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Governance

Dispute Resolution and Grievance Policy

Mechanisms for participants, charities and corporate partners to raise complaints, contest disputed impact milestones, resolve token redemption issues and challenge KERI-related revocations, aligned with Hong Kong law.

Version
v1.0
Effective
2026-07-19
Last reviewed
2026-07-20
Next review
2027-07-19
Owner
Ethics and Compliance Committee
Approver
Board of Directors
Anchored by content hashissued 2026-07-29
Payload hash
96591c5fed6ffd6d340809b624ef20fc44a175d01a25e4deac4a5a9c39bc83b6
SHA-256 digest of the receipt content
Issuer AID
EP1_FGkcwfHAuih6VUzv9kgAVBvvSoaswSUao61lkxhE
Party that issued this receipt
ImpactMiles handle
audit:governance:96591c5fed6ffd6d

This receipt is anchored by content hash. A resolvable credential SAID is not available for this record.

Applies to

  • All platform users (participants, charities, corporates)
  • Employees, contractors and third parties raising a grievance

Jurisdictions

  • Hong Kong (PDPO, IRD s.88)
  • United Kingdom (UK GDPR, DPA 2018)
  • European Union (GDPR)
  • Singapore (PDPA)
  • Australia (Privacy Act 1988)
  • Japan (APPI)
  • Wider APAC per country taxonomy

How this is applied in-product

  • Public complaint intake at /privacy and via direct contact
  • Trust and Verification Committee triage of credential disputes
  • Escalation timers tracked in the admin console
  • Arbitration clauses in Sponsor and Charity master agreements

1. Scope of Disputes

  • Impact disputes - contested milestones, verified action evidence, or IMI attribution.
  • Token and reward disputes - redemption failures, incorrect balances, expired tokens.
  • Verification disputes - revoked or refused TrustMark credentials, Trust Index changes.
  • Commercial disputes - fee application, disbursement delays, sponsorship performance.
  • Conduct disputes - alleged breaches of the Code of Conduct or discrimination.

2. Escalation Path

  • Tier 1 - Support: acknowledged within 1 business day, resolved within 5 where possible.
  • Tier 2 - Trust and Safety review: for evidence, credential or IMI disputes, resolved within 10 business days.
  • Tier 3 - Ethics and Compliance Committee: for unresolved matters or conduct complaints, resolved within 20 business days.
  • Tier 4 - External mediation, then arbitration administered by HKIAC under the HKIAC Administered Arbitration Rules where contracts permit.

3. Appeals

Any decision by the Trust and Verification Committee (including revocation) may be appealed in writing within 20 business days. Appeals are heard by a panel that excludes the original decision-maker.

4. Whistleblowing and Retaliation

Concerns may be raised confidentially via the Ethics and Compliance Committee. Retaliation against a good-faith reporter is a breach of the Code of Conduct and grounds for dismissal or termination.

5. Records

All disputes and their outcomes are logged. Aggregate statistics are reported to the Board quarterly and summarised in the annual Transparency Report.

Questions or concerns about this policy? Contact the DPO.

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