Grievance & whistleblower protection policy

Speak up policy

Last updated: July 24, 2026

Effective date: July 17, 2026

Speak Up Policy

Applies to: Employees, former employees, job applicants, contractors, customers, suppliers, business partners, local communities, and members of the public.

Contact

Reports or grievances may be submitted through any of the following channels:

  • Email: [email protected], using the subject line "Confidential Grievance or Report"

  • Phone: +1 323 407 7089

  • Request an in-person meeting

Reporting Officer

Reports are received and coordinated by the designated Reporting Officer. Miron Violetglass USA, Inc. has appointed an independent external confidential advisor (Whistleblowing Officer) through Meglio Coaching to receive, assess, and coordinate reports.

Contact details

Monika Rol - Meglio Coaching

Email: [email protected]

1) Purpose

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

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

  • raise a grievance concerning Miron Violetglass USA, Inc.;

  • report suspected misconduct, wrongdoing, or violations of law;

  • raise concerns about social, environmental, or governance impacts; and

  • do so without fear of retaliation or any other adverse consequences.

Miron Violetglass USA, Inc. views reports as an opportunity to identify risks, address concerns, and strengthen our policies, practices, and impact on stakeholders.

2) Scope

This policy applies to all internal and external stakeholders, including:

  • current and former employees;

  • job applicants, interns, temporary workers, and volunteers;

  • independent contractors, consultants, and other workers;

  • customers;

  • suppliers and their employees;

  • shareholders and business partners;

  • local communities; and

  • members of the public affected by our activities.

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

3) Grievances and Reports

a) Grievance

A grievance generally concerns an action, decision, experience, or impact that directly affects an individual, organization, community, or another stakeholder.

b) Report

A report is a communication regarding suspected misconduct, wrongdoing, or a violation of law that has occurred, is occurring, or is reasonably likely to occur in connection with the workplace or the activities of Miron Violetglass USA, Inc.

A reporting person is not required to prove that wrongdoing has occurred. However, the reporting person must have reasonable grounds to believe that the information reported was true at the time the report was made.

4) What may be reported

Reports may include, but are not limited to:

  • fraud, theft, bribery, corruption, or other financial misconduct;

  • conflicts of interest or abuse of authority;

  • violations of applicable laws or regulations;

  • violations of internal policies, codes of conduct, or contractual obligations;

  • unsafe working conditions or violations of health and safety requirements;

  • discrimination, harassment, bullying, intimidation, or unfair labor practices;

  • human rights violations, forced labor, child labor, 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 unfair business practices;

  • misconduct within our supply chain or by a business partner;

  • false or misleading statements regarding social or environmental performance;

  • false or misleading statements relating to B Corp Certification;

  • attempts to conceal any of the matters listed above;

  • retaliation against a person who makes or supports a report; or

  • any other credible and sufficiently specific concern relating to the activities or impacts of Miron Violetglass USA, Inc.

5) Matters outside the scope of this policy

Routine commercial inquiries, product questions, order-related matters, and customer service requests should normally be directed through the standard customer service channels.

Individual employment matters that do not involve suspected wrongdoing or a broader public interest concern may be addressed through Human Resources or other applicable internal procedures.

If a concern falls outside the scope of this policy, Miron Violetglass USA, Inc. will, where reasonably possible, direct the individual to the appropriate contact or process.

6) How to submit a report

A grievance or report may be submitted by email to: [email protected]

Please use the subject line: "Confidential Grievance or Report"

Reports may also be submitted by telephone or, upon request, during an in-person meeting with the designated Reporting Officer. Oral reports will be documented in a durable format. The reporting person will have the opportunity to review, correct, and approve the written record before it is retained.

Where possible, a report should include:

  • a clear description of the concern;

  • relevant dates, locations, departments, or organizations;

  • the names or roles of individuals involved, if known;

  • an explanation of how the reporting person became aware of the matter;

  • any supporting documents, correspondence, photographs, or other evidence;

  • information about any actions already taken to address the concern; and

  • contact information for follow-up communication, unless the report is submitted anonymously.

Reports may be submitted in English or any other language commonly used in the business activities of Miron Violetglass USA, Inc.

7) Anonymous reports

Reports may be submitted without providing a name or other identifying information. Individuals who wish to remain anonymous should avoid including details that could inadvertently reveal their identity.

Please note that a standard email account may disclose the sender's identity. Individuals wishing to remain anonymous may choose to use an email address that cannot be linked to them.

Miron Violetglass USA, Inc. will assess anonymous reports based on the information provided. Anonymous reporting may limit our ability to request additional information, conduct a comprehensive investigation, or communicate the outcome.

Anonymous reports will be documented and handled in the same manner as identified reports, provided they contain sufficient information for assessment.

8) Report handling procedure

a) Acknowledgment of receipt

Miron Violetglass USA, Inc. will acknowledge receipt of a report within seven calendar days, unless the report was submitted anonymously and no means of contact is available.

b) Initial assessment

The initial assessment will determine:

  • whether the matter falls within the scope of this policy;

  • whether immediate protective or corrective action is required;

  • who should be responsible for handling or investigating the report, ensuring that the individual is independent, impartial, and free from any conflict of interest;

  • whether an independent external investigator should be appointed; and

  • whether the matter should be referred to an appropriate regulatory, law enforcement, or other competent governmental authority.

c) Investigation

Reports will be investigated fairly, objectively, and without undue delay. The person responsible for handling the report must act independently and must not have a conflict of interest in relation to the matter being investigated.

An investigation may include reviewing documents, interviewing relevant individuals, obtaining expert advice, and giving affected persons an opportunity to respond before conclusions are reached.

All parties are expected to cooperate in good faith and preserve relevant information.

d) Feedback

Where permitted by law and where contact information is available, the reporting person will receive information about the assessment of the report and any follow-up actions within three months after acknowledgment of receipt.

Where appropriate, the reporting person may be contacted during the investigation to provide additional information or clarification.

If the investigation cannot reasonably be completed within that period, Miron Violetglass USA, Inc. will provide an update on the status of the matter and, where possible, an estimated timeline for completion.

e) Outcome and corrective action

Depending on the findings, Miron Violetglass USA, Inc. may take one or more of the following actions:

  • correct or stop the reported conduct;

  • improve policies, procedures, controls, or training;

  • remedy adverse impacts where reasonably possible;

  • take appropriate disciplinary action;

  • suspend or terminate a relationship with a supplier or business partner;

  • refer the matter to an appropriate regulatory, law enforcement, or other competent governmental authority; or

  • determine that no further action is required where the report is unsubstantiated.

Where permitted by law, the reporting person will receive a summary of the outcome. Personal, employment-related, or legally protected confidential information may be withheld.

If a concern does not qualify as a grievance or report under this policy, the individual will, where reasonably possible and permitted by law, be informed of the reason. Where appropriate, the individual will also be directed to the most suitable contact or process.

9) Review

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

Requests for review should be submitted to [email protected] and should explain the reasons for requesting the review.

Where reasonably possible, the review will be conducted by an individual who was not involved in the original decision.

10) Confidentiality

Reports and related personal information will be handled confidentially. Information will be shared only with individuals who need access for the purpose of assessing, investigating, or resolving the matter, or where disclosure is required by law.

Miron Violetglass USA, Inc. will not disclose the identity of a reporting person, or information that could reveal their identity, without the reporting person's consent, unless disclosure is required or permitted by law.

Where disclosure is legally required, the reporting person will normally be informed in advance unless doing so would compromise an investigation or violate applicable law.

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

11) Protection against retaliation

Miron Violetglass USA, Inc. prohibits any form of retaliation against a person who makes a report, seeks advice, assists a reporting person, or participates in an investigation, provided that the individual had reasonable grounds to believe the reported information was true at the time of reporting.

Where permitted by law, a reporting person may be accompanied during meetings relating to their report by a colleague, trusted person, legal representative, or union representative.

Prohibited retaliation may include, but is not limited to:

  • termination, suspension, demotion, or reduction of working hours;

  • denial of promotion, training, or employment opportunities;

  • unjustified negative performance evaluations;

  • harassment, intimidation, discrimination, or exclusion;

  • punitive changes to job duties or working conditions;

  • financial disadvantage or reputational harm;

  • termination or non-renewal of a contract;

  • blacklisting or denial of future employment or business opportunities;

  • threats or attempts to engage in retaliatory actions; or

  • retaliation against colleagues, family members, or organizations associated with the reporting person.

Anyone who believes they have experienced retaliation is encouraged to report it immediately to [email protected].

If retaliation is substantiated, Miron Violetglass USA, Inc. may take one or more appropriate corrective actions based on the seriousness of the circumstances.

12) Good faith reporting

A report does not need to be substantiated for the reporting person to receive protection under this policy. Protection applies provided the reporting person had reasonable grounds to believe the reported information was true at the time the report was made.

No action will be taken against a person solely because a report is not substantiated.

Knowingly making false or misleading reports, falsifying evidence, or submitting a report primarily to harm another person is not protected under this policy and may result in appropriate corrective or disciplinary action.

13) Rights of persons named in a report

People named in a report will be treated fairly and impartially. A report or allegation does not, by itself, mean that wrongdoing has occurred.

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

14) Personal data and recordkeeping

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

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

Reports, including oral reports and any written records, together with supporting documentation, investigation records, and outcomes, will be stored securely. Access will be limited to authorized individuals. Records will be retained only for as long as necessary to comply with applicable legal, regulatory, and business record retention requirements.

15) External reporting and independent advice

Advice

A reporting person may choose to report concerns internally or directly to an appropriate external authority. Miron Violetglass USA, Inc. encourages internal reporting whenever concerns can be addressed effectively and the reporting person feels comfortable doing so. However, internal reporting is not a legal prerequisite for reporting to an external authority where permitted by applicable law.

Depending on the nature of the concern, reporting persons may contact an appropriate federal, state, or local regulatory authority, law enforcement agency, or other competent governmental authority.

Individuals may also seek independent information or guidance from the governmental authority or regulatory agency responsible for overseeing the subject matter of their concern.

More information is available through the relevant federal, state, or local government agency.

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 any person's right to obtain independent legal advice, contact a labor union or employee representative where applicable, or consult another qualified advisor.

16) Monitoring and continuous improvement

Miron Violetglass USA, Inc. will document grievances and reports, the actions taken in response, and the outcomes, subject to applicable confidentiality and privacy requirements.

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

a) Governance

The management of Miron Violetglass USA, Inc. is responsible for overseeing the effectiveness of this policy and ensuring that adequate resources are available for its implementation.

Individuals responsible for receiving and handling reports will receive appropriate training.

This policy will be reviewed at least annually and whenever changes in applicable laws, regulations, or the organization's structure require an update.

17) Policy availability and review

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

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

18) Contact

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

Miron Violetglass USA, Inc.

Email: [email protected]