Commitment 7.3 We are accountable to our stakeholders.

Compliance Indicators

Compliance with the Commitments will be assessed against the following Compliance Indicators. All of the applicable Compliance Indicators must be met by every ACFID Member to be considered compliant with the Code. Each of the Compliance Indicators has one or more compliance Verifiers. Verifiers are the description of evidence that is required to substantiate compliance with each Compliance Indicator. Guidance is also provided. 

7.3.1 Members demonstrate an organisational commitment to operating transparently with all stakeholders.


Members are required to extend this compliance indicator and verifiers to partners through MOUs or similar.        

  • Policy, statement or guidance document (separate, or as part of other guidance such as for communications), that address expectations for transparency including what information is made public and when.  


A transparency policy should outline your organisation’s committing to disclosing timely, relevant and accurate information in an accessible format, with any exceptions clearly and reasonably explained (such as data protection issues). It should outline what information your organisation is committed and prepared to share with the public and how it will respond to requests for information. This is also sometimes referred to as an open information policy.

Information that your organisation is committed to sharing might include, for example, your organisation’s legal status, purpose and governance structure; descriptions of significant programmes; policy papers, reports and press releases; formal agreements with other organisations; strategic documents; budgets; financial records; research and reports, organizational policies; and records of the environmental impact of activities. An example of a transparency policy can be found in the Resources Section below.

7.3.2 Member development initiatives consistently demonstrate the separation of development and non-development activities

Members are required to extend this compliance indicator and verifiers to partners through MOUs or similar


Policy, statement or guidance document that addresses the separation of development activities from non-development activities in:

  • Programming.
  • Expenditure reporting.
  • Fundraising.
  • Advocacy campaigns.
  • Communications.
  • Choice for donors.
  • Partners.

Development initiatives that consistently show evidence of the separation of development and non-development activities


The policy, statement or guidance document that clearly separates aid and development and non-aid and development activity needs to refer explicitly to both religious adherence promotion and political activity. ACFID has a policy template to assist signatory organisations to develop policy that addresses the separation of development activities from non-development activities, which can be found in the Resources Section below.

7.3.3 Members enable stakeholders to make complaints to the organisation in a safe and confidential manner.


Members are required to extend this compliance indicator and verifiers to partners through MOUs or similar.         



A documented complaints handling policy that:

  • Is readily accessible on the organisation’s website.
  • Provides a safe and discrete point of contact for stakeholders in Australia and countries where work is conducted, to raise concerns or complaints about the organisation.
  • Is responsive and fair.
  • Provides information to all stakeholders, including to Members of the communities where activities are implemented, about the reporting and complaints procedure.
  • Provides information in a clear and easily understandable manner in appropriate forms and through appropriate media.
  • Ensures that requirements for filing a complaint take into consideration the needs of the most vulnerable and considers minority and disadvantaged stakeholders.
  • Advises a complainant of the ability to make a complaint regarding an alleged breach of the Code to the ACFID Code of Conduct Committee.
  • Provides information on how staff and volunteers are equipped to understand and implement the policy.
  • Includes a process for reviewing and analysing complaint information within the organisation.



ACFID's guidelines for the development of a Complaints handling policy are provided in the resources section below. A good example of a complaints handling policy, UNICEF's Complaints Policy, can also be found in the Resources Section below. Members will also  find links to the complaints policies of other Members by looking at their websites. 

7.3.4 Members make information about their organisation and its work available to all stakeholders.



Members will provide the following information on their website:

  • Information on its governance: structure, responsible persons and organisational contact information.
  • ABN.
  • Information on their work, including key projects or programs.
  • Information on partners and their roles.
  • A statement of commitment to adherence to the Code.
  • The scope for and mechanism/process for lodging a complaint against the organisation, and a point of contact.
  • Identification of the ability to lodge a complaint alleging a breach of the Code with the ACFID Code of Conduct Committee, and a point of contact.
  • An Annual Report including the ACFID-Code-compliant financial statement in line with ACFID requirements (as outlined in Compliance Indicators 8.3.1 and 8.3.2).
  • Key policies relevant to the public including but not limited to, privacy, complaints, transparency non-development activity, child protection, conflict of interest.



In general, information must be easily accessed, accurate and up to date. It may need to be tailored to increase its accessibility to different stakeholders, such as primary stakeholders (to whom development activities seek to directly benefit), partners, government, regulatory bodies, local leaders and officials, donors, supporters, volunteers, staff, governing body members, and peer organisations. 

7.3.5. Members seek input and feedback from all stakeholders


Policy, statement or guidance document committing the Member to the dissemination of information to all stakeholders and to seeking their inputs and feedback.


The policy, statement or guidance document may be a stand alone document or it might be addressed in other policy and guidance documents, such as in the organization’s policy on transparency (refer to 7.3.1) and its policy on complaints handling (refer to 7.3.3). However, it is important to note that this Compliance Indicator recognises the value of all types of input and feedback from stakeholders, not only complaints.  The important aspects that need to be addressed is the organisation’s commitment to sharing timely, relevant and accurate information in an accessible format; a commitment to providing stakeholders with an opportunity to provide input and feedback which includes compliments, suggestions and complaints; and a commitment to responding to feedback effectively and appropriately.

Good Practice Indicators

The following Good Practice Indicators describe a higher standard of practice than that set out in the Compliance Indicators. While Members do not need to meet the Good Practice Indicators to be considered compliant with the Code, they will self-assess against these indicators once every three years. This provides a clear pathway for Members to strengthen and improve practice over time.

  • Materials outlining organisation vision, mission and values, are available to partners and primary stakeholders in accessible forms. 
  • Complaints mechanisms are adapted to local contexts and provided in accessible formats and languages.


Good Practice Guidance

Here are some practical suggestions for your organisation to further deepen and improve practice over time. 


  • Publish a clearly defined mission statement
  • Publish information on your governance: structure, decision-making processes, governing body members and contact information
  • Comply with all relevant governance, financial accounting and reporting requirements
  • Publish an annual financial report that conforms with relevant laws and practices and is audited by a qualified independent auditor whose statement accompanies the report
  • Publish an annual report that also describes your NGO’s mission and values, objectives and outcomes achieved in programmes and advocacy work, environmental impact, governance structure, processes and main office bearers, main sources of funding, financial performance, and contact details
  • Maintain an updated website
  • Regularly update donors and supporters through a wide range of communication channels, such as through newsletters and your website and social media channels
  • Information should include organisational activity, including actual performance in relation to previously agreed goals, financial reports showing actual expenditure compared to budget, and any significant changes to programme goals or activities, the budget or key contacts.
  • Publish relevant information in the country of operations. This could include:
    • Background information on your organisation or partners, including the mission and values, country of origin, website, and legal status in country of operations
    • Details of the specific programme, including name, duration, location, goals, activities, target criteria and budget (while ensuring that the safety or wellbeing of any person or child is not compromised in doing so)
    • Contact information, including country office address, name and contact details of the programme manager and other relevant individuals
    • Regular reports of actual performance in relation to previously agreed goals
    • Regular financial reports showing actual expenditure compared to target
    • Any significant changes to programme goals or activities, the targets or key contacts
    • Dates and locations of key events such as meetings and consultations
    • Specific contact details for making comments or suggestions on the program activities or to request additional information
    • Information on how to make complaints about activities, including a named member of staff to contact and contact details
    • Tailor information for it to be readily accessible to the different stakeholders. 

Separation of non-development activity

  • Develop and document your organisation’s vision, purpose and values. For signatory organisations that engage in non-development activities, this can be used as the basis for discussion with partners and other stakeholders to develop shared understanding.
  • Signatory organisations that are accredited with the Australian Government ANCP program or have ‘approved organisation status’ under the Overseas Aid Gift Deductibility Scheme (OAGDS) funds raised under this scheme must not used for any purpose other than aid and development activity.  Signatory organisations should be aware that DFAT’s official definition of non-development activity includes welfare activities – refer to the Australian NGO Accreditation Guidance Manual.
  • For governing body members, volunteers or staff who are affiliated with a particular religion or political party in their private or professional lives, it can be challenging to separate this from their engagement in aid and development activities. In this situation you could implement the following:
    • Undertake orientation and training for all new board members, staff and volunteers to distinguish between development and non-developmental activities
    • Develop and disseminate clear guidance for any representatives engaging in field-based activities, such as monitoring or partner engagement, to ensure the distinction between the development and non-development activities is monitored and remains clear in activities, communication and practices
    • Ensure compliance with the separation by taking action where required to address inconsistent behaviour.
    • Help staff and volunteers understand that separating development and non-development activity doesn’t devalue their personal beliefs or affiliations, but can affirm and clarify the motivations that drive their involvement in development and justice.
  • Share your vision, purpose and values, and share and discuss your policy and guidelines on the separation or exclusion of non-development activity with partners and other key stakeholders to facilitate shared understanding
  • If necessary assist partners in training to help their staff and volunteers understand the reasons that separating development and non-development activities is critical for development effectiveness and assist your partner to develop their own policy on the separation or exclusion of non-development activity
  • Include explicit reference to the separation of non-development activities, including clear definitions, in partner agreements (or the equivalent) in order to ensure shared understanding and that such policy extends to partner and implementing organisations. This is a mandatory compliance requirement.
  • Monitor compliance of the clear separation or exclusion of non-aid and development activity through explicit reference in monitoring report templates and progress report templates
  • Where signatory organisation engage in non-development activities:
    • Ensure these dual activities are managed separately and can exists separately in a way that acknowledges the distinction between them
    • Do not incorporate such activities into programs designed to address poverty as this may exploit vulnerabilities[1]
    • Develop reporting tools that assist partners to report on and acquit non-development activities separately to development activities.
  • For signatory organisations that engage in non-development activities allow donors in online or printed fundraising materials to choose for their donation to be used for aid and development activities only or for non-development activities. Donors should be made aware that donations to non-development activities are not tax deductible. This is a mandatory compliance requirement.

[1] Proselytisation and Poverty, Church Agencies Network Statement, February 2014