Professional Documents
Culture Documents
Complaint Mechanisms: For Non-Governmental Organizations
Complaint Mechanisms: For Non-Governmental Organizations
A PRACTITIONER'S GUIDE
11 | 1
The Community of Cooperation of Bread for all & its partner organizations
September 2017
2|3
6|7
Acknowledgements
We would like to thank the Community of Cooperation of Bread
for all & its partner organizations for making this Practitioner’s
Guide possible. Special thanks to the organizations that have
played a pioneering role in having established, maintained and
continuously improved their complaint mechanisms. Many of
them helped us, through interviews, to get detailed insights into
the functioning and reality of their mechanisms. Their stories
are the key element in making this A Practitioner’s Guide ins-
tead of merely a theoretical study. Thank you also to any other
organization which offered valuable additional insights through
interviews.
A special thank you to every victim or witness of misconduct
or abuse within or by an organisation who shared their stories
in informal conversations. They took the time to explain how a
complaint mechanism would have helped in their personal cir-
cumstances; this allowed for the Guide to be adapted to real
needs.
Abbreviations and Acronyms
A G k E T I Arbeitsgruppe Kirchliche Entwicklungszusammenarbeit
von Transparency International Deutschland e.V.
CM Complaint Mechanism
D C A DanChurchAid
FP Focal Point
TI Transparency International
Contents
Introduction 3
Executive Summary 4
Acknowledgements 8
a. What Is a Complaint 16
b. Types of Complaints 17
b. T
ypes of Receivers: Internal
Complaints Officer vs External Ombudsperson 24
b. Resources 33
a. Create Trust 36
5. Communication 41
a. Internal Communication 42
b. External Communication 43
10 | 11
IV. Investigation 52
a. External Audit 54
a. Social audit 56
V. Decisions, Sanctions and Appeal 57
1. Decision Making 57
2. Sanctions 57
3. Appeal 58
4. Written Documentation 58
a. Systematic Analysis 59
b. A
dapting Existing - and Introducing New - Systems
and Guidelines 61
Conclusion 65
Annex 66
Interviews 74
The Increasing Demand for NGO force the Code of Conduct or anti-corruption
Accountability clauses and to discover structural malfunctions
Throughout recent decades, NGOs have de- of an organization. The mechanism is part of
veloped an increasingly important role in so- a larger set of measures to achieve more ac-
cial and environmental service provision and countability and transparency, and it improves
advocacy worldwide in a wide range of do- the overall credibility of the organization in the
mains. Traditionally, NGOs are not well regu- long term. Furthermore, an improved reputati-
lated in many countries, leaving them more at on increases trust and may have a positive im-
liberty and less controlled in their operations. pact on funding.
In light of the lack of direct legal and public The purpose of this paper is to help organiza-
oversight and accountability, severe discrepan- tions and institutions interested in establishing
cies, inconsistencies and even scandals have a complaint mechanism to understand how
occurred involving NGO management, finances best to develop and run it to make it success-
and operations. Examples include excessive sa- ful. The research and interviews have focused
laries of senior staff, high administrative costs, on non-governmental and faith-based organiz-
misappropriation of funding, corruption and a ations active in international development co-
general lack of transparency, e.g. due to a lack operation, which are the principal target group
of reporting about activities. To avoid scandals of this Practitioner’s Guide. It is both for small
and to become more transparent and accounta- grassroots organizations as well as large interna-
ble, many NGOs are increasingly striving to put tional ones, active in developing and developed
systems and mechanisms in place that improve countries alike. The best practices described in
their governance, integrity and transparency. this manual, however, can also be adapted to
Measures are diverse, ranging from new poli- the needs of other types of institutions, organi-
cies on gifts, travelling and hospitality to imple- zations and companies who want to establish a
menting a code of conduct or an anti-corrupti- complaint mechanism. The manual is not about
on policy. However, it is not sufficient simply to presenting a one-size-fits-all approach. Instead
adopt and improve new policies, systems and it provides various practitioners’ perspectives
procedures. It is necessary to find a way to en- of existing complaint mechanisms in order to
sure commitment to them and to enforce them show best practices, challenges and solutions,
in case of non-compliance. from the design to the implementation and im-
For an organization committed to maintaining provement of such a mechanism.
high standards of ethical and legal conduct The first part is designed to create a common
within the organization and in all its projects, understanding of the concept by defining what
programs and business relations, a complaint a complaint mechanism is, for whom it is me-
12 | 13
mechanism is an important tool. It allows all ant and why it is important to have one. Subse-
stakeholders - employees, project participants, quently, the different types of complaint mecha-
donors and so forth - to report abuse of power, nisms are outlined as well as the most important
fraud, corruption and sexual exploitation, for factors to make it a success.
example, as well as problems regarding the or- The second part illustrates the factors that go
ganization’s functionality. Thus, the complaint into establishing an effective complaint mecha-
mechanism is an important instrument to en- nism. We elucidate the best practices by analy-
zing challenges other organizations have faced nisms function and how complaints are recei-
and concluding with the lessons learned th- ved and handled. Throughout this process, the
rough tackling the problems. Emphasis is thus organizations with the most effective complaint
put on case studies and practical experiences. mechanisms and detailed documentation about
Subsequently, we present and refer to theoreti- them were identified.
cal considerations underlying the whole process As a second step, interviews were conducted
from design to implementation. with five NGOs: DanChurchAid, Danish Re-
The third part describes the steps for receiving fugee Council, Diakonia, Kindermissionswerk
and investigating complaints, making decisions “Die Sternsinger” and Lutheran World Federati-
and introducing lessons learned into project on. This is not an exhaustive list of NGOs with
improvement as well as evaluating, monito- complaint mechanisms, but rather those that
ring and developing the complaint mechanism. were available for interviews and that stand
These topics are explained following the same out both for having experience with establis-
structure as that of the previous parts. The last hing and maintaining a complaint mechanism
section presents the Guide’s conclusions. and having sufficient documentation that is pu-
blicly accessible. Their experience provided deep
Research Methodology of the Guide insights into the practical challenges encounte-
As a first step in preparing A Practitioner’s Guide, red in designing, implementing and improving
desk research about complaint mechanisms and complaint mechanisms and form the basis of this
whistle-blower protection in a range of domains Guide. Additionally, the task force of Transparen-
was conducted, examining the private, public cy International for Ecclesiastical Development
as well as civil society sectors. The desk rese- Cooperation and the campaign Report the Abuse
arch revealed that many larger companies and were interviewed for additional input. The ana-
banks use complaint mechanisms, partly due lysis of the interviews of these organizations led
to legal pressure. In the public sector in many to the formulation of the best practices and re-
developed countries, complaint mechanisms are commendations on how to deal with challenges
also becoming increasingly common. With a clo- that are presented in detail in this Practitioner’s
ser look at the civil society sector, on the other Guide, complemented by the documents of the
hand – specifically NGOs – another image emer- organizations. Throughout the text, Recommen-
ges: only a very limited number of organizations ded Sources boxes allow the reader to go more
have established complaint mechanisms. into depth on the different aspects of establishing
Following the wider literature review, an in- and maintaining a complaint mechanism.
depth, qualitative analysis of the documents of As an additional step throughout the course of
approximately 20 NGOs was conducted based the research, many informal discussions were
on their experience with complaint mechanis- held with victims and witnesses of abuse, cor-
ms. Among those documents were, for example, ruption or unfair treatment by organizations and
complaint mechanism policies and procedures, institutions who did not have the chance to re-
Codes of Conduct, anti-corruption-clauses, com- port their cases at the time of the incident. Their
plementary guidelines and complaint reports. feedback helped to adapt A Practitioner’s Gui-
The documents were compared to uncover si- de, taking into consideration the needs of those
milarities and differences in the way the mecha- whom a complaint mechanism intends to serve.
I. Complaint Mechanism –
Definition and Scope
1. What Is a Complaint Mechanism? person or anonymously by calling a complaint
In non-governmental organisations, various hotline, through a complaint email, by approa-
situations occur out of which complaints can ching an ombudsperson, by voicing the comp-
emerge: Project mismanagement, corruption, laint in a public meeting etc. The complaint is
misuse of funds, nepotism as well as psycho- then processed by (a) Complaint Officer(s) in a
logical, physical and sexual abuse. These inci- formalized manner.
dents leave victims or witnesses of wrongdoing Complaint mechanisms are used in various
with the question of how to voice their com- ways. In the context of organisations and ins-
plaints and organisations with the question of titutions, some only target severe cases of mis-
how to receive and handle them. A complaint conduct, such as corruption or misappropriati-
mechanism offers a solution by giving victims on of funds. Others include suggestions on how
and witnesses a chance to report a case through operations should be improved, e.g. by partici-
a formal and safe channel and for organisations pants in projects or by employees. Due to the
to deal with complaints in a formalized manner. variety of cases dealt with and the different na-
The Humanitarian Accountability Partnership ture of organisations, mechanisms differ from
(HAP)2 defines a complaint mechanism as fol- organisation to organisation.
lows: “An effective complaint mechanism promo- Both in the literature as well as in practice, a
tes accountability as communities and employees wide range of terminology is used to describe a
are better able to report abuse and access additio- complaint mechanism: Terms include “feedback
nal protection through deterrence.”3 A complaint mechanism”, “whistle-blowing program”4, “com-
mechanism can function through different ways plaints and response mechanism”, “reporting me-
and channels: A complaint by (a) victim(s) or chanism”, etc. It is advisable to keep the name
(a) witness(es) of misconduct can be made in of the complaint mechanism as neutral as pos-
sible, e.g. Reporting Mechanism.
14 | 15
nism. Including Incident Reporting for Employees, p. laints Mechanism Policy and Procedure, 2010, p.
9
Diakonia (2012): Complaints and Response Mecha-
7, https://www.diakonia.se/globalassets/blocks-ihl- 5-6, available at https://www.lutheranworld.org/
nism. Including Incident Reporting for Employees, p.
site/ihl-file-list/call-for-proposal-attachments-2016/ sites/default/files/DWS-Complaints_Mechanism_
16, https://www.diakonia.se/globalassets/blocks-ihl-
diakonia-complaints-response-mechanism.pdf Policy_0.pdf (Retrieved 24 April 2016) or Diakonia,
site/ihl-file-list/call-for-proposal-attachments-2016/
(Retrieved 15/07/15) Policy for Diakonia’s Complaints and Response
diakonia-complaints-response-mechanism.pdf
Ibid., p.8, 11-12 Mechanism, p. 11-12 (Retrieved 19 October 2015)
6
(Retrieved 19/1015)
Ibid., p.8 Diakonia, Policy for Diakonia’s Complaints and
12
7 10
Some organisations still opt to call it a «feedback
Response Mechanism, p. 11 (Retrieved 19 October
mechanism» as the term «complaint» can be percei-
Lutheran World Federation (2010): Complaints Me-
8
2015)
ved as too strong but will include complaints and
chanism. Policy and Procedures, p. 7-8, https://www.
give a response to cases. (see Annex 3: Case Study Ibid, p.12.
13
lutheranworld.org/sites/default/files/DWS-Comp-
Child in Need Institute)
b. Types of Complaints ploitation or abuse of persons (chil-
To define more specifically which ty- dren or adults)13
pes of complaints can be made or cases Examples:
reported through a complaint mecha- Corruption, Fraud & financial issues
nism, most organizations11 distinguish • C
orruption: A health worker re-
between two types: quests money or presents from pati-
• Operational complaints ents in exchange for treatment
• Serious complaints • N
epotism: A manager selects his
cousin for a job though he is unqua-
Operational complaints are mostly lified.
related to projects and programs, e.g. • M
isuse of funds and/or property:
the project management, the quality of An employee observes her colleague
work, donor registration, or “staff inci- using the organisation’s car many
dents related to accidents, disease or se- times for private purposes. The car
curity threats ”. 12 and its maintenance costs are paid
Examples are manifold: through project money meant to
• a former donor complains about not help those in need.
having been deleted from the fund-
raising data base yet Physical, psychological and sexual
• a community member complains abuse and exploitation
about not being selected to be in- • An aid worker in a refugee camp re-
volved in a project in spite of his fa- quests sexual favours from a young
mily’s need for support girl in exchange for food.
A serious complaint is related to a bre- As can be seen in Table 1, at Dan-
ach of the Code of Conduct of an orga- ChurchAid, serious (“sensitive”) comp-
nization. In general, serious complaints laints are outnumbered by operational
can be divided into two categories: complaints which typically compose
• Corruption, fraud and financial is- the main part of all incoming comp-
sues and laints, an experience shared by most of
•
physical, psychological, sexual ex- the organizations interviewed.
14%
Internal Audit 14.4%
13.9% ruments to develop;
6.8%
7.0%
• Explain the reasoning behind and
By Accident
benefits of these guidelines and inst-
8.3%
6.6%
3.0%
3.3%
2012
IV. Creating Trust
External Audit 2010
4.6%
In the long term, the establishment of
new systems and minimization of ca-
”Report to the Nations on occupational Fraud and Abuse – 2014
Global Fraud Study”, Association of Certified Fraud Examiners ses of misconduct improves trust not
Table 2: Initial Detection of Occupational Fraud only by outside actors but also within
20 | 21
echa
August 2015.
ber 2015.
a
As in most aspects of the complaint Table 3: Advantages & Disadvantages of Centralized and
22 | 23
echa
CARE International in Cambodia – Complaints Mechanism Case Study. Presented at HAPI Complaints Mechanism Workshop,
4-5 April, 2006, Denmark. http://www.chsalliance.org/files/files/Resources/Tools-and-guidance/care-cambodia-comp-
laints-mechanism-case-study.pdf (Retrieved 24 November 2016
Safety considers potential dangers and risks Accessibility allows the mechanism to be used by
to all parties and incorporates ways to as many people as possible from as
prevent injury and harm many groups as possible in places
where the organisation is operational.
Confidentiality restricts access to and dissemina-
Communities should be supported to
tion of information, requiring that
set up their own complaints procedu-
information is available only to a
res, and must be enabled to complain
limited number of authorized people
when problems arise.
(generally the Senior Management of
the organisation) for the purpose of Quality should be accurate, and have a clear
concluding necessary investigations. sequence of events.
Transparency staff and persons of the affected Verifiability to ensure that the information is relia-
community know it exists, and pos- ble.
sess sufficient information on how to Timeliness of reporting, and related follow-up
access it. People of concern should measures, must be ensured.
be able to speak to member staff
regularly about the operation of the Assistance to should be a part of the complaints
complaint mechanism and know who those reporting mechanism, to deal with possible
in the organization is responsible for psychosocial, medical and other
handling complaints and communica- needs.
ting outcomes. Documentation The importance of objective, reliable
documentation is critical.
for the purposes of this Guide. These long-term running of a complaint me-
are the following, summarized in Table chanism. The difficulties you might
4 by Act Alliance: face in the implementation process,
These factors are a good guideline for and how to deal with them, are the to-
making your mechanism a success. The pic of the next chapter, Establishing and
real challenge, however, lies in achie- Implementing an Effective Complaint
ving them in the implementation and Mechanism.
gation Guidelines, 2010, p.5, available at http:// and Response Mechanism, p.2 (Retrieved 5
actalliance.org/wp-content/uploads/2015/11/ February 2016).
Complaints-and-Investigation-Guide-
lines-July-2010-1.pdf (Retrieved 8 April 2015). Act Alliance, Complaints Handling, p.1 (Retrie-
24
Graphic from Diakonia, Policy for Diakonia’s Complaints and Response Mechanism, p. 16
28 | 29
Graphic 1: 12 Steps of Complaints Handling25
11 | 31
30
Recommended Source: power. A self-critical management that
• Diakonia, Policy for Diakonia‘s Complaints and values integrity highly and can questi-
Response Mechanism (2012), pp. 5-6 and 12-13, on its own organizational structures is
provides a detailed list of human resources and part of an open-minded organizational
steps needed to implement the complaint mecha-
culture. Moreover, an important cha-
nism policy and precise description of tasks of the
country, regional, and head office level racteristic of this integrity is a willing-
ness to communicate weaknesses open-
ly or learn from mistakes. This integrity
increases the trust stakeholders and
a. Open-minded employees need to use the mechanism.
Organizational Culture Senior management’s attitude toward
corruption and misconduct is crucial
Organizations often mention external
for the success and effectiveness of the
reasons for the implementation of a
mechanism.
complaint mechanism. These include,
for example, the desire to be transpa-
rent and accountable to donors, sta-
keholders, employees and the public.
Only a few organizations referred to
internal reasons for setting up a mecha-
nism. Those internal reasons can inclu- Recommended Source:
de, among others, management’s desire • Checkpoints for Managers,” in Act
to fight against corruption or misuse of Alliance, Complaints Handling and
Investigation Guidelines (2010), pp.
power in their own organization. Ho-
27-29
wever, this presumes an awareness of
the potential for corruption or abuse of
b. Resources 2. Let End-Users Decide and
In addition to organizational culture, Be Aware of the Cultural
another key element for the establis- Context
hment of a complaint mechanism is A basic challenge many organizations
resources. NGOs are under constant encounter is that there is no “one size
pressure to keep their administrative fits all” solution to creating a complaint
costs as low as possible. A complaint mechanism. Rather, the mechanism
mechanism brings additional costs. The must be adapted to the needs of the
organization thus needs to communica- “end-users.”
te and justify, both internally and ex- “What will help people of concern report
ternally, why a mechanism is important abuse in one environment may not help
and how the mechanism can improve people of concern in another environ-
its operations, protect its finances and ment. This is because barriers to repor-
deliver high-quality projects. ting vary greatly from place to place de-
Among the resources that need to be pending on factors such as the nature of
considered are human resources: eit- the humanitarian crisis, how people are
her a position should be created, or a vulnerable and local social norms, inclu-
percentage of an existing position de- ding gender norms. It is therefore essen-
dicated to the receiving and handling tial that organisations develop policies
of the complaints, or a person should in consultation with people of concern as
be hired pro bono. Additionally, at dif- well as staff. Policies used in a number
ferent points, other departments will of environments should be flexible and
need to contribute human resources, require staff to investigate local circum-
e.g. for a person to become part of the stances before and during implementati-
investigation process for a limited time on.” 26
frame. Financial resources are needed Regardless of whether you choose to
to develop training and training ma- establish a centralized or decentrali-
terial. Financial resources will also be zed system, make sure the mechanism
needed not only to establish a comp- is discussed not only at headquarters
laint mechanism but to sustain it. The but with end-users in each country. To
long-term success and credibility of a establish a well-functioning complaint
mechanism are at risk if funds to run it mechanism, it is essential to integrate
are insufficient.
32 | 33
34 | 35
3. Enable and Encourage a. Create Trust
End-Users to Use the Comp- To ensure that the complaint mecha-
laint Mechanism nism is used, trust is one of the most
Potential complainants need to have important factors. However, this can
easy and safe access to the mechanism. also be one of the weakest points of a
This is especially important for disad- complaint mechanism.
vantaged groups such as women, ethnic “Complainants – whether they are per-
minorities, the illiterate, the elderly or sons of concern or staff members – will
young people. Many do not know their not come forward unless they trust that
rights and entitlements. For this rea- the allegation will be taken seriously and
son, awareness must be raised among that they will be protected from reprisals.
end-users and their needs closely exa- Managers must create a culture and re-
mined to determine how to enable and lated systems that promote trust among
encourage them best to use the comp- the host country, international/national
laint mechanism. A key element is the staff and beneficiaries and in doing so
creation of trust in the mechanism. mitigate factors which may deter indivi-
duals from making complaints.” 28
Establishing trust is a long-term process
and depends very much on the organi-
zational culture regarding misconduct.
“One of the constraints is to make sure that people
Therefore, the management, those di-
really understand their entitlements.”
rectly responsible for the complaint
(Olivier Beucher, director of DRC’s programmes in Le-
banon and Syria.) mechanism and the wider organizati-
on all need to work together. Manage-
“They often don’t know about their rights because
we don’t tell them.” ment has an enormous responsibility
(Maria Kiani, senior accountability adviser at HAP about to create trust and encourage staff to
the importance of accountability in the field. Both support the complaint mechanism. Se-
quotations from IRIN news, “Put Accountability into
nior management support is therefore
Practice,” 4 December 2012. http://www.irinnews.org/fr/
node/252206 (Retrieved 27 October 2016) one of the most important enablers of
the effective implementation of a com-
plaint mechanism. Crucially, this sup-
36 | 37
b. Identify Barriers and I. Allow for Anonymous
Solutions to Overcome Them Complaints
There are many barriers to reporting: In some cases, a victim or witness of
for example, the fear of retaliation or misconduct may choose to remain an-
cultural norms that consider it unac- onymous when filing a complaint to
ceptable to challenge authority. Other protect his/her identity and to avoid
barriers include the fear of losing a job, negative repercussions.30 Among orga-
status, prospects or a source of income nizations with a complaint mechanism,
by filing a complaint, but also a simple anonymous complaints are the subject
lack of knowledge about the complaint of some controversy. Organizations like
mechanisms.29 When planning and es- Diakonia or Kindermissionswerk “Die
tablishing a complaint mechanism, you Sternsinger”, which have extensive ex-
need to consider barriers that might pre- perience receiving complaints, state
vent people from using the mechanism that it is essential to accept anonymous
and find solutions for overcoming them. complaints if a complaint mechanism is
Here are a few examples of possible to be taken seriously.31 The Danish Re-
obstacles and how to manage them: fugee Council (DRC) has been accept-
ing anonymous complaints for several
years, after having not done so. DRC
explains that many people who would
like to complain are in a dangerous si-
Best Practice: tuation. Only the possibility of anony-
At the organization Report The Abuse, cases of mity encourages them to complain.32
sexual abuse in the humanitarian and development Nevertheless, all interviewees also ad-
sector can be reported anonymously through an
mit that it is more difficult to verify the
online form. While completely anonymous reports
can already be filed, in the coming months additi- content of an anonymous complaint.
onal measures are being put into place to provide However, it is not impossible to inves-
more security for abuse survivors, as well as allo- tigate one. Trust needs to be created
wing for reports to be completed offline for uploa- with the anonymous complainant to es-
ding at a later time.
tablish more contacts and to obtain the
(Megan Nobert, Report the Abuse, interviewed
24 October 2016) needed information. In some cases, the
person ends up revealing his/her iden-
tity because (s)he understands how im-
and Response Mechanism, p. 9 (Retrieved 19 Natascha Linn Felix, DCA, interviewed 8 Decem-
October 2015). ber 2015.
38 | 39
who is bound by a confidentiality clau- Recommended Sources:
se. If resources do not allow, choose a • Diakonia, Policy for Diakonia‘s Com-
person of the gender/ethnicity/religi- plaints and Response Mechanism
on/language etc. that most end-users (2012)
will feel the most comfortable with. • International Council of Voluntary
Agencies (ICVA), Building Safer Orga-
nisations Guidelines (2007)
III. Fear of Repercussions • LWF, Complaints Mechanism. Policy
A victim r a witness might abstain from and Procedure (2010)
reporting due to fear of repercussions
(losing a position or advantages, physi-
cal threats etc.). The mechanism must
ensure that complainant protection is
in place. For more information on this
matter, see Chapter III.3 Identify Risks
and Provide Protection (“Whistle-blower
Protection”).
4. Protection from Malicious Best Practices: How to Detect Potential
Complaints Malicious Complaints
any oranizations are concerned about
According to Sonja Grolig of the task force of Transparency
the potential misuse of a complaint me-
International for Ecclesiastical Development Cooperation
chanism motivated by personal or poli- (AGkE TI), a serious complaint usually provides specific,
tical agendas. An employee could, for specified and documented facts. The clearer the complaint
example, use the mechanism as a tool statement is, the more probable it is that it is a genuine
to advance his/her political interests complaint.
or to denounce an innocent colleague The characteristics of a malicious complaint are:
by fabricating a story about him/her. a. U nspecific phrasing of the misuse/act and/or general
allegations
With this risk in mind, several organiz-
b. Use of personal, angered and less factual expressions
ations have included in their guidelines c. Existence of controversial complaints, meaning people
a zero-tolerance policy regarding mali- make anonymous allegations against one another
cious complaints. Diakonia emphasizes (Ewa Widén, Diakonia, interviewed 27 November 2015)
40 | 41
“Each country team needs to find out the best way Best practices: Communication
to communicate with the partners and stakeholders.
to Stakeholders
Setting up the process requires work, but once
you have it going on it is not that time-consuming “Make sure people of concern are aware
anymore.” of their rights and the mechanisms to
(Ewa Widén, Diakonia, interviewed 27 November 2015) enforce them. A mechanism will only
be effective if people of concern know
their rights and how they can enforce
them. Organizations will communicate
these messages most effectively if they
consider:
a. Internal Communication
• Their audience/s – what is the gender,
Internal communication means the
age, physical ability, language, level
communication that takes place on all of literacy and ethnicity of the target
levels within the organization, from population?
management to employees and vo- • The available communication tool/s –
lunteers. These stakeholders are both is it better to advertise through pos-
potential complainants as well as the ters, dramas, focus groups, local action
subject of a complaint and thus of key and/or community groups?
importance. Examples of internal com- • The core message – what does the
munication are: target population really need to know?
• Staff trainings: Upon introduction of • The budget – how can they reach the
the mechanism, annual training for widest cross-section of the community
within budgetary constraints?”
new employees as well as regular re-
(ICVA, Building Safer Organisations
fresher courses Guidelines, p.9)
• Information as part of a welcome
package to new employees
• Website: Link “complaint mecha-
nism” directly on the organization’s
home page, e.g. next to “contact us”
button
• Posters and flyers in central office
rooms indicating complaint mecha-
nism website, phone number and
email address
• Briefing on the mechanism at the an- Best Practices: Setting Up a Decentralized
nual employee appraisal interview Mechanism with Partners
and the annual staff assembly or
• Discuss the complaint mechanism with the team of each
information session
country
• Each country decides how to set up, implement and run
b. External Communication the mechanism
It is important also to promote the com-
• Fixed time frame: e.g. within two years partner offices
plaint mechanism externally. Examples need to set up their mechanism
are public meetings and presenta-
• Regular partners meeting to exchange and discuss diffi-
tions, newspapers, radio, theatre, culties, success stories, solutions challenges experienced,
etc. The research for this Practitioner’s and to ensure the quality of each complaint mechanism.
Guide identified several organizations
with a complaint mechanism but that
have no information on their websi-
te or other communication channels
es. In this case, representatives of the
about it. This lack of external commu-
regional office need to be involved in
nication limits the target groups that
the process and have the task of ensu-
can use and benefit from the mecha-
ring the visibility and accessibility of
nism. If, however, the CM is made vi-
the mechanism.36 The extent of invol-
sible and easily accessible to anyone,
vement depends on the type of mecha-
people who are not part of the organiz-
nism chosen. In a centralized system,
ation but who witness misconduct can
partners need to be involved in com-
file a complaint.
municating the existence of a mecha-
nism to stakeholders and how to use
6. Engage your it. In this case, the headquarters can
Partner Organizations simply give a time frame within which
One challenge can be the geographical the local trainings have to take place as
distance to the end-users. Often, di- well as provide informational material
rect communication between the head to assist partners.
office and the beneficiaries is difficult In a decentralized system, the obli-
because the organization operates th- gations of partners are more complex.
rough local partners as intermediari- They are responsible for establishing
42 | 43
7. Finalize Guidelines
and Policy
All aspects of the complaint mechanism
and the handling procedure need to be
detailed in the complaint mechanism
Graphic from Diakonia, Policy for Diakonia’s Complaints and Response Mechanism, p. 16
In this part, we will examine the diffe- registered in a standardized way (e.g.
rent steps that follow from receiving a in a complaint form; see Annex 5 for an
complaint and discuss the best practices example). In addition, a letter of ack-
to make your complaint mechanism ef- nowledgement should be sent to the
ficient. As in the previous sections, A complainant. The letter should inform
Practitioner’s Guide focuses on practical the complainant that the organization
experiences and best practices. We will or the ombudsperson has received the
briefly present the theory and provide complaint and should summarize the
links to further literature (see Recom- steps that will be taken next.
mended Sources Box). The schematic
diagram below illustrates the main
steps associated with receiving a com-
plaint.
Best Practice:
1. Give the Complainant a “Acknowledgement Letter states
• When and how the LWF/DWS received the complaint
Formal Confirmation • Who in LWF/DWS is responsible for acting on the comp-
The person responsible for receiving laint
the complaint has a duty to respond • Who the complainant should contact regarding ques-
adequately to the complainant. First, tions or feedback”
independent of whether the complaint (LWF, Complaints Mechanism. Policy and Procedure, p.12)
44 | 45
“This written acknowledgement is im- case as possible, i.e. where it comes
portant for reasons of accountability and from. Thus, it needs to be forwarded
transparency. It shows the complainant to the responsible staff, e.g. the project
that the allegation is taken seriously and manager. Often, these cases can be re-
it gives her/him the information he/she solved through a simple desk investiga-
needs to ensure that the LWF/DWS [De- tion.
partment for World Service] is respon- For a serious complaint however, the
ding properly. If an investigation follows, steps are more complex. It is recom-
this provides a record that the LWF/DWS mended to use the principle of the next
has received the complaint and has given higher person: if the complaint is about
initial indications on how it has hand- the person’s line manager, it should be
led the situation in the initial stage. […] forwarded to the next higher manage-
The acknowledgement letter should be in ment level. In general, serious com-
writing, concise and clear. If the complai- plaints are addressed by regional or
nant does not want a letter, or the LWF/ senior management at the head office.
DWS believes that such may put the com- This measure ensures consistency in
plainant or others at risk, it is possible to how the complaint is handled.
confirm receipt orally.” Serious complaints should be investi-
LWF/DWS, Complaints Mechanism. Policy and gated if enough evidence is available.
Procedure, p. 12
Safety risks should be identified and re-
sponded to immediately (see Annex 2:
Diakonia’s Flowchart for Handling Seri-
2. Decide What Type of
ous Complaints.)
Complaint It Is
The next step is to identify what kind
of complaint or incident it is in order to
decide how to handle it (see also chap-
ter I).
For an operational complaint the best
practice is the principle of the nearest
person: Usually, the operational comp-
laint should be handled as close to the
plaints and Response Mechanism, p.5 24 October 2016 Europe. Legal Protections For Whistleblowers
in the EU,” 2013, available at https://www.
Report The Abuse is a campaign that aims at ad-
40
Benjamin Novak, “Hungarian NGOs launch joint
42
transparency.de/fileadmin/pdfs/Themen/Hin-
dressing the problem of sexual violence against whistleblower protection program”, The Buda- weisgebersysteme/EU_Whistleblower_Report_
humanitarian and development workers, e.g. by pest Beacon, 24 April 2015, available at http:// final_web.pdf (Retrieved 25 April 2016).
gathering testimonies of survivors and witnes- budapestbeacon.com/featured-articles/hunga-
ses of sexual violence within the humanitarian rian-ngos-launch-joint-whistleblower-protecti-
and development community. See http://report- on-program/22256 (Retrieved 25 April 2016).
theabuse.org/ (Retrieved 21 March 2017)
Recommended Sources: European Union, only four have ful-
• United Nations Office on Drugs and ly-fledged whistle-blower protection
Crime, The United Nations Conven- laws. Sixteen have insufficient or par-
tion against Corruption: Resource tial legislation and seven have none or
Guide on Good Practices in the Pro-
very limited legislation43. (See Recom-
tection of Reporting Persons (2005)
mended Sources box for further infor-
• Paul Stephenson, What makes a
mation on whistle-blower protection.)
good whistleblower law? (2014)
4. Decide Whether
to Investigate
accept their decisions and allow them Upon receipt of a complaint, the re-
to change their minds later if this is sponsible person needs to decide
what they desire. It’s the key to a survi- whether to initiate an investigation. For
vor-centred approach. 41 this purpose, the following questions
Organizational efforts should be sup- can be raised:
ported at the state level: national le- • Does the complaint or incident rela-
gislation needs to ensure that it is te to a breach of Code of Conduct or
not a crime to report a crime. The law violation of any of the organization’s
should make clear that a person who policies and guidelines?
speaks up in the public interest cannot • Has the complaint been made in
be subject to civil or criminal lawsuits good faith? The complaint or inci-
for their disclosure.42 A whistle-blo- dent should be a genuine concern
wing law certainly needs to take into of the complainant. It should not be
account the legitimate reputational motivated by personal gain, personal
concerns of employers, but it must pri- interest or a grudge44
marily offer real protection to whist- • Is there sufficient information and
le-blowers who speak up about the risk evidence to start an investigation?
of harm or wrongdoing in the public • How realistic is it to solve the case
interest. Unfortunately, national legis- and to gain knowledge?
lation is not yet very advanced in this • Will the costs be higher than the be-
regard: of the 27 member states of the nefits from the investigation (cost-be-
48 | 49
nefit analysis)? This question con- Recommended Sources:
cerns corruption issues in particular. • Act Alliance, Complaints Handling and
Indicators for the decision include: Investigation Guidelines (2010)
-- Age of Case: If a case is older than • LWF, Complaints Mechanism. Policy
2-3 years, it is often not worth the and Procedure (2010)
effort of investigating due to lack • International Council of Voluntary
of evidence (no written documen- Agencies (ICVA), Building Safer Orga-
tation, staff turnover etc.). nisations Guidelines (2007)
-- Location: If a project is in a seclu-
ded location, documentation is of-
ten insufficient.
-- Value of misappropriated money or
bribe: If the amount is small, the
cost of investigation can quickly
exceed the amount involved. 45
To answer these questions and reach
Best Practice: Open Book Policy
a decision regarding launching an in-
Organizations often question how much informati-
on they should put online, both regarding the effort
vestigation, the responsible person
and an overflow of information. In this context, conducts desk research. This means he
an openly communicated Open Book Policy can or she looks into files, enters into infor-
help. It can be a simple statement on the website mal dialogue with possible informants,
that says that the books of the organization can be and so forth. In many cases, especially
accessed upon request from partners.
regarding operational complaints, the
“Just open your books and show the partner the
numbers. There are simple solutions once you have problem can be resolved at the stage of
analyzed what the problem is about.” the desk research if there is good com-
(Natascha Linn Felix, DCA, interviewed 8 December 2015) munication with the complainant. An
open book policy can benefit the orga-
nization (see Best Practice box).
ber 2015.
2015.
5. Have Defined Time Limits Action Time Allotment
For both the complainant as well as Complaint Received Incident should be reported soo-
nest but can be brought up within
the person(s) under investigation, fi- 6 months of incident
xed maximum time frames for each Acknowledgement of Complaint Within 2 days
Received
step of the complaint and investigati-
Resolution of Operational Com- Decision within 7 days
on process should be openly commu- plaints
nicated. Time limits make a complaint For Complaints needing further Actual investigation ideally in 7
mechanism more transparent and com- investigation days though may vary depending
on the nature and complexity of
prehensible. This goes hand in hand complaint.
Maximum 21 days
with continuous communication with
the complainant and the subject of the Inform Geneva Secretariat of Soonest information is known,
investigation. The complainant feels serious complaints and reflected in the Management
monthly report
safer and taken seriously if (s)he is in-
Resolution of a complaint under- Maximum 30 days of receipt of
formed about when to expect a reply, going investigation complaint
a decision etc. For the person(s) under Appeal process Within 30 days of decision
investigation on the other hand, time
Table 5: Time Allotment of Specific Actions of the Complaint Process46
limits are important for avoiding the
uncertainty of a never-ending investi-
gation.
Many organizations seek to resolve a
complaint within 30 working days of
Other organizations state that they pre-
receipt. Table 5 illustrates LWF’s list of
fer not to use time limits. The Danish
the time allotment for the specific ac-
Refugee Council, for example, argues
tions of a complaint mechanism:
that restrictive time limits are “artificial
and unwise because you need to give the
case the time it needs to be solved.”47 A
Practitioners Guide’s recommendation
is to define realistic time frames but to
allow for a (fixed) extension period for
particularly challenging cases.
50 | 51
IV. Investigation
Graphic from Diakonia, Policy on Diakonia’s Complaints and Response Mechanism, p.16
52 | 53
tive in relation to the case. Furthermo- Recommended Sources:
re, the persons responsible for investi- • CHS Alliance, Guidelines for Investiga-
gating should not report to their direct tions (2015)
management but to a higher instance • Act Alliance, Complaints Handling
such as the board, which also decides and Investigation Guidelines (2010),
when a case is finished. This guaran- p.18-22
tees a certain independence as well as • LWF, Complaints Mechanism Policy
the engagement of the board in risk ma- and Procedures (2010), Appendix 6
LWF/DWS Investigation Guidelines,
nagement. It offers the board a chance
p.26-35
to be involved in the practical work of
the organization and receive insights
into the weaknesses of the organization
that need to be addressed.
The investigation team should be
2. Investigation Process
able to conduct the investigation in a
Regarding Corruption Cases
thorough manner and to demonstrate
In cases of suspected corruption, the
clearly a zero-tolerance stance against
investigation process may require dif-
misconduct. Regarding the specific way
ferent types of tools and strategies. In
to investigate, there are many different
the following section, two examples of
options of developing an investigation
useful tools – namely, external and so-
plan, including how to gather evidence
cial audits are described.
and conduct interviews as well as the
contents of the final report and the fol-
a. External Audit
low-up. Sources containing detailed in-
An external audit is the auditing of the
formation and guidelines on these mat-
financial statements of an organization
ters can be found in the Recommended
or institution by an entity independent
Sources box.
of the subject of the audit. One of the
primary aims of the external audit is
not only to check finances but to send a
clear signal against corruption and for
transparency among partners. Even in
54 | 55
Recommended Source: to be able to question the organiza-
• Centre for Good Governance, Social Audit: A tion directly about it and to demand
Toolkit – A Guide for Performance Improvement accountability. This type of audit has
and Outcome Measurement (2005) long been supported and demanded
by Transparency International.51 Only
a few NGOs systematically undertake
social audits. Among churches, hardly
to avoid nepotism. As it can be difficult any audits from below are underta-
to identify a good audit company, their ken.
work should be checked regularly. The One of the major problems of social
cost of an external audit depends on audits is that only the partner in the
the financial amount in question and country has direct access to the target
the documents available at the part- group. Therefore, a foreign donor is
ner organization. Usually, it is higher dependent on the willingness of the
than an internal audit,50 because the partner to undertake a social audit.
external auditors examine the docu- The cost of the social audit, on the
mentation on the ground and conduct other hand, often has to be covered
interviews. Costs can be reduced by by the organization’s headquarters,
partnering with other donor organi- especially if there is no local budget
zations that have the same partner to for it. Furthermore, the effectiveness
conduct a collective external audit. depends on conditions in the country
Upon finalization of the external audit, (e.g. fear of criticizing openly) and
the partner receives the results and has the target group: if people are illitera-
a chance to explain any shortcomings. te, a neutral person is needed to read
all relevant documentation and exp-
a. Social audit lain financial statements in addition
In a social audit (also called ”audit to facilitate the meeting. For an orga-
from below“, ”public audit“ etc.), the nization, it can be difficult to commu-
target group of projects and programs nicate its complex expenses to project
is informed of how the money is used participants.
Graphic from Diakonia, Policy for Diakonia’s Complaints and Response Mechanism, p. 16
ber 2015
VI. Systematic Analysis,
Reporting and Improvements
1. Systemic Analysis
record in written form. This way, com-
for Improvement
plaints can be analyzed systematically
As Diakonia emphasizes, “One of the
and used for institutional improvement
main purposes for establishing a CRM
by detecting structural malfunctions.
[complaint and response mechanism]
Through the systematic analysis of a
is to learn and [to] improve an organiz-
complaint, we can find answers to the
ation.”54 To realize the potential of the
following questions:
complaint mechanism as a tool for le-
• How did the problem emerge?
arning and improvement, it is essential
• What weaknesses in my organization
to analyze the cases dealt with: What
led to the problem?
were the origins of a complaint? Was
• How should guidelines/policies be
it handled well? How can similar cases
adapted or which new instruments
be avoided in the future? Knowledge
and strategies are needed to avoid
can be gained from each complaint to
similar cases in the future?
improve the organization’s operations.
• How should new instruments against
The more cases detected, the more sys-
misconduct be best communicated?
tematic approaches can be developed.
The lessons learned can feed conti-
nuously into project improvement and
making anti-corruption activities more
successful.
Best Practices of Systematic Analysis for
a. Systematic Analysis Improvement:
With this purpose in mind, all comp-
• All lessons learned drawn from the investigation
laints received – whether they lead to reports are communicated to management and
investigation or not – should be kept on implemented in the organization
• Keep a record
• Create systematic statistics and analysis of
lessons learned about the complaint mechanism 58 | 59
60
• Adapt Guidelines
• Draw up a black list of organizations to which donations
are suspended due to involvement in corruption cases
Hence, it is important to analyze not -- Anonymous?
only the lessons learned, but also: -- Malicious?
• Who files complaints? •
How many complaints have been
• What entry points are used? proven to be valid?
• What types of complaints are made? The following practical experiences
-- External or internal? By which present two examples illustrating the
group of stakeholders? detection of weak points through syste-
-- Serious or operational? matic analysis:
b. Adapting Existing - and Solution: All these follow-up costs, which are even higher
Introducing New - Systems than the original cost of the bribery, were avoided through
and Guidelines a systematic analysis of the complaints. In this case the
Once weaknesses are detected, and or- analysis revealed the high incidence of construction cor-
ganization can consider how to over- ruption and led to the employment of an external consul-
tant to oversee professionally every construction project.
come them by adapting existing guide-
This provided an easy, low-budget measure that saved a
lines and introducing new systems and significant amount of donor money. It is therefore not only
policies. Below, you will find a practical important to have a CM, but also to reflect on the cases,
example of a very successful impro- provide statistics, and have a constructive exchange with
vement in efficiency due to the adapta- beneficiaries, employees and external persons in order to
find the best way to solve the problem.
tion of guidelines.
(Sonja Grolig, AGkE TI, interviewed 19 November 2015)
60 | 61
2. Annual Complaints Report
Graphic from Diakonia, Policy for Diakonia’s Complaints and Response Mechanism, p. 16
Response Mechanism, p. 15
2015.
“Each year an annual report is every interviewee of organizations wi-
done with a short summary of each thout reports lamented this fact, and at-
complaint, what we did, and what
tributed it to a lack of financial and per-
we learned. No names of persons or
partners are specified in the report” sonnel resources. As one anonymous
(Ewa Widén, Diakonia, interviewed 27 practitioner explained, “This [lack]
November 2015.) reflects two dimensions: First, that the
organization puts the main effort in
building the complaint mechanism. Se-
condly, that the management does not
sons from potential misconduct, because fully understand the importance of re-
they see on the paper that misconduct porting about the mechanism.”
will be prosecuted”.56
Despite many good arguments for an-
nual reports and the relatively small
amount of resources needed, not many Recommended Sources: Examples
organizations with a complaint mecha- of Complaint Reports:
nism develop or publish ACRs. In fact,
• Diakonia: Short and very concise reports can be
found on Diakonia’s Complaints, Incidents and
Feedback Page
• DanChurchAid: Detailed reports with excellent
systematic analysis of causes can be found on
DCA’s Complaints Page
62 | 63
3. Evaluation and Impro- Practical Experiences 1:
vement of the Complaint Opportunities to evaluate
Mechanism the complaint mechanism,
Systematic analysis of the complaint Danish Refugee Council
mechanism can help identify errors and “Misconduct demonstrates errors or
weaknesses in the system. In order to weaknesses in the system. Whenever an
adapt CM to the needs of the people and investigator detects such a weakness, it
the organization, complaint mechanisms will not be noted in the report itself but it
will be noted in a second advisory report,
should be evaluated regularly, for instan-
which then will be sent to the manage-
ce every three years. It is up to the orga- ment, without disclosing any confidential
nization to designate the persons respon- details about the complaint itself. General
sible for monitoring the CM. These can management then decides about syste-
be regional or senior management (as matic improvements.”
(Niels Bentzen, DRC, interviewed 3 November 2015)
practiced by the Danish Refugee Coun-
cil57 or Diakonia)58 or the person recei-
Practical Experience 2: Results
ving the complaints in coordination with
of a Monitoring and Evaluation
the country program focal point persons
Process (Diakonia)
(as practiced by LWF).59 The complaint
1. Problem: complaint mechanism do-
mechanism can be monitored through cuments (e.g. guidelines) are too long
liaison with staff at all levels. This may and thus not read by staff
include local initiatives with staff in > Solution: Less detailed documents
charge of handling the mechanism (for 2. Problem: staff does not use mechanism
instance the complaints handling com- due to lack of communication about it
mittee, focal persons etc.), exploring in > Solution: more information on the
web about the mechanism to make it
detail how resolved complaints were
easier to use it
handled to identify any possible lessons,
3. Problem: focused on corruption cases
improvements to complaints handling or
but forgot to inform donors about
suggestions for changes in practice, as them
well as good practice examples. The box > Solution: report to donors or donor
below provides two practical examples agencies immediately on suspicion of
of the process of evaluating the comp- corruption
(Ewa Widén, Diakonia, interviewed 27 November 2015)
laint mechanism as well as the results of
one of the evaluations:
CR = Country Representative
HO = Head Office
66 | 67
RM = Regional Management
Annex 3: Case Study – Child health services – then played a critical
in Need Institute’s Benefici- role in raising community awareness.
ary Feedback Mechanisms,
Kolkata, India Collecting and responding to feedback
[The information in this case study comes All stakeholders – mothers, community
from the “Beneficiary Feedback Mecha- members, government officials and he-
nism Case Study: India”, one of eight pilot alth service providers - were involved
studies compiled by World Vision and its in designing the feedback mechanism.
partners]62 Together they decided which issues
could be reported on and through which
Background methods and formats feedback could
Between 2014 and 2016, several NGOs be made. They decided to provide fee-
were supported by the UK Department dback through group meetings, one-on-
for International Development (DFID) one monitoring visits and suggestion
to pilot Beneficiary Feedback Mechanis- boxes. The community also agreed on
ms (BFMs)63 in their maternal and child indicators on which they would provide
health projects. One of the participants feedback regarding health centers and
was Child in Need Institute (CINI), a other services.
local NGO supporting children, ado-
lescents and women in disadvantaged During group meetings, mothers gathe-
areas of India. The BFM was piloted in red in small groups to fill out a pictorial
CINI’s urban Maternal and Child Health form indicating whether they were hap-
Nutrition Project in Kolkata. py with aspects of the services, suppor-
ted by written comments from literate
Raising community awareness mothers. The Change Agents collected
CINI shared information about the BFM the feedback and forwarded it to Ward
with the relevant stakeholders (commu- Supervisors (CINI employees). During
nity members, local government mem- one-on-one visits further feedback
bers, maternal and child care providers, was collected. Similar pictorial forms to
etc.). CINI’s volunteer Change Agents those used for group meetings were de-
– community members themselves re- veloped for the suggestion boxes and
sponsible for connecting mothers with distributed to families through the Ch-
68 | 69
• Increased buy-in and ownership was in the process by CINI only when nee-
achieved through community-desi- ded. The ownership and responsibility
gned and -led approaches; for sustainability would thus be with the
• Women said that by hearing feed- team and not CINI.
back during meetings they realized
their own problems were not indi-
Annex 4: Case Study –
vidual but common ones shared by
DanChurchAid: Establishing
others and became motivated to take
a Complaint Mechanism
action;
• An end of pilot survey showed that
through an Anti-Corruption
almost 85% of respondents were
Program
[The information for this case study co-
aware of the feedback system;
mes from an interview with Natascha
• Women were empowered (e.g. the
Linn Felix, Learning and Anti-Corrupti-
Change volunteers). Some women
on Advisor at Dan Church Aid, as well
started organizing a women’s group
as the organization’s Complaints Report
that met weekly to discuss the feed-
2014.] 64
back issues. The group then took ac-
tion, e.g. by successfully mobilizing
To better integrate the complaint me-
a community rally to keep the area
chanism into the organizational culture
cleaner.
at DanChurchAid, Natascha Linn Felix
designed and implemented an An-
Moving forward
ti-Corruption Program over the course
As CINI worries about the level of sus-
of two years. This program was desi-
tainability of the BFMs, the organizati-
gned to raise awareness about the CM
on would like to see sustainability built
and possible breaches of the Code of
directly into the design of future BFMs.
Conduct at all levels of the organiza-
In practice this would mean a core team
tion, including stakeholders and part-
from the start, including community re-
ners at the country level as well as staff
presentatives and different stakeholders.
members and management at the Head
This team would be responsible for im-
Office. To take the cultural context into
plementation, opening the suggestion
account, Ms. Linn Felix established two
box and responding to issues, supported
70 | 71
To better motivate the partner organiz- Result of the Anti-Corruption Program
ation to participate in the program, the This program aims at changing the
FPs try to involve partners as actively organization’s culture and attitude
as possible. towards corruption. Though this is a
long-term process, DCA reports a hig-
Perception of the people her awareness about corruption in
“In the field, people are more open and some countries and a slight increase in
interested in having a workshop about complaints in 2015.
corruption than in Denmark, at the head
quarter, because [she assumes] that Den- Conclusion
mark is known as the least corrupt coun- DCA has been able to establish a com-
try. But once the workshop starts, it ta- plaint mechanism in every country in
kes 10 minutes and everybody is talking which it is working. At the time of the
about different experiences and starting interview conducted for A Practitioner’s
to tell stories about corruption. So they Guide, Ms. Linn Felix hoped to train
recognize actually that corruption is member organizations around the wor-
everywhere.” (Natasha Linn Felix) ld to allow them to create their own
complaint mechanisms, adapted to the
Resources needed cultural context of each country. She
During the first year, the Learning and also hoped to start a systematic collec-
Anti-Corruption Advisor was a full-time tion and analysis of all reported cases
position. The advisor had support to in order to increase organizational le-
create the e-learning training. In the se- arning. The main challenge she cont-
cond year, she needed 25% of her time inues to encounter relates to building
(8-10 hours per week) to implement trust so that the system will be more
the program. successful.
Ibid.
66
Annex 5: Feedback Box Form nism, with information in both English
by World Vision and Arabic. It is part of a case study by
This feedback box form by World Visi- World Vision on a feedback mechanism
on65 is a good example of a form that for a food assistance program in South
is easy to use for a complaint mecha- Darfur.66
72 | 73
Interviews
Niels Bentzen Policy Advisor, Risk & Danish Refugee 3 November 2015
Governance Council
Dr. Petra Feil Global Quality Assuran- Lutheran World Federa- 30 July 2015
ce and Accountability tion
(QAA) and Planning,
Monitoring and Evalua-
ting (PME) Coordinator