Policies and Codes

Code of Ethics

Recognizing the vital importance of conducting its business subject to high ethical standards and in full compliance with all applicable laws and, even where not required by law, with integrity and honesty, Signet has adopted a Code of Ethics applicable to the Chairman, the independent Directors, the Chief Executive Officer, the Chief Financial Officer and other senior officers of Signet Jewelers Limited and its subsidiaries and affiliates.

The Company has also adopted a Code of Conduct that applies to directors, officers and employees of the Company. The Chairman, the Independent Directors, the Chief Executive Officer, the Chief Financial Officer and other senior officers of the Company that are subject to this Code of Ethics are also subject to the Code of Conduct.

Code of Conduct

This Code of Business Conduct and Ethics is designed to promote honest, ethical and lawful conduct by all employees, officers and directors of Signet Jewelers and all subsidiaries and entities controlled by it. The Code is intended to help employees, officers and directors understand the Company’s standards of ethical business practices and to stimulate awareness of ethical and legal issues that may be encountered in carrying out their responsibilities.

Supplier Code of Conduct

Signet Jewelers has the objective to operate as a profitable and responsible specialty jewelry retailer, delivering increasing value to our shareholders, while seeking to uphold our Social, Ethical and Environmental Principles and considering the interests of our other stakeholders: customers, employees, those with whom we do business, and society as a whole.

In seeking to achieve our objective we recognize that there are indirect impacts generated by our activities, in particular through our supply chain. We will seek to use our influence with those with whom we do business directly, in particular our agents and suppliers, to promote the achievement of our Social, Ethical and Environmental Principles. As a customer we believe we have an opportunity to seek to influence the social, ethical and environmental performance of our suppliers in a positive manner. In order to do so it is necessary that our suppliers, and in turn their suppliers, should understand Signet’s standards as set out in this Code. Therefore, we encourage suppliers to ensure that this Code is communicated throughout our supply chain.

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