Grievance & Whistleblower Protection Policy

1. Purpose

Miron Violetglass USA, Inc. is committed to conducting its business with integrity, transparency and accountability, and to considering the interests of all people and communities affected by its activities.

This policy provides a clear and accessible mechanism through which internal and external stakeholders can:

• raise a grievance or complaint concerning Miron Violetglass USA, Inc.;
• report suspected misconduct, wrongdoing or breaches of law;
• raise concerns about social, environmental or governance impacts; and
• do so without fear of retaliation or disadvantage.

Miron Violetglass USA, Inc. treats reports as an opportunity to identify risks, correct problems and improve its policies, practices and stakeholder impact.

2. Scope

This policy is available to all internal and external stakeholders, including:

• current and former employees;
• job applicants, interns, temporary workers and volunteers;
• self-employed workers, consultants and contractors;
• clients and customers;
• suppliers, vendors and their employees;
• shareholders and business partners;
• local communities; and
• members of the public affected by our activities.

This policy covers concerns relating to the activities, conduct, products, services, business relationships and supply chain of Miron Violetglass USA, Inc.

3. Grievances and whistleblower reports

3.1 Grievance or complaint

A grievance is generally a concern about an action, decision, experience or impact that directly affects an individual, organisation, community or other stakeholder.

3.2 Whistleblower report

A whistleblower report concerns suspected wrongdoing, misconduct or a breach of law that has occurred, is occurring or is likely to occur in a work-related context or in connection with the activities of Miron Violetglass USA, Inc.

A reporting person does not need to prove that wrongdoing has occurred. However, they should have reasonable grounds to believe that the information reported is accurate at the time of reporting.

4. What may be reported

Concerns may include, but are not limited to:

• fraud, theft, bribery, corruption or financial misconduct;
• conflicts of interest or abuse of authority;
• breaches of applicable laws or regulations;
• breaches of internal policies, codes of conduct or contractual obligations;
• unsafe working conditions or breaches of health and safety requirements;
• discrimination, harassment, bullying, intimidation or unfair labour practices;
• human rights violations, forced labour, child labour or worker exploitation;
• environmental harm or materially misleading environmental claims;
• improper waste management, pollution or unsustainable practices;
• product safety, product quality or consumer protection concerns;
• privacy, cybersecurity or personal data protection violations;
• anti-competitive conduct or improper business practices;
• misconduct within our supply chain or by a business partner;
• misrepresentation of social or environmental performance;
• misrepresentation relating to B Corp Certification;
• attempts to conceal any of the matters listed above; or
• retaliation against someone who has raised or supported a concern.

Other material, credible and specific concerns relating to the activities or impacts of Miron Violetglass USA, Inc. may also be considered.

5. Matters outside the scope of this policy

Routine commercial enquiries, product questions, order issues and requests for customer service should normally be submitted through our regular customer service channels.

Individual employment matters that do not involve suspected wrongdoing or a broader public interest may be addressed through the relevant internal HR or grievance procedure.

When a report falls outside the scope of this policy, Miron Violetglass USA, Inc. will, where reasonably possible, direct the reporting person to the appropriate contact or procedure.

6. How to submit a report

A grievance or whistleblower report may be submitted by email to:

[email protected]

Please use the subject line: “Confidential – Grievance or Whistleblower Report”.

Where possible, the report should include:

• a clear description of the concern;
• the relevant dates, locations, departments or organisations;
• the names or roles of people involved, where known;
• an explanation of how the reporting person became aware of the matter;
• any supporting documents, correspondence, photographs or other evidence;
• details of any steps already taken to address the concern; and
• contact details for follow-up, unless the report is submitted anonymously.

Reports may be submitted in English, Dutch or another language commonly used within the operations of Miron Violetglass USA, Inc.

7. Anonymous reporting

Reports may be submitted without providing a name or other identifying information. A person wishing to remain anonymous should avoid including information that could unintentionally reveal their identity.

Please note that an ordinary email account may disclose identifying information. A reporting person wishing to remain anonymous may choose to use an email address that does not reveal their identity.

Miron Violetglass USA, Inc. will assess anonymous reports based on the information available. Anonymous reporting may limit our ability to request additional information, investigate the matter or communicate the outcome.

8. Handling process

8.1 Acknowledgement

Miron Violetglass USA, Inc. will acknowledge receipt of a report within seven calendar days, unless the report was submitted anonymously without a means of communication.

8.2 Initial assessment

An initial assessment will determine:

• whether the matter falls within the scope of this policy;
• whether immediate protective or corrective measures are required;
• who should handle or investigate the report;
• whether an independent external investigator should be appointed; and
• whether the matter should be referred to a competent authority.

8.3 Investigation

Reports will be reviewed fairly, objectively and without unnecessary delay. The person handling the report must be sufficiently independent and must not have a conflict of interest in relation to the matter.

An investigation may include reviewing documentation, interviewing relevant people, obtaining specialist advice and giving affected persons an appropriate opportunity to respond.

All parties are expected to cooperate honestly and to preserve relevant information.

8.4 Feedback

The reporting person will receive information about the assessment and follow-up within three months of the acknowledgement of receipt, where legally permitted and where contact details are available.

If the investigation cannot reasonably be completed within this period, Miron Violetglass USA, Inc. will provide an update and, where possible, an indicative timeframe.

8.5 Outcome and corrective action

Depending on the findings, actions may include:

• correcting or stopping the relevant conduct;
• improving policies, processes, controls or training;
• remedying negative impacts where reasonably possible;
• taking proportionate disciplinary action;
• suspending or terminating a supplier or business relationship;
• reporting the matter to a regulator, law enforcement body or other authority; or
• taking no further action where the concern is not substantiated.

Where legally permitted, the reporting person will receive a summary of the outcome. Confidential employment, legal or personal information may be withheld.

9. Review or appeal

A reporting person who believes that a grievance was not handled fairly or that relevant information was not properly considered may request a review within ten business days of receiving the outcome.

The request should be sent to [email protected] and should explain the reasons for requesting a review.

Wherever reasonably possible, the review will be conducted by a person who was not responsible for the original decision.

10. Confidentiality

Reports and related personal information will be treated confidentially. Information will only be shared with people who need it to assess, investigate or resolve the matter, or where disclosure is required by law.

Miron Violetglass USA, Inc. will not disclose the identity of a reporting person, or information from which their identity may be inferred, without their consent unless disclosure is necessary and legally permitted or required.

Where disclosure is legally required, the reporting person will normally be informed in advance unless doing so would prejudice an investigation or breach a legal obligation.

Confidentiality also applies to the identity and rights of persons named in or affected by a report.

11. Protection against retaliation

Miron Violetglass USA, Inc. prohibits retaliation against anyone who reports a concern, seeks advice, assists a reporting person or participates in an investigation, provided they had reasonable grounds to believe the information reported was accurate.

Prohibited retaliation may include:

• dismissal, suspension, demotion or reduction of working hours;
• withholding promotion, training or employment opportunities;
• negative performance assessments without objective justification;
• harassment, intimidation, discrimination or exclusion;
• changing duties or working conditions as a punishment;
• financial disadvantage or reputational harm;
• cancelling or refusing to renew a contract;
• blacklisting or denying future work or business opportunities;
• threats or attempts to take any retaliatory action; or
• retaliation against colleagues, relatives or organisations connected to the reporting person.

Anyone who believes they have experienced retaliation should report this immediately to [email protected] .

Confirmed retaliation or attempts to obstruct a report may result in disciplinary, contractual or legal action.

12. Reports made in good faith

A report does not need to be substantiated for the reporting person to receive protection. Protection applies where the person had reasonable grounds to believe that the reported information was accurate.

No action will be taken against someone merely because a concern could not be substantiated.

Knowingly submitting false or misleading information, fabricating evidence or making a report primarily to harm another person is not protected and may result in appropriate action.

13. Rights of persons named in a report

People named in a report will be treated fairly and impartially. An allegation does not imply that wrongdoing has occurred.

Subject to confidentiality and legal restrictions, affected persons will be informed of the substance of allegations against them and given a reasonable opportunity to respond before conclusions are reached.

14. Personal data and record keeping

Personal data collected under this policy will be processed in accordance with applicable privacy and data protection laws.

Miron Violetglass USA, Inc. will only collect and retain information that is relevant and proportionate to the assessment, investigation and resolution of a report.

Reports, investigation records and outcomes will be stored securely and access will be restricted to authorised persons. Records will not be retained for longer than necessary, subject to applicable legal and regulatory retention requirements.

15. External reporting and independent advice

Reporting persons are encouraged to use the internal reporting channel where the matter can be addressed effectively and where they feel safe doing so. However, a person is not required to report internally before contacting a competent external authority.

Depending on the nature of the concern, reporting persons may contact a competent regulator, supervisory authority, law enforcement body or the Dutch Whistleblowers Authority.

The Dutch Whistleblowers Authority provides confidential and independent information and advice to people considering reporting work-related wrongdoing.

More information is available at: Dutch Whistleblowers Authority .

Concerns specifically relating to the conduct or B Corp Certification of a Certified B Corporation may also be submitted through B Lab’s public complaints process.

More information is available at: B Lab Public Complaints Process .

Nothing in this policy limits a person’s right to obtain independent legal advice, contact a trade union or consult another appropriate adviser.

16. Monitoring and continuous improvement

Miron Violetglass USA, Inc. will document grievances and reports, their handling and their outcomes, subject to confidentiality and data protection requirements.

Information may be reviewed in aggregated or anonymised form to identify recurring issues, improve controls, prevent negative impacts and strengthen our social, environmental and governance performance.

17. Policy accessibility and review

This policy is publicly available on the website of Miron Violetglass USA, Inc. and may also be referenced in employee information, contracts, supplier documentation and onboarding materials.

The policy will be reviewed at least annually and whenever there is a material change in applicable legislation, B Corp standards or the organisation and activities of Miron Violetglass USA, Inc.

18. Contact

Questions, grievances and whistleblower reports relating to this policy may be submitted to: