Complaints policy.

Article 1 – Definition of terms

The terms of this procedure are defined as follows:

1. Complaint: in the context of this procedure, a complaint is any written expression of grievance or a report of a (suspected) infraction or irregularity by or on behalf of a complainant, regarding:
   1. the communications, business conduct and/or working methods of Simavi in general;any behaviour, actions or negligence of any staff of Simavi (including the management, volunteers and the members of Supervisory Board);
   2. any behaviour, actions or negligence of partners, consultants and/or contractors of Simavi, involved in the implementation of programmes under responsibility of Simavi;
   3. any infringement of the principles stated in the Code of Conduct by Simavi or its affiliates;
   4. that has not been corrected after initial steps to raise the complaint have been taken informally.
2. Complainant: any natural or legal person who files a complaint.
3. Complaints Coordinator: the Director Finance and Operations (DFO). The DFO is entrusted to implement this Complaint policy and monitor and report on its processes and execution. In case the DFO is object of complaint, the Managing Director will replace the DFO as Complaints Coordinator.
4. Case Team: Two or more designated persons that will process the complaint, conduct the investigation, advise the Managing Director or Supervisory Board on actions to be taken if warranted, including disciplinary measures. If the Managing Director is object of complaint, his/her role in this procedure will be taken up by the chair of the Supervisory Board.
5. Interpersonal violation: discrimination, intimidation, humiliation, violence, bullying, unsolicited intimacy, sexual intimidation, sexual harassment and violence.

Article 2 – Who can submit a complaint

Any natural or legal person may submit a complaint or report a (suspected) irregularity. This disregarding its position or role, be it the aggrieved, victim, witness, (remorseful) perpetrator, affiliate or concerned citizen. Simavi employees and volunteers are also referred to the internal Confidential adviser and complaint policy (5.2.1.7).

Article 3 – Letter of Complaint

A complaint is filed by submitting a Letter of Complaint to the Complaints Coordinator of Simavi at the Simavi office, Naritaweg 135, 1043 BS, Amsterdam, the Netherlands, preferably by email to: complaints@simavi.nl.

The Letter of Complaint shall not be anonymous and should include:

• name and address of the complainant;
• a description and the date of the issue or behaviour complained about;
• the reason why the complainant objects to or reports this act/behaviour;
• in case of a suspicion: any supporting evidence for such suspicionin case of an interpersonal violation: the names of the parties involved and their roles;
• any available supporting information or documentation.

In case the violation is of such a nature that the complainant does not entrust Simavi to appropriately act or has strong reasons to protects its identity, the complainant can file its complaint or report the (suspected) irregularity by using the Whistle-Blower Policy of Simavi. This policy is available on the Simavi website: whistle-blower policy.

Article 4 – Confirmation of receipt

The Complaints Coordinator receives the complaint and will issue a written confirmation of receipt of the Letter of Complaint and register the receipt of the letter in the complaint register within one working week. The confirmation of receipt will include information on how the complaint is going to be dealt with and what the expected duration of the process will be.

Article 5 – Period of processing and adjournment

The Complaints Coordinator shall process the complaint within six weeks from the date of receiving the Letter of Complaint.The Complaints Coordinator can adjourn the processing of the complaint for a maximum of four weeks, or in case an external investigation is done, for the duration of such external investigation. This adjournment will be communicated in writing to the complainant.

Article 6 – Processing of the complaint

In processing of the complaint, priority is given to the interests and privacy of the complainant and the possible aggrieved or victim(s). The latter will, wherever possible, be protected and safeguarded from further harm and will be assisted to cope with the harm or damages suffered.

1. Preliminary investigation – The Complaints Coordinator assesses the complaint and will determine its validity, nature, severity and persons involved.
   Based on the assessment the Complaints Coordinator will
   1. in simple cases, propose a (re)action to the complaint to the Managing Director and implement such (re)action once approved.
      
      Otherwise the Complaints Coordinator will:
   2. appoint a Case Team, suited and equipped to deal with the complaint. In case of interpersonal violations, the Case Team will always have at least one male and one female member. The Complaint Coordinator will lead the Case Team;
   3. assess the need of disclosing the complaint to the relevant regulators or supervisory authorities and make such disclosure when necessary;
   4. in case of a crime, report this to the police;
   5. assess the need for and coordinate external communications when deemed appropriate.
2. Investigation – The Case Team will assess the need for further investigation and decide, based on the nature and severity, on investigating the complaint by themselves or to contract an external party to do that. In both cases, the case Team will submit an investigation proposal to the Managing Director for approval. The investigation proposal will also address how the interests of all parties involved are safeguarded.

Article 7 – Investigation, hearings and advise

1. The Case Team will execute or monitor the investigation according to the investigation proposal.
2. The complainant and the person complained against are offered the opportunity to present their cases and put their views. In case the complainant and/or the person complained about decline their right to be heard, no such hearing will take place. A report of the hearing will be drawn up and signed off by the persons heard.
3. Based on all available documentation, including evidence and the hearing reports, the Case Team will prepare an investigation report. This report will contain:
   1. A description of the complaint
   2. A summary of the evidence, the results of the hearings and any other outcomes of the investigation
   3. Conclusions and recommendations. The recommendations will, where applicable, entail actions and measures to be taken to protect the victims and prevent further harm, to restore justice and preventive measures to avoid repetition.
4. This report shall be submitted to the Managing Director or the Supervisory Board of Simavi. A copy of the report will be filed with the complaints register.

Article 8 – Adjudication

The Managing Director or Supervisory Board shall study the findings and recommendations of the investigation report to make a judgment. Where appropriate, the Managing Director or Supervisory Board will also decide on penalties and/or disciplinary and preventive measures to be taken. Penalties or disciplinary measures must always be proportionally and consistent.

Article 9 – Announcement of the judgment

1. The Complaints Coordinator will provide the complainant with a written and explanatory judgment based on the findings of the investigation, including the possible consequences thereof. The investigation report, as described in Article 7, will be attached to the judgment.A copy will be forwarded to the person complained about; copies of the judgment may also be sent to his/her superior and others involved in the investigation. However for privacy reasons such report may be withheld or only partially shared.
2. If the complainant is dissatisfied with the settlement of his/her complaint, he/she may turn to Supervisory Board of Simavi. The Board will then assess whether the complaints process and/or investigation has been conducted in the correct manner and the measures are justified and appropriate.

Article 10 – Registration in the complaints register

All complaints are recorded in the complaints register. Per complaint, a file is created containing all relevant documentation, including the investigation report and the judgment. This register is administered by the Complaints Coordinator, at the office of Simavi in Amsterdam, the Netherlands.