Annual Responsible Sourcing & Human Rights Report

Date:

Approved by:

1. Introduction and Commitment

Spinelli Kilcollin (hereinafter referred to as “the Company”) is a luxury jewelry company based in Los Angeles, CA, and a member of the Responsible Jewelry Council (RJC). Details of our RJC membership can be found here: https://www.responsiblejewellery.com/member/spinelli-kilcollin/

The Company is committed to conducting its business responsibly, respecting human rights across its own operations and supply chain, and ensuring that the materials it sources do not contribute to conflict, human rights abuses or other adverse social impacts. These commitments are set out in the Company’s Responsible Business Practices Policy, which has been endorsed by senior management and is publicly available.

This report summarizes the steps we took in 2026 to a) assess labor practices and human rights risks in our own operations and supply chain and b) map the geographical origin of our jewelry materials to understand actual or potential upstream risks at the point of mining and production. This due diligence was conducted in accordance with the requirements of the RJC Code of Practices (COP) Standard.

2. Management Systems

The following management system elements are maintained to support the Company’s human rights and supply chain due diligence obligations:

• A Responsible Business Practices Policy: [insert link to your policy once published] setting out the Company’s commitments on human rights, responsible sourcing and ethical business conduct, publicly available on the Company’s website.

• Defined roles and responsibilities: for executive oversight and policy commitments, due diligence processes and risk tools, supplier engagement and corrective action follow-up.

• A Human Rights & Supply Chain Due Diligence Procedure: documenting the step-by-step approach to identifying, assessing and responding to risks.

• Risk assessment tools: a Human Rights Risk Assessment for internal operations and a Supplier Risk Assessment Tool for tier 1 suppliers.

• A Supplier Questionnaire: used to collect human rights and material origin information from tier 1 suppliers.

• An accessible and confidential Grievance Mechanism: for employees, contractors, suppliers and external stakeholders. See our Responsible Business Practices Policy for further details.

• Staff training: on human rights, responsible sourcing and grievance procedures.

3. Internal Human Rights Due Diligence

3.1 Process

An annual internal human rights due diligence (HRDD) assessment is conducted in accordance with the Company’s human rights due diligence procedure, applying the UN Guiding Principles on Business and Human Rights (UNGPs) and ILO core conventions as the baseline framework. The assessment covers all operational sites and follows a four-step process: (1) information gathering from HR, health and safety, grievance and workplace observation sources; (2) risk identification and rating using the Human Rights Risk Assessment Tool, covering forced labor, child labor, discrimination, freedom of association, working conditions, community rights and grievance mechanisms; (3) response and remediation; and (4) internal and external reporting.

3.2 Findings

The 2026 human rights risk assessment did not identify any adverse human rights impacts in our own operations. Existing controls were found to be sufficient to manage identified risks across all assessed topics.

No human rights grievances were received from employees or external stakeholders during the reporting period. The Company’s grievance mechanism remains active and accessible to all relevant stakeholders.

4. Supply Chain Due Diligence

4.1 Process Overview

Supply chain due diligence is conducted in accordance with the Company’s Human Rights & Supply Chain Due Diligence Procedure and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance).

The process runs across two parallel workstreams: Workstream A – supplier level human rights risk and Workstream B - material origin and risks associated with the sourcing of materials from Conflict-Affected and High-Risk Areas (CAHRA’s).

The Company’s Supplier Questionnaire is distributed to all tier 1 direct suppliers of in-scope jewelry materials. Responses are reviewed against OECD red flag indicators and entered into the Supplier Risk Assessment Tool, generating ratings across three dimensions: AML and financial crime risk; labor practice risks; and supply chain due diligence risks. CAHRA screening is carried out by comparing reported countries of origin against the Company’s CAHRA Risk Index.

4.2 Risk Assessment Outcomes

Based on the information provided by our suppliers, the 2026 supplier due diligence exercise produced the following findings:

1. None of the Company’s direct suppliers were found to be associated with any adverse labor practice and/or other human rights risks or impacts requiring mitigation.

2. The Company was able to identify the countries of mining origin for all natural diamonds and natural precious-colored gemstones (rubies, sapphires and emeralds) it sources. None of these countries met the definition of a Conflict-Affected and High-Risk Area (CAHRA).

3. The Company was able to identify the countries where all of its Lab-Grown diamonds are produced. None of these countries met the definition of a Conflict-Affected and High-Risk Area (CAHRA).

4. The Company was also able to identify the precious metal refiners used for almost all of the gold, silver and platinum group metals it sources. Information on refiner identity is only outstanding for one direct supplier, and due diligence with this supplier is ongoing. None of the identified refiners were found to operate in countries meeting the definition of a Conflict-Affected and High-Risk Area (CAHRA).

5. Review and Reporting

The Company is committed to publishing an updated version of this report annually, setting out the outcomes of its most recent human rights and supply chain due diligence, any risks identified, and the actions taken to prevent, mitigate or remediate them. Each updated report will be made publicly available on the Company’s website, in line with the reporting requirements of the RJC Code of Practices (COP) Standard.

For queries regarding this report, please contact: [add contact details]