Merchandise Vendor Manual
March 12, 2009
Code of Conduct
Zale Corporation values its reputation as a company that maintains the highest
standards of ethical business conduct and corporate social responsibility and that treats
its customers with honesty and integrity. Zale strives to promote stable, sustainable,
long-term relationships with its vendors and other business partners based on the
principles of mutual trust and fair dealing. Accordingly, Zale requires its merchandise
vendors, as a condition of doing business with Zale, to conduct their businesses in a
lawful and responsible manner and to certify adherence to the Zale Corporation Vendor
Code of Conduct. (the “Code”).
Compliance with Applicable Law, Rules and Regulations
1. Vendors must comply with applicable laws, rules and regulations regarding the
same of jewelry including, without limitation, customs regulations, import/export
laws, including, without limitation, provisions governing
GSP, NAFTA, CBERA,
GPT, ATPA and IFTA or any other applicable trade programs, stamping and
tagging requirements, trademark registration laws, labor laws, tax laws, foreign
corrupt practices laws and laws prohibiting deceptive trade practices.
2. Jewelry vendors must comply with the FTC’s “Guides for Jewelry, Precious
Metals and Pewter Industries”.
3. Vendors must guarantee and warrant, as provided in this code, that the
diamonds they supply to Zale are conflict free.
4. Vendors must ensure that the products sold to Zale do not violate the patent,
trademark, copyright or other proprietary rights of any third person or entity.
5. Vendors must comply with their national labor and environmental laws, rules and
regulations. In addition, Zale expects its vendors to respect the fundamental
International Labor Organization conventions and the Universal Declaration of
Human Rights. Where the Code or applicable laws address the same issue, Zale
expects its vendors, at minimum, to be in compliance with the applicable legal
requirements of the country in which they operate.
6. In the event that Zale conducts an internal investigation regarding any practices
regulated by this Code, vendors must cooperate fully in that investigation
including for example, by making all relevant records available and providing all
relevant employees for interviews.
1. With respect to product fabricated from rough diamonds mined on or after
January 1, 2003, vendors guarantee that all diamonds provided to Zale have
Prohibition against Conflict Diamonds