PURPOSE OF THIS POLICY
The purpose of this policy is to increase the level of client and stakeholder satisfaction and
confidence with the work of Women’s Aid Organisation (WAO) by being receptive to complaints and
resolving them in an efficient, effective and professional manner.
WAO seeks to maintain its reputation as an organisation who undertake high Quality and accountable
work, provide the best possible service and are responsive to the needs and concerns of our clients
and stakeholders.
1.0 Scope
This policy applies to all WAO clients, staff (full time, part-time and contract), volunteers,
members, donors, supporters, other stakeholders and the public.
The WAO ‘Code of Conduct’ requires all staff, volunteers, members, donors, supporters or any
individual working with or representing WAO to report allegations, concerns or suspicions of
breaches related to abuse, exploitation, fraud and corruption.
A complaint for the purpose of this policy is a specific grievance linked directly in which WAO
failed to apply, enforce or otherwise implement the principles and commitments enshrined in WAO’s
policies and procedures and where a response or resolution is explicitly or implicitly expected by
the person or organisation that lodged the complaint.
2.0 Key definitions of complaints and it’s applicability
2.1 Sensitive complaints
All complaints are serious and ‘sensitive’ complaints are those relating to allegations of sexual
exploitation and abuse, fraud and corruption or other gross misconduct. Sensitive complaints that
involve sexual matters are channelled to and handled in accordance with the WAO Policy on
Harassment, Abuse and Other Conduct. Where there is a conflict (if any) between this Policy and the
WAO Policy on Harassment,
Abuse and Other Conduct, the latter shall prevail. WAO also takes into account among others the
Generic Victim Assistance Referral Pathway of the UN and adapts the Guidance Note on Communicating
Protection from Sexual Exploitation and Abuse [PSEA] Mandatory Reporting for Gender- Based Violence
Case Management Services in WAO’s Disclaimer Form in Appendix 0 found at page 55 to 58 of the WAO
Case Management SoP.
2.2 Anonymous complaints
WAO recognizes that at times people with genuine concerns cannot speak out because of special
circumstances and may wish to lodge a complaint without revealing their identities. As a principle,
WAO does not accept anonymous complaints as it makes it difficult to assess the reliability of the
complainant and the accuracy and credibility of the facts and evidence on which the complaint is
based. In exceptional cases, WAO may give consideration to anonymous complaints and will seek
further information if there are grounds for further action.
2.3 Malicious complaints
Investigation on complaints that are filed with malicious intent and with the intention of harming
someone must be stopped and the subject of the complaint is cleared when such malicious intent was
found to be true.
Complaints lodged for genuine reasons that are subsequently considered to be unfounded shall not be
treated as malicious.
3.0 Guiding principles for complaints handling
WAO considers the following guiding principles for efficient, effective and professional complaints
handling –
3.1 Confidentiality
Confidentiality is critical to a satisfactory outcome in order to protect the privacy and safety of all
concerned. Personally identifiable information concerning the complainant is actively protected
from disclosure. The nature of the complaint, its facts, the identity of the complainant or alleged
survivor, witnesses and the subject of the complaint as well as investigation records are dealt
in a confidential manner.
Disclosure is permitted when:
1. Specific permission was given by the complainant
2. It is required by law
3. It is needed to obtain specialist help for the complainant, victim or survivor or advice on the
evidence (with the permission of the complainant)
3.2 Non-retaliation
It is the right of all beneficiaries/staff/volunteers/stakeholders to complain. Any attempt of
retaliation against the complainant is considered gross misconduct and disciplinary action will be
taken against such behaviour.
3.3 Objectivity
Every complaint is addressed in an impartial, equitable and objective manner.
3.4 Safety and Welfare
The safety of the complainant, alleged victim or survivor, witnesses, subject of the complaint and
staff is paramount. A risk assessment must be carried out for each complaint, and safety and
welfare precautions must be considered before proceeding to deal with the complaint.
4.0 Procedure for lodging a complaint
4.1 Who can complain?
WAO will accept complaints from any individual or entity as long as it is submitted in good faith
and without malicious content.
4.2 How to complain?
Complaints can be filed by the following means:
a. Complaint boxes which are located in Refuge, CCC, Services Centre and WAO Headquarters. The keys
to these complaint boxes are held by the President of WAO (or such other persons designated by the
Executive Committee (EXCO)) and the boxes are opened at the beginning of every week on a working
Monday. If the Monday is not a working day, the boxes shall be opened on the next following working
day.
b. Complaints can be addressed to the HR Executive by means of making an appointment to meet or via
email and telephone calls.
C Complaints can also be addressed to the Executive Director or any member of the
EXCO.
d. Written complaints can be emailed to this email feedbacks.wao.org.my or mailed
to WAO’s registered address.
5.0 Investigation Process
5.1 Within 2 working days, the person receiving the complaint must inform the Executive Director,
the President/Vice President/Secretary or the HR Executive depending on the nature of the
complaint. For example, if the complaint is against the Executive Director, the person who received
the complaint shall inform either the President/Vice President or Secretary or the HR Executive.
5.2 The Executive Director upon receiving the complaint shall inform the President/Vice
President/Secretary of the complaint.
5.3 The HR Executive upon receiving the complaint shall inform the Executive Director and if the
complaint is against the Executive Director, the HR Executive shall inform the President/Vice
President/Secretary.
5.4 The President shall then inform the EXCO of the complaint.
5.5 The Executive Director and EXCO shall put in place appropriate temporary measures to prevent
further harm which can include the following:-
5.5.1 Instructing the accused to take temporary paid leave or unrecorded leave while investigation
takes place.
5.5.2 Granting the complainant or victim/survivor temporary paid unrecorded leave if necessary and
facilitate counselling (or related service) for the victim/survivor.
5.5.3 Any other measures required by law.
5.6 Within 5 working days after receiving the complaint, an Investigation Panel must be formed and
initiate investigations. The panel must comprise at least the following:-
– A member of the EXCO
– The Executive Director
– The HR Manager or HR Executive.
5.7 If any of these persons are the accused or complainant, the EXCO shall appoint a suitable
replacement.
5.8 The EXCO may appoint any other persons apart from the above to assist in the investigation e.g.
if an expert is required.
5.9 The investigation steps should include the following, if possible (not necessarily in this
order):-
– Interviewing the complainant. If the complainant is anonymous and if the EXCO views the
complaint as serious and of importance to the integrity or operations of WAO, the Investigation
Panel shall make the effort to communicate with the complainant to gather more information on the
complaint.
– Interviewing the victim/survivor (if different from the complainant)
– Interviewing the accused
– Interviewing any other witnesses
– Examining any other evidence.
6.0 Concluding the investigation
Within 4 working days after the complaint has been received, the Investigation Panel must conclude
their investigation and submit the investigation report to the EXCO. The report should include:-
– Opinion and comments on the complainant’s report
– Recommendations on actions to be taken on the accused (e.g. oral/written warning, suspension,
dismissal, counselling etc), remedies for the complainant / victim / survivor, suggested changes to
WAO policies and any other measures.
– Summary of investigation.
6.1 Within 21 days after receiving the complaint, the EXCO shall deliberate and decide on the
recommendations in the investigation report and ensure that the recommendations are carried out.
7.0 Filing
All complaints documents, records or evidence shall be filed and kept by the HR Executive and kept
confidential.
