Part One Complaints Handling Policy
1.1. Introduction
As an agency of the Bishops’ Conference of England and Wales, and a member of Caritas Internationalis, CSAN’s Vision, Mission and Values promote our belief and commitment to a world where every individual’s rights and dignity are respected. All CSAN staff, trustees, and volunteers (hereafter “staff”) have a signed commitment to our Code of Ethics and staff to the Code of Conduct, which is aligned with Caritas Internationalis. All our associates (consultants and contractors) are expected to act in a way consistent with our values.
We ensure that the people we serve and accompany, communities, partners, volunteers, and staff can communicate any perceived shortcomings, concerns or misconduct through appropriate, safe, accessible and confidential channels. This mechanism enables CSAN to fully close the accountability circle by identifying potential gaps and shortcomings in its delivery and relationship with the people it serves.
CSAN is committed to strengthen its culture of responsibility that prevents these wrongdoings and abuses through works on prevention and training, and to screen better when recruiting staff and volunteers. It is also committed to redress the damage done through false accusations.
CSAN has developed a Complaints Handling Mechanism (CHM) that is user-friendly, safe, and accessible, but is also simple, efficient, and effective and does not create undue burden.
The aim of this policy is to:
- encourage all improper, unethical, or inappropriate behaviour to be identified andchallenged at all levels of the organisation.
- ensure anyone aware of a wrongdoing is supported in total confidence in reportingmatters they suspect may involve anything improper, unethical, or inappropriate.
- provide clear procedures for the reporting of such matters.
- manage all disclosures in a timely, consistent, and professional manner.
- provide assurance that all disclosures will be taken seriously, treated as confidential and managed without fear of retaliation.
1.2. Scope and limitation of the policy
A complaint is an expression and a statement that something is unsatisfactory or unacceptable vis-a- vis the prescribed standard of quality work or is related to the actions taken or lack of action by staff or associates that directly or indirectly cause distress to the affected party.
What complaints can be made
Allegations of breaches in CSAN’s Code of Conduct, Code of Ethics and Children and Vulnerable Adults Safeguarding Policy by staff in relation to financial impropriety, corruption, fraud, sexual exploitation, and abuse, and not ensuring child safeguarding.
Anonymous complaints
We recognize that it can be difficult in some circumstances to speak out openly. Therefore, CSAN will accept and handle anonymous complaints with caution if there is sufficient information to clarify the issues, substantiate claims and investigate allegations properly.
Malicious complaints
When the investigation finds that an accusation was deliberately made falsely and with the aim of causing harm, and if the complainant is on the staff of CSAN, appropriate disciplinary action will be taken including dismissal. Reporting which proves to have been made maliciously will be viewed as a serious disciplinary offense. If the identity of the person against which the malicious accusation was made publicly known, CSAN will take due care to rehabilitate and restore their reputation.
Complaints against member of the clergy or religious congregations
Complaints made against staff that are members of the clergy or religious congregations are dealt with in coordination with the religious order of belonging or the competent Bishop.
What complaints will not be processed
Complaints related to CSAN member organizations staff grievance, performance issues, employment and labour matters, hostile work environment, harassment on the workplace are dealt exclusively by member organizations through appropriate HR policies and procedures.
1.3. Who can make a complaint under this policy
- Anyone who is impacted by activities carried out by CSAN staff. Complaints receivedby CSAN against a member organization will be referred to the member organisationfor follow-up and action.
- CSAN trustees, staff, or volunteers
- CSAN member organizations staff and associates
- Donors, public.
1.4. Reporting obligation
Any staff or associate who has knowledge or suspicion of a potential breach of the CSAN Code of Conduct, Code of Ethics or the Children and Vulnerable Adults Safeguarding Policy has an obligation to report the concerns. Not complying with this rule leads to disciplinary action.
1.5. Key areas and types of complaints
Key areas of possible complaint may include, but are not limited to:
- Behaviour or conduct of CSAN staff and associates
- Financial improprieties such as misuse of funds, fraud or corruption
- Harassment, including sexual exploitation and abuse
- Emotional abuse such as intimidation, humiliation, bullying and mobbing
1.6. Confidentiality
All complaints, whether sensitive or non-sensitive will be handled in a confidential manner. In some cases, it may be necessary to disclose information to third parties. This will be decided on a case-by- case basis and, as far as possible, with the agreement of the complainant. These two types of complaints need to be handled in different ways taking into consideration specific requirements and any risks to parties involved.
Confidentiality is paramount to guarantee safety to complainants, whistle blower, witnesses, and subjects of complaints. Information with regards to complaints and related investigations should only be shared on a need-to-know basis, clearly identified for each case. In case of breach of confidentiality, CSAN may take disciplinary action, except when:
- Disclosure is required by law
- Disclosure is required by management in the best interest of all parties involved
- Disclosure is needed to obtain specific expertise (medical, legal, other)Complaints that indicate a possible criminal offence has been committed should be referred by CSAN to the authorities responsible for investigating such matters.This policy will be sent to all CSAN member organisations and will be published on the website to make the policy and process as accessible as possible.
Part Two: Complaints Handling Procedure
2.1. Receiving a complaint
In the spirit of subsidiarity and solidarity, we hope to resolve any complaints that arise informally. We have a three-stage process for complaints
Stage One
The complaint is raised directly with the member of staff concern with a view to informal resolution.
Stage Two
When Stage One has proved unsuccessful, or inappropriate, the complainant raises their complaint informally with the CEO (or if the complaint is about the CEO, with the Chair of Trustees). The CEO, or Chair, will seek to resolve the complaint informally through mediation.
Stage Three
The formal stage. This should be used when informal communication has not resolved the complaint. Formal complaints should be made in writing or via e-mail for the attention of the CSAN Complaints Handling Officer (CHO) headed Formal Complaint, to
Caritas Social Action Network
55 Westminster Bridge Road
LONDON
SE1 7J
Email: complaints@csan.org.uk.
If a complaint is received by telephone or in person but cannot be dealt with at the time of the conversation, the complainant must be made aware of the CSAN Complaints Handling Policy and Procedure, including the possibility of making an anonymous complaint. The complainant decides whether to formally submit a complaint or not.
Complaints submitted to CSAN will be opened only by the CHO and passed on to the Chair. The complainant will receive notice of receipt within one week.
2.2. Recording the complaint
Complaints will be recorded onto an internal CSAN system to ensure confidentiality. It will have restricted staff access, and will support complaints being logged on receipt, actions tracked, and outcomes recorded.
2.3. Processing the complaint
It is the responsibility of the CHO to preliminarily assess the type and nature of the complaint and recommend the most appropriate course of action to be undertaken. This will be reviewed and approved by the Complaints Handling Committee (CHC). Sensitive complaints will be dealt with as per the procedure set forth in part. 2.4. The roles and responsibilities of CSAN staff will be determined at that stage.
2.4. Sensitive complaints
Sensitive complaints will be immediately referred to the CSAN CEO. With the CHO they will make the first screening and assessment of the complaint and agree the most appropriate course of action. Complaints contemplating allegations of sexual exploitation and abuse will be shared by the CHO only with the CEO, those relating to financial improprieties will also be shared with the Honorary Treasurer. The seriousness of the complaint will determine how the investigation should be conducted. Details will be shared on a strictly need to know basis.
2.5. Investigation process
The CHO will have the primary responsibility to coordinate the investigation. Investigations will be carried out confidentially and only persons that need to know about the complaint will be involved in the process. Complex sensitive complaints will be investigated by external qualified experts. The CHO will identify the most qualified expert investigator based on the nature of the complaint.
Timeframes for completing the investigation vary depending on their complexity. The aim is to conclude it within the shortest reasonable time ideally not exceeding sixty days from receiving the complaint. The final report will be shared with the CHC for review.
The Complaints Handling Committee, on receipt of the report, will determine whether there is a case to answer, considering advice from the CHO. If they conclude there is, the CHC, consisting of three trustees (who will appoint a chair), will convene a panel and invite the complainant to make their case in person. They may be accompanied by a friend, or union representative. The CHC may call any witnesses they deem to be helpful.
Having considered all the evidence, the CHC will then decide on the type of action to be taken at the conclusion of the investigation process.
If the CHC deem there is no case to answer, the CHO will inform the complainant of this in writing.
2.6. Communicating outcomes
The CHO will provide feedback to the complainant and those involved in the complaint as appropriate.
In case of a sensitive complaint, the complainant, unless he or she is at the same time the victim, has no “right” to know the outcome of the investigation. The CHO will provide the complainant with the information whether the complaint has been substantiated or that the complaint is not substantiated. No other information or detail will be disclosed.
*Staff refers to all member organizations staff and board members and those deployed through Caritas Internationalis mandated support mechanisms
*Associates refers to consultants, volunteers, interns, and contractors in service to member organisation.
2.7. Appeals procedure
CSAN wishes that any complaint be resolved in a satisfactory fashion for both the complainant and the organization. If the complainant does not feel satisfied with the outcome s/he can appeal to the CSAN CEO or Chair through the CHO. This can be done in writing, by letter or email, to the following address:
Caritas Social Action Network
55 Westminster Bridge Road
LONDON
SE1 7JB
Email: complaints@csan.org.uk.