D.6 Complaint-Handling Within Signatory Organisations

The ‘right to be heard’ and the ‘right to redress’ are basic consumer rights, as reflected in the consumer guarantee in the Australian Consumer Law and enshrined in the UN Guidelines for Consumer Protection.

The components of complaint handling include a sound process where a consumer or stakeholder is aware of the process, can access the process freely, can make queries or report and lodge a complaint, and receive a response.

This is a key part of accountability for signatory organisations and an important tool for organisations to improve their own practices and manage risks.

It is effective when the process is safe and robust, and the organisation is committed to responding to and learning from the complaint.

Section D.6 of the Code of Conduct includes two sets of Standards each with their respective Principles and Obligations. Standard D.6.1 encourages signatory organisations to recognise the value of complaints. Standard D.6.2 encourages signatory organisations to ensure that stakeholders are aware of and can access complaint-handling processes.

Note that these standards relate to your organisation’s own capacity to accept and address complaints. Complaints against signatory organisations for non-compliance with the Code of Conduct are brought to the ACFID Code of Conduct Committee, as outlined in Standard E.3.1.
 

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D.6.1 Value of Complaints

Principle

Signatory organisations recognise the importance and value of listening and responding to concerns and complaints.

Obligations

  1. Signatory organisations will equip staff and volunteers with an understanding of the organisation’s approach to complaints response and assist them to effectively implement the policies.
  2. The signatory organisation will have in place a process for reviewing and analysing information available from concerns and complaints raised with the organisation.

Why

The ability of stakeholders to communicate concerns or complaints is critical for an organisation’s accountability to its stakeholders. A complaints mechanism provides a way for stakeholders to question decisions and actions, receive a response and hold you to your commitments.

Complaints can relate to the whole range of your activities including ongoing business practices, policies and decision-making processes and programs. They could relate to non-compliance, corruption, and any decisions that may have a negative impact on stakeholders as well as development outcomes.

Values

This standard reflects the Code of Conduct’s commitment to:

  • Accountability to all stakeholders for performance and integrity
  • Building creative and trusting relationships
  • Honesty and transparency in all dealings
  • Strengthening civil society.

Practical guidance

Here are some practical suggestions for your organisation to strengthen its recognition of the value of complaints:

Organisation and policy level

  • Create and document a policy or guidelines outlining your acknowledgment of the importance and value of complaints to accountability. The document could include reference to:
    • The value of hearing stakeholders’ voices
    • Communicating to stakeholders the commitments you are accountable for
    • Ensuring a safe, fair and robust complaints mechanism that is accessible in different contexts
    • A review process that ensures confidentiality and impartiality
    • How to ensure internal and external stakeholders are aware of the mechanism
    • The process for response to a concern or complaint, including time frame
    • How you will review and learn lessons from the complaints
  • Respond to complaints using a clear process and mechanism that ensures the complaint is acknowledged, listened and responded to, within a reasonable amount of time.
  • Your governing body should delegate responsibilities for receiving and responding to complaints. Determine issues such as: Who is the first point of contact? Should complaints be reviewed by your governing body, management committee or other persons?
  • Document the procedures, tools and templates to assist the nominated persons responsible for reviewing and responding to concerns and complaints
  • Ensure that the nominated persons have the necessary resources to address the complaint, including seeking more information and analysing the issue
  • Establish and maintain a complaints register that documents complaints received, action taken and dates. The governing body should review the complaints register on an annual basis.
  • Ensure you have a system to keep track of trends or other useful information arising from aggregate complaint data as this could assist with risk management
  • Consider whether people are aware of the complaints process during monitoring and evaluation.

Staff and volunteers

  • During induction, orient new directors, staff and volunteers to the importance of a safe, fair and robust complaints mechanism and its link to ensuring accountability to all stakeholders. This will contribute to an organisational culture that respects the need for a complaints process.
  • Provide them with the relevant policy or guidelines.
  • Ensure they are aware of the complaints mechanism and processes
  • Nominate a staff person or staff group (depending on the size of the organisation) to act as the contact point to receive and process complaints.
  • Provide nominated staff with the relevant policy, tools and trainings to receive and process complaints, facilitate a response and capture learnings.
  • The complaint may need to be directed to and a response made, by a governing body member.

Partnership arrangements

  • Share all relevant policy and tools with partners
  • Ensure partners inform communities and beneficiaries of programs about the complaints mechanism
  • Involve partners in the development of a locally available mechanism that is accessible, practical and culturally safe. 

Resources

Cross-references to other standards

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D.6.2 Accessibility and Awareness

Principle

Signatory organisations will seek to ensure that their feedback and complaints handling processes are effective, safe, confidential and accessible to all stakeholders, irrespective of their gender, status or background and without prejudice to their future participation.

Obligations

  1. Signatory organisations will have a documented complaints handling policy and procedure that:
    1. Provides an accessible, safe and discreet point of contact for stakeholders in Australia and countries where work is carried out to raise concerns or complaints about the organisation
    2. Is responsive and fair
    3. Provides information to all stakeholders about the reporting and complaints procedure
    4. Provides information in a clear and easily understandable manner in appropriate forms and through appropriate media
    5. Ensures requirements for filing a complaint take into consideration the needs of the most vulnerable and considers minority and disadvantaged stakeholders
    6. Advises a complainant of the ability to make a complaint regarding an alleged breach of the Code to the ACFID Code of Conduct Committee.

Why

It is important that stakeholders are aware of your organisation’s complaints mechanism. It is also crucial that the mechanism is effective and that it is accessible. Your stakeholders must be confident that the mechanism is safe, fair and robust. Any challenges or obstacles to accessing the mechanism need to be addressed and resolved. Complaints should be dealt with quickly and fairly. This will help to increase trust. When organisations learn from issues raised, it can also improve their effectiveness.

Values

This standard reflects the Code of Conduct’s commitment to:

  • Accountability to all stakeholders for performance and integrity
  • Building creative and trusting relationships
  • Honesty and transparency in all dealings
  • Strengthening civil society.

Practical guidance

The basis for a sound complaint-handling process is that your stakeholders be informed of your vision and mission, and the commitments your organisation makes through its work. Any valid complaint must be based on comparing your organisation’s aims to performance, not on a lack of understanding of your work.

Here are some practical suggestions for your organisation to ensure its complaints process is accessible and effectively address feedback and handle complaints:

Policy

  • Create and document procedures to handle complaints, and ensure your stakeholders are aware of it and that it is accessible to all stakeholder groups, including those who may be marginalised and disadvantaged. The document should include reference to:
    • The value of hearing stakeholders’ voices
    • Definition or criteria of what constitutes a complaint
    • Ensuring a safe, fair and robust complaints mechanism that is accessible in different contexts
    • A review process that ensures confidentiality and impartiality
    • How to ensure internal and external stakeholders are aware of the mechanism
    • The process for response to a concern or complaint, including time frame
    • Who will receive, review and respond to complaints
    • How you will review and learn lessons from the complaints
    • Your commitment to overcoming barriers to access, power imbalances and discrimination.
  • Make the policy available in a contextually appropriate and relevant form to different stakeholder groups. It should be available on your website for those with internet access and could be available in leaflets in local languages in field locations.
  • While all organisations, regardless of size, should do this, the extent of documentation will vary according to your scale and capacity. If yours is a smaller organisation, a simple outline of procedures may suffice. But if yours is a larger organisation, you may document a range of policy, procedures, tools and templates that support your implementation of a complaints handling process.
  • Respond to complaints using a clear process and mechanism that ensures the complaint is acknowledged, listened and responded to, within a reasonable amount of time. 

Procedure

  • During induction, orient new directors, staff and volunteers to the importance of a safe, fair and robust complaints mechanism and its link to ensuring accountability to all stakeholders. This will contribute to an organisational culture that respects the need for a complaints process.
  • Provide them with the relevant policy or guidelines.
  • Ensure they are aware of the complaints mechanism and processes
  • Develop tools and templates to support the consistent and transparent application of the policy and procedures (e.g. templates for reporting and action plans).
  • Nominate people as points of contact in Australia and all field locations. In Australia, this should be a senior staff person and a member of the governing body. Depending on the scale of field operations and the geographic spread within countries, your organisation may need only one or a number of people to act as the key contact within each of your country operations. The contact person may be nominated from within your own in-country staff, partner staff or from the local community.
  • Provide the relevant policy, tools and trainings to the nominated points of contact
  • Ensure that those reviewing a complaint have the necessary resources – such as time and other staff – to address the complaint, including seeking more information and analysing the issue
  • Ensure the independence of the complaint mechanism (from assessment and investigation to resolution of the complaint), thereby contributing to the effectiveness, credibility, and trustworthiness of the process
  • Ensure the mechanism includes a way for complainants to appeal decisions and escalate complaints as far as the governing body.

Methods for making a complaint

  • With input from partners and local communities, determine how complaints can be made through a range of contextually appropriate complaints handling mechanisms. A genuine effort should be made to open channels for complaints in the local communities where the development work is taking place.
  • Consider the effect of power dynamics on a person’s ability to raise concerns and how these can be addressed in different contexts.
  • Methods for lodging complaints include through:
    • Your website
    • Simple printed forms at project sites
    • Locked boxes at project sites to submit feedback safely and confidentially
    • A series of pictorial cards which depict different commitments made by your organisation, possible problems that could arise or possible responses from community members – while this approach may be challenging, it can empower those that may not otherwise participate due to age or literacy. 

Resources

Cross-references to other standards

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