Scorp Group · Policy Document

Grievance Mechanism

Formal Complaint Procedure

Document Title

Formal Complaint and Grievance Mechanism

Document No.

SG-HR-PROC-004

Version

1.0

Effective Date

June 2025

Owner

Chief Sustainability Officer (CSO)

Approved by

Board of Directors, Scorp Group Ltd

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:

  • Legitimate — Enabling trust from the stakeholder groups they are intended to serve
  • Accessible — Known to and usable by all intended users
  • Predictable — A clear and known procedure with an indicative time frame
  • Equitable — Ensuring affected parties have reasonable access to information, advice
  • and expertise necessary to engage in a fair grievance process

  • Transparent — Keeping complainants informed of the process and outcomes
  • Rights-compatible — Ensuring outcomes accord with internationally recognised human rights
  • A source of learning — Drawing on regular analysis to improve the mechanism
  • Based on engagement and dialogue — Consulting affected stakeholder groups in the design
  • and review of the mechanism

    International frameworks underpinning this mechanism:

  • UN Guiding Principles on Business and Human Rights (UNGPs), Principles 28-31
  • OECD Guidelines for Multinational Enterprises (2023), Chapter II §6
  • OECD Due Diligence Guidance for Responsible Business Conduct (2018), Step 5
  • ILO Convention No. 158: Termination of Employment, 1982
  • ILO Tripartite Declaration of Principles Concerning Multinational Enterprises (2017)
  • ISO 26000:2010, Section 6.3.6 (Remediation)
  • UN Global Compact Principle 1 & 2
  • GRI Standard 2-26: Mechanisms for Seeking Advice and Raising Concerns (2021)
  • German Supply Chain Due Diligence Act (LkSG, 2023), Section 8
  • 2.SCOPE AND ELIGIBILITY

    This grievance mechanism is available to:

  • All employees of Scorp Group Ltd (permanent, fixed-term, part-time, temporary, and agency)
  • Workers in Scorp Group's direct supply chain (Tier 1 suppliers)
  • Workers in Scorp Group's indirect supply chain (Tier 2+ where accessible)
  • Local communities and individuals potentially affected by Scorp Group's operations
  • Business partners, contractors, and other external stakeholders
  • The mechanism covers grievances related to all human rights issues including but not limited to:

  • Forced or compulsory labour / modern slavery / human trafficking
  • Child labour
  • Discrimination and harassment (on any protected ground)
  • Occupational health and safety concerns
  • Freedom of association and collective bargaining violations
  • Wage theft, underpayment, or non-payment of wages
  • Excessive working hours or denial of rest periods
  • Unlawful eviction or land rights violations
  • Environmental damage affecting communities
  • Data privacy violations
  • Retaliation for raising concerns
  • Any other actual or potential adverse human rights impact
  • 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:

  • A unique complaint reference number
  • The name and contact details of the assigned Case Handler
  • An outline of the investigation process and indicative timeline
  • Confirmation that no retaliation will be tolerated
  • 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:

  • Confirm the complaint falls within the scope of this mechanism
  • Assess the urgency and severity of the alleged harm
  • Assign a priority level:
  • 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

  • Identify whether the matter should be referred to external authorities
  • (e.g. law enforcement, labour inspectorate)
  • 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:

  • Review of documentary evidence (payslips, timesheets, audit records, contracts)
  • Interviews with the complainant (with consent), witnesses, and respondent parties
  • On-site inspection or third-party audit where appropriate
  • Engagement with worker representatives or civil society organisations
  • Consultation with external human rights experts where required
  • 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:

  • Apology and formal acknowledgement of the harm caused
  • Financial compensation or restitution (e.g. unpaid wages, medical costs)
  • Reinstatement of employment where unlawful dismissal is found
  • Corrective Action Plan (CAP) issued to the relevant supplier or business unit
  • Disciplinary action against responsible individuals
  • Systemic policy or process changes to prevent recurrence
  • Referral to law enforcement or regulatory authorities where criminal conduct
  • 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.

  • No individual will face demotion, dismissal, harassment, or any other adverse consequence
  • for submitting a complaint or participating in an investigation.

  • Any confirmed act of retaliation will itself be treated as a serious disciplinary offence.
  • The non-retaliation guarantee applies equally to anonymous and identified complainants.
  • 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):

  • Overall ownership and governance of the grievance mechanism
  • Annual review and public reporting; Board escalation for critical cases
  • Grievance Officer (Sustainability Team):

  • Day-to-day management of the GMS; triage; assignment of Case Handlers
  • Oversight of investigation quality; reporting to CSO
  • Case Handlers (HR / Legal / Sustainability):

  • Conducting impartial investigations; preparing findings reports
  • Maintaining confidentiality; communicating with complainants
  • Legal & Compliance:

  • Advising on regulatory obligations; managing external referrals to authorities
  • Appeal review for unresolved cases
  • PSRC (Procurement & Sustainability Review Committee):

  • Review and approval of remedial actions for HIGH and CRITICAL cases
  • Supplier CAP oversight; contract review decisions
  • 8.MONITORING, LEARNING, AND REPORTING

    8.1 Scorp Group tracks the following KPIs for the grievance mechanism:

  • Total complaints received per reporting period (by category, geography, stakeholder group)
  • % of complaints acknowledged within 2 working days (target: 100%)
  • % of complaints resolved within target timeline (target: >= 90%)
  • % of complainants satisfied with resolution outcome (measured by follow-up survey)
  • Number of substantiated cases resulting in remediation (by type)
  • Number of repeat complaints indicating systemic issues
  • % of anonymous vs. identified complaints
  • 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:

  • GRI 2-26 (Mechanisms for Seeking Advice and Raising Concerns)
  • UNGP Reporting Framework, Section C (Remedy)
  • LkSG Section 10 (Documentation and Reporting)
  • 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:

  • Complaint forms and hotline available in all languages of operating countries
  • Pictorial complaint forms available for low-literacy users
  • Information posters displayed in worker-accessible areas at all Scorp Group sites
  • Information on the mechanism included in supplier onboarding and Scorp Group
  • employee induction

  • Worker representatives and NGO partners trained to assist workers in accessing the mechanism
  • No requirement to provide identification to use the hotline or online portal
  • 10.RELATED DOCUMENTS

  • Scorp Group Human Rights Policy (SG-HR-POL-001)
  • Human Rights Risk Analysis Procedure (SG-HR-PROC-003)
  • Supplier Incentive & Engagement Process (SG-HR-PROC-002)
  • Non-Discrimination Process (SG-HR-PROC-005)
  • Freedom of Association Process (SG-HR-PROC-008)
  • Supplier Code of Conduct
  • Corrective Action Plan (CAP) Template
  • Annual Human Rights & Sustainability Report
  • 11.INTERNATIONAL STANDARDS REFERENCED

  • UN Guiding Principles on Business and Human Rights (2011), Principles 28-31
  • UNGP Reporting Framework (Shift & Mazars, 2015), Section C
  • OECD Guidelines for Multinational Enterprises (2023), Chapter II §6
  • OECD Due Diligence Guidance for Responsible Business Conduct (2018), Step 5
  • ILO Tripartite Declaration of Principles Concerning Multinational Enterprises (2017)
  • ILO Convention No. 158: Termination of Employment (1982)
  • ISO 26000:2010, Section 6.3.6 (Remediation)
  • UN Global Compact Principles 1 & 2
  • GRI Standard 2-26: Mechanisms for Seeking Advice and Raising Concerns (2021)
  • German Supply Chain Due Diligence Act (LkSG, 2023), Section 8
  • SMETA 4-Pillar Audit Standard (Worker Voice Assessment)