Corporate Responsibilities

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California Transparency in Supply Chains Act

Shane Co. requires all of our suppliers to comply with the applicable laws and regulations of the United States, and those of the respective country of manufacture or exportation. In accordance with the California Transparency Supply Chains Act (SB 657), Shane Co. makes efforts to address human trafficking and slavery in the direct supply chain, which include both private and national brands, are described herein.

Verification

Shane Co. supply and legal executives meet on a regular basis, and informally as needed, to assess the risk of human trafficking and slavery in our supply chains and to assess whether our policies and procedures appropriately address those risks.

Shane Co. adheres to the Kimberley Process (http://www.kimberleyprocess.com/en/about) to collaborate with others in our industry to control the export and import of rough diamonds mined after January 1, 2003. This system is aimed at preventing criminals from introducing contraband diamonds mined in combat zones into the legitimate supply chain. Since 2003, the Kimberley Process Certification Scheme (“KPCS”), supported by national and international legislation, has sought to certify the legitimate origin of uncut diamonds. Kimberley Process members often work with the same manufacturers and suppliers, and benefit from sharing audit results that can contribute to setting consistent industry-wide expectations.

Through Shane Co.’s involvement with the Kimberley Process Certification Scheme, we are better able to understand and monitor risks associated with labor recruitment practices generally, as well as the use of specific labor intermediaries in our supply chain.

Audits

Shane Co. will not tolerate, and will investigate, any reports alleging human trafficking and slavery in the supply chain. All Shane Co. suppliers of diamonds undergo an annual certification process to ensure that such supplier is in compliance with the Kimberley Process. Action is taken against any supplier for non-compliance, resulting in possible termination of the business relationship.

Certification

All Shane Co. suppliers must adhere to our vendor standards, which includes strictly prohibiting human trafficking and slavery. Shane Co. also requires that all suppliers must also comply with the country of manufacture’s labor laws, whichever is stricter.

We also send periodic communications to suppliers making them aware of new laws or revisions to existing laws as appropriate. By accepting each and every purchase order, Shane Co.’s suppliers confirm their understanding and agreement to our vendor standards and that the diamonds are conflict-free and are not involved in funding conflict and are in compliance with the United Nation Resolutions related to “Diamonds In Conflict.”

Internal Accountability

Shane Co.’s associates adhere to an employee Code of Conduct that informs them about the requirements of Shane Co. policies relating to human trafficking. Non-compliance with Shane Co. standards regarding slavery and trafficking can result in corrective action or termination, depending on the number of non-compliance events found and their severity. If and when Shane Co. learns of employee or contractor compliance problems, we provide written notice and a specified period of time to take corrective action. While Shane Co. believes in sustainable remediation, we reserve the right to terminate a business relationship with an employee or contractor if it is deemed necessary.

Training

While Shane Co. does not have a formal training program, all Shane Co. employees responsible for supply chain-related decisions and product purchasing are aware of the industry standards and regulations around conflict free goods. When and if a Shane Co. associate becomes aware of a supplier or contractor who is not in compliance with our vendor standards, we address it immediately with a plan of action to correct or terminate the arrangement/relationship. Employees specifically responsible for supply chain-related decisions at Shane Co. receive more detailed training on identifying and addressing human trafficking and slavery in our supply chain.