Brilliant Earth Supplier Code of Conduct

Social and Environmental Requirements

Human Rights and Responsible Labor Practices

Supplier shall at all times respect the fundamental human rights of all workers, (including full- time, part-time or contracted) business partners and customers and observe the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, and the ILO Conventions on Labor Rights and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas in ways appropriate to their size and circumstances. Where relevant, Suppliers shall adhere to the guidelines outlined in the Responsible Jewellery Council Code of Practices. Suppliers shall use fair and responsible labor practices and treat all employees with full respect and dignity.

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals: Supplier, as applicable, is expected to adhere to all standards outlined in Annex II, Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict- Affected and High-Risk Areas. This includes the prohibition of:

• any forms of torture, cruel, inhuman and degrading treatment; any forms of forced or compulsory labor, which means work or service which is exacted from any person under the menace of penalty, and for which said person has not offered himself voluntarily; the worst forms of child labor;

• other gross human rights violations and abuses such as widespread sexual violence;

• war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

Child and Young Labor: Supplier shall not engage in the use of child labor as defined in ILO Convention 138 and the worst forms of child labor as defined in ILO Convention 182. Supplier shall ensure any juvenile (those between the minimum age and 18 years old) are not working in hazardous conditions or night work and comply with applicable laws. Additionally, Supplier shall have a child labor remediation policy and procedure promoting the protection of potential child workers.

Forced Labor: Supplier shall not engage in any forms of forced labor as defined in ILO Conventions 29 and 105, including trafficking in persons, bonded, indentured or involuntary prison labor. Neither Supplier nor any company supplying labor to Supplier shall withhold any part of a worker’s salary, benefits, property or documents (e.g., identification cards or passports) in an effort to force workers to continue working for Supplier. Workers shall be provided with a written and understandable (in a language understood by the employee) labor contract. If recruitment agencies must be utilized, Supplier shall monitor relationships for risks of human trafficking. Additionally, Supplier shall have a forced labor remediation policy and procedure promoting the protection of potential forced workers.

Foreign or Migrant Workers: Supplier agrees to assure that foreign or migrant workers will be employed in full compliance with applicable labor and immigration laws.

Harassment and Abuse: Supplier shall treat its workers with respect and dignity. Supplier shall not tolerate or engage in any form of corporal punishment or degrading treatment, sexual or physical harassment, mental, physical or verbal abuse, coercion or intimidation, or threats to management and staff, their family, or colleagues. Supplier shall clearly communicate disciplinary process, and related standards, and apply them equally to all management and staff.

No Support of Non-State Armed Groups: Supplier shall not provide support, directly or indirectly, to non-state armed groups, through activities related to the extraction, transport, trade, handling or export of minerals. Supplier shall not provide support, directly or indirectly to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain, or who illegally tax or extort money or minerals at point of access to mine sites, along transportation routes, or at points where minerals are traded, or illegally tax or extort intermediaries, export companies or international traders.

Working hours: Workers shall not be required to work more than 48 hours regular work and 12 hours additional overtime to total 60 hours per week, except in extraordinary business circumstances with their voluntary non-induced consent. Workers shall be entitled to at least one day of rest following six consecutive days worked. In all circumstances, Suppliers shall comply with all applicable laws related to working hours and holidays.

Fair wages and benefits: Supplier shall pay all workers a fair, equal wage based on the higher of either the applicable legal minimum wage, or the prevailing industry standards. Supplier should promote a living wage to meet basic needs and some discretionary income. Payment to worker shall be on a regular frequency and pre-determined basis as defined by local regulations and will accompany a wage slip which clearly details wage rates, benefits and deductions where applicable. Suggested frequency where no local regulations exist is monthly payment. Workers shall be compensated for overtime hours according to applicable legal requirements.

Discrimination: Supplier shall treat workers or prospective employees equally and fairly and not subject to discrimination or harassment based on race, sex, color, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, political opinion, maternity or any other status protected by applicable law.

Health & Safety: Supplier shall provide safe and healthy working conditions for workers in accordance with applicable laws, such as building and fire codes, and other relevant industry standards. This includes, but is not limited to, providing a safe and healthy workplace and on- site housing (if applicable); establishing a process to assess and minimize workplace hazards; offering trainings, personal protective equipment, potable water, access to sanitary facilities that are gender specific where relevant, access to medical facilities, and emergency response equipment; maintaining an emergency response plan; and fulfilling other criteria set forth in International Labour Organization (ILO) Occupational Safety and Health Convention 155 at no cost to the employee. Suppliers shall have a process in place for workers to report safety incidents and accidents, and investigate to determine root causes and necessary corrective actions to prevent reoccurrence.

Security: Supplier shall take measures to ensure the safety and security of its workers, contractors and visitors. This includes assessing security risks and implementing measures to protect against product theft, intellectual property theft or loss of employee or customer data during manufacturing and transport of goods.

Freedom of Association and Collective Bargaining: Suppliers shall not prevent workers from freedom of association or interfere with, penalize or retaliate against employees who lawfully associate and collectively bargain. Where laws prohibit these freedoms, Suppliers shall support parallel means for independent and free association and bargaining such as worker representatives and worker welfare committees.

Grievance Mechanism: Suppliers shall allow workers acting individually or with others to submit a grievance with the ability to raise concerns confidentially (and/or anonymously) without suffering any penalty or retaliation and shall have a process to investigate and document all grievances appropriately.

Employment Records: Suppliers shall maintain accurate employment, payroll and production records for employees and allow access by Brilliant Earth or its designated auditor upon request.

Employment Conditions and Contracts: Supplier shall establish in writing the terms and conditions of their employees’ agreements and work contracts in accordance with applicable laws and regulations. Agreements and work contracts must be available in a language understandable by the employee or worker.

Human Rights Commitment: Suppliers shall have a commitment to respect human rights which is endorsed by senior management and communicated to all employees.

Audit: Suppliers shall fully cooperate with any audit, and not withhold or misrepresent any information from auditors. Brilliant Earth or its designated third party to audit shall be granted unfettered access to the Supplier’s facilities, books and records, and employees for the purpose of interviewing them.

Community Development

Supplier shall make an effort to support the development of local communities in which it operates.

• Indigenous Peoples: Supplier shall recognize and respect the rights of all indigenous peoples, and recognize and respect the value of their traditional, cultural and social heritage.

• Community Engagement: Where applicable to their supply chain, Supplier should facilitate, support, and/or participate in authentic and constructive engagement with local communities from which diamonds, gemstones, precious metals, and jewelry are refined or manufactured, and where possible, where diamonds, gemstones and/or precious metals are sourced.

• Community Support and Development: Where possible, and as appropriate to the scale of the Supplier, Supplier should facilitate and support community development efforts and local community priorities including education, health care, women’s empowerment, economic development and preserving natural resources. Where practical, businesses should avoid filling roles that are the responsibility of others, especially governments, and instead take a partnership or collaborative approach to community development.

Environmental Practices

Supplier shall comply with all relevant environmental regulations and seek to ensure the efficiency of their business operations in terms of consumption of natural resources including, but not limited to water, waste and energy.

• Assess and Mitigate Environmental Impacts: Supplier should take proactive measures to identify and mitigate material environmental risks and significant impacts of their operations.

• Environmental Management: Supplier shall manage its environmental footprint by using natural resources responsibly including reducing energy consumption, water use, waste and emissions. Where applicable, and as appropriate to the scale of the Supplier, Supplier should implement an environmental management system that regularly reviews controls to minimize environmental impacts and measure performance.