Supplier Code of Conduct

At Mejuri, we believe in fine jewelry as an expression of self, and in creating the pieces you love, it is just as important
to us that our community feels good about how they are crafted. Our entire production ecosystem—including
sourcing, manufacturing, and branding—aims to positively impact the communities that support our business,
empower people around the world to design the life they want, and make our planet a better place. We want to use
our reach and resources to make a difference and we expect our Suppliers to share our commitment to human rights,
fair and safe labor practices, environmental protection and ethical business conduct.
In accordance with Mejuri’s commitment to ethics and social responsibility, all Mejuri suppliers, their affiliates, agents,subcontractors and any other party providing goods and/or services, whether directly or indirectly, to such suppliers(collectively, “Suppliers”) in connection with the production of any Mejuri merchandise or supply of any services toMejuri shall operate in compliance with applicable laws, rules and regulations, as well as with principles of faircompetition, and shall reject all forms of corruption.
We expect Suppliers to go beyond legal compliance and strive to meet internationally recognized standards for theadvancement of human rights, business ethics, and social and environmental responsibility. Suppliers are encouraged
to align with International Labor Organization (“ILO”) conventions, the United Nations Global Compact, Guiding
Principles on Business and Human Rights and Sustainable Development Goals, and work conscientiously to operate
within these frameworks. Accordingly, Suppliers shall adhere to the requirements throughout this Code of Conduct.
APPLICABILITY
This code is applicable to all Mejuri suppliers, their affiliates, agents, subcontractors and any other party providing
goods and/or services, whether directly or indirectly, to such suppliers. Suppliers are responsible for ensuring theCode of Conduct is understood and followed throughout their operations. Accordingly, Suppliers must make therequirements in this Code of Conduct known to all workers in their local language.
FREEDOM OF ASSOCIATION
Mejuri suppliers will respect the rights of employees to associate freely, organize and bargain collectively in a lawful
and peaceful manner, without penalty or interference.
Where laws prohibit these freedoms, suppliers will support parallel means for independent and free association andbargaining and will adhere to collective bargaining agreements, where such agreements exist.
FORCED LABOR
Suppliers will not employ forced, indentured, debt-bonded or convict labor, nor use any practice to coerce thecontinued employment of any person, such as requiring employees to pay recruitment commissions or withholding
any personal or travel documents. Employees are expected to be able to leave their employment without threat orcoercion. Neither the company nor any entity supplying labor to the company shall withhold any part of any
personnel’s salary, benefits, property, or documents in order to force such personnel to continue working for thecompany.
Suppliers shall monitor relationships with recruitment agencies or contracted labor for risk of human trafficking andcompliance with applicable anti-slavery laws.

1

CHILD LABOR & YOUNG WORKERS
Suppliers shall not use nor support the use of child labor as defined in ILO Convention 138 and the worst forms ofchild labor as defined in ILO Convention 182.
The minimum age for full time employment shall not be less than the age of completion of compulsory schooling and,in any case, shall not be less than 15 years (or 14 years where established by local laws in accordance with the ILO
developing-country exception).
Suppliers shall ensure any young workers (those between the minimum age described above and 18 years old) are
employed under well-defined circumstances, such as legal vocational training programs, that are not harmful to thehealth, safety or morals of young workers and that comply with applicable laws.
DISCRIMINATION
Suppliers will not practice or condone any form of discrimination in the workplace during any phase of theemployment relationship due to race, ethnicity, caste, national origin, religion or belief, disability, gender, sexualorientation, union membership, political opinion, marital status, parental status, physical appearance, social group,veterans status, medical status, or age, or any other basis specified by law. All individuals shall be accorded equal
opportunities and are not discriminated against on the basis of factors unrelated to their ability to perform their job.
HARASSMENT
All Mejuri suppliers are expected to provide a workplace that affords respect and dignity to all employees. The suppliershall ensure that employees are not subjected to harsh or degrading treatment, sexual or physical harassment,
mental, physical or verbal abuse, corporal punishment, threats or other forms or mental or physical coercion,
psychological or verbal harassment or intimidation to management and staff, their family, or colleagues shall not betolerated in any circumstance.
DISCIPLINE
Suppliers shall clearly communicate disciplinary processes, and related standards, and apply them equally to all
management and staff.
WORKING HOURS
Suppliers shall comply with local laws and seek to align with ILO conventions intended to ensure employees do notwork excessive hours per week. Understanding the seasonal nature of the industry, in extraordinary businesscircumstances with their voluntary non-induced consent employees may be asked to work longer than standard
hours. Workers shall be entitled to at least one day of rest following six consecutive days worked.
WAGES AND BENEFITS
Suppliers shall pay all workers a fair wage based on the higher of either the applicable legal minimum wage, or theprevailing industry standards.
Suppliers are encouraged to provide a level of compensation for a regular work week that is sufficient to meet basic
needs and provide discretionary income. At a minimum, suppliers shall comply with applicable law in the payment ofwages and the provision of benefits, including holidays, leaves and statutory severance.
Suppliers shall make payments to employees on a regular basis which has been previously communicated in writingand provide wage statements to employees which clearly states the wage rate, benefits and deductions for each payperiod. Employees must be compensated for overtime hours at the rate legally required by local law or, where suchlaws do not exist, overtime should be at least 125% of the regular hourly compensation rate in accordance with ILO
conventions.
GENERAL EMPLOYMENT TERMS
All employees shall be provided with a written, legally binding labor contract in a language the employee canunderstand.
SUBCONTRACTING
Suppliers shall not contract out any part of the work without disclosing such off-premise, homework, orsubcontracting relationships to Mejuri. Any person working on behalf of the supplier on Mejuri goods will be subject tothis Code and Suppliers are responsible for compliance with these requirements.

2

HEALTH AND SAFETY
Appropriate procedures should be in place to regularly assess the workplace for hazards and implement appropriate
programs and engineering controls to minimize the risks of work-related accidents. Suppliers will strive to continually
improve the effectiveness of their health and safety programs and seek to implement best practices in their industries.
Suppliers should be encouraged to have a nominated health & safety representative who monitors the facility'scompliance with procedures.
Suppliers will provide employees with the necessary health and safety training and/or education and will secureadequate systems to detect and avoid potential threats and to help continuously improving health and safety are put
in place.
ENVIRONMENT
Suppliers shall meet or exceed all environmental laws and regulations, and strive to meet or exceed the standards ofinternational environmental treaties and best practices in their industries. Suppliers shall identify environmental risks
and impacts, as well as opportunities for improving environmental performance. Suppliers shall implement andregularly review controls to mitigate identified environmental risks and minimize environmental impacts, including
resource use, discharges, emissions and waste disposal, and take a proactive approach to monitoring and collecting
data on these topics. Supplier operations and sourcing practices should strive to place special emphasis on themitigation of climate change and the preservation and rehabilitation of biodiversity and ecosystems.
COMMUNITY DEVELOPMENT
Suppliers shall make every effort to proactively engage with and support development in the local communities where
their operations and supply chains are located, and to employ, procure and build within those communities.
SECURITY
Suppliers shall take measures to ensure the safety and security of its workers, contractors and visitors. This includes
assessing security risks and implementing measures to protect against product theft, intellectual property theft or lossof employee or customer data during manufacturing and transport of goods.
Suppliers shall take steps to ensure that human rights are protected in all aspects of its security operations, including
in interactions among security personnel, workers and visitors. Suppliers are encouraged to align with the Voluntary
Principles on Security and Human Rights where applicable.
BUSINESS INTEGRITY
Mejuri expects the highest standards of business integrity are upheld in all business interactions. Ethical businessconduct and dealings, and transparency of those operations, are accurately reflected on their business books andrecords. Suppliers shall have a policy mandating business integrity.
PRODUCT DISCLOSURE
All disclosures on the nature and quality of materials and products sold to Mejuri must be accurately communicated.
This includes but is not limited to location of origin, weight, color and clarity, treatments of gemstones, the standard offineness and trademarks of articles of precious metals and other matters as required by applicable federal, state andlocal laws and in accordance with internationally accepted jewelry industry product disclosure standards.
Suppliers of diamonds (including diamonds set in jewelry) will take appropriate measures to mitigate the risk ofundisclosed synthetic diamonds from entering Mejuri’s supply chain.
ANTI CORRUPTION, BRIBERY, MONEY LAUNDERING
Suppliers shall not engage in any form of corrupt practices, including bribery, extortion, embezzlement, fraud, money
laundering or any business related to terrorist or armed activity. Suppliers shall not violate or cause any Mejuri
employee to violate the Canadian Corruption of Foreign Public Officials Act, United States Foreign Corrupt Practices
Act, and the UK Bribery Act or any other applicable anti-corruption or bribery laws. Suppliers shall implement theirown KYC-AML policy and monitoring and enforcement procedures shall be implemented to ensure compliance withapplicable anti-corruption and bribery laws.
Suppliers shall maintain financial accounts of all business transactions where required by applicable law and inaccordance with national or international accounting standards.
DUE DILIGENCE AND CONFLICT-AFFECTED AND HIGH-RISK AREAS
Suppliers of gold, silver, platinum group metals, natural diamonds and natural coloured gemstones will undertake
supply chain due diligence in accordance with the 5-Step framework of the OECD Due Diligence Guidance forResponsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Due Diligence Guidance).

3

KIMBERLEY PROCESS CERTIFICATION SCHEME
AND WORLD DIAMOND COUNCIL SYSTEM OF WARRANTIES
Mejuri supports the Kimberley Process Certification Scheme and the country-specific legislation that supports thelegal trade of diamonds. All suppliers involved in the sale or trade of diamonds, whether rough, polished, or set injewelry, shall adhere to the World Diamond Council System of Warranties and, where relevant, Kimberley ProcessCertification Scheme and have systems to ensure that all relevant invoices contain the required warranty statement toensure all diamonds under that invoice meet warranty requirements.
TRACEABILITY AND TRANSPARENCY OF MATERIALS
Traceability and transparency are key to avoiding unintended negative impacts at any stage of the jewelry-making
process and we are committed to the highest level of responsible sourcing. Suppliers shall make every effort toprovide accurate traceability information related to raw materials, processing, and final assembly of all products
manufactured for Mejuri’s subsequent sale or distribution. Accurate and consistent inventory controls shall be
implemented in all levels of the supply chain to ensure traceability and sourcing data is available for applicable raw
materials through the supply chain. Suppliers are encouraged, where applicable, to complete Reasonable Country of
Origin Inquiries for materials entering the recycled market. Suppliers shall provide accurate reporting on the annual
percentage of mined, pre-consumer, and post-consumer recycled precious metals from their smelting and refining
suppliers.
NON-MINED MATERIALSSuppliers of non-mined materials, including but not limited to, pearls, leather/hide and paper based products, willensure that these materials are responsibly sourced and produced in accordance with applicable laws, regulations
and relevant industry best practices and/or standards.
GRIEVANCE MECHANISMS AND REMEDY
Suppliers shall maintain grievance mechanisms to respond to concerns and complaints that ensure effective, timely,
respectful and transparent communication among workers, their representatives, management and the community.
LEGAL COMPLIANCE
Suppliers must, in addition to meeting the requirements of this Code, comply with all applicable local and national ,rules, regulations and industry standards pertaining to Suppliers’ operations and services. Where a difference between
the code and legal requirements exists, the higher of the two standards shall prevail.
COMPLIANCE EXPECTATION AND CONTINUOUS IMPROVEMENT
Suppliers are responsible to take appropriate steps to ensure the provisions of this Code are communicated to theiremployees and their own supply chain. Suppliers are also responsible to ensure that the principles referred to herein
are adopted and applied by their employees, suppliers, agents and contractors so far as reasonably possible.
Suppliers are encouraged to report non-conformance in their operations or supply chain proactively to Mejuri.
Suppliers will authorize Mejuri and its designated agents to engage in monitoring activities to confirm conformancewith this Code of Conduct and applicable law, including unannounced on-site inspections of manufacturing facilities
and employer-provided housing; reviews of books and records relating to employment matters; and private interviews
with employees. Manufacturers will maintain on site all documentation that may be needed to demonstrate compliance with this Code of Conduct and shall keep accurate and transparent records for all applicable areas of thebusiness including, but not limited to, working hours, wages, and benefits at all times for all staff employed, whether
on a full time, part time or seasonal basis. Suppliers shall regularly evaluate their conformance to this Code ofConduct and remediate any and all findings.
In the event of non-conformance to requirements, Mejuri Suppliers shall commit to remediate issues within thetimelines provided by the Corrective Action Plan. We seek to collaborate with all Suppliers toward continuous
improvement to achieve conformance with this Code; however, we reserve the right to cancel agreements orcontracts, suspend future purchases or terminate the relationship with any Supplier when the situation demands.
Mejuri reserves the right to make changes to this Code of Conduct as needed and will promptly inform Suppliers of
any changes thereof. Suppliers remain responsible for meeting the requirements of the most updated version.
This Code draws from industry and internationally accepted principles such as the Ethical Trading Initiative, InternationalLabor Organization’s (ILO) International Labor Standards, United Nations Guiding Principles on Business and HumanRights, Social Accountability International, SA 8000, the ILO’s Code of Practice in Safety and Health, National Fire
Protection Association, Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational
Enterprises, the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected andHigh-Risk Areas, and OHSAS 18001.

4