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UNGP Principle 31 Unified Workflow

Incident & Grievance Response Procedure

Document IIS-GOV-INC-001  •  Version 1.0  •  Effective 01 May 2026

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Document Reference
IIS-GOV-INC-001
Version
1.0
Effective Date
01 May 2026
Classification
PUBLIC
Jurisdiction
Ontario / Canada (primary), Global (secondary)
Approving Authority
CEO & Executive Leadership

1. Purpose

This Procedure establishes a single, consistent intake-to-remediation workflow for all categories of incident and grievance raised by any internal or external person regarding Integrated IT Support Inc. (the “Company”). It operationalises Principle 31 of the United Nations Guiding Principles on Business and Human Rights and supports the Company's compliance with PIPEDA breach-notification, OHSA incident-reporting, and S-211 due-diligence obligations.

2. Scope and Definitions

3. Effectiveness Criteria (UNGP Principle 31)

This Procedure is designed to be:

4. Intake Channels

5. Workflow

5.1 Acknowledgement (≤ 5 business days)

The GRC Office acknowledges receipt of every report. For anonymous reports, acknowledgement is published in the Company's quarterly transparency note where feasible.

5.2 Triage and Categorisation (≤ 10 business days)

Triage assesses severity, urgency, scope, irremediability, and applicable legal-reporting obligations. Categories include: Ethics; Human Rights; Labour; H&S; Information Security; Privacy; Environment; Community; Anti-Bribery; Other.

5.3 Investigation

Investigations are conducted by the GRC Office with independent expertise as required. Where the matter involves the GRC Office itself, an external investigator is appointed. Investigators apply natural-justice principles and the standard of preponderance of evidence.

5.4 Interim Measures

Where credible, immediate measures are taken to protect affected persons (e.g., separation of complainant and respondent, technical containment of security incidents, environmental spill containment, immediate cessation of contributing conduct).

5.5 Remediation

Where harm is found, appropriate remedy is provided in accordance with the Remediation Framework set out in Section 17 of the Human Rights Policy (IIS-GOV-HR-001). Remedies may include apology, restitution, restoration, compensation, behavioural-change measures, and guarantees of non-repetition.

5.6 Closure Communication

The complainant (if known and not anonymous) is informed of the outcome, the rationale, and any further recourse available, to the extent permitted by privacy and legal constraints.

5.7 Lessons Learned

Anonymised lessons are documented and shared with relevant teams; structural changes are integrated into the Company's policies and procedures.

6. Mandatory External Notifications

7. Records and Retention

All incident and grievance records are retained for a minimum of seven (7) years from the date of closure, in accordance with the Company's Records Retention Schedule and applicable law (PIPEDA, S-211, CRA). Access to records is restricted on a need-to-know basis and protected per the Information Security Policy.

8. Non-Retaliation

The Company prohibits, and will not tolerate, retaliation against any person who raises a concern in good faith. Retaliation is itself a serious breach of this Procedure and the Code of Conduct (IIS-GOV-COC-001), subject to disciplinary action up to and including termination.

9. Reporting on Mechanism Performance

The Company reports on grievance-mechanism performance — volume by category, mean time to close, remediation outcomes (in anonymised form), and lessons learned — in its annual Human Rights Due Diligence Report (iisupp.net/governance/human-rights) and to the Executive Leadership quarterly.

10. Continual Improvement

This Procedure is reviewed at least annually by the GRC Office in consultation with potentially affected stakeholders, and is updated to reflect operational lessons and changes in regulation, standards, or stakeholder expectations.

Approval and Authority

This document has been reviewed and approved by the Executive Leadership of Integrated IT Support Inc. and is issued under the authority of the Office of the Chief Executive Officer. The document is subject to periodic review and may be amended by the Approving Authority. Material amendments are communicated to all employees and key suppliers within thirty (30) days of issuance.

Signed for and on behalf of Integrated IT Support Inc.

Ahmad

Ahmad — Chief Executive Officer

Integrated IT Support Inc.

Date: 11 May 2026

Approved electronically by Ahmad, Chief Executive Officer, on 11 May 2026. This electronic signature is applied with the authority of the named signatory and is valid under the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Ontario Electronic Commerce Act, 2000.