Peter Hewitt Care for Africa Foundation Inc (CfA) is committed to providing high-quality humanitarian, development and advocacy programmes and to working in a transparent and accountable manner. In an effort to achieve high quality, we strive to meet and even surpass the expectations of our stakeholders, including our partners, crisis-affected communities, donors, supporters and the public. We realise, however, that there may be occasions when we do not meet the reasonable expectations of all stakeholders at all times. Managing these times is an essential part of being an effective agency.
CfA believes that having a well-managed mechanism for handling external complaints can improve the quality of its work, enhance the trust and confidence of stakeholders, identify areas of work that need to be improved, and ensure that CfA learns from the feedback provided through this process. Therefore the core objective of this policy is to ensure that CfA reacts constructively to complaints from the people it works with; its supporters, donors, the general public, official bodies and its partners.
This Policy solely deals with external complaints, including complaints made by our partners and other stakeholders relating to incidents that affect the complainant directly. Complaints that relate to issues of concern that do not directly affect the complaint are addressed according to our Whistle-Blower policy. Internal issues and grievances made by staff are dealt with according to our Internal Complaints Handling Policy and Procedure.
This policy covers complaints, concerns and/or feedback in relation to the following:
Breaches of the CfA Prevention of Sexual Exploitation Abuse and Harassment Policy (PSEAH): all staff, contractors representatives, volunteers or anyone else representing CfA must sign and abide by the PSEAH Policy and can be held to account for breaches of the Policy, which outlines CfA’s zero tolerance approach to sexual exploitation and abuse, corruption, fraud, or other abuses of power.
Breaches of the CfA Child and Vulnerable Person Policy: all CfA staff, volunteers, contractors, representatives, volunteers or anyone else representing CfA including through visiting an CfA partner or project must sign and abide by the Policy and can be held to account for breaches of the Policy. CfA also insists that all of our overseas programs partners maintain an equivalent zero tolerance approach to child abuse, and that their staff are similarly accountable.
Breaches of CfA’s Ethics and Professional Conduct Policy, which outlines clear standards for programs, partnerships and good organisational practice. CfA also has a range of other policies which create clear standards for our humanitarian and development work in Australia and overseas, and we can also be held to account for failing to uphold these standards in our programs, advocacy and other work.
Complaints may also be made if there is concern CfA or one of its staff have failed to deliver according to its quality and accountability standards as outlined in its various policies (see: www.careforafrica.org.au)
Types of Complaints Accepted/Not Accepted under this Relevant Complaints Mechanism complaints policy/mechanism:
Complaints from any CfA stakeholder about a CfA member, board member, volunteer or representative for breaching our Codes of Conduct, Codes of Good Practice or our other humanitarian and development policies, and where the complainant is directed affected
Please use the complaints form in Annex 1 and refer to Section 8 of this Policy. CfA’s general Code of Conduct, Child and Vulnerable Person Policy, Ethics and Professional Conduct policies are available on our website: www.careforafrica.org.au
Use the relevant complaints mechanism as above.
Complaints about serious misconduct in relation to our Codes of Conduct, policies, laws and external relations, where the concern does not directly affect the complainant.
In this instance please refer to our Whistle-Blower policy available on our website:
Complaints from CfA’s ‘supporters’ in Australia of any nature (except the areas above)
Please see the description of how supporters can lodge a complaint on the website:
CfA staff complaints against other staff
CfA’s Complaints Handling Procedure
CfA’s staff complaints about another organisation or one or more of its employees
Such complaints should be raised with CfA management and the staff member should be supported through the process of raising and addressing the complaint
Complaints against one or more employees of a third party organisation (eg not CfA or one of its partners)
Such complaints must be addressed to the management or governing board of the organisation
Offensive, malicious or abusive complaints, including complaints sent to as part of a bulk email to multiple organisations
CfA will not respond to these complaints
Complaints relating to ongoing legal proceedings
CfA will not hear these complaints until the case is resolved.
If an agency, group, or individual submits a complaint – hereinafter referred to as “the complainant” – that is not within the scope of this policy, s/he will be informed accordingly.
Our stakeholders have a right to raise any reasonable concern and provide feedback without any risks of reprisal or unfair treatment, including harassment or victimisation, or of losing their employment, entitlements or funding. All complaints are taken seriously, and we appreciate when people take the time to help us do our job better.
We also recognise that as a member of ACT Alliance we have a responsibility to ensure the safety, dignity and rights of crisis-affected populations and communities in all of our humanitarian and development programs. We therefore encourage all partners to explore and develop safe and effective complaints mechanisms that are accessible to all women, men, boys and girls with whom we work. Communities should be informed of their rights and entitlements and about how to make a complaint.
CfA defines a complaint as a formal expression of dissatisfaction or discontent, and/or misconduct about someone or something. We distinguish the term ‘complaint’ from ‘feedback’. Feedback is any positive or negative informal statement of opinion about someone or something – an opinion shared for information but without the intention of lodging a formal complaint. A complaint requires a response, but feedback may not.
CfA recognises the importance and value of listening and responding to concerns and complaints as set out in the ACFID Code of Conduct in ensuring that feedback and the complaints handling process is as effective, safe, confidential and accessible to all stakeholders as possible, irrespective of their gender, status or background and without prejudice to their future participation.2 It will do this by following these guiding principles:
Confidentiality: CfA will maintain the highest level of confidentiality regarding details shared in receiving and investigating a complaint, including the complainants name and personal details. Information will only be shared as necessary to investigating and reporting the complaint. Information will be stored in a locked file.
Visibility: Information about the process for making a complaint will be clear and well publicised to supporters, rights holders participating in programs, and other stakeholders. We make clear the value we place on receiving concerns and complaints in all relevant communications. Our website ’contact us’ page has a prominent tab with the word complaint linking to this policy and information on how to make a complaint. Our Partnership Agreements include a standard complaints report which is discussed with partners and a contextually appropriate mechanism agreed.
Accessibility: The complaints handling process is easily accessible to all stakeholders. CfA will ensure that flexibility is provided to complainants to ring, write and e-mail complaints and/or to raise concerns in person. Where literacy is a constraint we will orally invite expressions of concern and complaint on a regular basis. We will take care to give this invitation in a way that is culturally appropriate recognising that in some cultures people require greater encouragement to make a complaint. We will take special care to facilitate complaints from vulnerable populations including children and marginalised groups. If appropriate we will make use of pictorial means of communication. We will do our very best to assist a complainant to put their complaint in writing or to write it down ourselves as faithfully as we can. All relevant communication (including our website, annual report, partnership agreements, and staff policies) explain how to make a complaint including:
Objectivity: All complaints will be addressed in a fair and equitable, objective and unbiased manner throughout the complaints handling process. Issues of conflict of interest will be identified to ensure objectivity.
Responsiveness: All complaints and constructive feedback will be taken seriously and handled as swiftly as practicable. All complaints will be responded to immediately on receipt, and an investigation plan established. Whilst we aim to confirm all investigations within one month of notification, timeframes must remain flexible according to the investigation process. All complainants will be treated courteously and kept updated on the progress of their complaint through the complaints-handling process. Further, in line with the Core Humanitarian Standards only trained staff should investigate allegations of sexual exploitation and abuse.
Accountability: Accountability for handling complaints and reporting on the actions and decisions of CfA with respect to complaints handling will be clearly established. All complaints will be handled using the agreed complaints procedure. All staff will receive training on complaints handling and investigations. We will encourage partners to use the ACT Guidelines on Complaints Handling and Investigations to encourage them to establish a complaints mechanism for their organisation and their programs.
Continuous improvement: CfA is committed to the continual improvement of the complaints handling process and the quality of its work. This commitment is practically supported by the analysis and reporting of complaints trends, monitoring of complaints handling processes, auditing/management reviews of the complaints handling process, and refining of complaints handling in light of those reviews.
Organisational commitment to this policy: CfA will ensure that sufficient resources and expertise are provided to handle complaints. Our Complaints Policy will be distributed to all our Commissioners, paid staff, office-based volunteers, partners, consultants, contracted service providers and all others acting on our behalf. Commissioners, staff, volunteers, consultants and partners will be required to formally signify their commitment to this policy. CfA will run induction programs for all relevant personnel. Personnel directly involved in complaint handling are to be fully trained in all aspects of this policy and its implementation. We take special care to train our field facing personnel to encourage, receive and handle complaints taking account of language issues and cultural sensitivities.
Creating a safe environment: CfA seeks to provide a safe environment through which to voice a concern, without fear of reprisal or unfair treatment. We are committed to ensuring that all stakeholders should be able to raise reasonable concerns:
Without any risk of losing their employment or entitlements or suffering any form of retribution in the workplace or outside;
Knowing that harassment or victimisation will not arise from raising a genuine concern – and if it does, to know that we will deal with it as a disciplinary action under the appropriate procedure;
Knowing that their safety is our highest priority; and
Knowing that sensitive complaints will be addressed in a confidential manner.
Operational and sensitive complaints
This policy is designed to handle both operational complaints and sensitive complaints.
Operational Complaints: this may include CfA partners disagreeing over areas of operation, funding sources, priorities, differences of interest between the public relations interests of the funding partners, conflict over advocacy approaches, the capacities of implementing partners, or noncompliance with CfA programmatic principles, among others. Complaints may also relate to CfA, e.g. regarding decisions on funding appeals, strategy implementation, management issues, etc. Complaints may also relate to marketing, fundraising or campaigns activities.
Sensitive Complaints: Allegations of harassment or bullying, of sexual exploitation and abuse, fraud and corruption or other gross misconduct are considered by CfA as “sensitive” complaints. The policy supports the confidential handling of information related to sensitive complaints. It also ensures that sensitive complaints are addressed by senior management and that timely and appropriate support and redress is provided to any complainant who has suffered bullying, sexual exploitation, abuse or harassment.
As a principle, CfA does not accept anonymous complaints. We recognise, however, that at times people who have genuine concerns may not be able to speak out because of special circumstances and may wish to lodge a complaint with a staff person without revealing their identity to a wider audience. In this instance, we will accept the complaint and will endeavor through best efforts to protect the complainants identity through the course of the investigation and required reporting.
We operate under the assumption that all complaints are made in good faith and are not motivated by intent for personal gain, personal interest or a grudge. However, should a subsequent investigation reveal a complaint to be malicious – an accusation that the complainant knows to be false – any investigation underway must be stopped immediately and the Subject of Complaint (SoC) cleared. Complaints lodged for genuine reasons that are subsequently considered to be unfounded shall not be treated as malicious. If a malicious complaint is made by an CfA employee, disciplinary measures must be taken.
When to complain
If you wish to make a complaint, lodge your complaint as soon as possible after you become aware of your concern. CfA will not accept a complaint more than six months after the alleged incident, except in exceptional circumstances and then only in cases of allegations of abuse, exploitation, fraud, gross misconduct or malpractice.
How to complain
CfA invites its stakeholders – partners, supporters, beneficiaries or others – to contact CfA through one of the following means (noting that information will not be shared with multiple contact points unless necessary to dissolve the concern):
In Person: by speaking to an CfA staff member
By Email: email@example.com
By Letter: please use the Complaints Form (see Annex 1.)
If a complainant finds the outcome of a complaint be unsatisfactory, and it relates to a breach of the ACFID Code of Conduct (of which Care for Africa is a Signatory), then a complaint may also be lodged with the ACFID Code of Conduct Committee via the ACFID website https://acfid.asn.au/content/how-make-complaint
Minimum information required
When lodging your complaint, please include your name, address and contact telephone number in your email or letter so that we can contact you if we require further information. Where possible, let us know how you would like your complaint to be resolved.
Obligation to disclose to relevant donors and authorities.
All CfA staff and partners are required to report allegations, concerns or suspicions of breaches related to abuse (including but not limited to child and or sexual abuse), exploitation and fraud and corruption to relevant donors and authorities. Proven deliberate non-disclosure will lead to disciplinary action. Please see the CfA Code of Conduct for CfA employee commitments. Requirements for Partners are outlined in our Partnership and Grant Agreements.
On a continuing basis we will monitor the effectiveness of our complaints handling and make improvements as appropriate. We will:
Maintain secure registers and further data collection on complaints for the purpose of identifying trends for the purpose of enhancing information management and service provided;
Keep abreast of best practices (both locally and overseas) regarding complaint handling;
Foster a partnership/consumer/client-focused approach;
Undertake specific training and retraining of staff to foster better complaint handling practices;
Encourage innovation in complaint handling development; and
Recognise and reward exemplary complaint handling behaviour.
In addition to the reviews of our complaint handling, we will monitor how effectively we are publicising our complaints policy on a continuing basis and make necessary improvements in its communication.
1 – ‘Abuse of power’ includes any abusive behaviour (physical, psychological, sexual or emotional) by a person in a position of authority and trust against someone in a position of vulnerability and/or dependency.
2- ACFID Code of Conduct, Section D.6.2.
3- Section D.6.1 –ACFID Code of Conduct
4- Core Humanitarian Standards, point 5, page 19
CFA-P26.V2 Complaints Policy Effective Date: 20 September 2020
Approved By: Board of Management.
Controlled Document — Printed Versions are not controlled. CFA