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SUPPLY CHAIN CODE OF CONDUCT

De Vere Diamonds Limited (Trading as De Vere Diamonds) Supplier Code of Conduct

Introduction

De Vere Diamonds Limited (Trading as De Vere Diamonds) is committed to the highest standards of ethical and responsible business practice, sustainability, and transparency. Our reputation depends on the integrity of our supply chain. This Supplier Code of Conduct sets out the standards we expect from all suppliers, contractors, and business partners. Compliance with this Code is a condition of doing business with us.

1. Legal & Regulatory Compliance

  • Suppliers must comply with all applicable local, national, and international laws and regulations, including those relating to labor, health and safety, environment, anti-corruption, and trade.

  • Suppliers must maintain accurate records to demonstrate compliance.

  • All diamonds must be sourced in accordance with the Kimberley Process Certification Scheme (KPCS), OECD Due Diligence Guidance, and other relevant frameworks.

2. Responsible Sourcing of Diamonds

  • No Conflict Diamonds: Suppliers shall not source, trade, or sell diamonds that finance conflict or terrorism.

  • Traceability: Full disclosure of origin, chain of custody, and supply chain participants is required. Suppliers must provide supporting documentation.

  • Responsible Mining: Only diamonds from mines and partners that uphold human rights, fair labour, and community development are acceptable.

  • No Russian-Origin Diamonds: Suppliers must provide evidence that no diamonds originate from sanctioned jurisdictions, including the Russian Federation.

3. Human Rights & Labor Standards

  • Prohibition of Forced or Child Labour: No forced, bonded, indentured, or child labour. Minimum age requirements must be respected.

  • Fair Wages and Working Hours: Employees must receive fair compensation that meets or exceeds legal standards.

  • Non-Discrimination: Employment decisions must be based on ability and merit, not on race, gender, religion, age, disability, or sexual orientation.

  • Freedom of Association: Workers must be free to join trade unions and engage in collective bargaining without fear of retaliation.

4. Health, Safety & Wellbeing

  • Provide a safe and healthy workplace that complies with all applicable health and safety laws.

  • Take proactive steps to prevent accidents, injuries, and occupational illnesses.

  • Provide necessary protective equipment, training, and emergency preparedness measures.

5. Environmental Responsibility

  • Suppliers must minimise their environmental footprint and adopt sustainable practices.

  • This includes responsible use of energy and water, waste management, reduction of greenhouse gas emissions, and rehabilitation of mining sites.

  • Suppliers are encouraged to align with global sustainability goals, such as the UN Sustainable Development Goals (SDGs).

6. Anti-Corruption & Business Integrity

  • Zero tolerance for bribery, corruption, extortion, or embezzlement.

  • Suppliers must not offer, give, solicit, or accept bribes or improper payments.

  • Transparent recordkeeping and disclosure of any conflicts of interest are required.

7. Transparency & Audit Rights

  • Suppliers must provide De Vere Diamonds Limited (Trading as De Vere Diamonds) with access to all relevant documentation and facilities to verify compliance with this Code.

  • Independent third-party audits may be conducted.

  • Suppliers are expected to self-monitor and promptly address any breaches of the Code.

8. Community & Social Development

  • Suppliers are encouraged to invest in local communities, particularly where diamonds are mined or processed.

  • This includes supporting education, healthcare, livelihood development, and infrastructure.

9. Reporting & Whistleblowing

  • Suppliers must maintain effective grievance mechanisms for employees and stakeholders to raise concerns safely.

  • De Vere Diamonds Limited (Trading as De Vere Diamonds) maintains a confidential reporting channel for ethical concerns. Retaliation against whistleblowers will not be tolerated.

10. Continuous Improvement

  • Suppliers are expected to demonstrate a commitment to continuous improvement in ethical business practices, sustainability, and transparency.

  • De Vere Diamonds Limited (Trading as De Vere Diamonds) will prioritise long-term relationships with suppliers who share our values.

Acknowledgment

All suppliers must sign an acknowledgment confirming their understanding and acceptance of this Supplier Code of Conduct and their commitment to compliance.

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