Responsible Sourcing

OUR COMMITMENT TO RESPONSIBLE SOURCING

Jewelry is personal. It is an expression of love, of joy, a symbol of our most meaningful moments in life. Jewelry touches the lives of millions of people around the world.

We have taken a leadership role in the development of harmonized industry guidance and standards for many years to ensure that our jewelry is made with integrity, and sourced from a supply chain that is held to a higher standard. As part of our Core Values we are always looking for ways to continuously improve and to do the right thing even when no one is looking. While the jewelry industry is associated with many celebratory moments, it is also connected to a complex supply chain filled with concerns about the origin of many materials – such as gold and diamonds. The industry as a whole has taken steps to improve the transparency and integrity of the jewelry supply chain.

OUR RESPONSIBLE SOURCING POLICY

As the world’s largest retailer of diamond jewelry, we know we must lead by example. Our dedication to product integrity is at the core of how we do business. When a customer purchases jewelry from a Signet brand store, they assume that our jewelry has been sourced responsibly. When a customer asks a question about our sourcing practices, our Team Members have the information available to answer them. We are not only dedicated to our own supply chain, but are leading the efforts to foster increasingly transparent and responsible jewelry supply chains around the world.

Signet Jewelers and our North American and UK operations (Signet) are fully committed to the responsible sourcing of our products and the respect of human rights, and we expect the same from our suppliers around the world. We continually strive to assure our customers, employees, investors and other stakeholders that our supply chain avoids action that may directly or indirectly finance armed conflict and serious human rights violations around the world including the Democratic Republic of Congo and its adjoining countries.

Ensuring the integrity of the supply chain is an issue that affects the entire jewelry industry. Signet therefore believes it is often best to address the challenges through dedicated industry organizations. Signet is a Founding and Certified member of the Responsible Jewellery Council (RJC), an organization that is committed to promoting responsible ethical, human rights, social and environmental practices throughout the jewelry supply chain. As a Founding Member and active participant, we fully support the RJC’s membership Code of Practices and Chain of Custody standards. We are also members of Jewelers of America (JA) and the Jewelers Vigilance Committee (JVC). Please see our CSR Report for a detailed list.

Signet is also active in cross-sector coalitions and working groups that reach beyond the jewelry industry to ensure that companies respect human rights and avoid contributing to armed conflict. Signet supports the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the London Bullion Market Association (LBMA) Responsible Metals Standards, and the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502, relating to our supplies of gold.

Throughout our supply chain, whether we are sourcing directly from mining companies, from the open market or buying from jewelry manufacturers, we have a rigorous due diligence process. Our verification process includes internal and third-party audits, as well as third-party verification such as RJC certification.

Our Supplier Code of Conduct is included in our vendor-buyer agreement and sets out the Company’s expectations of suppliers to align with our responsible sourcing practices.

THE SIGNET RESPONSIBLE SOURCING PROTOCOLS (SRSPs)

We believe that a responsible, conflict-free supply chain is fundamental to the reputation of the jewelry industry as a whole, and are committed to our efforts to advance responsible sourcing throughout the supply chain.

We have taken an industry-leading role by establishing our Signet Responsible Sourcing Protocols for Gold, for Tungsten, Tantalum, and Tin (3Ts) which became company policy for all suppliers in 2013. We expanded the SRSPs in 2016 when we introduced our SRSP for Diamonds and again in 2017 when we introduced the SRSP for Silver and Platinum Group Metals. By closely collaborating with key partners throughout our supply chain, we designed flexible and adaptable systems that raise the standard for responsibly sourcing raw materials in the jewelry supply chain. The Protocols are aligned with the Organisation for Economic Co-operation and Development (OECD), Due Diligence Guidance for Responsible Supply Chains and industry standards, and verifiable by third-party audit.

The Signet Responsible Sourcing Protocols for Gold and 3Ts

Based on international standards and guidance, Signet conducted extensive research and consulted with many of our suppliers to develop the Signet Responsible Sourcing Protocol (“SRSP”). The purpose of the SRSP is to outline practical procedures that will reasonably ensure any gold, tin, tantalum, or tungsten, defined as “conflict minerals” by OECD and the SEC, in products supplied to Signet are verified as conflict-free (see SRSP for conflict-free gold and SRSP for conflict-free 3Ts). The SRSP was established as company policy effective 1/1/2013 and requires all suppliers to report annually that supplies to Signet are compliant with the SRSPs. These SRSP reports may be subject to third party audit: to download a full copy of the Signet SRSP Audit Guidance click here.

The Signet Responsible Sourcing Protocol for Diamonds

In 2016 Signet introduced the Signet Responsible Sourcing Protocol for diamonds (D-SRSP) alongside existing SRSPs for gold and 3Ts. The objective of the D-SRSP is to ensure that all Signet diamonds are responsibly sourced. The D-SRSP is based on the OECD Due Diligence Guidance for Responsible Supply Chains, and builds on the Kimberley Process and the World Diamond Council System of Warranties. Signet believes that a responsible supply chain is fundamental to the reputation of the jewelry industry, and we have been active in the development of harmonized industry guidance and standards. We believe in the protection of human rights in the jewelry supply chain, and the D-SRSP references the 2011 UN Guiding Principles on Business & Human Rights.

From 2017, all Signet diamond and diamond jewelry suppliers must have the appropriate policies, systems and processes in place to evidence compliance with the D-SRSP. They will be asked to report compliance with all SRSPs (gold, 3Ts and diamonds) from September 2017. To download a full copy of the D-SRSP click here.

 D-SRSP Named Supply Chain Project of the Year

On September 29, 2016 the UK-based Retail Week trade magazine awarded Signet Jewelers the International Supply Chain Project of the Year.

The Hermes Retail Week Supply Chain Awards 2016 recognizes retailers, suppliers or individuals who are re-inventing all aspects of modern retail supply chains, from delivery and logistics, to technology and talent development.

The honor was given for the creation and launch of the Signet Responsible Sourcing Protocol for Diamonds (D-SRSP), which provides increased transparency and further commitment to the continuous improvement in the integrity of the global diamond supply chain.

The Signet Responsible Sourcing Protocol for Silver and Platinum Group Metals (PGMs)

In 2017 Signet is introducing the Signet Responsible Sourcing Protocol for Silver and Platinum Group metals (“PGMs”, namely platinum, palladium, rhodium, ruthenium, osmium and iridium) alongside existing SRSPs for gold, 3Ts and diamonds. The objective of the SRSP for Silver and PGMs is to ensure that all Signet precious metals are responsibly sourced. The SRSP for Silver and PGMs is consistent with the existing SRSP for gold.

During 2017 all Signet suppliers of silver and PGMs are expected to undertake due diligence on their supply chains and ensure they have the appropriate policies, systems and processes in place to evidence compliance by 2018, by sourcing though accredited refineries and other suppliers defined in the SRSP. To download a full copy of the SRSP for Silver and PGMs click here.

The Signet Responsible Sourcing Protocol for Colored Gemstones

As part of our commitment to ensure the integrity of all the primary metals and minerals in our supply chain, Signet is currently working to develop SRSP for colored gemstones. Based on the successful model of our previous SRSPs, we are working collaboratively with our industry partners and other key stakeholders in the jewelry supply chain and aim to launch this new protocol by 2020.

ADDITIONAL RESPONSIBLE SOURCING INITIATIVES

MOBILE SCHOOLS IN THE DEMOCRATIC REPUBLIC OF CONGO (DRC)

Schools are often far away from artisanal mining communities, so children miss out on formal education and may work in the mining fields. Through its “Sending Schools to Kids” initiative, the Diamond Development Initiative (DDI), an international non-profit organization focusing on the political, social and economic challenges facing the artisanal diamond mining sector, is sending schools to them, taking children from the mine to the classroom. DDI provides mobile facilities, portable materials and teachers to remote mining communities where education is not available. In 2016, Signet partnered with DDI to fund two mobile schools for mining communities in the Kasai Occidental province of the DRC. These schools provide customized education to 50 children who might otherwise be working in the mining fields. Students are provided with uniforms, school materials and daily meals.

RESPONSIBLE ARTISANAL GOLD SOLUTIONS FORUM (RAGSF)

In 2015, Signet contributed funding to the Responsible Artisanal Gold Solutions Forum (RAGSF), a multistakeholder coalition including supply chain participants in the jewelry and electronics industries (refiners, manufacturers, distributors and retailers), governments, civil society, the OECD and industry organizations such as LBMA and RJC. RAGSF seeks to learn about, and address the critical barriers to the production and trade of artisanal gold from the Great Lakes Region in the DRC and establish transferable best practice for the artisanal industry internationally. RAGSF is under discussion with pilot sourcing projects to test and learn about responsible artisanal gold supply chains in the DRC, including adapting and implementing due diligence guidance. Signet is committed to helping ensure that gold from these projects can be part of Signet’s supply chain in the future.


DIAMONDS DO GOOD / DIAMOND EMPOWERMENT FUND
The Diamonds Do Good Initiative was created by the Diamond Empowerment Fund, of which Signet has been a long-time member and supporter. Signet supports the Diamond Empowerment Fund/Diamonds Do Good mission because it focuses on how diamonds enrich the lives of people in the communities all along the supply chain. In 2016, Signet implemented a program to raise awareness of the initiative by displaying the Diamonds Do Good seal in US stores as well as promoting the initiative via our Kay,Jared and Zales websites.

COMPLIANCE WITH NATIONAL/INTERNATIONAL LEGISLATION

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act

Signet Jewelers Limited filed a “DRC Conflict Free” Conflict Minerals Report (“CMR”) with the U.S. Securities and Exchange Commission (“SEC”) as part of its Specialized Disclosure Report (“Form SD”) filed on May 31, 2017.

Please follow this hyperlink to see Signet’s Form SD and the attached CMR.

In accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), Signet filed a Form SD and an accompanying, independently audited CMR stating that Signet has determined that its jewelry and gift products containing gold, tin, tungsten, or tantalum (“3Ts”) are “DRC conflict-free” as defined by Section 1502 of the Dodd-Frank Act (which added a new Section 13(p) to the Securities Exchange Act of 1934) and Rule 13p-1 and Form SD promulgated by the SEC under this statute.

The CMR states that through the exercise of due diligence, Signet has identified sources of gold and 3Ts in its supply chain which originated, or may have originated, in the Democratic Republic of the Congo and neighboring countries, and has determined that all of these sources qualify as DRC conflict-free for purposes of Section 1502 of the Dodd-Frank Act, the SEC’s rules thereunder and internationally recognized industry guidance and standards.

Signet believes that a responsible, conflict-free supply chain is fundamental to the reputation of the jewelry industry, not just to Signet and is, therefore, committed to continuing our longstanding efforts to advance responsible sourcing throughout the jewelry industry supply chain.

California Transparency in Supply Chains Act of 2010

Signet Jewelers Ltd expects its business suppliers to comply with the applicable laws and regulations of the United States and those of the respective country of manufacture or exportation. Per the California Transparency in Supply Chains Act of 2010 (SB 657), below consumers will find a disclosure of the efforts Signet is taking to address slavery and human trafficking in its direct supply chain.

Engagement in verification of product supply chains to evaluate and address risks of human trafficking and slavery:

Signet conducts risk assessments of its significant suppliers in its effort to evaluate and address risks of human trafficking and slavery. These risk assessments are conducted by independent external third parties. If potential risks are identified, a course of action is determined to best address them.

Auditing of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains:

Many of Signet’s largest suppliers are certified members of the Responsible Jewellery Council (RJC), as Signet encourages all its suppliers to be. Suppliers that are certified RJC members receive scheduled audits by independent third party firms as part of a rigorous and fulsome RJC Code of Practices certification process. Significant suppliers that are not certified members of RJC are audited by independent third party firms that conduct audits that, while announced, are only announced with sufficient advance notice to permit access. In addition, for all suppliers, Purchase Order Terms and Conditions include statements regarding compliance with all laws. By agreeing to these terms and conditions, our suppliers confirm their understanding and agreement to these compliance standards.

Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business:

Signet suppliers are asked to agree to adhere to the respective laws regarding human trafficking and slavery.

Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking:

Signet expects all employees to adhere to and comply with all laws which would include such laws related to human trafficking and slavery. Management is responsible for ensuring that all employees are aware of and adhere to a code of conduct which includes compliance with all laws. Any known incidences where an employee does not do so, appropriate disciplinary action is taken.

Training on human trafficking and slavery for company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products:

All Signet employees responsible for supply chain-related decisions and product purchasing are required to complete training and assessment programs that are geared to enhance their knowledge of various compliance matters. These programs will be supplemented in 2012 to include identifying and addressing human trafficking and slavery in Signet direct supply chains.

Modern Slavery Act 2015 (UK)

Signet Trading Ltd expects its business suppliers to comply with the applicable laws and regulations of the United Kingdom and those of the respective country of manufacture or exportation. In accordance with the requirements of the Modern Slavery Act 2015, consumers will find below details of the steps Signet is taking to address slavery and human trafficking in its direct supply chain.

Engagement in verification of product supply chains to evaluate and address risks of human trafficking and slavery:

Signet conducts risk assessments of its significant suppliers in its effort to evaluate and address risks of human trafficking and slavery. These risk assessments are conducted by independent external third parties. If potential risks are identified, a course of action is determined to best address them.

Auditing of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains:

Many of Signet’s largest suppliers are certified members of the Responsible Jewellery Council (RJC), as Signet encourages all its suppliers to be. Suppliers that are certified RJC members receive scheduled audits by independent third party firms as part of a rigorous and fulsome RJC Code of Practices certification process. Significant suppliers that are not certified members of RJC are audited by independent third party firms who conduct audits that, while announced, are only announced with sufficient advance notice to permit access. In addition, for all suppliers, purchase order terms and conditions include statements regarding compliance with all laws. By agreeing to these terms and conditions, our suppliers confirm their understanding and agreement to these compliance standards.

Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business:

Signet suppliers are asked to agree to adhere to the respective laws regarding human trafficking and slavery.

Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking:

Signet expects all employees to adhere to and comply with all laws which would include such laws related to human trafficking and slavery. Management is responsible for ensuring that all employees are aware of and adhere to a code of conduct which includes compliance with all laws. Any known incidences where an employee does not do so, appropriate disciplinary action is taken.

Training on human trafficking and slavery for company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products:

All Signet employees responsible for supply chain-related decisions and product purchasing are required to complete training and assessment programs that are geared to enhance their knowledge of various compliance matters. These programs include identifying and addressing human trafficking and slavery in Signet direct supply chains.

European Union (EU) Conflict Minerals Legislation

In May 2017, the EU passed “conflict minerals legislation” to ensure that minerals and metals exported to the EU do not contribute to conflict, that smelters and refiners in the EU and globally do not use raw materials from sources which may contribute to conflict, and that mine workers are not abused.

The law also supports the development of local communities. The law requires EU companies to ensure they import these minerals and metals from responsible sources only.

The law will be enforced from January 1, 2021 and Signet is confident that our already robust processes and procedures will ensure compliance with this legislation.

SUPPLIER REQUIREMENTS

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 Supplier Code of Conduct (“Code”). Therefore, we encourage suppliers to ensure that this Code is communicated throughout our supply chain

To read more about our Supplier Code of Conduct please click here: http://www.signetjewelers.com/corporate-responsibility/supplier-code-of-conduct/default.aspx

Supplier Compliance with the Signet Responsible Sourcing Protocols

Beginning in 2013, Signet produced global guidance for all suppliers of gold, tin, tungsten and tantalum (“3TG”). Compliance with the SRSPs for gold and 3Ts are a required legal imperative related to Signet’s SEC reporting. (See The Signet Responsible Sourcing Protocols section above)

Similarly, Signet has developed an SRSP for diamonds (*D-SRSP), which is being implemented in 2016 in accordance with OECD guidance, which applies to all minerals, and also for Silver and Platinum Group Metals (See The Signet Responsible Sourcing Protocols section above)

The cornerstone of compliance with the SRSPs is a requirement that suppliers report to Signet annually that they are sourcing materials supplied to Signet responsibly and in conformance with the requirements of all of the relevant SRSPs in their supply chains.

Supplier RJC Membership Requirement

Signet is a founding and certified member of the Responsible Jewellery Council (“RJC”), which is the global standard for responsible practices in the jewelry industry. Companies certified under the RJC’s Code of Practices are demonstrating their commitment to the reputation of the jewelry industry, which is fundamental to maintaining consumer confidence.

As a result, and aligned with Signet’s dedication to the continuous improvement in the integrity of global jewelry supply chain, beginning January 31, 2017, Signet has made RJC membership and certification a requirement for all suppliers.

As a clear benefit to our suppliers, RJC certification with the Signet Responsible Sourcing Protocols (“SRSPs”) as “Provenance Claims” gives Signet assurances about the responsible practices of each supplier company as well as confidence regarding responsible sourcing through each supplier’s supply chain, which is an important component of Signet’s supply chain due diligence and risk assessment. Suppliers which achieve this level of certification are not required to be audited separately by Signet.

Our Supplier Audit Policy

Any Signet supplier who is not yet a Certified RJC member with the SRSP as a Provenance Claim (see above) may be subject to an audit of their mandatory SRSP Compliance Report by an independent third party audit firm.

Audits are conducted on a 3-year rotational basis and Signet Suppliers are responsible for the expense of an audit.

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