ETHICAL SOURCING POLICY

ROGERS JEWELRY COMPANY DIAMOND SOURCING POLICY
Rogers Jewelry Co. takes the issue of ethical diamond sourcing very seriously. We fully support the Kimberly Process Certification Scheme, the United Nations resolutions and the Clean Diamond Trade Act, and demand from our manufacturers and suppliers their assurances that all diamonds we buy are conflict free. KPCS certificates received from our suppliers are kept on file in our central office and compliance with the KPCS protocol is monitored and reviewed annually by our compliance officer.

The Warranty is as follows:
"The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations resolutions. The seller hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds."

Rogers Jewelry Co. only buys diamonds from suppliers we have personal relationships with dating back many years. We do not buy diamonds from unknown sources. Many of our suppliers are receiving their diamonds directly from DeBeers virtually eliminating the possibility of conflict.

POLICY ON DIAMONDS FROM ZIMBABWE

We are deeply concerned about the reports of human rights abuses in the Marange region of Zimbabwe and other problems related to diamonds from the region.
We are fully committed to responsible sourcing of diamonds.
We are requiring our suppliers to provide additional written reassurances, beyond the World Diamond Council’s System of Warranties statement, that the diamonds they supply us have not been obtained in violation of applicable national laws and/or sanctions.
We strongly support the efforts of our trade association, Jewelers of America, to collectively ensure good practices at every level of the supply chain by actively participating in and supporting initiatives such as the Kimberley Process Certification Scheme (KPCS), the Responsible Jewellery Council (RJC), the World Diamond Council (WDC) and the Diamond Development Initiative International (DDII).
We completely abhor the notion that diamond jewelry could be linked to human rights violations in Zimbabwe or elsewhere and we believe that even one diamond from a conflict source is one diamond too many.

Progress has been made in the implementation of the Kimberly Process Joint Work Plan (JWP), instituted with Zimbabwe's consent, at the November 2009 KP Plenary. However, Rogers Jewelry Co. has decided - due to concerns that are beyond the scope of the KP - to not source any diamonds from the Marange region until additional issues are resolved.

These include serious unresolved questions about the legal ownership of diamonds mined in the Marange region, and the fact that a number of Zimbabwean entities and individuals who are connected with diamond mining (such as Grace Mugabe and the Zimbabwe Mining Development Corporation) are on the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC) sanctions list.

As such, we are practicing due diligence, doing what we can, within our spheres of influence, to protect the legal integrity of the diamonds we trade in. This includes requiring our suppliers to provide additional written reassurances, beyond the WDC's System of Warranties statement, that the diamonds they supply us have not been obtained in violation of applicable national laws and/or sanctions. Despite the fact that limited exports from the Marange region of Zimbabwe will have KP certificates, we believe these diamonds should be considered such a violation at the present time.

We remain deeply concerned about reported human rights abuses in the diamond fields of Marange, and will continue to watch the situation closely.

POLICY ON RESPONSIBLE GOLD
We expect our business partners to adhere to socially and environmentally responsible business practices. We take the impact of our company’s supply chain seriously and we believe that gold should be extracted and processed in a manner that respects people and the earth.

We believe a commitment to responsible gold must include suppliers, to ensure that responsible practices are addressed at every point in the supply chain. Without the engagement of all segments of our industry, retailers’ individual pledges to source responsibly will not be meaningful.

Our membership in the national trade association, Jewelers of America, links our company to a wide range of both industry and non-industry stakeholders (including the World Gold Council, the Responsible Jewellery Council, the U.S. Department of State and non-governmental organizations) to support good practices at every level of the gold jewelry supply chain.

Jewelers of America was a founding member of the Responsible Jewellery Council*(RJC), which officially launched its system in 2009 following an intensive, four-year period that involved wide-ranging and transparent consultation with the industry and its stakeholders. JA also participates in and supports initiatives such as the Alliance for Responsible Mining (ARM), the Initiative for Responsible Mining Assurance (IRMA), and the Madison Dialogue.

*RESPONSIBLE JEWELLERY COUNCIL
The Responsible Jewellery Council (RJC) has created a worldwide diamond and gold jewelry supply chain system for companies in all sectors, from mining through to retail. RJC published its core system documents in 2008. These included a requirement that members undertake third-party verification of their responsible practices by independent auditors, as defined by the RJC Code of Practices. RJC's system was officially launched in 2009. It was developed over an intensive, four-year period and involved wide-ranging and transparent consultation with the industry and its stakeholders. RJC recently completed its Mining Supplement standards, developed over an 18-month period that involved three public comment periods, logging the nearly 400 comments received and the RJC's responses. Jewelers of America represents the viewpoint of its members within RJC.