Introduction

“Carbonhound is committed to operating with the highest standards of ethical, moral, and legal business conduct. This Whistleblower & Grievance Procedure provides a framework for anyone — including employees, customers, community members, suppliers, investors, and members of the public — to confidentially report concerns or misconduct related to our operations.

Who Can Report

This procedure is available to all Carbonhound employees, contractors, vendors, partners, customers, and external stakeholders. Reports may be submitted anonymously.

What You Can Report

You are encouraged to report any actual or suspected violations of Carbonhound’s policies, ethical standards, or applicable laws. This includes, but is not limited to, concerns related to:

• Environmental impact
• Health and safety
• Labor practices
• Ethical conduct
• Community impact
• Fraud or financial misconduct
• Data privacy or security breaches

How to Submit a Report

External stakeholders may submit a grievance through the whistleblower form on Carbonhound’s website. The form supports anonymous submissions and collects the following information:

• Your relationship to the company
• Date and location of the incident
• Category of the grievance
• A detailed description of the concern
• Whether the issue has been previously reported
• Any supporting evidence (file uploads accepted)
• Your desired outcome or resolution

Where you provide contact information and request follow-up, updates will be communicated through your preferred contact method.

Anonymity & Confidentiality

Reports can be made anonymously. All submissions are treated as confidential to the maximum extent possible. When identifying information is provided, it is stored separately from grievance details, with access restricted to the investigating officer.

Anti-Retaliation Policy

Carbonhound strictly prohibits retaliation against any individual who reports a concern in good faith. We enforce this through the following measures:

• Anonymity safeguards — Reporting channels support fully anonymous submissions. Where identifying information is provided, it is kept separate from the grievance record.
• Confidentiality controls — Grievance records are stored in a secure, access-restricted system and shared only on a strict need-to-know basis.
• Risk assessment — Upon receipt of a report, the investigating officer evaluates whether the submitter faces potential risk of retaliation and implements additional protective measures where needed.
• Ongoing monitoring — Carbonhound proactively monitors for signs of retaliation for at least 12 months following the submission of a grievance.

How Reports Are Handled

1. Acknowledgment

All reports are acknowledged within 2 business days of receipt. If you have provided a contact method, you will receive confirmation that your grievance has been received and is under review.

2. Classification

Each grievance is classified by category and severity:

• Level 1 — Low: Minor concerns, process suggestions, or isolated incidents with limited impact.
• Level 2 — Moderate: Recurring issues, potential policy violations, or matters affecting multiple stakeholders.
• Level 3 — Severe: Allegations involving significant legal, regulatory, financial, or reputational risk, such as fraud, systemic discrimination, serious environmental harm, or data breaches. Severe grievances are escalated to the Board of Directors.

3. Investigation

Investigations are conducted promptly and impartially by a designated officer. Where grievances involve third parties, relevant departments (e.g., Legal, Operations, Sustainability) may be engaged. Where a grievance involves a member of senior leadership responsible for managing this procedure, the report will be escalated directly to the Board of Directors, who will appoint an independent third party to conduct the investigation. The individual(s) named in the grievance will be excluded from all aspects of the investigation and resolution process.

4. Communication Throughout the Process

Where contact information has been provided, Carbonhound will keep you informed at each stage:

• Acknowledgment — within 2 business days of receipt
• Classification notification — within 5 business days
• Investigation updates — at least once every 15 business days during an active investigation
• Resolution notification — within 30 business days of acknowledgment (unless extended)

5. Resolution

Investigation outcomes are documented and appropriate corrective action is taken. This may include policy changes, disciplinary measures, process improvements, remediation of harm, or referral to external authorities where required by law. Where you have requested follow-up, a summary of the resolution will be communicated within 30 business days.

6. Non-Acceptance of a Grievance

If a submission does not meet the grounds for acceptance — for example, if it falls outside the scope of company operations, lacks sufficient detail, or pertains to a matter already fully resolved — you will be notified in writing with a clear rationale within 10 business days. You will also be advised on alternative avenues for your concern and may resubmit with additional information.

Oversight & Accountability

This procedure is overseen by Carbonhound’s senior leadership. Severe grievances (Level 3) are escalated to the Board of Directors within 48 hours of classification. The Board receives a quarterly grievance summary report covering the number of grievances received, classification levels, investigation status, resolution outcomes, and any systemic trends identified.

Policy Review

This procedure is reviewed annually and updated as needed to ensure it remains effective and compliant with all applicable laws and regulations.

Our Commitment

Carbonhound is dedicated to maintaining an environment where concerns can be raised without fear of reprisal. This procedure is a cornerstone of our commitment to transparency, accountability, and ethical business practices.