Blue nileEDUCATION. GUIDANCE. DIAMONDS AND FINE JEWELRY

Statement of Policy

Blue Nile, Inc. (the "Company") is committed to providing a workplace conducive to open discussion of our business practices and is committed to complying with the laws and regulations to which we are subject, as well as our Code of Ethics (our "Code"). Accordingly, the Company will not tolerate conduct that is in violation of such laws, regulations or our Code. Each employee has a responsibility to promptly report any suspected misconduct, illegal activities or fraud, including any questionable accounting, internal accounting controls and auditing matters, or other violations of federal and state laws or of our Code (collectively "Misconduct") in accordance with the provisions of this policy. Any other third party, such as vendors, consumers, stockholders or competitors also may report, under the procedures provided in this policy, a good faith compliant regarding accounting or auditing matters. In order to facilitate the reporting of communications regarding alleged Misconduct, the Audit Committee of our Board of Directors (the "Audit Committee") has established procedures for (i) the submission by employees of reports of alleged Misconduct and (ii) the receipt, retention and treatment of these reports.

Policy of Non-Retaliation

It is our policy to comply with all applicable laws that protect our employees against unlawful discrimination or retaliation as a result of their lawfully reporting information regarding, or their participation in investigations involving alleged Misconduct by the Company or its agents. Specifically, our policy is designed to prevent employees from being subject to disciplinary or retaliatory action by the Company or any of its agents or employees as a result of an employee's:

If any employee believes he or she has been subjected to any discrimination or retaliation or other action by us or our agents for reporting suspected Misconduct in accordance with this policy, he or she may file a complaint with our Compliance Officer by following the procedures set forth below under the heading "Method of Reporting." If it is determined that an employee has experienced any improper employment action in violation of this policy, we endeavor to promptly take appropriate corrective action.

Method of Reporting

The Audit Committee of the Board of Directors of the Company (the "Audit Committee") has designated the Chairman of the Audit Committee as the Compliance Officer responsible for administering this policy. The Compliance Officer will be assisted by the Ethics Compliance Officer established by the Code in the administration of this policy with respect to alleged violations of the Code by individuals other than executive officers and directors. We have established a procedure under which alleged Misconduct, including alleged Misconduct relating to questionable accounting, internal accounting controls or auditing matters may be reported anonymously and confidentially. Employees may anonymously report (unless submitted via email) an alleged violation to (i) our Compliance Hotline at (866) 292-4481, (ii) our Compliance Email Box at http://www.ethicspoint.com, or by delivering the report via regular mail to c/o Audit Committee, Blue Nile, Inc., 705 Fifth Avenue S, Suite 900, Seattle, Washington 98104. Reports regarding retaliation for reporting suspected Misconduct may also be reported by any of these methods.

If a reporting employee wishes to disclose his or her identity, the employee may do so. Confidentiality of the employee submitting the report will be maintained to the fullest extent possible, consistent with the need to conduct an adequate investigation. In the course of any investigation, we may find it necessary to share information with others on a "need to know" basis.

Employees should make every effort to report their concerns using one or more of the methods specified above. The reporting procedure is specifically designed so that employees have a mechanism that allows the employee to bypass a supervisor he or she believes is engaged in prohibited conduct under this policy. Anonymous reports should be factual instead of speculative or conclusory, and should contain as much specific information as possible to allow the persons investigating the report to adequately assess the nature, extent and urgency of the situation. Employees should realize that if an anonymous report cannot be properly investigated without additional information, we may have to close the matter for lack of sufficient information.

Policy for Receiving and Investigating Reports

Upon receipt of any reported violation of the Code by any person other than an executive officer or director of the Company, the Ethics Compliance Officer will determine whether the information alleged in the report alleges or contains allegations that might constitute a violation of the Code. To the extent the Ethics Compliance Officer deems appropriate, the Ethics Compliance Officer will appoint one or mor internal and/or external investigators to promptly and fully investigate such report under the supervision of the Ethics Compliance Officer. The Ethics Compliance Officer shall, to the extent deemed appropriate, consult with the Compliance Officer and Audit Committee with respect to conduct or results of any such investigation. The Ethics Compliance Officer will inform the reporting person (if his or her identity is known) that the report has been received and, to the extent appropriate, provide him or her with the name of, and contact information for, the investigator assigned to the report.

With respect to any other report pursuant to this policy, upon receipt of such report, the Compliance Officer will determine whether the information alleged in the report alleges or contains allegations that might constitute Misconduct. The Audit Committee shall be notified promptly of reports of alleged Misconduct determined to involve accounting, internal accounting controls and auditing concerns or alleged violations of the Code by executive officers or directors of the Company. The Audit Committee will, to the extent it deems appropriate, appoint one or more internal and/or external investigators to promptly and fully investigate claims of alleged Misconduct, under the supervision of the Compliance Officer, or, in the case of (i) alleged Misconduct relating to accounting, internal accounting controls and auditing concerns or (ii) alleged violations of the Code by executive officers or directors of the Company, under the supervision and oversight of the Audit Committee or such other persons as the Audit Committee determines to be appropriate under the circumstances. The Compliance Officer will inform the reporting person (if his or her identity is known) that the report has been received and, to the extent appropriate, provide him or her with the name of, and contact information for, the investigator assigned to the report.

If the investigation confirms that Misconduct has occurred, we will promptly take appropriate corrective action with respect to the person(s) involved, including possible termination of such person(s), and will also take appropriate steps to correct and remedy any Misconduct.

Retention of Reports

The Compliance Officer and Ethics Compliance Officer will maintain a log of all reports, tracking their receipt, investigation and resolution. Each member of the Audit Committee and, at the discretion of the Compliance Officer or Ethics Compliance Officer, as appropriate, other personnel involved in the investigation of reports, shall have access to the log. Copies of the log and all documents obtained or created in connection with any investigation will be retained for a period of three years.