Responsible Sourcing Policy

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 businesses have the responsibility to respect human rights and the ability to contribute to positive human rights impacts. We also recognise that risks of significant adverse impacts may be associated with the extraction, trade, handling, and export of minerals from conflict-affected and high-risk areas.

This Responsible Sourcing Policy (RSP) communicates our commitment to:

  • Respect human rights;
  • Avoid contributing to the finance of conflict;
  • Comply with all relevant UN sanctions, resolutions, and laws;
  • Set clear expectations for suppliers regarding the responsible sourcing of raw materials.

This RSP is aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and is applicable to all precious metals, minerals, diamonds, and coloured gemstones sourced by Canora Diamonds, whether directly or through business partners.

2. Scope

This policy applies to all Canora Diamonds employees and all direct and indirect suppliers globally, including subcontractors.

Finished jewellery is manufactured by our Tier 1 partners in India. We apply enhanced due diligence to these manufacturing partners and require full compliance with this policy, our Supplier Code of Conduct, and applicable Indian labour and environmental laws.

Our RSP requirements are integrated into our Supplier Code of Conduct and contractual conditions. We require suppliers to incorporate these requirements in their own sourcing practices.

3. Our Commitments

Canora Diamonds commits to providing assurance that we:

a. Respect human rights according to the Universal Declaration of Human Rights and ILO Fundamental Rights at Work;

b. Do not engage in or tolerate bribery, corruption, money laundering, or financing of terrorism;

c. Support transparency of government payments and rights-compatible security forces in the extractives industry;

d. Do not provide direct or indirect support to illegal armed groups;

e. Enable stakeholders to voice concerns about the jewellery supply chain; and

f. Implement the OECD framework as a management process for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

4. Serious Abuses

We will neither tolerate nor profit from, contribute to, assist, or facilitate:

a. Torture, cruel, inhuman, and degrading treatment;

b. Forced or compulsory labour;

c. Child labour;

d. Human rights violations and abuses; or

e. War crimes, violations of international humanitarian law, crimes against humanity, or genocide.

We will immediately stop working with upstream suppliers if we find a reasonable risk that they are committing these abuses or are sourcing from any party committing them.

5. Non-State Armed Groups

We only sell or purchase precious metals and diamonds that do not directly or indirectly support non-state armed groups, including procuring from, making payments to, or otherwise helping non-state armed groups or their affiliates who illegally control mine sites, transportation routes, or trading points.

6. Public and Private Security Forces

We affirm that the role of public or private security forces is to provide security in accordance with the rule of law, including laws that guarantee human rights. We will not provide direct or indirect support to security forces that commit abuses.

7. Bribery and Fraudulent Misrepresentation

We will not offer, promise, give, or demand bribes, or misrepresent the origin of precious metals or diamonds. See our Code of Ethics for further information on ethical business conduct.

8. Money Laundering

We will support efforts to eliminate money laundering where we identify a reasonable risk connected to the extraction, trade, handling, transport, or export of precious metals and diamonds.

9. Natural Diamonds

Suppliers sourcing natural diamonds must ensure they are conflict-free as defined by the United Nations, by adhering to:

  • The Kimberley Process Certification Scheme (KPCS);
  • The World Diamond Council (WDC) System of Warranties.

Suppliers shall confirm the WDC statement on every invoice and provide full disclosure of the physical characteristics of stones, including any treatments.

Suppliers must implement measures to prevent the accidental mixing of mined and lab-grown diamonds.

10. Laboratory-Grown Diamonds

Suppliers sourcing lab-grown diamonds must:

  • Disclose the growing method (HPHT or CVD);
  • Ensure lab-grown diamonds are clearly identified and segregated from natural diamonds;
  • Provide supply chain disclosure enabling traceability where possible;
  • Provide full disclosure of physical characteristics, including any treatments.

11. Gemstones and Pearls

Suppliers sourcing gemstones and pearls must ensure they are mined and processed respecting human and labour rights, are conflict-free, and make best efforts to minimise environmental damage. Country of origin must be disclosed at minimum.

12. Precious Metals

Suppliers must source metals responsibly, prioritising recycled metals from legitimate refiners. Evidence of recycled content and chain of custody should be provided on request.

13. Compliance and Remediation

We have a due diligence and risk management approach informed by the UN Guiding Principles and OECD Due Diligence Guidance. If we identify a reasonable risk in our supply chain, we will immediately take appropriate actions.

We reserve the right to suspend or terminate our relationship with a supplier found in breach of this RSP. If a breach cannot be rectified, the relationship will be terminated.

14. Stakeholder Engagement

We engage with internal and external stakeholders to understand human rights-related concerns, strengthen our approach, and monitor performance. We work with suppliers and partners to advance our responsible sourcing commitments.

15. Raising Concerns

Our Speak Up Policy is available to all employees, business partners, and third parties who want to report concerns about possible breaches of this RSP. Contact: policy@canoradiamonds.com

16. Governance

The Director holds accountability for the delivery of our responsible sourcing commitments. This policy is reviewed annually.

17. 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