1- INTRODUCTION

A grievance is considered to be a complaint, request, comment, question, concern or suggestion for redress from persons affected or potentially affected by the Company’s activities.
from persons affected or potentially affected by the activities of the company and its subsidiaries.
company and its subsidiaries. This promotes social inclusion and sustainable development by giving the stakeholders concerned a greater say in the projects and activities that affect them.

This document explains the purpose of the company’s grievance mechanism, who can lodge a grievance, where and how it can be lodged, and how it can be dealt with,
where and how it can be filed, and describes the internal process for handling and responding to grievances. The
grievance procedure is free, open and accessible to all, and complaints will be dealt with in a fair and
fair and transparent manner.

The company’s grievance procedure has been developed with the following objectives in mind.

2- AUTHORISED COMPLAINT

Who may file a grievance?

Interested party or stakeholder (hereinafter “complainant”) : A person or organization1 or entity that may affect, be affected by, or perceive itself as being negatively affected by a decision or activity of the company; this may include:

• Customers;
• Suppliers;
• Communities: (e.g. individual groups of people living on or near a project site);
• Regulators
• Non-governmental organisations ;
• Investors
• Employees and;
• Trade unions

Complaints may be submitted through a representative if the persons on whose behalf the representative is acting are identified and if proof of the representative’s authority in this regard is provided in the complaint.
representative acts are identified and evidence of the representative’s authority in this regard is provided in the
complaint.

3- SCOPE

The grounds on which a complaint may be lodged fall into two main categories:
a) Environmental and social: Significant adverse effects on any of the following: Labour and working conditions
conditions; resource efficiency and pollution; health, safety and security of communities;
land acquisition and involuntary resettlement; biodiversity conservation and sustainable management of living
natural resources; rights of indigenous peoples; cultural heritage; equality and non-discrimination; gender-based violence; customer protection; and the right to privacy.

b) Governance and business integrity: legal or unethical behaviour by the company or individuals
or individuals, including failure to comply with legal requirements and deviations from good business
good business practice in relation to money laundering, fraud, corruption, bribery (e.g., bribery of employees)
bribery (e.g. facilitation payments), conflicts of interest or commercial collusion.

4- KEY ROLES AND RESPONSIBILITIES

The roles and responsibilities of the company’s grievance mechanism are as follows:

a) Complaints relating to environmental and social management are assigned to the Corporate Compliance and Risk Officer.
b) Complaints relating to corporate governance and integrity are assigned to the Chief Compliance and Risk Officer. This means that the CRO is responsible for receiving complaints, assessing their admissibility, carrying out preliminary analyses and proposing actions to the governing bodies. The CRO reports to the Board of Directors of Teyliom Finance and its subsidiaries, which has overall responsibility and decision-making for the company’s complaints mechanism.

5-  ELIGIBILITY CRITERIA FOR GRIEVANCES

A complaint is considered eligible for further investigation if it meets each of the following criteria
of the following criteria:

• Where requests concern a partnership investment, interested parties are encouraged to submit their complaint directly to the company’s subsidiaries, but if the problems are not resolved or are not properly dealt with at the level of the project company or in an emergency, they may submit their request to the company;
• The complaint must relate to the activities of the company and its subsidiaries;
• The complaint must contain information on the main negative effects;
• The complainant believes that he or she is or will be adversely affected by the circumstances described.
• The complaint is made in good faith and corresponds to the primary objective of the company’s complaints mechanism.
  mechanism. Abuses of the mechanism include, but are not limited to, cases in which :
• The complaint is filed with the aim of obtaining unnecessary compensation;
• The complaint is made solely for the purpose of delaying the implementation of a project managed by
  the company and its subsidiaries;
• The mechanism is used with the aim of damaging the credit or reputation of the activities of the
  and its subsidiaries;
• The complaint was lodged for political purposes unrelated to the activities of the company and its
  subsidiaries;
• The complaint contains significant falsehoods. Any complaint that does not meet all the eligibility criteria will not be followed through the stages of the procedure.

6-PROCEDURE

i) Stage 1: Registering a complaint
Complaints are accepted verbally or in writing. Any eligible complainant may submit a complaint, in one of the available languages (English and French), by :

• by using the complaints form on the company’s website. An automatic
  will be sent by e-mail to the Compliance and Risk Manager.

If necessary, grievances can also be sent to the company’s grievance mechanism:

• Send an e-mail to: crofficer@teyliom.com
• By sending a letter to the address indicated on the company’s website:
  “33 Avenue du Général De Gaulle, 01 B.P. 13108 ABIDJAN 01 Abidjan Plateau “
• By calling the company on the number given on the company website, i.e. +225 27 20 31 18 61
  and speaking to a representative (either the Chief Compliance and Risk Officer or another representative)
  during office hours or leave a message.

ii) Stage 2: Information to be provided
All complaints must contain, in substance, the following information:

• The identity of the complainant(s): name(s), address(es) and other contact details. The company’s complaints
  guarantees the strict confidentiality of information relating to the identity of complainants.
• If the interested party filing the complaint does so on behalf of an affected person or community,
  it must provide proof that it has been asked to submit the complaint on behalf of the person or persons affected by the project.
  affected by the project.
• A description of the relevant activity of the company and its subsidiaries, to the extent that the complainant
  is aware of it.
• The complainant should provide as much information as possible about the problem when making their complaint,
  including copies of any relevant documents or photographs.
• A description of the situation that is the subject of the complaint:

iii) Environmental or social impacts: A statement of how the complainant believes it has been or is likely to be affected by the environmental and/or social impacts of the activities.

iv) Corporate governance and integrity: description of non-compliance with laws and regulations or deviation from best practice in the area of corporate governance or integrity.

• Explanation and/or suggestion as to why and how the complainant tried to resolve the problem.
  they did so.

v) Stage 3: Acknowledgement of receipt

• The Company will acknowledge receipt of the complaint by letter or e-mail within seven working days of
  days of receipt.
• The acknowledgement of receipt will indicate a contact person within the company and a description of what is expected from the investigation to be carried out, including an expected timeframe for the review and the outcome to be communicated.
  expected from the investigation to be carried out, including an expected timeframe for the review and the outcome to be communicated
  to the complainant.
• The company will assess the complaint received and respond as soon as possible.

vi) Stage 4: Examination of admissibility and preliminary assessment
The company will appoint a person with the necessary expertise to resolve the complaint. He/she will
examine the admissibility of the complaint by assessing whether it complies with the scope of the mechanism,
the authorised complainants and the eligibility criteria described above.

In the case of complaints that are not related to company factors, a written explanation will be sent by
company to explain why it considers that the complaint does not require further action by the company.
action on the part of the company.

Once the complaint is deemed admissible, an assessment of the complaint is carried out in order to gain a general understanding of the problems.
general understanding of the problems. In addition, the company manager :

• Consulter la documentation existante sur le projet ou l’activité faisant l’objet de la plainte ;
• Make a commitment to the complainant and the company receiving the investment;
• Identify local communities and any other stakeholders affected by the complaint.

If a complaint seems a little complicated, the manager may decide to present the problem immediately to a group of senior partners.
to a group of senior partners, who decide on the most appropriate action to take: further investigation
investigation, dispute resolution, compliance review, etc.

The officer in charge shall contact the complainant during the investigation and inform him/her of the decision taken.
If it is decided to reject the complaint, the official responsible will inform the complainant of the reasons for this decision and close the complaint file.
and close the complaint file.

vii) Stage 5: Investigation, consultation and resolution

The procedures implemented during an investigation may include

• Review of documentation ;
• Meeting with the complainant, the company’s staff, the representative of the beneficiary company, officials of the country where the activities are taking place, representatives of non-governmental organisations, etc.
  officials of the country where the activities are taking place, representatives of local and
  organisations and other stakeholders;
• Site visits; and
• Consultation of experts and publications relating to the issues of negative impact raised in the
  complaint.

Once the investigation is complete, the company will discuss the results and agree resolution options with the complainant, including a timetable for implementing the action.
the complainant, including a timetable for implementing the action. If the complainant is still not satisfied
satisfied, recourse to a party may be considered.

Where possible, a formal response will be provided within 30 days of receipt of the grievance.

viii) Stage 6: Closure, archiving and follow-up

• The company will close the grievance as soon as the agreed resolution has been implemented.
• The company will ask the party concerned to sign a declaration attesting to the resolution of the
  dispute.
• If the complainant does not agree with the proposed resolution, the company will close the grievance. However, the
  grievor may choose to appeal the decision to close the grievance or to pursue another
  other recourse.
• The company can rework the same grievance by providing additional essential information.
  information.
• The company will monitor the progress and status of the implementation of the resolution options and ensure that no further issues arise.
  and ensure that no further issues arise.
• All complaints lodged as part of the company’s complaints mechanism and all information
  information gathered must be properly filed and archived.
• The company shall keep a record of the lessons learned from the handling of complaints and shall submit to the Board of Directors, at least every two years, a report on the effectiveness of the complaints mechanism.
  at least every two years, a report on the effectiveness of the company’s complaints mechanism.