Canora Diamonds Inc.
Financial Year Ending: 31 December 2026
Last Updated: 1 June 2026
1. Introduction
Canora Diamonds Inc. ("Canora Diamonds", "we", "us", or "our") is opposed to any form of slavery, forced labour, human trafficking, child labour, and other unlawful or unethical practices throughout our business, operations, and supply chain. We do not accept any form of modern slavery in our business or supply chain.
This Statement is reviewed and updated annually as part of our commitment to respecting human rights and preventing any form of modern slavery, forced labour, or child labour in our company and supply chain.
This Statement has been prepared pursuant to:
- Section 54 of the UK Modern Slavery Act 2015 (where applicable to our operations);
- The California Transparency in Supply Chains Act (CTSCA) 2012 (Senate Bill 657);
- Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211), which requires certain entities to report on measures taken to prevent and reduce the risk of forced labour and child labour in their supply chains;
- The EU Corporate Sustainability Due Diligence Directive (CSDDD) and French devoir de vigilance principles, as applicable.
2. Our Business
2.1 Company Overview
Canora Diamonds Inc. is a Canadian corporation incorporated on 13 April 2026 under the Canada Business Corporations Act (Corporation Number: 1785487-1). Our registered office is located at 33 Pindar Crescent, Toronto, Ontario M2J 3L3, Canada.
We design, source, and sell fine jewellery and diamonds — including natural diamonds, laboratory-grown diamonds, and combined jewellery-and-diamond products — to customers in Canada, the United States, and France through our e-commerce platform.
2.2 Business Structure
| Area | Description |
|---|---|
| Head Office | Toronto, Ontario, Canada |
| Sales Channels | E-commerce (Shopify) — online only; no physical retail stores |
| Product Categories | Fine jewellery, loose diamonds (natural and lab-grown), gemstones, bespoke pieces |
| Markets | Canada, United States, France |
2.3 Supply Chain Overview
Our supply chain encompasses the sourcing of raw materials (precious metals, diamonds, gemstones), manufacturing of finished jewellery, packaging, and logistics. We engage suppliers who manufacture, cut, set, and finish our products.
Finished jewellery is produced by our Tier 1 manufacturing partners in India. Loose diamonds and gemstones may be sourced from additional countries depending on product specifications. All finished jewellery items are subject to our supplier due diligence, quality standards, and Supplier Code of Conduct regardless of manufacturing location.
Supply Chain Tiers:
| Tier | Description |
|---|---|
| Tier 1 | Partner factories in India manufacturing finished Canora Diamonds jewellery products |
| Tier 2 | Component manufacturers, chain makers, and gemstone/diamond cutters supplying Tier 1 |
| Tier 3 | Metal refineries and raw material processors |
| Tier 4 | Traders of raw materials (gemstones, diamonds) |
| Tier 5 | Extraction or creation of raw materials (mines, lab-grown diamond producers) |
We recognise that the primary modern slavery and human trafficking risks in our industry exist within the supply chain, notably in the sourcing of raw materials and product manufacturing.
3. Our Policies
We have implemented a suite of policies to address modern slavery and human rights risks:
| Policy | Purpose |
|---|---|
| Human Rights Policy | Sets out our commitment to respecting human rights across operations and supply chain |
| Responsible Sourcing Policy | Addresses conflict minerals, ethical sourcing of diamonds and precious metals |
| Supplier Code of Conduct | Minimum standards for all suppliers |
| Code of Ethics | Ethical business conduct for all employees and partners |
| Speak Up Policy | Mechanism for reporting concerns confidentially |
| Environmental Policy | Environmental stewardship throughout our value chain |
4. Risk Assessment
4.1 Salient Human Rights Risks
Based on our industry and supply chain geography, we have identified the following salient human rights risks:
| Risk Area | Description | Priority |
|---|---|---|
| Forced labour | Risk in manufacturing facilities, particularly in high-risk geographies | High |
| Child labour | Risk in gemstone cutting and informal manufacturing | High |
| Health and safety | Workshop conditions in jewellery manufacturing | Medium |
| Wages and working hours | Non-payment of minimum/living wages, excessive overtime | High |
| Freedom of association | Restrictions on workers' rights to organise | Medium |
| Migrant workers | Exploitation of non-native workers, recruitment fees | High |
4.2 Geographic Risk
We assess the human rights context of countries where our suppliers operate, utilising global indices and country risk assessments. As our finished jewellery is manufactured in India, we apply enhanced due diligence to our Indian manufacturing partners, including labour practices, working conditions, wages, and health and safety standards. Suppliers in other countries identified as higher risk undergo similar enhanced due diligence.
5. Due Diligence
5.1 Supplier Onboarding
Before engaging a new supplier, we conduct due diligence including:
- Completion of a Know Your Counterparty (KYC) questionnaire;
- Review of the supplier's country of operation and associated risk profile;
- Verification that the supplier agrees to our Supplier Code of Conduct;
- Assessment of labour practices, health and safety standards, and environmental compliance;
- Background checks where appropriate.
5.2 Ongoing Monitoring
- All Tier 1 suppliers sign our Supplier Code of Conduct annually;
- We conduct periodic supplier assessments and site visits where practicable;
- We require suppliers to report any breaches of our Code promptly;
- Non-compliances are addressed through corrective action plans with defined timelines;
- Failure to remediate may result in suspension or termination of the supplier relationship.
5.3 Diamond and Precious Metal Sourcing
- Natural diamonds are sourced in compliance with the Kimberley Process Certification Scheme and the World Diamond Council System of Warranties;
- We do not source from Conflict-Affected and High-Risk Areas (CAHRAs) without enhanced due diligence;
- Precious metals are sourced from responsible refiners with verifiable chain of custody where possible.
6. Accountability and Governance
| Role | Responsibility |
|---|---|
| Board of Directors / Director | Overall accountability for human rights and modern slavery commitments |
| Management | Day-to-day implementation of policies and due diligence |
| All Employees | Uphold human rights standards and report concerns via Speak Up channels |
7. Training
We are committed to providing human rights and modern slavery awareness training to all employees. Training covers:
- Identifying signs of modern slavery and human trafficking;
- Our policies and reporting mechanisms;
- Supplier due diligence responsibilities for relevant roles.
8. Grievance Mechanism
We maintain a Speak Up Policy that enables employees, suppliers, and third parties to report concerns about modern slavery, human rights violations, or unethical conduct. Reports can be made:
- Email: policy@canoradiamonds.com
- Mail: Canora Diamonds Inc., 33 Pindar Crescent, Toronto, Ontario M2J 3L3, Canada
Reports may be made anonymously where permitted by law. We prohibit retaliation against anyone who reports concerns in good faith.
9. Remediation
If we identify modern slavery or forced labour in our operations or supply chain, we will:
- Investigate the allegation promptly and thoroughly;
- Require the supplier to develop and implement a corrective action plan;
- Monitor remediation progress;
- Suspend or terminate the relationship if remediation is not achieved;
- Report to relevant authorities where appropriate.
10. Continuous Improvement
We are committed to continuously improving our approach to preventing modern slavery. Planned actions include:
- Expanding supplier due diligence to additional supply chain tiers;
- Implementing annual employee training on human rights and modern slavery;
- Reviewing and updating all related policies annually;
- Increasing supply chain traceability for diamonds and precious metals;
- Engaging with industry initiatives and standards (e.g., Responsible Jewellery Council).
11. Approval
This Statement has been approved by the Director of Canora Diamonds Inc.
Meet Sureshbhai Manani
Director, Canora Diamonds Inc.
Date: 1 June 2026
12. Contact
Canora Diamonds Inc.
33 Pindar Crescent, Toronto, Ontario M2J 3L3, Canada
Email: policy@canoradiamonds.com
Under Bill S-211, Canora Diamonds Inc. must file an annual report with the Government of Canada if the company meets applicable revenue, asset, or employee thresholds. Consult legal counsel to determine filing obligations.