Tuesday, June 30, 2026
B Corp Recertification

Stakeholder Grievance
and Whistleblower Policy

As a Certified B Corporation, Shinebox, LLC is committed to ethical business practices, transparency, and accountability. This Policy establishes a mechanism for all stakeholders to raise concerns, ensures those concerns are handled fairly, and protects individuals from retaliation for reporting in good faith.

PURPOSE

This Policy is designed to:

• Promote ethical, lawful, and responsible business conduct

• Provide a safe and accessible reporting mechanism for all stakeholders

• Ensure concerns are reviewed fairly and promptly

• Protect individuals from retaliation for making good-faith reports

• Support Shinebox’s commitment to accountability, transparency, stakeholder governance, and continuous improvement, including alignment with B Corp principles

SCOPE

This Policy applies to all internal and external stakeholders, including but not limited to:

Internal Stakeholders

• Employees

• Interns

• Temporary staff

• Independent contractors

• Volunteers

External Stakeholders

• Clients

• Vendors and suppliers

• Freelancers and consultants

• Community members

• Applicants and candidates

• Former employees

• Business partners

• Members of the public impacted by company

REPORTABLE CONCERNS

Individuals may report concerns including, but not limited to:

Workplace Conduct

• Harassment or discrimination

• Retaliation

• Bullying or abusive behavior

• Unsafe working conditions

• Wage and hour concerns

• Violations of company policies or code of conduct

Ethics & Compliance

• Fraud or theft

• Financial misconduct

• Conflicts of interest

• Bribery or corruption

• Misuse of company assets

• Falsification of records

• Violations of law or regulation

• Misrepresentation of B Corp practices or standards

Stakeholder & Community Concerns

• Vendor or supplier concerns

• Client complaints involving ethics or misconduct

• Environmental concerns

• Community impact concerns

• Accessibility or inclusion concerns

• Human rights concerns

Other Concerns

• Any conduct inconsistent with the organization’s values, code of conduct, stakeholder commitments, or applicable ethical standards


Note: Issues unrelated to company conduct, or internal HR matters not relevant to third parties, may not be investigated through this process.

REPORTING METHODS

A formal grievance may be submitted through any of the following channels:

Email
contact@shinebox.com

Online Form
Grievance Reporting Form available at shinebox.com. Anonymous submissions are accepted.

Mail
Mark correspondence as “Confidential” to: VP Human Resources, Shinebox, LLC, 401 1st Avenue North, Suite 100, Minneapolis, MN

Direct Report
Reports may be made directly to Human Resources, Senior Leadership, or a Department Manager.

Open Door
Employees are encouraged to speak directly to their manager or a member of the senior leadership team.

The grievance process shall be made reasonably accessible to all stakeholders, including individuals with disabilities or language barriers, where practical.

NON-RETALIATION

Shinebox, LLC strictly prohibits retaliation against any individual who:

• Reports a concern in good faith

• Participates in an investigation

• Requests guidance regarding ethical concerns

• Assists another individual in making a report

Retaliation may include, but is not limited to: termination, demotion, harassment, threats, intimidation, reduced hours, exclusion from opportunities, or adverse vendor treatment.

Any individual who engages in retaliation may be subject to disciplinary action, up to and including termination of employment or business relationship.

CONFIDENTIALITY

Shinebox will make reasonable efforts to maintain confidentiality. Complete confidentiality cannot be guaranteed where disclosure is necessary to conduct a fair investigation or comply with legal obligations. The identity of a reporter will be protected to the extent practicable under the circumstances.

REVIEW & INVESTIGATION PROCESS

Upon receipt of a report, Shinebox will follow this process:

Step 1
Concern documented on the grievance tracking log.

Step 2
Acknowledgment sent within 3 working days when contact information is provided.

Step 3
Preliminary review within 7 working days to determine appropriate next steps.

Step 4
Investigation initiated within 30 working days when action is warranted.

Step 5
Corrective or preventative action proposed where warranted.

Step 5a
If the grievance is denied, the reporter receives written notice of the denial within 5 working days, including a summary of findings and the basis for the decision.

Step 5b
The reporter may submit a written appeal within 10 working days of receiving the denial notice. Appeals are reviewed by senior leadership or a designee not previously involved in the matter. A final written decision is provided within 15 working days.

Step 6
Follow-up within 3 months of corrective action to verify effective implementation.

Step 7
Matter documented and retained per company recordkeeping procedures.

RECORD-KEEPING

All grievances are logged, documented, and retained. Aggregate, anonymized reporting may be included in Shinebox’s annual B Corp reporting.

Records maintained for each grievance include:

• Report date

• Stakeholder type

• Nature of concern

• Investigation status

• Resolution actions

• Closure date

Records are retained in accordance with applicable legal and operational requirements. On an annual basis, Senior Leadership reviews grievance trends, resolutions, and policy effectiveness to support organizational accountability and continuous improvement.

POLICY ADMINISTRATION

This Policy is administered by the VP Finance. Shinebox reserves the right to engage outside legal counsel or third-party investigators where appropriate.

POLICY AVAILABILITY

This Policy is:

• Available to employees in company policy documents on monday.com

• Accessible to internal and external stakeholders upon request or through the company website at shinebox.com

QUESTIONS

Questions about this Policy may be directed to: contact@shinebox.com or by contacting the VP HR & Finance directly.