If a grievance is not accepted, we will explain the reasons in writing. The complainant will be kept informed at each stage of the process, including the decision-making approach, timelines, and outcome.

5.1 Tiered Resolution

Resolutions are proportionate to severity. We apply a tiered approach:

• Tier 1 — Internal resolution: direct discussion and mediated agreement between the parties.
• Tier 2 — Mediation: facilitated by a trained internal or external mediator.
• Tier 3 — Independent arbitration: review by an independent arbiter with no connection to the company or the grievance.

6. Conflict of Interest Controls

All personnel involved in reviewing or resolving a grievance must have no conflict of interest with the case. This is ensured through:

• A signed declaration of no conflict of interest from all assigned reviewers.
• Assignment of reviewers from departments unrelated to the grievance.

• Use of independent external arbiters for Tier 3 cases or where internal independence cannot be assured.

7. Protection from Retaliation

We are committed to a strict policy of no retaliation. No stakeholder will suffer any adverse consequence for raising a grievance in good faith. This protection applies equally to the grievance raiser, witnesses, and anyone assisting in the process.

Protective measures include:

• Confidentiality of the grievance raiser’s identity, maintained unless disclosure is legally required or explicitly consented to.
• Consent obtained before sharing information with any additional parties.
• Disciplinary action against any person found to have retaliated.
• Risk assessments for vulnerable stakeholders, with collaboration from independent third parties where needed.

8. Tracking, Accountability, and Reporting

All grievances are logged in a central register maintained by the Grievance Officer, recording the date received, category, status, assigned reviewer, resolution, and date closed.

The Grievance Officer reports to the highest governing body, Board of Directors, on a quarterly basis on:
The number and types of grievances received.

• Resolution rates and average time to resolution.
• Trending or recurring issues and corrective actions taken.
• Outcomes of any appeals.

We publish an annual aggregate summary of grievance data. No personal information is disclosed without consent.

9. Stakeholder Notification

We proactively notify stakeholders of this grievance procedure through:

1. Publication on our website in relevant languages.
2. Inclusion in employee onboarding and training materials.
3. Communication to suppliers and partners through contract clauses and codes of conduct.
4. Community engagement activities and public notices.
5. Posters in workplaces.

10. External Remedies

This procedure does not replace any statutory rights. Stakeholders retain the right to refer matters to:

• Relevant national regulatory or supervisory authorities.
• National courts or judicial mechanisms.
• National Human Rights Institutions.
• OECD National Contact Points for Responsible Business Conduct.

11. Policy Review

This policy is reviewed at least annually or following a material change in operations, legal requirements, or stakeholder feedback. Reviews consider the effectiveness of the procedure using the UNGP Principle 31 criteria: legitimacy, accessibility, predictability, equitability, transparency, rights-compatibility, and continuous learning.

12. Regulatory and Standards Alignment