Last updated: October 2026

1. Purpose and commitment

De Vere Diamonds Limited (trading as De Vere Diamonds) is committed to ensuring that every diamond and all precious metal we supply is sourced responsibly, ethically and legally. We categorically reject “blood diamonds” and any material linked to conflict, human rights abuses or environmental harm.

We align our practice with UK and international sanctions regimes, the OECD Due Diligence Guidance, the UN Guiding Principles on Business and Human Rights, the UN Sustainable Development Goals and the Modern Slavery Act 2015.

This policy sets out our controls. Our Responsible Sourcing Policy sets out the commitments behind them.

2. Scope

This policy applies to:

• all natural diamonds purchased or sold by De Vere Diamonds, and any cut, polished or set for us;

• all precious metals used in our jewellery;

• all suppliers, contractors, workshops and partners in our supply chain;

• our clients, and the destinations we deliver to, so far as sanctions law requires.

3. Sanctions and origin controls

3.1 We do not purchase, handle or sell diamonds of Russian origin, of any size, regardless of where they were cut or polished. UK law bans Russian diamonds processed in other countries from 0.5 carats. Our ban has no lower limit.

3.2 We comply with all applicable sanctions and trade restrictions imposed by the UK, the EU, the G7, the US and the UN.

3.3 We require suppliers to provide documentation proving country of origin and supply chain route, including the declarations required when polished diamonds are imported.

3.4 Evidence is retained for at least six years to demonstrate compliance for audits and regulatory purposes.

3.5 We screen suppliers, and clients and payers where the risk calls for it, against the UK Sanctions List and other relevant lists. We do this when a relationship begins and at intervals afterwards.

3.6 We do not deliver to any destination, or deal with any person, where UK sanctions or export controls prohibit it.

3.7 If we know or suspect that sanctions have been breached, or that we are dealing with a designated person, we stop. We then report to the Office of Financial Sanctions Implementation or another authority as the law requires.

4. Traceability and transparency

4.1 We require full supply chain traceability, from mine to market, for every principal diamond we supply. Our partners record each diamond on an independent tracing platform (Tracr, Sarine, iTraceiT or Authentia), and when it reaches us we verify it again on the platform used at source. Accent diamonds are verified wherever possible. Where one cannot be verified by its own certificate, it is obtained only from our recognised supply chain partners.

4.2 All suppliers must provide verifiable documentation: invoices, certificates, shipping documents and customs declarations.

4.3 For deliveries to clients in the European Union, EU rules require the importer of a polished diamond of 0.5 carats or more to give customs a due diligence statement, with evidence that the diamond was not mined, processed or produced in Russia. We provide that evidence with every such delivery.

4.4 We report publicly on our responsible sourcing. We publish our supply chain partners and their certification, how we verify what we say, and our Modern Slavery Statement.

5. Supplier standards and due diligence

5.1 All suppliers must comply with our Supply Chain 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), and a World Diamond Council System of Warranties statement on every invoice;

• current certification against the Responsible Jewellery Council Code of Practices, and membership of or alignment with other recognised standards such as Fairmined and Fairtrade;

• a warranty that every diamond is natural, with any treatment disclosed.

5.4 We check each supplier’s RJC certification when we first work with them and again before it expires. We place no new orders with a supplier whose certification has lapsed.

6. Human rights and modern slavery

6.1 We do not tolerate forced labour, child labour or exploitation in our supply chain.

6.2 Our turnover is below the threshold in section 54 of the Modern Slavery Act 2015. We publish a statement every year voluntarily.

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 whose sources use lower-impact mining practices, restore land and are reducing their carbon footprint.

7.2 The precious metals used in our jewellery (gold and platinum) are sourced from certified Fairmined or Fairtrade suppliers wherever possible, and otherwise from LBMA-accredited or LPPM-accredited refiners. Our workshop partners are registered or licensed with Fairtrade and Fairmined.

7.3 We continue to review and improve our own ESG performance, including packaging, logistics and energy use.

8. Risk management

8.1 We review every supplier at least once a year: certification status, sanctions screening, a questionnaire and supporting evidence. We rely on the independent audits required for RJC certification, and we reserve the right to audit a supplier ourselves.

8.2 If risks of conflict, human rights abuse or sanctions breaches are identified, we:

• investigate immediately;

• suspend orders with the supplier pending clarification;

• terminate the relationship 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 client 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 are 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 to do more than regulation requires, and to be able to show the evidence for everything we say.

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, Michelle Hunter Smith, who also acts as our nominated officer for anti-money-laundering and sanctions reporting.

12.3 The Board receives regular updates on compliance status and risk management.