RESPONSIBLE SOURCING AND SANCTIONS POLICY
1. Purpose and Commitment
De Vere Diamonds Limited (Trading as De Vere Diamonds) is committed to ensuring that all diamonds and precious metals used in our jewellery are sourced responsibly, ethically, and legally. We categorically reject “blood diamonds” and any materials linked to conflict, human rights abuses, or environmental harm.
We are fully aligned with international sanctions regimes, the OECD Due Diligence Guidance, the UN Sustainable Development Goals, and UK Modern Slavery Act requirements.
2. Scope
This policy applies to:
All natural diamonds purchased, processed, or sold by De Vere Diamonds Limited (Trading as De Vere Diamonds).
All precious metals used in our jewellery.
All suppliers, contractors, workshops, and partners within our supply chain.
3. Sanctions and Origin Controls
3.1 We do not purchase, process, or sell diamonds of Russian origin, regardless of where they are cut or polished.
3.2 We comply with all applicable sanctions and trade restrictions imposed by the UK, EU, G7, US, and UN.
3.3 We require suppliers to provide documentation proving country of origin and supply chain route.
3.4 Evidence must be retained to demonstrate compliance for audits and regulatory purposes.
4. Traceability and Transparency
4.1 We require full supply chain traceability for all diamonds from mine to market.
4.2 All suppliers must provide verifiable documentation (invoices, certificates, shipping documents, customs declarations).
4.3 From January 2026, all diamonds sold into the EU will require certified origin documentation. De Vere Diamonds Limited (Trading as De Vere Diamonds) will fully comply with these rules.
4.4 We publicly report on our responsible sourcing efforts to demonstrate transparency and accountability.
5. Supplier Standards and Due Diligence
5.1 All suppliers must comply with our Supplier Code of Conduct.
5.2 We conduct Know Your Counterparty (KYC) checks and enhanced due diligence on all our diamond and jewellery suppliers.
5.3 We require suppliers to provide:
Evidence of ethical mining or sourcing practices.
Modern slavery statements (if applicable).
Kimberley Process compliance (where relevant).
Membership or alignment with recognised standards (e.g., Responsible Jewellery Council, Fairmined, Fairtrade).
6. Human Rights and Modern Slavery
6.1 We do not tolerate forced labour, child labour, or exploitation in our supply chain.
6.2 We comply with Section 54 of the UK Modern Slavery Act 2015, publishing an annual statement.
6.3 We prioritise suppliers who demonstrate social good — including community reinvestment, fair wages, and safe working conditions.
7. Environmental Responsibility
7.1 We favour suppliers who use sustainable mining practices, land restoration, and reduced carbon footprint initiatives.
7.2 Precious metals used in our jewellery (gold, platinum) are sourced from certified Fairmined/Fairtrade suppliers wherever possible.
7.3 We continue to review and improve our ESG performance, including packaging, logistics, and energy use.
8. Risk Management
8.1 We carry out regular supply chain audits and require suppliers to complete questionnaires and provide evidence.
8.2 If risks of conflict, human rights abuse, or sanction breaches are identified, we:
Investigate immediately.
Suspend orders with the supplier pending clarification.
Terminate relationships where non-compliance is confirmed.
8.3 Findings and corrective actions are documented and available for inspection by regulators, investors, or auditors.
9. Training and Awareness
9.1 All staff involved in procurement, compliance, and customer communication are trained in responsible sourcing obligations.
9.2 Training covers sanctions, anti-money laundering (AML), due diligence, modern slavery, and ESG requirements.
10. Reporting and Whistleblowing
10.1 Employees, suppliers, and stakeholders are encouraged to report concerns about unethical practices.
10.2 Concerns can be reported confidentially to: hello@deverediamonds.com.
10.3 All reports will be investigated promptly and acted upon without retaliation.
11. Continuous Improvement
11.1 We regularly review this policy to reflect legal updates, sanctions changes, and industry best practice.
11.2 We aim not only to comply with regulations but to set the standard for ethical diamond sourcing in the global jewellery industry.
12. Governance
12.1 This policy is approved by the Board of Directors of De Vere Diamonds Limited (Trading as De Vere Diamonds).
12.2 Responsibility for implementation rests with the Compliance Officer / MLRO (Money Laundering Reporting Officer).
12.3 The Board receives regular updates on compliance status and risk management.