Code of Conduct

Business Partner Code of Conduct

Safdico and its affiliates conduct their business in accordance with high ethical standards and expect our
business partners to share this philosophy. We utilize these standards in the selection of our business
partners, expecting full compliance from our business partners, including all diamond manufacturers,
polishing companies, private buyers, mediators, and suppliers. Safdico will always strive to improve the
working environment for those involved in the production of our products. It is imperative that our
customers will be confident that our products are handled in facilities that are in full compliance with
regulatory requirements regarding workers’ rights, which provide a safe and healthy work environment in
order to adhere to all Safdico business partner code of conduct policies, as set forth herein. Participation in
this program and adherence to program policy is mandatory for all Safdico business partners.

WORK ENVIRONMENT

Safdico will only work with business partners who provide a safe and healthy workplace that complies with
all local laws. Business partners who provide a dormitory and/or residential facilities for their workers must
ensure these facilities are safe, healthy, and in compliance with local standards. Safdico expects all business
partners to promote employee health and safety through internal training and awareness programs.

LABOR POLICY

Safdico will not knowingly work with business partners who use forced or compulsory labor, perceived or
otherwise, in its manufacturing facilities. Labor, including overtime, shall be voluntary at all times.

EQUAL EMPLOYMENT OPPORTUNITIES

Safdico has the highest respect for cultural differences. However, we believe workers should be employed
based on their abilities, rather than their race, gender, personal characteristics, or beliefs. Evidence of
discrimination or discriminatory behavior in the workplace, or any form of this, will not be tolerated.

WORKERS RIGHTS

Safdico expect their business partners to obey all applicable local laws for respecting the rights of workers.
Business partners are encouraged to develop internal programs, policies, and procedures that clearly define
their business practices and provide employees with a viable means of managing conflict and resolving
disputes.

WORKING HOURS

Safdico seeks business partners that do not require employees to work a number of hours, during a week,
that exceeds local laws or business customs. Business partners should maintain a workweek consistent with
normal hours of operation for their industry, with compensated overtime, in compliance with local law.

WAGES & BENEFITS

Safdico seeks business partners that provide wages and benefits in compliance with local laws and that are
committed to the betterment of wage and benefit levels that address the basic needs of workers and their
families.

CHILD LABOR

Safdico will not knowingly work with business partners who utilize child labor. Child labor is defined as
either being below the local minimum working age, or the age of 14, whichever is greater.

COUNTRY OF ORIGIN

Safdico will not knowingly work with business partners who use deceptive trade practices to deliberately
misrepresent the country of origin to evade from a quota or other import restrictions or duties on any
product(s).

ENVIRONMENTAL

Safdico will not knowingly work with business partners that are not in full compliance with all applicable
environmental regulations.
The business partner agrees to permit and fully cooperate with any inspection, audit, or product
investigation by Safdico management at the business partner’s facilities. Failure to comply with the
requirements detailed in this document may lead to the immediate cancellation by Safdico of all outstanding
purchase orders or other business with the business partner.
Furthermore, Safdico reserves the right to reject or return any merchandise not produced or supplied in
compliance with the foregoing and to charge the business partner for any and all costs from the business
partner that fails to comply with said standards.