Canora Diamonds Inc.
Version: 1.0
Effective Date: 1 June 2026
Last Updated: 1 June 2026
Foreword from the Director
Our Code of Ethics is an important document that shows how we integrate ethical thinking into our everyday culture. Our ambition is to be a leader in ethical and sustainable practices in the jewellery and diamond industry. This Code should guide our decision-making. If you are unsure whether a decision is ethical, ask questions, collaborate with colleagues, and contribute to our culture of integrity.
Please read this Code carefully. It is up to everyone to ensure that our core values are upheld in our daily work.
Meet Sureshbhai Manani
Director, Canora Diamonds Inc.
1. What Is the Code of Ethics?
Canora Diamonds Inc. ("Canora Diamonds", "we", "us", or "our") is committed to maintaining a reputation as an ethical and socially responsible company. Our Code of Ethics provides a guide to the policies, standards, and procedures that govern how we do business.
By following this Code and acting with integrity, each of us plays an integral role in supporting our culture of ethics.
This Code is organised into three categories:
- As a business
- As an employer
- As a responsible corporate citizen
2. Who Is Responsible?
This Code applies to everyone in the company — directors, employees, contractors, and agents — wherever they work.
Our Director is responsible for adopting this Code. Management is responsible for promoting, monitoring, and enforcing it. We are all responsible for ethical decision-making.
3. Personal Responsibility
Act with integrity and follow this Code. Our reputation is built by each of us, one decision at a time.
As a matter of policy, we must:
- Respect and follow this Code of Ethics;
- Respect all people and all cultures;
- Lead with sustainable thinking;
- Consider the planet and our effect on it;
- Always do what is right; and
- Be accountable for our actions.
4. Our Commitments as a Business
4.1 Integrity
Canora Diamonds conducts business ethically, honestly, and in full compliance with all applicable laws, regulations, and sanctions in Canada, the United States, and France.
We are committed to operating transparently, engaging with stakeholders, conducting risk assessments, and putting controls in place to mitigate risks.
4.2 Our Products
We are committed to creating beautiful, high-quality jewellery and diamonds that meet all quality and ethical requirements. All decisions must account for the quality and ethical standards of our products.
We clearly disclose whether diamonds are natural or lab-grown. See our Diamond and Jewellery Disclosure Policy.
4.3 Business Partners
We work with business partners who share our values, comply with law, and demonstrate high ethical standards. All potential partners must undergo due diligence before engagement.
When onboarding partners, we share at minimum:
- Our Supplier Code of Conduct (for suppliers)
- Our Human Rights Policy
4.4 Supplier Selection
All suppliers must comply with our Supplier Code of Conduct as a condition of doing business with us. Supplier selection must be based on merit, quality, and reputation — not personal relationships or unlawful incentives.
4.5 Fair Treatment of Business Partners
We nurture relationships built on fairness, mutual respect, non-discrimination, and sustainability. We will never take advantage of partners through manipulation, misuse of facts, or unfair negotiation tactics.
4.6 Conflicts of Interest
Avoid conflicts between personal interests and Canora Diamonds' interests. Disclose any potential conflict to management. Having a conflict is not a violation; failing to disclose it is.
4.7 Gifts and Entertainment
Exercise good judgement when giving or accepting gifts. Gifts must be:
- In good faith, occasional, reasonable, and appropriate;
- A normal business courtesy; and
- Transparent.
Never give or accept gifts intended to influence decision-making, in the form of cash, or associated with public officials in a manner that could be interpreted as bribery.
4.8 Bribery and Corruption
We have zero tolerance for bribery and corruption. Never offer or accept a bribe. Keep accurate financial records. Report any suspected bribery immediately.
4.9 Advertising and Marketing
Represent our products and sustainability work truthfully. Never overstate product qualities, use misleading information, or make unsubstantiated claims.
4.10 Confidential Information and Intellectual Property
Protect confidential information and intellectual property belonging to Canora Diamonds and our business partners. Do not share without proper authorisation.
4.11 Privacy and Data Protection
Uphold privacy rights and comply with legal obligations. See our Privacy Policy.
4.12 Financial Records and Anti-Money Laundering
Maintain accurate financial records. Be alert to red flags such as suspicious refund requests or unusual payment terms. Report concerns to management immediately.
5. Our Commitments as an Employer
5.1 Human Rights
We respect human rights across our business and supply chain. See our Human Rights Policy.
5.2 Health and Safety
We provide a safe working environment and expect employees to minimise health and safety risks, report accidents, and follow emergency procedures.
5.3 Diversity, Equity, and Inclusion
Every individual must be treated with respect and dignity. We do not tolerate discrimination or harassment.
5.4 Harassment and Bullying
We provide a secure environment free from harassment, abuse, or threats. Report any instances witnessed in our operations or supply chain.
6. Our Commitments as a Responsible Corporate Citizen
6.1 Environmental Stewardship
We seek to minimise our environmental impact. See our Environmental Policy.
6.2 Political Activities
Canora Diamonds does not make donations to political parties or candidates. Employees may engage in personal political activity but must make clear their views are their own, not the company's.
6.3 Community Contribution
We seek to have a positive impact on communities through ethical business practices and responsible sourcing.
7. Raising Concerns
We foster a culture of openness. If you have a concern, speak to your manager or contact policy@canoradiamonds.com. See our Speak Up Policy.
8. Version Control
| Version | Date | Notes |
|---|---|---|
| 1.0 | June 2026 | Initial policy |
Approved by: Meet Sureshbhai Manani, Director
Date: 1 June 2026
Canora Diamonds Inc.
33 Pindar Crescent, Toronto, Ontario M2J 3L3, Canada