This policy sets out the two channels SESAMm S.A.S. operates under Regulation (EU) 2024/3005: a complaints-handling mechanism under Article 19 and a channel for reasoned concerns from stakeholders under Article 20. It is owned by the Compliance Officer and approved by the Supervisory Board. This policy and the contact details for both channels are published on SESAMm's website. It complements, and does not replace, the internal ESG Rating Review, Correction Procedure (data-quality and factual-error corrections) and Anonymous Reporting Procedure (whistleblowing).
1. Scope
The complaints channel (Article 19) is open to users and subscribers of SESAMm's ESG ratings, to rated items and to issuers. It covers complaints about how a rating was produced, whether a rating is representative, and how the methodology was applied to an individual rating, as well as factual errors in the underlying data. The reasoned-concerns channel (Article 20) is open to any stakeholder, including parties who are neither users nor rated, who provides their name and position.
2. How to submit
SESAMm operates two intake routes. Rated items and issuers, and users and subscribers, use the secure portal, reached through the personalised link SESAMm provides, where they can review the relevant data and raise a factual error, a case challenge, or a regulatory or methodology question. Any stakeholder who does not use the portal, including parties who are neither users nor rated such as NGOs or academics, may write to Enable JavaScript to view, providing their name and position. Where a case challenge or factual error is sent by email by a party that has portal access, SESAMm redirects it to the portal so that the matter is logged and addressed in a single place.
3. Complaints handling (Article 19)
SESAMm receives, investigates and keeps records of each complaint. Within the portal, factual errors and case challenges are handled under the internal ESG Rating Review and Correction Procedure, while regulatory and methodology questions are routed to SESAMm's regulatory team. Receipt is acknowledged and the matter is investigated fairly. A complaint about how a rating was produced or whether a rating is representative is reviewed independently of the persons who produced the rating concerned. The outcome and the reasons for it are communicated to the complainant in a timely manner. Disagreement with the methodology itself, where it has been correctly applied to accurate data, is recorded and answered but does not constitute a correctable error.
4. Reasoned concerns (Article 20)
SESAMm receives reasoned concerns from any stakeholder who provides their name and position, in particular at Enable JavaScript to view. Such concerns are logged and, SESAMm not being a small ESG rating provider within the meaning of the Regulation, SESAMm endeavours to reply within 30 working days of receipt.
5. Independence and escalation
Complaints and concerns are handled by the Compliance Officer or by a person not involved in producing the rating concerned, so that no person reviews their own work. Matters that cannot be resolved at that level, or that concern the Compliance Officer, are escalated to the Supervisory Board.
6. Records
Both channels are logged in a register maintained by the Compliance Officer, recording the date, the originator, the subject, the assessment, the outcome and the date of reply. Records are retained for at least five years and feed the annual compliance report to the Supervisory Board.
7. Publication and review
This policy and the contact details for both channels are published on SESAMm's website, in accordance with Article 19. The policy is reviewed at least annually and on any material change, and is approved by the Supervisory Board.
8. Related Documents
Internal:
- ESG Rating Review and Correction Procedure
- Anonymous Reporting Procedure
- Conflict of Interest Policy
Restricted:
- TextReveal ESG Alerts: Controversy Exposure Score (CES) Rating Methodology - Supplementary Disclosures to Users and Rated Items
Public:
- TextReveal ESG Alerts: Controversy Exposure Score (CES) Rating Methodology
9. Approval and Signatures
Prepared by: Pierre Rinaldi - COO & Compliance Officer.
Approved by: Supervisory Board (Conseil de Surveillance) of SESAMm S.A.S.
Approval date: 2026-06-19
Formal approval of policies relevant to Regulation (EU) 2024/3005 is recorded in the Supervisory Board minutes, which serve as the central record of signature.
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