This policy sets out:

• Who can raise concerns and what can be reported.
• How to submit a report (including options for confidentiality).
• How AuHandel receives, assesses, and responds.
• Non-retaliation commitments.
• How outcomes are recorded and used to improve controls.

Reports may relate to (non-exhaustive):

• Responsible sourcing concerns (origin misrepresentation, CAHRA risk, supply chain integrity issues).
• Human rights concerns (forced labour, child labour, trafficking, severe abuses).
• Bribery and corruption (bribes, facilitation payments, kickbacks, improper gifts/hospitality).
• AML/CTF concerns (suspicious settlement structures, unexplained third-party payments, illicit finance indicators).
• Fraud or misrepresentation (false documentation, identity deception, tax/royalty evasion indicators).
• Environmental or safety concerns connected to our business relationships (where relevant).
• Any other serious compliance or ethical concern connected to AuHandel’s operations or business relationships.
• This mechanism is available to employees and external stakeholders, including counterparties and potentially impacted persons in the supply chain.

AuHandel’s grievance mechanism is designed to be:

• Accessible: simple ways to submit concerns and ask questions.
• Predictable: clear process steps and responsibilities.
• Fair and impartial: concerns assessed objectively and proportionately.
• Confidential: handled discreetly with information shared on a need-to-know basis.
• Protective: non-retaliation for good-faith reporting.
• Learning-oriented: outcomes used to improve due diligence and controls.

Reports can be submitted via:

• Email:complaints@auhandel.com
• Anonymous reporting (where legally and practically feasible).

Anonymous reporting is permitted where legally and practically feasible. If you report anonymously, please provide enough detail for us to assess and respond.

To help us act effectively, include (where possible):

• Description of the concern (what happened / what is suspected).
• Names of involved parties (if known).
• Dates, locations, and transaction context (if relevant).
• Supporting documents or evidence (if available).
• Your preferred contact method (if you want a response).
• You are not required to prove your concern—raise it in good faith with whatever information you have.

AuHandel prohibits retaliation against any person who:

• Raises a concern in good faith.
• Participates in an investigation.
• Refuses to engage in unlawful or unethical conduct.
• Retaliation includes threats, harassment, discrimination, demotion, termination, intimidation, or any adverse treatment connected to reporting.
• Retaliation itself is treated as a serious compliance breach.

AuHandel handles reports through a structured process, proportional to the severity and credibility of the concern.

• Step 1 — Receipt and acknowledgement: acknowledged where contact details are provided and acknowledgement is possible. If immediate risk of harm is indicated, AuHandel may prioritise urgent action.
• Step 2 — Triage and initial assessment: assessed for credibility, severity, and urgency; categorised (e.g., responsible sourcing, human rights, integrity, AML/CTF); conflicts of interest considered and escalated as needed.
• Step 3 — Investigation (proportionate): may include requesting additional information, reviewing transaction records and due diligence files, conducting interviews (where relevant), and consulting external advisors where necessary.
• Step 4 — Outcome and corrective action: may include risk mitigation, suspending/refusing transactions, disengagement, strengthening controls, and referral to authorities where legally required.
• Step 5 — Communication and closure: where possible, a response/closure notice is provided consistent with confidentiality and legal constraints; some outcomes cannot be shared in full due to privacy, contractual, or legal restrictions.
• These steps reflect good-practice features emphasised in grievance mechanism guidance, including predictability and transparency about process.

AuHandel treats reports as confidential and shares information only:

• With those who need it to assess and respond.
• To comply with legal obligations.
• To protect individuals from harm.
• AuHandel will handle personal data in accordance with applicable privacy requirements.

High-severity matters (e.g., severe human rights abuses, armed group links, credible bribery demands, illicit finance indicators) are escalated to senior management.

• AuHandel maintains documentation of the report, assessment, actions taken, and closure status, consistent with confidentiality and legal requirements.

Where appropriate, AuHandel may consider collaborating with relevant third parties (e.g., industry initiatives or remedy organisations) to improve accessibility or effectiveness of grievance handling for affected groups, consistent with good-practice partnership approaches.

This mechanism is intended for good-faith reporting. Deliberate false reporting made maliciously may be treated as misconduct; however, reports made in good faith will not be penalised even if unsubstantiated.

AuHandel reviews this mechanism periodically (at least annually) and after significant cases to improve accessibility, responsiveness, and effectiveness.