Stakeholder Grievance Policy

1. Purpose

Green Earth Group N.V. and its controlled entities ("Green Earth") provide a clear and accessible way for external stakeholders to report a serious concern about Green Earth's conduct or the direct social, environmental or governance impact of its activities.

This policy complements, and does not replace, Green Earth's existing procedures for staff grievances, whistleblowing, farmer grievances, customer service, contractual disputes, safeguarding, disciplinary matters or legal claims. Where a more specific Green Earth procedure applies, the report may be redirected to that procedure.

This mechanism gives stakeholders a right to submit a grievance and receive a fair response. It does not give a complainant authority over Green Earth's operations, personnel decisions, contractual decisions or remedies.

2. Scope

This policy is available to customers, suppliers, contractors, business partners, project-affected communities and other persons or organisations that may be directly affected by Green Earth's activities or value chain.

A grievance under this policy is a reasonably specific concern about actual or potential:

• unlawful or seriously unethical conduct;
• human-rights or worker-rights impacts;
• material environmental or community harm;
• fraud, corruption, misleading public claims or material data manipulation;
• serious safety risks;
• abuse of authority, discrimination, harassment or retaliation;
• a material breach of a Green Earth policy or commitment that directly affects the complainant or an identifiable stakeholder group.

The following are normally outside this policy:

• general opinions about Green Earth's strategy, commercial choices or public positions;
• ordinary customer-service questions, refund requests or minor service dissatisfaction;
• commercial negotiations, pricing disagreements or contractual disputes that have their own resolution route;
• employment matters covered by the Staff Grievance or Whistleblower procedures;
• farmer matters covered by the Farmer Grievance and Dispute procedure;
• allegations that are vague, purely speculative, abusive or unrelated to Green Earth;
• repeated submissions that raise no material new facts;
• demands for a particular sanction, payment, admission, policy change or business decision.

Green Earth may redirect, combine, close or decline a submission when another procedure is more appropriate, the matter is outside scope, or there is insufficient information to conduct a meaningful review. The complainant will be informed of that decision where contact details are available.

3. How to submit a grievance

A grievance may be submitted through:

• the grievance option on Green Earth's public contact form: https://www.green.earth/contact; or
• the designated grievance email address published on Green Earth's website.

Every grievance must contain enough specific information to pass the TIME – PLACE – FORM – EVENT intake check:

• TIME: when the matter happened, including the date or period and, where relevant, the approximate time and whether it is ongoing or repeated;
• PLACE: where it happened, such as the country, project, site, office, community, online channel or other identifiable location;
• FORM: how the matter occurred or was observed, including the relevant activity, communication, transaction, decision, document or conduct and whether the information was personally observed or received from another identified source;
• EVENT: the concrete incident or sequence of events, including who or what was involved, what Green Earth conduct or impact is being challenged and how the complainant or another identifiable stakeholder group was affected.

The complainant should also provide, as far as reasonably possible:

• their relationship to Green Earth;
• available supporting documents or other evidence;
• whether the matter has previously been reported and, if so, where;
• the outcome they request, while recognising that Green Earth decides the appropriate response.

Reports should distinguish facts from opinions, assumptions and requested outcomes. Evidence is not required to submit a grievance, but the information provided must give a reasonable basis for review. If essential TIME, PLACE, FORM or EVENT information is missing, Green Earth may request clarification and is not required to open a substantive review until sufficient information is provided.

4. Good faith, anonymity and misuse

A person is protected under this policy when they report in good faith: they honestly believe the information may be true and do not knowingly misrepresent material facts.

Grievances may be submitted confidentially. Anonymous grievances will be considered, but anonymity may limit Green Earth's ability to verify facts, ask questions or communicate an outcome. Green Earth will not make an adverse finding against a person solely on the basis of an uncorroborated anonymous allegation.

Knowingly false, materially misleading, malicious, threatening, discriminatory, defamatory or abusive submissions are not protected. Green Earth may close such submissions, restrict abusive use of the channel and take appropriate contractual, employment or legal action where justified.

An allegation is not evidence that misconduct occurred. No person will be treated as responsible unless the available information, assessed fairly, supports that conclusion.

5. Intake and initial assessment

Green Earth will normally acknowledge receipt within five working days when contact details are available.

The policy owner or a designated case coordinator will conduct an initial assessment to determine:

• whether the submission falls within scope;
• whether sufficient information is available;
• whether another internal procedure or responsible department should handle it;
• the seriousness, urgency and potential impact of the matter;
• whether immediate protective or preservation measures are reasonably necessary;
• whether there is a conflict of interest in the proposed handling route.

An acknowledgement means only that the submission was received. It does not mean that Green Earth accepts the allegation or requested outcome.

6. Review and investigation

Green Earth determines the proportionate handling method. This may include clarification, document review, interviews, referral to a responsible department, an internal investigation, an external independent review or closure after initial assessment.

The reviewer must not be the subject of the grievance and must disclose any material conflict of interest. A grievance involving the policy owner will be assigned by the Chief Executive Officer to an appropriate senior manager; a grievance involving the Chief Executive Officer will be assigned by the Board. Green Earth may appoint an external reviewer when independence, expertise or legal requirements make this appropriate.

The process will be impartial and based on relevant facts. A person materially criticised in a grievance will, where fair and lawful, be informed of the substance of the allegation and given a reasonable opportunity to respond before an adverse finding or measure is decided.

Green Earth may take temporary precautionary measures while reviewing a matter. Such measures do not amount to a finding of wrongdoing.

The standard of review is whether the available information, on balance, reasonably supports the relevant finding. Serious employment, contractual, regulatory or legal measures remain subject to the applicable Green Earth procedure and governing law.

7. Decision and response

Green Earth, not the complainant, decides whether a grievance is substantiated and what response is proportionate. Possible responses include no further action, clarification, correction of an error, process improvement, remediation, additional monitoring, contractual action, disciplinary referral or referral to a competent authority.

Green Earth aims to provide a status update or outcome response within 30 calendar days after receipt. Complex matters may take longer. If so, Green Earth will, where possible, explain that the review remains open and provide a revised indicative timeframe.

The response may state:

• whether the grievance was accepted and reviewed;
• whether it was substantiated, partly substantiated, unsubstantiated or could not be determined;
• whether appropriate action was taken or is planned;
• whether another route is more suitable.

Green Earth will not disclose confidential personnel information, privileged advice, commercially sensitive information, personal data, security information, investigation methods or details that could prejudice another process. The complainant has no right to select the investigator, direct the investigation, question witnesses, receive the full case file, approve the outcome or determine sanctions.

8. Review of process

A complainant may request one internal process review within ten working days of the outcome if they can identify:

• a material procedural error;
• a material conflict of interest;
• significant new information that was not reasonably available earlier.

Dissatisfaction with the outcome alone is not a ground for review. The review considers the fairness of the process and material new information; it is not an automatic reinvestigation. The review decision is final within this mechanism. This does not limit any non-waivable legal or regulatory right.

9. Non-retaliation

Green Earth will not retaliate against a person for submitting or assisting with a grievance in good faith. Prohibited retaliation includes threats, intimidation or a materially adverse action taken because of the good-faith report.

Non-retaliation does not:

• protect knowingly false, malicious or abusive conduct;
• prevent Green Earth from enforcing contracts, performance standards, policies or lawful decisions for reasons unrelated to the grievance;
• guarantee continuation of a commercial, employment or project relationship;
• give immunity for the complainant's own misconduct.

Concerns about retaliation should be reported through the same channel and will be assessed separately.

10. Confidentiality and privacy

Information will be shared only with persons who reasonably need it to assess, investigate, decide or implement the response, or where disclosure is required by law, regulation, certification rules or legitimate protection of persons and assets.

Confidentiality will be protected as far as reasonably possible but cannot be guaranteed absolutely. Fair investigation may require disclosure of the substance of an allegation.

Green Earth will process and retain personal information in accordance with applicable privacy requirements and its records-management rules.

11. Responsibility, records and oversight

The Director of New Projects (Holding, Division 6) is responsible for the management of external stakeholder grievances across Green Earth. This is the receiving post under the Academy procedure "External Stakeholder Complaint, Grievance, Investigation, and Remedy". Farmer grievances follow the farmer grievance procedure and are also logged in the central complaints register; discrimination and other serious cases are also filed as an Academy Alert. The Director of New Projects coordinates with the Head of Legal (Division 7) throughout the process so that every grievance is properly and appropriately handled.

The policy owner maintains a restricted grievance register containing, as appropriate:

• date received and channel;
• stakeholder category and general subject;
• status and responsible owner;
• material steps and dates;
• outcome category and corrective actions;
• closure date.

Access is limited to authorised persons. Case records will normally be retained for at least three years, or longer where required by law, contract, certification, litigation hold or legitimate risk-management needs.

At least annually, management will review an anonymised summary of grievance numbers, types, status, outcomes, timeliness and relevant improvement actions, and report it to the Board. Public reporting, where required, will use aggregated or anonymised information and will not create a right to case-specific disclosure.

12. Relationship with existing Green Earth procedures

• External stakeholder cases are handled step by step under the External Stakeholder Complaints, Grievances, and Remedy Policy and the External Stakeholder Complaint, Grievance, Investigation, and Remedy procedure.
• Staff grievances follow the Grievance and Complaints (Staff) Policy and the Staff Grievance Reporting procedure.
• Reports of serious internal wrongdoing follow the Whistleblower and Non-Retaliation Policy and the applicable Alert Report procedures.
• Enrolled farmer grievances follow the applicable Farmer Grievance and Dispute Policy and the Farmer Grievance Reporting procedure.
• Customer-service, contractual, safeguarding, disciplinary and legal matters follow their applicable specialist route.

Where a submission falls under more than one procedure, Green Earth will select or coordinate the route that best protects fairness, confidentiality, legal compliance and efficient resolution. This policy does not amend contractual rights, admit liability or create enforceable rights beyond those required by applicable law.

13. Approval and review

This policy is approved by the Chief Executive Officer on behalf of the Board. The policy owner reviews it at least once a year, and after a material change in Green Earth's structure, operations or legal obligations.