Ethical & Responsible Sourcing Policy

Our commitment to responsible and ethical sourcing is fundamental to how we conduct business

1. Introduction & Purpose

At Rosy Blue, responsible and ethical sourcing is fundamental to how we conduct business. Operating within a global and highly interconnected diamond supply chain, we recognise that sourcing decisions can have significant human, social, environmental, and geopolitical implications. As a result, Rosy Blue is committed to ensuring that all diamonds handled, traded, or supplied by the company are sourced responsibly, transparently, and in full compliance with applicable laws and internationally recognised standards.

This Ethical & Responsible Sourcing Policy exists to ensure respect for human rights, prevent any direct or indirect contribution to conflict or illicit activity, and safeguard the integrity of the diamond industry. It provides a structured framework through which Rosy Blue identifies, assesses, mitigates, and monitors supply-chain risks in line with the OECD Due Diligence Guidance, international sanctions regimes, and emerging regulatory expectations related to traceability and supply-chain transparency.

Rosy Blue has long supported collective industry action as a means to drive meaningful and lasting change. The company has been a founding member of the Responsible Jewellery Council (RJC) since its inception, reflecting our commitment to independently audited standards covering responsible sourcing, business ethics, human rights, and environmental responsibility. In addition, Rosy Blue actively supports the World Jewellery Initiative 2030 (WJI 2030), recognising that collaboration across the industry is essential to address shared sustainability challenges and advance responsible practices at scale.

Through this policy, Rosy Blue also seeks to meet the evolving expectations of customers, financial institutions, regulators, and other stakeholders, many of whom require enhanced levels of due diligence, origin transparency, and audit readiness. By embedding responsible sourcing into our governance structures, operational procedures, and day-to-day decision-making, Rosy Blue aims to protect its stakeholders, preserve trust in the diamond supply chain, and support the long-term sustainability of both our business and the industry as a whole.

2. Scope & Applicability

This policy applies to all employees, suppliers, contractors, and business partners of Rosy Blue NV involved in the sourcing, trading, and handling of diamonds and jewelry materials. It covers our entire supply chain, from mining to retail.

3. Normative Frameworks

Rosy Blue adheres to the following legal and normative frameworks:

  • OECD Due Diligence Guidance for Responsible Supply Chains
  • United Nations Guiding Principles on Business and Human Rights (UNGPs)
  • RJC Code of Practices
  • Kimberley Process Certification Scheme (KPCS)
  • G7 and EU Sanctions on diamonds of Russian origin

4. Ethical Sourcing Principles

Rosy Blue has zero tolerance for:

  • Conflict diamonds
  • Child labor or forced labor
  • Human rights abuses, torture or war crimes
  • Bribery, money laundering, or tax evasion
  • Fraudulent misrepresentation of origin

We only source from suppliers who comply with our due diligence requirements and who demonstrate a commitment to ethical conduct.

5. Supplier Due Diligence

Due diligence is a continuous, proactive, and reactive process that enables companies to ensure they respect human rights and avoid contributing to conflict. It also supports compliance with international and domestic legal requirements, including those related to the illicit trade in minerals and United Nations sanctions.

Risk-based due diligence involves taking structured steps to identify, evaluate, and respond to actual or potential risks, with the objective of preventing or mitigating adverse impacts linked to a company's operations or sourcing activities.

All suppliers must comply with the following without exception:

  1. 1.Complete Rosy Blue's Supplier Due Diligence Questionnaire.
  2. 2.Sign the Business Partner Code of Conduct.
  3. 3.Rough origin data to be provided to the fullest extent possible, including both country of origin and mining company.
  4. 4.Be RJC certified or undergo enhanced due diligence.
  5. 5.Provide accurate, complete, and verifiable documentation for every transaction.
  6. 6.Allow Rosy Blue to perform audits or additional requests at any time.

Failure or refusal to comply = automatic red flag + transaction hold.

6. Traceability & Provenance Claims

We require:

  • Provenance traceability for single stones (supplier, mine and country)
  • Mass balance traceability for 0.18ct and smaller diamonds.
  • Accurate, truthful invoice statements stating:
  • Natural and untreated origin
  • Conflict-free status
  • Non-Russian, non-Zimbabwean.

7. Alignment With High-Standard Clients Sourcing Protocols

Certain luxury clients in the global watch and jewellery sector apply enhanced sourcing protocols that specify strict requirements regarding approved mining sources, documentation standards, warranty statements, inventory controls, and audit expectations.

Rosy Blue integrates these requirements into its responsible sourcing system to ensure full compliance whenever supplying clients who operate under such protocols.

7.1 Approved Sources & Origin Requirements

Some clients maintain an Approved Sources List identifying the mines, producers, and countries from which diamonds may originate. These lists commonly include major responsible producers across Africa, Canada and Australia.

Rosy Blue ensures that for any transaction requiring compliance with such protocols:

  • Diamonds originate only from documented and approved mines/countries.
  • No diamonds originate from prohibited or subject sources identified as high-risk for human rights violations or armed conflict.
  • Full mine-level or country-level origin documentation is retained and available for verification.

This includes complete segregation of goods intended for high-standard clients from any non-approved origin material.

7.2. Mandatory Warranty & Documentation Requirements

High-standard protocols require three categories of warranty statements on invoices or commercial documents:

1. Protocol-Specific Source Warranty

Attesting that diamonds were obtained exclusively from approved sources and not from any prohibited origins.

2. World Diamond Council (WDC) System of Warranties Statement

Mandates that diamond buyers and sellers include a warrantly statement on their invoices, ensuring that diamonds originate from rough stones certified by the Kimberley Process Certification Scheme.

3. Natural & Untreated Confirmation

Confirming that all diamonds are of natural origin and untreated.

Where required, Rosy Blue will also include industry-standard unique identifiers such as WDC UIN numbers.

7.3. Inventory Control & Audit Obligations

Some clients require their suppliers to maintain qualified inventory control procedures, including:

  • Segregation of goods from different origins
  • Full chain-of-custody traceability
  • Documentation retention (minimum five years)
  • Annual source warranty audits
  • Periodic invoice reconciliation assessments by independent auditors

7.4. High-Risk or Prohibited Origin Restrictions

Under several high-standard protocols, certain countries or mining regions are prohibited due to sanctions, conflict involvement, or severe governance risks.

Rosy Blue aligns with these protocols by prohibiting:

  • Diamonds from sanctioned countries
  • Diamonds from conflict-affected or human-rights-risk regions
  • Diamonds lacking complete, verifiable origin documentation

Rosy Blue will only supply goods that fully comply with the origin restrictions applicable to the relevant client.

7.5. Verification & Source Documents

Requires that all warranties be issued based on "best knowledge," supported by:

  • Verified upstream warranties
  • Kimberley Process Certificates
  • Transparent origin documentation
  • Segregated inventory control procedures

Rosy Blue reviews all such documents before issuing any warranty and escalates discrepancies through our internal red-flag and risk-assessment procedures.

7.6. Transparency, Cooperation & Audit Readiness

Rosy Blue cooperates with all client requests related to:

  • Origin verification
  • Transaction-level documentation
  • Audit support
  • Due diligence questionnaires
  • Corrective actions and compliance reviews

These expectations are fully embedded into Rosy Blue's broader Ethical Sourcing Framework and support our commitment to integrity and supply chain transparency.

8. Governance & Responsibilities

The implementation and oversight of this policy lies with the Director of Supply Chain supported by the Compliance Officer, COO, and Internal Audit team. Any red flags or deviations must be escalated to the Director of Supply Chain and Chief Operating Officer.

9. Monitoring, Audit & KPIs

We commit to ongoing monitoring, internal and external audits, and reporting. Key indicators include:

  • % of suppliers fully screened
  • % of suppliers with verified origin documentation
  • Number of red flags detected
  • Number of escalated supplier reviews
  • Annual audit compliance ratio.

10. Grievance Mechanism

Any stakeholder can report ethical sourcing concerns via:

All complaints will be documented, investigated, and resolved transparently without retaliation.

11. Policy Review & Updates

This policy will be reviewed at least annually and updated as required to remain in line with evolving legal requirements, international standards, and business practices.

Version: 01.2026

Prepared by: Koen Boogaerts – Director Supply Chain

Reviewed by: Alexandra Uskokovic – Chief Operating Officer

Next Review: January 2027