Grievance and complaints policy

1. Purpose and Objectives

Tangible Srl SB is committed to maintaining the highest ethical and professional standards. This policy establishes a formal mechanism to receive, manage and respond to grievances and complaints regarding company policies, unethical behavior or other issues.

This document defines the procedures to ensure that all reports are handled fairly, promptly and confidentially, ensuring protection for those who report and effective resolution of the issues raised.

2. Scope of Application

This policy applies to:

• All employees, consultants and collaborators of Tangible
• Customers, suppliers and business partners
• Any third party that interacts with the organization

The grievance mechanism is available to anyone who wishes to report behaviors or situations that may be contrary to company values and policies.

3. Types of Accepted Reports

The grievance mechanism handles:

• Company policy violations
• Unethical or inappropriate behavior
• Discrimination, harassment or offensive conduct
• Conflicts of interest
• Service quality issues
• Corporate Code of Ethics violations
• Workplace safety issues
• Environmental and sustainability issues

4. Reporting Methods

4.1 Public Access

• Online form available at tangible.is/codice-etico
• Accessible without registration or authentication requirements
• Available 24 hours a day, 7 days a week
• Available in Italian and English

4.2 Anonymity Guarantee

• Possibility to make completely anonymous reports
• Option to provide contacts to receive feedback (optional)
• Absolute protection of reporter's identity when requested
• Separation of contact information from report content

5. Management Process

5.1 Receipt and Registration

• All reports are automatically received by the dedicated team (segnalazioni@tangible.is)
• Immediate registration in the internal tracking system
• Assignment of a unique reference code

5.2 Receipt Confirmation

• Sending receipt confirmation within 3 business days (if contacts provided)
• Communication of reference code for any follow-up

5.3 Preliminary Assessment

• Preliminary examination of the report within 5 business days
• Classification by severity, urgency and competence
• Assignment of the case to the competent manager

5.4 Investigation and Analysis

• Start of thorough investigation within 15 business days from receipt
• Collection of evidence, documentation and testimonies
• Maintenance of maximum confidentiality throughout the process
• Involvement of only the people necessary for resolution

5.5 Resolution and Communication

• Conclusion of investigation and final decision within 15 business days
• Communication of outcome to the reporter (if contacts provided)
• Implementation of corrective, disciplinary or improvement actions when necessary
• Documentation of actions taken

6. Reporter Protection

6.1 Absolute Prohibition of Retaliation

• Tangible strictly prohibits any form of retaliation, discrimination or unfavorable treatment towards those who report in good faith
• Protection extended also to those who provide assistance in investigations
• Severe disciplinary measures against anyone who implements forms of retaliation

6.2 Confidentiality and Data Protection

• All reports are handled with maximum confidentiality
• Access to information limited exclusively to people necessary for investigation
• Secure data storage in compliance with GDPR
• Possibility of destroying personal data upon reporter's request

6.3 Reporter Support

• Assistance and support throughout the process for those who identify themselves
• Possibility to request updates on the status of the report
• Dedicated and protected communication channels

7. Response Times and Guarantees

7.1 Guaranteed Timelines

• Receipt confirmation: within 3 business days
• Investigation start: within 5 business days
• Process completion: within 15 business days
• Outcome communication: within 3 days from completion

7.2 Escalation

• In case of particularly serious or complex reports, timelines may be extended with prior communication to the reporter
• Possibility of escalation to the Board of Directors for critical cases

8. Reporting and Transparency

8.1 Public Annual Report

• Annual publication of aggregated statistics of received reports
• Analysis of the most frequent types of issues
• Reporting of improvement actions implemented
• Anonymous and aggregated data to ensure privacy

8.2 Continuous Monitoring

• Quarterly review of mechanism effectiveness
• Analysis of response times and process satisfaction
• Policy updates when necessary
• Periodic training for involved personnel

9. Responsibilities and Governance

9.1 Reports Team

• Operational management responsibility: Impact Manager
• Supervision: Board of Directors
• Involvement of external consultants when necessary

9.2 Training and Awareness

• Periodic training for all personnel on the reporting mechanism
• Regular communication of the importance of ethical culture
• Promotion of an open and transparent work environment

10. Contacts and Access

Reports Team Email: segnalazioni@tangible.is
Online Form: https://tangible.is/codice-etico
Availability Hours: 24/7 for online reports

For urgent reports requiring immediate intervention, contact the company anagement directly: https://tangible.is/en/contacts

11. Entry into Force and Revisions

This policy enters into force from July 1, 2025 and is subject to periodic reviews at least annually or when required by regulatory, organizational or operational changes.

The policy is an integral part of Tangible's ethical governance system and supports the maintenance of B Corp certification and Benefit Corporation status.

Approved by the Board of Directors on: June 30, 2025