Policy for Grievance /Complaints

Handling
Doc No: POL/HR/001 Issue No : 01 Revision No : 00 Effective Date : 23/11/2019

1. Objective & Scope

1.1 The purpose of this document is to formalize the management of grievances from TICL
stakeholders to minimize the social risks to the business. The grievance process, outlined
in the document, provides an avenue for stakeholders to voice their concerns and gives
transparency on how grievances will be managed internally, which aims to reduce conflict
and strengthen relationships between stakeholders

1.2 The grievance mechanism procedure applies to all internal and external stakeholders of
our operations.

2. Responsibility
2.1 Internal Stakeholders (Employee / Contractor)

2.2 External Stakeholders (Community, NGOs and Government)

3. Internal Stakeholders
3.1 It is envisaged that the majority of routine grievances can be resolved on an informal
basis. Therefore, the grievance should first be discussed with the employee’s /
contractor’s immediate manager who will investigate the matter in an attempt to resolve
the issue on an informal basis.

3.2 If it is not appropriate to raise the matter informally, or if the employees / contractor do not
receive a satisfactory outcome, the grievance should be made in writing to the Site Head
setting out full details and put in the Complaint Boxes installed at different locations.

3.3 The Personal Assistant of Site Head will open the complaints box on fortnightly basis and
collect all the complaints.

3.4 He will write down all particular in Grievances / Complaints Register (FRM/HR/030) and
present it to the Site Head along with complaints.

3.5 The Site Head will make arrangements for the proper investigation of the grievance /
complaint and hearing to be conducted by unconcerned HOD or assigned manager.

3.6 The hearing will normally be held within ten working days of receipt of the written
grievance, although this may need to be extended depending on the length of the
investigation and the availability of the appropriate manager.

3.7 Employees / contractors must take all reasonable steps to attend disciplinary meetings.
However, the employees / contractor must notify the Company forthwith if they are unable
to attend a meeting and a re-scheduled meeting will be arranged within (usually) 5 days
of the date originally proposed for the meeting.

3.8 During the hearing, the person accompanying the employees / contractor may consult
with the employees / contractor, and address the hearing, but may not answer question
on the employee’s / contractor’s behalf.

3.9 Following the hearing, a written response will be given to the employees / contractor,
normally within five working days.
 Policy for Grievance /Complaints
Handling
Doc No: POL/HR/001 Issue No : 01 Revision No : 00 Effective Date : 23/11/2019

3.10 If the employees / contractor are unsatisfied with the response, he may appeal in writing
to the Site Head setting out full details. The Site Head will arrange for a further hearing to
be conducted by a more senior manager than the manager responsible for the original
decision or send it to the Head of HR in Head Office. Their decision will be final and
there is no further appeal from this decision.

3.11 Following the hearing, a written response will be given to the employees / contractor,
normally within five working days.

3.12 If the employees / contractor wish to lodge a grievance after their employment has ended,
the Company and the employees / contractor may either go through the hearing and
appeals part of the Procedure, or the parties can agree to deal with matters on the basis
of a written grievance and response (without a hearing). The parties will discuss
whichever option is easiest at the time.

4. Complaint Through Telephone/Message/WhatsApp

4.1 Apart from complaint boxes, a mobile number is displayed at different location of the site
for logging a grievance / complaint.

4.2 The employees / contractor can call or drop SMS / WhatsApp on the given number with
his name, designation, department, site and details of the grievance/complaint.

4.3 All the complaints will be logged on the Grievances / Complaints Register (FRM/HR/030)
and allocated to site heads for further investigation.

4.4 After investigation, the response will be shared with the complainant.

5. Grievances / Complaints from External Customers (Farmers, NGOs, Government)

5.1 In case of farmers have any grievance with mills regarding price of sugar cane, fertilizer
provision, services, mill staff behavior etc. he can voluntarily register his complaint on
helpdesk number, provided on each farmer location.

5.2 Mills Office superintendent or any person designate by Head of AGRI, log farmer
complaint on Grievances / Complaints Register (FRM/HR/030).

5.3 If the severity of complaint is low and can be resolved through discussion with farmer by
Agri field officer or relevant Agri Manager, then it will be marked to the designated officer
for resolution as majority of routine grievances can be resolved on an informal basis.

5.4 If the nature of grievance/dispute is high and need involvement of the Agri head, such
complaints will be sent to respective Site Agri Head for further investigation and
resolution.

5.5 If the nature of complaint is critical or Agri department is a party or there is a conflict of
interest, such complaint will be handled through Grievance Handling Committee, which
comprises of the following members:

5.5.1 Head of Finance or designate

5.5.2 Head of Internal Audit
5.5.3 Head of Administration
5.5.4 Designated person from Agri Department
 Policy for Grievance /Complaints
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Doc No: POL/HR/001 Issue No : 01 Revision No : 00 Effective Date : 23/11/2019

5.6 Designated person / committee will evaluation the root cause of assigned complaint and
take appropriate corrective action.

5.7 Office Superintendent or designated person by Head of Agri will note the suggested root
cause and corrective action on Grievances / Complaints Register (FRM/HR/030).

5.8 Office Superintendent will be responsible to collect the Complainant’s feedback about
satisfaction/dissatisfaction.

5.9 In case of NGOs and Government the stakeholder contact officer is responsible
for assigning a grievance owner to liaise with the external stakeholder/s and work
on a resolution. Grievances will be screened depending the level of severity in
order to determine who the grievance owner will be and how the grievance is
approached. See below table categorizing the different levels:

Category Description Grievance Owner

When an answer can be provided immediately
And/or TICL are already working on a
Stakeholder Contact
Level 1 resolution.
Officer
(Only formal grievances to be lodged in the
External Grievance Register)
One off grievances that will not affect the Supervisor level or
Level 2
Reputation of TICL. above
Repeated, extensive and high profile grievances
Level 3 That may jeopardize the reputation of Executive level
TICL.

5.10 Mills administration after receiving complaint will investigate the matter and further find
the ways to resolve permanently.

Storing of Grievance

6. Reference Document
6.1 Grievances / Complaints Register (FRM/HR/030).
7. Distribution list
7.1 All Site Heads
7.2 All Agri Heads
7.3 VP HR & Sustainability
7.4 Site Administration Heads
7.5 All HODs
 Policy for Grievance /Complaints
Handling
Doc No: POL/HR/001 Issue No : 01 Revision No : 00 Effective Date : 23/11/2019

Prepared by:

(Name and signature)

Reviewed by:

(Name and signature)

Approved by:

(Name and signature)