AFAP Complaints Handling Policy

Introduction:

AFAP Action on Poverty believes receiving feedback and responding to complaints from stakeholders is an important part of improving AFAP’s accountability. To achieve this, a well-managed mechanism for handling external complaints is essential. This mechanism works to improve the quality of our work, enhance the trust and confidence of stakeholders, identify areas of work that need to be improved, and ensure AFAP learns from the feedback provided through this process.

AFAP staff and management therefore recognise and welcome the importance of complaints and regard them as an opportunity to rectify issues that have been identified through the people we work with: members, partners, staff, donors and the general public, with the aim to improve in the future.

In the operationalising of this policy all staff, volunteers, stakeholders, partners and any other parties associated with AFAP should be made aware of this policy. The Policy will be made available on AFAP’s website and displayed in a public area in the office of AFAP.

AFAP will make it a priority for all staff, volunteers and partners to be educated on and in the use of the AFAP Complaints policy and procedures.

Policy Aims:

This policy aims to fulfill the following:
• To deal with complaints in a timely manner
• To provide the highest quality service to all our stakeholders and partners
• To use the feedback obtained through the complaints to identify areas of improvement
• To use the opportunity that an issue raises to enhance the relationship with our stakeholders and partners.

In recognising that informal complaints are dealt with in a shorter timeframe, the policy aims:
• To respond with the necessary information and offer an apology if necessary
• To resolve informal complaints in the shortest possible timeframe
• To effectively manage the communications surrounding the issues raised.

 

Definitions:

For the purpose of this Policy, AFAP defines a complaint as:
“an external grievance made against AFAP or against one or more of its employees, consultants, suppliers, partners or anyone else acting on its behalf, where the organisation has allegedly failed to meet a requirement. That commitment might be related to AFAP’s activities, use of resources, mission and values, staff conduct/behaviour or a legal requirement”.
A complaint is not:

• A general query about AFAP’s work
• A request for information
• A contractual dispute
• A request to amend records eg. To correct an address, cancel a donation
• A request to unsubscribe from an AFAP service eg. Campaign newsletter or email

The processes for dealing with the above issues are different and separate to that of AFAP’s internal complaints processes and this Complaints Handling Policy. These are covered in the AFAP Operations Manual and the APP Partner Manual (available on request).

Examples of complaints that are covered in this policy include (but are not limited to):
• A member of the public contacts AFAP to express their concern about the way in which we have conducted a fundraising campaign; or
• A local person or partner raising concerns with us about one of our programs and/or staff behaviour of one of our Australian or in-country partners.
• A government, NGO, partner or other actors brings criminal allegations of fraud, unlawful harassment or child abuse against AFAP and/or its partners in relation to Australian laws and regulations, or local laws and regulations applying to communities supported by AFAP and/or AFAP’s own policies and regulations. In such cases the most stringent standard will apply whether it be the local regulations or AFAP’s policies. For more information please refer to the AFAP Whistleblowing Policy.

A complaint may be made by a person to whom AFAP delivers programs (beneficiaries) or support including a partner, a local organisation with which we work, a national government or other NGOs, as well as members of the Australian public, supporters, donors, the Australian Government, and trusts and foundations.
Anonymous complaints can be made, but our ability to investigate them may be limited due to their anonymity.


Principles:

The following principles will guide AFAP in the handling of complaints and ensure, that as a signatory to the ACFID Code of Conduct, we comply with the standards relating to complaints handling as follows:
• We recognise the importance and value of listening and responding to concerns and complaints ( Section D.6.1 –ACFID Code of Conduct);
• The feedback and 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 (Section D.6.2-ACFID Code of Conduct);
Visibility: Information about the process for making a complaint will be clear and well publicised to members, donors, partners participating in programs and other stakeholders.
Accessibility: The complaints handling process is easily accessible to all stakeholders (via the AFAP website). There is readily accessible information about the process of making and resolving complaints in a range of formats so that no complainants are disadvantaged. AFAP will ensure that flexibility is provided to complainants to ring, write and email complaints and/or to raise concerns in person.
Objectivity: All complaints are 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.
Confidentiality: Confidentiality relating to the complaint will be safeguarded so far as reasonably practicable including the person(s) to whom the complaint is addressed.
Collaborative approach: AFAP takes a collaborative approach to its programs and actively welcomes feedback including complaints and compliments. As such AFAP is committed to resolving all complaints through keeping people informed and where possible coming up with solutions that are satisfactory for all parties.
Responsiveness: All complaints and constructive feedback will be taken seriously and handled as swiftly as practicable. All complaints will be treated courteously and kept updated on the progress of their complaint through the complaints handling process.
Accountability: Accountability for handling complaints and reporting on the actions and decisions of AFAP with respect to complaints handling will be clearly established. All complaints will be recorded through one central point before action is taken.
Continuous improvement: AFAP is committed to the continual improvement of the complaints handling process and the quality of AFAP’s work. This commitment is practically supported by the monitoring of the complaints handling processes; and the auditing/management reviews of the complaints handling process and refining of complaints handling in light of those reviews.
Organisational commitment to this policy: AFAP will ensure that sufficient resources and expertise are provided to handle complaints. Staff will be briefed on the nature and purpose of the policy and senior managers dealing with the complaints will be given training in handling complaints. Complaints will be handled in accordance with AFAP’s policies and procedures and in accordance with Australian laws and regulations. The Executive Director and Chair of the Board, depending upon the nature and level of complaints will be the key people to receive external complaints.

Standards:

The handling of complaints at AFAP will meet the following standards.
• All complaints will be acknowledged within a 3 business days of complaints being received.
• All complainants will receive a copy of the AFAP Complaints Handling Policy.
• Any persons implicated in a complaint will not handle the complaint.
• If a complaint cannot be resolved immediately it will be handled within 15 business days, from receipt of acknowledgement of complaint, by AFAP.
• All complainants will be appointed a point of contact within AFAP that they can communicate with.
• All complainants will receive a response outlining the outcome of their complaint within 20 business days or 30 business days if it needs to be referred to the field. If this deadline cannot be met and the matter is more complex, AFAP will communicate this with the complainant, outlining what further investigation is required to resolve the complaint and the estimated timeframe.
• If necessary and depending on the severity of the complaint it may be brought to the attention of the Australian Federal Police.
• All complaints should be recorded on the AFAP Complaints Handling Form and Report.
• All complaints will be treated respectfully, whether it is felt the complaint is justified or not.

Publicising our Policy:

AFAP is very clear in the value that we place on receiving concerns and complaints in all relevant communications. The home page of the AFAP website has a link to the AFAP Complaint Handling Policy, the Complaint Process and the AFAP Complaint Form. Where literacy is a constraint, we will verbally invite expressions of concern and complaint on a regular basis. AFAP will take care to approach this idea in a culturally appropriate way, recognising that in some cultures people require greater encouragement to make complaints.
AFAP takes special care to facilitate complaints from vulnerable populations including children and marginalised groups.
This policy ensures that making a complaint is easy and accessible to all.

Educating our organisation on our complaint policy and training relevant personnel:

Our Complaint Handling Policy is distributed to all our paid staff, our volunteers, our partners, stakeholders, contracted service providers and all others acting on our behalf. We require all those who may be involved in any way with a complaint to formally signify their commitment to this policy.

Making a Complaint:

To ensure AFAP can give fair and efficient consideration to your complaint as much information as possible should be provided. AFAP Complaint forms are available upon request/ via the website, but for those who chose not to use it please provide:
• Your name
• Address
• Email
• Telephone number
• Details of the complaint
• Date of the complaint occurring
• Current date
• The remedy or outcome you would like to see as a result of your complaint
All complaints, no matter their severity, will need to be formally written down and filed correctly.
Anonymous complaints are accepted, however, they will only be considered if sufficient information is provided.

Confidentiality:

All information provided to AFAP is treated as confidential. 


Sharing of Information:

Sharing information is dependent on the severity of the allegation and only ever entered into after gaining the consent from the complainant.
If you are making a complaint or enquiry on behalf of a stakeholder we will need to contact that stakeholder to verify information provided. The person making the complaint will need to give us permission to speak directly to the primary complaint stakeholder unless there is a safety or security concern related to doing so.
If the complainant disputes an assessment that a complaint should not be investigated, the member of staff handling the complaint will refer it to a more senior staff member for review. If such a dispute is unresolvable AFAP, will refer the complainant to the Code Committee of the Australian Council for International Development (ACFID).


How to make a complaint:

Complaints should be marked “Confidential” and addressed to:
Executive Director
AFAP
PO Box 12
Crows Nest, 1585

Via email: info@afap.org  
Via telephone: 02 99063792
Via fax: 02 9436 4637
You are welcome to visit the AFAP office in person in order to voice your complaint. We are located at:
AFAP Action on Poverty
Suite 102, Level 1, 619 Pacific Hwy
St Leonards
NSW 2065
Australia

If you believe AFAP has breached the ACFID Code of Conduct, you can lodge a complaint on the ACFID website http://www.acfid.asn.au/code-of-conduct/complaints

When a complaint may be declined:

AFAP reserves the right to decline a complaint that they deem too frivolous, vexatious, not made in good faith, misconceived or lacking in substance. AFAP will provide feedback regarding the complaint and why it is not being taken further.

AFAP strives to keep all parties involved during the process of the complaint and works to complete an investigation in a manner specific to the complaint.

AFAP Complaint Process:

The process that AFAP takes after receiving a complaint is as follows:
• Staff member receives a complaint either over the phone; by email or in a letter.
Irrespective of how the complaint is made, the complainant will receive an immediate notification of their complaint being received.
• Staff member then fills in the AFAP Complaints Handling Report outlining appropriate notes of the complaint and the relevant contact details. Staff then send the complainant the AFAP Complaints Form to fill out and return along with the AFAP Complaints Handling Policy. The complainant will also be provided with the name and contact details of their AFAP point of contact. This must occur for all people making a complaint, no matter the severity.
• Upon receiving the completed complaint form, the staff member (taking the complaint) will then approach the most appropriate person (below) for advice and the best way to handle the complaint. The AFAP Complaints Handling Report will remain a “living” document until the complaint has been dealt with.
• Below is a list of people to whom complaints should be directed to (depending on the complaint):
• Finance and Fraud: Finance Director
• Programs and AFAP Management: Executive Director
• Communications and fundraising: Communications, Marketing and Fundraising Manager
• Ethics Committee
• Board
As a general principle any staff member implicated in the complaint will not handle the complaint in any way.
• If the complaint cannot be handled immediately then it will processed within a 5 day period. All complainants will receive a response outlining the outcome of their complaint within 10 business days. If the complaint needs to be referred to the field then complainants will receive a response in 30 business days. If this deadline cannot be met and the matter is more complex, AFAP will communicate this with the complainant, outlining any further investigation required to resolve the complaint and the estimated timeframe.
• Depending on the severity of the complaint, it may be referred to the Australian Federal Police.
• If the complaint is deemed to be addressing a more urgent and confidential issue it may fall under the AFAP Whistleblowing Policy, the AFAP Child Protection Policy and Procedures or the AFAP Fraud Policy and Procedures.
• The complaint will be filed away in AFAP’s HR folder once it has been resolved.

How AFAP will respond to and close a complaint:

The AFAP Executive Director or senior manager delegated by her/him is tasked with making decisions based on complaints that have required investigation (not a minor complaint). As mentioned above decisions on serious complaints may be referred to our Ethics Committee and/or Board.
AFAP will communicate our decision on a complaint as soon as is practical. Our communication will be in writing in the appropriate language, and either through email, post or verbally.
AFAP encourages the complainant to respond and advise as to whether or not they are satisfied with our decision. In our decision we will advise that if a complainant is not satisfied, we will be prepared to consider any additional information they may provide and to review our decision.
In all cases we will advise that the complainant may be referred to the Code Committee of ACFID. We will provide all necessary information for the referral to the Code Committee.

Monitoring and Review of the Policy and Procedure:

AFAP’s Complaints Handling Policy and process must be reviewed every three years by the Board and relevant committees. The review must address the efficiency of the Complaints Handling Process, and any significant revisions must be submitted and endorsed by the Board and Executive Director.
As part of the participatory review and reflection process, AFAP staff will reflect on the learning’s from the complaints and constructive feedback they have received. This will feed into AFAP’s own learning and development practices. AFAP is prepared to change the way in which we operate and improve or undertake further training of staff. Where needed, we will counsel or discipline staff or volunteers.
Where appropriate, we will consult and take advice from ACFID and/or other relevant regulatory/enforcement authorities.
The AFAP Complaints Handling Policy and Procedures will be reviewed by an external body every five years.