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") is committed to maintaining a culture of transparency, accountability, and ethical conduct. We have established this Speak Up Policy and mechanism to hear concerns about circumstances related to any of our activities in operations and the supply chain, and to provide a transparent and consistent process for resolving them.
2. Scope
This Policy applies to everyone working for Canora Diamonds worldwide, including all employees, managers, and directors. It also applies to temporary and contract employees, consultants, agents, vendors, partners, customers, suppliers, and other stakeholders who wish to raise a concern about Canora Diamonds' practices or actions.
This Policy covers concerns relating to (but not limited to):
- Accounting, auditing, and internal financial controls;
- Conflicts of interest;
- Criminal activity;
- Disclosure of confidential information;
- Discrimination or harassment;
- Environmental issues in our operations or supply chain;
- Human rights;
- Improper receiving or giving of gifts;
- Marketing or advertising misconduct;
- Modern slavery and forced labour;
- Theft;
- Violation of company policies;
- Violence or threats;
- Wrongful termination or HR-related issues.
3. Definitions
3.1 Whistleblowing
Whistleblowing is the process of exposing wrongdoing, illegal or unethical practices, or violations of regulations within an organisation. It is typically done by an employee or former employee who reports misconduct internally, or as a last resort, to a regulatory body.
3.2 Grievance
A grievance is a report about a personal experience, distinct from whistleblowing which tends to focus on conduct that affects the public interest or the organisation broadly.
3.3 Complaint
A formal expression of dissatisfaction relating to the scope of this Policy.
4. Protected Disclosures
A "protected disclosure" is a disclosure made in accordance with this policy, made in the reasonable belief that it is in the public interest and tends to show one or more of the following:
- A criminal offence has been committed, is being committed, or is likely to be committed;
- A person has failed, is failing, or is likely to fail to comply with any legal obligation;
- A miscarriage of justice has occurred, is occurring, or is likely to occur;
- The health or safety of any individual has been, is being, or is likely to be endangered;
- The environment has been, is being, or is likely to be damaged; or
- Information regarding the above has been, is being, or is likely to be deliberately concealed.
5. Reporting Channels
5.1 Internal Reporting
Employees and stakeholders are encouraged to report concerns through:
- Their manager or supervisor;
- The Director;
- Email: policy@canoradiamonds.com
- Mail: Canora Diamonds Inc., 33 Pindar Crescent, Toronto, Ontario M2J 3L3, Canada
5.2 Anonymous Reporting
Reports may be made anonymously where permitted by law. Anonymous reports should include as much detail as possible to enable investigation.
5.3 External Reporting
If internal channels are unavailable or ineffective, or if the concern involves serious misconduct, individuals may report to relevant external authorities:
Canada:
- Office of the Privacy Commissioner of Canada
- Canadian Human Rights Commission
- Local law enforcement
- Public Services and Procurement Canada (for forced labour concerns under Bill S-211)
United States:
- Occupational Safety and Health Administration (OSHA)
- Equal Employment Opportunity Commission (EEOC)
- Federal Bureau of Investigation (FBI)
- State attorney general offices
France:
- Défenseur des droits
- CNIL (data protection)
- Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF)
6. Protections
6.1 Confidentiality
We treat all reports and the identity of reporters with the highest level of confidentiality, to the extent permitted by law.
6.2 Non-Retaliation
We strictly prohibit retaliation against anyone who reports concerns in good faith, including termination, demotion, harassment, or discrimination.
6.3 False Reporting
We do not tolerate false or malicious reports made with intent to harm. Appropriate action will be taken against individuals found to have knowingly made false reports.
7. Reporting Procedure
- Gather information: Include the nature of the concern, individuals involved, supporting evidence, and desired outcome.
- Choose a channel: Email policy@canoradiamonds.com or contact management directly.
- Make the report: Provide a written or verbal statement with supporting evidence.
- Follow up: You may request updates on the investigation progress.
8. Investigation and Response
We will promptly and thoroughly investigate all reports received.
| Stage | Timeline |
|---|---|
| Acknowledgement of receipt | Within 24 hours |
| Initial status update | Within 5 business days |
| Initial investigation | Up to 30 working days |
The investigation process includes:
- Review and assess the disclosure;
- Notify affected parties where appropriate (without compromising the investigation);
- Collect and preserve evidence;
- Analyse evidence and determine validity;
- Provide feedback to the discloser where possible;
- Decide on outcome and take corrective action.
If the investigation substantiates the concern, we will take appropriate corrective actions, which may include disciplinary measures, process improvements, supplier remediation, or reporting to authorities.
9. Record Keeping
We maintain records of all reports, investigations, and actions taken for a minimum of 7 years (or 10 years where required by applicable law).
10. Communication and Training
This policy is communicated to all employees and is available publicly on our website. Training on this policy will be provided to employees.
11. Governance and Review
This policy is reviewed annually and owned by the Director of Canora Diamonds Inc.
12. 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