Supply Chain Policy

George Pragnell Limited

25th May 2023

1.This policy confirms George Pragnell Limited’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.

2. George Pragnell Limited is a member of the Responsible Jewellery Council (RJC). As such, we commit to proving, through independent third-party verification, that we:

3. We also commit to using our influence to prevent abuses by others. We carry out regular due diligence on our supply chain to confirm the statements you have made, including but not limited to, checking invoices etc to ensure compliance with the Kimberley Process and WDC System of Warranties via Know Your Counterparty. Concerns regarding our supply chain can be raised by contacting Tom Crookenden at [email protected].

4. Regarding serious abuses associated with the extraction, transport or trade of minerals and precious metals: We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

5. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph 4 or are sourcing from, or linked to, any party committing these abuses.

6. Regarding direct or indirect support to non-state armed groups: We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds or precious metals from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally: a. control mine sites, transportation routes, points where diamonds or precious metals are traded and upstream actors in the supply chain; or b. tax or extort money, or diamond or precious metals at mine sites, along transportation routes or at points where diamonds or precious metals are traded, or from intermediaries, export companies or international traders.

7. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.

8. Regarding public or private security forces: We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4, or that act illegally as described in paragraph 6.

9. Regarding bribery and fraudulent misrepresentation of the origin of minerals or precious metals: We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of minerals or precious metals, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of minerals and precious metals.

10. Regarding money laundering: We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of minerals or precious metals.

Charlie Pragnell

Managing Director