1.PURPOSE AND COMMITMENT
Scorp Group Ltd is committed to providing an accessible, transparent, impartial, and effective
grievance mechanism for all individuals and groups who may be affected by our business
operations and supply chain activities. This mechanism enables workers, suppliers, communities,
and other stakeholders to raise concerns about actual or potential adverse human rights impacts
in a safe environment, free from fear of retaliation.
This Formal Complaint and Grievance Mechanism is designed and operated in accordance with the
effectiveness criteria established by the UN Guiding Principles on Business and Human Rights
(UNGPs), Principle 31, which requires that grievance mechanisms be:
and expertise necessary to engage in a fair grievance process
and review of the mechanism
International frameworks underpinning this mechanism:
2.SCOPE AND ELIGIBILITY
This grievance mechanism is available to:
The mechanism covers grievances related to all human rights issues including but not limited to:
3.CHANNELS FOR SUBMITTING COMPLAINTS
Scorp Group provides multiple accessible channels to accommodate different languages, literacy
levels, locations, and preferences:
CHANNEL 1 — ANONYMOUS WHISTLEBLOWING HOTLINE
Available: 24 hours a day, 7 days a week
Languages: Available in all languages of Scorp Group's operating countries
Access: Freephone number posted at all Scorp Group sites and supplier facilities
Anonymity: Full anonymity guaranteed; no caller ID or recording without consent
CHANNEL 2 — ONLINE GRIEVANCE PORTAL
URL: https://scorp.marketing/grievance-mechanism
Available: 24 hours a day, 7 days a week
Languages: Multilingual interface
Anonymity: Option to submit anonymously or with identity disclosed
CHANNEL 3 — EMAIL
Address: grievance@scorp.com
Languages: Responses provided in the language of the complainant
Response: Acknowledgement within 2 working days of receipt
CHANNEL 4 — WRITTEN COMPLAINT (POSTAL / IN PERSON)
Address: Human Rights Grievance Officer, Scorp Group Ltd
c/o Chief Sustainability Officer's Office
Languages: Submissions accepted in any language
Access: Complaint forms available at all Scorp Group reception areas and on the website
CHANNEL 5 — DIRECT REPORT TO HR OR LINE MANAGEMENT
For Scorp Group employees who prefer to raise concerns directly with their HR
Business Partner or a manager outside their direct line of management.
Contact details available on the company intranet.
CHANNEL 6 — WORKER REPRESENTATIVE / TRADE UNION
Concerns may also be raised through elected worker representatives, trade union
shop stewards, or works council members, who will escalate formally on behalf
of the worker if appropriate.
4.COMPLAINT HANDLING PROCESS
STAGE 1 — RECEIPT AND ACKNOWLEDGEMENT
1.1 All complaints received via any channel are logged in Scorp Group's Grievance
Management System (GMS) within 1 working day of receipt.
1.2 The complainant (if not anonymous) receives a written acknowledgement within
2 working days, including:
1.3 Anonymous complaints are treated with equal seriousness and investigated fully.
Reference: UNGP Principle 31(b) Accessible; LkSG Section 8(1).
STAGE 2 — INITIAL ASSESSMENT AND TRIAGE
2.1 The Grievance Officer conducts an initial assessment within 5 working days to:
CRITICAL: Immediate risk to life, safety, or freedom — respond within 24 hours
HIGH: Serious ongoing harm (e.g. forced labour, child labour) — 10 working days
MEDIUM: Significant issue without immediate risk — 20 working days
LOW: General concern or policy question — 30 working days
2.2 Where a complaint is outside scope, the complainant is informed and, where possible,
directed to a more appropriate mechanism (e.g. national labour authority).
Reference: OECD DDG Step 5; UNGP Principle 31(c) Predictable.
STAGE 3 — INVESTIGATION
3.1 All investigations are conducted by a trained, independent Case Handler (drawn from
the Sustainability, Legal, or HR function) who has no direct reporting relationship
to the individuals or business units involved.
3.2 The investigation may include:
3.3 The complainant is kept informed of progress at minimum every 10 working days.
3.4 The principle of confidentiality is maintained throughout. The identity of the complainant
is not disclosed to the respondent without the complainant's explicit consent.
Reference: UNGP Principle 31(d) Equitable; UNGP Principle 31(e) Transparent.
STAGE 4 — RESOLUTION AND REMEDIATION
4.1 Upon completion of the investigation, the Case Handler prepares a written findings
report and recommended resolution, which is reviewed by the Grievance Officer and,
for HIGH or CRITICAL cases, the PSRC (Procurement and Sustainability Review Committee).
4.2 Where the complaint is substantiated, Scorp Group will take appropriate remedial action,
which may include:
is identified or legally required
4.3 The resolution is communicated to the complainant in writing, in their language, within
the applicable resolution timeline.
4.4 Remediation is designed in consultation with the affected party wherever possible,
to ensure it is appropriate and proportionate to the harm suffered.
Reference: UNGP Principle 22 (Remediation); UNGP Principle 31(f) Rights-compatible;
OECD DDG Step 5; LkSG Section 8(3).
STAGE 5 — APPEAL
5.1 If the complainant is not satisfied with the resolution, they may submit a written
appeal within 15 working days of receiving the outcome.
5.2 Appeals are reviewed by a senior member of the Legal or Sustainability team who
was not involved in the original investigation.
5.3 The appeal outcome is communicated within 15 working days of receipt of the appeal.
5.4 Where internal resolution is exhausted and the complainant remains unsatisfied,
Scorp Group will provide information on available external dispute resolution mechanisms,
including national labour courts, ombudspersons, and NCP (National Contact Point)
under the OECD Guidelines for Multinational Enterprises.
Reference: UNGP Principle 31(h) Based on engagement and dialogue.
5.NON-RETALIATION GUARANTEE
Scorp Group maintains an absolute zero-tolerance policy for retaliation against any individual
who raises a concern in good faith through this mechanism — whether they are an employee,
supplier worker, contractor, community member, or any other stakeholder.
for submitting a complaint or participating in an investigation.
Supplier employees who fear reprisal from their employer for raising a concern with Scorp Group
are encouraged to use the anonymous hotline or online portal, and Scorp Group will not share
complainant identity with the supplier without explicit consent.
Reference: UNGP Principle 31(a) Legitimate; ILO C158; LkSG Section 8(2).
6.RESOLUTION TIMELINES SUMMARY
Priority Level Initial Response Target Resolution
CRITICAL Within 24 hours Within 5 working days
HIGH Within 2 work. days Within 10 working days
MEDIUM Within 2 work. days Within 20 working days
LOW Within 2 work. days Within 30 working days
7.ROLES AND RESPONSIBILITIES
Chief Sustainability Officer (CSO):
Grievance Officer (Sustainability Team):
Case Handlers (HR / Legal / Sustainability):
Legal & Compliance:
PSRC (Procurement & Sustainability Review Committee):
8.MONITORING, LEARNING, AND REPORTING
8.1 Scorp Group tracks the following KPIs for the grievance mechanism:
8.2 Grievance data is reviewed quarterly by the CSO and used to identify patterns, systemic
issues, and opportunities to improve working conditions across operations and supply chain.
8.3 Aggregated, anonymised grievance statistics and key outcomes are reported annually in
Scorp Group's Human Rights & Sustainability Report, aligned with:
8.4 This mechanism is reviewed annually by the CSO in consultation with relevant stakeholder
groups, and updated based on lessons learned and emerging best practices.
Reference: UNGP Principle 31(g) A source of learning; OECD DDG Step 6.
9.ACCESSIBILITY MEASURES
Scorp Group takes the following measures to ensure the mechanism is genuinely accessible
to all stakeholders, including those facing language, literacy, cultural, or technological barriers:
employee induction