Fronteer Grievance & Complaints Mechanism
Purpose and Scope
Fronteer is committed to transparency, accountability, and the fair treatment of all stakeholders. This Grievance & Complaints Mechanism provides employees, clients, partners, suppliers, and community members with a clear process to raise concerns or complaints related to our activities or business relationships.
1. Access and Reporting Channels
Grievances can be submitted through the following channels:
A dedicated email address: complaints@fronteer.com
Business-to-business contract clauses with dispute resolution provisions
“Open-door” or “speak up” policies for employees
Suggestion or feedback boxes (digital and physical)
Stakeholder engagement sessions and worker committees
Customer services contact points
Supplier Code of Conduct mechanisms
Audit processes, including monthly worker interviews with their dedicated manager
Community outreach and engagement forums
An external confidential counselor who is available to employees
Instructions for submitting grievances are published on Fronteer’s website.
2. Process and Steps
Acknowledgement: confirmation of receipt within 5 working days.
Assessment: review to determine whether the issue qualifies as a grievance.
Investigation: conducted by an internal representative or external third party if needed.
Resolution: corrective action or mediation between relevant parties.
Communication: the complainant will be updated regularly and informed of the final outcome.
Grounds for Accepting or Rejecting a Grievance
Grounds for Acceptance
Fronteer will formally accept and process a grievance when it meets one or more of the following conditions:
Relevance. The grievance relates to Fronteer’s activities, services, projects, or business relationships.
Nature of the Issue. The grievance concerns:
Violations of law, regulation, or Fronteer policies (e.g. Code of Conduct, ESG commitments).
Human rights concerns, labour rights issues, or environmental impacts linked to Fronteer’s work.
Harassment, discrimination, retaliation, or other workplace misconduct.
Breaches of professional ethics, integrity, or conflicts of interest.
Material negative impact on stakeholders or communities.
Good Faith Basis. The complaint is made with a reasonable belief that the concern is genuine and supported by available information.
Standing. The grievance is raised by an affected stakeholder (employee, client, partner, supplier, community member) or a legitimate representative acting on their behalf.
Grounds for Rejection
A grievance may not be accepted if:
It is unrelated to Fronteer’s operations or sphere of influence.
It represents general feedback, suggestions, or personal dissatisfaction that does not indicate misconduct or adverse impact.
It is malicious, knowingly false, or made in bad faith.
It duplicates a grievance already reviewed, unless new evidence or information has emerged.
In cases of rejection, Fronteer will provide the complainant with a clear explanation of why the grievance could not be accepted and, where possible, redirect them to alternative channels (e.g. general feedback process, legal authorities, mediation bodies).
Timeline: Fronteer aims to resolve grievances within 30 days. If more time is required, the complainant will be notified. After the finalization of each step, Fronteer will contact the complainant to let them know where we are in the process and what the next step will look like.
3. Outcomes
Resolution and corrective action
Mediation or dialogue
Explanation of why the issue is not accepted as a grievance
4. Protection Against Retaliation
Fronteer guarantees that stakeholders raising grievances will be protected from retaliation. This includes confidentiality safeguards and disciplinary measures against any retaliatory behaviour.
5. Continuous Improvement
Annual anonymised reporting on grievance themes and outcomes.
Regular reviews of the mechanism to ensure effectiveness and accessibility.
Fronteer Whistleblower Protection Policy
Purpose and Commitment
Fronteer is committed to the highest standards of integrity, accountability, and transparency. We formally adopt a zero-tolerance approach to retaliation against whistleblowers. Any individual who raises concerns in good faith will be protected, regardless of their role, seniority, or relationship to Fronteer.
This policy ensures that whistleblowers are able to safely report misconduct, breaches of policy, or unethical practices without fear of reprisal.
1. Scope
This policy applies to all Fronteer employees, contractors, suppliers, partners, clients, and community stakeholders who may raise a concern through the Grievance & Complaints Mechanism or other designated reporting channels.
2. Commitment to Protect Whistleblowers
Fronteer guarantees that whistleblowers will not face retaliation, including dismissal, demotion, harassment, intimidation, discrimination, reputational harm, or any other negative consequence.
Equal protection applies to both internal employees and external stakeholders.
Reports may be submitted confidentially or anonymously.
Confidentiality will always be maintained unless disclosure is legally required or the whistleblower provides explicit consent.
3. Consequences for Retaliation
Individuals who engage in retaliation will face disciplinary action, which may include warnings, suspension, demotion, or termination of employment.
Where retaliation is identified among external stakeholders (such as suppliers or contractors), Fronteer reserves the right to terminate contracts or partnerships immediately.
Severe cases may be reported to the relevant authorities in line with legal obligations.
4. Mechanisms to Ensure Whistleblower Protection
To guarantee protection in practice, Fronteer has established the following mechanisms:
Confidential reporting channels: dedicated email address, secure online form, and an anonymous whistleblower hotline.
Confidential Reporting Officer: a designated senior staff member responsible for receiving, managing, and protecting whistleblower reports.
Risk assessments: each case will be reviewed for potential risks to the whistleblower, with proactive measures taken to mitigate them.
Follow-up procedure: acknowledgement of reports within 5 working days, regular updates on the status of investigations, and a clear communication of outcomes.
Escalation and appeal process: if a whistleblower believes their concern has not been handled fairly, they may escalate the issue to the Management Team or request an external review.
5. Best Practice Principles
Fronteer further commits to:
Informing whistleblowers at the outset about who may need to be involved.
Seeking consent before sharing information with additional parties.
Maintaining confidentiality regarding outcomes, except when legally required.
Providing enhanced training for all personnel handling whistleblower reports.
Enforcing disciplinary measures in cases of confidentiality breaches.
Engaging independent third parties in cases involving vulnerable whistleblowers.
6. Governance and Oversight
The Management Team is accountable for ensuring the effective enforcement of this policy.
All whistleblower reports will be logged and periodically reviewed to identify patterns or systemic issues.
The policy will be reviewed annually to ensure alignment with best practices, B Lab standards, and evolving legislation.
