Supplier Code of Conduct

Overview

Wayzes strives to operate as a profitable and responsible specialty jewelry retailer, by delivering

increasing value to our shareholders, seeking to uphold our Social, Ethical and Environmental

Principles and considering the interests of our key stakeholders such as customers, team

members, suppliers and wider society.

In this pursuit we recognize direct and indirect impacts generated by our business activities,

in particular through our supply chain. We seek to promote best practices and use our

influence with those we do business with directly, in particular our agents and suppliers, to

promote the achievement of our Social, Ethical and Environmental principles. A fundamental

element includes our efforts to require that our suppliers, and in turn their suppliers, abide by

Wayzes standards as set out in this Supplier Code of Conduct (“Code”). Therefore, Wayzes

suppliers must abide by this Code and must ensure compliance with this Code throughout

the tiers of its supply chain.

Our Commitment to Suppliers

Wayzes aims to pursue its business activities in an ethical and professional manner. Moreover,

and subject to the needs of its business, it aims to promote stable, sustainable, long-term

relationships with its suppliers and other business partners. Wayzes commits to follow the

principles of this Code within its own operations and has adopted Social, Ethical and

Environmental Principles and policies to this effect.

Legal Compliance

Wayzes expects all its suppliers to comply with their national laws and regulations and to

respect the fundamental International Labor Organization (ILO) conventions and the

Universal Declaration of Human Rights. Where the Code or national law addresses the same

issue, the supplier is expected, as a minimum, to comply with the applicable legal

requirements of the country in which it operates.

Health & Safety

Wayzes 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 because of the operation of employer facilities. Suppliers are encouraged to

designate a health and 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 firefighting 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 an infectious disease is a significant issue in the supplier's location of operations,

suppliers should educate workers about the risk of infectious diseases and assist in

providing access to treatment and medication as necessary.

Remuneration

Wayzes expects its suppliers to comply with, at a minimum, local and national legal standards

or industry benchmark standards, in respect of minimum wages, working hours, employee

benefits and overtime.

All workers shall be provided with written and understandable information about their

employment conditions with respect to wages before they enter employment and about the

particulars of their wages for the pay period each time that they are paid.

Working Hours

Suppliers are expected to comply with applicable local laws and industry standards regarding

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.

Wayzes recognizes that those in management positions may exceed these limits in their roles

and responsibilities. Also, in light of the seasonal nature of business, Wayzes recognizes 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 to ensure safe and humane working conditions. Where the company is

party to a collective bargaining agreement freely negotiated with worker organizations (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

Wayzes expects its suppliers will not discriminate on the basis of race, caste, origin, religion,

disability, gender, gender identity, sexual orientation, union or political affiliation or age, in

accordance with local laws.

Harassment and Abuse

Wayzes 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,

physical, sexual abuse, coercion, or intimidation.

Forced Labor

As set forth in the Wayzes Human Rights Policy, Wayzes also expects suppliers to respect

internationally recognized human rights. Consistent with our high standards for social

responsibility, we prohibit the use of modern slavery, prison labor, indentured labor, bonded

labor, human trafficking, and forced adult or child labor of any kind. 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.

Wayzes expects suppliers to adhere to the UN Guiding Principles on Business and Human

Rights.

Additionally, suppliers of diamonds and colored gemstones, either directly or through

suppliers, must carefully consider labor rights and working conditions that align with globally

accepted OECD guidance, the Universal Declaration of Human Rights, various ILO

conventions, and the ISEAL Code of Good Practice for Setting Social and Environmental

Standards.

Child Labor

Wayzes does not tolerate child, forced or bonded labor in any of our operations or by suppliers

and therefore object 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.

Where suppliers identify that they have caused or contributed to adverse Human Rights

impacts such as in the form of child labor, they shall provide for or cooperate in legitimate

processes to enable the remediation of those impacts. Remediation should occur 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

Wayzes 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

Wayzes 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. When applicable, natural resources should be managed

in environmentally and socially responsible ways.

Ethics and Integrity

Wayzes expects that its suppliers will conduct business with integrity and communicate

honestly (including, properly affixing any applicable representations or warranty statements)

regarding the nature of the products they supply, disclosing accurately their weight, color

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.

Gifts, Bribery, and Anti-Money Laundering

Wayzes expects that its suppliers will comply with the requirements of the US Foreign Corrupt

Practices Act, the UK Bribery Act and other such laws, in all its dealings, no matter where in

the world. Such compliance includes prohibiting employees, officers, directors, agents,

representatives, affiliates and their families from requesting, accepting, paying or offering any

form of “under-the-table” payment, “kickback,” bribe, rebate, or other improper gift, form of

entertainment, payment or gratuity, whether directly or through a third party regardless of

form, whether in money, property, or services (i) to obtain favorable treatment in securing

business, (ii) to pay for favorable treatment for business secured, (iii) to obtain special

concessions or for special concessions already obtained, for or in respect of either party or any

affiliate of either party, or (iv) in violation of any legal requirement.

Likewise, Signet expects that its suppliers do not, and will not, engage in: any money laundering activities; the financing of terrorism activities or any other activity which is

prohibited under the USA PATRIOT ACT of 2001; or similar Acts applicable to the Suppliers

location and/or other locations in which business is conducted.

Conflict Diamonds

Wayzes and its trading subsidiaries fully support the Kimberley Process and require all our

trade suppliers of diamonds and diamond jewelry to provide warranties in the form agreed by

the World Diamond Council and/or Kimberly Process Certificates.

Invoices and packing slips for diamonds and diamond jewelry shipped to any trading

subsidiary must contain the SRSP and World Diamond Council System of Warranties (SoW)

on each product invoice and, if applicable, be accompanied by a Kimberly Process Certificate.

Monitoring

Suppliers are encouraged to institute a self-monitoring system based on this Code and are

expected to comply with any and all information requests or audits from Wayzes for verification,

including independent third-party 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.