ENVIRONMENTAL & ETHICAL CLAIMS POLICY

Last updated: October 2026

1. Purpose

De Vere Diamonds Limited (trading as De Vere Diamonds) is committed to ensuring that every environmental and ethical claim in our marketing, communications and descriptions is truthful, accurate, substantiated and lawful. “No Doubt” is a promise we can keep only if every claim we make is one we can show.

We follow:

the Digital Markets, Competition and Consumers Act 2024, which bans misleading claims and omissions and lets the Competition and Markets Authority (CMA) fine a business directly;
the CMA Green Claims Code, and the CMA’s 2026 guidance on green claims across the supply chain, under which we are responsible for a supplier’s claim once we repeat it;
the ASA CAP Code, and the equivalent advertising standards of the countries we sell to.

CMA Green Claims Code: Check your Green Claims

ASA CAP Code: Non-broadcast Code

2. Scope

This policy applies to:

all marketing campaigns, adverts, films and social media posts;
website descriptions and imagery;
client communications, including emails, brochures and press releases;
Client Journeys and testimonials;
ESG statements and investor communications;
supplier claims that we repeat;
anything drafted with the help of AI tools, which is checked by a person before it is published.

3. Core principles

Our claims must always be:

Truthful: no exaggeration and no misleading wording.
Clear: plain language, no jargon.
Evidence-based: supported by verifiable data, certification or documentation.
Up to date: reviewed regularly and corrected if outdated.
Balanced: presenting limitations where appropriate. Planting trees, for example, does not make a business “carbon neutral”.
Complete: leaving out nothing a client would need in order to judge the claim.
Fair in comparison: comparing like with like.

4. Environmental claims

4.1 We describe a product or practice as “sustainable”, “eco-friendly” or “green” only where we have independent verification.

4.2 Examples of acceptable claims:

“Your diamond is traced from the mine to your hand, and we can show you the documents.”
“We fund tree planting through Tree-Nation.”
“The trees we have planted through Tree-Nation are projected to capture more CO₂ than our company emits.” We keep the calculation on file and say which period it covers.

4.3 Examples of unacceptable claims:

“Our jewellery is 100% sustainable”, unless certified by an independent recognised body.
“Carbon neutral”, or any claim to “offset” our footprint, without a measured footprint, a lifecycle analysis and verified offsets.
“No impact on people or the planet”, or any suggestion that mining leaves no trace.

4.4 Any environmental comparison between natural and laboratory-grown diamonds must rest on published, like-for-like evidence.

5. Ethical, origin and product claims

5.1 We use “conflict-free” or “responsibly sourced” only when supported by documented proof.

5.2 Supplier claims must be backed by third-party audits, membership of recognised schemes such as the Responsible Jewellery Council or Fairmined, or direct evidence. We check before we repeat.

5.3 We always make the difference between natural diamonds and laboratory-grown diamonds clear, so that no client is misled. We call man-made diamonds “laboratory-grown”, “laboratory-created” or “synthetic”, in line with the industry’s Diamond Terminology Guideline, and we never suggest they are not diamonds.

5.4 We never make comparative ethical claims, such as “better than others”, without evidence.

5.5 Absolute claims. Words such as “every”, “all”, “never” and “fully” are used only where they are true of every diamond we supply and we hold the evidence for each.

5.6 Traceability and origin. “Traceable” means we hold documents showing a diamond’s country of origin and each step of its journey. We name a country of origin only where a GIA Diamond Origin Report or equivalent documentation supports it.

5.7 Age. We describe natural diamonds as formed “more than a billion years ago”, a figure the geology supports.

5.8 Certification. We describe a partner as certified only while its certificate is current. We do not use another organisation’s name or mark, such as RJC, Fairtrade or Fairmined, in a way its rules do not allow.

5.9 Value. We never present a diamond as an investment.

5.10 Limits. We say what a system cannot prove as well as what it can.

6. Substantiation and record-keeping

6.1 All claims must be substantiated with written evidence, such as certificates, audit reports, emissions data or independent studies.

6.2 Evidence must be retained for at least 6 years to cover legal and regulatory review.

6.3 Marketing and compliance must both sign off a claim before it is published.

7. Social and community impact claims

7.1 Any claim about supporting mining communities must be backed by verifiable contributions, such as a stated percentage of proceeds or a named community development programme.

7.2 Images of communities or miners used in marketing must be factually representative and used with consent.

7.3 We say we “support” an organisation where we promote or donate to its work. We say we “partner” with it only where there is an agreement between us.

8. Packaging and operations claims

8.1 Where we claim packaging is recyclable, biodegradable or compostable, we must hold supplier certificates confirming compliance with UK and EU environmental standards.

8.2 We do not use terms such as “plastic-free” unless verified.

8.3 Claims about our own operations, such as the energy used to host our website, rest on the provider’s written confirmation.

9. Client stories and reviews

9.1 Client Journeys and testimonials are genuine, are published with the client’s permission, and are never edited to change their meaning.

9.2 We never publish fake reviews, and we disclose any incentive given for a review.

10. Corrective action

10.1 If a claim is challenged by a regulator, the media or a client, we will:

review the evidence immediately;
correct or withdraw the claim if it is unsupported;
issue a clarification or apology where necessary.

10.2 The Compliance Officer must record all corrective actions and report them to the Board.

11. Training and oversight

11.1 All marketing, PR and sales staff are trained annually on the CMA Green Claims Code and advertising rules.

11.2 The Compliance Officer must sign off all sustainability and ethical claims.

11.3 The Board receives a quarterly update on ESG marketing compliance.

12. Continuous improvement

We commit to:

regularly reviewing industry standards and regulations;
updating our practices as legal and client expectations change;
going beyond compliance, so that every claim we make is one we can show.