DIAMOND MANUFACTURERS & IMPORTERS ASSOCIATION OF AMERICA

(DMIA, INC.)

Member Code of Conduct (Adopted 2008)

Preamble: It is the policy of the Diamond Manufacturers & Importers Association of America (“DMIA”) that its members shall observe the highest standards of business and personal conduct in all activities relating to the business of diamonds and diamond jewelry, including:

  1. Ethical behavior in their activities.
  2. Compliance with the spirit, as well as the letter, of all applicable domestic and international laws, rules and regulations.
  3. Avoidance of activities that may damage or reflect adversely upon the good name, reputation and worldwide image of the diamond industry.
  4. Develop, maintain and promote high ideals and standards of practice for all industry participants.

Legal Compliance: DMIA members shall respect and comply with all applicable international, national and local laws, rules and regulations which apply to the diamond industry and to the lawful conduct of business generally.

DMIA members shall be especially aware of and compliant with the following:

  1. Regulatory provisions of the Kimberley Process (a joint initiative of governments, the international diamond industry, and civil society to stem the flow of conflict diamonds).
  2. Domestic and international Anti-money laundering laws, rules and regulations which seek to halt use of diamonds for any illegal or illicit purposes.
  3. The United States Federal Trade Commission’s “Guides for the Jewelry, Precious Metals and Pewter Industries” (16 CFR Part 23), including, but not limited to the FTC Guide’s definition of a “diamond” as well as the provisions therein requiring full and accurate disclosure of diamond weight and/or all diamond treatments.
  4. Laws, rules, regulations and industry-developed standards requiring full and honest disclosure in the advertisement, sale and distribution of industry products.

Rules of Business Conduct: We recognize that DMIA members are economic entities engaged in the diamond business for profit. Nevertheless, members of the diamond trade, in addition to being economic entities, shall observe the highest standards of business conduct, including:

  1. Promoting standards of honesty and integrity in all business dealings.
  2. Engaging in fair, transparent, free and open competition.
  3. Providing full and accurate disclosure in the advertisement, sale and distribution of any industry product. d. Promoting social responsibility.
  4. Compliance with all international, national and local laws, rules and regulations.
  5. Developing and promoting industry standards which advance the highest standards of honesty, integrity and ethical behavior for observance by all industry participants.

Fair and Ethical Labor Practices: DMIA members shall engage in fair and ethical labor practices, including:

  1. Treating all employees with respect and dignity. No employee shall be subjected to any physical, sexual, psychological or verbal harassment or abuse.
  2. Refraining from all discrimination, including discrimination based upon gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.
  3. Providing a safe and healthy working environment, and to the extent possible, free from danger of accident and injury to the health, physical or emotional well-being of employees.
  4. Paying fair and reasonable wages and benefits which are essential to meeting the employees’ basic needs. In no event shall the minimum wage paid or the benefits provided to employees fall below the minimum wage or benefits required by local law. e. Consulting with labor organizations.

Commitment to the Best Interests of Customers and Consumers: DMIA members shall strive to act fairly, honestly and ethically in all business dealings, provide full disclosure, and accurately and honestly represent their products in all advertising, promotion and sales. DMIA members shall not engage in deceptive, deceitful or dishonest trade practices. In their dealings with all other members of the diamond and jewelry industry, DMIA members shall encourage suppliers, vendors and subcontractors whose trade and business practices comply with the requirements of this code of conduct.

DMIA members will seek to foster a level playing field for all industry participants.

Commitment to Society and the World at Large: As participants in an important global industry, DMIA members can and should seek to make a contribution to the advancement of our society and to the world at large.

We therefore have a responsibility to:

  1. Respect human rights and democratic institutions and promote them whenever possible.
  2. Support policies and programs, which promote human development through harmonious relations between the diamond industry and other segments of society.
  3. Maintain a dedication to raising standards of health, education, workplace safety and economic well-being.
  4. Promote and stimulate sustainable development in preserving and enhancing the physical environment and the earth’s resources.
  5. Engage in trade practices and support programs which encourage peace, security, diversity, social integration and the economic and social advancement of disadvantaged nations.

Compliance with the Code: The future of the diamond industry depends on compliance by all DMIA members and all other industry participants with the principles and standards expressed in this Code of Conduct.

Each member should encourage and support adherence by other industry members. We recognize that the diversity and global nature of the international diamond industry may pose obstacles to the enforcement of this Code.

Nevertheless, any material violation of this Code of Conduct may result in termination of DMIA membership.