Grievance - Reinaert LLC

Purpose

Anyone who, in good faith, reports a suspected or actual violation of law, regulation, company policy or procedure, or ethical or professional standards, will be protected from retaliation because of such reporting regardless of whether or not, after investigation, a violation is found to have occurred.

No member of Reinaert shall discharge, demote, suspend, threaten, harass, or discriminate against the whistleblower for reporting what the whistleblower sincerely believes to be a serious actual or suspected violation or unethical act.

This whistleblower protection extends to individuals who provide information in relation to an investigation of a report by a whistleblower.

Any act of retaliation shall be treated by Reinaert as a serious violation of policy, which will result in disciplinary action.

If a whistleblower believes he/she is being retaliated against after reporting a violation, he/she should contact the CEO of Reinaert at (601) 207–2127.

If the CEO of Reinaert does not adequately resolve the issue, then the member is encouraged to call and report the issue to United States Department of Labor (www.whistleblowers.gov, 1-800-321-6742).

Employee Procedures

Employees must be treated fairly and receive prompt responses to problems and concerns. For this reason, Reinaert provides a grievance procedure that permits anonymity, to promote quick and responsible resolution of issues raised by staff. This procedure may be used freely without fear of retaliation, and the Manager of Human Resources (HR) will be available to assist throughout the process. The process outlined below should be used if an individual disagrees with a supervisor’s action, including any disciplinary action.

Step One:

Discuss Complaint with Immediate Supervisor.

Reinaert encourages informal resolution of complaints at the lowest level. Employees should first discuss the complaint with their immediate supervisor within three (3) business days of the situation whenever possible. If the complaint is not resolved because of this discussion, or such a discussion is not appropriate under the circumstances, proceed to Step Two. If the action in dispute involves suspension or termination of employment, Steps One and Two should be bypassed.

Note: If the immediate supervisor is an officer of the company, Step Two should be bypassed and the complaint submitted directly to the CEO, who will then schedule a meeting for the employee.

Step Two:

Prepare and Submit a Complaint Procedure Form to HR for Review by the company Operations Manager.

If the employee feels the complaint was not resolved in discussions with their immediate supervisor. In that case, they may prepare and submit a formal written complaint which will be reviewed by the person to whom the employee’s immediate supervisor reports (“second-level supervisor”). To do so, the employee should prepare a Complaint Procedure Form and submit it to HR within seven (7) business days of the Step One discussion with the immediate supervisor (or within seven (7) days of the event being grieved if Step One is bypassed). HR will then review the complaint, send a copy to the second-level supervisor and the immediate supervisor (if appropriate), and schedule a meeting for the employee, the second-level supervisor, to discuss the complaint. The meeting will ordinarily be held within five (5) business days of the HR’s receipt of the Complaint Procedure Form. The second-level supervisor will issue a written decision, generally within five (5) business days of the meeting. If the complaint is not resolved to the employee’s satisfaction, they may proceed to Step Three.

Step Three:

Submit Complaint Procedure Form to HR for Review by the company President.

Suppose the employee is not satisfied with the Step Two decision. In that case, they may proceed with the complaint within five (5) business days of receipt of the Step Two decision by submitting it to HR for review by the company CEO. A meeting between the employee, the Operations Manager, and the CEO will generally be held within five (5) business days. The company CEO will issue a written decision, generally within five (5) business days of the meeting.

General Information

The time limits above are subject to modification on a case-by-case basis due to operational requirements, travel away from the home office, in-depth investigations, etc. The CEO shall have the final authority to resolve any disputes regarding implementing this Complaint Procedure, including the determination of the appropriate decision-makers.

Client Complaint Procedure

Reinaert welcomes the information and feedback from clients, which will enable Reinaert to improve the quality of service provided. Reinaert recognizes the value in complaints and will accept the complaint openly. The complaint is seen as an opportunity to review and evaluate the service we deliver.

Steps:

1. Complaints will be made in person, over the phone, by email or in writing determined by the client (anonymous complaints are accepted).

2. The staff member who receives the complaint will immediately notify the Department Manager.

3. The complaint will be logged, as well as the action taken in the Non-conformance log.

4. All complaints will be treated seriously but will be dealt with at the lowest operational level, to ensure the issue is resolved promptly.

5. The staff member will advise the client of the complaint process, providing a written copy of the procedure and a flow chart.

6. The client will then submit a written notification addressed to the Department Manager or Client Manager.

7. We will attempt to resolve the issue within 14 days.

8. If the issue is not resolved to the client’s satisfaction, the client can raise the issue with the Client Manager.

9. The Client Manager will further investigate and prepare a response to the complaint and a report for the CEO of Reinaert within 28 days of receipt.

Third Party Grievance Procedure

Reinaert will handle grievances from third parties in a transparent and fair manner, and with due consideration for confidentiality and restrictions imposed by local laws in accordance with our global grievance policy. We will respect the confidentiality of the complainant, unless required by law to reveal their identity, and take all reasonable steps to protect complainants from retaliation. We will

report grievances to the appropriate external authorities when the nature or severity of the matter requires such action and give full support to any external investigating authorities.

How Third Parties can contact us

To register a grievance, third parties should send an email to [email protected] or access through the website at https://reinaert.com/about/ giving as much information as possible of the circumstances and Reinaert’s alleged involvement or fault.

Reinaert’s Response

Reinaert’s will acknowledge its receipt of the grievance promptly and no later than within 28 days. Senior management will undertake an initial assessment of the matter and will agree the parameters of the investigation. A member of Reinaert’s management team will be nominated to act as the point of contact for the complainant. The point of contact will provide an outline of the resolution process, the associated timeframes, progress updates and report on the outcome.

If a third party believes that their grievance has been handled inappropriately and would prefer to seek redress through an independent body, they are advised to refer to a relevant external body. Reinaert can provide guidance on which body is most relevant.