Anara Impact | Grievance Mechanism & Feedback

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Grievance Mechanism

Grievance Mechanism & Feedback

We are accountable to the entrepreneurs, communities and ecosystems we invest in. This page explains how to raise a concern and what happens when you do.

Aligned with IFC Performance Standards

Last updated: June 2026

Contents

Purpose & Scope

Who Can Submit a Grievance

Types of Grievances

How to Submit

Grievance Process & Timelines

Confidentiality & Non-Retaliation

Appeal & Escalation

Portfolio Company Grievances

Feedback & General Enquiries

01 · Purpose

Purpose & Scope

Anara Impact Capital is committed to operating with integrity, transparency and accountability. This Grievance Mechanism provides a structured, accessible and fair process for any individual or organisation to raise concerns about Anara’s activities, investment practices, or the conduct of companies in our portfolio.

This mechanism is aligned with the IFC Performance Standards on Environmental and Social Sustainability, the UN Guiding Principles on Business and Human Rights, and the Operating Principles for Impact Management (OPIM). It covers grievances relating to:

Anara Impact Capital as an investment manager

Portfolio companies in which Anara holds an investment

Anara’s fund operations, investment conduct and stakeholder engagement

Our commitment: Every grievance received will be acknowledged, investigated fairly, and resolved as promptly as possible. We treat all complaints in good faith and with appropriate confidentiality. Anonymous submissions are accepted.

02 · Who Can Submit

Who Can Submit a Grievance

This mechanism is open to any individual or organisation that believes they have been affected by the actions of Anara Impact Capital or a company in which Anara has invested. This includes, but is not limited to:

Founders and entrepreneurs who have pitched to, or invested alongside, Anara

Employees of Anara portfolio companies

Communities or individuals affected by the operations of portfolio companies

Investors, limited partners or co-investors

Suppliers, contractors or partners of Anara or portfolio companies

Any individual or organisation with a legitimate concern relating to Anara’s conduct

There are no nationality, geography or sector restrictions on who may submit a grievance. Submissions may be made in English, Arabic or French.

03 · Types of Grievances

Types of Grievances

Grievances that may be raised through this mechanism include:

Environmental & Social Concerns

Environmental harm caused by portfolio company operations

Labour rights violations, including unfair dismissal, discrimination or unsafe working conditions

Community impacts or displacement resulting from portfolio company activities

Failure to deliver stated social or environmental outcomes

Governance & Conduct Concerns

Allegations of fraud, corruption or bribery

Conflicts of interest not properly disclosed or managed

Misrepresentation of impact data or impact washing

Violations of Anara’s investment policies, exclusion criteria or SFDR commitments

Investor & Founder Relations

Concerns about the fairness or transparency of Anara’s investment process

Alleged breach of confidentiality regarding pitch materials or business information

Complaints about investor conduct or communications

04 · How to Submit

How to Submit a Grievance

Grievances may be submitted through any of the following channels. Anonymous submissions are accepted and will be treated with the same seriousness as identified submissions.

Online form: Complete the form below on this page — the quickest and most trackable method.

Email: Send your grievance to claims@anaraimpact.com

Post: Address a written grievance to the Compliance Officer, Anara Impact Capital, [Registered Address], Netherlands.

When submitting, please include as much detail as possible: the nature of the concern, the parties involved, dates, any evidence or documentation, and your preferred contact method for follow-up (if not anonymous).

05 · Process & Timelines

Grievance Process & Timelines

All grievances received are handled according to the following process:

Submission: Grievance received via form, email or post. Logged in the grievance register with a unique reference number.

Acknowledgement: Within 5 business days, the submitter (if identified) receives written confirmation of receipt.

Preliminary Review: The case officer conducts an initial review within 10 business days to determine scope, jurisdiction and appropriate investigation path. Manifestly unfounded or out-of-scope submissions will be notified of this determination with reasons.

Investigation: A full investigation is conducted within 15–30 days depending on complexity. The investigation may involve interviews, document review, engagement with relevant portfolio companies, and consultation with external experts where appropriate.

Resolution & Response: A written resolution is communicated to the submitter (if identified) within 45 days of acknowledgement. The resolution will include findings, any remedial actions taken or planned, and the appeals process if the submitter disagrees.

Monitoring: Where remedial action is required, Anara monitors implementation and reports outcomes in its annual impact report (where permitted by confidentiality obligations).

A consolidated PAI Statement is published annually and made available to investors upon request.

Complexity extensions: For complex multi-party grievances, the 45-day resolution timeline may be extended by up to 30 additional days. Submitters will be notified in writing if this applies, with a revised expected resolution date.

06 · Confidentiality

Confidentiality & Non-Retaliation

Confidentiality

All grievances are treated with strict confidentiality. The identity of the submitter (if provided) will not be disclosed to any party beyond those directly involved in investigating and resolving the grievance, except where required by applicable law or regulatory obligation. Anonymous submissions will be investigated based solely on the information provided, without any attempt to identify the submitter.

Non-Retaliation

Anara Impact Capital prohibits any form of retaliation against individuals who raise grievances in good faith. This applies to employees, founders, portfolio company staff, investors and any other stakeholders. Any attempt to retaliate against a grievance submitter will itself be treated as a serious conduct matter.

If you believe you have experienced retaliation for raising a grievance, please contact us immediately at claims@anaraimpact.com

07 · Appeal

Appeal & Escalation

If you are dissatisfied with the outcome or process of your grievance, you may appeal. The appeal process is as follows:

Submit a written appeal to claims@anaraimpact.com within 30 days of receiving the resolution, citing the reference number and grounds for appeal.

Appeals are reviewed by a senior partner not previously involved in the original investigation.

An appeal decision will be communicated within 30 days of the appeal submission.

External Escalation

If you remain unsatisfied following Anara’s internal appeal process, you retain the right to escalate to relevant external bodies, which may include:

The relevant regulatory authority in the Netherlands (Autoriteit Financiële Markten — AFM) for matters under Dutch financial regulation

The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) for data protection concerns

The IFC Compliance Advisor/Ombudsman (CAO) framework, where applicable

Any other competent judicial or regulatory authority in the relevant jurisdiction

08 · Portfolio Companies

Portfolio Company Grievances

Grievances relating to the conduct or activities of companies in which Anara has invested will be handled as follows:

Anara will engage directly with the portfolio company management and relevant stakeholders to understand the nature of the concern.

Where a grievance implicates a potential breach of the portfolio company’s impact commitments, ESG covenants or Anara’s investment conditions, Anara may exercise its governance rights to require remedial action.

Anara will communicate findings and any actions taken to the submitter (subject to confidentiality obligations).

Where a portfolio company has a direct-to-beneficiary product or service, Anara will also encourage and support the establishment of the company’s own accessible grievance mechanism.

Note: Anara’s ability to resolve grievances relating to portfolio companies is constrained by our shareholder rights and the degree of influence we have over management decisions. We will always act within our governance remit and in good faith to address concerns raised.

09 · Feedback

Feedback & General Enquiries

Not all concerns rise to the level of a formal grievance. If you have feedback about Anara’s investment approach, impact strategy, stakeholder engagement, or any other aspect of our work — we welcome it.

General feedback can be submitted via:

The form above (select “Other” as the grievance type)

Email to claims@anaraimpact.com

Feedback submitted in good faith will be reviewed by the team and used to continuously improve our practices. We may not be able to respond individually to all general feedback, but we read every message.

An early-stage impact fund investing in learning, wellbeing and climate resilience — built on two decades of regional conviction.

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Grievance Mechanism & Feedback

Domiciled in the Netherlands · External AIFM under EU Directive 2011/61/EU

Anara is part of the broader efforts under the Social Entrepreneurship Fund (SEF) – a catalyst financing initiative for the social economy started by remarkable group of institutional investors such as BMZ and EU.

Attention: This investment falls outside AFM supervision. No license required for this activity. This website is for informational purposes only and does not constitute an offer to buy or sell any security. Prospective investors should consult their own professional advisers before any investment decision.

An early-stage impact fund investing in learning, wellbeing and climate resilience — built on two decades of regional conviction.

Explore

Engage

Careers

Compliance

Sustainability Disclosures (SFDR)

Grievance Mechanism & Feedback