Complaints & Grievance Mechanism
Effective date: 13 May 2026 · Version 1.0
Minerva Sustainability is committed to delivering ethical, impartial and high-quality social and environmental audit services. We welcome complaints from any stakeholder who believes our conduct, our auditors, or the quality of one of our audits has fallen short of the standards required by APSCA, Cascale, Worldly, ZDHC and our own Code of Conduct.
1. Scope — What We Accept
- Audit quality, accuracy or completeness
- Auditor conduct, professionalism or competence
- Breach of confidentiality or data protection
- Conflict of interest, real or perceived
- Bribery, facilitation payments, fraud or corruption
- Discrimination, harassment or coercion by an auditor
- Retaliation against a worker, supplier or whistleblower
- Falsification or manipulation of audit findings
- Worker grievances arising from an audit we conducted
- Any concern about our integrity, independence or professional conduct
2. Who Can Submit
Anyone — factory workers and their families, trade unions, audited suppliers, brands and clients, NGOs and journalists, Minerva employees and contractors, or any third party with a legitimate concern.
3. Our Principles
| Principle | What it means |
|---|---|
| Confidentiality | Your identity is shared only with those who must know to investigate, never with the audited facility or auditor without your written consent unless required by law. |
| Impartiality | Investigated by personnel independent of the original audit. |
| Non-retaliation | Retaliation against complainants or witnesses is itself a violation of our Code of Conduct and grounds for termination. |
| No fee | Submitting a complaint is free of charge. |
| Anonymity | Anonymous complaints are accepted and investigated to the extent the evidence allows. |
| Timeliness | We commit to the timelines in Section 5. |
4. How to Submit
Use the secure form below, or e-mail info@minervava.com with the subject line [COMPLAINT], or write to:
Compliance & Ethics Officer, Minerva Sustainability,
Maslak Mah. AOS 55. Sk. 42 Maslak, B Blok, No: 4, İç Kapı No: 542, 34485 Sarıyer / İstanbul, Türkiye
Languages accepted: English, Turkish, Spanish.
5. Process & Timeline
| Stage | Timeline |
|---|---|
| Written acknowledgement with case reference | 5 business days |
| Initial assessment & risk decision | 15 business days |
| Investigation by independent personnel | 30–60 business days |
| Written determination | 10 business days after investigation |
| Outcome notification to complainant | 10 business days after determination |
| Records retention | Minimum 5 years |
6. Possible Outcomes
Re-audit at no cost; withdrawal or re-issue of the audit report; corrective action plan, retraining, suspension or termination of the auditor; notification of clients and accreditation bodies (APSCA, Cascale, ZDHC, Worldly); disciplinary action up to dismissal for Minerva employees; referral to law-enforcement where criminal conduct is suspected; changes to Minerva’s policies and training.
7. Non-Retaliation & Whistleblower Protection
Retaliation in any form — termination, blacklisting, intimidation, withdrawal of business, pressure on a worker’s family — against anyone who in good faith submits a complaint or participates in an investigation is strictly prohibited and is itself grounds for dismissal, contract termination, and escalation to APSCA and national authorities.
8. Confidentiality & Data Protection
Personal data submitted through this process is handled under our Privacy Policy and, for Turkey, our KVKK Aydınlatma Metni. Access is restricted to authorised Compliance & Ethics personnel and, where necessary, external investigators bound by confidentiality.
9. Right to Escalate
You may escalate to the relevant accreditation body or regulator at any time, without first exhausting our internal process:
| Body | Scope | Where |
|---|---|---|
| APSCA | Auditor & firm conduct, ethics, integrity | theapsca.org |
| Cascale | Higg FEM, FSLM, related programmes | cascale.org |
| Worldly | Higg verification, FDM validation | worldly.io |
| ZDHC | Wastewater, MRSL, ZDHC training | roadmaptozero.com |
| KVKK | Personal-data complaints (Türkiye) | kvkk.gov.tr |
10. Reporting
Minerva maintains a confidential complaints register reviewed quarterly by senior management. Anonymised aggregate statistics are reported annually to APSCA and our accreditation partners.
Submit a Complaint
Fields marked * are required. To submit anonymously, choose “Anonymous” below — identity fields then become optional and disabled.