Purchasing and the Head of Ethics and Compliance at Rolex SA. The main role of this committee, which meets at least twice a year, is to guarantee ethics and compliance governance by approving the internal charter, rollout plans and due diligence work. Its responsibilities also include approving risk maps, working with at-risk stakeholders and reviewing the due diligence report, which it submits to the Board of Directors for signature.

Ethics and Compliance Steering Committee
The Ethics and Compliance Steering Committee is made up of, at a minimum, the Heads of Purchasing of Rolex SA, Manufacture des Montres Rolex SA, Montres TUDOR SA and Manufacture TUDOR SA, the Head of Public Relations of the Communication and Image Division of Rolex SA, the Head of Finance Switzerland of Rolex SA and the Head of Ethics and Compliance of Rolex SA. This committee meets at least 10 times a year. It oversees the production of the annual due diligence report, the rollout plan and due diligence work, as well as stakeholder management and cases emanating from the alert system.

Ethics and Compliance Team
The Ethics and Compliance Team reports to the Ethics and Compliance Steering Committee. The Head of the Ethics and Compliance Team has direct access to both the Strategy Committee and the Steering Committee, with whom they communicate and talk regularly. In charge of operational activities relating to ethics and compliance, this team is responsible for:
— monitoring value chains and due diligence requirements;
— training all the group’s stakeholders in due diligence and compliance;
— ensuring the group’s external due diligence audit is completed successfully;
— monitoring the integration process for new external stakeholders;
— monitoring the process for investigating and closing alerts;
— preserving the anonymity and confidentiality of the whistleblowers.

The Ethics and Compliance Team carries out its activities impartially and independently of the objectives of other internal departments or divisions. This provides additional assurance regarding the level of control of the risks associated, among other things, with the scope of the ODiTr.

Traceability governance

A specific framework

In addition to the ethics and compliance control and monitoring activities, Rolex has introduced specific governance for traceability topics related to its supply chain.

Precious metals and precious stones committees

As the supervisory body for responsible purchasing practices, the Precious Metals Committee guarantees governance, approves strategy and ensures decisions are coherent. It meets regularly to carry out strategic and operational monitoring. Gold, silver, platinum and palladium, in particular, are handled by this committee. This level of governance is replicated for precious stones within a Precious Stones Committee.

Sourcing committee

The Sourcing Committee meets annually with each supplier to assess its performance and define an action plan for certain precious materials.

Communicating about sustainability

Internal and external communications

For years, the company has been regularly communicating internally about the development of its ‘Impact and Sustainability’ initiative, both via its Intranet and via specific communication channels intended for management.

After rolling out a dedicated information campaign at the end of 2022 aimed at all the company’s key personnel, a monthly themed publication was launched in 2023. The Intranet has also featured a specific section dedicated to Corporate Social Responsibility (CSR) since October 2023.

Rolex has also strengthened its external communications about sustainability. Since October 2023, the general public has been able to read up on the brand’s commitments to sustainable development on dedicated pages of the Rolex website (rolex.com).

In this report – and for the first time publicly – the brand is also communicating all its sustainability initiatives. Prior to this, it had been producing sustainability reports for internal use since 2017.

Finally, to meet the requirements of the Swiss Ordinance on due diligence and transparency (ODiTr), Rolex has produced an internal report with details of the organization put in place to ensure respect for human rights in its supply chain, as well as the traceability of certain raw materials, notably gold, tungsten, tantalum and tin. The brand complies with article 964k of the Swiss Code of Obligations, which requires to comply with the due diligence obligations in relation to minerals and metals from conflict-affected areas. Rolex is working with PricewaterhouseCoopers SA as the independent assurance specialist in that regard.

Communication about the traceability system and the alert system was rolled out internally for Rolex employees. This information is also available on the brand’s institutional websites for all its stakeholders. All direct suppliers were informed by letter of Rolex’s implementation of an ethical, social and environmental risk management system and the formalization of responsible purchasing practices. Suppliers were also informed of the online availability of Rolex’s alert system and the rollout of its ethics and compliance governance.

Code of conduct

Shared values and principles

Drawn up in 2023 for distribution in 2024, the Rolex Code of Conduct defines the commitment expected of the brand’s employees in terms of the company’s business conduct, particularly in areas such as corruption, conflicts of interest and fair competition practices, as well as in the management of health and safety in the workplace and, among other things, environmental practices.

Data protection and cybersecurity

Guaranteeing a secure environment

Data protection

Rolex has always paid particular attention to protecting personal data, whether belonging to its employees, partners or customers. The company channels technical and organizational resources into guaranteeing this protection. In this context, its approach concerns the collection and secure storage of data, as well as the regulation of its use. The aim is to prevent any misuse or unauthorized access.

Supervised and managed by specialist teams, this activity covers risk and compliance, training and awareness raising, incident management and security testing. Data confidentiality and tracking policies are also available on the company’s website (rolex.com).

The company has organized itself at every level to optimize security, and guarantee compliance and the fulfilment of its legal obligations. To this end, it created the position of Personal Data Protection Advisor and appointed staff to raise awareness across all business lines concerned, to guarantee best practices and ensure compliance.

Each IT project is also supervised to ensure it features protection solutions designed to prevent accidental loss, unauthorized use or access, and any modification or disclosure of personal data. Requests can also be made to assert rights, such as the right to be forgotten. The team processed 15 personal data erasure requests in 2023. It should be noted that no substantiated complaints, leaks, thefts or identified losses were recorded during the financial year under review.

Cybersecurity

In addition to its data protection policy, Rolex has implemented a secure infrastructure and environment to protect all its activities against cyberattacks. At the same time, the brand enforces internal regulations and organizes various online training initiatives for all staff and compulsory in-person training for management. Initiatives designed to raise awareness about data protection are also implemented throughout the company, including regular anti-phishing campaigns, the publication of newsletters and online articles, the organization of conferences, and occasional communication campaigns in shared areas.

In 2023, an anti-phishing campaign raised awareness among more than 7,000 people (company employees and service providers). Another more targeted campaign was also rolled out to reach at-risk divisions. This involved a total of around 2,500 people.

Sustainable development