For the financial year ended 31 January 2026

Introduction

De Vere Diamonds Limited (trading as De Vere Diamonds) is committed to ensuring that modern slavery and human trafficking have no place in our business or our supply chains. Luxury must always be matched with integrity, and we take that responsibility seriously.

Our turnover is below the threshold for mandatory reporting under section 54 of the Modern Slavery Act 2015. We publish this statement voluntarily, because we think you should be able to read it.

1. Our business and supply chains

De Vere Diamonds is based in Mayfair, London. We source natural diamonds for private clients and, where a client wishes, design and commission bespoke jewellery around them. We are a small company, and we do not own mines, cutting works or workshops.

Our supply chains include:

• diamond suppliers, listed on our Supply Chain Partners page, who provide natural, conflict-free, traceable diamonds from sources including Botswana, Canada and Namibia;

• workshop partners in the United Kingdom and India, who make our settings;

• precious metal suppliers, including Fairmined and Fairtrade gold providers;

• supporting services such as grading, secure logistics, packaging and marketing.

We carry out due diligence to make sure our partners share our commitment to ethical practice.

2. Our policies

• A Supply Chain Code of Conduct, which requires compliance with labour, human rights and ethical standards.

• A Responsible Sourcing Policy and a Responsible Sourcing and Sanctions Policy.

• Contractual clauses prohibiting forced labour, child labour and human trafficking.

• A whistleblowing channel through which staff, suppliers and stakeholders can report concerns in confidence: hello@deverediamonds.com.

3. Risk assessment

We recognise that risks of forced labour and exploitation exist in parts of the global diamond and precious metals industries. They are highest in artisanal and small-scale mining, in cutting and polishing, and in gold mining. To reduce these risks, we:

• source only from suppliers with demonstrable traceability and ethical certification;

• reject diamonds of Russian origin, in line with UK and G7 sanctions;

• prioritise suppliers engaged in community benefit, land restoration and fair working conditions.

4. Due diligence

• We carry out KYC (Know Your Counterparty) checks and enhanced due diligence before we buy from any supplier.

• We require every supplier and workshop partner to hold current Responsible Jewellery Council certification, which brings independent audit of labour standards.

• We review every supplier at least once a year.

• If we find or suspect modern slavery, we investigate at once and suspend orders. We work with the supplier to put things right in the interests of the workers affected, and we end the relationship if that does not happen.

5. Training

All staff involved in procurement and supplier relationships receive training on:

• the Modern Slavery Act;

• responsible sourcing requirements;

• identifying red flags in supply chains.

6. Measuring effectiveness

We track:

• the proportion of suppliers and workshop partners holding current RJC certification;

• the proportion who have signed our Supply Chain Code of Conduct;

• the number of concerns raised, and how each was resolved;

• completion of training.

Continuous improvement

We are committed to:

• regularly reviewing our policies and due diligence;

• strengthening supplier partnerships that support human rights and social good;

• aligning our practices with the UN Sustainable Development Goals.

Board approval

This statement has been approved by the Board of Directors of De Vere Diamonds Limited (trading as De Vere Diamonds). It is reviewed annually and updated as our business grows.

Signed:

Philip De Vere

Managing Director, De Vere Diamonds Limited (trading as De Vere Diamonds)

Date: 31/01/2026