Supplier Code of Conduct

Canora Diamonds Inc.

Version: 1.0 — 2026
Effective Date: 1 June 2026
Last Updated: 1 June 2026

A. Introduction

CANORA DIAMONDS INC. ("Canora Diamonds," "we," or "us") is committed to ethical business practices with customers, suppliers, employees, and communities. To align our supply chain, we require suppliers to follow this Supplier Code of Conduct ("the Code"), outlining minimum standards for behaviour, practices, and regulations.

This Code complements any Supplier Agreement between Canora Diamonds and the supplier. Suppliers, including their subsidiaries, affiliates, and employees, must comply with all applicable laws, industry regulations, this Code, and related policies. They must also ensure responsible sourcing practices throughout their supply chain.

B. Our Values

Our sustainability approach is built on three pillars:

  1. Preserving our Planet (Environment)
  2. Protecting our People (Social)
  3. Inspiring our Industry (Governance)

These pillars guide all our efforts and form the foundation of this Supplier Code of Conduct.

To ensure ethical conduct, we offer a grievance mechanism for reporting concerns. Suppliers and their employees may report violations to policy@canoradiamonds.com.

C. About This Code

This Code applies to all suppliers who manufacture, source, or supply products or services to Canora Diamonds. By signing this Code, suppliers confirm adherence to the following Canora Diamonds documents:

Supply Chain Tiers

Tier Description
Tier 1 Partner factories in India manufacturing finished Canora Diamonds jewellery products
Tier 2 Chain manufacturers, gemstone cutters, and component suppliers
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 producers)

We encourage open exchange and will support suppliers to implement this Code and improve performance.

D. Compliance and Monitoring

Suppliers must provide relevant data on request to demonstrate compliance. Canora Diamonds may verify compliance through self-assessments, site visits, or audits (including unannounced), conducted by Canora Diamonds or a third party.

Suppliers must promptly report any breaches to Canora Diamonds. Failure to remedy breaches may lead to suspension or termination, and legal violations will be reported to authorities.

Order of Precedence: Applicable law takes precedence, but suppliers must meet this Code's standards where they exceed legal requirements.

Review: This Code is reviewed annually with reasonable notice to suppliers.

E. Environmental Requirements

Environmental Compliance

Suppliers must comply with all environmental laws and maintain necessary licences and permits.

Environmental Policy

Suppliers should have a written environmental policy and designate a responsible individual for environmental performance.

Transparent Sourcing and Traceability

Suppliers must transparently provide data on raw material sources and origin locations for traceability purposes.

Packaging and Shipments

Suppliers should use recycled, recyclable, or compostable packaging materials where possible, without compromising quality. Shipments should be consolidated where feasible.

Emissions Reduction

Suppliers should:

  • Report carbon emissions (Scope 1 and 2 as a minimum) annually;
  • Work towards setting emissions reduction targets;
  • Support Canora Diamonds' sustainability efforts across the value chain.

Waste and Recycling

Suppliers must implement plans to reduce waste, natural resource use, and energy consumption.

Water

Suppliers should make efforts to reduce water usage and maintain wastewater treatment systems where applicable.

F. Social Requirements

F.1 Labour — Human Rights

Suppliers must respect human rights in line with Canora Diamonds' Human Rights Policy by:

  • Conducting due diligence to identify and address human rights risks;
  • Taking steps to prevent and mitigate human rights abuses; and
  • Remedying adverse impacts linked to their operations.

Suppliers must not source goods produced with forced labour, including from regions subject to import prohibitions under applicable law (e.g., Uyghur Forced Labor Prevention Act in the United States).

F.2 Terms of Employment

Provide employees with clear, written, legally binding contracts in a language they understand, outlining wages, hours, benefits, and conditions.

F.3 Modern Slavery, Involuntary Labour, and Human Trafficking

All work must be voluntary. Suppliers must prevent all forms of modern slavery, human trafficking, forced, bonded, indentured, or prison labour. Employees must be free to leave employment with reasonable notice. Suppliers must prohibit retention of identification documents (unless legally required) and charging of recruitment fees.

F.4 Wages

Pay at least the local minimum or prevailing wage, whichever is higher, and comply with all legal requirements for benefits.

F.5 Working Hours and Overtime

Comply with local laws and ILO standards. Regular workweek shall not exceed 48 hours, with a maximum of 60 hours including overtime (or the legal limit, if lower). Overtime must be voluntary and compensated at legal rates or at least 125% of the regular rate.

F.6 Disciplinary Practices

No employee shall be subject to physical, sexual, psychological, or verbal harassment or abuse. Monetary fines or wage deductions must not be used as discipline.

F.7 Freedom of Association

Respect employees' rights to freedom of association and collective bargaining.

F.8 Subcontracting

Suppliers must not use unauthorised subcontractors for Canora Diamonds products. All production must take place in pre-approved facilities.

F.9 Child Labour

Do not employ workers under 15 or the legal minimum age, whichever is higher. Workers under 18 must not perform hazardous work.

F.10 Health and Safety

Provide a safe, healthy, and hygienic workplace. Comply with fire safety laws, provide PPE where necessary, manage hazardous materials safely, and ensure access to clean water and sanitation.

F.11 Non-Discrimination and Fair Treatment

Ensure a workplace free from harassment and discrimination based on any prohibited grounds.

G. Governance Requirements

Compliance with Laws

Comply with all applicable laws in countries of operation.

International Sanctions and Trade Compliance

Adhere to trade, sanctions, and embargo laws issued by recognised authorities (UN, EU, US, Canada).

Anti-Money Laundering and Fraud Prevention

Maintain robust processes to prevent illicit sourcing of funds, terrorism financing, and fraud.

Bribery and Corruption

Comply with anti-bribery laws. Prohibit corruption, extortion, embezzlement, and bribery in any form.

Data Protection and Privacy

Safeguard personal data and confidential information.

Conflicts of Interest

Avoid and disclose actual or potential conflicts of interest.

Grievance Mechanism

Maintain grievance procedures allowing employees and stakeholders to report concerns without retaliation.

Due Diligence

Perform due diligence across the supply chain to maintain high standards.

H. Raw Material Requirements

H.1 Metals and Minerals

Source responsibly, respecting human rights and minimising environmental harm. Do not source from conflict regions that fund armed groups. Disclose country of origin and provide supporting documentation.

Prioritise recycled metals from legitimate refiners with verifiable chain of custody.

H.2 Natural Diamonds

Ensure diamonds are conflict-free per the Kimberley Process Certification Scheme and World Diamond Council System of Warranties. Confirm the WDC statement on every invoice. Prevent accidental mixing of mined and lab-grown diamonds.

H.3 Lab-Grown Diamonds

Disclose the growing method (HPHT or CVD). Ensure clear segregation from natural diamonds. Provide supply chain disclosure for traceability. Disclose all physical characteristics including treatments.

H.4 Gemstones

Source respecting human rights, conflict-free, with country of origin disclosed. Disclose treatments and physical characteristics.

H.5 Pearls

Harvested and processed respecting human rights with minimal environmental damage. Disclose country of origin where possible.

I. Branded Packaging

  • Cardboard boxes: FSC-certified where possible
  • Pouches: Minimum recycled content where possible
  • Paper packaging: FSC-certified and recyclable

J. Reporting Concerns

Suppliers and their employees must promptly report violations to:

Email: policy@canoradiamonds.com
Mail: Canora Diamonds Inc., 33 Pindar Crescent, Toronto, Ontario M2J 3L3, Canada

K. Acknowledgement

By doing business with Canora Diamonds Inc., the supplier acknowledges that it has read, understood, and agrees to comply with this Supplier Code of Conduct.

Supplier Name: ___________________________

Authorised Signature: ___________________________

Date: ___________________________

Canora Diamonds Inc.
33 Pindar Crescent, Toronto, Ontario M2J 3L3, Canada
Corporation Number: 1785487-1