Grievance and Complaints Policy

1. Purpose

This policy establishes a formal framework for employees, contractors, partners, and stakeholders to raise grievances, complaints, and concerns in a fair, transparent, and timely manner. It demonstrates our commitment to maintaining high ethical standards and responding constructively to feedback.

The policy specifically addresses concerns related to customer projects that may have adverse social or environmental impacts, reflecting our responsibility to operate sustainably and ethically.

2. Scope

This policy applies to:

All employees, regardless of position or tenure
Contractors, consultants, and temporary workers
Business partners, suppliers, and vendors
Customers and external stakeholders
Members of the public affected by our operations or customer projects

3. Policy Statement

We are committed to creating an environment where concerns can be raised without fear of retaliation. All complaints will be treated seriously, investigated thoroughly, and resolved fairly. We recognise that early intervention and open communication are essential to maintaining trust and addressing issues before they escalate.

We acknowledge our broader responsibilities to society and the environment. Where our work or that of our customers may have adverse social or environmental impacts, we commit to transparent assessment and appropriate action.

4. Definitions

Grievance

A concern, problem, or complaint raised by an individual regarding their treatment, working conditions, or the conduct of others within the organisation.

Complaint

A formal expression of dissatisfaction regarding services, products, policies, or the conduct of the organisation or its representatives.

Social Impact Concern

A concern relating to actual or potential adverse effects on communities, human rights, labour practices, health and safety, or societal wellbeing arising from our activities or those of our customers.

Environmental Impact Concern

A concern relating to actual or potential adverse effects on the natural environment, including pollution, resource depletion, biodiversity loss, climate impacts, or ecological damage arising from our activities or those of our customers.

Complainant

Any individual or party raising a grievance, complaint, or concern under this policy.

5. Types of Grievances and Complaints Covered

5.1 Workplace Grievances

Bullying, harassment, or discrimination
Unfair treatment or inconsistent application of policies
Health and safety concerns
Disputes regarding terms and conditions of employment
Concerns about management decisions or organisational change

5.2 Ethical and Compliance Concerns

Suspected fraud, corruption, or financial irregularities
Breaches of legal or regulatory requirements
Conflicts of interest
Violations of the Code of Conduct

5.3 Service and Product Complaints

Quality or delivery issues
Contractual disputes
Customer service concerns

We recognise that our platform and services may be used to support customer projects across diverse sectors. While we celebrate innovation, we acknowledge our responsibility to consider the broader implications of the work we enable.

Employees, partners, and stakeholders are encouraged to raise concerns about customer projects that may involve:

Social Impact Concerns:

Projects that may adversely affect vulnerable communities or populations
Potential human rights violations in supply chains or operations
Labour exploitation or unsafe working conditions
Discrimination or exclusion of marginalised groups
Public health risks or safety hazards
Displacement of communities or livelihoods
Privacy violations or misuse of personal data

Environmental Impact Concerns:

Significant carbon emissions or contribution to climate change
Air, water, or soil pollution
Destruction or degradation of natural habitats
Threats to biodiversity or endangered species
Unsustainable resource extraction or consumption
Improper waste disposal or hazardous material handling
Non-compliance with environmental regulations

Any individual who becomes aware of a customer project that may have significant adverse social or environmental impacts should:

Document the concern with as much detail as possible, including the customer, project description, and nature of the potential impact
Submit the concern through the designated channel (see Section 7)
Maintain confidentiality regarding the concern until it has been reviewed

6.3 Assessment Process

Upon receipt of a social or environmental impact concern, the following assessment process will be initiated:

Initial Review: The Ethics and Compliance Officer will conduct a preliminary assessment within 5 working days to determine if further investigation is warranted
Impact Assessment: Where appropriate, a formal impact assessment will be conducted, potentially involving external experts or stakeholder consultation
Risk Evaluation: The concern will be evaluated against our risk framework, considering severity, likelihood, reversibility, and scope of potential harm
Recommendation: A recommendation will be made to the appropriate decision-making body (see Section 6.4)

6.4 Decision-Making and Outcomes

Decisions regarding customer projects with potential adverse impacts will be made by the Ethics Review Committee, which may include senior leadership, legal counsel, and relevant subject matter experts.

Possible outcomes include:

Continuation: Project proceeds with no changes required
Conditional Continuation: Project proceeds with specific safeguards, modifications, or monitoring requirements
Pause: Project temporarily suspended pending further assessment or remediation
Termination: Engagement with the customer project is ended
Escalation: Matter referred to Board level for strategic decision

6.5 Communication and Transparency

The complainant will be informed of the outcome of the assessment within a reasonable timeframe. Where appropriate and subject to confidentiality obligations, we will communicate transparently about our decision-making process and any actions taken.

7. Complaints Procedure

7.1 Channels for Raising Concerns

Type of Concern	Primary Channel	Alternative Channel
Workplace Grievance	Line Manager or HR Department	Skip-level manager
Ethical/Compliance	Ethics and Compliance Officer	Whistleblowing Hotline
Service/Product Complaint	Customer Success Team	Senior Management
Social/Environmental Impact	Ethics and Compliance Officer	CPO or CEO

7.2 Procedure Steps

Step 1: Initial Submission

Submit your concern through the appropriate channel, providing as much detail as possible including dates, individuals involved, and any supporting evidence. You will receive acknowledgement within 3 working days.

Step 2: Initial Assessment

The receiving party will conduct an initial assessment to understand the nature of the concern and determine the appropriate course of action. This will be completed within 10 working days.

Step 3: Investigation

Where necessary, a formal investigation will be conducted. This may involve interviews, document review, and consultation with relevant parties. The investigation will be conducted fairly and impartially.

Step 4: Resolution

Based on the investigation findings, appropriate action will be taken. This may include mediation, corrective measures, policy changes, or disciplinary action where warranted.

Step 5: Communication

The complainant will be informed of the outcome and any actions taken, subject to confidentiality constraints. Feedback on the process is welcomed.

8. Escalation Process

If you are not satisfied with the handling or outcome of your complaint, you may escalate the matter through the following channels:

First Escalation: Senior Manager or Director of the relevant department
Second Escalation: Chief People Officer
Final Escalation: Chief Executive Officer or Board of Directors
External Escalation: Relevant external bodies (e.g., ACAS, regulatory authorities) where appropriate

9. Confidentiality and Non-Retaliation

9.1 Confidentiality

All complaints and grievances will be handled with appropriate confidentiality. Information will only be shared on a need-to-know basis with those directly involved in the investigation and resolution process. Personal data will be processed in accordance with data protection legislation.

9.2 Non-Retaliation

We strictly prohibit any form of retaliation against individuals who raise concerns in good faith. Retaliation includes but is not limited to:

Dismissal or threat of dismissal
Demotion or denial of promotion
Harassment, bullying, or ostracism
Unfavourable changes to terms and conditions
Any other detrimental treatment

Any individual found to have engaged in retaliation will be subject to disciplinary action, up to and including termination of employment or contract.

9.3 Anonymous Reporting

While we encourage individuals to identify themselves to facilitate investigation, anonymous reporting is permitted. However, please note that anonymity may limit our ability to investigate thoroughly or provide feedback on outcomes.

10. Record Keeping

All complaints, grievances, and concerns will be documented and retained in accordance with our records retention policy. Records will include:

Nature and details of the complaint
Steps taken during investigation
Findings and conclusions
Actions taken and outcomes
Any appeals or escalations

Aggregated and anonymised data will be used to identify trends, improve processes, and report to the Board on the effectiveness of this policy.