California Transparency in Supply Chains Act Disclosure
About this document
The California Transparency in Supply Chains Act requires a description of practice. We have done what the statute requires — described our verification, audits, certification, accountability, and training procedures across five sections that mirror the five disclosure pillars of the Act — and then added two more. The first additional section comes before the procedural disclosures and describes the four categories of raw material we source. The second comes after, and describes the channels through which any party who suspects a violation may bring it to us.
The reason for these additions is that procedure without position is not informative. A reader of an anti-slavery statement that begins with the word "Verification" cannot tell what is being verified. We begin instead with a statement of what we source and from where. Once that is clear, the procedures that follow can be read in context.
The luxury jewelry industry has a longer history with supply chain transparency than many sectors, partly because the diamond industry was forced to confront the problem in the 1990s and partly because finished jewelry concentrates raw materials whose extraction is sometimes associated with serious labor abuses. We do not approach this disclosure as a marketing exercise. We approach it as a description of how we attempt, imperfectly, to do an industry that has historically been opaque and to do it well.
Before describing the procedures we follow to verify our supply chain, we should describe what we are sourcing in the first place. The four categories of raw materials below comprise the entirety of what enters a Since Love piece — rough natural diamonds, lab-grown diamonds, colored gemstones, and refined precious metals. Our position on each is set out plainly so that the procedures described in subsequent sections can be understood in context.
Natural Diamonds
We source rough and polished natural diamonds exclusively from suppliers who have provided Kimberley Process Certification Scheme (KPCS) documentation at the rough stage and who have demonstrated participation in the System of Warranties for the polished stage. Where origin tracking is available — such as through Tracr, GIA Origin, or supplier-specific country-of-origin programs — we obtain and retain that documentation as part of our chain-of-custody records.
Lab-Grown Diamonds
We source lab-grown diamonds from producers operating in the United States, India, and China who have demonstrated production through documented chemical vapor deposition (CVD) or high pressure high temperature (HPHT) processes. Lab-grown diamonds are not subject to the Kimberley Process by definition, but we apply equivalent supplier verification regarding labor practices, energy sourcing where claimed, and downstream cutting facility conditions.
Colored Gemstones
For sapphires, rubies, emeralds, and other colored gemstones, we work with a small set of suppliers who have provided documentation regarding mining or trading source country, and where applicable, alignment with frameworks such as the American Gem Trade Association (AGTA) Source Disclosure or the Responsible Jewellery Council (RJC) chain-of-custody standards. We do not knowingly source from regions subject to U.S. sanctions or where credible reports indicate forced labor in the gemstone supply chain.
Refined Recycled Gold & Platinum
Our gold and platinum is refined recycled metal sourced from refiners who have provided documentation of LBMA Responsible Gold Guidance compliance or equivalent due diligence frameworks. Refined recycled metal originates from a combination of post-industrial scrap, post-consumer jewelry, and electronic recovery streams; the use of refined recycled material substantially reduces the supply chain risk associated with newly mined precious metals while delivering the same metallurgical quality.
Before we engage any new supplier — whether for rough diamonds, polished stones, colored gemstones, refined metals, or finished components — we conduct a written supplier risk assessment that evaluates the supplier's business operations, sourcing geographies, contractual relationships with downstream miners, refiners, or traders, and the supplier's own due-diligence program. The objective of this verification is to assess and mitigate the risk that slavery, forced labor, child labor, or human trafficking exists at any point in the upstream chain that supplies us.
Supplier Risk Assessment Procedures
The following verification procedures are applied uniformly to all candidate suppliers prior to engagement. The procedures are equally applied to direct suppliers (those who sell to us) and to material upstream actors (mining, cutting, refining, manufacturing) where the direct supplier provides identifying information about its own sources.
- Geographic risk screening. We assess each candidate supplier's sourcing geographies against publicly available country-level risk indicators including the U.S. Department of Labor List of Goods Produced by Child Labor or Forced Labor, the U.S. Department of State Trafficking in Persons Report, and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Higher-risk geographies trigger additional verification before engagement.
- Sanctions screening. All candidate suppliers and their identified upstream sources are screened against the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) Specially Designated Nationals List, the European Union sanctions consolidated list, and the United Nations sanctions list. We do not engage with any party appearing on any of these lists.
- Documentation review. We require submission of the supplier's own modern slavery, forced labor, or human rights policy where applicable; the supplier's certifications under industry frameworks (Kimberley Process Certification, RJC certification, LBMA Responsible Gold Guidance, AGTA Source Disclosure); and recent third-party audit reports where the supplier has obtained any.
- Chain-of-custody assessment. For natural diamonds, we require that the supplier provide a chain-of-custody protocol that allows different sourcing channels to be tracked, separated, and managed. For colored gemstones, we require source-country documentation. For refined metals, we require the refiner's documentation regarding the proportion of recycled versus newly-mined input.
- Code of Conduct acknowledgment. Before any goods are ordered, the candidate supplier is required to review and acknowledge the Since Love Jewelry Supplier Code of Conduct in writing, which establishes the substantive labor, human rights, environmental, and anti-bribery standards applicable to all goods supplied to us.
Internal verification, not third-party verification. The verification procedures described in this section are conducted by our internal sourcing team. They are not independently verified by an outside third party. Independent verification of our overall due-diligence program is described in Section 7.
Verification of supplier policies and certifications at the engagement stage is necessary but not sufficient. We supplement engagement-stage verification with ongoing audits of our suppliers' actual practices — some announced, some unannounced, some on-site, some documentary, and where appropriate involving an independent third party. The audit program is designed to evaluate whether the supplier's contractual representations correspond to the supplier's day-to-day reality.
Audit Methods and Frequency
We use a tiered audit framework calibrated to the assessed risk level of each supplier and material category. Direct suppliers in higher-risk categories are audited more frequently and through a wider range of methods than direct suppliers in lower-risk categories.
- On-site audits. Periodic on-site visits to the facilities of our most material suppliers, conducted by members of the Since Love sourcing team and where appropriate accompanied by an independent third-party auditor. On-site audits include inspection of the production floor, review of personnel records and wage records, interviews with workers conducted privately and in their first language, and inspection of dormitory or living conditions where the supplier provides housing.
- Off-site audits. Documentary audits conducted remotely, including review of the supplier's submitted documentation against external records (sanctions lists, government registries, country-of-origin documentation), review of the supplier's compliance reports, and verification of the supplier's certifications with the issuing authority.
- Announced audits. Audits scheduled in advance with the supplier, allowing the supplier to prepare documentation and to make personnel available for interviews. Announced audits provide a thorough but observable view; they are most useful for documentation review and for relationship-building.
- Unannounced audits. Audits conducted without advance notice to the supplier, providing a view of the supplier's operations as they ordinarily occur. Unannounced audits are reserved for higher-risk suppliers, are coordinated with our independent third-party audit partners where applicable, and are conducted in compliance with applicable contractual rights of inspection.
- Third-party audits. Where a supplier holds an existing third-party audit certification — such as RJC certification, SA8000 certification, or an audit conducted under the Responsible Minerals Initiative — we obtain and review the audit report. Where no existing third-party audit is available and the assessed risk level warrants, we may commission an independent audit through firms specialized in supply-chain due diligence.
Audit frequency calibrated to risk. Tier-one direct suppliers in higher-risk categories are audited at least annually through a combination of the methods above. Tier-one direct suppliers in lower-risk categories are audited at least every two years. Upstream actors identified by our direct suppliers are audited or attestation-verified on a risk-weighted schedule. Findings from each audit cycle inform the audit plan for the following cycle.
Beyond ad-hoc verification at engagement and ongoing audit, every supplier engaged by Since Love Jewelry executes a written certification of compliance with our Supplier Code of Conduct. The certification is a binding contractual document, and it is renewed annually so that the supplier's representation always reflects current practice. The certification covers the substantive labor, human rights, environmental, and ethical sourcing standards that apply across our supply chain.
Supplier Code of Conduct & Annual Recertification
Each direct supplier is required to provide written certification covering, at minimum, the following substantive standards. The certification is not a unilateral declaration by the supplier; it is signed as part of the supply agreement and is contractually enforceable.
- Compliance with anti-slavery and anti-human-trafficking laws of the country in which the supplier operates and of any country into which the supplier exports goods to us. This includes, where applicable, the U.S. Tariff Act §307 prohibition on importation of goods produced by forced or convict labor, the UK Modern Slavery Act, the German Supply Chain Due Diligence Act (LkSG), and similar instruments.
- Prohibition of forced labor and child labor at all stages of the supplier's operations, including upstream sources. The supplier must certify that no goods supplied to us are produced in whole or in part by labor that is forced, indentured, bonded, or by labor performed by persons under the minimum legal age of employment in the supplier's country.
- Compliance with applicable wage, hour, and working-condition laws in each jurisdiction in which the supplier operates. The supplier must provide records, upon request, demonstrating that workers are paid at least the legally required minimum wage, that overtime is compensated as required by law, and that working hours do not exceed legally permitted maxima.
- Adherence to the Since Love Jewelry Supplier Code of Conduct in its current published form. The Code addresses, among other matters, freedom of association, non-discrimination, occupational health and safety, environmental compliance, anti-bribery and anti-corruption, and the supplier's obligation to extend equivalent standards to its own subcontractors and upstream sources.
- Continued chain-of-custody integrity. The supplier must certify that the goods delivered to Since Love Jewelry have followed the chain-of-custody protocol disclosed at engagement, that no comingling has occurred with goods of unknown or non-conforming origin, and that any change in upstream sourcing has been reported to us before goods originating from the new source are delivered.
Annual recertification. The certification is renewed annually as part of the supply contract renewal process. A supplier whose annual recertification reveals a material change in upstream sourcing is required to provide updated risk assessment documentation before continuing to supply us.
External standards are only as effective as the internal mechanisms that implement them. Since Love Jewelry maintains internal accountability standards and procedures that apply to our own employees and contractors regarding the supply-chain integrity expectations established by our policies and our Supplier Code of Conduct.
Accountability for Employees and Contractors
Our internal accountability framework consists of policies that apply to our own employees and contractors, escalation procedures for suspected non-compliance, and disciplinary measures up to and including termination of employment or termination of contract.
- Employee Code of Conduct. All Since Love Jewelry employees and contractors are required to comply with the Employee Code of Conduct, which incorporates the standards established by the Supplier Code of Conduct and extends additional standards regarding the manner in which our employees evaluate, engage, and oversee suppliers. Acknowledgment of the Employee Code of Conduct is a condition of employment.
- Conflict of interest disclosure. Employees with sourcing or supplier-management responsibilities are required to disclose any personal or financial relationship with a supplier or candidate supplier. Sourcing decisions involving disclosed conflicts are escalated to a separate decision-maker.
- Disciplinary measures for non-compliance. Failure of an employee to comply with the standards of the Employee Code of Conduct, including failure to escalate suspected supplier non-compliance through the procedures described in Section 8, may result in disciplinary measures up to and including termination of employment.
- Supplier corrective action and termination. Where a supplier is found to have violated the Supplier Code of Conduct, the response is calibrated to the severity of the violation and the supplier's response. Minor violations may result in a corrective action plan with defined milestones and follow-up audit. Material violations may result in suspension of the supplier relationship pending remediation. Findings of forced labor, child labor, or human trafficking result in immediate termination of the supplier relationship and reporting to applicable authorities.
- Documentation and recordkeeping. Records of supplier verification, audit findings, corrective action plans, and termination decisions are maintained for a minimum of seven years and are available for review by regulatory authorities, third-party auditors, and counsel.
Policies do not enforce themselves. Since Love Jewelry provides training to employees and management who have direct responsibility for supply chain decisions, and broader awareness training to employees whose work involves any contact with the supply chain. The training programs described below ensure that the policies set out in earlier sections are understood and applied in practice.
Training Programs for Employees and Management
Training is differentiated by role. Employees with direct responsibility for sourcing decisions receive the most extensive training; employees in adjacent functions receive awareness-level training; all employees and contractors receive baseline orientation regarding our anti-slavery and anti-human-trafficking standards.
- Sourcing-team training. Members of our sourcing team receive training upon hire and annually thereafter on the substantive law of human rights and supply chain due diligence (the U.S. Tariff Act §307, the UK Modern Slavery Act, the German LkSG, the EU Corporate Sustainability Due Diligence Directive), the operation of the Kimberley Process Certification Scheme and related industry frameworks, the conduct of supplier risk assessments and audits, and the recognition of indicators of forced labor and human trafficking.
- Management training. Senior management with budgetary or strategic authority over supply chain decisions receive briefings at least annually on emerging supply chain risks, regulatory developments, and the status of our supplier base against our risk assessment criteria.
- Customer-facing employee training. Employees in our boutique, customer service, and virtual consultation functions receive training on the substantive content of this Disclosure, the contents of our Supplier Code of Conduct, and the procedures by which a customer or third party may raise a concern about our supply chain. They are not expected to be supply chain specialists; they are expected to be able to receive a concern, document it accurately, and direct it to the appropriate internal channel.
- Indicator awareness. All training programs cover the indicators of potential forced labor and human trafficking that may be observed in supply chain interactions, including unexplained restrictions on worker movement or communication, evidence of debt bondage or document retention, abnormal worker turnover patterns, and discrepancies between supplier representations and observable conditions.
Internal due diligence is necessary; independent verification of that due diligence is what gives the program credibility outside the company. The fifth disclosure required by SB 657 covers internal accountability; this section covers a sixth area — not required by SB 657 but disclosed for completeness — in which an independent third party reviews and attests to the design and operation of our overall due-diligence program.
Third-Party Attestation of Due Diligence
We have committed to engaging a qualified third party to review the design and effectiveness of our supply-chain due-diligence program. The third-party review is broader than any individual supplier audit; it is a review of our entire program — the policies, the verification procedures, the audit methodology, the certification framework, the accountability standards, and the training curriculum.
The third-party review is conducted against established industry standards, including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the UN Guiding Principles on Business and Human Rights, and the relevant guidance from the Responsible Jewellery Council. Where deficiencies are identified, the reviewing party makes recommendations and we incorporate those recommendations into the next program cycle.
Status of third-party attestation. The first formal third-party attestation is scheduled for completion within twelve months of the Effective Date of this Disclosure. The reviewing party will be selected from firms specialized in supply-chain due-diligence assessment for the jewelry industry. Upon completion, a summary of the attestation findings will be incorporated into this Disclosure and the version number will be incremented accordingly. Until the first attestation is completed, this section describes our committed program rather than a completed third-party review.
A supply-chain due-diligence program that does not provide a credible channel for reporting concerns is incomplete. The channels below are available to any party — an employee, a contractor, a supplier worker, a customer, a non-governmental organization, an investigative journalist, or any other person — who has reason to believe that goods entering Since Love Jewelry's supply chain may be tainted by slavery, forced labor, child labor, human trafficking, or other serious human-rights violations.
If you have a concern, we want to hear it.
All reports received through these channels are investigated. Reports may be made anonymously, and we do not retaliate against any person who in good faith reports a suspected violation. Reports involving an immediate risk to life or safety should be made to local law enforcement or to the U.S. National Human Trafficking Hotline (1-888-373-7888) before or in addition to reporting to us.
Attn: Compliance Lead
30 N Gould St, Ste 6362
Sheridan, WY 82801
Investigation Procedure
Upon receipt of a report, the Compliance Lead conducts an initial assessment to determine the scope and severity of the concern. Reports involving suppliers known to be in our active supply chain are prioritized; reports involving entities not known to us are nonetheless investigated to determine whether the entity may be an upstream actor we are not yet aware of. Where the report concerns a supplier we engage with, we notify that supplier of the concern (without revealing the identity of an anonymous reporter), require an immediate response, and, where appropriate, conduct an unannounced audit per the procedures of Section 3. Findings are documented and, where corroborated, may result in supplier corrective action, suspension, or termination per Section 5.
Non-Retaliation
Since Love Jewelry does not retaliate against any person who in good faith reports a suspected violation through the channels above, whether the reporting person is an employee, a contractor, a supplier worker, a customer, or any other party. Retaliation against an employee or contractor for good-faith reporting is itself a violation of our Employee Code of Conduct and may result in disciplinary measures up to and including termination of employment. We undertake to maintain reporter anonymity to the maximum extent consistent with our obligation to investigate, and we will inform the reporting party (where contact information is provided) of the disposition of their report at the conclusion of the investigation.