Responsible Sourcing

Policy in Support of Conflict-Free Sourcing

Signet Jewelers Limited and our US 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.

Signet has been at the forefront of responsible sourcing in the jewelry supply chain. 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.

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 guidelines supplement for gold, the London Bullion Market Association (LBMA) Responsible Gold Guidance, and the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502, relating to our supplies of gold.

Based on these 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 recognized as conflict-free (see SRSP for conflict-free gold and SRSP for conflict-free 3Ts). The SRSP is established as company policy effective 1/1/2013 and requires all suppliers to certify and independently verify that supplies to Signet are compliant with the SRSP.

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 30, 2014.

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.

Conflict Diamonds

As part of an on-going campaign to educate both consumers and the trade about important diamond-related issues, the diamond industry hosts an informational website, http://www.diamondfacts.org

The source of our diamonds is an issue we take very seriously.

We are appalled by the violence in countries where proceeds from the sale of diamonds and other natural resources (e.g. oil, timber) are used to fund rebel activities or lead to human rights abuses.

All nations with significant involvement in the diamond trade agreed a global certification system to control the export and import of rough diamonds mined from January 1, 2003. This system is aimed at preventing criminals from introducing contraband diamonds mined in combat zones into the legitimate supply chain. Since 2003, the Kimberley Process Certification Scheme (“KPCS”), supported by national and international legislation, has sought to certify the legitimate origin of uncut diamonds.

Kimberley Process members (“Members”) account for approximately 99.8% of the global production of rough diamonds.

We welcomed this important development and are actively supporting the system designed to safeguard our products’ integrity.

The Kimberley Process (“KP”) has done more than just stem the flow of conflict diamonds, it has also helped stabilize fragile countries and supported their development. As the KP has made life harder for criminals, it has brought large volumes of diamonds onto the legal market that would not otherwise have made it there. This has increased the revenues of poor governments, and helped them to address their countries’ development challenges. For instance, some $98 million worth of diamonds were legally exported from Sierra Leone in 2008, compared to almost none at the end of the 1990s (source: Tacy Ltd).

Role of Governments
As of January 2012, 50 Participants, representing 76 countries (the European Union and its member states count as an individual participant) had adopted the KPCS. It requires that each shipment of rough diamonds – before stones are cut and polished – be in a tamper-resistant container and accompanied by a government-validated certificate. Each certificate is uniquely numbered and contains data describing the shipment’s contents.

Participating countries have pledged to turn back or impound shipments of rough diamonds from any nation that fails to subscribe to KPCS standards. Shipments lacking proper certification will be treated in a similar way.

At later stages of the diamond’s journey to market, rough diamonds also carry a certificate describing the shipment’s contents and confirming that the stones are coming from a Kimberley Process participant. Any country declining to participate is effectively banned from the international diamond trade. Learn more at http://www.kimberleyprocess.com/

Role of Industry
To supplement the government program, the International Diamond Manufacturers Association (IDMA) and the World federation of Diamond Bourses (WFDB) – representing virtually all significant processors and traders – have established a regimen of self-regulation. Its principal element is a system of warranties that will accompany invoices covering the sale of rough diamonds, polished diamonds and diamond jewelry. The requirement applies to rough diamonds mined after December 31, 2002 and products fabricated from them.

Participants of the KPCS must have internal controls to prevent conflict diamonds from entering the supply chain of legitimate diamonds and must carry out annual audit compliance. Furthermore, participants only trade with counterparts who themselves have met the minimum requirements of the certification scheme.

Role of the retailer
This information outlines the steps Signet and the industry have been taking to address conflict diamonds.

All of the diamonds we buy are warranted to be sourced from KPCS compliant countries. Retailers who support the Kimberley Process must buy diamonds and diamond jewelry from dealers and manufacturers who adhere to the System of Warranties explained above. We follow this policy. All diamonds and diamond jewelry merchandise that we buy, must be accompanied by a warranty from the supplier. This warranty assures us that the supplier vouches for the legitimacy of the merchandise and that the supplier, in turn, has required the same warranty from their sources of merchandise.

Our Source of Diamonds
We fully support the Kimberley Process and require all our trade suppliers of diamonds and diamond jewelry to provide us with a warranty that they do not supply us with conflict diamonds.

The warranty is as follows:
“The Diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and are in compliance with United Nations Resolutions. The seller hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.”

KPCS certificates for rough diamonds and warranties for polished diamonds received from suppliers are kept at our central office. Compliance with KPCS regulations, the World Diamond Council, the IDMA, and the WFDB is reviewed annually by our company’s internal audit department. The results are reported by the Company’s Audit Committee.

Gold Supply Chain Information

We are aware of the issues being raised over mining practices and we take them very seriously.

Signet expects our business partners to adhere to socially and environmentally responsible business practices. We take the impact of our company’s supply chain seriously and we believe that gold should be extracted and processed in a manner that respects the needs of current and future generations.

Signet believes that it is best to strive for improvements in mining practices and supply chain conditions through industry initiatives so as to maximize our effectiveness in addressing these issues. Such industry bodies have much greater credibility with governments and international organizations, whose co-operation is essential in successfully tackling these matters.

Signet believes meaningful reform must incorporate a wide range of industry stakeholders to ensure that responsible practices are developed and can be followed all the way through the supply chain.

Therefore, the Responsible Jewellery Council (RJC), a non-profit organization, was founded in May 2005. RJC’s mission is to advance responsible ethical, social and environmental practices, which respect human rights, throughout the diamond, gold and platinum metals jewelry supply chain, from mine to retail. Membership of RJC is comprised of companies and trade groups that, in total, are representative of the entire supply chain, from mine to retail.

Jewelers of America, the US national trade association of retail jewelers, of which we are a member, is one of the founders of RJC, as were we. RJC has developed a set of Principles and a Code of Practice for companies from mining through to retail involved in the worldwide diamond, gold and platinum metals jewelry industry. RJC has consulted widely with many stakeholders in the jewelry industry on the development of its Principles, and it’s Code of Practices which have now been published and outline the ethical, social, human rights and environmental practices to which RJC members should adhere. This includes a comprehensive mining specific responsible sourcing code.

RJC requires that members must be audited by accredited, third party auditors to verify their conformance with the Code of Practices.

In December 2009, RJC incorporated the Mining Supplement standards into its Code of Practices, which aims to develop further standards to address mining-specific issues within the diamond and gold jewelry supply chain. These standards are applicable to Members’ mine sites, and are in addition to the requirements already outlined in the Code of Practices.

RJC believes there is a need for an open and transparent approach and believes that by working in collaboration with civil society and governments it can promote and develop responsible business practices throughout the supply chain. Therefore, RJC places importance on ensuring that interested parties, including Non-Governmental Organizations, are represented and given the opportunity to be part of the overall consultation process.

For more information regarding RJC’s mission statement, founding members, and other information, please visit www.responsiblejewellery.com.

Gemstones from Myanmar/Burma

Signet takes supply chain issues seriously and the events in Myanmar/Burma are very disturbing.

Signet’s vision and commitments are expressed in the Social, Ethical & Environmental Principles. Signet has been working for many years on issues that are of concern to the entire industry, and has joined other organizations to drive positive change throughout the supply chain. For example, Signet is a founding member of the Responsible Jewellery Council (RJC) and the World Diamond Council (WDC), and, in the United States, a member of Jewelers of America (JA) and the Jewelers Vigilance Committee (JVC).

Given Signet’s deep concern about the unrest in Myanmar/Burma, and its military government’s human rights violations, beginning October 12, 2007 all suppliers are required to not knowingly sell Signet any gemstones of Burmese origin. Signet also issued instructions to its suppliers in both the US and UK, requiring that they confirm on all future orders placed that the gemstones provided were not knowingly mined in Myanmar/Burma.

In addition, in both the US and UK Signet has implemented a independent, third-party country-of-origin quality assurance random testing programs of its ruby jewelry in partnership with the Gemological Institute of America (GIA), the world’s largest and most respected non-profit institute of gemological research and learning.

The Tom Lantos Block Burmese JADE (Junta’s Anti-Democratic Efforts) Act of 2008 was approved unanimously by Congress and signed by President George W. Bush in July 2008. It went into effect on September 27, 2008 and enforcement of the law’s requirements began on October 27, 2008 following a 30-day grace period granted by the US Customs and Border Protection agency.

It outlaws the importation of Burmese-origin rubies and jade into the US. It does not cover other types of precious gemstones produced by Burma, nor does it forbid the sale of Burmese-origin gems legally imported to the US under prior rules.

Since Signet is not a direct importer of rubies, Signet has received written confirmation from the suppliers to its US business that they are taking the legally required steps to comply to the JADE Act. Signet has also maintained its independent, third-party, country-of-origin testing of rubies that are provided by its suppliers.

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.

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