Supplier Code of Conduct

Signet Jewelers Limited (“Signet”) 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 recognise 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.

Signet recognises that suppliers may need time to address areas in which they may not currently be in compliance. Signet recognises that the ability to influence and promote these Principles beyond its direct suppliers varies and may be limited. We believe that compliance can only be achieved through a process of continuous improvement over a period of time.

Our commitment to suppliers

Signet aims to pursue its business activities in what it considers to be an ethical and professional manner. Specifically and subject to the needs of its business, it aims to promote stable, sustainable, long-term relationships with its suppliers and other business partners. Signet intends to live by the principles of this Code within its own operations and has adopted Social, Ethical and Environmental Principles and policies to this effect.

Legal compliance

Signet expects all its suppliers to comply with their national laws and regulations and to respect the fundamental International Labour Organisation (ILO) conventions and the Universal Declaration of Human Rights.

Where the Code or national law address the same issue, the supplier is expected, as a minimum, to be in compliance with the applicable legal requirements of the country in which it operates.

Health & safety

Signet expects its suppliers to provide a safe and healthy environment for their employees in accordance with applicable local laws and regulations. Appropriate procedures should be in place to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employer facilities. Suppliers should be encouraged to have a nominated health & safety representative who monitors the facility’s compliance with procedures.

Specifically suppliers should ensure that:

• Safe alternatives to the use of hazardous substances are adopted
• The use of cobalt discs is avoided
• Workers’ eyesight is protected by ensuring the availability and use of appropriate magnifying tools when working on jewelry, diamonds and gemstones, and by providing appropriate lighting
• Workers are protected from repetitive strain injury as far as possible considering the ergonomics of their workplace
• Facilities have adequate ventilation from harmful fumes or dust
• Appropriate protective clothing is provided and use of protective clothing is ensured
• Facilities need to have adequate fire safety standards/procedures, including regular fire drills for all employees, appropriate fire fighting equipment, and easily accessible, and marked and open fire exits in case of emergency
• Residential facilities for workers are kept safe and healthy in accordance with local laws and regulations
• Facilities should have easily accessible, adequate and clean bathrooms
• Potable water should be available at all times
• Where HIV/AIDS is a significant issue in the supplier’s location of operations, suppliers should educate workers about the risk of HIV/AIDS and assist in providing access to treatment and medication as necessary.

Remuneration

Signet expects its suppliers to comply with local laws in respect of minimum wages, working hours, employee benefits and overtime.

Working hours

Suppliers are expected to comply with applicable local laws and industry standards on working hours. Suppliers should not, except in special circumstances or as permitted by local law, expect employees to work more than the lesser of:

• 48 hours per week
• The limits on regular hours allowed by local law.

Signet recognises that those in management positions may exceed these limits in the course of carrying out their roles and responsibilities. Also, in light of the seasonal nature of business, Signet recognises that suppliers' employees may be expected in special circumstances to work longer hours for relatively short periods of time. Where this occurs it should be in compliance with the regulations of the country of employment. Working hours exceeding 48 hours per week should be planned in a way to ensure safe and humane working conditions. Where the company is party to a collective bargaining agreement freely negotiated with worker organisations (as defined by the ILO) representing a significant portion of its workforce, it may require overtime work in accordance with such agreement to meet short-term business demand.

Discrimination

Signet expects that its suppliers will not discriminate on race, caste, origin, religion, disability, gender, sexual orientation, union or political affiliation or age.

Harassment and abuse

Signet expects that its suppliers will provide a safe workplace free from harassment, and they will not permit the use of monetary fines, corporal punishment or other forms of mental or physical abuse, coercion or intimidation.

Forced labor

Signet expects that its suppliers will not permit the use of any forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise. Forced labor should be considered to include any work or service which is extracted from any person under the threat of penalty for its non-performance and for which the worker does not offer himself or herself voluntarily.

Child labor

Signet objects to the employment of persons younger than 15 years of age (or 14 where the law of the country permits) or younger than the age for completing compulsory education where this is greater than 15 in the relevant country. In addition, employers must comply with all their local legal requirements for young workers, particularly those pertaining to hours of work, wages, health and safety and general working conditions. A younger worker is defined as any worker over the age of a child as defined above and under the age of 18 years old.

Child labor should be phased out in a responsible manner that does not harm the welfare of the child and ensures that the child’s right to health and education are met.

Freedom of association

Signet expects that its suppliers will not prevent employees and other workers from associating freely with any lawful workers' association or collective bargaining association. Where laws prohibit these freedoms, the supplier is encouraged to facilitate parallel means of association and bargaining.

Environment

Signet expects its suppliers to protect the Environment within their respective spheres of influence. This includes supporting initiatives to promote greater environmental responsibility along the entire jewelry supply chain as well as complying with relevant locally applicable environmental law and regulations.

More specifically Signet believes that natural resources should be developed in a manner that respects the needs of current and future generations. The jewelry industry uses metals and other minerals for a wide variety of purposes and it is therefore in the industry’s best interest to ensure that the minerals upon which it depends are obtained, produced and used in environmentally and socially responsible ways.

Ethics and integrity

Signet expects that its suppliers will conduct business with integrity and communicate honestly regarding the nature of the products they supply, disclosing accurately their weight, colour and clarity, treatments of gemstones, the standard of fineness and trademarks of articles of precious metals and other matters as required by applicable federal, state and local laws and regulations.

Conflict Diamonds

Signet requires a warranty, in the form agreed by the World Diamond Council, for any product fabricated from rough diamonds mined from January 1, 2003 onwards.

Invoices and packing slips for diamonds and diamond jewelry shipped to any trading subsidiary from February 1, 2003 onwards must state:

"For any product fabricated from rough diamonds mined from January 1, 2003 onward, the seller warrants that the diamonds have been purchased from legitimate sources not involved in funding conflict and are in compliance with United Nations Resolutions. The seller hereby gurantees that the diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds.

For any product fabricated from rough diamonds mined prior to Janauary 1, 2003, the seller warrants that conflict diamonds will not be knowingly sold and that, to the best of their ability, will undertake reasonable measures to help prevent the sale of conflict diamonds in this country."

Read more about Conflict Diamonds.

Monitoring

Suppliers are encouraged to institute a self-monitoring system based on this Code and move towards independent verification of Code compliance.

Communication

Suppliers are encouraged to take appropriate steps to ensure the provisions of this Code are communicated to their employees and their own supply chain. Suppliers are also encouraged to ensure that the Principles referred to above are adopted and applied by their employees, suppliers, agents and contractors so far as reasonably possible.

Updated October 2008