Brilliant Earth Group Inc

a. Disclosure in lieu of reporting on a Current Report on Form 8-K.

None.

b. Insider Trading Arrangements and Policies

Adoption and Termination of Trading Arrangements

(b) During the three months ended December 31, 2023, the following directors and "officers" (as defined in Rule 16a-1(f) under the Exchange Act) of the Company adopted, modified orterminated "Rule 10b5-1 trading arrangements" and/or "non-Rule 10b5-1 trading arrangements" (each as defined in Item 408 of Regulation S-K).

On November 28, 2023, Jennifer Harris, a member of the Company’s Board of Directors, adopted a Rule 10b5-1 trading arrangement (the “Harris Sales Plan”) that is intended to satisfy the affirmative defense of Rule 10b5-1(c) of the Exchange Act and which provides for the sale of an indeterminate number of Class A common stock related to the future vesting of up to 37,940 restricted stock units. The Harris Sales Plan will remain in effect until the earliest of (1) November 15, 2024, (2) the date on which an aggregate of 37,940 shares of the Company’s Class A common stock have been sold, or (3) such time as the Harris Sales Plan is otherwise terminated or expires according to its terms.

On December 12, 2023, Just Rocks, Inc., a Delaware corporation which is jointly owned and controlled by Beth Gerstein, the Company’s Chief Executive Officer and a member of the Board of Directors, and Eric Grossberg, the Company’s Executive Chairman, terminated an existing Rule 10b5-1 trading arrangement (the “Original Just Rocks Sales Plan”) intended to satisfy the affirmative defense of Rule 10b5-1(c) and originally adopted on November 23, 2022 and providing for the sale of up to 4,700,000 shares of the Company’s Class A common stock. Prior to its termination, no shares of Class A common stock were sold under the Original Just Rocks Sales Plan. On December 12, 2023, Just Rocks adopted a new Rule 10b5-1 trading arrangement (the “Just Rocks Sales Plan”) that is intended to satisfy the affirmative defense of Rule 10b5-1(c) of the Exchange Act and which provides for the sale of up to 700,000 shares of the Company’s Class A common stock. The Just Rocks Sales Plan will remain in effect until the earliest of (1) November 15, 2024, (2) the date on which an aggregate of 700,000 shares of the Company’s Class A common stock have been sold under the Just Rocks Sales Plan, or (3) such time as the Just Rocks Sales Plan is otherwise terminated or expires according to its terms.