Annual Responsible Sourcing & Human Rights Report 2026

Annual Responsible Sourcing & Human Rights Report

Brilliant Jewelers / MJJ Inc.
Reporting Period: 2026  |  Date of Issue: June 2026

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1. Introduction and Commitment

Brilliant Jewelers / MJJ Inc. (hereinafter referred to as “the Company”) is a jewelry manufacturer and wholesaler with operations in New York, USA and Mérida, Mexico.

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 satisfies the annual public reporting requirements of COP/LGMS 3.1a, COP/LGMS 6.1g and COP/LGMS 7 / OECD Step 5, and covers activities undertaken during 2026.

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 setting out the Company’s commitments on human rights, responsible sourcing and ethical business conduct, publicly available on the Company’s website. The Company is an active member of the Responsible Jewellery Council (RJC).
• 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 (COP/LGMS 6)

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 both 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 assessment did not identify any confirmed adverse human rights impacts in the Company’s own operations. Existing controls were found to be sufficient to manage identified risks across all assessed topics, with certain items, in particular those relating to CAHRA sourcing and supply chain traceability, flagged for ongoing monitoring and addressed in Section 4 of this report.

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 (COP/LGMS 7)

4.1 Process Overview

Supply chain due diligence is conducted in accordance with the Company’s 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 risks) and Workstream B (material origin and CAHRA risk).

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 practices risk; and supply chain due diligence risk. CAHRA screening is carried out by comparing reported countries of origin against the Company’s CAHRA Risk Index.

4.2 Risk Assessment Outcomes

The 2026 supplier due diligence exercise is substantially underway but not yet complete. No labor practice risks and no AML risks have been identified across any supplier assessed to date.

For a subset of suppliers, follow-up is ongoing: some have not yet disclosed the identities of precious metal refiners in their supply chain, and others have not provided complete country-of-origin information for natural gemstones and/or laboratory-grown materials. These cases are classified accordingly, pending resolution, and the Company is actively pursuing the outstanding information. The supply chain due diligence process will be updated as responses are received.

4.3 CAHRA Identification and Enhanced Due Diligence

One supplier has been identified as sourcing natural colored gemstones from a conflict-affected and high-risk area (CAHRA). No confirmed adverse impacts have been identified in connection with this sourcing at this stage.

In accordance with the Company’s procedure and the OECD Guidance, enhanced due diligence has been initiated with this supplier, including a formal request for information on the specific mine(s) of origin and the circumstances of extraction and trade.

If the exercise reveals confirmed adverse impacts that cannot be mitigated to an acceptable level, the Company will take appropriate action up to and including disengagement from the supplier.

5. Legal Proceedings

No fines, judgements, penalties or non-monetary sanctions for failure to comply with applicable law in connection with matters covered by the RJC Code of Practices or the Laboratory Grown Materials Standard were incurred by the Company during the 2026 reporting period.

For queries regarding this report, please contact: Atul Kampani — [email protected]