This External Complaint & Complaints Policy outlines the process by which any external stakeholder may raise a concern or complaint relating to the company’s operations, supply chain, conduct, or impacts. The policy exists to ensure all complaints are heard, addressed in a timely manner, and resolved fairly, transparently, and without risk of retaliation. 

Stakeholders include (but are not limited to): workers, suppliers, contractors, customers, community members, civil society organisations, and any affected individual or group. 

This mechanism is available to all external stakeholders who wish to raise a complaint or

concern about the company’s activities, behaviour, staff, or business partners, including

issues relating to:

• Human rights

• Labour rights

• Environmental concerns

• Ethical conduct

• Health and safety

• Date protection or privacy

• Product or service concerns

• Supplier practices

• Community impacts

Stakeholders may contact the Company; Make a complaint containing the nature and details of the complaint.

When a complaint is received, the company will acknowledge receipt and provide the complainant with clear information about how their matter will be handled.

The company accepts complaints that relate to any of the following:

• Alleged violations of laws, regulations, internal policies, or contractual obligations

• Adverse impacts on individuals, workers, communities, or the environment

• Conduct that is inconsistent with the company’s values, Code of Conduct, or ethical standards

• Any behaviour, action, or omission that has caused—or may cause—harm to stakeholders

If a submission does not meet these criteria, the company will clearly explain why it cannot be accepted as a formal complaint.

Upon acknowledgment, ideally within 10 working days, the company will outline the steps involved in reviewing and resolving the complaint. This includes:

• How the complaint will be assessed and reviewed

• The expected timeframes for each stage of the process

• How relevant information will be gathered (e.g., interviews, document review, discussions with involved parties)

• How findings will be evaluated and how decisions will be made

This ensures that complainants understand what to expect throughout the process.

The company will explain the possible pathways to resolution, which may include:

• Corrective actions to address the issue

• Mitigation measures to reduce or prevent harm

• Mediation or facilitated dialogue between relevant parties

• A written response outlining findings and conclusions

• Escalation to senior management if the matter is complex or serious

The complainant will be informed of the outcome once the process is completed, along with any steps taken by the company in response.

The company will acknowledge receipt by email and provide an outline of the process and timelines.

The complaint is reviewed to determine:

• Whether it meets the criteria for acceptance

• What additional information is required

• Who in the organisation needs to be involved

If the complaint is not accepted, the company will provide a written explanation.

The company will gather relevant information, which may include interviews, document reviews, supplier engagement, depending on the nature of the complaint.

A resolution will be proposed and discussed with the stakeholder, including corrective actions, mitigation measures, or other appropriate remedies.

The company will:

• Provide regular updates on progress

• Share outcomes of each step

• Confirm when a resolution has been implemented

The Company strictly prohibits any form of retaliation against an individual making a compliant in good-faith or who participates in an investigation. Any individual who believes they have been subjected to retaliation is expected to report the matter using the reporting procedures outlined in this policy. 

The Company will address any complaint of retaliation using the most appropriate measures available, based on the nature and severity of the conduct. Consequences may include, but are not limited to, formal disciplinary action, up to and including termination of employment. Depending on the circumstances, the Company may also implement additional corrective actions such as mandatory training or other remedial steps necessary to ensure a safe and compliant working environment. The Company reserves the right to take any further action it deems necessary to prevent future retaliation and protect the integrity of the reporting process.