1. Purpose

Athletic Brewing Company LLC (the “Company”) is committed to giving its stakeholders a clear, safe, and accessible way to raise concerns about the company’s social, environmental, or governance conduct, and to seek resolution. This procedure describes how a Grievance can be raised, how it will be handled, and how the person raising it is protected from Retaliation.

This procedure is adopted to satisfy the Purpose & Stakeholder Governance requirements of the B Impact Assessment used in B Corporation certification, and to put into practice the Company’s commitment to stakeholder governance.

2. Scope

This procedure applies to Grievances raised by any stakeholder about the Company, including workers, suppliers, customers, investors, and members of communities where the company or its value chain operates. This procedure must be publicly available on the Company’s website and, where needed, in alternative languages or forms so that all stakeholders can access it, regardless of where they are located.

3. Definitions

“Grievance” means a concern raised by a stakeholder about an actual or potential negative social, environmental, or governance impact caused or contributed to by the Company, that meets the grounds described in Section 6.1. 

“Grievance Raiser” means the stakeholder who submits a Grievance, whether on their own behalf or on behalf of another affected stakeholder.

“Retaliation” any adverse action taken against a person because they raised, supported, or participated in theinvestigation of a Grievance in good faith.

“Vulnerable Stakeholder” a Grievance Raiser or affected stakeholder who faces a heightened risk of harm or retaliation as a result of raising a Grievance, for example due to their employment relationship, geographic location, or lack of independent recourse.

4. Policy Statement

4.1 Access

The Company commits to making this procedure publicly accessible on its website, and to providing alternative formats or languages where needed so that all of its main stakeholder groups can use it.

4.2 Safety and Non-Retaliation

The Company commits to protecting anyone who raises a Grievance in good faith from Retaliation, and to giving Grievance Raisers control over confidentiality wherever possible, as described in Section 6.3.

4.3 Fair and Transparent Process

The Company commits to a transparent, consistent process for handling Grievances, including clear grounds for acceptance, defined process steps and target timeframes, and regular communication with the Grievance Raiser about status and outcome.

4.4 Accountability

The Company commits to building, over time, the internal capability to track Grievances, assign clear accountability for their resolution, and report on Grievance activity internally to the Board of Managers and publicly to stakeholders.

5. Roles & Responsibilities

The Board of Managers must receive periodic reporting on Grievances and their resolution. The Chief Human Resources Officer (the “Policy Owner”) owns this procedure, must resolve any dispute about whether a submission qualifies as a Grievance, and is the point of escalation for complex or sensitive Grievances. The intake owner(s) must log each Grievance received, acknowledge it within the timeframe in Section 6.2, and see it through to resolution or closure. Anyone handling a Grievance must maintain confidentiality consistent with Section 6.3 and must not retaliate, or permit Retaliation, against a Grievance Raiser or any other affected stakeholder.

6. Procedures

6.1 Grounds for a Grievance

A submission qualifies as a Grievance under this procedure if it concerns an actual or potential negative social, environmental, or governance impact caused or contributed to by the Company. Matters that are purely commercial in nature (for example, a routine product refund request) may be more appropriately handled through our Customer

Experience team, and the Grievance Raiser will be told so.

6.2 Process Steps and Timeframes

Once a Grievance is submitted, the intake owner must follow these steps:

• Acknowledge receipt within 72 hours;

• Assess whether the submission meets the grounds in Section 6.1 within thirty (30) days, and, if it does not, explain to the Grievance Raiser why it was not accepted;

• If accepted, investigate and work toward resolution, providing the Grievance Raiser with regular updates at each material step, targeting resolution as soon as reasonably practicable taking into account the severity of the Grievance and its impact on Stakeholders; and

• Confirm with the Grievance Raiser when the Grievance has been resolved or provide a clear explanation of the outcome if it could not be resolved as requested.

6.3 Protection from Retaliation

The Company must take the following measures to protect Grievance Raisers and other affected stakeholders from

Retaliation:

• A Grievance Raiser or other affected stakeholder may request that their identity remain confidential if they anticipate Retaliation;

• Grievance Raisers must be told at the outset who will need to be involved in or informed of the Grievance;

• The Company must seek the Grievance Raiser’s consent before sharing their information with additional parties, except the Company’s Executive team, Board of Managers, Legal Department, Compliance Department and Human Resources Department;

• The outcome of a Grievance process must be kept confidential except as needed to close it out with the Grievance Raiser or as required by law;

• Anyone handling Grievances must receive training on confidentiality and non-retaliation;

• A confirmed breach of confidentiality by anyone handling a Grievance is subject to discipline up to and including termination, consistent with the Company’s then-current Employee Handbook; and

• The Policy Owner may engage independent third parties to assess Retaliation and other risks.

6.4 Notification to Stakeholders

The Company must notify each of its main stakeholder groups (workers, suppliers, customers, investors, and relevant communities) that this procedure exists through email and posting this policy on the Company’s internal employee website.

7. Enforcement/Consequences

Compliance is verified through the tracking and reporting described in Section 6.5 and through the Policy Owner’s review of individual case files.

Employees who fail to follow this procedure, breach confidentiality, or retaliate against a Grievance Raiser are subject to discipline up to and including termination, consistent with the Company’s then-current Employee Handbook.

8. Effective Date

This procedure is effective as of September 14, 2026.

9. Version History

Version	Date	Author	Summary of Changes
0.1	2026-07-14	Legal Department	Initial draft from 2026 B-Corp Deliverable Brief

4926-6671-8141, v. 1