Canora Diamonds Inc.
Version: 1.0
Effective Date: 1 June 2026
Last Updated: 1 June 2026
1. Introduction
Canora Diamonds Inc. ("Canora Diamonds", "we", "us", or "our") recognises that business has the responsibility to respect human rights and the ability to contribute to positive human rights impacts. People and respect for human rights are at the core of our values and a key element of conducting business responsibly.
In addition to abiding by applicable law and regulation, we are committed to respecting the internationally recognised human rights of all stakeholders relevant to our operations, including employees, supply chain workers, communities, and consumers.
We are committed to upholding:
- The United Nations Guiding Principles on Business and Human Rights (UNGPs);
- The International Bill of Human Rights;
- The International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work;
- The OECD Guidelines for Multinational Enterprises;
- The UN Global Compact Ten Principles.
Where there is a conflict between a legal requirement and this policy, we will seek to apply the higher standard while complying with all applicable laws.
2. Scope
This Policy applies to everyone working for Canora Diamonds worldwide, regardless of location, role, or level of seniority. This includes all employees, managers, and directors.
We require that temporary and contract employees, consultants, agents, and any third party acting in the Company's name comply with the principles of this Policy.
We only work with business partners who share and uphold the same values, and expect our supply chain to meet the human rights standards set out in this policy and our Supplier Code of Conduct.
3. Our Commitments
Consistent with our commitment and in accordance with applicable law, we:
- Respect and promote human rights in our operations and entire value chain;
- Work to avoid infringing on human rights and address adverse impacts we may cause or contribute to;
- Identify, prevent, and mitigate possible human rights risks through appropriate due diligence;
- Promote and respect the rule of law and comply with applicable law in every country where we operate;
- Operate within the framework of our Code of Ethics;
- Respect the environment and minimise our impact, recognising that environmental interactions affect people;
- Value dialogue with stakeholders in our value chain;
- Provide an accessible, transparent, fair, and equitable grievance procedure;
- Are transparent about policies, activities, and risks, and report on human rights impacts regularly.
4. Respect for Human Rights in Our Operations
4.1 Child Labour
We do not practice or tolerate any form of child labour. Consistent with ILO standards, we prohibit the employment of children under the age of 16 (or the legal minimum age, whichever is higher). No employee under 18 shall perform hazardous work.
We reserve the right to terminate any business relationship if child labour is found in a business partner's operations.
4.2 Forced Labour and Human Trafficking
We prohibit any form of forced labour, bonded or indentured labour, slavery, or human trafficking throughout our operations and supply chain. We undertake due diligence to assess and address risks of modern slavery and report annually under our Modern Slavery Statement.
4.3 Vulnerable Groups
We acknowledge and respect the rights of vulnerable groups, including indigenous peoples, ethnic and religious minorities, migrants, refugees, LGBTQ+ individuals, and women. We prohibit the charging of recruitment fees to workers and require clear, written employment terms in a language workers understand.
4.4 Wages, Working Hours, and Benefits
We operate in full compliance with applicable laws relating to wages, working hours, paid time off, and benefits. We are committed to paying fair wages that meet or exceed applicable legal minimums.
4.5 Diversity and Non-Discrimination
We are an equal opportunities employer. We do not tolerate discrimination based on age, race, gender, disability, sexual orientation, religion, political opinion, or any other characteristic protected by law.
4.6 Harassment
We are committed to providing a secure working environment free from verbal, psychological, sexual, or physical harassment, abuse, or threats.
4.7 Freedom of Association
We respect the principles of freedom of association and the right to collective bargaining, in accordance with applicable law.
4.8 Safe, Secure, and Healthy Workplace
We are committed to providing a safe, secure, and healthy workplace, promoting a safety culture and supporting positive mental health.
4.9 Job Security and Fair Dismissal
We respect employees' rights to job security and protection against unfair dismissal. Termination decisions must follow fair, transparent, and legally compliant processes.
5. Engaging With Business Partners
We want to work with business partners that share our commitments to human rights, safety, and ethics. We expect our suppliers to comply with our Supplier Code of Conduct and Responsible Sourcing Policy.
We expect business partners to uphold these standards in their relations with their own suppliers and to act transparently with a commitment to continuous improvement.
6. Human Rights Due Diligence
Our due diligence approach is informed by the UN Guiding Principles and the OECD Due Diligence Guidance:
- Commit and embed human rights;
- Identify and assess risks;
- Cease, prevent, or mitigate adverse impacts;
- Monitor performance;
- Communicate progress;
- Provide remediation.
We apply a risk-based approach to prioritise supplier engagement based on supply chain tier, geographic risk, spend level, and severity of potential impacts. As our finished jewellery is manufactured in India, we prioritise due diligence and ongoing monitoring of our Indian manufacturing partners.
Triggers for re-assessment include supplier onboarding, product expansion, and geographic expansion.
6.1 Mitigation and Remediation
If we determine that a business partner has violated human rights, we will require corrective action, support remediation where appropriate, and may suspend or terminate the relationship. Violations by employees will be addressed through our disciplinary procedures.
7. Raising Concerns
Our Speak Up Policy is available to all employees, business partners, and interested third parties who want to report human rights violations. Reports can be made to policy@canoradiamonds.com. Anyone raising a concern in good faith is protected from retaliation.
8. Governance and Review
| Role | Responsibility |
|---|---|
| Director | Overall accountability for human rights commitments |
| Management | Implementation and monitoring |
| All Employees | Respect human rights in daily roles; report concerns |
This policy is reviewed annually and approved by the Director.
9. Communication and Training
We communicate this policy publicly and internally. Employee training on human rights will be conducted to build awareness and capability.
10. 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
Email: policy@canoradiamonds.com