Last updated: 23/12/2025
Purpose
HewardMills is committed to operating with the highest standards of ethics, transparency, and accountability. This policy outlines how stakeholders may raise complaints be these governance concerns or grievances including but not limited to reports of misconduct. This policy sets out the procedures we follow to address these concerns. It also references our Whistleblowers Protection Policy which outlines strict protections for whistleblowers and our zero-tolerance approach to retaliation.
Scope
This Policy applies to all internal and external stakeholders including, but not limited to, employees,
contractors, clients, suppliers, and partners of HewardMills Ltd, HewardMills (Ireland) Limited, HewardMills
DPO Ghana Limited, HewardMills Nordics AS (collectively HewardMills) as well as the general public.
Governance & Grievance
HewardMills encourages the reporting of governance and grievance concerns related to:
- ethical misconduct such as fraud, corruption, or bribery
- environmental violations or unsustainable practices
- human rights violations or abuse
- unsafe or illegal workplace behaviour
- breaches of our policies, codes of conduct, or
- third-party obligations
You may raise a Complaint
- by sending an email to governance@hewardmills.com using Subject: Confidential – Governance/Grievance
- by completing the Governance/Grievance form here
The reporting message should contain details such as a description of the violation, date, time, location, and any supporting evidence. You may choose to remain anonymous.
Excluded Issues: issues not related to the company’s conduct, or internal HR matters not relevant to third parties, will not be investigated through this process. For further details on how to raise a complaint in relation to excluded matters, please consult the HewardMills Employee or Contractor Handbook.
Whistleblowing
HewardMills strictly prohibits retaliation against anyone who reports a complaint in good faith, regardless of the outcome of the investigation be this a governance concern or grievance.
Retaliation includes, but is not limited to:
- termination or demotion
- harassment or intimidation
- contract cancellation
- denial of future work or business
Consequences for retaliation may include:
- employees: subject to disciplinary action, up to and including termination
- suppliers/vendors/clients: subject to contract termination and permanent disqualification
- partners: subject to suspension or termination of business relationships
Complainants may report anonymously by omitting personal details in email or post. All reports will be handled with strict confidentiality. Identities are only disclosed with consent or when legally required.
Access to complaint details is limited to those involved in the investigation.
Anyone seeking protection against retaliation or wishing to raise a complaint in this context can do so by
- sending an email to governance@hewardmills.com using Subject: Confidential – Whistleblowing
- by completing the Whistleblowing form here
Whistleblowers Protection
HewardMills is committed to addressing all complaints raised under this policy in a fair and robust manner. HewardMills strictly prohibits any retaliatory actions taken against anyone raising a complaint and will apply the provisions of its Whistleblower Protection Policy as required.
Complaint Handling Process
| Stage | Timeline | Details |
|---|---|---|
|
Acknowledgement |
|
A confirmation will be sent to the complainant unless the complaint is submitted anonymously |
|
Initial review |
|
We will assess admissibility and assign an ethics case manager |
| Investigation |
|
We will conduct a thorough and impartial investigation with updates provided every 10 business days |
|
Resolution |
Varies by complexity | A written outcome will be shared. If the complaint is not accepted, a clear explanation will be provided |
An ethics case manager or team will be assigned to each complaint. This individual or team will be responsible for managing communication and co-ordination. An investigative team may include internal or external experts, depending on the issue. The HewardMills Executive team will maintain oversight and assume overall responsibility.
If the investigation finds that a third party (e.g. supplier or client) has acted unethically or illegally,
HewardMills may:
- terminate the contract or engagement
- report the matter to regulatory authorities
- prohibit future collaboration
Disciplinary procedure for Employees
HewardMills requires good standards of conduct from all employees and satisfactory standards of work and aims to foster an environment where issues are resolved quickly and informally whenever possible. HewardMills Disciplinary Policy and Procedure is designed to improve the specific issue and protect HewardMills’ business operations and the health and safety of HewardMills employees. The Disciplinary Policy and Procedure will be followed if the outcome of any complaint and investigation under this Policy finds this warranted.
Communication and Updates
Complainants (unless anonymous) will receive regular updates on the progress of their governance concern or grievance. A summary of the findings and actions taken will be shared once the matter is resolved. In cases where the complaint is not investigated, a written explanation will be provided.
