Grievance Mechanism

Introduction

VENBEST LLC is committed to upholding the highest standards of ethical conduct, human rights,and accountability in all aspects of its operations. This Grievance Mechanism is designed toprovide a transparent, accessible, and effective process for receiving, addressing, and resolvingcomplaints related to the conduct of VENBEST LLC personnel and operations, in accordance withthe principles of ISO 18788 and the International Code of Conduct for Private Security ServiceProviders (ICoCA).

Purpose

The purpose of this Grievance Mechanism is to:

  • Provide a clear and accessible channel for stakeholders, including clients, personnel,subcontractors, and affected communities, to raise concerns or complaints regardingVENBEST’s operations or personnel conduct.
  • Ensure timely, fair, and impartial investigation and resolution of grievances.
  • Promote transparency, accountability, and continuous improvement in VENBEST’s security services.
  • Support compliance with applicable laws, human rights standards, and contractual obligations.

Scope

This mechanism applies to all VENBEST LLC personnel, subcontractors, and operations worldwide.
It covers grievances related to:

  • Alleged violations of laws, regulations, or company policies.
  • Human rights abuses, including discrimination, harassment, abuse, or exploitation.
  • Breaches of the International Code of Conduct for Private Security Service Providers.
  • Any other conduct that negatively impacts clients, personnel, or affected communities.

Principles

VENBEST’s grievance process is guided by the following principles:

  • Accessibility: The grievance mechanism is available to all stakeholders without discrimination.
  • Confidentiality: Complainants’ identities and information are protected to the fullest extent possible.
  • Impartiality: Grievances are handled fairly and without bias.
  • Transparency: Complainants are informed about the process and outcomes.
  • Non-retaliation: No retaliation or adverse consequences will be tolerated against those who raise grievances in good faith.
  • Timeliness: Complaints will be addressed promptly within defined timeframes.

Reporting Channels

Venbest provides multiple channels for submitting grievances:

  • Direct contact: Complaints can be submitted verbally or in writing to any Venbest manager or supervisor.
  • Dedicated email: mailto: complaints@venbest.com.ua
  • Anonymous reporting: Through a 24/7 hotline 0800207523 or “Contact us” form on the website https://venbest.ua/
  • In-person: At Venbest offices all over Ukraine (addresses whit the current working hoursare availableon the website https://venbest.ua/

Grievance Handling Process

1. Receipt and Registration

  • All grievances received are logged in a secure Grievance Register.
  • Acknowledgment of receipt is provided to the complainant within 5 business days.

2. Assessment and Investigation

  • The grievance is assessed for severity, credibility, and urgency. of receipt is provided to the complainant within 5 business days.
  • An impartial investigation team is assigned.
  • Investigations are conducted confidentially, respecting the rights of all parties.
  • Evidence is collected, and interviews are conducted as necessary.

3. Resolution and Response

  • Based on findings, appropriate corrective or disciplinary actions are taken.
  • The complainant is informed of the outcome and any remedial measures within 30 calendar days, or sooner if possible.
  • Where grievances cannot be resolved directly, referral to external authorities or mediation may occur.

4. Cooperation with External Investigations

  • VENBEST LLC is fully committed to escalating or reporting complaints to competent authorities when required.
  • Our process includes a duty to cooperate fully with external investigations. Where allowed and appropriate, all relevant records and documentation will be made available to competent authorities to facilitate thorough and effective investigations.

5. Monitoring and Follow-up

  • Implementation of corrective actions is monitored.
  • Follow-up is conducted to ensure grievance closure and satisfaction of the complainant.
  • Records of grievances and outcomes are maintained for continuous improvement.

Protection Against Retaliation

VENBESR LLC strictly prohibits retaliation against anyone who raises a grievance or participates in an investigation. Any retaliation will result in disciplinary action, up to and including termination.

Confidentiality and Data Protection

All grievance-related information is handled confidentially and stored securely in compliance with applicable data protection laws and company policies. Disclosure of information to competent authorities will occur only as required by law, or with the consent of the complainant, except where disclosure is necessary for legal compliance or investigation purposes.

Communication and Training

VENBEST commits to regularly informing all personnel and stakeholders about the grievance mechanism and providing training to ensure effective implementation.

Review and Continuous Improvement

This Grievance Mechanism is reviewed annually oras needed to incorporate lessons learned,changes in legal requirements, orbest practices, ensuring ongoing effectiveness and alignmentwith ISO 18788 and ICoCA standards.

Date of Implementation: 13 May 2025

Vadym Olianishyn

General Director

VENBEST LLC

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