COMPLAINTS POLICY
Policy Statement
Global Talent Pathway is committed to providing high-quality humanitarian, development, and advocacy programmes and to working in a transparent and accountable manner. To achieve high quality, we strive to meet and even surpass the expectations of our stakeholders, including our partners, communities affected by forced displacement, donors, supporters, and the public. We realise, however, that there may be occasions when we do not always meet the reasonable expectations of all stakeholders. Managing these times is an essential part of being an effective agency. The development of the complaints policy is the first step in Global Talent Pathway managing this process.
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 it when people take the time to help us do our job better by raising their concerns with us.
We also recognise that we have a responsibility to ensure the safety, dignity and rights of crisis-affected populations and communities in all our humanitarian and development programs. We therefore encourage all our in-country partners to explore and develop safe and effective complaints mechanisms that are accessible to all persons with whom we work. Communities should be informed of their rights and entitlements and about how to make a complaint. Our in-country and implementing Partners are encouraged to access resources on the Core Humanitarian Standards (CHS) Complaints and Investigations Guidelines 20152 to assist them to establish a complaints mechanism for their organisation and their programmes.
Objective
The purpose of this policy is to recognize, promote and protect stakeholder rights, including the right to raise a concern, give feedback and/or complain; whilst providing clear policy guidance for responding to and resolving complaints. Global Talent Pathway 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 Global Talent Pathway learns from the feedback provided through this process. Therefore, the core objective of this policy is to ensure that Global Talent Pathway reacts constructively to complaints from the people it works with, its supporters, donors, the general public, official bodies, and its partners.
Principles and Standards
Global Talent Pathway 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, age, ability, status, background, or other elements of their identify and without prejudice to their future participation. It will do this by following these guiding principles:
Confidentiality: Global Talent Pathway 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 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. Global Talent Pathway will ensure that flexibility is provided to complainants to phone, write and e-mail complaints and/or to raise concerns in person. Global Talent Pathway’s stakeholders have varying levels of confidence in written English which is our main mode of communication. Where we can, we will provide information about our complaints and feedback policy and procedures verbally, allowing us to check shared understanding. We will take care to give this information 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:
Where or to whom complaints can be made
Information to be provided by the complainant.
The process for handling complaints, including confidentiality and protection for the complainant.
Time periods associated with various stages in the process.
The complainants’ options for remedy, including external means.
How the complainant can obtain feedback on the status of the complaint.
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 and managed 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 conclude 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 personnel should investigate allegations of sexual exploitation and abuse.
Accountability: All complaints will be handled using the agreed complaints procedure. All staff will receive training on the complaints policy and the handling of complaints We will encourage in-country partners to use the Core Humanitarian Standards on Complaints Handling and Investigations to encourage them to establish a complaints mechanism for their organisation and their programs.
Continuous improvement: Global Talent Pathway 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: Global Talent Pathway will ensure that sufficient resources and expertise are provided to handle complaints, including using an external complaints and whistleblowing service to support the lodging of complaints. Our Complaints Policy will be accessible on the website and distributed to our Board, paid staff, office-based volunteers, partners, consultants, contracted service providers and all others acting on our behalf. Global Talent Pathway 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: Global Talent Pathway 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.
Knowing that sensitive complaints will be addressed in a confidential manner; and
Ensuring that survivors/victims of safeguarding breaches are at the heart of our safeguarding prevention and response and provided with sufficient resources including counselling, health and legal services and information.
Scope
This Policy solely deals with external complaints. Internal issues and grievances made by staff are dealt with according to our Staff Grievance Handling Policy.
If a current of former Global Talent Pathway employee, volunteer, Board Director, contractor, consultant, or service provider wishes to raise an issue of wrongdoing or malpractice within Global Talent Pathway, this should be dealt with according to the Whistleblowing Policy.
This policy covers complaints, concerns and/or feedback in relation to the following:
Breaches of the Global Talent Pathway Code of Conduct: all staff, contractors’ representatives, volunteers, or anyone else representing Global Talent Pathway must sign and abide by the Code of Conduct and can be held to account for breaches of the Code, which outlines Global Talent Pathway’s zero tolerance approach to sexual exploitation and abuse, corruption, fraud, or other abuses of power.
Breaches of the Global Talent Pathway Child-Safe Code of Conduct: all Global Talent Pathway staff, volunteers, consultants, representatives, volunteers, or anyone else representing Global Talent Pathway including through visiting a Global Talent Pathway partner or project must abide by the Code of Conduct and can be held to account for breaches of the Code. Global Talent Pathway also insists that all our overseas program’s partners maintain an equivalent zero tolerance approach to child abuse, and that their staff are similarly accountable.
Breaches of Global Talent Pathway’s Code of Good Practice, which outlines clear standards for programs, partnerships, and good organisational practice. Global Talent Pathway 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.
The Complaints Policy is to be enacted alongside the above Global Talent Pathway Codes and obligations confirmed in additional Global Talent Pathway policies including:
Code of Conduct
Child Safeguarding Policy
Whistle-blower Policy
Prevention of Sexual Exploitation, Abuse and Harassment Policy
Complaints may also be made if there is concern Global Talent Pathway or one of its staff have failed to deliver according to its quality and accountability standards as outlined in its various policies (see: www.globaltalentpathway.org)
Types of Complaints Accepted/Not Accepted under this complaint’s policy/mechanism & Relevant Complaints Mechanism
Complaints from any Global Talent Pathway stakeholder about a Global Talent Pathway staff member, Board Director, volunteer, or representative for breaching one of our two Codes of Conduct, which are mandatory Global Talent Pathway standards for individual behaviour.
For concerns related to Child Safeguarding, an applicable incident form is available within the Child Safeguarding policy on our website. Global Talent Pathway’s general Code of Conduct and Global Talent Pathway’s Child Safeguarding Code of Conduct are available on our website: www.globaltalentpathway.org
Complaints that Global Talent Pathway, as an organisation, has not lived up to the standards it has adopted under its Code of Good Practice or its other humanitarian and development policies.
Please refer to Section 6 of this Policy for the different ways you may lodge a complaint. To access Global Talent Pathway’s humanitarian and development policies, see our website: www.globaltalentpathway.org
Anonymous complaints. If you have genuine concern about revealing your identity, please confirm this when you contact us.
Feedback and complaints from Global Talent Pathway ‘supporters’ in Australia of any nature (except the areas above).
Please see the description of how supporters can lodge feedback or a complaint on the website.
Global Talent Pathway staff complaints against other staff.
These complaints should use Global Talent Pathway’s Grievance Policy.
Global Talent Pathway staff complaints about another organisation or one or more of its employees.
Such complaints should be raised with Global Talent Pathway 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 (e.g. not Global Talent Pathway or one of its partners and not complaints raised by Global Talent Pathway staff, volunteers, or contractors).
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.
Global Talent Pathway will not respond to these complaints.
Complaints relating to ongoing legal proceedings. Global Talent Pathway will not hear these complaints until the case is resolved, unless the complaint brings additional and relevant evidence forward
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.
Definitions
Feedback: 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.
Complaints: Global Talent Pathway defines a complaint as a formal expression of dissatisfaction or discontent, and/or misconduct about someone or something.
Operational Complaints: this may include Global Talent Pathway 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 non-compliance with Global Talent Pathway programmatic principles, among others. Complaints may also relate to Global Talent Pathway, e.g. regarding decisions on funding appeals, strategy implementation, management issues, 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 Global Talent Pathway 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.
Anonymous complaints: 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 endeavour through best efforts to protect the complainant’s identity through the investigation and required reporting.
Malicious and Vexatious complaints: 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 or vexatious – 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 considered unfounded shall not be treated as malicious. If a malicious complaint is made by an Global Talent Pathway employee, disciplinary measures must be taken.
Notifying Global Talent Pathway of a Complaint
When to complain
If you wish to make a complaint, lodge your complaint as soon as possible after you become aware of the concern. Global Talent Pathway 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
Global Talent Pathway invites its stakeholders – partners, supporters, beneficiaries, or others - to contact Global Talent Pathway through one of the following means (noting that information will not be shared with multiple contact points unless necessary to dissolve the concern):
Direct to Global Talent Pathway
In Person: by speaking to a Global Talent Pathway staff member.
By Email: complaints@globaltalentpathway.org or by emailing your Global Talent Pathway focal point.
By phone: contact your Global Talent Pathway contact, or the Head of Operations on: 1300 161 630.
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.
All Global Talent Pathway staff, volunteers, partners, consultants, and contractors are required to report allegations, concerns or suspicions of breaches related to abuse (including but not limited to child abuse), exploitation and fraud and corruption to relevant donors and authorities. Proven deliberate non-disclosure will lead to disciplinary action.
Please see the Global Talent Pathway Code of Conduct for Global Talent Pathway employee commitments.
Managing Complaints
All complaints will be taken seriously. Global Talent Pathway aims to respond to the complainant within five working days and investigate the complaint within one month of receipt of the complaint. Where an investigation requires more time the Global Talent Pathway will revise the timeframe and will, where possible, inform the parties who have made the complaint.
Depending on the nature of the complaint, it may be investigated and dealt with internally or externally. Global Talent Pathway may be required to seek further information from the person making the complaint. If the complaint cannot be resolved within Global Talent Pathway, it may be referred to external processes such as mediation, or statutory complaints handling bodies.
Global Talent Pathway commits to prioritising the safety and wellbeing of survivor/victims of safeguarding breeches and providing appropriate assistance and support.
Where possible, the person who has made the complaint will be advised in writing of the outcome of the investigation into this and of the proposed strategy for dealing with the complaint.
Global Talent Pathway will keep a confidential register of complaints with the ability to de-identify complaints at the victim/survivor's request.
Global Talent Pathway will ensure independence in managing the complaint. If a complaint has been made about a complaint focal point, the Head of Operations or CEO, they will be excluded from the investigation team.
Review cycle
Continuingly, we will monitor the effectiveness of our complaints handling and make improvements as appropriate. We will:
Maintain registers and further data collection on complaints to identify trends and enhance 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 https://acfid.asn.au/code-of-conduct
Recognise and reward exemplary complaint handling behaviour.
We will conduct an internal review of the effectiveness of our complaint handling every year and will commission an independent review of the effectiveness of our complaint handling every five years. In addition to the general 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.
Annex 1: Complaints Form
This form could be completed (or adapted) by or for the person wishing to lodge a complaint. If the person making a complaint would rather use a different format, that is fine too.
Please ensure that enough information is provided to enable Global Talent Pathway to contact you to discuss your concerns. If you have genuine concern about revealing your identity, please confirm this. Global Talent Pathway aims to ensure that all complaints are handled fairly, timely and appropriately. Information shared will be kept confidential unless we need to share it to resolve a complaint, in which case we will discuss this with the complainant first. We will also do our best to support the complainant through the process of resolving the complaint.
A: General Information
Name of complainant:
Complainant Organisation (if any):
Complainant Location (city, country):
Male/Female/prefer not to say:
Age:
Address:
Tel:
Email:
Name of the person and/or organisation you wish to lodge a complaint against (if known):
Date of incident or concern:
Time of incident or concern:
Place of incident:
Date of reporting:
Time of reporting:
B: Please list any concerns you have for the safety of children or others, including yourself, in making this report. Please confirm if these concerns require immediate action.
C: Brief description of the incident or concern
D: Name of witnesses (if any/ and if relevant). Include the names of witnesses and where they can be contacted, if known.
E: State what kind of response you expect from Global Talent Pathway and how you wish to see the matter resolved:
(Name) Signature
Please send by email, addressed to: The Global Talent Pathway Complaints Officer: complaints@globaltalentpathway.org
Annex 2: Resource and Reference List
Core Humanitarian Standards - https://www.chsalliance.org/get-support/resource/guidelines-for-investigations/
ACFID - https://acfid.asn.au/code-of-conduct
ACNC - https://www.acnc.gov.au/for-charities/manage-your-charity/governance-hub/governance-standards Australian Consumer Law https://consumer.gov.au/sites/consumer/files/2017/12/guide_acl_fundraising-1.pdf
Annex 3: Policy Objectives and Indicators to Measure Progress towards Objectives.
OBJECTIVES
To ensure that Global Talent Pathway is accountable to its standards and constructively manages complaints from its stakeholders.
INDICATORS
Global Talent Pathway’s organisational standards and the behaviour standards expected of its staff and others are clearly communicated to its stakeholders.
Global Talent Pathway’s maintains a safe and accessible complaints mechanism.
Relevant staff and stakeholders are aware of the complaints policy.
All complaints are managed according to best practice principles.