Grievance & whistleblower protection policy
Speak up policy
Last updated: 24 July 2026
Effective date: 17 July 2026
Speak up policy
Applies to: Employees, former employees, applicants, contractors, clients, customers, suppliers, business partners, local communities and members of the public.
Contact: Reports may be submitted by
E-mail to [email protected] using the subject line “Confidential grievance or whistleblower report”.
Telephone via +31528760060
Requesting an in-person meeting.
Designated speak up officer:
Reports are received and coordinated by the designated Speak Up Officer. Miron Violetglass B.V. has appointed an independent external confidential counsellor (Whistleblowing Officer) through Meglio Coaching to receive, assess and coordinate whistleblower reports.
Contact details:
Monika Rol - Meglio Coaching
E-mail [email protected]
1) Purpose
Miron Violetglass B.V. 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 B.V.
Report suspected misconduct, wrongdoing or breaches of law
Raise concerns about social, environmental or governance impacts
Do so without fear of retaliation or disadvantage
Miron Violetglass B.V. 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
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 B.V.
3) Grievances and whistleblower reports
a) Grievance or complaint
A grievance is generally a concern about an action, decision, experience or impact that directly affects an individual, organization, community or other stakeholder.
b) 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 B.V.
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
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 B.V. 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 B.V. 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”.
Reports may also be submitted by telephone or, upon request, through an in-person meeting with the Designated Speak Up Officer. Oral reports will be documented in a durable form. The reporting person will be offered the opportunity to review, correct and approve the written record before it is retained.
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
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 B.V.
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 B.V. 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.
Anonymous reports will be registered and handled in the same manner as identified reports where sufficient information is available.
8) Handling process
a) Acknowledgement
Miron Violetglass B.V. will acknowledge receipt of a report within seven calendar days, unless the report was submitted anonymously without a means of communication.
b) 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, ensuring that the designated person is independent, impartial and free from conflicts of interest
Whether an independent external investigator should be appointed
Whether the matter should be referred to a competent authority
c) 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.
d) 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.
Where appropriate, the reporting person may be contacted during the investigation to request additional information or clarification.
If the investigation cannot reasonably be completed within this period, Miron Violetglass B.V. will provide an update and, where possible, an indicative timeframe.
e) 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
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.
If a report is not accepted as a grievance under this policy, the reporting person will, where reasonably possible and legally permitted, receive an explanation of why the matter falls outside the scope of this policy. Where appropriate, the reporting person will also be directed to the most suitable alternative procedure or contact point.
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 B.V. 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 B.V. 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.
Reporting persons may be accompanied by a colleague, trusted adviser, legal representative or trade union representative during meetings relating to their report, where permitted by law.
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
Retaliation against colleagues, relatives or organizations connected to the reporting person
Anyone who believes they have experienced retaliation should report this immediately to [email protected].
Confirmed retaliation against a reporting person may result in one or more of the following actions, depending on the seriousness of the conduct:
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 B.V. will only collect and retain information that is relevant and proportionate to the assessment, investigation and resolution of a report.
Reports, including oral reports and any written records thereof, together with supporting documentation, investigation records and outcomes, will be stored securely and access will be restricted to authorised persons. Such records will be retained only for as long as necessary in accordance with applicable legal and regulatory retention requirements.
15) External reporting and independent advice
Advice
Reporting persons may choose to report internally or directly to a competent external authority. Miron Violetglass B.V. encourages internal reporting where the concern can be addressed effectively and the reporting person feels safe doing so, but internal reporting is not a legal prerequisite for external reporting.
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 B.V. 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.
a) Governance
The Board of Miron Violetglass B.V. is responsible for overseeing the effectiveness of this policy and ensuring adequate resources for its implementation.
Persons responsible for receiving and handling reports will receive appropriate training.
This policy will be reviewed at least annually and whenever changes in legislation or organisational structure require it.
17) Policy accessibility and review
This policy is publicly available on the website of Miron Violetglass B.V. 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 B.V.
18) Contact
Questions, grievances and whistleblower reports relating to this policy may be submitted to:
Miron Violetglass B.V.
Email: [email protected]