Social Ethical & Environmental Policies

Signet has a formal social ethical & environmental ("SEE") governance framework with SEE principles and policies being included in the schedule of matters reserved for the Board. The Chief Executive Officer has been designated as the director responsible for SEE matters including those relating specifically to climate change, and reports to the Board on a regular basis.

Signet's SEE Committee chaired by the Group Company Secretary, and consisting of senior managers from the US and UK divisions, has responsibility for the implementation of the various aspects of the SEE principles and policies, including climate change initiatives, through a program approved by the Board.

The procedures for SEE risk management are embedded within Signet's management structure. SEE risks are discussed in the Risk factors section. However, Signet's share of the worldwide jewelry and watch market is less than 3% of the total. Therefore, it is management's belief that it can be most effective in influencing improvements in the supply chain by working with other industry representatives who together can, by concentration into a single industry voice, be representative of many aspects of the supply chain and use their combined influence in working to improve the supply chain as a whole. In support of this position, the Chief Executive of the US division is on the Board of Jewelers of America and its Ethical Initiatives Committee and chairs the Industry Affairs Committee. Signet's Group Company Secretary is a director of the Responsible Jewellery Council ("RJC") and of the World Diamond Council ("WDC").

The Board has adopted a Statement of SEE Principles ("Principles") outlining Signet's policy to operate as a profitable and reputable specialty jewelery retailer, and its responsibilities to various stakeholders and the SEE principles by which it operates.

Supply Chain Standards

Signet has a Supplier Code of Conduct ("Supplier Code") and policies on business integrity, health and safety, the environment and labor standards. The Supplier Code applies to suppliers and agents with whom Signet deals directly. They are encouraged to ensure that the Supplier Code is communicated throughout the supply chain.

Most of the raw and processed materials for the merchandise sold by Signet are traded on commodity exchanges or through multiple brokers and traders thereby making the original source difficult to trace. Signet believes that SEE issues at the mining, trading and secondary processing phases of the supply chain are more effectively managed through co-operation within the industry.

Conflict diamonds

One of the issues facing Signet and the diamond sector is conflict diamonds. These are diamonds sold by rebel movements to fund military campaigns. Signet has worked with industry members, the United Nations, government bodies, commercial interests and civil society to introduce an effective system for the certification of the source of uncut diamonds. This system, known as the Kimberley Process Certification System ("KPCS") was formally adopted in November 2002 and came into operation during 2003. Details regarding the KPCS are available at www.kimberleyprocess.com.  The WDC has also introduced a system of warranties for the trade in polished diamonds whereby the seller confirms that the diamonds comply with the KPCS. Details concerning the WDC are available at www.diamondfacts.org. Signet has trained its buying staff and sales associates with regard to the KPCS and the WDC system of warranties requirements and operation. The audit of these procedures as required by KPCS is undertaken regularly, and the audit results have confirmed Signet's compliance. Signet has been commended for its robustness in this area.

The Responsible Jewellery Council

As Signet believes it can be most effective in influencing improvements in the supply chain by working with other industry representatives it has played a leading role in the formation of the Responsible Jewellery Council ("RJC"). The RJC is an industry group representing the entire length of the diamond and gold jewelry industry supply chain from the mine to retail. In 2004, Signet was one of the signatories to a Statement of Intent that formed the basis of an agreement for further co-operation to promote increased consumer confidence and integrity in diamond and gold jewelery by promoting responsible business practices throughout the industry. As a result the RJC was formed in 2005 as a not for profit organization whose members are participants in all aspects of the diamond and gold jewelery industry. The RJC mission statement is to promote responsible practices relating to business ethics, social, human rights, and environmental performance throughout the diamond and gold jewelery supply chain, from mine to retail. A key membership requirement of the RJC is an independent assessment of compliance with the Code of Practices in accordance with the RJC Responsible Practices Framework which was launched in December 2008. More information is available from www.responsiblejewellery.com.

May 2011: Signet achieved certification to meet the ethical, human rights, social and environmental standards as established by the RJC's Member Certification System. Signet's certification encompasses all of our US and UK operations.

Environment

The direct environmental impact of Signet's operations is considered to be relatively low compared to many business sectors and to other retailers. Notwithstanding Signet takes its environmental performance seriously and seeks opportunities to improve it. The Group has been implementing eco-efficiency initiatives to reduce energy use since 2003 and continues to assess further opportunities to minimize resource use. In the UK, The Carbon Trust carried out a review of Signet's head office and store emission levels in 2009, and recommended a number of initiatives. These initiatives have been finalized and will be implemented by the end of Fiscal 2011, with the aim of a significant reduction in green house gases.

Community affairs

Both divisions have an active local community relationship program. During Fiscal 2009 Signet advanced various employment sourcing relationships with a number of community organizations relating to people who are disabled, being rehabilitated or suffering from development difficulties. These community activities were continued through Fiscal 2010 and 2011.

Charitable support

Signet believes it is best to give support to a small number of specific charities rather than fragment its charitable giving. In the US, support is primarily given to The United Way, St. Jude Children's Research Hospital and Jewelers for Children, the industry's charity. In Fiscal 2011, Signet presented St. jude with a check for $4.3 million, our largest donation ever. In the UK, Signet supports the Variety Club and Marie Curie Cancer Care.

No political donations were made in the US or the UK in Fiscal 2011 (Fiscal 2010: $nil).

Human rights

Signet supports the Fundamental Conventions of the International Labor Organization and the United Nations Declaration of Human Rights and encourages support and respect for these principles within its sphere of influence through the Supplier Code. Signet is working at a senior executive level to address human rights in the jewelry supply chain on an industry wide basis, through the RJC described above.

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, we 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.