ANTI-MONEY LAUNDERING POLICY
1. Introduction
1.1 As a company, we are committed to carrying on business in accordance with the highest
ethical standards. This includes complying with all applicable laws and regulations aimed at
combating money laundering and terrorist financing.
This Policy has been developed by Designer for Less by WCS Jewelry LLC to reduce the risk
of money laundering and terrorist financing associated with its business and the sale of its
products. This Policy explains our individual responsibility in complying with anti-money
laundering and counter terrorist financing laws ("AML Laws") around the world and ensuring that
any third parties that we engage to act on our behalf, do the same. 1.2 The management of
Designer for Less by WCS Jewelry LLC is committed to complying with all laws. Any employee
who violates the rules in this Policy or who permits anyone to violate those rules may be subject
to appropriate disciplinary action, up to and including dismissal, and may be subject to personal
civil or criminal fines. 1.3 If you have any questions about this Policy you should contact the
Ethics and Compliance or the Legal Department.
2. Policy Statement on AML
2.1 It is our policy to comply with all applicable AML Laws in our operations worldwide. To this
end, DFL by WCS Jewelry LLC will only conduct business with customers who are involved in
legitimate business activity and whose funds are derived from legitimate sources. 2.2 This
Policy is intended to help employees, contractors, and other third parties acting on the
company’s behalf to understand where breaches of AML Laws might arise and to support them
in making the right decisions in line with our corporate position as stated in this Policy.
3. Management Endorsement
3.1 Management will not criticise management for any loss of business resulting from
adherence to this Policy. No employee or contractor will suffer as a consequence of bringing to
the attention of the Board or senior management, in good faith, a known or suspected breach of
this Policy nor will any employee or contractors suffer any adverse employment or contract
decision for abiding by this Policy.
4. Who is subject to this Policy?
4.1 This Policy applies to Designer for Less by WCS Jewelry LLC’'s operations globally,
including all legal entities worldwide owned or controlled by Designer for Less by WCS Jewelry
LLC (including all group companies), and to all directors, officers, employees, contractors, and
other third parties acting on behalf of the foregoing.

5. What’s the risk?
5.1 Violations of AML Laws may lead to severe civil and/or criminal penalties against companies
and individuals, including significant monetary fines, imprisonment, extradition, blacklisting,
revocation of licences, and disqualification of directors. 5.2 In addition, violations of AML Laws
can lead to damaging practical consequences, including harm to reputation and commercial
relationships, restrictions in the way we can do business, and extensive time and cost in
conducting internal investigations and/or defending against government investigations and
enforcement actions.

6. What do we mean by Money Laundering and Terrorist Financing?
6.1 Money laundering means exchanging money or assets that were obtained criminally for
money or other assets that are ‘clean’. The clean money or assets don’t have an obvious link
with any criminal activity. Money laundering also includes money that’s used to fund terrorism,
however it’s obtained. 6.2 The following types of activities are considered to be “money
laundering” and are prohibited under this Policy: a) the conversion or transfer of property
(including money), knowing or suspecting that such property is derived from criminal or certain
specified unlawful activity ("criminal property"), for the purpose of concealing or disguising the
illicit origin of the property or of assisting any person who is involved in the commission of such
activity to evade the legal consequences of his action; b) conducting a financial transaction
which involves criminal property; c) the concealment or disguise of the true nature, source,
location, disposition, movement, rights with respect to, ownership or control of criminal property;
d) the acquisition, possession or use of criminal property; e) promoting the carrying on of
unlawful activity; and f) participation in, association to commit, attempts to commit and aiding,
abetting, facilitating and counselling the commission of any of the actions mentioned in the
foregoing points. 6.3 The broad definition of money laundering means that anybody (including
any Designer for Less by WCS Jewelry employee) could be in violation of the law if he/she
becomes aware of, or suspects, the existence of criminal property within the business and
becomes involved in or continues to be involved in a matter which relates to that property being
linked to the business without reporting his/her concerns. 6.4 Property can be criminal property
where it derives from any criminal conduct, whether the underlying criminal conduct has taken
place in the country where you are situated or overseas. 6.5 Terrorist financing may not involve
the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of
the funds, which will later be used for criminal purposes

7. Red Flags
7.1 Where any suspicions arise that criminal conduct may have taken place involving a
customer, colleague or third party, you should consider whether there is a risk that money
laundering or terrorist financing has occurred or may occur. 7.2 Some examples of red flags to
be reported include: A customer provides insufficient, false or suspicious information or is
reluctant to provide complete information Methods or volumes of payment that are not
consistent with the payment policy or that are not customarily used in the course of business,
e.g., payments with money orders, traveller’s checks, and/or multiple instruments, and
payments from unrelated third parties Receipts of multiple negotiable instruments to pay a
single invoice Requests by a customer or partner to pay in cash Early repayments of a loan,
especially if payment is from an unrelated third party or involves another unacceptable form of
payment Orders or purchases that are inconsistent with the customer’s trade or business
Payments to or from third parties that have no apparent or logical connection with the customer
or transaction Payment to or from countries considered high risk for money laundering or
terrorist financing Payments to or from countries considered to be tax havens or offshore
jurisdictions. Payments from countries unrelated to the transaction or not logical for the
customer A customer’s business formation documents are from a tax haven, or a country that
poses a high risk for money laundering, terrorism or terrorist financing, or a country that is not
logical for the customer Overpayments followed by directions to refund a payment, especially if
requested to send the payment to a third party Any customer for whom you cannot determine
the true beneficial owner Structuring transactions to avoid government reporting or record
keeping requirements Unusually complex business structures, payment patterns that reflect no
real business purpose Wire transfer activity that is not consistent with the business activities of
the customer, or which originates or terminates with parties unrelated to the transaction
Unexpected spikes in a customer’s activities The above is not intended to be an exhaustive list.
Deviation from customer and accepted business practice should alert you to further investigate
the activity in accordance with this Policy.

8. Compliance Controls
8.1 Senior management in each Designer for Less by WCS Jewelry LLC business are
responsible for ensuring that their business has a culture of compliance and effective controls to
comply with AML laws and regulations to prevent, detect and respond to money laundering and
counter-terrorism financing and to communicate the serious consequences of non-compliance
to employees.

9. Employee Responsibility
9.1 You have the obligation to read and follow this Policy, to understand and identify any red
flags that may arise in their business activities and to escalate potential compliance concerns
related to AML to Ethics and Compliance or the Legal Department without notifying anyone
involved in the transaction and should not take any actions prior to receiving advice and/or
instructions.
10. Due Diligence and Record Keeping
10.1 It is our policy to carry out due diligence ("DD") at the outset of any business relationship
and, if necessary, where any red flags arise subsequently on our suppliers, distributors,
counterparties, agents and any person with whom Designer for Less by WCS Jewelry LLC has
an established business relationship that will involve the transfer to or receipt of funds
("Customers"), so we can be satisfied that they are who they say they are and so that we can
ensure that there are no legal barriers to working with them before contracts are signed or
transactions occur. Various factors will determine the appropriate forms and levels of screening.
10.2 You should escalate any instances where you have cause for suspicion as a result of
carrying out DD and ongoing monitoring to Ethics and Compliance or the Legal Department,
who will advise them regarding which tools and processes should be used to facilitate
appropriate screening. 10.3 You must, in consultation with the Ethics and Compliance or the
Legal Department, carefully consider screening outcomes before deciding whether to do
business with the third party.
10.4 Finance managers must regularly monitor and/or review Customers to identify business
activity or governance that could indicate money laundering or terrorist financing is taking place.
10.5 Record-keeping is an essential component of the audit trail required to assist in any
investigation. You must maintain records as evidence of the DD and ongoing monitoring
undertaken.
11. Non-compliance
11.1 Any Designer for Less by WCS Jewelry LLC employee or contractor, who violates this
Policy may be subject to appropriate disciplinary action, independently from potential other
penalties resulting from their behaviour. 11.2 Internal Audit shall conduct regular checks on local
businesses to ensure compliance with AML Laws.
12. Updates, Review and Ownership
12.1 This Policy may be updated from time, and the updated version of the Policy will be
immediately made available on the Designer for Less by WCS Jewelry LLC website.