Stakeholder Grievance and Whistleblower Protection Policy

Countless LLC — Grievance Mechanism & Whistleblower Protection Policy

Last updated: July 10, 2026

1. Introduction

Countless is committed to the highest standards of integrity, transparency, and accountability. As part of our ongoing commitment to social and environmental responsibility — including our pursuit of B Corp Certification — we recognize that our operations impact our team, clients, suppliers, and community. We encourage all stakeholders to speak up if they encounter conduct that falls short of our values or legal obligations.

2. Scope and Access

This policy applies to all stakeholders, including team members, clients, suppliers, and community partners.

How to Submit a Grievance

  • Form: Submit a Grievance
  • Email: ethics@countless.io, marked “Confidential,” attention: Operations Coordinator
  • Open-Door Policy: Team members are encouraged to raise concerns directly with their manager or the Operations Coordinator in the first instance.

Please include your name and contact information (or indicate if you wish to remain anonymous), a description of the concern, relevant dates, and any supporting documentation.

3. Grounds for Accepting a Grievance

Grievances will be accepted for review if they relate to:

  • Discrimination, harassment, or unfair treatment
  • Breach of confidentiality or data privacy
  • Unethical, unsafe, or illegal conduct
  • Unfair business, employment, or vendor practices
  • Environmental or community impact concerns
  • Concerns related to Countless’ stated purpose, values, or social and environmental commitments

Grievances outside these categories may still be considered if they relate to a material, credible, and specific concern about Countless’ operations or conduct.

4. Process Steps and Timelines

Step
Action
Timeline
1. Acknowledgment
We confirm receipt and provide a reference number.
Within 3 business days
2. Initial Assessment
We determine whether the grievance falls within scope.
Within 7 business days
3. Investigation
The Ethics Contact gathers facts and interviews relevant parties.
Within 30 business days
4. Resolution
We propose a resolution or corrective action.
Upon completion of investigation
5. Follow-Up
We confirm the resolution was implemented effectively.
Within 90 days post-resolution

How Resolutions Are Facilitated

Resolutions are reached through direct dialogue between the Ethics Contact and the complainant, and, where appropriate, independent mediation. If an investigation finds Countless’ actions caused harm, we are committed to remediation — which may include corrective action, policy changes, or other appropriate measures.

Appeals

If a complainant is dissatisfied with the outcome, they may appeal within 10 business days of the resolution. Appeals will be reviewed by Countless’ CEO, with a final decision communicated within 20 business days.

5. Whistleblower Protection & Anti-Retaliation

Countless strictly prohibits retaliation against any individual who raises a grievance in good faith, participates in an investigation, or provides related information — regardless of outcome.

  • Confidentiality: Identifying details are shared only with those directly involved in investigating the matter, and only with the complainant’s consent where possible.
  • Anonymity: Grievances may be submitted anonymously, though this may limit our ability to investigate fully or provide direct follow-up.
  • Consequences of Retaliation: Any team member found retaliating against a complainant will face disciplinary action, up to and including termination. Retaliation by a supplier or partner may result in termination of the business relationship.

6. Communication and Transparency

If a grievance is accepted, we commit to communicating progress at each major step through resolution. If a grievance is not accepted, we will provide a written explanation and, where possible, suggest alternative resources.

7. Monitoring and Reporting

All grievances and their resolutions are documented internally and reviewed periodically to identify patterns and opportunities for improvement.