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Brilliant Earth’s California Transparency in Supply Chains Act Statement

As the global leader in ethically sourced fine jewelry, Brilliant Earth is passionate about cultivating a more transparent, sustainable, and compassionate jewelry industry. Brilliant Earth is committed to taking actions to help safeguard against modern slavery in its operations and supply chain.

Verification

Brilliant Earth evaluates the business operations and sourcing practices of Suppliers prior to engaging with them in an effort to better understand the risks of modern slavery in that Supplier’s operations. This evaluation includes an assessment of Supplier-provided data of their sourcing practices and business operations, as well as a review of other information available to and requested by Brilliant Earth.

Brilliant Earth’s Supplier Code of Conduct (“Code”) sets forth our risk-based approach to identifying risks of non-compliance with our standards, which include prohibitions against the use of modern slavery, as well as the management systems in place to monitor Supplier compliance with the Code.

Our natural diamond Suppliers are also required to demonstrate a robust chain of custody protocol for their diamonds and to have the ability to track and segregate diamonds by country of origin.

Audits

Brilliant Earth Suppliers undergo assessments that include the evaluation of modern slavery risks in their supply chain. Our Suppliers may be subject to in-person, announced assessments by Brilliant Earth or announced third-party audits.

Certification

Suppliers are expected to provide written acknowledgement of compliance with our Supplier Code of Conduct, which includes our expectations regarding human rights issues including the prohibition of modern slavery in our supply chain. The Code includes expectations regarding Suppliers’ policies and practices to safeguard against modern slavery in their operations. Brilliant Earth is also a member of the Responsible Jewellery Council and relies on this certification, or adherence to similar guidelines, for relevant Suppliers, as described in the Code.

Accountability

Brilliant Earth employees are expected to abide by policies in our Employee Handbook and our Ethical Business Policy, which include prohibitions against the use of modern slavery. These documents also outline the Company’s other human rights standards, and procedures for reporting any alleged violations of Brilliant Earth policies. Violation of these guidelines can result in disciplinary action, up to and including termination of employment. If a Supplier is unable to meet our requirements as specified in the Code or we have reason to believe that a Supplier is not meeting said requirements, we would implement a corrective action plan and terminate the Supplier if warranted.

Brilliant Earth’s Director of Responsible Sourcing is accountable for overseeing compliance with expectations outlined in the Code.

Training

Brilliant Earth’s standards and policies are regularly communicated to employees, including during their onboarding orientation. Employees with roles and responsibilities related to supply chain management also receive specific training related to our supply chain policies and procedures, including vendor evaluation procedures to mitigate human rights risks.

Brilliant Earth has established a Vendor Compliance Team to review current industry standards, and conduct due diligence of our supply chain, including mitigating risks associated with human rights. In addition, we partner with third-party firms to develop a deeper understanding of relevant trends and risks in our supply chain.

3rd Party Attestation of Due Diligence Practices

Brilliant Earth has engaged and worked with RCS Global Group, a global audit and advisory firm with specialization in the responsible sourcing of minerals, to review our due diligence systems and practices. Based on a desk review / assessment and subsequent action taken by Brilliant Earth to address identified gaps in the period of Q3 2018 - Q1 2019, and to the best of RCS Global’s knowledge, RCS attested that Brilliant Earth’s supply chain due diligence management system for diamonds and gold is meeting the expectations of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition.