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Grievance Procedure

1. Purpose and Objectives

The grievance procedure enables employees, suppliers, contractors, customers, community members, and other stakeholders to:

● Safely raise concerns about any company practice, communication, or decision that may cause, contribute to, or be linked with negative social, environmental, or ethical impacts.

● Seek timely resolution, remediation, or explanation without fear of retaliation.

● Contribute to continual improvement of Gloucester Brewery’s performance and governance.

This mechanism is a key component of Gloucester Brewery’s broader human rights due diligence and ESG accountability framework.


2. Scope and Accessibility

The grievance process is available to:

● Internal stakeholders: Employees, contractors, and temporary staff.

● External stakeholders: Suppliers, customers, partners, community members, NGOs, investors, regulators, and other affected parties.

Grievances may be raised through multiple channels to ensure accessibility: ● Dedicated email address kai@gloucesterbrewery.co.uk or if the proposer wishes to remain anonymous through our third party HR kate@brave-people.com

● Physical submission through the brewery which is publicly accessible form 0800-2200 Monday to Friday.

Information about the mechanism and its channels is publicly available on the company website and in supplier and community engagement materials.


3. Acceptable Grounds for a Grievance

The company accepts grievances relating to:

● Unethical, unsafe, or unlawful company practices.

● Environmental or social impacts (e.g., pollution, land use, community relations).

● Discrimination, harassment, or human rights abuses.

● Misleading or harmful communications or marketing.

● Breaches of contract, policy, or stakeholder commitments.

● Health, safety, or labor concerns in operations or supply chains.

Grievances that are clearly malicious, unrelated to company activities, or legally outside company control may not be accepted; in such cases, an explanation and referral to an alternative channel are provided.

4. Governance and Oversight


● The Grievance Officer (or equivalent) is responsible for receiving and coordinating grievance handling.

● Investigations are conducted by impartial personnel or third-party investigators where independence is required.

● Findings and learnings are integrated into risk management, materiality assessments and policy review processes.


5. Process and Timelines

Stage Description Target Timeline Responsible Party

  1. Submission Grievance received via designated channels and logged securely. Ongoing Complainant / Grievance Officer

 2. Acknowledgment

 Complainant receives written confirmation and case reference number. Within 5 working days Grievance Officer

3. Initial

Assessment Determination of whether the issue qualifies as a grievance and appropriate route for handling. Within 5 working days Grievance Officer

4. Acceptance or Explanation

If accepted, the complainant is notified and the investigation begins. If not accepted, a written explanation is provided (see Section 8). Within 10 working days HR / Compliance

5. Investigation

Fact-finding, stakeholder interviews, evidence review, and analysis of company practices or impacts. Within 20 working days Investigator / Compliance / HR

6. Communication of Progress

Regular updates are shared with the complainant during investigation. Every 10 working days Grievance Officer

7. Resolution & Feedback

Findings and proposed corrective actions are discussed with the complainant. Within 5 working days after investigation HR / Compliance

8. Written Outcome

Complainant receives written summary of findings, rationale, and corrective measures. Within 5 working days after resolution meeting HR / Sustainability Team

9. Appeal Process

Complainant may appeal to senior management if unsatisfied. Within 10 working days of outcome Senior Management

10. Final Decision

Company issues a final written decision and implements agreed actions. Within 15 working days of appeal Senior Management / Board Committee


6. Protection of Complainants

To ensure the mechanism is trusted and effective:

● Non-retaliation policy: Retaliation against any stakeholder who raises a grievance in good faith is strictly prohibited and treated as a disciplinary offence.

● Confidentiality: Identities and case details are handled securely and shared only on a need-to-know basis.

● Monitoring: HR, Compliance, or the Sustainability Team conducts follow-up to ensure no adverse treatment occurs.

● Anonymous reporting: Available for stakeholders who prefer not to disclose their identity, subject to jurisdictional limitations.

● Safe communication channels: Whistleblower and ethics channels are managed by independent third-party providers in some jurisdictions.

7. Resolution and Remediation

The company facilitates fair and effective resolution through:

● Dialogue and mediation between affected parties.

● Corrective actions (policy or procedural changes, staff retraining, disciplinary measures).

● Remediation such as apology, compensation, or restoration where harm has occurred.

● Systemic prevention by integrating lessons learned into sustainability and governance frameworks.

Progress and completion of corrective actions are tracked until full implementation.

 

8. Communication and Outcomes

a) When a Grievance Is Accepted

● The complainant is informed at each stage: acknowledgment, investigation start, progress updates, and resolution.

● Upon closure, a written confirmation is issued summarizing actions taken and measures implemented to prevent recurrence.

● Significant grievances and corrective actions may be disclosed in aggregated form in annual sustainability or ESG reports.

b) When a Grievance Is Not Accepted

● The complainant receives a written explanation detailing why the issue could not be addressed through this mechanism (e.g., outside scope, insufficient information, unrelated to company operations).

● The company provides guidance on alternative recourse channels (e.g., customer care, regulatory complaint mechanisms, or public mediation forums).

 

9. Monitoring and Reporting

● Grievance data (types, status, resolution rates, and timeframes) are tracked through a central system.

● Aggregate, non-identifiable data are reported annually in the Sustainability Report and reviewed by the Board or Ethics Committee.

● Key performance indicators include:

○ Number of grievances received and resolved.

○ Average resolution time.

○ Percentage of grievances closed with stakeholder satisfaction.

○ Actions implemented to address systemic issues.

 

10. Continuous Improvement

The company regularly reviews the grievance mechanism to ensure:

● It remains accessible, trusted, and effective for all stakeholder groups.

● It aligns with evolving international standards and stakeholder expectations.

● Feedback from users and lessons learned inform updates to policies, training, and communication materials.

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