1 Business Ethics

• We are committed to conducting our businesses to a high ethical standard, and to ensuring integrity, transparency and conformance with Applicable Law.
• We will not engage in Bribery and/or corruption.
• We will not tolerate Money Laundering and/or financing of terrorism.
• We will adhere to the Kimberley Process Certification System and the World Diamond Council voluntary System of Warranties. We will not deal in conflict diamonds.
• We will not use conflict Gold to make the jewellery we supply to you.
• We will fully and accurately disclose the material characteristics of the products that we send you.
• We will take reasonable measures to ensure the physical integrity and security of product shipments.
• We will respect commercial confidentiality and data privacy.

2 Human Rights and Social Performance

• We believe in and will respect the fundamental human rights and the dignity of the individual, according to the United Nations Universal Declaration of Human Rights.
• We will not tolerate the use of Child Labour or forced, bonded, indentured or prison labour, nor restrict the freedom of movement of Employees and dependents.
• We are committed to high standards of Health and Safety in our operations.
• We will not prevent workers from associating freely.
• We will not discriminate based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, marital status, physical appearance, age, or any other applicable prohibited basis in the workplace.
• We will not use corporal punishment under any circumstances and will prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form.
• We will adhere to working hours and remuneration legislation.

3 Environmental Performance

• We will conduct our business in an environmentally responsible manner.
• We will manage our environmental footprint by eliminating or minimising negative environmental impacts.
• We will comply with all applicable environmental Regulations

4 Legal Compliance

• Kimberly System of Warranties
• CPSIA Cadmium Requirements and Statutes
• California Toxic Substances Requirements and Statutes
• Irradiated Gemstone Requirements and Statutes
• Colored Diamond Requirements and Statues
• JVC (Jewelers Vigilance Committee) Guide to Gold and Silver
• Dodd Frank Act – Conflict Minerals Requirements of Dodd Frank Law
• FCPA-Foreign Corrupt Practices Act
• California Transparency Act
• Patriot Act (Anti-Money Laundering)

Vendor Code of Conduct Acknowledgment

Vendor hereby certifies to NYJ Group as follows:

1) The Vendor has received, read, and understood the guiding principles and expectations outlined in the NYJ Group Vendor Code of Conduct.

2) The Vendor acknowledges and agrees to conduct periodic self-assessments to ensure that Vendor, its subcontractors, and next-tier Vendors are complying with this Code as well as applicable laws. NYJ Group reserves the right to conduct periodic on-site visits through the use of internal resources. These visits will be for the purpose of confirming Vendor’s compliance with this Code and applicable laws and regulations.

Signature: ______________________________________

Name / Company (Printed):__________________________________

Title: __________________________________________

Entity: _________________________________________

Date: __________________________________________