NFR Innovation Inc. Sustainability Statement

January 2024

As a member of the Responsible Jewellery Council (RJC), NFR Innovation is committed to the implementation of the RJC Code of Practices (COP) standard. As such, we have developed a range of policies and procedures to ensure our ongoing compliance with its requirements.

We are also committed to developing and nurturing strong relationships with suppliers and other business partners to promote responsible business practices throughout the diamond supply chain. This includes taking steps to identify and, where applicable, mitigate negative impacts with a particular focus on addressing issues related to human rights, child labour and forced labour. We expect all of our suppliers to take part in this process and align with our principles for a responsible and sustainable jewellery supply chain.

To achieve this, we carry out due diligence on all of our diamond suppliers in alignment with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). This includes:

In 2023, we completed a comprehensive review of our supply chain by asking all of our tier 1 suppliers to share information about their internal labour practices and sources of supply for diamonds. The purpose of this exercise was to identify potential human rights risks in our supply chain and to map the geographical origin of the diamonds we source, helping us to identify diamonds that may have originated from higher-risk countries.

We found that the majority of our suppliers implemented robust employment practices, and we did not identify any serious risks with regard to actual or potential forced labour, child labour or other abuses that would negatively impact the well-being of employees. Many of our suppliers do not, however, have documented human rights policies, and we will be encouraging all of our suppliers to adopt formalised policies going forward.

With regard to the geographical origin of the diamonds in our supply chain, a small number of suppliers reported sourcing diamonds from countries that meet our definition of a CAHRA. We are in the process of following up with these suppliers to verify the origin of the actual diamonds purchased, and we will complete additional enhanced due diligence on these sources in alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as applicable.

The above is endorsed by Dylan Dix, Managing Director and Owner, NFR Innovation Inc.