1. Policy Statement
It is UNICEF Aotearoa’s policy to provide donors and the public with a mechanism to raise any concerns or make a complaint to UNICEF Aotearoa in relation to its conduct of fundraising, advocacy, campaign or programme activities.
UNICEF Aotearoa seeks to have any complaint or dispute raised and received in a constructive and open manner and resolution achieved in a timely and effective way.
Any complaint or dispute about an aspect of UNICEF Aotearoa’s operations or practices will be dealt with confidentially, effectively and with the appropriate degree of urgency.
All complaints will be managed to ensure there is procedural fairness to all parties, there is no conflict of interest by either party, there is no victimisation or retaliation and confidentiality is assured throughout the process.
2. Purpose/Objectives
The purpose of this policy is to ensure transparency and accountability to all stakeholders in relation to complaints regarding UNICEF Aotearoa and its operations. It seeks to make clear the mechanisms available for making complaints and the way in which complaints will be handled and resolved.
UNICEF Aotearoa values feedback as a valuable tool in understanding and responding to stakeholder’s expectations. We therefore welcome feedback and will respond constructively and in a timely manner to complaints.
Complaints may come from our supporters, donors, the public, beneficiaries, official bodies and our partners. This policy deals only with external complaints and does not cover internal issues and/or complaints by staff, interns or volunteers. These are dealt with in accordance with the UNICEF Aotearoa employment issue policies.
The Whistle blower/Protected Disclosures policy can be used by either internal or external complainants, where the issue is of a serious nature. This policy is in the UNICEF Aotearoa Policy and Procedures manual.
Guiding principles
- Confidentiality: UNICEF Aotearoa is committed to ensuring that all information related to complaints and their resolution will remain confidential. The privacy of individuals will be maintained, and personal information will only be shared in accordance with the Privacy Act 2020.
- Accessibility: complaints procedures should be easily accessible and well publicised to the people we work with and other stakeholders. Information relating to the process is accessible and options exist to make a complaint to ensure no complainants are disadvantaged.
- Objectivity: complaints are treated with respect in a fair and equitable manner. Conflicts of interest will be identified to ensure objectivity.
- Responsiveness: complaints are dealt with in a manner that is timely and responsive. Complaints will be taken seriously and complainants will be kept informed on the progress of their complaint through the process.
3. Definitions
UNICEF Aotearoa defines a complaint as an expression of dissatisfaction about the standards of service, actions or lack of actions by UNICEF Aotearoa. It could be:
- Concern about the behaviour of staff, volunteers, board members, suppliers, partners or others acting on UNICEF Aotearoa’s behalf,
- Criticism about a fundraising campaign or action,
- Concern over inappropriate use of funding,
- Any breach of the CID Code of Conduct,
- A breach of organisational practices, policies or procedures,
- Complaints about UNICEF Aotearoa -supported programmes and/or the operations of partner Country Offices.
- A complainant is any person or organisation making a complaint
Remedy is action taken to correct or rectify a situation for an individual where it identified he/she has been treated poorly or unfairly by the system.
Systems improvement is an opportunity to improve policies, procedures, organisational culture, or similar issues to prevent future problems.
4. Relevant legislative and regulatory context
- New Zealand legislation
- CID Code of Conduct
- Fundraising Institute of New Zealand
- Public Fundraising Regulatory Association (PFRA) and the PFRA Code of Conduct.
- New Zealand Privacy Act 2020
5. Compliance
The consequence of UNICEF Aotearoa staff not complying with the policy and procedures range from disciplinary action to performance management to cessation of employment or contract agreement, dependant on the seriousness of the non- compliance.
6. Procedures
Complaints Handling Process
UNICEF Aotearoa will receive and respond to all complaints irrespective of who makes them or the nature of the complaint. It is acknowledged that some complaints are of a more minor nature and can be resolved quickly and informally (informal resolution).
Where a complaint cannot be resolved easily and informally, the Complaints Handling Process described below should be followed.
Making and receiving a complaint
How can a complaint be made?
The process for making a complaint is outlined on the UNICEF Aotearoa website as follows:
“UNICEF Aotearoa is committed to the highest ethical standards in its fundraising, advocacy and other activities. UNICEF Aotearoa is a member of the Council for International Development (CID) and is a signatory to the CID Code of Conduct. If you feel that we have not been fair or ethical in our conduct, you have the right to send your feedback. You may submit your feedback online by emailing us at [email protected] and outlining your reasons for concern and other relevant facts. Alternatively, you can call us on 0800 243 757 (NZ only) and +(64) (04) 815 9370. This number is answered by a Supporter Relations Representative.”
To ensure no disadvantages or barriers to making a complaint, where necessary, language interpreters may be required to help establish the nature of the complaint.
Where possible, and depending on the seriousness of the complaint, the complainant should be encouraged to make a complaint in writing to the Chief Executive Officer (CEO) describing the nature of complaint, reasons for the concern, and other relevant facts.
If providing the complaint in writing is not feasible or appropriate, the staff member handling the complaint will record these details and refer the complaint to the Chief Executive Officer. The Chief Executive Officer may delegate investigation to another senior staff member, depending on the nature of the complaint.
Acknowledging a complaint has been received
Each complaint must be acknowledged as it is received. Acknowledgement will also include an outline of the next steps. If a verbal complaint is received the staff member will take the name and contact details of the complainant so the outcome can be communicated.
Registering Complaints
All complaints will be logged on a register of complaints kept by the Supporter Relations team on the Complaints Record log. All records will be treated as confidential and kept in accordance with the data protection and privacy legislation.
These records will be used to ensure complaints are dealt with effectively, to monitor trends and to ensure continuous improvement of the complaints handling process and our work.
If a staff member, other than a Supporter Relations Representative, receives a complaint they should send the details of the complaint to the Supporter Relations team for recording.
Assessing and reviewing a complaint
When a complaint is received and addressed through the Complaints Handling Process, an assessment must be made about the appropriate course of action. This can only be achieved through investigation. Frivolous or vexatious complaints will not be investigated.
Investigations will be conducted as follows:
- Where there is a complaint about the activities of UNICEF Aotearoa (e.g., a campaign, a programme, fundraising or advertising, etc), the relevant manager will investigate.
- If a complaint involves the manager, it will be dealt with by that manager’s direct supervisor
- If a complaint implicates the Chief Executive Officer, the complaint will be referred to the Chair of the Board.
- The investigation will establish the facts and gather the relevant information and, if necessary and/or practicable, interview those involved.
- Once the investigation is completed a recommended course of action will be made by the person handling the complaint to the CEO.
- Any action taken in relation to an employee as a result of the investigation will be in accordance with relevant disciplinary and other organisational policies and procedures (e.g., UNICEF Aotearoa Child Safeguarding Policy, Fraud Policy).
Remedy or system improvement
At times, remedy and systems improvement may arise out of complaints dealt with under either Informal Resolution or under the Complaints Handling process. This procedure will be initiated by the relevant manager using the following steps. It also applies to suggestions.
- Assess if remedy and/or systems improvement is warranted or no action is required.
- Implement immediate remedy/system improvement or plan future implementation of remedy/system improvement.
- Inform complainant of outcome.
Remedy may involve one or more of:
- Providing explanation and reasons if not previously provided,
- Dismissing the complaint if the decision accords with relevant policy or procedure,
- Concluding that the complaint has been substantially resolved,
- Reaching a compromise solution,
- Giving an apology or providing a service not previously provided,
- Addressing or referring the issue for system improvement.
Systems improvement may involve one or more of:
- Referral for consideration of policy change,
- Policy development or revision,
- Process improvement, such as changes to procedures and workplace practices,
- Programme review,
- Expert assistance, staff development or performance improvement,
- Improved implementation, such as issuing updated documentation or reminders,
- Monitoring compliance,
- Other action to ensure that the matter is handled appropriately in future.
Informing complainant of outcome
Once the complaint has been resolved, the complainant will be advised of the outcome.
- If the complaint is well founded, UNICEF Aotearoa will endeavour to provide redress (e.g., a retraction, or recompense, etc), or where this is not possible or appropriate, provide a formal written apology. This may also include suppression of the donor’s personal information on the database, and confirmation of how their personal data has been used.
Timeframe for response
For less serious complaints UNICEF Aotearoa will endeavour to resolve matters, or provide an update with expected timeframe, within 48 hours for fundraising complaints and 10 working days for all others.
For more serious complaints UNICEF Aotearoa will endeavour to resolve matters, or provide an update with expected timeframe, within one month.
Appeals process
If the complainant is still not satisfied, the complaint may be referred in the first instance to the Executive Team for a response through the CEO, and beyond that to the Board. If the complaint involves the CEO it should be referred to the Chair of the Board.
Publication of the Policy
UNICEF Aotearoa will provide clear information to its stakeholders and members of the public about how to make a complaint.
This information will be made public on the UNICEF Aotearoa website and in the Annual Report. UNICEF Aotearoa staff will inform relevant stakeholders of the policy where appropriate and provide copies of the policy on request.
Policy familiarisation
New employees will be provided with the policy as part of their induction to the organisation. The policy will also be available for all staff within the UNICEF Aotearoa Policy and Procedures Manual.
Training and/or communication will also be provided following an update or change to the policy.
Beneficiaries and stakeholders of international programs
UNICEF Aotearoa may receive complaints relating to one of our directly supported programs or Country Office partners by a community member, including children and youth, implementing partner or government official. All complaints relating to UNICEF’s in-country operations will be managed according to UNICEF’s established internal mechanisms, as outlined in the UNICEF Executive Directive CF/EXD/2007- 005 Revision 2 – Section 3.
UNICEF Country Offices are responsible for responding to complaints relating to UNICEF’s operations in each respective country. Complaints made directly to UNICEF Aotearoa will be referred to the head of the office (Country Representative) or division concerned.
Serious complaints of misconduct related to UNICEF country offices (particularly relating to fraud or sexual exploitation and abuse) will be made to the designated authority and managed according to established guidelines, including:
(a) the Director, Office of Internal Audit and Investigation
(b) the focal point appointed to receive reports of sexual exploitation and abuse
During monitoring trips, the UNICEF Aotearoa International Programmes team will discuss with in-country staff the complaints process; the complaints received, action taken to resolve them as well as identify any trends and any action to address ongoing programmes. Significant trends and corrective action are reported back to the UNICEF Aotearoa Executive meetings as required.
Responsibilities
This policy is governed by, and should be interpreted in accordance with, the laws and regulations of New Zealand.
It is the responsibility of the Chief Operating Officer (COO) to ensure the effective implementation and maintenance of this policy, and any associated documents.
The Chief Executive Officer is ultimately responsible for complaints which cannot be resolved by management team.
The Chair of the Board is responsible for managing complaints relating to the CEO.
The role of the appropriate UNICEF Aotearoa Manager is to investigate and make recommendations to the CEO or Executive team and ensure that the follow up actions have taken place.
The UNICEF Aotearoa Executive team is responsible for ensuring that UNICEF Aotearoa responds to complaints according to the policy and procedures.
The Frontline Support Team Leader is responsible for ensuring that all complaints are logged, assessed, and referred on:
- Initial assessment of complaints and identifying those which can be dealt with informally and those which are clear, serious, or complex complaints to be addressed according to the complaints handling procedure.
- Ensuring complaints are appropriately referred to appropriate line manager
- Maintaining the Complaints Log.
UNICEF Aotearoa is a member of the Fundraising Institute of New Zealand and the Public Fundraising Regulatory Association and abides by its Code of Conduct. It is the responsibility of the Head of Individual Giving or the Finance Officer to report to UNICEF Private Fundraising and Partnership Division if an unsolicited donation has been received from a corporate entity which falls under the specific exclusionary criteria, and that any such donation is returned to the corporate entity in a timely manner.
It is the responsibility of the International Development Manager to ensure that all complaints related to directly supported programmes are referred to the UNCEF in- country office Deputy Representative/Country Representative and are followed up.
Supporting Documents
Protection against retaliation for reporting misconduct or for cooperating with duly authorized audits, investigations and other oversight activities - UNICEF Executive Directive CF/EXD/2007-005 Revision 2 – Section 3 (6 February 2015)
UNICEF Policy Prohibiting and Combatting Fraud and Corruption – UNICEF Executive Directive CF/EXD/2013-008 (29 August 2013)
Secretary-General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Sexual Abuse – UNICEF Executive Directive CF/EXD 2003-029 (30 December 2003)
Further Guidance on the Implementation of the Secretary-General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Sexual Abuse – UNICEF Executive Directive CF/EXD/2004002 (28 January 2004).
Prohibition of discrimination, harassment, sexual harassment and abuse of authority – UNICEF Executive Directive CF/EXD/2012-007 (30 November 2012