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 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 collections in the United Kingdom 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 2020, the Company manufactured and 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 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 on the Company’s website at www.birks.com. 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 Business Alliance, formerly the Electronic Industry Citizenship Coalition, and the Global e-Sustainability Initiative, 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 material 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.
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