Grievance Procedure

EcoSecurities Grievance Procedure “Procedure”

Procedure for handling complaints, claims and appeals – updated 17th April 2025

This Procedure is applicable to all of EcoSecurities’ business activities and open to all stakeholders.

1) INTRODUCTION

EcoSecurities has designed this Procedure for handling complaints, claims and appeals from its stakeholders, aligned with best practices and international standards, to strengthen its culture and ensure compliance with conduct regulations.  This reflects our commitment to transparency, ensuring consistent stakeholder engagement supported by clear communication.

EcoSecurities operates as a developer and marketer of climate and carbon finance instruments, including those used in voluntary and/or regulated carbon markets at both national and international levels. Through these activities, it aims to reduce greenhouse gas (GHG) concentrations and support global climate change mitigation efforts

 

2) OBJECTIVE

The purpose of this Procedure is to establish the mechanisms for handling and, if applicable, resolving any complaint or claim presented to EcoSecurities, ensuring that they are addressed fairly and impartially, and within the timeframes established herein.

 

3) GROUNDS FOR  CONSIDERING A CLAIM

Complaints will be considered in accordance with the below:

1. Material Claims: The complaint must involve issues that are significant or substantial in nature, meaning that the claim has the potential to affect the operations, reputation, or legal standing of the business. A material claim typically refers to allegations that could have a meaningful impact on EcoSecurities business practices, financial performance, or compliance with applicable laws and regulations.
2. Credible Claims: The claim must be based on facts, evidence, or circumstances that make it believable and reasonable. This means the complaint should be supported by clear, verifiable information, such as documented evidence, credible witness testimony, or other relevant data that can substantiate the allegation. Unfounded or speculative claims without supporting evidence will not be considered for investigation.
3. Specific Claims: The complaint must be clear and detailed, identifying particular incidents, behaviours, or actions that are being raised as concerns. Vague or generalized claims, such as broad accusations without clear examples or specific detail, will not be investigated. Specificity is necessary to understand the nature of the issue and to determine the appropriate course of action for resolution or further inquiry.

 

Generally, EcoSecurities will not investigate:

• Complaints regarding project delays which are directly attributable to backlogs with the carbon standards and therefore beyond the direct control of EcoSecurities;
• Complaints that are pending legal action and/or include accusations of illegal acts without a formal legal resolution.
• Complaints that are not directly tied to our business; or
• Complaints that include illegal actions and/or threats.

These exclusions are in place to maintain focus on matters within EcoSecurities control and to ensure compliance with legal and ethical standards.

 

4) MAKING A COMPLAINT

4.1. Requirements for submitting complaints

• The complaint must in writing and include the following information:
• name of the person submitting the complaint;
• name of the organization, if applicable;
• contact information of the person submitting the complaint; ;
• details of the complaint with material evidence; and
• statement of any conflict of interest when submitting the complaint.

 

The complaint must be addressed to the Chief Financial Officer listed on the EcoSecurities website and must be sent via email to lsc@ecosecurities.com with the word “complaint” in the subject line or it may be sent by post to:

EcoSecurities Head Office: Bâtiment Alto, Esplanade de Pont-Rouge 9A, 1212 Grand-Lancy, Geneva, Switzerland

 

5) GRIEVANCE HANDLING PROCESS AND TIMELINE

EcoSecurities process to manage claims includes the following steps:

1. EcoSecurities Head of Legal will review the claim within thirty (30) business days of receipt, to decide if it qualifies EcoSecurities will then notify the person who submitted it whether the claim will be considered further.
2. If considered further, the Chief Financial Officer will inform all relevant parties and assign EcoSecurities personnel to investigate the claim.

 

The investigation starts within two weeks and includes gathering input, reviewing facts, and preparing a draft report.

• A final report will be reviewed by the Board, approved, and shared with the stakeholder and the proposed resolution shall be communicated accordingly.
• Stakeholders have fifteen (15) business days to provide feedback on the report.
• The process is closed and documented within two weeks.

 

All information submitted regarding the complaint will be treated confidentially by EcoSecurities.

 

6) COMMUNICATION OF OUTCOME

EcoSecurities will communicate with the claimant at each major step of the process and will confirm when the grievance has been resolved. If the issue raised does not qualify as a grievance based on the grounds listed above under clause 3, the claimant will be informed of the rationale for non-acceptance.

 

7) APPEALS PROCESS

When a complaint has been submitted following the previous procedure and it has not been resolved to the satisfaction of the claimant, the claimant may use the following procedure to request an appeal:

1. The appeal must include the following information:
2. Name of the person submitting the appeal.
3. Name of the organization, if applicable.
4. Contact information of the person submitting the appeal.
5. Details of the appeal, including reference to the original complaint, claim, or report submitted.

The appeal must be sent via email to lsc@ecosecurities.com and addressed to the Chief Financial Officer of EcoSecurities with the word “Appeal” in the subject line. The sender will then receive an email response in which EcoSecurities acknowledges receipt of the appeal.

All information submitted with regard to the appeal will be treated confidentially by EcoSecurities.

 

8) PROTECTION AGAINST RETALIATION

8.1 EcoSecurities ensures that all stakeholders who raise concerns in good faith are protected from retaliation, harassment, adverse actions or any unfavourable treatment. Retaliation against claimants making a report will not be tolerated. We are committed to facilitating open communication and encouraging feedback, ensuring that stakeholders may report concerns without fear of retaliation or adverse consequences.

8.2 Stakeholders who have reasonable grounds to believe that retaliatory action has been taken against them, or is likely to be taken against them, as a consequence of their involvement in a protected activity may seek redress by submitting a formal complaint of retaliation to the Chief Financial Officer of EcoSecurities. Such submission must include all relevant information and supporting documentation available in relation to the complaint.

8.3 EcoSecurities designated authority (CEO) will review the retaliation complaint within (30) business days of receipt. During the review process, interim measures such as temporary suspension of the reported retaliatory action, may be taken to safeguard the claimant.

8.4 Whether an adverse action constitutes retaliation shall be determined by whether the action would have been taken for independent and legitimate reasons, absent the protected activity. If no such reasons exist, the action shall generally be considered retaliatory.

8.5 EcoSecurities reserves the right to take appropriate measures against any individual who initiates or threatens retaliation against any stakeholder making a report under this Policy. Any occurrence of retaliation will result in disciplinary measures.

 

9) ANNEX

Online platform for submitting Claims or Reports:

https://www.ecosecurities.com/contact