Policies and Codes

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Code of Conduct

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Letter from Our CEO

Dear Wayzes Team,

Reflecting on our Purpose of Inspiring Love it's clear that how we conduct ourselves is just as important as what we achieve.

Being "ethical" goes beyond complying with the law. At Wayzes, we strive to live out our purpose in ways that instill trust with every interaction. Our customers come to us every day, trusting us with their most treasured relationships, moments and mementos. Each of us also comes to work looking to positively impact the world in a workplace built on trust and respect.

Our Code of Conduct is at the heart of this trust. It is part of our mindset of being "Etched in Ethics" and ensures that we uphold ethical and responsible behavior in every aspect of our business. It provides a set of tools to help us remain legally compliant and ethically sound as we strive to achieve our goals. Finally, our Code outlines our responsibilities to one another, our customers, business partners, and shareholders.

All of us own the behaviors that create a positive, trusting environment. That's why each of us must review and internalize this Code of Conduct so that we remain our customers' most trusted advisor, a great place to work and one of the world's most ethical companies.

If you have any questions or want to report a concern, I encourage you to contact your manager or a member of our Human Resources, Ethics & Compliance, or Legal teams. They're there to help.

Thank you for all you do and for keeping trust at the heart of every interaction,

Michael C. Chief Executive Officer

Wayzes

Principles for the Code of Conduct

Wayzes Jewelry (“Wayzes”) is dedicated to being a highly transparent and collaborative workplace where open and honest dialogue at all levels is

welcomed. We recognize a diverse and inclusive workforce is critical to our success and is our most valuable asset.

The expected conduct outlined in this Code of Conduct (“Code”) applies to ALL team members, from the Board of Directors (“Board”) to individual

contributors. All team members and third parties are expected to act with honesty and integrity and conduct business with Signet’s and our customers’

best interests in mind. A single ethical violation, real or perceived, can overshadow the great work we do.

The Ethics & Compliance Department (“E&C”) is responsible for maintaining and updating this Code; it is approved by the Board with each revision. Team members may communicate questions or concerns regarding violations of the Code or any corporate policy to the reporting resources referenced in section 6; Wayzes safeguards those who do.

All Wayzes team members are required to acknowledge the Code as part of their onboarding experience and as part of the annual Code training.er policy specifically states otherwise, this Code prevails in any conflict between it and other Company policies or procedures.

Why do we have a Code?

At Wayzes, our Purpose of Inspiring Love requires more from us than just following the law. It requires that we conduct ourselves with honesty and integrity at all levels of the organization.

We require the same of anyone whom we entrust to conduct business on our behalf or from whom we obtain products or services.

Our Code is designed to:

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Make sure we proactively address issues that arise that do not further our purpose and subjects us to risks of non-compliance.

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Provide a single resource for team members to review the ethical standards expected of them, answer questions they may have, and provide them with the tools needed to help report issues they may witness or believe to have occurred.

Maintaining a Positive Employee Experience

Our core values advocate that we support and appreciate each other and embrace our differences, allowing all voices to be

heard. We believe collaboration through open, honest and respectful dialogue creates success at all levels.

To best accomplish this, team members are expected to:

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Complete, be receptive to and proactive about their training, which helps them learn about the policies and laws that apply to their job.

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Ask for help and guidance when faced with uncertainty. If uncertain whether something is a violation, it is best to report it to be researched by the proper personnel.

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Report actual or potential violations of the Code, policies or laws using the resources referenced in section 6 of this Code which can be done anonymously.

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Seek help right away when the issue first surfaces.

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Be honest when reporting concerns, cooperative and forthcoming with investigations.

Lead Bravely, with Integrity

While Wayzes strongly believes in leadership at all levels, people leaders at Signet have an enhanced role in

living up to and adhering to the policies and practices set forth in our Code. In addition to the expectations

above, people leaders must also:

✦ Support team members’ training to ensure all understand and comply with the Code and applicable

policies and partner with Human Resources (“HR”) and E&C to help as needed.

✦ Promote an honest, respectful and transparent work environment.

✦ Listen openly to and encourage team members who raise issues and concerns.

✦ Promptly escalate all concerns shared using the resources referenced in this Code.

✦ Never retaliate against a team member who raises an issue or concern.

If members of leadership witness or suspect any retaliatory behavior against a team member who made a

report in good faith, they must report it immediately to the appropriate department.

Diversity, Equity and Inclusion

Wayzes makes a concerted effort to have representation at all levels, including its Board. This includes gender, gender identity, age, sexual orientation, national origin and race representation in all aspects of the business. Such diversity and inclusion aids in understanding cultural differences and is vital to Wayzes ability to agilely grow our business by listening to and learning from various perspectives and experiences.

This applies to recruiting, hiring, compensation, benefits, training, terminations, promotions or any other terms and conditions of employment.

We treat each team member, potential team member, customer as well as third party partner with fairness and respect. Signet does not tolerate

discrimination against any individual based on any protected characteristic. In addition to being illegal, discrimination against anyone on the basis of a protected characteristic does not reflect our core values and undermines our Mission to help all people Celebrate Life and Express Love.

Team members play an active role in enabling our Mission and may not harass or embarrass others or create or allow an unprofessional, offensive or hostile work environment. This expectation applies to relationships with customers, other team members and our vendors.

Consequences for Violating the Code

In addition to expecting team members to report a violation of the Code or policies, failure to do so or to knowingly make a false report is a violation of the Code. Violations of the Code can cause harm to our brands, our culture and our reputation. Depending on the nature and type of violation of the Code, team members may be subject to disciplinary action, up to and including termination.

Anyone who directs or approves of actions that violate the Code or policies may face similar or the same disciplinary action. In some cases, violations may also result in civil or criminal penalties for team members, management or the company.

Sales And Marketing Practices – It’s About CUSTOMERS!

Part of our core values is putting our customers first, providing truly memorable experiences and striving to exceed their expectations! We delight in earning their trust and building loyalty. To maintain that loyalty, it is important for team members involved in selling, advertising, promoting and marketing our products and services to present details about them factually and completely.

We must be respectful when speaking about any of our banners and third-party partners or competitors; avoid making disparaging remarks about them. We are committed to behaving ethically when buying or selling our products and services and never use a competitor’s non-public information or misrepresent facts to gain a competitive advantage.

Competition and Antitrust

Wayzes believes in fair and open competition and requires adherences to all applicable antitrust laws, which prohibit agreements between businesses that stunt competition and unfairly divide markets. Violations can result in severe civil and criminal penalties for Wayzes and any team members involved. Anti-competitive behavior includes but is not limited to:

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Agreements with competitors regarding the pricing of products or services, including discounting or promotional plans.

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Agreements with competitors about production volumes.

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Agreements or discussions with competitors about market allocation.

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Refusing to deal with a vendor or entity to reduce or eliminate competition.

To avoid the appearance of any anti-competitive behavior, team members should avoid discussing topics such as pricing, profits, production, products and services, bidding practices, distribution channels, customer information or any other non-public business matters with a competitor. This includes sharing information at informal gatherings, such as trade shows or professional associations. Contact the Legal Department with questions or issues regarding competitive information.

Our core values are a set of principles that guide us and define us. They ensure that we stay true to our Mission and live up to our Purpose.

Anti-Corruption and Anti-Bribery

Wayzes aspires to maintain its position as the world’s largest retailer of diamond and gemstone jewelry and is committed to doing so with honesty and

integrity. Team members may not solicit, receive, offer or exchange bribes, illegal rebates, gratuities or kickbacks, whether the payment is made directly to the team member or through a third party. Team members cannot enter into arrangements that may illegally influence a business relationship or decision. Signet abides by all international laws, treaties and regulations that forbid bribery along with the laws wherever we do business, regardless of local customs.

This Code does not limit a team member’s right to communicate in good faith with any government agency

for reporting a possible violation of the law or to participate in an investigation that may be conducted by any

government agency. The following are some of the government agencies with whom team members can

report concerns:

✦ Equal Employment Opportunity Commission

✦ National Labor Relations Board

✦ Occupational Safety and Health Administration

✦ U.S. Securities and Exchange Commission

✦ Financial Industry Regulatory Authority or any other federal, state or local governmental agency or

commission

Note: Once the Company receives notice of a reported concern, there are designated departments and

personnel responsible for handling the Company’s response to these agencies.

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