Grievance & Complaints Mechanism – MORFO

Version: June 2025

Owner: Ethics Officer

Applies to: All whistleblowers, internal or external

Legal Reference: EU Directive 2019/1937, GDPR, Loi Waserman

1. Purpose

This policy sets out the principles, responsibilities, and measures in place at MORFO to protect any individual who reports, or is perceived to have reported, a concern in good faith. It ensures protection from retaliation, safeguards confidentiality, and outlines the company’s commitment to act promptly and fairly.

MORFO recognizes that protecting whistleblowers is essential to maintaining trust, preventing misconduct, and upholding its obligations under applicable legal frameworks and impact standards (e.g. B Corp Pathway 2).

2. Who is Protected

The protection framework applies to any person who reports a concern involving MORFO, including but not limited to:

Employees (regardless of seniority, contract type, nationality, or location)
Former employees, job applicants, interns, apprentices
Independent contractors, freelancers, service providers
Suppliers and their employees
Clients, partners, investors
Community members, field actors, rightsholders
Observers or third parties indirectly exposed to wrongdoing

Protection also extends to persons supporting or associated with the whistleblower (e.g. HR staff, witnesses, legal advisors) or perceived as such.

3. What is Protected

MORFO guarantees protection when the report concerns actual or suspected:

Violations of laws or regulations (national, EU, international)
Corruption, fraud, collusion, embezzlement, insider misconduct
Human rights violations, environmental harm, unsafe conditions
Harassment, discrimination, abuse of authority
Attempts to conceal, destroy, or falsify information
Retaliation following a prior report or participation in an investigation

The report must be made in good faith, with reasonable grounds to believe the facts are true at the time of disclosure — proof is not required.

4. Prohibited Retaliation — Non-Exhaustive List

Retaliation is strictly prohibited. This includes any adverse or discriminatory measure, direct or indirect, material or psychological, such as:

Dismissal, forced resignation, non-renewal of contract
Demotion, unfavorable transfer, career obstruction
Salary reduction, bonus denial, or loss of benefits
Threats, intimidation, surveillance, ostracism
Defamation, internal discredit, unofficial sanctions
Termination of a service relationship or business contract
Harassment or pressure applied to third parties (e.g. colleagues, family)

Any act of retaliation, even attempted or suggested, constitutes a violation of this policy and may result in disciplinary or legal consequences.

5. Protective Measures in Place

To prevent or address retaliation, MORFO provides the following concrete measures:

Anonymous reporting is available via the Factorial system
Pre-assessment of retaliation risk upon receiving every report
Early intervention: immediate precautionary measures if signs of retaliation appear (e.g. neutral reassignment, temporary detachment)
Access to Ethics Officer for confidential advisory support at all times
Monitoring of whistleblower’s working conditions for 12 months post-report
Right to request internal protection (job transfer, schedule flexibility, manager change)
Legal and psychological support through an external network (on demand)
Priority access to mediation for informal resolution in complex or sensitive situations

All protection measures are available without the need to identify the perpetrator or demonstrate intent.

6. Procedure in Case of Suspected Retaliation

Step	Action Description
1. Report	The whistleblower reports suspected retaliation via Factorial or directly to the Ethics Officer (people@morfo.eco).
2. Acknowledgment	The Ethics Officer acknowledges receipt of the report within 3 business days, unless the report is anonymous.
3. Risk Assessment	A preliminary risk analysis is conducted immediately to assess potential severity, urgency, and exposure.
4. Interim Measures	If a risk is identified, immediate protective actions are taken (e.g. temporary reassignment, separation from the accused, flexible leave, etc.).
5. Investigation	A formal and confidential investigation is conducted by the Ethics Officer (or delegated neutral party) within 15 working days.
6. Resolution	If retaliation is confirmed, MORFO applies corrective actions (e.g. reinstatement, compensation) and disciplinary sanctions against the retaliator.
7. Communication	A written summary of the findings and measures taken is provided to the whistleblower, unless anonymity prevents contact.

7. Governance & Oversight

The Ethics Officer oversees retaliation management and confidentiality compliance
People & Culture ensures integration of protection into HR systems and case tracking
Leadership receives anonymized reporting on retaliation cases and systemic risks
No manager or decision-maker involved in the report may interfere with case handling

8. Recordkeeping & Audit

All retaliation cases are logged in a confidential register (Factorial)
Retention period: 5 years unless legal proceedings extend it
Only the Ethics Officer and HR Director may access the full case record
An annual protection audit is conducted internally, and measures updated accordingly

9. External Remedies

This policy does not affect the right of the whistleblower to:

Report directly to external authorities (e.g. Defender of Rights, CNIL, EU agencies)
File a complaint before a labor court or civil tribunal
Request protection under official whistleblower status (as per Law 2022-401)
Request safe disclosure pathways via trade unions or independent legal counsel

10. Legal Framework & Reference Standards

This policy implements and exceeds the minimum requirements of:

Directive (EU) 2019/1937 on whistleblower protection
General Data Protection Regulation (GDPR – EU 2016/679)
French Law No. 2022-401 ("Loi Waserman")
B Lab Risk Review – Pathway 2 (Controversial Clients Framework)
OECD Guidelines, UNGP, and ILO Convention 190