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Grievance Redressal & Complaint Mechanism Policy

INTRODUCTION

Nuvem Labs Private Limited is committed to maintaining a transparent, ethical, fair, and inclusive work environment for all employees, partners, suppliers, contractors, clients, and stakeholders.

Nuvem Labs recognizes that an effective grievance and complaint mechanism is essential for promoting accountability, protecting stakeholder rights, and ensuring compliance with legal, ethical, and ESG-related obligations.

We are committed to providing an accessible and confidential mechanism through which stakeholders can raise concerns, complaints, or grievances without fear of retaliation or discrimination.

OVERVIEW

Nuvem Labs believes that organizations should maintain a formal grievance management process that encourages open communication, fair treatment, and timely resolution of concerns.

The organization is committed to handling grievances in a professional, impartial, and confidential manner while implementing appropriate corrective and preventive actions wherever required.

This policy supports Nuvem Labs’ commitment towards ethical business conduct, employee well-being, human rights, compliance, and responsible business practices.

SCOPE

The scope of the Nuvem Labs Grievance Redressal & Complaint Mechanism Policy applies to:

• Employees
• Contractors
• Suppliers and vendors
• Business partners
• Clients and customers
• Consultants
• Any other stakeholders associated with Nuvem Labs

POLICY STATEMENT

Nuvem Labs makes the following commitments regarding grievance handling and complaint management. Employees, contractors, partners, and suppliers are expected to adhere to these commitments and support the grievance management process.

• Accessible Grievance Mechanism

Nuvem Labs shall maintain formal grievance reporting channels through which stakeholders can raise concerns related to:

  • Workplace issues
  • Harassment or discrimination
  • Ethical misconduct
  • Human rights concerns
  • ESG and sustainability matters
  • Information security or privacy concerns
  • Compliance violations
  • Vendor or supplier-related concerns

• Confidentiality & Non-Retaliation

All grievances and complaints shall be handled confidentially to the extent reasonably possible.
Nuvem Labs strictly prohibits retaliation, discrimination, intimidation, or unfair treatment against any individual raising a concern in good faith.

• Fair Investigation & Resolution

All complaints received shall be reviewed appropriately and investigated in a fair, impartial, and timely manner.
Where necessary, corrective and preventive actions shall be implemented to address identified concerns and prevent recurrence.

• Compliance Monitoring & Tracking

Nuvem Labs shall maintain appropriate grievance tracking and compliance monitoring mechanisms, including:

  • Complaint registration and tracking
  • Investigation status monitoring
  • Resolution timelines
  • Corrective action tracking
  • Escalation management
  • Periodic management review

• Awareness & Accessibility

Employees and stakeholders shall be informed about the grievance mechanism and available reporting channels.
Complaints may be submitted through official communication channels, including designated grievance or compliance email addresses and website contact mechanisms.

• Continuous Improvement

Nuvem Labs is committed to periodically reviewing grievance trends, corrective actions, and process effectiveness to strengthen organizational compliance and stakeholder trust.

HOW TO RAISE A COMPLAINT

Stakeholders may raise grievances or complaints through the following channels:

  • Grievance Email: grievance@nuvemlabs.com
  • Compliance Email: compliance@nuvemlabs.com
  • HR Support: hr@nuvemlabs.com
  • Website grievance/contact form available on the official website
  • Reporting to HR or management representatives
  • Escalation to the Compliance Officer where required

Complaints may be submitted anonymously where permitted by applicable laws and regulations.
The complainant should provide sufficient details regarding the concern to support appropriate review and investigation.

COMPLAINT HANDLING PROCESS

• Complaint Receipt & Registration

All complaints received shall be formally recorded and assigned for review.

• Acknowledgement

An acknowledgement of receipt may be shared with the complainant within a reasonable timeframe where contact details are available.

• Review & Investigation

The complaint shall be reviewed by the appropriate department or authorized personnel. Investigations shall be conducted fairly, objectively, and confidentially

• Corrective & Preventive Actions

Where required, corrective and preventive actions shall be implemented to address identified issues and reduce the risk of recurrence.

• Resolution & Closure

Upon completion of the review or investigation, the complaint shall be closed and resolution status communicated to the complainant where applicable.

• Escalation Mechanism

If the complainant is not satisfied with the outcome or resolution, the matter may be escalated to senior management or the designated compliance authority.

GRIEVANCE TRACKING & RECORD RETENTION

Nuvem Labs shall maintain appropriate records of complaints, investigations, actions taken, and resolutions for compliance and monitoring purposes.

Records shall be securely maintained in accordance with applicable legal, regulatory, and organizational requirements.

ROLES & RESPONSIBILITIES

• Employees & Stakeholders

  • Report concerns responsibly and in good faith
  • Cooperate during investigations where required

• Managers & Department Heads

  • Support fair grievance handling
  • Ensure timely review and resolution of concerns

• HR / Compliance Team

  • Maintain grievance records
  • Monitor complaint handling processes
  • Ensure confidentiality and compliance oversight

• Senior Management

  • Review escalated matters
  • Support implementation of corrective actions and policy effectiveness

POLICY REVIEW

Nuvem Labs shall periodically review this policy, grievance trends, and monitoring mechanisms to ensure effectiveness, regulatory compliance, and alignment with organizational values and ESG commitments.

ADMINISTRATIVE INFORMATION

This policy is applicable to all employees and stakeholders associated with Nuvem Labs Private Limited and is effective from 1st Jan 2026.

Any exceptions to the clauses in this policy can be approved only by the Director of the business unit. The policy may be reviewed and updated from time to time based on business, legal, regulatory, or ESG requirements.

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