Responsible Supply Chain Policy

Policy owner: General Manager / Senior Management

Effective date: 11 August 2026

Review cycle: At least annually, and when material risks or RJC requirements change

1. Purpose

Australian Opal Cutters Pty Ltd is committed to sourcing opals, gemstones, precious metals, diamonds and jewellery-related materials responsibly, lawfully and ethically. We apply risk-based due diligence appropriate to the nature, scale and impact of our business and seek to avoid contributing to conflict, serious human rights abuses, corruption, money laundering or terrorist financing.

2. Our commitments

We communicate this policy to relevant suppliers and expect suppliers and contractors to support responsible sourcing and provide reasonable information needed for due diligence.

We seek to understand our supply chains and the origin and circumstances of materials where risk warrants further investigation, with particular attention to conflict-affected and high-risk areas (CAHRAs).

We use reasonable, risk-based checks to confirm that suppliers are legitimate businesses and are not known to be implicated in serious human rights abuses, fraud, money laundering, terrorist financing or applicable sanctions.

We will not knowingly source materials where there is a material risk that the supply supports torture, cruel or degrading treatment, forced or compulsory labour, the worst forms of child labour, serious human rights violations, unlawful armed groups or other serious abuses described in Annex II of the OECD Due Diligence Guidance.

We comply with applicable laws and relevant industry requirements, including Kimberley Process and World Diamond Council requirements where applicable to diamonds.

We keep appropriate records of supplier due diligence, risk assessments, decisions and corrective actions.

3. Risk identification and response

Where a supply-chain risk or red flag is identified, we will investigate it proportionately. Depending on the severity and our ability to influence the supplier, we may seek further information, require corrective action, temporarily suspend purchasing, or disengage from the supplier. We will not ignore credible evidence of serious abuse.

4. Reporting concerns

Employees, suppliers, customers and other stakeholders may raise concerns about sourcing practices with Australian Opal Cutters management. Concerns will be considered fairly, documented where appropriate and handled without retaliation against a person who raises a genuine concern in good faith.

5. Responsibility and review

Senior management is responsible for endorsing this policy and ensuring appropriate procedures, records and responsibilities are maintained. The policy and our supply-chain due diligence approach will be reviewed periodically and improved when risks, laws, business activities or RJC requirements change.

Prepared with reference to the Responsible Jewellery Council (RJC) Code of Practices 2024, including COP 2 (Policy and Management Systems), COP 6 (Human Rights), COP 7 (Due Diligence for Responsible Sourcing) and related ethical business requirements. This policy supports RJC alignment but does not by itself establish or guarantee RJC certification.

Australian Opal Cutters Pty Ltd | Public Policy