SUPPLY CHAIN CODE OF CONDUCT

Last updated: October 2026

Introduction

De Vere Diamonds Limited (trading as De Vere Diamonds) is committed to the highest standards of ethical and responsible business practice and to transparency. Our reputation depends on the integrity of our supply chain. This Code sets out the standards we expect of every supplier, contractor, workshop and business partner. Compliance with this Code is a condition of doing business with us.

1. Legal and regulatory compliance

Suppliers must comply with all applicable local, national and international laws and regulations, including those on labour, health and safety, the environment, anti-corruption, sanctions, data protection and trade.
Suppliers must maintain accurate records to demonstrate compliance.
All diamonds must be sourced in accordance with the Kimberley Process Certification Scheme (KPCS), the World Diamond Council System of Warranties, the OECD Due Diligence Guidance and other relevant frameworks.
Diamond suppliers and workshop partners must hold current certification against the Responsible Jewellery Council Code of Practices, and must tell us at once if it lapses, is suspended or is withdrawn.

2. Responsible sourcing of diamonds

Natural diamonds only. Every diamond supplied to us must be natural. Laboratory-grown diamonds and simulants must never be supplied or mixed in, and suppliers must screen their parcels to make sure.
Full disclosure. Any treatment must be disclosed in writing before supply.
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 diamond originates from a sanctioned jurisdiction, including the Russian Federation, whatever its size and wherever it was cut or polished.
Warranties. Every invoice must carry the World Diamond Council System of Warranties statement.

3. Precious metals

Gold must be Fairtrade or Fairmined certified where we specify it, and must otherwise come from an LBMA-accredited refiner. Platinum must come from an LPPM-accredited refiner.
Workshop partners must hold the Fairtrade or Fairmined registration or licence needed to work with certified metal.
Chain-of-custody documentation must accompany each supply.
Every article must meet the requirements of the Hallmarking Act 1973 and be described accurately.

4. Human rights and labour standards

Prohibition of forced or child labour. No forced, bonded, indentured or child labour. Minimum age requirements must be respected. Workers must not be charged recruitment fees or have their identity documents withheld.
Fair wages and working hours. Employees must receive fair pay that meets or exceeds legal standards, and working hours must stay within legal limits.
Non-discrimination. Employment decisions must be based on ability and merit, not on race, gender, religion, age, disability or sexual orientation. Harassment and abuse are not tolerated.
Freedom of association. Workers must be free to join trade unions and to bargain collectively without fear of retaliation.

5. Health, safety and 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 the necessary protective equipment, training and emergency preparedness.

6. Environmental responsibility

Suppliers must minimise their environmental footprint and adopt responsible 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 goals such as the UN Sustainable Development Goals (SDGs).

7. Anti-corruption and business integrity

Zero tolerance for bribery, corruption, extortion or embezzlement.
Suppliers must not offer, give, solicit or accept bribes or improper payments, including facilitation payments, and must comply with the UK Bribery Act 2010 in everything they do for us.
Transparent record-keeping and disclosure of any conflict of interest are required.

8. Confidentiality, client information and designs

Client names, details and stories are confidential. They must be used only to carry out our instructions, kept secure, and deleted or returned when the work is done.
Designs, sketches and CAD files remain the property of De Vere Diamonds. They must not be copied, reused, shown or sold.
Suppliers must not publicise their work for us, or for any client of ours, without our written consent.

9. Subcontracting

No part of our work may be subcontracted without our written consent.
Any approved subcontractor must meet this Code, and the supplier remains responsible for their work.

10. Transparency and audit rights

Suppliers must give De Vere Diamonds access to all relevant documentation and facilities to verify compliance with this Code.
Independent third-party audits may be conducted.
Suppliers are expected to monitor themselves and to address any breach of the Code promptly.

11. Community and social development

Suppliers are encouraged to invest in local communities, particularly where diamonds are mined or processed.
This includes supporting education, healthcare, livelihoods and infrastructure.

12. Reporting and whistleblowing

Suppliers must maintain effective grievance mechanisms through which employees and stakeholders can raise concerns safely.
De Vere Diamonds maintains a confidential reporting channel for ethical concerns at hello@deverediamonds.com. Retaliation against whistleblowers will not be tolerated.

13. When standards are not met

Suppliers must tell us promptly of any breach of this Code.
Where a breach can be put right, we will agree a corrective plan and a timetable, and we may suspend orders in the meantime.
We will end the relationship where a serious breach is confirmed or is not put right.
Where a worker has been harmed, putting that right for the worker comes first.

14. Continuous improvement

Suppliers are expected to show a commitment to continuous improvement in ethical business practice, environmental care and transparency.
De Vere Diamonds will prioritise long-term relationships with suppliers who share our values.

Acknowledgment (Individual copies completed by appropriate supply chain partners)

All suppliers must sign an acknowledgment confirming that they understand and accept this Supply Chain Code of Conduct and commit to complying with it.

Supplier name:

Authorised signatory and position:

Signature:

Date: