Last updated: August 29, 2011

We at the Rapaport Group of Companies (“Rapaport”) are proud of our tradition of conducting our business in accordance with the highest moral and ethical standards and in compliance with the laws of the countries in which we operate.

Rapaport is committed to legal compliance and ethical business practices in all its operations and seeks to do business with those who share that commitment.

Rapaport will only do business with those who obey the laws of the country in which they operate and follow the principles expressed in this Code of Conduct.

Rapaport will only do business with entities or individuals who have certified to us that their business practices are lawful, ethical and in compliance with the principles set forth in this Code of Conduct.

Rapaport Minimum Human Rights Standard: All diamonds that are legal and not directly involved in severe human rights violations should be freely, fairly and legally traded. For the purposes of the foregoing, the phrase “directly involved in severe human rights violations” is defined as diamonds whose physical production involved murder, rape, physical violence or forced servitude.

Legal and Ethical Business Practices: All Users, Subscribers, Customers and Suppliers must fully comply with all applicable local, state, federal, national and international laws, rules and regulations. Subscribers, customers and suppliers must be ethical in their business practices and act in such a way so as not to bring the diamond, gem and jewelry industry or Rapaport into disrepute.

Conflict Diamonds: We recognize the great harm done to local populations as a result of conflict in diamond mining/trading areas. Rapaport will not purchase, sell or in any way deal with conflict diamonds, nor will it contract with subscribers, customers or suppliers who purchase or trade in diamonds which were used to fund conflict or are traded in any way in violation of any United Nations resolutions or the Kimberley Process. No subscriber may list or trade diamonds through Rapaport or any service offered by Rapaport businesses, including RapNet® and Rapaport Auctions, which do not meet the Kimberley Process standards ,the Rapaport Code of Conduct and Rapaport Minimum Human Rights Standards.

Forced Labor: No diamonds that were mined, cut, polished or in any way produced using child labor, forced labor, prison labor, indentured labor or exploited bonded labor may be listed, or traded through Rapaport businesses, including RapNet and Rapaport Auctions.

Treatment: Rapaport is committed to the highest level of disclosure regarding any treatment to natural diamonds and requires all subscribers, customers and suppliers to fully disclose any and all treatment and processes performed on any diamond listed or traded through Rapaport businesses. No heat treated (HPHT) or synthetic diamonds may be listed or traded through Rapaport businesses, including RapNet and Rapaport Auctions, without full disclosure when listing the treated diamond.