Supply Chain Policy

1. Ben Bridge Jeweler has thirty-six Ben Bridge Jewelry stores across the United States with 110 years of operation. This policy confirms Ben Bridge Jeweler’s commitment to respect human rights, avoid contributing to the finance of conflict and comply with all relevant UN sanctions, resolutions and laws.
2. Ben Bridge Jeweler is committed to the responsible sourcing of diamonds, gold, and other precious minerals and gemstones. As such, we pledge that we:
   1. respect human rights according to the Universal Declaration of Human Rights and International Labour Organization Fundamental Rights at Work;
   2. do not engage in or tolerate bribery, corruption, money laundering or finance of terrorism;
   3. support transparency of government payments and rights-compatible security forces in the extractives industry;
   4. do not provide direct or indirect support to illegal armed groups; and
   5. enable stakeholders to voice concerns about the jewellery supply chain.
   6. are implementing the OECD 5-Step framework as a management process for risk based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.
3. We also commit to using our influence to prevent abuses by others.
   1. We require all new vendors to sign our supply chain policy. We require jewelry producers to supply sourcing information from their supply chain, as far back as sourced mine, and documentation to support.
   2. Any vendors found to be non-compliant will first receive an offer of assistance to create a compliance plan; if this is refused or not followed we terminate our partnership
   3. Parties interested in voicing concerns about our supply chain may contact our Due Diligence Officer: Angela Hope, VP of Merchandise at Angela.Hope@benbridge.com
4. Regarding serious abuses associated with the extraction, transport or trade of diamonds/coloured gemstones
   We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:
   1. torture, cruel, inhuman and degrading treatment;
   2. forced or compulsory labour;
   3. the worst forms of child labour;
   4. human rights violations and abuses; or
   5. war crimes, violations of international humanitarian law, crimes against humanity or genocide.
5. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in 4 or are sourcing from, or linked to, any party committing these abuses.
6. Regarding direct or indirect support to non-state armed groups
   We only sell or purchase diamonds/coloured gemstones that are fully compliant with the Kimberley Process Certification Scheme and, as such, will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring diamonds/coloured gemstones from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:
   1. control mine sites, transportation routes, points where diamonds/coloured gemstones are traded and upstream actors in the supply chain; or
   2. tax or extort money or diamonds/coloured gemstones at mine sites, along transportation routes or at points where diamonds/coloured gemstones are traded, or from intermediaries, export companies or international traders.
7. We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph 6.
8. Regarding public or private security forces
   We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph 4 or that act illegally as described in paragraph 6.
9. Regarding bribery and fraudulent misrepresentation of the origin of diamonds/coloured gemstones
   We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of diamonds/coloured gemstones, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of diamonds.
10. Regarding money laundering
    We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of diamonds/coloured gemstones.

Signed,

Lisa Bridge, CEO

Date of effect: September 30, 2021