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.
• outlines a triage system for escalating serious incidents.
• outlines a referral process for complaints that do not fall within the scope of the policy. (e.g. Complaints that do not fall within the scope of the policy would include, for example, complaints against an employee of another organisation or government department.)
• commits to providing appropriate assistance and referrals to survivors (e.g. providing assistance to complainants might include medical, social, legal and financial assistance, or referrals to such services.)

A documented investigation procedure, which stipulates that an organisational record must be kept of all misconduct complaints, noting the ability to de-identify complaints at the request of the complainant or survivor.

Guidance

Having a complaints policy that is clear and readily accessible by all stakeholders is critical to fostering and ensuring accountability. It is a vital part of an organisation’s safeguarding mechanisms.

A complaints policy provides internal guidance to staff on how a complaint must be handled. A triage or prioritisation system for escalating serious complaints ensures that complaints are classified and prioritised according to their seriousness and appropriately handled within the organisation. Providing a clear reporting classification and reporting system ensures complaints are handled by the right people in the organisation, and follow appropriate response protocols. For example, a complaint from a regular supporter about the volume of marketing material they receive would be classified and handled differently to a complaint about the behaviour of staff, such as an act of fraud or sexual exploitation or abuse. The complaints policy should outline what processes should be followed for different types and degrees of complaints – for example, sexual misconduct, financial misconduct, child safeguarding incidents, HR misconduct incidents, and supporter concerns. The policy should also provide guidance to staff on how to manage complaints that do not fall within the scope of the member’s policy – usually by referral to the entity that is the subject of the complaint.

A policy also provides an important statement of the organisation’s commitment to welcoming and responding to complaints and being accountable to stakeholders. It is used to communicate this commitment to both internal and external stakeholders. This includes a commitment to providing appropriate assistance and referrals to survivors of sexual exploitation or abuse such as by mapping out key stakeholders and service providers for referrals, and by seeking to provide financial support to the extent practicable.

Members can find links to the complaints policies of other Members by looking at their websites.

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).
• Staff Code of Conduct (or equivalent)
• Key policies relevant to the public including but not limited to, privacy, complaints, transparency, non-development activity, child protection, prevention of sexual exploitation and abuse, and conflict of interest.

Primary Stakeholder communication:

• Information is provided to primary stakeholders on the expected behaviour of the organisation’s staff and volunteers, and access to its local complaints mechanism.

Guidance

Making the information listed above available on your website, ensures it is accessible to a range of stakeholders and makes a public statement about the organisation’s commitment to the policy areas covered such as child protection, PSEA and welcoming complaints. 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. Including the organisations staff code of conduct, enables all stakeholders to familiarise themselves with the behaviours they can expect of staff and makes a public statement about the expectations of the organisation of its staff. Communicating this same information to primary stakeholders also makes a public commitment by the organisation and enables primary stakeholders to understand what is acceptable and unacceptable behaviour. This is a critical component in accountability and the prevention of sexual exploitation and abuse. It is equally important that the organisation ensures that primary stakeholders understand the information provided to them.

Documented protocols for the reporting of serious incidents to the governing body. Safeguarding should form a standing agenda item for governing body meetings.

Guidance

Requiring the governing body to systematically and regularly consider safeguarding, elevates the importance of safeguarding within an organisation ensuring the governing body is providing leadership on safeguarding and PSEA. This requirement should be documented within the mandate or list of responsibilities of the governing body and in documented reporting protocols to ensure it is institutionalised. The governing body as the leadership of the organisation, should be accountable for serious incidents. Involving the governing body will assist in fostering a leadership and culture in the organisation that promotes safeguarding.