Policies and reporting
Grievance procedure
Complete translation of the Dutch source text. The original PDF is available via the link on this page.
Public procedure · Sustainability Partner BV · Version 1.0
Who can submit a complaint?
Any stakeholder may submit a complaint: employees, freelancers, clients, suppliers and partners, investors/owners, members of the wider community and other individuals or groups who believe they are affected by Sustainability Partner or by a relevant business relationship of Sustainability Partner.
How do you submit a complaint?
Complete the complaint form on our website: Reporting point for complaints & concerns – Sustainability Partner – Fill in form
Preferably provide your contact details, a description of what happened or threatens to happen, when it occurred, who or what is involved, the impact you experience and the solution you consider reasonable. Supporting evidence is welcome but is not required to submit a complaint.
You may ask for your identity to be shared as little as possible. Anonymous or pseudonymous reports are also assessed when sufficient information is available for a meaningful investigation. Anonymity may, however, limit the feedback we can provide or the facts we can verify.
When do we accept a complaint?
A complaint is generally accepted when there is a reasonable connection with Sustainability Partner and the reported issue calls for investigation, remedy, correction or a reasoned decision.
You can scroll this table horizontally. With a keyboard: focus the table and use the arrow keys.
| Situation | Handling | Examples | What we communicate |
|---|---|---|---|
| Within scope | We accept the report as a complaint when its subject relates to our activities, services, decisions, working practices, the behaviour of people acting on our behalf or a business relationship over which we have influence. | Potential negative social or environmental impact; unfair or unethical treatment; breach of an agreement or public commitment; serious quality issue; privacy/data; conflict of interest; retaliation. | Confirmation of acceptance, case owner, next step and target date. |
| Insufficient information | We request specific missing information when the complaint cannot otherwise be meaningfully assessed or investigated. | Insufficient data/context; unclear who or which assignment is involved. | What information is missing and by when we will decide after receiving it. |
| Not a complaint | We handle the report as a general enquiry, commercial enquiry or feedback when no investigation or remedy procedure is required. | General information request, quotation request, suggestion with no reported harm. | Why it is not handled as a complaint and, where possible, the appropriate person or channel. |
| Outside scope / abuse | We do not accept the report when there is no clear connection with Sustainability Partner, when it consists solely of spam or threatening/abusive behaviour, or when the exact same case has been definitively closed without new facts. | Complaint about an entirely unrelated company; repeated identical report without new information. | A brief, specific reason for non-acceptance; an alternative channel where useful and known. |
A complaint is not rejected because it is critical, because no evidence has yet been provided, because the relationship with Sustainability Partner has since ended or because the same complaint was previously raised informally. A report of possible retaliation is always assessed separately and as a priority.
Standard grievance procedure and target deadlines
The deadlines below are target deadlines in working days. When a case is exceptionally complex or depends on external information, we explain before the relevant deadline expires why more time is needed, what remains to be done and when the next update will follow. During an ongoing investigation, we provide a status update at least every 10 working days, even if there is no final outcome yet.
You can scroll this table horizontally. With a keyboard: focus the table and use the arrow keys.
| Step | What happens? | Target deadline | Communication and evidence |
|---|---|---|---|
| 1. Receipt | We record the date, subject and contact option and carry out an initial urgency and conflict check. | Within 3 working days | Acknowledgement of receipt, contact person and explanation of confidentiality and non-retaliation. |
| 2. Intake and scope | An uninvolved case owner assesses whether the report is accepted as a grievance and what information is needed. In a conflict of interest, the case is immediately reassigned. | Within 7 working days of receipt | Acceptance with next steps or a reasoned explanation of why the report is not accepted as a grievance. |
| 3. Investigation | We gather relevant documents and facts, hear the complainant and other necessary parties and assess the reported impact. Only information necessary for a fair assessment is shared. | Within 20 working days of acceptance | Start of the investigation, any requests for information and a status update at least every 10 working days. |
| 4. Resolution and decision | The case owner formulates findings and a proportionate solution. The reviewer checks reasonableness, absence of conflicts, non-retaliation and feasibility. | Target: within 30 working days of acceptance; complex cases within 45 working days | Outcome, key reasons, agreed measures, owner and implementation timing. |
| 5. Implementation and closure | Agreed measures are implemented. We ask whether the complainant sees any material outstanding issues and then confirm the status of the case. | Closure notice within 5 working days of implementing the agreed measures | Confirmation of what has been implemented, whether the case is considered resolved/closed and any follow-up date. |
How we facilitate a solution
The desired solution is discussed with the complainant early in the process. Sustainability Partner does not promise a predetermined outcome, but seeks a solution that is proportionate to the established or plausible impact, feasible and, where possible, prevents recurrence.
Possible forms of remedy or resolution
- A direct conversation, facilitated dialogue or, if necessary, independent mediation when this increases the chance of a lasting solution and the parties involved can agree to it.
- A factual correction, explanation, acknowledgement or apology where this can rectify a misunderstanding, error or shortcoming.
- Reperformance or adjustment of a service, a financial correction or another contractual solution where appropriate.
- Correction or mitigation of data or privacy issues, insofar as this is possible within our authority and the applicable rules.
- Adjustment of a working method, decision, process, policy, control or allocation of responsibilities to address identified shortcomings structurally and prevent recurrence.
- Measures to stop, limit, remedy or further monitor negative social or environmental impact, depending on the nature and severity of that impact.
- Escalation to, corrective action involving or – where proportionate – restriction or termination of a supplier or partner relationship when less intrusive measures produce insufficient results or the severity of the situation requires it.
Protection against retaliation
No one may be disadvantaged because they submit a complaint, provide information, cooperate as a witness or support a complainant. This protection also applies when a complaint is not substantiated following investigation, provided there is no deliberately misleading or threatening abuse of the channel.
Specific protective measures
- Need-to-know access: complaint files are shared only with the case owner, the reviewer and people whose information is strictly necessary. The complainant’s identity is not shared more widely than necessary.
- Conflict separation: a person who is the subject of a complaint does not decide on acceptance, investigation, resolution, reassessment or closure of their own case and only has access to the information necessary to provide a factual response.
- Prohibition of adverse treatment: threats, intimidation, reputational damage, exclusion, pressure to withdraw the complaint, adverse changes to assignments, rates or cooperation, withholding payments due or other disadvantage because of the report are prohibited.
- Separate follow-up: indications of retaliation are recorded as a new, priority grievance and handled by a different case owner where possible.
- Follow-up: for material cases, at closure and again approximately 30 days later, we ask whether there are signs of retaliation or unintended negative consequences. Relevant signals are reopened and investigated.
- External rights remain intact: this procedure does not restrict anyone from using a competent authority, court, professional body, trade union, adviser or other external mechanism.
Public accessibility
The current version of this procedure is published on Sustainability Partner’s website. That page also contains a link to the complaint form.
When the procedure or form changes, the website is updated at the same time. The public version always states a version number and date so that it is clear which procedure applies.
Ownership
- The Managing Partner owns the process and has ultimate responsibility for publication, accessibility of the reporting point, annual evaluation and operation of the complaints register, except in cases in which the Managing Partner is personally involved.
- When internal independence cannot credibly be guaranteed, an external independent reviewer, mediator or relevant professional adviser is engaged.
Approved by: Dennis Duinslaeger, Managing Partner