Purpose

At TBCo, we are committed to operating responsibly, ethically, and transparently. We value feedback from our stakeholders and recognise the importance of providing a safe, fair, and accessible process for raising concerns regarding our business activities, products, services, people, supply chain, or impacts.

This Stakeholder Grievance Procedure provides a mechanism for stakeholders to raise concerns, seek resolution, and help us continuously improve our practices.

Scope

This procedure is available to any stakeholder who may be affected by TBCo's operations, including:

• Employees and former employees

• Customers

• Suppliers and supplier workers

• Contractors and service providers

• Business partners

• Community members

• Industry organisations

• Investors and shareholders

• Any individual or organisation impacted by TBCo's activities

This procedure may be used to raise concerns regarding TBCo's business conduct, products, services, operations, supply chain, environmental impacts, social impacts, governance practices, or compliance with company policies and commitments.

Grounds for Accepting a Grievance

A grievance may relate to, but is not limited to:

• Human rights concerns

• Labour and working conditions

• Discrimination, harassment, or unfair treatment

• Supplier conduct or responsible sourcing concerns

• Environmental impacts

• Product safety concerns

• Ethical business conduct

• Corruption, bribery, or fraud

• Breaches of company policies

• Concerns relating to TBCo's public commitments, including B Corp commitments

• Public policy, advocacy, or lobbying activities

• Any conduct inconsistent with TBCo's values

Certain concerns, including suspected fraud, bribery, corruption, criminal activity, modern slavery, serious human rights abuses, or breaches of law may be handled under TBCo's Whistleblowing Procedure where applicable.

TBCo will assess whether a concern falls within the scope of this procedure and will explain its decision where a grievance is not accepted.

How to Raise a Grievance

Stakeholders may raise a grievance through any of the following channels:

Email: responsibility@tbco.com

Post:
TBCo
170b Great Junction Street
Edinburgh
EH6 5LJ
United Kingdom

Stakeholders are encouraged to provide:

• Their name and contact details (unless they wish to remain anonymous)

• A description of the concern

• Relevant dates, locations, or individuals involved

• Any supporting evidence available

• The outcome they are seeking, if applicable

Anonymous grievances will be accepted where sufficient information is provided to allow investigation.

Grievance Process

Stage 1: Acknowledgement

TBCo will acknowledge receipt of a grievance within seven(7) working days wherever possible.

The stakeholder will be informed:

• That the grievance has been received

• The next steps in the process

• The expected review timeline

Stage 2: Initial Assessment

Stage 2: Initial Assessment Within fourteen (14) working days of acknowledgement, TBCo will conduct an initial assessment to determine:

• Whether the matter falls within the scope of this procedure.

• The appropriate investigation approach.

• Any immediate actions required.

Investigations will be conducted by individuals with appropriate authority, expertise, and independence from the matters being investigated. Any individual with a conflict of interest in relation to a grievance will not participate in the investigation or decision-making process.

Stage 3: Investigation

Where a grievance is accepted, TBCo will conduct a fair and proportionate investigation.

The investigation may include:

• Reviewing relevant documents and records

• Speaking with affected parties

• Gathering additional evidence

• Seeking specialist advice where appropriate

The company aims to complete investigations within forty-five (45) working days, although complex cases may require additional time.

Stage 4: Outcome and Resolution

Following investigation, TBCo will communicate the outcome to the stakeholder.

Potential outcomes may include:

• Clarification or explanation

• Corrective action

• Process or policy improvements

• Supplier engagement or remediation

• Additional monitoring or review

• Referral to another process

• Closure following investigation where no breach, impact, or corrective action is identified.

The company aims to provide a final response within sixty (60) working days of receiving the grievance. Where TBCo identifies that it has caused or contributed to adverse impacts, the company will seek to provide or support appropriate remediation.

Stage 5: Appeal

If the stakeholder believes the grievance has not been handled fairly, they may submit an appeal within fourteen (14) days of receiving the outcome.

Appeals will be reviewed by an individual who was not directly involved in the original decision wherever reasonably practicable.

The appeal decision will normally be communicated within thirty (30) working days and will be considered final.

Where a stakeholder remains dissatisfied after completion of the grievance process, they may seek advice or raise concerns with relevant regulators, certification bodies, legal representatives, or other appropriate external organisations.

Protection Against Retaliation

TBCo prohibits retaliation against any stakeholder who raises a concern in good faith.

No individual will be disadvantaged, discriminated against, threatened, harassed, or penalised for reporting a genuine concern.

To support this commitment, TBCo will:

• Respect confidentiality wherever possible

• Allow stakeholders to request anonymity

• Share information only with those who need to be involved in resolving the grievance

• Seek consent before sharing information more widely where practical

• Investigate any allegations of retaliation

• Take appropriate disciplinary or corrective action where retaliation occurs

Confidentiality

All grievances will be handled as confidentially as reasonably possible.

Information relating to a grievance will only be disclosed where necessary to investigate and resolve the issue, comply with legal obligations, or protect individuals from harm.

Records will be maintained securely and in accordance with applicable data protection requirements.

Communication

TBCo is committed to keeping stakeholders informed throughout the grievance process.

Where contact details are available, stakeholders will receive updates regarding:

• Receipt of the grievance

• Acceptance or rejection of the grievance

• Progress of the investigation

• Expected timelines

• Resolution and outcome

• Closure of the grievance

Governance and Oversight

The Chief Executive Officer is accountable for ensuring the effective operation of this procedure. Where a grievance concerns the Chief Executive Officer, responsibility for oversight will transfer to another independent director or board member.

The Leadership Team is responsible for:

• Monitoring grievance trends

• Reviewing significant grievances

• Identifying opportunities for improvement

• Ensuring appropriate corrective actions are implemented

Significant or recurring grievances may be reported to the Board of Directors as part of governance oversight.

Grievance records will normally be retained for a minimum of six years unless a longer retention period is required by law or ongoing proceedings.

Reporting and Transparency

TBCo may publish aggregated and anonymised information regarding grievance trends and outcomes as part of its sustainability, B Corp, or annual reporting activities.

Continuous Improvement

TBCo will review grievance data periodically to identify trends, recurring issues, and opportunities to improve our policies, practices, and stakeholder relationships.

Policy Review

This procedure will be reviewed annually or sooner if required by changes in legislation, stakeholder expectations, or business operations.