Grievance Mechanism

As part of ensuring effective stakeholder engagement, Aqua-Spark has developed a grievance mechanism which is communicated, implemented, and monitored to ensure that any complaints or feedback received from external stakeholders are formally recorded and are appropriately responded to. Aqua-Spark’s internal grievance mechanism (called the Internal Grievance Procedure) is included and explained in the Internal Grievance Procedure including a clause to ensure confidentiality.

This section of the Manual explains the grievance process for external grievances.

1.     Submitting grievances

In cases where external stakeholders would like to express concern, complaints or suggestions regarding the company’s personnel and activities, they are encouraged as a first step to lodge grievances in writing, telephonically or verbally directly with the portfolio companies of the fund(s) of Aqua-Spark.

However, if external stakeholders wish to submit their grievances to Aqua-Spark directly, they can do so through the ‘Contact’ section on Aqua-Spark’s website, by sending an email to your preferred contact person at Aqua-Spark or to grievances@aqua-spark.nl and by using the grievances form.

A formal grievance must contain:

• A brief and factual description of the complaint;
• The name of the complainant and any accused;
• Date of the complaint and signature of the complain
• The steps taken by the complainant and any related (evidence) documents

When Aqua-Spark receives a complaint, it will acknowledge receipt of the complaint by sharing the following details with the complainant:

• unique grievance case number assigned to the grievance;
• the category assigned (as described in the section below);
• the name and contact details of the person in charge of handling the grievance;
• a preliminary indication of the time that would be required for the internal investigation of the grievance.

2.    Registering grievances

When grievances are submitted to Aqua-Spark, Aqua-Spark will register these in the Grievance Register. The following must be recorded for each grievance entered into the register as the information becomes available:

• Grievance case number;
• Grievance status (open, resolved, unresolved or abandoned);
• Complainant’s name and contact details;
• Date of grievance;
• Details of grievance;
• Level of grievance (see assessing grievance section below);
• History of related grievances / queries / questions (if known);
• Resolutions discussed and agreed with the party(ies) in question;
• Actions implemented (including dates) and;
• Outcome of the actions implemented.

3.    Assessing grievances

Each grievance must be assessed to determine the type of response required. Aqua-Spark has identified three levels of risk associated with grievances which are used to assign responsibility and define the type of response required. When a grievance is assessed, different levels should be considered. Table 1 below outlines the three levels and associated detail.

Grievance levels

Level A: 

• Positive feedback requiring acknowledgement and thanking
• Feedback that is not related to Aqua-Spark (funds) or its portfolio companies and needs to be directed elsewhere
• Question or request for information only

Level B:

• Grievance, but it is not related to a recurrent question/request for information
• Grievance, but there has been no regulatory breach
• Grievance, but there has been no fund and/or portfolio company policy breach
• Grievance, but it is not related to death or serious illness or pollution

Level C:

• Repeated or widespread grievance
• Grievance that is a regulatory breach
• Grievance that is a breach of the funds and/or portfolio company’s policy
• Direct accusation of breach of human rights
• Grievance related to death or serious illness or pollution

4.   Investigating grievances

Once responsibility of a grievance has been assigned to an individual, it should be investigated and resolved. Investigating grievance is depending on the topic of the grievance, with a monitoring role for Aqua-Spark Senior Management, as appropriate, where possible.

When resolving any grievance, records of all correspondence must be kept. Any follow-up monitoring required must be documented and an implementation plan developed and actioned.

The E&S Grievance Register must be completed detailing resolutions discussed and agreed with the party(ies) in question, actions implemented (including dates), follow up monitoring requirements and the outcome of the actions implemented.

5.    Responding to grievances

A response should be provided to the complainant in all cases explaining the action taken or not taken to resolve the complaint. Responses must be provided to the complainant in written form and explained verbally if required. Should the grievance be of level B or C, the response or update may need to be provided directly by Aqua-Spark’s Senior Management and should provide clear information on the proposed final corrective action and detail any related commitments made by both parties.

6.    Communication

For questions or feedback regarding this External Grievance Mechanism please reach out to grievances@aqua-spark.nl.

Fill out grievances form