Grievance Policy

Product complaints and side effects: If you become aware of any circumstances in relation to Metagenics products that may pose a health, hygiene, or safety risk to consumers including adverse events, product complaints, or potential safety concerns, please notify Metagenics ANZ immediately. Reports should be directed to Metagenics Customer Service on 1800 777 648 or via info@metagenics.com.au or info@metagenics.co.nz.

Privacy questions: ANZ_Privacy@metagenics.com. See our Privacy Policy.

This procedure does not affect your rights under the Australian Consumer Law or the Consumer Guarantees Act 1993.

Effective: April 2026
Version: 1.0
Review: Annual
Applies to: All Metagenics stakeholders globally
Aligned with: B Corp Standards (PSG3) & the UN Guiding Principles

Purpose & scope
Guiding principles
How to submit a grievance
Grievance procedure
Roles & responsibilities
Protection, confidentiality & non-retaliation
Tracking, accountability & reporting
Policy governance

Executive summary

The Metagenics Grievance Policy establishes a fair, transparent, and accessible mechanism through which any stakeholder can raise concerns about the company's social, environmental, or governance impacts and seek resolution. Aligned with B Corp Standards (PSG3) and the UN Guiding Principles on Business and Human Rights, the policy defines who can raise a grievance, how grievances are submitted and resolved, and the protections in place to ensure confidentiality, non-retaliation, and rights-compatible outcomes. It applies globally and supports accountability, continuous improvement, and responsible stakeholder governance.

1. Purpose & scope

Metagenics is committed to operating with integrity and to making a meaningful positive impact on all its stakeholders. This Grievance Policy establishes a fair, transparent, and accessible procedure through which any stakeholder negatively affected by Metagenics' activities can raise concerns and seek resolution.

This policy is a core element of our B Corp Certification obligations under B Lab Standards V2.2, specifically PSG3 (Stakeholder Grievance Procedures), and aligns with the UN Guiding Principles on Business and Human Rights.

1.1 Who can raise a grievance

This policy applies to all stakeholders who are or may be negatively affected by Metagenics' activities, including:

Employees (permanent, temporary, part-time, seasonal, or casual)
Independent contractors, freelancers, and consultants
Suppliers, business partners, and value chain workers
Customers and consumers
Local communities, civil society organizations, and NGOs
Environmental representatives and any person or entity with a legitimate concern about Metagenics' social, environmental, or governance conduct

1.2 What constitutes a grievance

A grievance is a concern or complaint about Metagenics' actual or potential social, environmental, or governance impacts. This includes, but is not limited to:

Adverse human rights impacts connected to Metagenics' operations or value chain
Environmental harm or non-compliance with environmental commitments
Unsafe or unfair labor practices, including discrimination, harassment, or unsafe working conditions
Breaches of the company's Code of Conduct or supplier standards
Community impacts arising from Metagenics' business activities
Consumer safety or product quality concerns with a social or ethical dimension

This policy does not cover routine interpersonal disagreements without any policy, conduct, or human rights dimension (e.g. scheduling preferences or day-to-day team disagreements — please refer to the People & Culture department or your line manager), or matters that fall strictly within the scope of any regional or global Whistleblower Policy. Claims of harassment, discrimination, bullying, or any breach of the Code of Conduct are explicitly within scope of this policy, regardless of whether the parties involved are colleagues.

2. Guiding principles

This grievance procedure is built on the effectiveness criteria of the UN Guiding Principles on Business and Human Rights (UNGPs) and upholds the following principles:

Legitimacy: The procedure is trusted by all stakeholders and operates with integrity, free from conflicts of interest.
Accessibility: The procedure is publicly available, communicated proactively, and offered in accessible formats and languages as needed.
Predictability: Clear steps, timeframes, and roles are defined so stakeholders know what to expect.
Equitability: Grievance raisers have access to the information and support necessary to engage fairly in the process.
Transparency: Outcomes and aggregate data are reported publicly and to the highest governing body annually.
Rights-compatibility: Outcomes are consistent with internationally recognized human rights standards.
Non-retaliation: No stakeholder will suffer any form of retaliation for raising a grievance in good faith.
Confidentiality: The identity of grievance raisers is protected to the extent permitted by law.

3. How to submit a grievance

Metagenics provides multiple accessible channels through which a grievance may be submitted. Grievances may be submitted anonymously where technically possible. This policy and its submission channels are available in English as the global working language, and in Dutch and French for EMEA operations. Translation into other operational languages (including those used in NAM and APAC operations) will be provided on request, at no cost to the submitter, within 14 calendar days.

Online form: Anonymous submission possible · accessible globally. Open the form
Email — global: raiseyourconcern@metagenics.com · confidential inbox monitored by the Global Grievance Officer
Email — United States: privacy@metagenics.com · inbox for communications regarding the U.S. Notice of Privacy Practices

3.1 What to include in your submission

To enable a thorough review, please include the following information where possible:

Your name, contact details, and relationship to Metagenics (unless submitting anonymously)
A clear and concise description of the concern, including relevant dates, locations, and persons involved
Any supporting evidence, documents, or witness information
Whether the issue has previously been raised with Metagenics, and any response received
The outcome or resolution you are seeking
A request for confidentiality, if desired

Anonymous submissions are accepted. Please note that anonymous submissions may limit Metagenics' ability to follow up or provide feedback. Where an online form is used, the grievance reference number must be retained by the submitter to track communication.

4. Grievance procedure

The following steps describe the end-to-end process from submission to resolution. Metagenics is committed to fair, timely, and transparent handling of all grievances.

Submission. The stakeholder submits a grievance through one of the channels described in Section 3.
Acknowledgement — within 7 calendar days. The Grievance Officer acknowledges receipt and confirms whether the matter falls within the scope of this policy. If not in scope, the submitter is directed to the appropriate channel (e.g. People & Culture, Whistleblower Officer).
Assessment & triage. The Grievance Officer assesses the nature, severity, and urgency of the grievance and assigns an appropriate resolution tier (see Section 4.1). Potential conflicts of interest are identified and addressed.
Investigation. A fair and impartial investigation is conducted. All parties named in the grievance are given an opportunity to be heard at the appropriate time, subject to confidentiality protections.
Resolution — within 3 months of acceptance. The Grievance Officer communicates the outcome to the grievance raiser and, where appropriate, to other affected parties. Remediation or corrective actions are agreed upon and documented.
Closure & follow-up. The case is formally closed. Corrective actions are tracked. The submitter is informed of closure. Cases remain open until resolution is confirmed.
Annual review. All grievances are logged and analyzed annually. Trends and outcomes are reported to the highest governing body and disclosed publicly (see Section 6).

4.1 Tiered resolution approach

Metagenics applies a proportionate, three-tier approach to resolution based on the nature and severity of the grievance:

Tier 1: Internal resolution. Resolved directly between the grievance raiser and the Grievance Officer through dialogue and corrective action.
Tier 2: Mediated resolution. An internal mediator (with no conflict of interest) facilitates discussions between parties to reach an agreed outcome.
Tier 3: Independent mediation or arbitration. An independent external mediator or arbitrator with no conflict of interest reviews the case and issues a recommendation or binding decision.

5. Roles & responsibilities

5.1 Grievance Officer

The Grievance Officer is the primary point of contact for all grievances submitted under this policy. The role is assigned to a designated member of the People & Culture team with defined responsibilities for:

Receiving, logging, and triaging all grievances
Ensuring acknowledgements and updates are communicated within the required timeframes
Coordinating investigations and engaging mediators or arbitrators where required
Maintaining the grievance register and annual summary
Reporting to the highest governing body and the executive team

The Grievance Officer must not have a conflict of interest in any case they administer. Where a conflict exists, the matter is reassigned to an alternative officer or escalated to an independent party.

5.2 Whistleblower Officers (cross-reference)

Where a grievance falls within the scope of the Whistleblower Policy (e.g. reports of fraud, corruption, serious legal violations, or other matters covered by EU Directive 2019/1937 and equivalent regional whistleblower legislation), the matter is referred to the designated Whistleblower Officer for handling under the Whistleblower Policy. The Grievance Officer is responsible for identifying such cases at the triage stage (Step 3) and informing the submitter of the referral. The protections set out in Section 6 of this policy (non-retaliation, confidentiality, data protection) apply equally during and after any such referral.

5.3 Highest governing body

The highest governing body (Board of Directors / Executive team) receives an annual report on grievance outcomes and trends from the Grievance Officer, and is responsible for ensuring the effectiveness of this policy and integrating its findings into company strategy and governance.

6. Protection, confidentiality & non-retaliation

6.1 Non-retaliation

Metagenics has a strict zero-tolerance policy on retaliation. Any stakeholder who raises a grievance in good faith under this policy is fully protected from any form of direct or indirect retaliation, adverse treatment, or negative consequence. This protection applies even if the concern ultimately proves to be unfounded, provided it was raised honestly and without malicious intent.

Any act of retaliation against a grievance raiser will be treated as a serious disciplinary matter.

6.2 Confidentiality

The identity of a grievance raiser will be kept strictly confidential throughout the process. Information will only be shared with those who need to be involved in the investigation or resolution, and only with the knowledge and — where practicable — the consent of the grievance raiser. Metagenics implements the following confidentiality safeguards:

Grievance raisers may request that their identity remain confidential at any stage
Grievance raisers are informed upfront of who will be involved or informed in the process
Consent is sought before sharing information with additional parties
Confidentiality of the process outcome is maintained where appropriate
Disciplinary action is enforced in cases of confidentiality breaches
Independent third parties may be engaged to assess risks for vulnerable stakeholders

Identity may only be disclosed without consent where required by law or a proportionate legal obligation, for example in the context of judicial proceedings or investigations by competent authorities.

6.3 Data protection

All personal data collected in connection with grievance procedures is processed in accordance with applicable data protection law, including the General Data Protection Regulation (GDPR) and Metagenics' Privacy Policy. Personal data is retained only as long as necessary and is not used for any purpose other than handling the grievance. For full details, refer to the privacy statement in the Klokkenluidersbeleid or the U.S. Notice of Privacy Practices.

7. Tracking, accountability & reporting

7.1 Grievance register

The Grievance Officer maintains a secure grievance register for all cases submitted under this policy. Each entry records the following information:

Unique grievance case reference number
Date of submission
Grievance raiser (or 'Anonymous' if applicable)
Defendant or subject party
Nature and category of the grievance
Location (if relevant and not sensitive)
Current status: Under Review / Active / Closed
Resolution outcome and date of closure

7.2 Annual internal report

At the close of each calendar year, the Grievance Officer prepares an annual internal report for the highest governing body covering:

All grievances raised and accepted during the year
An evaluation of the effectiveness of the grievance procedure
Identification of trends, patterns, and hotspot areas
Recommendations for improving procedures or addressing systemic concerns

7.3 Public reporting

In line with B Lab Standards PSG3.4 and the UNGP Effectiveness Criteria, Metagenics publicly reports annually on the following grievance data (aggregated and anonymized):

Number and types of grievances received
Number of cases rejected and grounds for rejection
Number of completed cases, outcomes, follow-up actions, and average duration
Stakeholder satisfaction levels where measured
Any additional data that supports public understanding of the procedure's performance

Public reports are accessible via Metagenics' website and/or annual impact report. No personal data is included in public disclosures.

8. Policy governance

This policy is published on the Metagenics website and communicated to all relevant stakeholders through onboarding materials, supplier communications, and periodic updates.

Questions about this policy may be directed to raiseyourconcern@metagenics.com.