Grievance Policy

Date: June 2026

1. Purpose and Scope

ID Genève Watches (hereinafter “ID Genève”) is committed to conducting its business in a responsible, ethical, and transparent manner.

This procedure defines:

• the conditions under which a complaint may be filed

• the processing steps and associated deadlines

• internal responsibilities

• the protections guaranteed to individuals who file a complaint

• the procedures for follow-up, closure, and annual reporting

2. Who can file a complaint?

Any stakeholder of ID Genève is entitled to submit a complaint, including:

• staff members (employees, independent contractors, interns)

• clients

• business partners and suppliers

• community members or individuals who feel affected by ID Genève’s activities

• any other concerned individual or organization

Anonymous complaints are accepted. In such cases, ID Geneva cannot always guarantee personalized follow-up, but the complaint will be treated with the same seriousness.

3. Acceptable Grounds

A complaint may relate to one or more of the following grounds:

• Non-compliance with ID Genève’s internal policies (code of conduct, sustainability policy)

• Inappropriate behavior, harassment, discrimination, or violations of human dignity

• Negative environmental impact related to the activities of ID Genève or its suppliers

• Negative social impact or human rights violations

• Corruption, conflicts of interest, or fraud

• Non-compliance with applicable laws (labor law, environmental law, etc.)

• Misleading communication or greenwashing

• Any other behavior contrary to ID Genève’s values and commitments

Complaints outside the scope (e.g., commercial complaints regarding an order or a product) are redirected to the appropriate department. Furthermore, complaints unrelated to the company’s activities, insufficiently documented, or submitted in bad faith may not be considered formal complaints.

4. How to file a complaint?

ID Genève provides the following channel for filing a complaint:

Complaints are submitted exclusively via the online form available on the ID Genève website: www.idwatch.ch/grievance

This form is accessible to all stakeholders, both internal and external. Anonymous complaints are accepted.

5. Handling Process

Step 1 — Receipt and Acknowledgment (Timeframe: 5 business days)

Upon receipt of a complaint, the designated officer:

• records the complaint in the tracking log (see Section 7)

• sends an acknowledgment of receipt to the complainant (if contact information is provided) within 5 business days

• assigns a unique case number

Step 2 — Initial Assessment (timeframe: 10 business days)

The designated manager assesses the admissibility of the complaint:

• Does the complaint fall within the scope defined in Section 3?

• Is it sufficiently specific to be investigated?

• Is there a conflict of interest with the designated officer?

If the complaint is not accepted, the complainant is notified in writing with a clear explanation of the reason for rejection within 10 business days.

In the event of a confirmed conflict of interest, the case is transferred to another team member or to a designated neutral third party (arbitrator).

Step 3 — Investigation and Resolution (timeframe: 30 calendar days)

For accepted complaints, the designated manager:

• conducts an investigation commensurate with the nature and severity of the complaint

• may request additional information from the complainant or internal parties

• proposes a resolution or a corrective action plan

• submits the resolution to Management for approval if the complaint is serious or systemic

The target resolution timeframe is 30 calendar days from the date of acceptance. If this deadline cannot be met, the complainant will be notified and provided with a new estimated timeline.

Step 4 — Closure and Communication

Upon completion of the procedure, the designated manager:

• notifies the complainant of the resolution in writing (if contact information is provided), detailing the measures taken or the decision rendered

• closes the case in the tracking log with the closure date and a summary of the resolution

• documents lessons learned to improve ID Genève’s practices

6. Confidentiality and Protection Against Retaliation

6.1 Confidentiality

All information related to a complaint is treated as strictly confidential. It is shared only with those directly involved in its handling.

Complainants’ personal data is processed in accordance with ID Genève’s privacy policy and applicable Swiss law (LPD).

6.2 Protection Against Retaliation

Any form of retaliation against a person who has filed a complaint in good faith is strictly prohibited. This protection applies to all stakeholders, whether internal or external.

Any proven act of retaliation constitutes a violation of this procedure and may result in disciplinary action or appropriate corrective measures.

If a person believes they have been subjected to retaliation after filing a complaint, they may contact ID Genève management directly at info@idwatch.ch

7. Designated Officer

ID Geneva designates a single officer responsible for managing complaints:

Officer Nicolas Freudiger

Position CEO

Contact grievance@idwatch.ch

Deputy Cédric Mulhauser (in case of absence or conflict of interest)

8. Tracking Register and Annual Reporting

Each complaint received is recorded in the complaint tracking register (dedicated file). The register contains at a minimum:

• unique case number

• date of receipt

• nature and subject of the complaint

• status (In Progress / Resolved / Rejected / Closed)

• closing date

• summary of the resolution

Once a year, the designated manager prepares an annual summary for management, including:

• the number of complaints received

• breakdown by type of reason

• resolution rate and average processing times

• corrective actions or improvements

If no complaints have been received during the year, the designated manager formally records this in the log to demonstrate that the process is in place.

9. Review and Continuous Improvement

This procedure is reviewed at least every 12 months, or in the event of a significant occurrence (serious complaint, regulatory changes).

Any revision is approved by management prior to publication.

This procedure is publicly available on the ID Genève website and constitutes an official governance document.

Appendix – Monitoring and Traceability

Version: 1.0 – June 2026

Responsible Party: Nicolas Freudiger

This document is approved by ID Genève’s management