Complaints Handling Mechanisms (CHM) 

A guide for CAFOD staff to accompany partner organisations

to set up CHM within international programme activities

Version 1.0

June 2010

Complaints Handling Mechanisms: An implementation guide Page 1

 

Introduction.........................................................................................3
1. Basic Concepts..............................................................................4
1.1 Accountability ................................................................................................................................................. 4

1.2 What is feedback and complaints? ................................................................................................................. 4

1.3 Principles ........................................................................................................................................................ 5

2. Consultation, Participation and Information Sharing ................7

2.1 Consultation and Participation ....................................................................................................................... 7

2.2 Information Sharing ........................................................................................................................................ 9

3. Designing and Implementing a CHM .........................................10

3. Designing and Implementing a CHM .........................................10
3.1 Main features of a CHM ...............................................................................................................................10

3.2 Implementing a CHM ....................................................................................................................................10

3.3 Roles and responsibilities .............................................................................................................................13

4. Monitoring, Reviewing and Learning from Complaints ............15

4.1 Monitoring and reviewing the CHM system .................................................................................................15

4.2 Learning from Complaints ............................................................................................................................16

ANNEXES ..........................................................................................17
Annex 1:  HAP Principles of Accountability ........................................................................................................17

Annex 2: Benefits and Challenges ......................................................................................................................18

Annex 3: Participation ........................................................................................................................................20

Annex 4:  Characteristics of complaints handling ..............................................................................................20

Annex 4:  Characteristics of complaints handling ..............................................................................................21

Annex 5: Useful Tools .........................................................................................................................................22

Annex 6: Case Studies .........................................................................................................................................23

Annex 7: Investigations ......................................................................................................................................25 

Complaints Handling Mechanisms: An implementation guide Page 2

Introduction

This document’s four sections are intended to guide CAFOD staff when accompanying CAFOD’s
partners to set-up and implement a Complaints Handling Mechanism (CHM) for beneficiaries and
other stakeholders of a project and/or programme. The structure of the guide is as follows:

1. Basic Concepts (2 pages). The first section presents the basic concepts underlying
complaints handling. It gives definitions as well as setting out some of the core principles to
consider when setting up a CHM.

2. Consultation, Participation and Information sharing (3 pages). This looks at: the
importance of how to approach setting-up a CHM with user groups; what constitutes a valid
complaint; the difference between sensitive and non-sensitive complaints; and the information
that needs to be shared before setting up a CHM.

3. Designing and Implementing a CHM (5 pages). This outlines the main features required and
looks in detail at the various aspects of implementing a CHM: the receipt, tracking and recording
complaints, processing, review and investigation of complaints, the response to the
complainant(s) and the appeal processes. It also covers some of the principles underlying
investigations, responses, appeals and information provision to users of the CHM and other
stakeholders.

4. Monitoring, Reviewing and Learning from Complaints (2 pages). This last section looks at
how to check that a CHM is working effectively and efficiently. It also provides some guidance on
how to use the information from the complaints themselves to inform and improve organisational
and programme work and approaches.

How to use this Guide

The four sections of this document are designed to provide programme staff in CAFOD with
guidance and support when accompanying partners through the process of setting-up a CHM.
There are references to suggested tools and case studies that may offer some guidance to assist
with the challenges and issues that can arise when implementing a CHM.

Staff using this Guide should ensure that they are familiar with the general principles of
accountability to which CAFOD is committed as part of our membership and certification with
HAP International (See Annex 1). Staff should also have a good understanding of the policies,
standards and codes that CAFOD is committed to upholding (See PCM Guidance Notes:
Standards of Accountability)

Discussions held as part of previous programme development processes (e.g. CAFOD’s POP,
PCM and Accountability Checklist, Minimum Standards and Accountability Planning Tool) can
provide a good understanding of a partners values, commitments and plans. They can also help
identify programme stakeholders, what measures are already being taken with regard to
accountability and how these can support the process of setting-up a CHM. See Annex 4 “Useful
Tools” and Annex 5 “Case Studies” for further guidance.

Key CAFOD related documents

• CAFOD Complaints Handling Policy
• PCM Guidance Notes: Standards of Accountability
• Accountability Check List, Minimum Standards and Accountability Planning Tool

Complaints Handling Mechanisms: An implementation guide Page 3

1. Basic Concepts

1.1 Accountability

For CAFOD, accountability means taking responsibility for listening to the needs, concerns and
views of our supporters, donors, partners and the communities that we serve. We are committed
to act on what they are telling us and to be answerable to them for the decisions we make and
the actions we take. It means that we strive to improve the quality, learning and effectiveness of
our international programmes as we place our partners and the communities that they serve at
the centre of our work. At its heart, being accountable is about how we relate to people - men,
women and children - with dignity and respect.

Handling feedback and complaints is an essential part of any organisation’s commitment to being
accountable to its stakeholders. At CAFOD we are committed to learning and improving, and
encourage partners and stakeholders to comment on the progress and effectiveness of our work.
Our feedback and complaints mechanisms support our culture of accountability enabling us to
improve the quality of our programmes and the relationships we build with partners and
communities.

CAFOD is open to receiving honest feedback and complaints, and considers them as
opportunities for learning, improving and developing. CAFOD wants to encourage staff and
partner organisations to:
• recognise that mistakes can be made and commit to learn from them
• do more than just “listen” to stakeholders, especially programme beneficiaries
• work to shift the power balance more towards those receiving assistance and support
• check that they are being held to account

CAFOD and partner staff receive and collect feedback and complaints as a regular part of
programme monitoring and evaluation activities. Often minor issues that are raised in this way
can be dealt with informally but where there is concern of a more serious nature or someone
wants to more formally report something that concerns them, then a Complaint Handling
Mechanism (CHM) will provide a safe way for them to do so, and for us to take appropriate action
in response.

An effective Complaints Handling Mechanism (CHM) can serve to hold CAFOD or partners to
account against the promises and commitments made to beneficiaries and stakeholders. It can
offer checks as to whether specified goals are being met and can provide early warnings that
things might be going wrong. From information received through a CHM, well-timed changes can
be made or decisions taken to remedy situations or mitigate against potential problems.

It is essential that any CHM works for the people it is intended for. Therefore it must be culturally
and contextually appropriate to the specific situation where programme activities are
implemented. Local forms of communication and governance structures need to be taken into
consideration when designing and implementing a CHM. If local ways to handle complaints exist,
which are effective and safe for people to use, then these can be used or can be integrated into a
CHM.

1.2 What is feedback and complaints?

Feedback is a comment or concern that can be positive or negative but does not require a formal
response. Feedback provides useful insights into how project activities are perceived or how they

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are being implemented. Feedback of this nature can be addressed informally during programme
monitoring visits or can be referred to management staff to if necessary.

A complaint is an expression of dissatisfaction about the standard or quality of assistance being

provided and is related to the actions or lack of actions taken by staff or volunteers that directly or
indirectly cause anyone distress.

Complaints are directly associated to the commitments made by an organisation, in terms of what
and how it promises to deliver assistance and give support. People on the receiving end of
assistance and support have the right to complain if standards are not being met, if assistance is
not appropriate to them or are not as promised to them by implementing organisations or there
are serious breaches of codes of conduct. A formal complaint demands a response and an
organisation receiving a complaint has a duty to respond to the complainant.

It will be the responsibility of programme staff receiving feedback and complaints to determine
how serious in nature they are and whether they can be dealt with informally verbally straight
away or if they need to be dealt with formally.

1.3 Principles

People wishing to make a complaint or raise a concern will only do so if they have confidence
that complaints will be dealt with promptly, fairly and without risk to themselves or others. The
fear of retaliation (getting back at a person for complaining) can range from a concern that they or
their community will be excluded from receiving aid by the organisation, to the fear that they will
be personally persecuted for complaining. In some situations e.g. conflict or volatile contexts, this
may be particularly acute and needs careful consideration.

To ensure that a complaints system is effective, trusted and therefore used, depends on following
some key principles:

• Participation: A successful and effective system will only be achieved if it is developed in

a highly participatory way with representatives from all stakeholder groups and if it is fully
integrated into programme activities. People, or user groups, need to be involved in each
stage of the processes from design to implementation and review.

• Contextualisation and appropriateness: Any process to develop a system must be

localised in order that it is appropriate to the local context, be in keeping with local
governance structures and fit within the specific nature of the programme being
implemented. Again this will only be achieved if the mechanism is designed in a
participatory way in consultation with its potential users and other stakeholders.

• Safety: To ensure that people are protected and are safe when wanting to raise a
concern or complaint, the potential risks to different users need to be carefully considered
and incorporated into the design of a CHM. Ensuring the safety of those using the
mechanism is essential if it is to be trusted and used effectively.

• Confidentiality: To create an environment in which people are more likely to raise

concerns, trust the mechanism and feel confident that there will not be reprisal or
retaliation if they use it, confidential processes need to be assured. Confidentiality helps
to ensure safety and protection for those making, and those affected by, a complaint.
This is achieved by restricting those that have access to sensitive information.

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 • Transparency: Users must be clearly informed how they can access the CHM, and the
various procedures that follow once they do so. It is important that the purpose and
function of the mechanism is transparent.

• Accessibility: It is essential that the mechanism can be accessed by as many people as

possible within any stakeholder group, especially those who are often excluded or are
most marginalised, or vulnerable. Where the risk of exclusion is high, special
consideration must be given to safe mechanisms that do not require literacy.

Experienced staff will recognise these principles as elements of normal good practice in
development and humanitarian work, and in many cases will already be applying them. The
purpose of establishing a CHM is to build on this good practice and formalise how complaints
are managed to ensure consistency and accountability.

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2. Consultation, Participation and Information Sharing
As we have seen in Section 1, a CHM must be clear to potential users and other stakeholders,
and culturally appropriate to the local situation. To achieve this objective staff need to involve
stakeholders and beneficiary communities in the key stages of developing a CHM through
consultation and by encouraging participation in the process. This section discusses some of the
key issues that need to be considered and makes some suggestions about methodology.

2.1 Consultation and Participation

Involving beneficiary communities and other stakeholders in any activity and decision that
impacts upon them ensures that activities are in line with needs, helps create ownership and can
play an important role in empowering people to take control of their lives. Therefore it’s important
that beneficiary communities and other stakeholders are meaningfully involved in developing a
CHM: from planning and design, to its implementation and evaluation. This means more than
simply sharing information and consulting alone; it requires us to listen to stakeholders’ views and
opinions and making adjustments accordingly. As far as possible, decisions about how the CHM
will work should be made jointly with the user groups (see Annex 2 “Participation”).

Providing a mechanism for people to complain may go against existing customs and structures,
or there might be a stigma attached to complaining. Involving users in the design process is a
good way of ensuring complaints mechanisms are sensitive to such factors. Existing power
dynamics and local governance structures within stakeholder communities need to be recognised
and understood in order that appropriate ways to make a complaint are identified to ensure equal
access to a CHM by all potential ‘users’. In challenging local power structures however, sensitivity
and diplomacy are vital, and where this is necessary CAFOD will rely on the experience of its
senior regional staff and trusted stakeholders.

Key issues to consult on with stakeholders

i. Defining a valid complaint

It is important to have clarity on what constitutes a complaint within the scope of the activities
being implemented. A valid complaint is one that relates directly to the commitments and
promises made by CAFOD or the partner and issues that are under the control of CAFOD or
partner. It is therefore essential that all staff have a clear understanding of what commitments
(mission statement, values, organisational strategies, project/programme plans and other
codes of conduct or guidelines e.g. RCCC, Sphere) have been made to beneficiaries and
other stakeholders.

Complaints or comments that relate to issues outside the control of CAFOD or CAFOD’s
partner can be referred to other agencies considered responsible, but CAFOD or the partner
cannot accept responsibility for how other institutions treat complaints.

ii. Understanding sensitive and non-sensitive complaints

A CHM needs to handle complaints on all issues from beneficiary entitlements to serious
grievances such as corruption, sexual harassment and mismanagement. In order to manage
complaints appropriately CAFOD classifies complaints into ‘sensitive’ and ‘non-sensitive’.

A non-sensitive complaint concerns the implementation of activities, decision taken, or

advocacy / policy position held by CAFOD or a partner. A sensitive complaint is typically a
complaint about corruption, sexual exploitation or abuse, gross misconduct or malpractice.
Given the risks associated with coming forward with sensitive concerns, the CHM needs to be
designed in such a way that complainants feel safe to do so. Stakeholders might have
specific ideas as to how to overcome this potential barrier which could be incorporated into
the design of the CHM.

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 By giving assurance to users that sensitive complaints will handled confidentially and without
retaliation by the organisation, a degree of protection to the complainant can be guaranteed.
It is therefore important to communicate with stakeholders about how each type of complaint
will be handled according to organisational policy and practice. A partner may have policies
already in place to manage complaints about some specific issues (e.g. fraud, corruption,
staff conduct etc) and these practices can be part of any CHM, provided they are effective
and safe for users (Refer to CAFOD’s Complaints Handling Policy and Procedures for
example of how CAFOD handles different types of complaint).

iii. Who will be the main ‘users’ of a system? The main users are likely to be the end-
beneficiaries. However the mechanism should not be restricted to direct beneficiaries but
also include potential, indirect or non-beneficiaries as they too have an interest in the work of
the organisation and are affected by it. Developing a detailed stakeholder analysis of the
stakeholder community can provide useful insights and understanding of the community
structure. From this information the CHM can be designed to ensure that all groups are
offered the most appropriate way for them to best access the CHM.

iv. What are the barriers to raising concerns / making a complaint? Potential users may
have concerns or ‘barriers’ to their willingness or ability to complain. It is essential to
understand what these are and to come up with the most effective ways that they can be
minimised or overcome. Information from the stakeholder analysis can be used to consult
with and involve a wide-range of users particularly those that are often marginalised or most
vulnerable, to ensure that all members of user-groups are able to raise a concern or
complaint safely and confidently.

While the specific form of a complaints procedure will vary depending on context, below are
some examples of how other organisations and stakeholders have approached the issue.

  Examples from other organisations

• Complaints boxes within communities where beneficiaries can make anonymous written
complaints
• An appeals process that individuals who are not selected as beneficiaries for a project can
use to challenge the decision
• An hour once a week is set aside when beneficiaries can come to an organisation’s office and
raise concerns with a member of staff assigned responsibility for handling complaints
• A phone number that beneficiaries can call anonymously to make complaints regarding the
project
• Time is set aside at the end of every community meeting where beneficiaries can voice their
concerns and complaints either publicly or privately with local staff
• A village complaints committee composed of local staff and community representatives
receives and investigates concerns/complaints from beneficiaries and decides follow-up
actions

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2.2 Information Sharing

Effective information provision can strengthen trust, build community ownership and encourage
participation. People can’t be involved in a project or service if they are not adequately informed.
Lack of information about a project is an instant block to community participation, ownership and
empowerment. Stakeholders have the right to be informed of what organisations do and how they
do it in a manner that is accessible to them. Greater transparency and information sharing can
serve to strengthen accountability between CAFOD, partners and key stakeholders, including
beneficiary communities (see “Transparency and information sharing box” below).

To ensure a CHM is effective, potential users need basic information about the organisation and
need to understand their rights and entitlements, within the scope of the programme. It is
essential to get a sense across to the communities that they have the RIGHT to complain and
that all complaints will be dealt with fairly, efficiently and as simply as possible.

It is essential to make relevant information publicly available to beneficiary communities and other
stakeholders. Communication must be clear and in an appropriate format depending on the
specific user group. It is also necessary to consult with the user groups to determine how best to
communicate essential information - language, media, literacy, location of information etc. Where
there is a high level of illiteracy in the community, oral procedures must be put in place. It is
important to regularly check that the right information is reaching the right people, and if it isn’t,
then adapt the methods being used. With the right information being communicated the CHM can
work more effectively and for its intended purpose.

Essential information to be provided to stakeholders

• Organisational background and mandate
• Objectives and timeframes of project activities
• Dates and locations of key events open to community participation
• Contact details for responsible person of implementing organisation
• Purpose and procedures for submitting and handling feedback and complaints (CHM)
• Names of donors
• Regular project progress reports and updates
• Basic financial information and financial reports

Transparency and information sharing:

Increasingly accountable programmes

1. Limited programme 2. Detailed and updated 3. Information is

and budgetary programme and supplied on the basis of
information is shared in budgetary information is what the community
an ad hoc manner with shared regularly with needs to know and is
communities and communities in a variety interested in, and in
stakeholders of ways ways that are relevant
and accessible to them

Complaints Handling Mechanisms: An implementation guide Page 9

3. Designing and Implementing a CHM
Once sufficient information has been shared about the purpose of the CHM, the different ways in
which users prefer to complain understood, and the commitments made by the organisation /
project or programme to different stakeholders identified, it is possible to design and implement a
CHM.

3.1 Main features of a CHM

The design of any CHM needs to include all the main features shown below. This flow-diagram
can be used to map-out how the complaint handling process will work within the structure of an
organisation.

3.2 Implementing a CHM

If users meaningfully participate in the design of a CHM, and it is clear to all (staff in the
implementing organisation and users) what the CHM is intended for and their own role, then
many of the potential practical difficulties in implementation can be eliminated.
The questions below (in the “Key questions” box) can be helpful when thinking through the
development of the main features of the CHM which are explained below through points A – G.

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 Key questions when designing and implementing CHM

• Information – How will you go about engaging stakeholders in the process? What information do they
need to know about you and your organisation, and what do you need to know from them?
• Culture - Is there a ‘culture of complaining’ or is making complaints taboo? Is there an existing
traditional system for complaining locally? Is it formal /informal? What does it handle and how?
• Context - Are there any conflicts in the community or further afield that could impact on the
mechanism? Are there any political issues or issues with authorities to be aware of?
• Terminology and language - Is ‘complain’ a sensitive word in the local language – do you perhaps
need to discuss what it means to them and find ways to that make sense in the local language / culture?
• Accessibility - what are the safe ways and formats for different people in the community / other users
or stakeholders to submit a complaint (written, oral, formal, informal, etc). What is the literacy rate
among men and women? How can marginal or vulnerable groups access the mechanism? What might
prevent people from coming forwards to complain?
• Location - If a central location is used for complaint submission, where would be best? Where would be
most safe and accessible?
• Trusted system - Who do people prefer to talk to? Is it acceptable for women to talk to unknown men?
Do people feel / trust their leaders? Who can children talk to – who do they trust and what would work
best for them?
• Communication methods - What communication is available and preferred by users – Written, verbal?
Do people prefer to go to a central place to complain or have people come to them?

A. Complaint Received
It should be possible for an organisation to provide several entry points and various formats
through which complaints can be submitted e.g. a complaints box; the telephone, letters, via a
trusted person, at community meetings etc. For different users there may be different options but
key to this is that each option is understood and agreed to by the users and the organisation. If a
number of entry points are provided there needs to be a clear procedure within the organisation
as to how complaints will be collated, recorded onto a centralised system and managed
consistently.

B. Processing a Complaint
The organisation needs to establish what ‘type’ of complaint it is and therefore which policy or
procedure will be used to deal with the complaint. For example CAFOD classifies complaints as
sensitive or non-sensitive (see page 7) in order that complaints are dealt with in-line with the
appropriate policy and procedure. Different types of complaint require different approaches in
handling them: if sensitive it might be necessary to carry-out a confidential investigation; if non-
sensitive the complaint can most likely be resolved more immediately with necessary changes
made in-line with programme documentation.

Once it has been decided how the complaint will be handled, the complainant needs to be given
acknowledgment that their complaint has been received as soon as possible. They also need to
be given an explanation of how the complaint will be dealt with and what they can expect from
the process. To manage expectations of people submitting a complaint timeframes for giving a
response should be established and clearly communicated to users. For non-sensitive
complaints, it would be expected that a response could be given within one working week,
whereas for sensitive complaints a longer timeframe would be expected because of more
complex investigation processes. So a clear indication of this must be communicated to the
complainant. Where possible, responses should be given both verbally and in writing, be
recorded by the organisation so that it is possible to check that a response has been given and
acted upon.

C. Review and Investigation

Complaints need to be reviewed and investigated to: determine their validity; to clearly identify
what commitment or promise has been breached; and to decide what action needs to be taken in

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response. The decision on how to investigate a complaint lies with the delegated staff
responsible for processing complaints.

For non-sensitive complaints it is typically a programme manager and field / support staff who will
review the complaint in line with programme documentation and deal with the complaint directly.
For sensitive complaints the investigation will follow appropriate organisational policies and
involve a limited number of people to ensure confidentiality e.g. for CAFOD, a complaint
concerning financial corruption defers to the Director of Finance and would follow CAFOD’s
Fraud Policy and Procedures. If the complaint is about something for which CAFOD or its partner
does not accept responsibility, it may be referred to an appropriate body or authority or another
organisation concerned.

Key considerations for those involved in investigations

• Competency: those undertaking investigations should have the ability to take the appropriate
action and / or decision and be able to enforce it.
• Transparency: for non-sensitive complaints it is important to ensure that the procedure followed is
transparent. This includes the composition of the investigating team, and the choice of the
decision-makers. Any key decisions that are made must be clearly publicised.
• Confidentiality: confidentiality is essential especially when dealing with sensitive complaints.
Information must be handled on a strict ‘need to know’ basis in order to protect both the
complainant and the person against whom the complaint is made. The detailed advice in the
CAFOD Complaints Handling Policy must be followed.
• Impartiality: the impartiality of investigators is crucial if the handling of complaints and the
response to them are to be fair. If those involved in the handling of any complaint have a vested
interest in the outcome of an investigation this will undermine the CHM and can cause further
distress or harm to those concerned.

Some serious sensitive complaints may require that investigators are trained to carry out
specialist investigations in ways that do no harm and that maintain the integrity of the CHM (e.g.
sexual exploitation and abuse cases). Where the complaint relates to a criminal or legal issue, it
may be that this cannot be handled internally but needs to be handled by the authorities or go
through the local legal processes instead (e.g. fraud and corruption cases which breach local or
national laws).

Because some investigations and responses can have far-reaching consequences for CAFOD
and/or the partner and/or the complainant, staff should consider what the risks and implications
are. Look at how prepared the complainant (and CAFOD/partner) is for the implications of the
investigation? What role will the complainant have? Will they be willing to publically say what their
concern is? Under what circumstances will CAFOD / partner or complainant want to stop or not
go further with an investigation?

Anonymous and malicious complaints or rumours can sometimes give indications to an

organisation that there are other issues that people wish to raise but may be reluctant or unable
to bring up openly, or that they have concerns about the integrity of the CHM. These can be
useful warning signals to an organisation. Refer to Annex 2 for observations on the challenges
associated with receiving anonymous, unsubstantiated and malicious complaints.

D. Response and Action

As a result of a review and investigation something needs to be put right, amended or changed in
order to improve the situation and resolve the issue. A formal complaint requires a timely
response by the organisation. It is vital to clearly communicate any findings of the review and

Complaints Handling Mechanisms: An implementation guide Page 12

investigation processes with the complainant and to keep them appropriately informed of what
actions will be taken as a result of the decisions taken. Sometimes it might be necessary to
communicate what actions will be taken with the wider community if they have also been
affected. Responses can be written or verbal as agreed with the complainant and will need to be
documented.

This feedback demonstrates that CAFOD and the partner are listening and taking complaints
seriously. It shows that the issues have been considered and appropriate action taken. It also
demonstrates to users that the CHM works and is safe to use. It can be useful to consider what
the complainant is hoping to get as a response: do they want restitution? do they want to draw
attention to the issue?

Responses may be negative or the claim found not to be proved. Or they can be positive and a
remedy offered, e.g. agreeing that someone previously not on a beneficiary list can now be
added. When the response is not accepted, it is necessary to allow the complainant to appeal the
decision. Where the issue is outside the control of the organisation, and the complaint is referred
to another, the complainant must be made aware that this has happened and told what action
was taken.

E. Appeal Process
If the response is not accepted and a resolution cannot be reached between the parties
concerned, the complainant may wish to appeal against the response. The appeal process will
re-examine the investigation process already taken and determine whether to uphold the original
decision or make a new decision based the findings of this review.

The appeals process should be clearly defined: when it can be used; how it will work and who will
be involved in it. The appeals process, where it is invoked, checks whether the initial decision or
response was appropriate. The appeal should be conducted by a different set of people from
those involved in the original investigation, to further demonstrate impartiality and safety to the
complainants and to maintain trust in the CHM. Appeals are most likely in more difficult or
sensitive cases and allow for more senior staff to re-examine the issue. If too many responses
are being appealed this may indicate that there is a problem with either the original CHM process
or with the implementation of a project, or perhaps with a staff member. It may then be necessary
to look at these factors in more detail.

F. Resolution
An agreement is reached between all parties involved in the complaint and most importantly, the
complainant is satisfied that the complaint was dealt with fairly, appropriately and that the action
taken offers a solution.

G. Tracking and Recording Complaints

In order to monitor and manage complaints received, a way of tracking and recording key stages
of any complaint is necessary. It is important to track how many complaints are received and by
whom, from where and from whom, about what, when and how the organisation has responded
to the complaint and what measures were taken. Making an analysis of this information collected
can be reviewed against programme timescales and key events to indicate trends in performance
and can help show what changes need to be considered in the future. Keeping track of the
responses can help to feed into the review process (see Section 4) and allow for learning,
adjustments to both the CHM and / or to projects, if required.

3.3 Roles and responsibilities

The roles and responsibilities of different people involved in the CHM need to be carefully defined
and communicated. Some staff will already have designated roles e.g. HR policies define who the

Complaints Handling Mechanisms: An implementation guide Page 13

first point of contact is for an internal staff issue, and these need to be taken into consideration
when designing the overall system:

• Senior management / Head of organisation – the head of the organisation has ultimate
responsibility for the CHM and they may be involved in the Appeals process. If the complaint
is against them, then there may be a need to consider external parties (e.g. the Board, or
partner organisation) as another authority in which to lodge the complaint. To avoid
overloading the head of organisation, their direct operational role should be limited

• Immediate manager to the complainant – for complaints concerning staff, the immediate
manager will usually be involved in the process but for sensitive issues, it might be
necessary to rely on senior management, HR or others

• Programme / Field staff – most non-sensitive complaints can be directly managed and
handled by staff closest to the situation. If it is about them directly or a sensitive issue,
support from more senior or specifically designated staff may be required. It is important to
consider that people, especially community members, may not be comfortable complaining
directly to staff they work with every day and it might be more suitable to them to complain to
someone more removed or senior within the programme / organisation.

• Beneficiary representative(s) – having a beneficiary or stakeholder representative involved

in the complaints process can be a positive and transparent addition, but it is important to
that everyone involved understands the authority and knowledge they hold (who do they
represent?) within a community and how this will contribute to the process and solution

• Donor or other partner NGO – an external and relatively unbiased stakeholder can add
value in terms of legitimacy and options for possible responses and action i.e. reallocation of
funds or support for the investigation.

Complaints Handling Mechanisms: An implementation guide Page 14

4. Monitoring, Reviewing and Learning from Complaints

4.1 Monitoring and reviewing the CHM system

In order to determine if a CHM is functioning as intended it is essential to build in a monitoring

and review process of the CHM itself. Monitoring should be used to track and reflect on the
complaints, the access points, the formats used, the investigation processes and the responses
given; this constitutes a check on how these different aspects of the mechanism are working, and
in particular on whether users (check which people) understand their rights, are able to use and
understand the system, and may also suggest ways to improve it. In addition, a full review of the
system should be carried out periodically to examine the system for any bottlenecks in
processing or responding to the complainant.

The CHM processes and steps can then be re-visited, approaches adapted and the system can
evolve to ensure it is serving its purpose. See Annex 4 for “Characteristics of Complaint
Handling” to assist with monitoring and reviewing CHM systems.

When reviewing a CHM, check how the following principles are working in practice:

• Participation - Check how people (users) are or were involved in designing, implementing
and monitoring the system. In particular, check that it is reaching out to the programme /
project target groups and is not discriminatory or is missing out people that you are trying to
reach, work with or protect.

• Contextual and appropriate - Check that the CHM fits and reflects the specific situation of
the programme, the context of the country, region, location and the culture where activities
are being implemented. Make sure that the CHM fits within the way that programme activities
are implemented or delivered.

• User-friendly and accessible information - Monitor that information is disseminated in a

user- friendly way and is accessible by all user groups. Check to see if user groups know
who the implementing organisation is, if they know what the programme involves and who it
is intended for, do they know how the CHM process works and how they can access it? Is
the information in the right format for the intended user group, e.g. if the programme is for
children or for more illiterate people then perhaps information represented in pictures or
diagrams. Is the language correct and easily understood?

• Transparency - Ensure that the purpose of the CHM, its limitations and how the system
works is made clear. If, for instance, many complaints are being received that are not
relevant to the programme/project, this may indicate that there is a problem with the basic
information being provided. It may be necessary to review how information is being
communicated and adjust the approach / methods use in order to make clear to users what
they can expect.

• Accessible and safe procedures - It is vital that users feel they can access the system
safely and they will not be put at risk if they use the system or suffer because they complain.
This applies to staff as well as the communities or other stakeholders.

• Respectful and dignifying - Check with users how they perceive the system, whether they
feel they are asking for ‘favours’ or acting within their rights.

• Independence, confidentiality and non-retaliation (where appropriate) - Consulting the

users on how they perceive these elements, and reviewing confidentiality processes and
checking with users that they don’t feel threatened or unwilling to use the system is essential.

Complaints Handling Mechanisms: An implementation guide Page 15

• Empowering - If an organisation can demonstrate that it takes complaints and feedback
seriously, that they listen to what they are being told and this is reflected in the way they
work, it is likely to reinforce a sense of confidence in the organisation by the users and other
stakeholders. People are more likely to continue to use a CHM when they can see that if they
speak out about the things that concern them they can have a direct impact on the situation.

• Appropriate capabilities, values, attitudes and behaviours - Check how staff perceive the
CHM. Do they value it and demonstrate this in the way they behave or work with the
community? Staff may see it as a check on them and so may not trust the system and may
not be keen to set it up or promote it within their communities. Senior management need to
also demonstrate they value the system and the learning from it.

4.2 Learning from Complaints

Reviewing the CHM assists the organisation to identify issues arising from the complaints
themselves and can provide insights into how well a programme / project is meeting its stated
objectives and how well CAFOD and that partner are implementing activities. Information
gathered from the types, nature and number of complaints can be used positively to adapt and
evolve in order to strengthen the quality of programme work.

It can also serve as an early warning of a problem with programme implementation or of an issue
with particular staff members. For example, the recurrence of the issues may indicate a structural
flaw in the programme/project. Information from complaints feed into organisational learning
processes and influence future programme planning, design and implementation.

Complaints Handling Mechanisms: An implementation guide Page 16

 ANNEXES

Annex 1: HAP Principles of Accountability

As a partnership-based organisation CAFOD has committed to improving our accountability to
our partners and to encourage and supporting partners that we work in solidarity with to
strengthening their accountability practices.

The seven HAP Accountability Principles that CAFOD are committed to:

1) Commitment to humanitarian standards and rights

Organisations commit to respect and foster humanitarian standards and the rights of
beneficiaries

2) Setting standards and building capacity

Organisations set a framework of accountability to their stakeholders (footnote).
Organisations set and periodically review their standards and performance indicators, and
revise them if necessary. They provide appropriate training in the use and implementation
of standards.

3) Communication
Organisations inform, and consult with, stakeholders, particularly beneficiaries and staff,
about the standards adopted, programmes to be undertaken and mechanisms available
for addressing concerns.

4) Participation in programmes
Organisations involve beneficiaries in the planning, implementation, monitoring and
evaluation of programmes and report to them on progress, subject only to serious
operational constraints.

5) Monitoring and reporting on compliance

Organisations involve beneficiaries and staff when they monitor and revise standards.
They regularly monitor and evaluate compliance with standards, using robust processes.
Organisations report at least annually to stakeholders, including beneficiaries, on
compliance with standards. Reporting may take a variety of forms.

6) Addressing complaints
Organisations enable beneficiaries and staff to report complaints and seek redress safely.

7) Implementing partners
Organisations are committed to the implementation of these principles if and when
working through implementing partners.

Footnote: Framework of accountability includes standards, quality standards, principles, policies,

guidelines, training and other capacity-building work, etc. The framework must include measurable
performance indicators. Standards may be internal to the organisation or they may be collective, e.g.
Sphere or People in Aid.

See CAFOD’s Accountability Framework on CAFOD CONNECT Accountability COW

Complaints Handling Mechanisms: An implementation guide Page 17

Annex 2: Benefits and Challenges

Potential benefits of implementing CHM within programme activities:

• It alerts agencies to problems with staff or with their programme implementation

• Allows agencies to rectify minor and unintended mistakes; to manage risk before it gets
too big
• Protects staff by providing them with a way to investigate issues and respond to them
• Continuous learning and improvement for both the CHM and the organisation/project
• Effective response enhances public standing as it demonstrates the organisation is
listening
• It allows for better use of resources as you can check if people are satisfied with how the
organisation is responding to them.
• Provides valuable management information – on how the project/ programme, staff and
organisation are working.

Challenges and issues of CHM in practice:

• Complaints, culture and history: how to trust the system? - complaints are seen as
different in different cultures - exploring how they do this – what are the traditional or
acceptable methods for raising issues and tapping in to this to gain the trust of the
stakeholders.
• Coverage - communicating to busy people in various situations to make sure all members
of a community are aware of their right to complain and the process.
• Clarity on what can be complained about – it is important people understand that there
are limits on what can be complained about so as to manage expectations and ensure
that the system is effective for both the stakeholders and the organisation.
• Language and literacy – translation into the ‘national’ language is often not enough as
many need to have it their local language or in pictorial formats, for illiterate community
members.
• Power imbalances within communities – whose voices counts? – In communities and
agencies, power is often not shared equally. Community committees, which are set up to
represent a community do not always do so in the fairest ways. There are also tensions
between communities and staff.
• Involving communities – setting up ‘blueprint’ systems will often not be appropriate.
Involving members of the communities in setting up a system is likely to ensure a better
system. The process of involving the community from the outset that develops a more
trusting relationship.
• Attitudes – it helps that staff with good attitudes towards communities helps with the
effectiveness of the CRM as they help build good relationships.
• Gender balance in staff – many female community members often feel more comfortable
discussing complaints with female members of staff, especially if these are over sensitive
issues so it is important to consider the gender balance of your staff group.
• Skills and training- staff need to confident in their abilities to implement and manage the
system. Training needs to be geared to their style of learning.
• Senior management commitment – is vital to ensure an effective CHM.

Complaints Handling Mechanisms: An implementation guide Page 18

Challenges: anonymous, unsubstantiated and malicious complaints

• Some allegations may not satisfy the formal requirements of ‘complaints’ as they lack
crucial information. However, failing to act when there is a suspicion of breach of policy or
abuse may be a violation of an organisation’s duty of care. In such circumstances an
initial investigation may be required to trace an allegation back to its source. There may
be a victim or witness to talk to about the possibility of bringing a complaint or blowing the
whistle.
• It may be possible to investigate anonymous complaints, where the victim/complainant is
not known, if there is sufficient background information and/or good leads to witnesses
who can give strong testimony about the alleged abuse. It is important to treat anonymous
complaints seriously because of the potential for future abuse and harm, and our
responsibility to create a safe and abuse-free environment. A more difficult issue is how to
deal with rumours, such as allegations that are common knowledge but have not been
submitted as formal complaints.
• In some cases, potentially malicious (nasty or untrue) or unsubstantiated complaints may
be made by people who feel angry or upset by something an organisation – or people the
organisation is involved with – has done or not done. Again, these types of complaints can
be very damaging if they are not dealt with and managed carefully. They must be
investigated sensitively and a response given or it is likely that the complainant will
continue to undermine the work of the organisation.
• Anonymous and malicious complaints or rumours can sometimes give indications to an
organisation that there are other issues that people wish to raise but may be reluctant or
unable to bring up openly, or that they have concerns about the integrity of the CHM.
These can be useful warning signals to an organisation.

Complaints Handling Mechanisms: An implementation guide Page 19

 Annex 3: Participation

As far as possible decisions at a programme or project level should be made jointly with the
beneficiaries and key stakeholders as appropriate. This helps to generate ownership of the
activities and builds trust between the implementing organisation and beneficiary communities. A
high level participatory approach can empower beneficiaries to coordinate projects themselves,
with the organisation playing a supporting role.

Increasingly accountable programmes

1. The communities 2. Communities are 3. Communities and 4. The communities

are informed of the consulted at the start of the NGO jointly take the initiative,
project activities but the project and provide undertake the act independently of
have not been information that is used analysis of needs, external actors.
consulted by the NGO to design it programme NGOs support in the
and implement it; conception and process but the
however communities do design. The community initiate,
not have any influence community also has design and
over the process or decision making implement the

Key monitoring points of participation in the programme cycle:

1. The organisation has involved community members in processes used to develop

selection criteria, identification and final selection of beneficiaries

2. The community have been given opportunities to influence design of the project,
implementation, monitoring and evaluation mechanisms

3. The majority of beneficiaries know what opportunities there exist to participate and
feedback on the project

4. Vulnerable and marginalised groups have been given opportunities to participate in

the project

5. The community feel a sense of ownership and responsibility over the project

Complaints Handling Mechanisms: An implementation guide Page 20

 Annex 4: Characteristics of complaints handling
 

Increasingly accountable programmes

1 2 3 4
No formal system; Communities are informed Basic formal mechanism in Formal mechanism for
Characteristics

Informal complaints dealt as to their right to give place though with minimum complaints and feedback
with on an ad hoc basis feedback on a programme, community consultation; operational and is
and are not well including complaints, and feedback is encouraged effective, accessible and
recognised within the are offered at least one way safe and designed with
organisation of providing such feedback full consultation with the
though this may be informal communities

• Informal handling of • Verbal complaints to • Formal policy in place • The organisation has
complaints project staff • Training for staff an established and
• No staff • Some guidance and • Awareness of the need documented
Practices

guidance/training on support to staff for confidentiality complaints handling

how to handle • Feedback through • Communication plan for procedure
complaints community committees community • Implementation plan
• Many complaints not • Complaints mechanism for staff and
dealt with to accessible to majority of beneficiaries
conclusion the community
• Variety of feedback
mechanisms
• No records of • Community making • Policy includes the right • Full CRM in place
complaints complaints informally to complain; how to and functioning
What you might see

• Project design changed complain; what happens • Implementation

as a result of informal as a result plan and progress
feedback • Staff guidelines reports against it
• Some written evidence • Evidence of complaints • Documented
of discussion of records and feedback to complaints records;
community feedback/ the community written responses
complaints (minutes of • Good community • Evidence of
team meetings) information reflection on the
• Community feedback analysis of received
meetings complaints and
subsequent changes
to ways of working
• Training records
• Frustrated local • More than 50% of • Greater engagement • Beneficiaries,
What you might

community community know who of community communities and

• Community have to speak to if they • Most people know that staff are aware of
little/no awareness have an issue they can complain and the procedures and
of how to raise a • People unsure of what feel confident in the have confident in
find

complaint or give will happen as a result system its integrity and

feedback of raising a complaint • Most people know the effectiveness
• Community don’t • Staff feel they handle process of how to
feel engaged in the complaints as part of complain and what will
project their daily job happen to their
complaint

Complaints Handling Mechanisms: An implementation guide Page 21

Annex 5: Useful Tools
 

• Danish Refugee Council’s Handbook on Complaints Mechanisms

http://www.drc.dk/relief-work/humanitarian-accountability-framework/complaints-mechanism-
handbook

This handbook is a very comprehensive guide to CRMs. It contains a very detailed step by step
guide (Chapter 3; p.41) leading the practitioner through a process of generating support for the
CRM to setting it up. Useful tools to use in discussion and analysis to guide the development of a
CRM system are available.

• World Vision’s Community Complaints Cards

http://www.hapinternational.org/pool/files/wv-sri-lanka-community-complaints-handling-cards.pdf

This exercise is simple way to involve the community in establishing what they would like
community complaints mechanism to look like. The cards provide a means of prompting
discussion about different aspects of a complaints mechanism such as the need for a
mechanism, access of the mechanism to different groups within the community and the
processing and handling of complaints by an agency.

• The Guide to the HAP Standard, Tool 26: Points to remember when implementing a
complaints handling mechanism (Annex 3; p217)
http://www.hapinternational.org/pool/files/hap-annex-3.pdf

This 2 page table has some key points to keep in mind when implementing a CRM.

• The Good Enough Guide

http://www.ecbproject.org/pool/good-enough-guide.pdf

What difference are we making? How do we know? The Good Enough Guide helps busy field
workers to address these questions. It offers a set of basic guidelines on how to be accountable
to local people and measure programme impact in emergency situations.
Its ‘good enough’ approach emphasises simple and practical solutions and encourages the user
to choose tools that are safe, quick, and easy to implement.

Complaints Handling Mechanisms: An implementation guide Page 22

 Annex 6: Case Studies 
A complaints and response mechanism in action
Medair responded to the Kashmir earthquake in October 2005 with emergency shelter and non-food items.
The team soon realised that it needed a mechanism to address constant queries and complaints. One hour
a day was dedicated to dealing with complaints at the main project base. This was the only time that
Medair would receive complaints. A complainant could speak to the administrator or office manager. If
possible, complaints were resolved informally. Otherwise, office staff completed a complaints form and
passed this to an assessment team in the field. Complaints about staff members were investigated by the
project manager at each base.

Most complaints came from earthquake survivors who had not received a shelter. They also came from
people outside Medair’s own project area. In those cases, Medair lobbied the responsible agency.
Sometimes, if nothing happened, Medair provided help itself. If a complaint investigated by an assessment
team was upheld, the beneficiary received assistance, depending on Medair’s resources.

A spreadsheet recorded the numbers of complaints from each village, and how many complaints had been
dealt with. This enabled project staff to assess progress and to integrate complaints into project planning.
By the end of the emergency phase, Medair had dealt with approximately 1,600 complaints, 70% of all
those it had received. Not all complaints could be investigated because by March 2006 Medair had used up
its project funds. Checking more households would raise false expectations. Also, 5 months after the
earthquake, most homes had been rehabilitated. Of the complaints investigated, 18% were upheld.
Complaints about staff led to dismissal for 3 individuals who had given preferential treatment to their tribal
or family members.

The complaints mechanism saved Medair teams significant time in both field and office and in identifying
gaps in coverage. By using this mechanism, Medair helped 290 families whose needs would otherwise
have been overlooked. Medair was new to Pakistan and the complaints and response mechanism helped
to compensate for limited local knowledge. By the end of the project, communities would contact Medair
about any discrepancy they saw in its distributions, confident that the agency would take appropriate
action.

From: written communication with Robert Schofield and John Primrose, Medair (adapted). (ECB Tool 12)

Tearfund - Beneficiary reference groups

Tearfund ran emergency programmes in Northern Kenya for pastoralists affected by drought. The
programmes stressed the importance of community participation. But they were challenged by villagers’
reluctance to speak publicly, and by conflicts of interest among local committee members involved in
identifying beneficiaries.

Tearfund established Beneficiary Reference Groups (BRGs) in ten communities. They were composed of
respected youth, women, elders and church volunteers who were not part of any Tearfund committee.
They acted as their community’s ‘eyes’, receiving local questions, feedback and concerns, and working
with staff from Tearfund and other NGOs to address issues swiftly. Tearfund discovered that the BRGs
played a pivotal role in enhancing participation and transparency during the emergency programme.
Because the BRGs did not control resources, they could help ensure that beneficiaries were identified
fairly, and also support conflict resolution.They allowed Tearfund to hear the views of the more vulnerable
groups, as well as overall community feedback on how Tearfund was perceived.

Source: http://www.hapinternational.org/pool/files/tearfund‐north‐kenya‐programme‐ncreasinglevels‐
of‐participation.pdf

Complaints Handling Mechanisms: An implementation guide Page 23

 Christian Community Services Mount Kenya East (CCSMKE); 2009

A Station Development Committee (SDC) is a group of community stakeholders made up of the religious
committee, community members, relevant government line ministries and other development actors, selected to
represent the community. In the past CCSMKE had engaged with SDCs for consultation and planning, but had
not explicitly identified their role in project implementation. There was a need for systematic community
involvement throughout the project cycle and as part of their action plan, the use of existing community structures
were reviewed by CCSMKE staff to ensure direct beneficiaries had a voice. In 2008-9, in response to the drought
in Northern Kenya, an emergency program was initiated by CCSMKE in Sololo. The inclusion of a community
accountability process through the SDC was a central part to the project design stage. Isaiah Oba, CCSMKE
project coordinator observed that ‘downward accountability has made our work easier. Community members
and SDCs are now the custodians of the projects. Because they know the budgets, they monitor the
whole process from tendering to implementation and evaluation to ensure value for money’.

Organisational changes

These small steps have led to much wider organisational changes through a process of piloting and reflection.
The benefits of better downward accountability have been so strong and visible that it has triggered a change in
the organisation’s process of project management. This includes the following:

Planning
The Board of Directors make a decision to engage communities at project inception, which is communicated to
the relevant SDC. The SDC invites stakeholders to discuss the proposals and to participate in a needs
assessment where communities are able to identify their problems, resources and possible solutions.
Programme technical staff facilitate the prioritisation of the problems and plans by the community to design their
intervention strategy. CCSMKE management forward this for presentation to the Board and partners.

Monitoring
Monitoring is carried out by the SDC every quarter and as well as when issues arise through site visits and
review of narrative and financial reports. CCSMKE’s Central Coordinating Office and the specially constituted
monitoring committee of the CCSMKE Board also regularly monitors the progress of the project through periodic
visits to the stations and projects sites, reports, updates, interactions and internal audit.

Evaluation
The Mid-term and end-term evaluations process involves partners, government, church and community
representatives who visit project sites and interact with beneficiaries. During the process the community is duly
informed of the visits and allowed to air their concerns with the evaluation team. Observations of the team are
shared with the SDC and technical staff and later with the Board, partners and the communities.
 

Source: Christian Aid 

Complaints Handling Mechanisms: An implementation guide Page 24

Annex 7: Investigations

CAFOD has a set of guidelines for use when investigating allegations against a member of staff.
The guidelines may be useful for other investigations, but their primary purpose if for investigating
allegations made against CAFOD staff members.

In CAFOD the principles of investigations are:

ƒ Impartiality
ƒ Swiftness
ƒ Dignity
ƒ Separation of investigation and disciplinary decision making

In CAFOD, investigations are undertaken to establish the facts of an allegation. Allegations could
stem from a number of things, such as a complaint from a partner or beneficiary about a CAFOD
staff member, a complaint from a supporter in England and Wales about a CAFOD staff member,
an allegation of misconduct or a grievance against a staff member by either another member of
staff or an external party. Investigations can only be initiated in line with the relevant policy,
depending on the issue e.g. for a complaint by a beneficiary the relevant policy is the Complaints
Handling Mechanism, for an allegation against a staff member the relevant policy will be either
the grievance or disciplinary policy.

In all cases investigations will be as a result of the actions set out by the relevant policy. If
conducting an investigation under the disciplinary or grievance policy the relevant HR Adviser
must be involved from the outset.

The purpose of any investigation is to establish whether there is evidence to support an

allegation that has been made against a member/s of staff. This is done through gathering all the
relevant facts by checking appropriate records, collecting relevant documents and, if appropriate,
taking statements from any witnesses or anyone else who may have a bearing on, or pertinent
knowledge about, the matter.

Investigations are conducted by an investigator or investigations team who report to an

investigation manager. The investigation manager commissions the investigation and is usually
the disciplinary decision maker.

Following an investigation, the investigation report is submitted to the disciplinary decision maker
for a decision on what action is to be taken if any.

CAFOD has a small number of experienced investigators for particular types of investigation.
Refer to Human Resources in the first instance when looking for an investigator.

The investigation guidelines can be found in CAFOD People on the Ask HR page of connect.

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