Complaints Mechanism Handbook 2008

Chapter 1 INTRODUCTION | 3
CHAPTER 1a - INTRODUCTION
INTRODUCTION
Offering beneficiaries a channel through which they can provide feedback and raise
complaints about the assistance they receive is generally regarded by humanitarian
agencies as an important part of being accountable. In spite of this, a complaints
mechanism (CM) understood as a formalised system addressing grievances is a
relatively new concept within the general humanitarian sphere.
A CM seeks to provide a safe opportunity to raise valid concerns and to have con-
cerns addressed objectively against a standard set of rules, resting in the values
and commitments of the agency.
For many agencies, the setting up and running of a CM in a humanitarian context
brings with it a new manner of interaction between the agency and its beneficiar-
ies. One consequence of setting up a CM is often a more extensive and proactive
approach to the way in which programme objectives and agency commitments are
communicated to the beneficiary population.
However, this usually implies an adaptation of the existing system, rather than the
setting up of something entirely new. To add value to the programme and for the CM
to have the best chances of success, it should integrate existing practices, such as
beneficiary involvement and communication strategies, that are already present in
the programme. To the extent possible, the CM should build upon local structures
and systems of addressing complaints and dealing with grievances. In the eyes of
the user, this will facilitate and strengthen the legitimacy of the mechanism.
In some contexts, a formal system managed by an unbiased stakeholder forms the
most proper system. In more traditional contexts such as clan-based societies, other
models might prevail and be regarded as legitimate. Given the differences from one
operation to the next, one standard CM cannot be developed to fit all programme
contexts. Issues such as literacy levels, the type of assistance offered, protection
gaps, the culture of dealing with grievances, available resources, security levels,
agency operational approach etc. all influence how a CM should be designed, man-
aged and communicated.
Objective of the handbook

The main objective of this handbook is to offer practical solutions to the challenge of
setting up and managing a successful CM. The handbook provides a Step by Step
guide, including a number of practical tools and exercises to facilitate the process,
and it contextualises the concept of a CM and presents some of the added values
and opportunities that a CM offers in a humanitarian context.
As the local context needs to be carefully analysed in order to succeed, the hand-
4 | The Danish Refugee Council COMPLAINTS MECHANISM Handbook 2008
book does not offer a catch all solution. Rather, it helps the user to design a tailored
CM through prompting necessary questions and offering different solutions.
The handbook is based on a set of minimum requirements that need to be observed
by agencies in order to ensure that the CM is of a satisfactory quality and that the
resulting benefits are materialised. By setting a minimum standard, a common un-
derstanding of the concept of the CM and a certain quality level are guaranteed.
This will allow users, donors and host communities / authorities to know what they
can expect when the agency claims to have a CM. It will also enable the agency
to monitor, and hence document, that the minimum requirements presented in this
handbook are met.
Another reason for working with minimum standards is to ensure the protection of
beneficiaries. A poorly designed and managed CM has the potential to endanger
those it was intended to benefit and protect. This is especially the case when work-
ing in contexts where the safety of the individual is at stake, and / or when the safety
of the individuals or the group rests on the fact that the subject of their complaint re-
mains confidential. Disrespect for the basic confidentiality of the complainant could
result in the leaking of sensitive information and the deterioration of the complain-
ant’s situation.
How to use this handbook

Due to the difference in programme contexts, and hence the difference in the steps
required to set up a CM, not all the Tools and Annexes presented here will be of
universal and equal importance. In terms of the intended audience of the hand-
book, there are roughly three groups of readers, with the following predicted levels
of interest.
The newcomer, or those curious and simply wishing an introduction to CMs, would
benefit from reading through the documents presented in Section 2.
The practitioner, who is about to establish a CM. The practitioner is advised to read
Section 2, and subsequently progress to the Step by Step guide in Section 3 and
the relevant Tools and Annexes presented in Sections 4 and 5. Section 3 includes
recommendations on how best to involve agency staff and users of the CM in its
design and management.
The manager of a CM already in place, who may wish to identify weaknesses and
make improvements to his agency CM. For the manager, it may prove relevant sim-
ply to skim through the Tools documents in Section 4 for inspiration and to read one
or two of the concrete steps addressing their specific issue of interest.
Throughout the handbook, references to other documents are made as chapter
references followed by code reference. This means that a reference made to, for
example, the Tool on mapping complaints, will read “Tool 4C”. Please refer to the
complete introduction of the Tools and Annexes in the next chapter.

All material contained in this book is available in the attached CD-ROM, including
Tools, Annexes and a PowerPoint presentation relevant for workshops. The web-
page www.drc.dk/cm will provide an opportunity to find lessons learned from other
contexts.
Copying of the material in parts is allowed against proper reference.
How this handbook was developed

The handbook has been developed by Danish Refugee Council (DRC). Through-
out the process, the Humanitarian Accountability Partnership (HAP) has been con-
sulted in order to ensure compliance with the minimum requirements under the
HAP principles. It has been developed on the experiences from DRC’s international
programme portfolio, consultative talks with various key informants and recommen-
dations generated, for example, from a workshop facilitated by DRC and HAP in
2006.
Initially, the material was made to facilitate the establishment of CMs in all DRC
international projects due to the lack of a concrete “How to” guide. Following exten-
sive interest shown by other agencies and stakeholders, however, the material was
adapted for a wider audience of humanitarian agencies.
Feedback – please!
Has the last been said with the development of this handbook? No. To date, the
handbook constitutes a first effort to draw up an easy and practical guide, but as the
tools and exercises are tested more thoroughly in the field, elements and sections
will need to be changed and improved. There are some shortcomings in this mate-
rial, most notably the absence of a database to manage complaints and from which
statistics can be generated. Such has yet to be developed.
For these reasons, you are encouraged to share your experience and advice both in
terms of using the handbook, the resulting documents that you have developed and
in suggesting improvements for the material. You are also welcome to share own
best practises and tools. Please provide your input and feedback at [email protected]. The
material remains in working progress, and updates will be available through DRCs
website, www.drc.dk/cm.
On behalf of DRC, I would like to express my sincere thanks to everybody who have
provided input and support for the development of the “Complaints Mechanisms:
Handbook on how to set up and run a Complaints Mechanism in the field”.
Happy reading and good luck with the development of your CM.
Christian Jacob Hansen

Danish Refugee Council,
Copenhagen, October 2008
chapter 1b - iNTRODUCTION
THE FIVE sections OF THE HANDBOOK
This handbook has been developed as a step-by-step description, taking the user
through a simple and straightforward process of identifying and answering the key
questions necessary for setting up a CM in humanitarian contexts. It consists of five
main sections, as follows:
Introduction
Reference Material
Step By Step Description
Tools and Annexes
» 1. Introduction: An introduction to the handbook (1A) followed by a more thorough

presentation of the Tools (1B).
» 2. Reference Material: Background to understanding the CM in a wider context.
In addition to introducing mainly programme staff with a general view of various
aspects of a CM, this section is also relevant for HQ staff, donors and members
of the general public interested in knowing the basic elements of a CM. 2C links
the HAP Benchmarks with relevant sections of the handbook.
» 3. Step by Step:The main document for the practitioner.This takes you through 11
Steps and will lead you through a process from generating support for the initia-
tive to answering all the relevant questions in relation to setting up a CM.
» 4. Tool Box: The Tools constitute a number of concrete techniques for use with
the Steps in Section 3. Where relevant, the Tools will be referred to in the Step by
Step description.
- Tool 4A The Concept of Complaining in Perspective. This is a small exercise

to introduce and demystify the concept.
- Tool 4B Choosing Sectors. A Tool to analyse a project’s components within a
country programme, in order to identify which sectors should become sub-
ject to a CM.
- Tool 4C Mapping Complaints. A brainstorming exercise that provides rough
impressions about potential complainants and complaints.
- Tool 4D Setting up a Complaints Handling System. Describes necessary
considerations to take when designing a complaints handling system.
- Tool 4E Suggested Indicators, Means of Verification and Activities. Matrices
providing inspiration for concrete indicators, means of verification and activi-
ties in order to comply with minimum outputs.
- Tool 4F Presentation of Complaints Mechanism, including guide. A Power-
Point presentation and a guidance note for the facilitator prepared on the
basis of Reference 2A.
» 5. Annexes: The Annexes are developed to facilitate and support the process of
undertaking the Step by Step process. The Annexes are referred to, when rel-
evant.
- Annex 5A Choosing Sectors. Template to be used with Tool 4B.
- Annex 5B Mapping Complaints. Template to be used with Tool 4C.
- Annex 5C Who will have Access to Complain? Template to be used with
Step 3.
- Annex 5D User and Appeals Matrix. Template to be used with Tool 4D.
- Annex 5E User Entry Points for Complaining. Template to be used with Step
5.
- Annex 5F Complaints Form. Suggestion for a format to be used for non-
sensitive complaints.
- Annex 5G Means of Communication as per Potential User. Analytical tool to
identify best possible means of communicating to different types of users.
- Annex 5H What to Communicate to Users. Exercise to generate information
relevant to communicate in the local context (group exercise).
- Annex 5I Developing an LFA. Template to develop an LFA for the complaints
mechanism.
On the next page, please find a complete list of the 11 Steps to take to develop a
CM, linked to relevant Tools and Annexes.
• Objective: To define the purpose and ensure that those involved have the
right understanding of the objectives of the CM.
Step • Output: Preliminary list of points why the agency wishes a CM
1 • Tools: Tool 4A – The Concept of Complaining in Perspective
Tool 4F – Presentation of Complaints Mechanism incl. guide
Annex 5I – Developing an LFA
• Objective: To define what constitutes a valid complaint that the agency will
accept by analysing complaints raised against the agency and its activities.
• Output: Map the type of complaints, complainants, aspects of relevance etc.
Step
• Tools: Tool 4B – Choosing Sectors
2
Annex 5A – Choosing Sectors template
Tool 4C – Mapping Complaints
Annex 5B – Mapping Complaints, template
• Objective: To identify the stakeholders who should have access to use the
Step CM, through analysing who is affected by the agency’s activities.
3 • Output: List of stakeholders who will have access to complain.
• Tools: Annex 5C – Who will have Access to Complain
• Objective: To design the systems capable of handling the different types of

complaints and complainants (the Complaints Handling System).
Step
• Output: CHS design, and a table of entry points and the appeals structure.
4
• Tools: Tool 4D – Setting up a Complaints Handling System
Annex 5D – User and Appeals Matrix
• Objective: Based on analysis of the local context, to decide how and

through which entry points the user of the CM should be able to submit
Step complaints.
5 • Output: List of different complaint entry points and how complaints should
be made.
• Tools: Annex 5E – User Entry Point Analysis
• Objective: To decide in which form the complaints can be submitted – writ-

ten and/or verbal – and relevant information to be conveyed when com-
Step
plaining.
6
• Output: Draft Complaints Form(s)
• Tools: Annex 5F – Complaints Form
• Objective: To describe the internal agency cycle that the complaint under-
Step
goes from receiving the complaint, processing and responding.
7
• Output: A map / description on the Complaints Processing Cycle.
• Objective: To decide on the procedure and persons to investigate com-

Step
plaints, especially in terms of sensitive and non-sensitive complaints.
8
• Output: Considerations made on how to investigate complaints.
• Objective: To consider how and what to communicate when responding to

Step
complaints.
9
• Output: Input for consideration.
• Objective: To decide on what and how to communicate to the users of the

Step CM in terms of making an information campaign.
10 • Output: A description of what and how to communicate.
• Objective: To develop an LFA summarising how the CM respects the mini-

Step mum requirements related to the establishment and running of a CM.
11 • Output: An LFA.
• Tools: Annex 5I – Developing an LFA.
Chapter 2 REFERENCE Material | 11
CHAPTER 2a - Reference material

complaints mechanism concept paper
While many humanitarian programmes almost daily are receiving complaints and
providing feedback, a CM as a formalised system is a relatively new concept. The
access for beneficiaries to provide feedback and to complain about the assistance
provided is nowadays regarded by humanitarian agencies as an important part of
their accountability. Some agencies have tried to address the issue of complaints
handling in a more formalised manner, but with the inclusion of Complaints Mecha-
nisms (CMs) under the Humanitarian Accountability Partnership (HAP) Principles of
Accountability, an additional step has been taken to enable beneficiaries and staff to
report complaints and seek redress safely as a means to strengthen accountability
based on minimum standards.
This concept paper contributes to the effort of introducing CMs to humanitarian pro-
grammes by ensuring a basic mutual understanding about various considerations
that need to be made when establishing a CM. This paper consists of 5 parts.
» 1.Definition of a Complaints Mechanism. The definition of a CM, presented and
analysed in comparison with the relevant HAP principles. The definition of a CM
is presented, and introduced.
» 2.What are the benefits ofa Complaints Mechanism? A closer look at a CM,
conceived of as a formalised set of rules (as opposed to mere feedback), and
examination of some of the opportunities and positive aspects presented when
making a CM.
» 3.What are the risks of a Complaints Mechanism? A closer examination of the
risks and potential challenges in setting up and managing a CM.
» 4.General characteristics of a Complaints Mechanism. An introduction to the
general considerations necessary to make, 1) prior to the establishment of a CM,
2) when the complaint is filed, 3) when the complaint is processed and 4) when
redress/response is provided, and finally 5) with respect to the elements to be
learned from the complaints processing.
» 5.Three examples of Complaints Mechanisms. An introduction to three types of
CMs in order to illustrate the variety and differences worthy for consideration in
different contexts.
1. Definition of a Complaints Mechanism

As part of the effort to strengthen accountability to beneficiaries, a number of hu-
manitarian agencies joined HAP in 2004. Membership of HAP is binding in the sense
that members commit themselves to abide by the Principles of Accountability.

The HAP principles are related to aspects of beneficiary accountability and are for-
mulated fairly generally, but supported by concrete Benchmarks. In accordance with
Principle 6, members enable beneficiaries and staff to report complaints and seek
redress safely. The implication of this principle is described more thoroughly under
Benchmark 51 . The HAP initiative is one among others focusing on complaints.
The development of a definition of a CM via this material has been guided by and
inspired by other initiatives, including considerations about what is practical and
manageable in the field. Based on these analyses, one definition applicable for all
CM has been developed:
Simple procedures and mechanisms that give users access to safe means of
voicing complaints on areas relevant and within the control of the agency.
Yet with this definition, a number of aspects need to be clarified. The wording em-
phasises the need for the mechanism and its procedures to be simple. It is implicit
in the definition that beneficiaries have access to voice complaints and that by voic-
ing complaints, the complainant will have redress / a response. In addition to the
beneficiaries having access to complain, it needs to be decided and defined who
else has access to use the CM. As a matter of principle, stakeholders should have
access to complain as they can be affected by the agency’s work. In this context,
the stakeholders who form the class of potential beneficiaries, donors, NGOs, host
communities, agency staff members etc. are among those relevant to consider.
Furthermore, the definition of the CM highlights that the complaint must be both
relevant and within the control of the agency. These elements are logical, as a com-
plainant would not be interested in filing complaints on issues that the agency nei-
ther can nor will change. This limitation, though, increases the need for clarity in the
scope of the CM and of informing beneficiaries about possible limitations of the
CM.
In order to make the definition more concrete, it has been translated into four more
concrete outputs. The following outputs are mandatory to comply with and are intro-
duced more thoroughly throughout the Step by Step description:
Outputs
1.The procedure, purpose and parameters of the CM have been communi-

cated and made available to relevant stakeholders.
2.Intended users have safe and easy access to use the CM.
3.Logical and easily-understood procedures are developed for submission,

processing and response / redress of complaints.
4.Complaints are processed by a competent body guided by transparency,

confidentiality and impartiality.
2. What are the benefits of a complaints mechanism?

The term complaint alone can be misleading and problematic, and sometimes even
more so when translated into local languages. In some European countries, the term
“ombudsman” would be more appropriate. In the Middle East, reference to “divan al
matalem” would be well received as a familiar and trusted institution. A “complaint” is
often understood in a negative and confrontational sense, which is why considera-
tions have been made on whether to change the concept to something else (e.g.
Feedback Mechanisms). Though the term “Complaint Mechanism” can be mislead-
ing, feedback and CM have different characteristics.
Yet as a concept, a CM is more formalised. It must allow more serious grievances
or issues that may need to be investigated and processed more thoroughly, impar-
tially and confidentially. The CM seeks to provide an opportunity to safely address
a specific matter and to have this matter processed objectively on the basis of a
standard set of rules.
Feedback, on the other hand, is generally less specific. It does not involve the same
formalised procedure of processing the information and does not necessitate a
response. Feedback can be both positive and negative.
“A CM seeks to provide a safe opportunity to raise a valid concern and to have

this concern addressed objectively against a standard set of rules resting in
the values and commitments of the agency”.
Processed complaints can and should also “feed back” adjustments to the pro-
gramme, but it is important to distinguish between the two. The more general proc-
ess of getting feedback through evaluations and monitoring does not respect key
elements of a CM. Feedback remains an important part of interacting with benefici-
aries, while addressing the CM in many situations will constitute a “last” option.
The differences between complaints and feedback can be illustrated, as below. Cru-
cially, the complainant naturally can choose to address an issue / grievance directly
to the CM without first informing field staff (as the field staff may indeed be the
object of the complaint).
Figure 1.
Normal/daily Complaint
feedback Mechanism
Beneficiary wishes A more serious

to confront / issue. Beneficiary
address the files a complaint
agency with an on a concrete
issue. matter.
A minor issue.
The complaint is
Beneficiary infor-
processed and
mally tells field
the beneficiary
staff and receives
receives answer /
an immediate
redress.
answer.
The complaint is
appealed.
Looking into the benefits of the CM, the most important is the strengthened sense of
accountability towards beneficiaries in terms of being provided with better quality of
assistance and better usage of resources. Strengthened accountability, though, can
be achieved through various means that ultimately contribute to better impact and
materialises through better interaction between beneficiaries and the agency.
Below, the aspect of accountability in terms of a CM is highlighted along with a few
other potential benefits of the CM in a humanitarian context.
2.1 CM - a dignifying mechanism

Mechanisms of dealing with complaints are not new.The private / commercial sector
has been using CMs for years. The hotlines of telephone companies, the “whistle-
blower” initiatives of world banks and the ombudsman institution of Denmark and
other countries constitute examples2. Even the small “suggestions box” and the tick-
off cards seen in restaurants can be regarded as a type of CM. All are used to
identify weaknesses and wrongdoings in the product or service, and to signal that
the company / service provider recognises that mistakes can happen and should be
rectified. Though all do not respect basic requirements, such a CM is dignifying for
the user as the companies / service providers hold themselves responsible to the
promises, principles and products / services given to their consumers.

Through establishing a CM, a humanitarian agency is expressing a wish to arrive
at some of these “corporate” values in strengthening accountability. By setting up a
CM, agencies acknowledge that some people may have been missed when select-
ing beneficiaries or that some vulnerability criteria may have been neglected etc.
With the CM, the agency states that it is prepared to - and interested in - correcting
mistakes to improve the programme and the rights of the beneficiary.
2.2 CM as a separate project component

In an often non-functioning society, a CM is a civilised, respectful and sometimes
the only non-violent manner to deal with grievances. In this respect, a CM supports
basic functions of a society, sending a message that power and influence is not de-
cisive for the outcome when someone feels that he/she did not receive the product
promised, or dignified treatment.
From this perspective, a properly established CM can in many humanitarian con-
texts constitute a separate (fundable) project component. As humanitarian agencies
and development organisations often operate in very volatile environments where
fair and equal systems of dealing with complaints often are non-existent, a CM can
constitute a model to show alternatives, or as a first step ultimately to set up a court
system. The CM could constitute a component within a larger project, which focuses
on generating awareness among the population about their rights, or to draw atten-
tion to particular problems which are handled ineffectively. Furthermore, realising
that grievances eventually will arise in all contexts where humans are involved, the
setting up systems to receive and process complaints is an important aspect in en-
suring, for example, the sustainability in NGO networks and other capacity building
initiatives as to the continuation of the constructive co-operation.
It is important to be aware that the CM as generally presented throughout this paper
is a relatively Western way of thinking – especially if not carefully adapted to the lo-
cal context and customs. When including a CM as part of a project, it is particularly
important that the user population is involved in the decision to establish it, as well
as its design.
2.3 CM as an early warning indicator

Private companies regard CMs as a tool that enables them to deal with a problem
before it escalates (i.e. an instrument that helps them to avoid lawsuits by solving
issues before the customer takes legal action). From this perspective, a CM can
save a company from not only lawsuits, but negative media coverage owing to, for
instance, dissatisfied customers not being able to complain directly to the company
and out of frustration addresses the local news paper. The nature of humanitarian
work is different in many aspects, starting with the fact that the beneficiaries rarely
have these options or the resources to hold the humanitarian “service provider” re-
sponsible in a public legal system and in medias. The frustration and sense of mis-
treatment, though, remains!
The CM can function as a lightning conductor. Allowing for complaints to be ad-
dressed and processed objectively, according to a procedure that has been made
public, a CM can serve to rectify minor and unintended mistakes or injustice as well
as simple misunderstandings that could generate rumours. Such rumours can be
very problematic in relation to accessing communities or vulnerable groups if the
beneficiaries - rightly or wrongly - distrust the agency. Furthermore, rumours can
develop into threats and acts of retaliation against staff if no channels exist for set-
tling issues of grievance or misunderstanding. If accepted by the local community
and beneficiaries, the CM can act as this canal.
2.4. CM from a cost-benefit perspective

The CM can be cost-effective in a humanitarian context too, as it constitutes an
organised system for interaction with persons / beneficiaries. All field programmes
are frequently approached by beneficiaries and potential beneficiaries who wish to
complain. These interactions can be time-consuming and difficult for both field staff
and management when receiving a steady stream of visitors and complainants de-
manding answers to outstanding issues of various kinds.
Through establishing a formalised and institutionalised system (known to benefi-
ciaries) that receives and addresses complainants, it becomes legitimate and still
dignifying to refer people to the CM. Not only is the user sure that their complaint
is handled by a competent body, but it is equally important that agency staff avoid
spending extensive time making often unsubstantiated promises and excuses when
required to make an immediate response.
2.5 CMs are complementing impact monitoring

The process of defining the scope of the CM can help the development of impact
indicators and monitoring activities since designing a CM involves analysis of the
agency’s promises and commitments. Whereas the process of impact monitoring
involves the agency actively going to the field to measure and verify that outputs
and objectives have been met, the CM invites beneficiaries to come to the agency to
report about issues that may not have been taken into consideration when design-
ing the monitoring framework or plan.
Impact monitoring will naturally only focuses on elements identified and defined
by the agency, while the CM ideally should invite complaints about issues that the
agency may be unaware of (such as unforeseen and unintended side effects of a
certain intervention).
As such, the CM and monitoring activities are related and should support each other
(but can of course never replace one another). Part of the monitoring process could
easily be to inform / remind beneficiaries about their access to use the complaints
mechanism. Patterns identified through the CM should be included in the monitoring
framework where possible.
2.6 CM as statistic documentation

Complaints should be processed and recorded in a manner whereas patterns feed
into the general programme planning (and as such constitute a feedback instru-
ment). By allowing this, the agency gains a valuable mechanism to improve the
quality of the programme and hence the funding basis. Such patterns are identified
more easily when complaints and grievances are processed though a formalised
system e.g. generating statistics through a database to be used in reporting and
applications to donors.
The fact that an agency does not receive any complaints, though, cannot be re-
garded as documentation of a perfectly functioning operation. More likely, the CM
has not been set up properly or its existence has not been communicated to its
expected users.
3 What are the risks of a complaints mechanism?

The problems that could arise from establishing a CM are mainly the consequences
of either a poor/inappropriate CM, or poor/inappropriate communication with the
beneficiaries. Poor design and communication could also be the result of wrong, or
missing, analysis of the local context, including failure to involve the user population
in key decisions.
The potential challenges or drawbacks listed below serves to highlight the fact that
one CM cannot automatically be copied from one context to the other, but needs to
be carefully adapted for the local context. For this reason, it is difficult to talk about
drawbacks in general terms, but rather as potential challenges. The relevant issues
to consider when designing and setting up a CM are dealt with in the Step by Step
description, but a few general issues.are relevant to mention here.
3.1 Security considerations

Humanitarian agencies are to an increasing extent operating in volatile environ-
ments where not only the lives of the affected / vulnerable population are in danger,
but those of agency workers, too. Humanitarian agencies can no longer protect
themselves behind their status as independent and unbiased, and are to a larger
extent being drawn into the conflict (e.g. to generate visibility to the cause of the
rebel groups or for ransom). One consequence is that many agencies keep a very
low profile needs to sometimes operate through remote management.

As the establishment of a CM necessitates a rather extensive degree of commu-
nication (project information, agency information, valid complaints etc. to be shared
with the users of the CM) and beneficiary involvement (design of the mechanism,
members of the complaints-handling board etc.), the agency is likely to expose itself
and its staff. Refugees fearing eviction may equally feel that they are being exposed
by the additional attention drawn to them via a project and the setting up of a CM.
The beneficiaries of humanitarian assistance in volatile and dangerous en-

vironments have of course the same rights to accountable assistance and
to complain as those living in more safe areas, but safety should never be
jeopardised for anyone.
The beneficiaries of humanitarian assistance in volatile and dangerous situations

have of course the same rights to accountable assistance and to complain as those
living in more safe areas, but safety should never be jeopardised for anyone.
A consequence could be that the accepted users of the CM are limited to being
the direct beneficiaries of the project (and not potential beneficiaries, local NGOs,
authorities etc.). This will allow an information campaign to be undertaken through
the use of pamphlets and explanation notes handed to the beneficiaries directly (as
opposed to posters and more open campaigns) and the complaints to be submitted
through sealed envelopes only (as opposed to information desks or complaints box-
es). This may as well result in beneficiaries of the project not having access to the
complaints handling board. These are compromises to the optimal CM, but indicate
an effort by the agency to secure access to complaining, as opposed to none.
3.2 Protecting the users when dealing with sensitive issues

An aspect of security that deserves particular attention is the protection of a CM’s
users. The reason is that the CM - if designed and managed improperly - has the
potential to endanger those it was supposed to benefit and protect. Working with vul-
nerable persons and conflict displacement in particular, it is important to be aware
about the potential – actual or perceived – risk that the a person takes when using
a CM or in being identified as a user.
Not only do information campaigns, visibility and extended agency-beneficiary in-
teraction pose a potential security hazard to agency staff, but to the beneficiary as
well. In this respect, the following three points illustrate three areas in which to pay
particular attention:
» Disrespect for the basic confidentiality of the complainant, which may result in
the leaking of sensitive information or wrong composition of the complaints han-
dling board.
» The information campaign could draw attention to people who do not wish to be
known as beneficiaries to the agency (e.g. when protection of rights and refugee
status is an issue, in areas influenced by insurgents who see INGOs as part of
the enemy, where there is risk of extradition etc.).
» Danger related to travel to the complaints submission point, and danger – real
or perceived – from retaliation from the community or head of community for
complaining (the mechanism may challenge trust and authority within the com-
munity).
The danger is most prominent when working in contexts where the safety of the
individual is at stake, and / or when the safety of the individuals or the group rests
on the fact that the subject of their complaint remains unknown. Disrespect for the
basic confidentiality of the complainant could result in the leaking of sensitive infor-
mation, leading to a deterioration of their safety or situation.
A country is home to a number of Iraqis without a legal permit to stay and

many have been know to be forcefully returned to Iraq when encountering the
police.
The police make no special effort to find the Iraqis, but increased attention by
agencies to this group could generate a change of policy to a more pro-active
effort to identify the Iraqis.
It is the responsibility of the agency to consider these aspects of sensitivity and

ensure protection no matter who is using the CM. These problems can be solved by
carefully analysing how the complaints are solicited and handled, and also serve to
highlight the importance of a sound and carefully designed CM.
In many instances, the CM does not deal with sensitive complaints and it is worth
considering whether the CM should allow submission if it is not possible to guaran-
tee the protection the complainant. At the same time, these types of violations often
constitute the most extreme forms of breaches of accountability and require the at-
tention that a properly set up and managed CM would offer. It is important to recog-
nise, though, that dealing with sensitive and non-sensitive issues are very different.
It is always the user of the CM who decides if an issue is sensitive or not. Though
seemingly non-sensitive to the agency, individual or personal circumstance may
make the issue sensitive for the complainant. In some societies, for instance, the
mere fact that a woman voices a complaint could jeopardise the honour of her
family or her safety, even though the issue does not appear to be sensitive from the
agency’s perspective.
3.3 Resources to manage a Complaints Mechanism

Obviously, the designing, setting up and managing of a CM costs – in terms of fund-
ing, dedicating relatively senior staff, time etc. This is especially so for smaller pro-
grammes, as it may be difficult to make the necessary investments; staff resources
are limited and there is a need to focus attention on completing the project at hand
within the contracted time-frame.
However, it is important to regard the CM as an investment in quality and account-
ability, and to regard its importance on the same level as direct outputs, such as
non-food kits distributed or the number of wells constructed.
This is facilitated by recognising that impact and results are as well a matter of
strengthened dignity to the beneficiaries, since they are allowed to voice their con-
cerns. The agency needs to recognise that quality input from the affected population
is part of being accountable and part of improving one’s programme. As mentioned
above, the well-functioning CM has a benefit in some contexts of improving inter-
action with beneficiaries and saves resources by bringing the CM into the greater
communication and information strategy.
By allocating resources in the budget from the start, donors are likely to support ini-
tiatives to strengthen accountability. Resources could be allocated to additional staff,
for an information campaign and visibility and for example, external consultancy
assistance to provide guidance and training of the staff in setting up and running
a CM.
3.4 Complaints Mechanism is a Western concept.

In many of the countries and areas where humanitarian agencies are operating
today, the settling of right and wrong is linked to resources, family ties and power.
However logical and beneficial it may seem to simply set up a CM to strengthen
the weak, from unjust treatement, it could contradict local traditions being both re-
spected and trusted though not democratic.
Humanitarian agencies are often bringing extensive resources to poor communities,
which will always have extensive impacts – be they positive or negative. Among the
values of allowing people to complain is for the agency to become aware about the
negative side-effects of their intervention. The CM is as well a regulatory mecha-
nism in terms of who decides how resources are used - a regulatory mechanism
that may work very different for the existing systems. As a consequence, some are
empowered while others may feel they are losing control. The power balance of the
community is shifted.
A solution is often to de-westernise the CM and adapt the system to the existing
traditions by carefully analysing existing structures and involve – to the extent pos-
sible – national staff and the user-population throughout the process. The agency
as well needs to decide whether the CM actually is part of an effort to change the
existing power balance in the community as part of protecting others.
3.5 Fear of being over-burdened

Another concern of many agencies about to establish a CM is the fear of being
over-burdened by complaints; that providing access to complaining will generate
a massive storm for dissatisfied “customers” simply wishing more - a storm that
is more likely to generate such a frustration and dissatisfaction among the users
that the sensation of dignity and empowerment will falter because the system can-
not cope. However, the problem should not be in receiving of too many legitimate
complaints, as these of course would be important for the agency to address. More
often, the concern is of over-burdening from illegitimate complaints that are not rel-
evant or are outside the control of the agency.
Assuming that the information campaign has been effective in informing about the
scope of the CM, and has specified clearly the types of acceptable complaints,
one solution could be to start up slowly with only a minor part of the programme
as a way to learn about the complaints culture of users. Another would be to make
a complaints handling board, consisting of beneficiary representatives acting as a
filter.
An agency is distributing NFI-kits to refugees scattered throughout the coun-

try. In order to provide access to complain, a standard letter is included in
all NFI-kits providing a brief introduction to the project and the agency. This
description is followed by a list of the items included in the kit and a phone
number to a Project Officer that the beneficiaries are invited to call should any
items be missing / damaged.
This CM may not live up to the minimum requirements, but does, however,
constitute a simple system designed to address complaints in a certain op-
erational context.
It remains a fact that over-burdened mechanisms remain the exception when com-
pared to the problem of the intended users simply not using the mechanism (e.g.
they may not understand it, are afraid to use it for fear of losing their assistance etc).
Normally, the over-burdening and “under-burdening” is the result of an insufficient
and inconsistent information campaign or a mechanism not adapted to the local
context. What is important to note is that fear of over-burdening is not an automatic
reason why a CM cannot be established; rather, that over-burdening is a matter of

design.
It is important to keep in mind that it is not for the sake of the humanitarian agency
that CMs are established, but for the users.
4. General Characteristics of a Complaints Mechanism

Based on research by One World Trust3, an evaluation conducted by HAP of DRC
North Caucasus information centres and evidence from the humanitarian context
in general, a number of basic elements characterising CMs are outlined and dis-
cussed below.The description focuses on considerations necessary to make 1) prior
to the establishment of a CM, 2) when the complaint is filed, 3) when it is processed
and 4) the provided redress. Finally in 5) are some elements to be learned from the
complaints processing4.
4.1. Internal capacity and scope of the Complaints Mechanism

Establishing a CM for a programme, or parts of a programme, requires willingness
by management to allocate resources and to be prepared to change the programme
when necessary. Some key elements that need to be considered beforehand are
highlighted here and will be addressed in the step by step description.
» The necessary resources are allocated. No matter the size and type of the CM,
it will cost funds and time. The process of designing, establishing, communicating
and running a system to register, process and finally redress complaints neces-
sitate staff being trained and dedicated to this task.
» Possible effects on the programme. Aside from the benefits of a CM, many areas
where humanitarian agencies operate are not used to such institutions. It can
be difficult to predict how such a mechanism is received by the local community.
Questions that need to be considered when designing a CM include: Do some
segments / institutions in the population feel threatened? Does the need for in-
creased transparency constitute a security threat? Is there a danger of the office
/ CM being over-burdened?
» Communication to potential users. This should cover element such as:
- Scope of the mechanism. (E.g. does it cover all of the programme or only
certain project components?).
- What constitutes a valid complaint. How are valid criticism and complaints to
be distinguished from non-valid ones?
- Who can file a complaint. (Beneficiaries, possible beneficiaries, stakeholders
affected by the activities, media, community members, other NGOs?).
- How and where to publicise information on how to file a complaint.

- How could / should senior management be involved / informed if necessary.
(To respect the nature or possible sensitivity of the complaint by functioning
as an appeals board).
- Who should be members of the complaints-handling board.
» A description of the complaints process, informing potential users. Following
some of the potential problems outlined above it should:
- Outline exactly what can be complained about. (Based on what the benefici-
aries can expect and the principles / approach of the project.)
- State what is the procedure and time-frame for complaining. (Easy and safe
to use.)
- State the rules governing decision-making and remedy. (Fair process.)
The definition of a CM discussed above indicates that the complaint must be rel-
evant and within the control of the agency. Outlining acceptable complaints is im-
portant in order to avoid overloading the CM. Limiting the acceptable complaints,
and at the same time allowing unforeseen matters access and redress, is a balance
between a usable/relevant mechanism and a manageable mechanism. The more
restrictions made to acceptable complaints most often results in lesser value to the
user population.
In an operation in North Caucasus, it is possible to complain about 8 very spe-

cific issues only. The operation is a large-scale food and non-food operation,
with 250,000 beneficiaries.
This limitation in accepted types of complaints has been made for the CM to
be manageable.
The rhetorical question the agency should consider when trying to identify the scope
of acceptable complaints is: “What are our commitments to standards worth if we
are not prepared to be held accountable to them?”
The relevant areas an agency may wish to be held accountable to are principally
guided by the promises and commitments it makes. Most importantly are concrete
commitments directly related / made to beneficiaries, but they could as well be the
obligations made as an organisation and to donors. These issues are related both to
what is provided and how it is provided.
Promises made to beneficiaries

Beneficiary / vulnerability / selection criteria, implementation approach, qual-
ity and quantity of product or service, aspects of voluntary choices, unfor-
tunate side-effects, quality of or access to information, appropriateness of
approach and output, participatory approach etc.
External codes of conduct
Code of Conduct, HAP, SPHERE, Assistance Framework etc. These could
include commitments to participation and use of local resources, misuse
of funds, gender balance, attitude of staff, the CM-procedure itself, dignified
approach, impartiality etc. These “soft” commitments need to be defined /
explained if complaints are accepted related to these.
Contractual agreements
Commitments may have been made in the application / contract or as part of
being an implementing partner to, for example, ECHO and UNHCR. (These
would include procurement procedures, code of conduct for staff, etc.)
The challenge when making this analysis is that a CM has the added benefit of mak-
ing the Agency aware about unintended side-effects of its activities. By establishing
a narrow margin for acceptable complaints, the benefit of identifying unintended
side-effects (that may be harmful) is often lost. Often, the users are not only benefi-
ciaries, but as well potential beneficiaries – persons that the agency’s assessment
missed when locating beneficiaries for the NFI distribution. These as well should
have access to complain if a needs-based approach to assistance is adopted.
Agencies tend to be very focused on the reporting guidelines presented by the do-
nor, while commitments to the beneficiary population are met with a larger degree
of flexibility. The reason why stems from the uneven power balance between the
donors, who have direct and immediate power to withhold or cease funding based
on a legally-binding contractual agreement, and the beneficiaries, who may not even
be aware about the commitments that the agency has adopted on their behalf.
This accountability breach is as well the responsibility of the inflexible donor focus-
ing rigorously on reporting guidelines, but as humanitarian agencies are taking it
upon themselves to be accountable towards beneficiaries, they too need to ensure
a fair power balance.
4.2 Filing a complaint

» Information about the CM is clear, visible and easily available. Disseminating
information about the CM and the procedure for processing complaints could be
via handouts to beneficiaries / community leaders, posted on the wall of the office
or the areas of implementation. Considering that beneficiaries are often illiterate,
deprived from moving freely or have limited capacity, alternative channels of dis-
semination are often necessary, including information meetings etc.

» The procedure itself should be non-threatening and welcoming to use, so that
feedback and complaints are actively solicited. Agency staff should be informed
about and understand the procedure. The staff should not regard it as a mecha-
nism to reveal their misconduct and, as such, established against them, but as
an accountability mechanism to ensure the dignity of the beneficiaries. Filing a
complaint should not be regarded as negative or working against the interest of
the agency, which should be reflected at all levels of information dissemination
and procedure. It is a positive contribution to being accountable.
» The procedure should be easy to access and safe to use. While working in often
volatile environments with vulnerable people and minorities in need of protec-
tion, both physical and safe access is crucial. Important considerations related to
access include:
- Location. (Do beneficiaries know where? Is the area safe for all?)
- Distance. (Recommended as not too far.)
- Travel costs. (This could include a minor travel compensation fee.)
- Special permits necessary.
- To whom does one complain (Fear of retaliation, involvement of public of-
fices.)
- Confidentiality of the complainant. (Privacy when submitting complaints.)
- Possibility to file complaints on behalf of others, (Due to illiteracy, fear of
retaliation, inability to travel etc.)
- Free to use. (No fees requested.)
- Sensitivity to cultural traditions, gender, age and religion.
» The CM should be easy to use. The process of filing a complaint should be
straightforward and the procedure should not require special qualifications.
» Submission of complaint should preferably be recorded in written form (as op-
posed to verbally) for the following reasons:
- In order to process a complaint, the agency and the complainant need to
have a clear understanding of the grievance.
- The complaint should preferably be signed by both parties to limit the danger
of alteration, and allow for better and precise response to a concrete issue.
- For the CM to constitute a systemised feedback mechanism to programme
planning, the complaints and redress need to be computerised. A filing sys-
tem is important to track patterns in the complaints.
- It is important that the system allows for another person to process the com-
plaint than the one receiving. Complaints may not be processed immedi-
ately.
A problem with written complaints is that some users may fear retaliation. In other
contexts, the operational context may not allow beneficiaries access to file writ-
ten complaints as opposed to verbally transmitted. Requesting written submissions
could also be difficult when dealing with very sensitive issues. Consequently, written
submission of complaints is normally ideal, but not mandatory.
» The complainant should ideally receive a receipt that confirms their complaint
has been filed and recorded. This receipt could be a copy of the submitted and
signed description of the complaint. The receipt would include an indication of
when the complaint is processed. For verbally-submitted complaints, receipts are
less important. As with the written submission, it may not always be possible to
provide receipts (if complaints are submitted via phone, for instance).
4.3 Processing a complaint

» The CM should be impartial and independent from the subject of the complaint
(to the extent possible and manageable). In order to avoid conflicts of interest,
the staff designated to process the complaint must be different from field staff.
It is important that all staff have a mutual comprehension of what guides the
investigation (being the effort to strengthen accountability).
» Complaints should be processed against a clear, published definition of a com-
plaint and against clear, published criteria, including a time frame for processing
the complaint. It is important that the complainant is provided with a description
of the CM process.
» Complaints are treated confidentially. Files are kept confidential so that publish-
ing / sharing information about the complaint cannot be used to trace the indi-
vidual complainant.
» Complaints are processed by a qualified entity. Staff members processing com-
plaints are qualified and understand the sensitive nature of a CM. The sensitive
nature of complaining often deems necessary a gender balance and often a
senior committee dealing with the complaints. In some instances, (elected) ben-
eficiary representatives or community leaders could improve the level of trust in
the CM from the side of the users. Sometimes the opposite.
4.4 Redress for the complainant

» The complainant should receive a clear response that comprises an answer and
explanation, as well as an indication that the complaint has gone through an es-
tablished due process. Responses should be provided with due sensitivity.
» The complainant should acknowledge that they have understood the answer. In
case of any belief that there has been a discrepancy in the process or the result,
the complainant can apply again. The complainants and staff should be made
aware that the system has alternative channels for grievance, and these should
be explained. Beneficiaries of HAP members have access to address complaints
to the HAP-board. An alternative solution could be that the agency and the com-
plainant identify another external body to decide on the grievance (e.g. UNHCR,
OCHA, HAP local office, other INGO etc).
» The agency should be clear on the type of remedy offered. In line with the defi-
nition for CM, the agency should not accept claims that will result in a larger
remedy than the agency is prepared to offer. Outlining the remedy - and hence
limiting it - is an important part of explaining the procedure of the CM to the us-
ers.
» When closing the case, agreement should be made with the complainant on rem-
edy, and both parties ideally should sign their approval of the case being closed
and that the outcome is accepted. Copies are kept in both hard and electronic
format. Precise responsibility for redress is mutually identified and agreed. For-
mal closure, though, is not always possible if complaints are communicated, for
example, via phone.
Having investigated a complaint of a family, the Agency recognises that it falls

within beneficiary criteria for housing, but was not chosen. Funding, though,
has been committed elsewhere.
Principally, the agency does not need to commit to providing the families with
new houses, but simply an acceptance that the agency has made a mistake.
This could generate frustration, but the agency shows accountability in recog-
nising its mistake.
4.5 Learning from a complaint

» Complaints should be used as feedback to the programme and filing should en-
able the agency to generate statistics through which tendencies and possible
weaknesses in assessing, planning, implementation, monitoring or evaluating
can be identified.
» Programme planning allows for minor corrections in case of redress bearing
influence. The organisational culture is open to lessons arising from complaints.
Senior management are responsive, and relevant stakeholders and, especially
donors, are informed about the CM.
5. Three Examples Of Complaints Mechanisms

Based on the minimum criteria outlined above, some initiatives would not qualify
as a CM, but would allow a certain feedback and access to address some types
of complaint. In order to give an impression of a possible CM, three very different
examples are described below. The examples will show:
» Difference in type and scope, and how a CM in one operation cannot necessarily
be copied in other contexts.
» How a CM can be an integrated and active part contributing to the programme.
5.1 Large-scale food or non-food distribution
In the North Caucasus, an agency conducts food and non-food distribution by a
monthly cycle to more than 250,000 beneficiaries. The distribution is done through
20-30 pre-selected and known distribution points on the basis of concrete and pub-
lished beneficiary criteria. The CM has been facilitated through 9 information cen-
tres, which already existed, receiving up to 10,000 visitors per month.
Only complaints in relation to beneficiary status are accepted. The beneficiary will
use one of the 8 ready-made forms covering common reasons why someone would
change their status (marriage, birth, death, return and changed address), which is
provided in one of the 9 information centres. The complaint is processed in the field
office by two senior officers, who will send field assistants to investigate the correct-
ness of the information provided by the beneficiary, if deemed necessary. Process-
ing the complaint normally lasts 10 days. The complainant receives a verbal answer
except in more complicated circumstances when a written explanation is needed.
Main characteristics:
- Extensive operation with a large number of beneficiaries and complaints.
- The programme is simple and of a mainly quantitative / logistic nature. Is-
sues relevant to complain about are limited.
- Issues possible to complain about have been limited in order to ensure that
the CM is manageable and will not become over-burdened.
- The issues accepted in the CM are concrete and non-sensitive.
- The CM is an integrated and accepted / known part of updating assess-
ments and beneficiary lists.
5.2 Sexual abuse of vulnerable groups (specific and sensitive issues)

In large parts of Tanzania, rumours about sexual abuse by humanitarian staff
against the beneficiaries in the local villages are circulating5. An agency sets up
a CM, which will cover the operational areas of all the agencies in a district. The
agency initiates an information campaign informing the staff of all agencies and
beneficiary communities about sexual abuse as well as a thorough introduction to

the CM (procedure, redress, requirements etc).
Only signed complaints are accepted, but do not need to be submitted by the vio-
lated person. The violated person must accept to be contacted by / meet the Agency
Officer (expatriate), who will conduct a preliminary investigation into the allegations.
Based on the procedures, the Agency Officer will involve the Complaints Handling
Board of selected NGOs, if a violation seems probable. All nationals – beneficiaries
and non-beneficiaries – have access to use the CM. The complaints forms are pro-
vided with a special code, and third persons only have access to see the code. The
codes match a confidential sheet of paper with all the relevant names. This sheet of
paper and the case files are kept separate at all times.
- The complaints are extremely sensitive to all parties involved.
- The mere setting up of a CM can have a preventive benefit and limit ad-
ditional violations.
- Issues such as confidentiality and safety of use are pivotal for the design
of the CM.
- Impartiality, thoroughness, accuracy and objectivity of the Complains Han-
dling Board is important.
- Anonymity of the victims must be secured, but willingness to share with the
agency / CDC is necessary for processing the case and ensure that the CM
in not misused.
5.3 Multi-sector programme / CM

In Iraq, a humanitarian agency is operational in 7 villages located in 6 different parts
of the country with activities within shelter, income generation, social rehabilitation,
legal aid and community infrastructure. Activities focus on the displaced population
and host communities, and are implemented through a participatory community-
based approach. The security situation is very volatile and national staff have been
threatened due to their affiliation with international agencies. Expatriate staff are
not able to enter the country, but are accommodated in neighbouring Jordan and
Kuwait. Monitoring of impact and approach is very difficult. The agency is working in
close co-operation with another international NGO that basically has the same set
up and objective.
A CM has been established by setting up locked ‘suggestions boxes’ in all villages
where the agency is operating. All national and international staff members are
introduced very thoroughly to the purpose and procedures of the CM, and were
as well part of its development. Prior to initiation of activities, a village committee
of community leaders is presented with a thorough description of objectives and
expected outputs of the project, approach and operational principles, as well as a

description of the CM equal to the one staff received. Persons living in the village
(only) are invited to file a complaint or provide feedback by using the suggestions
boxes. Acceptable complaints fall within the scope of the advertised approach and
objectives of the project. The complaint need not be signed and the complainant
has the option of presenting the complaint (written or orally) directly to the agency
expatriate management (whom a village representative has met in Kuwait) or to the
Office Manager.
The ‘suggestions boxes’ are opened by a Committee (made of gender-balanced
national and international staff members) bi-weekly. A written response is provided
(when the complainant has provided their identity).
- Extremely volatile security environment with limited expatriate staff access.
- Danger in relation to visibility to actors outside the implementation area.
- CM designed to address activity and criteria-related complaints. Complaints
can be filed only by village members, only within certain agency-chosen ele-
ments and mainly through ‘suggestions boxes’.
- The CM strengthens monitoring and beneficiaries’ access to management.
It is important for the agency’s donors as well.
- The CM is an integrated part of improving approach, criteria, output/design
etc.
- The CM helps both expatriate and national staff to commit to and improve
approach, criteria, output/design etc.
- It enables beneficiaries (and others) to report misuse of funds, harassment
or undignified behaviour by Agency / NGO / contractor / partner staff.6
- Easy access for the most vulnerable segments of the community.
- Facilitates / invites to semi-sensitive and non-sensitive issues.
- Strengthens the community’s trust in the agency (could be the opposite if
procedures and scope are not understood / communicated properly).
5.4 Concluding remarks

CMs can vary much in scope and type. From the extensive system entailing a large-
scale operation with numerous staff, information centres, mobile teams, databases,
questionnaires etc at one end of the scale, and at the other, one could imagine the
everyday situation where a beneficiary, who has been knocking on the door of the
office, receives an answer to why, for example, he is not on the beneficiary list. In that
respect, all programmes have a CM, and all societies have some way of dealing with
complaints and grievances.
Most offices regularly receive complaints from beneficiaries and provide answers
to these as a normal part of everyday work. The same applies to the local commu-
nity that may have a weekly meeting and elders-boards that deals with grievances.
These are the initiatives and existing structures that are important to build upon
to save the CM process from becoming too comprehensive and alien in the local
context. Establishing a CM should be guided by the will to improve a programme’s
impact as well as to make things easier and more transparent. Consequently, the
extent to which a parallel system is established should be minimised as opposed to
the effort of building upon existing procedures, resources and traditions.
Notes
1) Please refer to Reference 2C for linking the minimum requirements in this Handbook with those of HAP.
2) This handbook does not address setting up a whistle blowing mechanism. Whistle blowing does normally not involve
communication between the agency and whistle blower, but is simply a mechanism that allows breaches of e.g. fraud to
be reported anonymously. Such a mechanism could e.g. be established in HQ parallel to a CM in the field.
3) One Trust World conducts research on practical ways to make organisations, companies and institutions more respon-
sive to the people they affect. This includes a Global Accountability Project, which for example identifies complaints and
redress mechanisms as an important measure. www.oneworldtrust.org
4) It is very important to stress that though a perfect CM would include all these part, 5, which outlines three different types
of CM, will show that both size and scope can differ considerably.
5) Other examples could be humanitarian field staff threatening, harassing or stealing from beneficiaries, misuse of funds
and relief aid etc. This example is made up.
6) Though the described CM is not designed for very sensitive and confidential issue, misconduct by humanitarian staff is
especially difficult to identify in operations where expatriate staff do not have direct access to the beneficiaries. National
staff should have access to use the CM as well.
CHAPTER 2B - Reference material

Minimum Requirements for a Complaints
Mechanism
Working with a set of minimum requirements linked to a system of indicators is
an important and proactive means of ensuring that the programme objectives and
expected impacts are achieved. Reference 2B introduces the mandatory standards
and outputs.
It is important throughout the process of setting up a CM to ensure that the mini-
mum requirements are respected, while at the same time keeping the CM as sim-
ple as possible for the programme to manage. This balance is sought achieved
through the development of one standard and a set of outputs mandatory for all
programmes, and secondly a guide to assist the programme in developing indica-
tors, means / sources of verification and activities individually-adapted to the context
of the programme.
In short, this is a common set of minimum requirements mandatory to every pro-
gramme setting up a CM supported by individually designed indicators and verifica-
tion instruments identified by the programmes themselves, which can support the
differences in size, scope and ambition of various CMs.
Standard Mandatory
Outputs Mandatory
Indicators Individually designed
MoV / Activity Individually designed

1. Standards and outputs

Standards and outputs are of course mandatory. The standard for a CM to achieve
is very close to the definition of a CM.
Simple procedures and mechanisms that give users access to safe means of
voicing complaints on areas relevant and within the control of the agency has
been facilitated.
In order to achieve this standard, a number of outputs have been formulated. The
outputs constitute minimum requirements that guide and bring about the operation
of the standard. By respecting the minimum requirements, the agency is able to
guarantee a certain level and quality based on which HAP, donors, partners and us-
ers can base their expectations.
The following outputs have been developed which are mandatory for all CMs.
1.The procedure, purpose and parameters of the CM have been communi-

cated and made available to relevant stakeholders.
2.Intended users have safe and easy access to use the CM.
3.A logical and easily-understood set of procedures has been developed for
submission, processing and response / redress of complaints.
4.Complaints are processed by a competent body guided by transparency,

confidentiality and impartiality.
What is not specifically outlined in the outputs is the importance of involving benefi-
ciaries. It is of key importance that beneficiaries are consulted and involved for the
CM to be accepted and trusted within a given community. As the CM is ultimately an
effort to strengthen accountability, beneficiary consultation and involvement should
be sought to the best extent possible.
2. Indicators and means / sources of verification

While the standard and outputs are mandatory to all CMs, the indicators and means
of verification will differ from one operation to the next, based on the sectors / areas
of the programme that the CM addresses, the number of potential users of the CM,
the levels of sensitivity of the complaints as well as cultural, political, geographical
and literacy differences. These differences are important to incorporate for the CM
to have the intended impact.

The outputs include a number of aspects that should be reflected in the indicators.
Which indicators and hence the degree to which the programme feels able to live up
to and document the achievement under each of the outputs, though, differs.The de-
velopment of indicators is achieved through the final Step 11, in 3A Step by Step.
CHAPTER 2C - Reference material

Linking the CM Handbook and the HAP
Benchmarks
During the past few years, a number of organisations have been developing tools
and material to guide agencies in setting up a CM. Parallel to the process under
DRC, HAP has been developing a set of minimum requirements – or Benchmarks
– necessary to comply with in order to be HAP certified
By complying with the four outputs and by following 3A Step by Step presented in
this handbook, the agency will automatically comply with the HAP Benchmarks.
While the handbook has been developed mainly with the aim of providing practical
guidance on how to set up and manage a CM in different operational contexts, fulfil-
ment of the HAP Benchmarks is also focused on the agency’s ability to document
that it both respects and meets the Benchmarks. For this reason, it is relevant for
users of the CM handbook to know exactly which documents and material produced
(as a result of following the Step by Step chapter of this handbook) can serve as
documentation towards HAP in order to become certified.
The table over the page matches each HAP Benchmark with a description of how
and where the CM handbook addresses them, including what can be used as docu-
mentation.
No. HAP Benchmark HOW - does the CM handbook address the HAP Benchmarks WHERE -
WHAT - can be used to document compliance with HAP Benchmarks in the handbook
5.1 The agency shall The involvement of intended users in designing and running the CM is an inte- Participation:
ask intended grated part throughout the Step by Step description, especially in terms of staff 3A Step 1
beneficiaries and and the direct beneficiary population.
the host community For each of the Steps, recommendations and exercises are provided on how
about appropriate staff members and CM users could be included in designing this element of the
ways to handle CM.
complaints.
5.2 The agency shall The final Step by Step description is to summarise the commitments in an LFA. Documenting:
establish and docu- As indicated in Benchmark 5.2, the agency is required to “document” compliance. 3A Step 11
ment complaints- Reference is made below for each sub-benchmarks under 5.2 on what can be
handling proce- used as documentation.
dures which clearly
state:
5.2 a) the right of The stakeholder’s who are guaranteed access to complain will always include Defining users:
beneficiaries and agency staff members and beneficiaries, while Tool 4C and Annex 5C provide 3A Step 3
other specified the analytical framework of deciding additional users of the CM. Tool 4C
stakeholders to file The right to complain is part of the definition of a CM that agencies commit to. Annex 5C
a complaint. Documentation: copy of the information material as this includes a list of ac-
cepted complainants.
5.2 b) the purpose, The purpose is initially identified in Step 1, but may be revised as part of design- Defining pur-
parameters and ing the CM through the Step by Step process. pose:
limitations of the The parameters / scope of the CM is determined in Step 2 by analysing the local 3A Step 1
procedure. context, actual complaints received and areas of the programme likely to gener- Defining scope:
ate complaints. 3A Step 2
The requirements of 5.2b are reflected in Outputs 1 and 3. Documentation: The
purpose of the CM can be found in Annex 5I. The scope is defined in Annex 5B.
5.2 c) the procedure The procedure for submitting complaints is divided into the practical aspects of Entry points:
for submitting com- format (written or verbally) and entry points (phone, complaints boxes, internet 3A Step 5
plaints. ...). An example of a complaints form is found in Annex 5F. Submission form:
The requirements of 5.2c are reflected in output 3. 3A Step 6
Documentation: Annex 5E and 5F, and the information material generated from Complaints form:
the exercise in Annex 5H. Annex 5F
Information
material:
Annex 5H
5.2 d) the steps taken Aspects of processing complaints include internal agency steps, where the hand- Submission form:
in processing com- book addresses the following aspects: 3A Step 6
plaints. - Designing a system capable and competent in terms of deciding on complaints Complaint cycle:
/ remedy. 3A Step 7
- Designing the system / paper trail that the complaint goes through from being
received by the agency to a response being provided.
- Aspects of investigating sensitive and non-sensitive complaints.
- How to respond to complaints.
The requirements of 5.2d are reflected in Outputs 3 and 4. Documentation: Gen-
erated from Step 7.
5.2 e) confidentiality Thorough attention is dedicated to the establishment of an impartial and compe- Complaints
and non-retaliation tent complaints handling board guided by confidentiality and integrity. board:
policy for complain- The requirements of 5.2e are reflected in Output 4. 3A Step 4
ants. Documentation: generated from Step 4 and communicated to user in Step 10. Tool 4D
5.2 f) the process for Part of designing a complaints handling system includes mapping the appeals Complaints
safe referral of board for each type of CM user. Tool 4D and Annex 5D provide the analytical board:
complaints that framework to design an appeals system. 3A Step 4
the agency is not Documentation: Annex 5D Tool 4D
equipped to handle. Annex 5D
5.2 g) the right to re- The right to complain is worthless if responses are not guaranteed! Aspects on Responding:
ceive a response HOW and WHAT to respond is described in details in 3A Step 9
Step 9.
The requirements of 5.2g are reflected in Output 3.
Documentation: Step 10 and Annex 5H
5.3 The agency Aspects of both WHAT to communicate (introducing the agency, presentation to Information: 3A
shall ensure that the project and description of the CM) and HOW to communicate (leaflets, infor- Step 10
intended ben- mation meetings, internet, community meetings etc.) are described in step 10.
eficiaries, affected The requirements of 5.3 are reflected in Output 1.
communities and Documentation: Tool 4E and Annex 5I
its staff understand
the complaints han-
dling procedures.
5.4 The agency shall It is a minimum requirement that complaints undergo a transparent process Information:
verify that all com- whereby an agency commits to its beneficiaries that the system communicated 3A Step 10
plaints received are to them is the same one applied by the agency when processing their complaint. Complaints
handled accord- The requirements of 5.4 are reflected in Output 4. board:
ing to the stated 3A Step 4
procedures
Chapter 3 STEP BY STEP | 41
CHAPTER 3A - STEP BY STEP

Setting up a Complaints Mechanism
Having read the introduction and the concept paper, you are now familiar with the
overall values and challenges of a CM. This Step by Step description is first and
foremost a practical guide to the steps to be taken in setting up a CM, including
aspects of designing an information campaign, developing a Complaints Handling
System, the involvement of stakeholders, establishing a complaints procedure etc.
The description should be read in conjunction with the various Tools introduced in
Section 4, as references to them are made throughout the description.
How to use
The recommendations and suggestions provided here should be regarded as both
an inspiration and a guide, but the manager responsible for setting up the mecha-
nism is encouraged to keep the mechanism as simple as possible. If all recommen-
dations are followed to the point, the resulting CM is likely to be very procedurally
and administratively comprehensive and complex, which undermines the aim of
strengthening accountability.
What is important, and what this Step by Step description can do, is to depict ideal
solutions, present samples of choices and designs, and to list some important con-
siderations. This knowledge will enable a responsible manager to take informed
choices in terms of design, and help in establishing the consequences when com-
promising with the ideal. The CM should live up to a set of minimum standards pre-
sented in Reference 2B, but these need to be translated into to the local context to
see how the decisions and actions taken will differ from one operation to the next.
Going through the Step by Step description is a process. All the decisions taken are
interdependent and will have consequences for the available choices in the Steps
to come. As it is not possible from the start to consider all aspects, it will be neces-
sary throughout the process to revise and adapt what was decided earlier. In some
contexts, it could as well be relevant to rearrange the order in which the Steps are
taken.
Composition of the Steps

» Each Step starts with a box presenting and summarising:
- Objective: The concrete objective of the Step.
- Means: Means necessary to meet the objective.
- Outcome: The concrete outcome expected from the Step.
- Tools: Relevant tools to use.
- Reading: Reference to find more inspiration relevant to complete the Step.

» The main narrative part following the introduction box is a general description of
the issues to be considered, examples of how this can be achieved and a brief
presentation of the relevant Tools, Annexes and minimum requirements.
» Having read this section and the relevant Tools, the manager is now prepared
to make the necessary choices and decisions. Under the heading “Concrete Ac-
tion to Take”, bullet points list what exactly to decide and do in order to fulfil the
Step.
» Under the heading “facilitation”, suggestions are presented on how the work and
analysis related to each Step can be facilitated by including national staff and
users of the CM. The degree of importance attached to user involvement is rated
with stars, from one to three. Based on the choice of sessions, a workshop can
be initiated. For each Step, duration is estimated for planning purposes.
» Following each Step, there is blank space for your notes.
Linking Annexes and Tools with the Steps
• Objective: To define the purpose and ensure that those involved have the
right understanding of the objectives of the CM.
Step • Output: Preliminary list of points why the agency wishes a CM
1 • Tools: Tool 4A – The Concept of Complaining in Perspective
Tool 4F – Presentation of Complaints Mechanism incl. guide
• Objective: To define what constitutes a valid complaint that the agency will
accept by analysing complaints raised against the agency and its activities.
• Output: Map the type of complaints, complainants, aspects of relevance etc.
Step
• Tools: Tool 4B – Choosing Sectors
2
Annex 5A – Choosing Sectors template
Tool 4C – Mapping Complaints
Annex 5B – Mapping Complaints, template
• Objective: To identify the stakeholders who should have access to use the
Step CM, through analysing who is affected by the agency’s activities.
3 • Output: List of stakeholders who will have access to complain.
• Tools: Annex 5C – Who will have Access to Complain
• Objective: To design the systems capable of handling the different types of

complaints and complainants (the Complaints Handling System).
Step
• Output: CHS design, and a table of entry points and the appeals structure.
4
• Tools: Tool 4D – Setting up a Complaints Handling System
Annex 5D – User and Appeals Matrix
• Objective: Based on analysis of the local context, to decide how and

through which entry points the user of the CM should be able to submit
Step complaints.
5 • Output: List of different complaint entry points and how complaints should
be made.
• Tools: Annex 5E – User Entry Point Analysis
• Objective: To decide in which form the complaints can be submitted – writ-

ten and/or verbal – and relevant information to be conveyed when com-
Step
plaining.
6
• Output: Draft Complaints Form(s)
• Objective: To describe the internal agency cycle that the complaint under-
Step
goes from receiving the complaint, processing and responding.
7
• Output: A map / description on the Complaints Processing Cycle.
• Objective: To decide on the procedure and persons to investigate com-

Step
plaints, especially in terms of sensitive and non-sensitive complaints.
8
• Output: Considerations made on how to investigate complaints.
• Objective: To consider how and what to communicate when responding to

Step
complaints.
9
• Output: Input for consideration.
• Objective: To decide on what and how to communicate to the users of the

Step CM in terms of making an information campaign.
10 • Output: A description of what and how to communicate.
• Objective: To develop an LFA summarising how the CM respects the mini-

Step mum requirements related to the establishment and running of a CM.
11 • Output: An LFA.
• Tools: Annex 5I – Developing an LFA.
STEP 1
Ensure committment to and define the purpose of the CM

Define the purpose of the CM and to ensure commitment and
Objective support. This introductory Step puts into perspective why support
from staff and beneficiaries is important for the CM to succeed.
Proper introduction and involvement of interested parties in

Means
developing the aim of the CM.
Outcome Preliminary list of reasons why the agency wishes a CM.
Tool 4A – The concept of complaining in perspective

Tools Tool 4F – Presentation of complaints mechanism
Reading Reference 2A, Chapter 2 and 3
Establishing and managing a CM requires resources, which vary depending on the

size of the organisation and the scope of the CM. But for any CM to be effective, it
is crucial that there is a high level of commitment from staff at all levels. To increase
the accountability to beneficiaries at the field office level in particular, staff need to
be dedicated to both setting up and running the mechanism. For this to happen,
all staff involved need to have a clear and shared understanding of why the CM is
being set up and what its purpose is. This first Step describes why it is important to
involve staff members and, ideally, the user population.
The organisational commitment to establish a CM should derive from a wish to
strengthen the accountability to beneficiaries and hence improve the positive impact
to those the organisation seeks to protect and assist. In addition, the field office
may have sectors of their work that need special attention or that generate many
complaints. A concrete problem or accountability breach that everybody can see
and agree about can serve as a good basis to ensure the commitment to the setting
up of a CM.
To organisation staff, the CM may be perceived as an initiative to reveal their mis-
conduct. In special instances, the CM will be established to deal with specific staff-
related misconduct, such as sexual abuse, misuse of funds, improper behavior etc.
These types of violations and extreme accountability breaches are, however, ex-
ceptional reasons behind the establishment of a CM. The perpetrators will of course
oppose such a system which in turn represents one preventive benefit of a CM.
Though a properly established CM will also address complaints related to neglect or
misconduct by staff members, it is important to communicate that a CM is a means
to strengthen accountability to beneficiaries and shorten communication lines. En-

suring that field staff understand why the CM is established, and how it will affect
them, is important in order to have a successful and well-functioning CM. Field staff
members have daily face-to-face contact with beneficiaries and it is normal that
most staff-related complaints will be received at this level. A distrustful environment
within the office is not desirable; the staff need to understand that the CM is not a
way to control and police their behaviour; rather that it will improve their practice, the
programme and increase effectiveness and positive impact.
To users of the CM1, the concept of complaints might be new. The CM will only be
used if the system is understood, trusted and perceived as safe to use, and if the
consequences of complaining are known (what outcome to expect, procedure, who
decides on the complaint etc). The CM is primarily established for the sake of the
users, so communicating the commitment to strengthen accountability is equally
important for the beneficiary population.
However, involving the beneficiary populations can be difficult in some contexts.
This is especially the case in emergency operations or volatile operational contexts,
when the relationship between the agency and beneficiary population could be
weak and open discussions may be difficult. It is easier to encourage participation
for example, where local NGOs form part of a capacity building project or where the
agency has been working within a community for a significant number of years.
Consequently, the most critical aspect of ensuring positive commitment and success
of the CM is to generate and maintain the support of all stakeholders. This commit-
ment is best secured through the involvement of staff members and expected users
of the CM in the process of developing, setting up and managing a CM.
How the designing and setting up of a CM is planned and carried out by the indi-
vidual agency needs thorough consideration and a sincere effort to involve staff
and beneficiaries. The recommended and possible involvement will differ based
on local contexts, but through studying this handbook and tools, the designated
manager will find assistance on how to undertake an inclusive process that will al-
low the answering of many of the sensitive questions and ensuring the right point
of departure.
Concrete action to take

» Securing the buy-in of staff and beneficiary users is important. To avoid setting
the scene with a concrete complaint or accountability breach, Tool 4A instead
offers a small general exercise that will remind people that complaining is nor-
mal; that complaining happens as part of everybody’s daily lives and that raising
a complaint can be beneficial for both the complainant and the subject of the
complaint. Discussions on the benefits of establishing a CM will further facilitate
a shared sense of ownership among staff members and participating beneficiar-

ies.
» Inspired by these discussions, list one to five concrete reasons why the agency
wishes to establish a CM. These will become the guiding reference and frame-
work throughout the process of developing the CM. The person who facilitates
the establishment of the CM should make repeated reference to these reasons
at all points in the process, but should also be prepared to change these as eve-
ryone becomes more familiar with the possibilities, potentials and benefits from
of the CM. The reasons are listed on the top of Annex 5I, which will be returned
to during Step 11.
The reasons behind the CM should be related to aspects of strengthening benefici-
ary accountability, but could also refer to:
General aspects: A wish to strengthen communication, transparency, participation,

dignity and a wish to bridge / limit the power gap between the strong humanitarian
agencies and the vulnerable population. Positive aspects of strengthening
accountability to beneficiaries and achieving an even more positive impact in
targeted communities should always be the main aim of a CM. See Reference 2A,
chapters 2 and 3.
Concrete breaches: Concrete problems or accountability breaches that led the

agency to realise the importance of establishing a CM may as well play a role.
These could derive from rumours of fraud or misuse of funds, incidents of sexual
abuse by staff members, an environment of allegations and distrust etc. Such
motivations for establishing a CM should not stand alone.
External requirement: Finally, some agencies may for strategic reasons wish to
strengthen accountability worldwide and for that reason the field office may have
been requested to establish a CM. As a member of HAP, for example, a CM would
be mandatory for all field operations. Others may have been invited by donors
or partners to establish a CM to address certain problems. Such motivations for
establishing a CM should not stand alone.
The setting up of a CM would constitute a threat to perpetrators and as such a CM
could prove very effective in stopping both false rumours and potential miscon-
duct. However, it is difficult to generate the necessary support for a CM that has
such motives as its driving force. What will happen when the perpetrator has been
caught? What if staff members are wrongly accused? A CM can reveal accountabil-
ity breaches, but can as well serve to protect the pure hearted. No matter the motive
behind the wish to establish a CM, sincere support is generally difficult to achieve
unless the objectives are positive and constructive.
Facilitation
User involvement ; ;;
Duration of exercise 120 minutes
Method
» 1.Introduce the purpose and ultimate aim of the workshop. (10-15 min)
» 2.Do the small exercise in Tool 4A (25 min).
» 3.Make a larger presentation and introduction of Reference 2A by using Tool 4F
and Tool 4G. After and during the presentation, workshop participants are invited
to ask questions (50-60 min).
» 4.Based on the PowerPoint presentation (Tool 4G) and inspired by the local con-
text, identify the agency-specific purposes of the CM. The facilitator is encour-
aged to draft a few objectives in co-ordination with the management based on
which the discussions can take off. In some situations, management may wish to
suggest the objectives in advance. (10-20 min)
NOTES:
STEP 2
Define what constitutes a valid complaint

Define what constitutes a valid complaint based on a familiarity
with the local complaint customs, including likely complaints to
Objective
be posed to the agency, who the potential complainants are and
what the sensitive aspects are.
Through one or two tools, to analyse the complaints culture and

Means
identify sectors to become subject to a CM.
A complaints map. A map of relevant complaints being received,

Outcome who the complainants are and whether the individual complaint is
sensitive or not.
Tool 4B – Choosing sectors

Annex 5A – Choosing sectors (template)
Tools
Tool 4C – Mapping complaints
Annex 5B – Mapping complaints (template)
Reading
What constitutes a valid complaint? An important aspect in answering this question

is related to what is relevant and within the control of the organisation. The answers
to these questions will influence the whole design of the CM, determinate the chan-
nels through which beneficiaries can complain and guide how the complaints pro-
cedure is organised. The answers should build on and be framed by the reasons for
establishing a CM identified under Step 1. These reasons may need to be adapted
if they are either too wide or too narrow.

» Identify the object of the complaint (what types of complaints and/or in relation to
what) by using one or both of the following two tools:
Tool 4B: This Tool will enable staff to choose the most relevant sector(s) or
programme component that should become subject to a CM. This tool is most
applicable for the programmes that are not yet operational and where the staff is
not yet familiar with the types of complaints received. The tool and subsequent
exercise can be done by the designated manager solely or in consultation with staff
members, but most often it is more relevant to turn to Tool 4C. Annex 5A is linked
to this Tool.
Tool 4C: This tool is an exercise to be conducted with national staff and preferably
beneficiary representatives to map and categorise complaints and potential
complainants. This tool is most applicable for existing / ongoing operations.
Involvement of national staff, especially in the exercise linked to Tool 4C is important
to facilitate commitment and a successful materialisation of the CM. Annex 5B is
linked to this Tool.
Tool 4C can be completed without completing Tool 4B, but the information gener-
ated from the exercise linked to Tool 4C will be used in the following two Steps and
must be completed.
» On the basis of this analysis, a clear impression is provided on the types of com-
plaints received, and hence what a CM should address. From especially Annex
5B, a pattern may have emerged as to area(s) or sector(s) most relevant to focus
on in terms of establishing a CM. The agency will probably not be able to address
all types of complaints from all types of complainants. Step 3 will define who will
have access to complaint!
The list of acceptable types / categorise of complaints will be tentative at
this stage. The acceptable complaints needs to be easy communicable and
logic2 without footnotes and extensive set of pre-conditions. The definition of
acceptable complaints is closely related to Step 10 on designing an informa-
tion campaign.
Facilitation
Duration of exercise 50-70 minutes
Method
» This Step is best facilitated in plenum using a projector with a person filling out
Annex 5B as the input is provided by the workshop participants. Alternatively,
a flip chart can be used. As the outcome of Annex 5B will inspire the following
steps, it is recommended to make a relatively exhaustive list of complaints and at
least cover different types of complaints and complainants (see different types of
complainants under step 3). When involving field staff, it may be relevant to focus
mainly on the complainants that national staff has interaction with.
» This is mainly a brainstorming exercise and a session where the input from na-
tional staff is valuable and can generate the necessary ownership by the partici-
pants.
NOTES:
STEP 3
Define who will have access to use the CM

Objective Decide who will have formal access to use the CM
Analysing the complainants identified in Annex 5B and consider-

Means
ing other potential and relevant complainants / users of the CM..
A list of acceptable users, who will have access to use the CM,
Outcome and argumentation why other relevant stakeholders do not have
access.
Tools Annex 5C – Who has access to complain
Reading
In Step 2, the de facto complainants, whzo come to the agency to voice their con-
cern or dissatisfaction, were listed. The optimal solution would naturally be to allow
access to everyone addressing a valid and relevant issue to the agency, but there
could be many reasons why the agency wishes to focus on a certain group or limit
the accepted groups of complainants. The obvious users of the CM are the direct
beneficiaries of the programme, but in order to facilitate optimal accountability to the
very same beneficiaries, other groups should as well have access to file complaints.
The next step is to decide on who will have access to use the CM.
All complaints related to, and stakeholders affected by, agency activities (directly
or indirectly) should have a forum for voicing their complaints or concerns. This
need not be the same forum for all (see Step 4), but access should in principle be
granted. Maybe a separate channel is not needed for all stakeholders as they have
other ways of approaching the agency (e.g. donors could be argued as relevant
complainants, but they would most likely direct their complaints directly to HQ or
Country Director and not through a field-based mechanism). Another constraint is
that the field mechanism may not have the capacity or competency to deal with all
stakeholders.
Agencies tend to be very focused on reporting guidelines presented by the donor,
while commitments to the beneficiary population are met with a larger degree of
flexibility. The reason why stems from the uneven power balance between the do-
nors, who have direct and immediate power to withhold or cease funding based on
legally-binding agreements, whereas the beneficiaries, who may not even be aware
about the commitments that the agency has taken upon itself on their behalf, have
very limited powers to hold the agency accountable.
This accountability breach is also the responsibility of inflexible donors focusing rig-
orously on reporting guidelines. Yet since humanitarian agencies take the responsi-
bility for being accountable towards beneficiaries, and other affected groups, there
is still a need to ensure a fair power balance by allowing access.
In order to make sure that potential users of the CM are given necessary focus,
please include the considerations listed below of the different groups. The list is not
exhaustive as other stakeholders could be relevant in your area of operation.
» Direct beneficiary (refugee, partner organisation of a capacity building pro-
gramme etc).The direct beneficiary must have access to a mechanism devel-
oped to strengthen accountability to them.
» Potential beneficiary (e.g. family from the targeted community just falling outside
the criteria for assistance, other local NGOs not targeted for e.g. capacity build-
ing etc.).
Identifying beneficiaries based on vulnerability criteria is difficult. As a means
of avoiding mistakes due to incorrect assessments or registrations, or if the
applied beneficiary criteria does not capture the most vulnerable segments
in the population, it is relevant to allow potential beneficiaries access to file
complaints within a certain set of criteria.
If a potential beneficiary does not have access to voice complaints, he /she will
continue to feel cheated by the agency, which could lead to conflict, rumours
etc. Such deterioration deriving from the agency’s presences and work is an
agency’s responsibility and could be limited by granting this certain group access
to the CM.
» Host community / displacement affected community (The resident population of
the community in which a programme is targeting e.g. refugees)
Humanitarian agencies influence the communities in which they operate, and
they are accountable both for the positive and the negative impact posed. For
this reason, it is relevant to consider whether the host community should have for-
malised access to complain about unfortunate side effects (e.g. the micro credit
programme is generating unfair competition, environmental complaints etc.).
The CM could serve as a means to avoid alienation of the targeted population
and to encourage communication, and this too is the agency’s responsibility to
avoid if alienation of minorities or groups is generated by their presence. A CM
can build bridges between populations if incorporated properly into the agency’s
approach, or it can at the very least avoid widening the gap.
» Agency staff (e.g. own agency staff complaining about colleagues, misuse of
funds within the agency etc.)
Agency staff is often the best sources to identify the most serious accountability
breaches, and within many agencies, staff members have a responsibility to in-
form if they become aware of misconduct (misuse of funds, harassment, sexual
abuse, and neglect etc). It is the responsibility of the agency, though, to make
sure that a proper line of communication is established3. Staff member are unfor-
tunately also often the source of serious accountability breaches.
Some may feel confident in going to the management, others may need a facilita-
tor to report these kinds of accountability breaches. The mere access for staff to
complaints may serve to limit misconduct. As some agencies have a code of con-
duct for staff, the CM could be a good facilitator for identifying potential breaches
and process them in a proper manner. According to the HAP Benchmarks, staff
must have formalised access to complain.
» Other NGOs, authorities, donors and other stakeholders
There could be other relevant stakeholders who may need access to file com-
plaints. Very often, they will have other channels to tell the agency about their
observations or concerns, but there could be a reason for the agency to suggest
a more formalised procedure for complaints handling.
Please note that the issue about HOW the stakeholder should complain is dealt
with in Step 5. According to the HAP Benchmark 5, intended beneficiaries, disaster-
affected communities, agency staff, humanitarian partners and other specified bod-
ies must have access to complain. All these stakeholders are relevant, but exemp-
tions are allowed (security, capacity, protection of groups etc). Please refer to HAP
Benchmark 5 in Reference 2C.

» Based on the outcome of the exercise in Tool 4B and the input provided above,
potential complainants are listed using Annex 5C. Consider the list of all potential
types of users of the CM and decide whether they should have access to com-
plain. In Annex 5C, a number of tentative potential users are listed in the left hand
side. Based on the local context, it may be relevant to include other potential
groups and / or sub-divided groups. Some of the listed may not be relevant.
There may be reasons both for and against allowing certain stakeholders access
to complain, but write down carefully, with the reasons why, certain (relevant)
groups are not allowed access to complain (as requested under the HAP certi-
fication).
Facilitation
User involvement ; ;
Method
» 1.The facilitator makes a presentation of the different types of potential complain-
ants (e.g. inspired by those described in the Step) and opens the floor to alter-
native suggestions on groups who are affected by the agency’s humanitarian
operation (and hence could have access). The presentation will be inspired by
the output generated from Annex 5B.
» 2.Facilitate in plenum e.g. using preferably projector with a person filling out An-
nex 5C as the inputs are provided (as the results will be used throughout the
process) or flip chart. The issue to be discussed in a larger plenum is mainly
which groups that the national staff members interacts with in the field (other than
direct beneficiaries) should have access to complain.
NOTES:
STEP 4
Design the Complaints Handling System
Design the Complaints Handling System, including a decision on

Objective
the complaints boards and appeals system
Based on the list of expected complaints and complainants to

Means analyse and map users and for the agency to ensure an effective
and safe system.
Design the composition of the complaints boards and a ma-

trix showing the different systems through which the different
Outcome
complaints will operate, based on levels of sensitivity. The matrix
includes the appeals systems.
Reference 2B – Minimum requirements for a CM

Tools Tool 4D – Setting up a complaints handling system
Annex 5D – User and appeals matrix
Reading Reference 2A, Chapter 3
Having identified the users of the CM, the next step is to decide on the Complaints
Handling System. The Complaints Handling System is the agency apparatus that
decides on the complaint and remedy, and consists of one or more Complaints
Board. The Complaints Boards processes the complaints and are normally hierar-
chically structured with one acting as an appeal to the other.
Complaints Board Level 2
Appeal
To set up a Complaints Board, it is relevant to use two documents. Reference 2B

introduces the minimum requirements and Tool 4D guides the process of develop-
ing a Complaints Handling System:
Reference 2B – Minimum requirements for a CM

Reference 2B is a presentation of the mandatory standard and the four mandatory
outputs that all CMs must comply with in order to qualify as a CM. These minimum
requirements were introduced in Reference 2B. Reference 2B constitutes a core
point of reference for the following Steps with a special focus on output 4, which
deals with complaints boards.
Tool 4D – Setting up a Complaints Handling Board

This tool provides input for consideration when deciding on the design and com-
position of the Complaints Board, in terms of who could be a member, appeals
possibility, appeals body etc. Please take specific notice of the section on aspects
of sensitivity.
The requirement to be met under this Step is output 4. It reads:
“Complaints are processed by a competent body guided by transparency, con-

fidentiality and impartiality”.

Having studied both tools, the following questions should be addressed.
» 1.In Tool 4D, a Complaints Handling Body is exemplified, consisting of a main
body and a secondary body. Describe and draw a model of the complaints bod-
ies in your Complaints Handling System, reflecting on the following issues:
Which levels does your Complaints Handling System comprise of?
- This should be done on the basis of the types of complaints expected to be
received (as outlined in Annex 5B).
- Maybe you need only one level if the mechanism does not address sensi-
tive complaints. Maybe two or three level 1 is required as they have different
qualifications or sector expertise.
Who is represented in each of the bodies?
- Take into consideration which potential users could have their confidentially
breached by the persons chosen to sit at the Complaints Boards.
- Maybe one from the relevant sector should always be represented.
Reflect briefly on how the composition fulfils output 4, which focuses on aspects of
impartiality, transparency4 and confidentiality of the body. Inspiration can be drawn
from Tool 4D and will be relevant for completing Step 11.
» 2.In order for the beneficiaries to know whether to address their complaint to one
or the other complaints body, draw up a tentative definition of what constitute a
“sensitive” and a “non-sensitive” complaint. This distinction is of course up to the
beneficiaries to decide, but guidelines need to be communicated for both exter-

nal and internal purposes. Draw on the outcome of the exercise linked to Annex
5B. Acceptable complaints and the scope of the CM have already been identified
under Step 2.
» 3.On the basis of the Complaints Handling System that has been decided and
the CMs intended users, fill in Annex 5D with the identified complainants, to
whom the sensitive and non-sensitive complaints should go and the appeals
body / institution for each group. The decision / discussions should be inspired
by Annex 5C.
» 4.Please note that in order to comply with HAP Benchmark 5.2e (see Reference
2C), the agency is required to formulate a “confidentiality and non-retaliation
policy for complainants”. This can be done simply by committing to these princi-
ples and to communicate this commitment to the user population. The Agency
HQ may have a more elaborated policy or guide to be used and such could be
made part of the Staff Code of Conduct.
Facilitation
User involvement ;
Duration of exercise (not suitable for a large group)
Method
» Designing a Complaints Handling System is difficult in a large forum and prob-
ably better done by a small group. However, it is relevant to include, for example,
a senior staff member and a beneficiary representative, to provide input as to
whether the systems will be trusted by the users and to keep the process trans-
parent. Tool 4D and Annex 5D will guide the process.
NOTES:
STEP 5
Design entry points for the users when filing complaints
Design the user-agency interface in terms of where the com-

Objective
plainant should go in order to submit the complaint.
Analysis of the local context and considering the directions pro-

Means
vided in the Step description.
Complaint entry points. List of the different types of entry points

Outcome
through which the users can complain.
Tools Annex 5E – User entry point analysis
Reading Reference 2A Chapter 4.3, Reference 2B
The main challenge in developing appropriate entry points to the CM is to ensure an

open and straightforward user-agency interface. Step 6 will consider in which form
complaints should be submitted, while this Step will dedicate attention to answering
the question: Where should the complaints be submitted? It is important to be aware
that Step 5, Step 6 and Step 7 are very closely related and difficult to separate.
The minimum requirements are addressed in Output 2, and it is relevant to look
to Reference 2B for direction and inspiration on how to ensure that the Output re-
quirements are met. Read through Reference 2A chapter 4.3 for inspiration and
additional information.
How to submit a complaint

Output 2 “Intended users have safe and easy access to use the CM”.
Aspects of “safe” and “easy” must be “user perceived”. This basically means that the
user should find that the CM is safe and easy to use – not necessarily the agency.
For this to be achieved it is logical and recommended to involve the users in help-
ing define agency-user interaction. If the user does not feel comfortable with the
user-agency interface, the CM will most likely not be used. The fact that the CM is
not used cannot necessarily be regarded as an indication that there is nothing to
complain about. More likely, the organisation has failed in setting up a mechanism
that the users understand and trust.
Applicable means of submitting complaints differ and it is required to consider the
level of literacy among the users, the type of user, special protection issues for vul-
nerable people or minorities, gender, the type of programme, distances / geography,
ethnic tensions etc. Furthermore, the system chosen should take into account how
information is best communicated (see Steps 9 and 10). All these issues need to be
considered when designing appropriate means of submission.
Below, a few suggestions are listed on concrete entry points for the complainant to
use, including a few comments on their strengths and weaknesses. First, though, a
few important and general issues to consider.
» The requirement in Output 2 that the users have safe access to use the CM is
not only a matter of physical security, but underlines how important it is for the
system to admit sensitive complaints. In order to facilitate both sensitive and non-
sensitive complaints, two different means of submitting complaints are normally
necessary. While the non-sensitive complaints could be directed to open ses-
sions (e.g. to a public information centre opened on a weekly basis), more sensi-
tive complaints should be granted more confidential and private access.
It is normally not advisable to allow submission of anonymous complaints as
they are difficult to investigate and tend to be linked to rumours. In some contexts,
though, it could be necessary to set up a system allowing complainants a cer-
tain level of discretion, where a complaint can be submitted without third parties
knowing. These include – but are not limited to – aspects of sexual abuse, misuse
of resources or power and neglect. Please refer to the material developed from
Annex 5B on types of sensitive complaints in your context.
» The mechanism needs to be visible and known to all users. This is linked to the
information system and, for example, levels of literacy and traditional / existing
means of communicating.
A maximum distance for travelling should be set. Otherwise, the CM will discrimi-
nate those living far away and cannot travel due to health, age, time or financial
reasons.
» The area of the CM needs to be safe for all to access. Alternatively, other access
entry points should be suggested to avoid de facto discrimination.
» Communicating to the users. The system needs to allow access to information
about the purpose, procedures and restrictions of the CM. Who can complaint
and about what, how to complain, how the complaint is processed (see Step
10).
Examples of means through which the complaint can be submitted:

» A sealed box hanging in the village or in front of the office, which is emptied regu-
larly by agency staff. This, though, allows only written complaints and does not
enable the agency to provide assistance and guidance on what the procedures
are. A complaint box does not provide confidentiality.
» Fixed days where the agency office is open to receiving complaints.This is a very
open and transparent access, but could as well generate too much noise and
crowds in the office.
» Information booths open regularly in the project implementation areas.This could
be an active way to facilitate communication in general and for other purposes,
which limits the distance between agency and beneficiary.
» Information Manager visiting project implementation areas on fixed days to facili-
tate complaints.
» Allow complaints submission through the internet. This requires access to the
internet, but usable especially for partner complaints or complaints directed to
HQ.
» Allow complaints submission through posted mail or by phone.
» Direct access to talk with higher managers. This is relevant for the most sensi-
tive complaints, and is a very accountable and dignifying system, but with large
numbers, could take up much time.
» Facilitated through weekly village meetings, where issues can be discussed and
potentially addressed on the spot. This method is best for more general issues
and does not allow for sensitive issues to be raised.
A combination of different means is advisable. Normally, it is possible to choose
means where the benefits and strengths of one cover for the drawbacks of the
other. Use your imagination and involve staff and beneficiaries in the decision.

With the above considerations and guidelines in mind, identify and analyse possible
entry points
Means of complaints submission. Which entry points will the user have for com-
plaints submission to each of the Complaints Boards? It could be relevant to re-
view the list of concrete complaints and complainants generated during the exercise
linked to Annex 5B and through these, consider which type of entry point should be
recommended.
The number of types of entry point is a balance between optimal and manageable.
The challenge is to allow safe and easy access, without unduly using up too many
additional resources. Too many entry points could as well confuse the logic and
simplicity of the system. It remains relevant at this stage to suggest and analyse a
number of entry points to the CM. It is equally important, though, to keep in mind
that the system may need fine-tuning. The decisions taken in the coming Steps may
require changes to the entry points, why this is best regarded as an analysis of the
most applicable options.

The entry points should preferably be identified in close co-ordination with nation-
al staff members and representatives from the user population. The exercise de-
scribed in Annex 5E can help the process. The outcome of the analysis can be to
select the most appropriate entry points and provide input to aspects that needs to
be reflected when designing the Complaints Processing Cycle in Step 7.
Facilitation
User involvemen ; ;;
Duration of exercise 50-90 minutes (90 min if Steps 5 and 6 are combined)
Method
» 1.The facilitator makes a presentation in plenum about some of the issues to
keep in mind when identifying entry points for complaining. The presentation
should be put in perspective with examples from the local context
» 2.Annex 5E is explained.
» 3.Based on the number of workshop participants, the exercise is done in plenum
or in smaller groups. The groups can be divided to focus on such issues as types
of complaints, sectors or types of complainants, and fills out Annex 5E. Step 5
and Step 6 are presented interdependently in this handbook, but it could be rel-
evant to task the groups with addressing both issues simultaneously.
» 4.When the groups return, they each present the results of their discussions. In
most cases, a combination of solutions is best. At this stage, it may not be pos-
sible (or advisable) to reach a final decision, as the set up may be adapted fol-
lowing decisions taken in the coming Steps. A few systems can be decided with
a rough description of the procedures to be identified.
NOTES:
STEP 6
Decide the form in which the complaint should be submitted
Decide in which format the complaints should be submitted,

Objective
including the development of a complaints form
Analysis of the local context and consideration of the directions

provided in the Step description, including aspects of anonymous
Means
complaints and written as opposed to verbally submitted com-
plaints.
Outcome List of acceptable complaints formats
Tools Annex 5F – Complaints form
Reading Reference 2A Chapter 4.3, Reference 2B
This Step will focus on answering the question: In which form should the complaints
be submitted?
The minimum requirements to meet are addressed in Output 3. Reference 2A chap-
ter 4.2 may also provide relevant inspiration and information.
Output 3 “Logical and easily-understood procedures developed for submis-

sion, processing and response / redress of complaints”.
Referring to the wording of Output 3, this section will deal with the submission of
complaints, while processing and response / redress is described in the next Step.
Whereas Step 5 helped to decide on the interface between user and agency in
terms of physical submission, this Step deals with the question of which form / for-
mat the complaint is presented.
The reason why the procedure should be logical and easy to understand is to avoid
that extended level of education is needed to understand and use the system, and
to ensure that the users find trust in the procedure. As the procedure should be
easily accessible, and easy to use, it is relevant to consult with staff and users to
facilitate this Step. A number of aspects to consider:
Written as opposed to verbally submitted complaints.

Accepting only written complaints would in many contexts discriminate a large per-
centage of potential users, but there are a number of reasons why sticking to written
complaints would be beneficial both to the user and the agency.
» In order to process a complaint, the agency and the complainant need to have a
clear and mutual understanding of the grievance that does not allow for misinter-
pretation. This is best secured in writing.
» The complaint should preferably be signed by both parties to limit the danger of
(accusation of) alteration, and allow for better and precise response to a concrete
issue.
» For the CM to constitute a systemised feedback mechanism for programme plan-
ning, the complaint and redress need to be computerised.
» It is important that the system allows for another person (the Complaints Board)
to process the complaint different to the one receiving the complaint (e.g. the
information officer). Complaints may not be processed immediately, and verbal
transmission only increases the danger of details being lost or altered.
For these reasons, it is beneficial both for the agency and for the user, that com-
plaints are submitted in written form. As indicated, though, discrimination of those
who cannot write needs to be addressed.
The question about the form in which the complaints should be submitted requires
the agency to balance the benefits against the local context. One solution could be
to allow that a family member writes the complaint on behalf of the complainant,
who then signs. Alternatively, or in addition, the complaints submission system may
then allow agency staff to write down the complaint on behalf of the complainant,
which the complainant signs. The latter could be facilitated by the opening of a
manned “Information and Complaints Desk”.
Requirements for and design of the complaints form (example in Annex 5F)
It is an optimal solution if the system allows for the complainant to receive a written
token as proof that the complaint has been handed in or accepted. The provision
of a token with a unique number for complaints accepted by the complaints of-
fice “protects” the agency and the complainant from misunderstandings in terms of
whether a complaint was within the scope of the CM or whether the complaint has
been submitted in the first place. Without a written token, these issues are difficult
to prove and could lead to allegations and mistrust. With a token, the complainant is
simply asked to bring it when requesting a response. Please refer to Step 9 on how
to respond to complaints.
The complaints form should preferably have a section where the user signs to ac-
cept the legitimacy of the Complaints Handling System and the composition of the
Complaints Board that deals with the complaint.This is an important basis for reach-
ing a decision (positive or negative) that both parties accept. The complainant does
not necessarily accept the response provided by the Complaints Board, but cannot
afterwards – if dissatisfied with the response – complain about the procedure or the
composition of the Complaints Board. If the beneficiary from the start does not ap-
prove the legitimacy of the system, it does not give sense to process the complaint.
It is worth considering how to allow the complainant to relate their expectations in
terms of outcome. Sometimes a complainant may not wish to be compensated, but
simply expects a moral recognition of being right. An indication of the expected
outcome of the process can guide the complaints handling board toward the kind of
solution they should be seeking.
For sensitive complaints, requesting written submission may constitute a barrier.
Often with these types of complaints, the complainant does not wish a reply, but
simply wants to alert the agency to the accountability breach. An option to protect
the complainant is that the Country Director or dedicated board can take notes for
further investigation, and such issues do often not need the same level processing,
filing and response.
Annex 5F is an example of a complaints form that includes the main requirements.
This is a very general form, which can be made much more specific, and to hence
increase the possibility for the Complaints Board to decide on the outcome of the
complaint immediately instead of initiating an additional investigation. If the com-
plaints, for instance, always fall within certain categories, it could be beneficial to
develop a specific form (e.g. for complaints related to one’s status on the distribu-
tion list, or for the technical complaints related to construction work). Through this,
key information can be provided immediately. Continuous improvement to the form
leads towards improvement of the system.
The complaints format is to ensure that key information is collected (name, date,
description etc.). As mentioned above, many forms may be required to best facilitate
different types of complaints, while sticking to the effort of keeping things simple.
Each will be signed by the user (and if possible by an agency staff member). For
each complaint submitted, the token / slip should be given to the complainant, read-
ing a unique number matching the one on the complaints form. This slip should as
well include a date (and place) where the complainant can receive a response. If
the system does not include face-to-face contact, it should be clearly stated when,
where and how the complainant can receive a response.
Concrete action to take:
» 1.Prepare suitable forms to be used for complaints submission. It should be

adapted to the chosen means of complaints submission – it may be necessary to
change the means if the required form is not applicable. Please see Annex 5F as
an example that presents the main requirements of a complaints form.
Facilitation
Duration of exercise 30-90 minutes (90 min of Steps 5 and 6 are combined
Method
» 1.This Step is introduced including the main issues important to consider.
» 2.As Step 5 and Step 6 are interdependent, it could be relevant to task the groups
with addressing both issues simultaneously. The concrete design of the format
should not be done during a workshop. A format made in advance can be shared
for commenting but the input from national staff and users is most valuable in
relation to the level of literacy and adaptation to user-know / existing systems and
traditions.
» 3.Having worked through Step 5 and Step 6, a possibility is to identify a group
dedicated to the task of fine-tuning.
NOTES:
STEP 7
Describing the complaints processing cycle
Describe the internal cycle that the complaint undergoes from

Objective
receiving the complaint, processing and responding
Analysing the local context in trying to identify the most appropri-

Means
ate system for the CM.
Outcome A map / description of the complaints processing cycle.
Tools Non specific.
Reading Outputs from Steps 5 and 6, and material generated from here.
Describing the Complaints Processing Cycle is a task that you may not be prepared
to do to its full extent at this stage, but it is relevant give initial thought to what the
process will be. How often the complaints boxes are emptied if you plan such? How
long should the user wait till they will have a response? Where can the user get a
response to their complaints? etc.
Before making the cycle description, it is necessary to briefly consider the relevant
outputs and to consider aspects of sensitivity:
Relevant outputs
When looking to the minimum standards, Output 3 stresses that the procedure for
“processing” the complaints must be logical and easily understood, whereas Output
1 gives emphasis to the fact that the procedure of the CM must be communicated
and made available to relevant stakeholders. Consequently, the procedure must be
made and communicated in a form where the potential users of the system easily
understand it and has easy access to find it. Users and beneficiaries should ideally
be consulted whether the procedure and the description / explanation of the proce-
dure is acceptable.
Aspects of sensitivity
The Complaints Processing Cycle for sensitive vis a vis non-sensitive complaints
are very different. Non-sensitive issues can be dealt with in a more public manner
and does not need discretion, it is different with sensitive issues. Sensitive issues
are much more diverse in content, as a high level of confidentiality needs to be
respected. The mere fact that a certain person in the community is seen submitting
a complaint can be sensitive and endanger this person. Please refer to the sec-
tion in Tool 4D entitled “Aspects of Sensitivity” for more information about sensitive
complaint.
One universal complaint processing cycle cannot be developed, as the local con-
text always requires consideration. To provide inspiration to how a context-specific
system may look, an example has been made below. It is important to note that the
system dealing with sensitive aspects de facto operates independently from the
system dealing with non-sensitive ones.
Example of the Complaints Processing Cycle

1. Every Monday at 10-11.00 AM, complaints boxes (hung at all villages where the
agency is operational) are emptied by the Agency Information Manager and a com-
munity representative. At the same period of time, it is possible to approach the
Information Manager with complaints, if e.g. the complainant is uncertain about the
system or cannot write. A complaints form is filled and signed. A receipt / token is
provided. On the same day, complaints handed directly to the Agency office are
compiled. Persons submitting a complaint use the standard form and rip off a re-
ceipt from the bottom of the page containing a unique number (See Annex 5F).
Complaints are put into an envelope marked ‘S’ for sensitive and ‘N’ for non-sensitive.
It is as well possible to hand sensitive complaints directly to the Country Director at
the office.
2. Every Tuesday, the Complaints Handling Board (consisting of a Community rep-
resentative, the Information Manager, an Expatriate Project Manager) meets in the
Agency office. All envelopes, marked “N” are opened, and the complaints are dis-
cussed and decided upon. In situations of disagreement or lack of (e.g. techni-
cal) information or knowledge, agency staff specialists, or the Country Director, are
called to assist or clarify issues. Sensitive issues and envelopes marked “S” are
handed over to the Country Director for him to deal with solely.
3. Based on the decisions reached, the Information Manager enters the response
/ decision including possible remedy into the database. Copies are printed and at-
tached to the complaints form, and two sets are brought to the field.
4. The following Monday, the Information Manager and the community representa-
tive are back in the village at 10-11.00 AM.The complainants come to receive a copy
of the response to their complaint and receives an explanation, if any questions. The
complainant is presented with his appeals options. He is explained the procedure for
using these and exact information / explanation of the next step if the complainant
is granted some kind of remedy. Two copies of the complaints form are signed - one
for the complainant, one for the agency file.
5. When all the responses have been given, the cycle starts over with emptying the
complaints box for new complaints.
» First Monday in every month:

- Information meetings are held to inform about the CM and to discuss the
procedure.
- Agency informs about the programme in general (incl. what the CM has led
to).
- New beneficiary representative is elected / chosen. Male – Female are rotat-
ing.
» Parallel to the above system:
- The HQ has established a CM at the Agency website through which all stake-
holders are able to present their complaints to senior management as well
as to read about the system. Though the beneficiaries do not generally have
access to the internet, donors, staff members and other stakeholders have
the possibility to draw issues to the attention of the agency.
- At the website, it is possible to fill or print out complaints forms.
» Sensitive complaints:
- The Country Director joins the team first Monday every month to receive sen-
sitive complaints (e.g. as the Agency office is located 5km away). Response
is provided in sealed envelopes during the following cycle.
- Users have access to visit the Agency office to meet with the Country Direc-
tor personally to share sensitive issues and complaints.
Concrete action to take:

Based on the input and inspiration from above and the results from earlier Steps,
make a step-by-step description of how the processing cycle should work – a Com-
plaints Processing Cycle. The effort may lead to change in the means of submitting
complaints as new options become clear, and decisions taken in earlier Steps take
effect. The description must be very simple and understandable to all users of the
CM.
Facilitation
Duration of exercise 30-50 minutes (time for feedback and discussions in plenum)
Method
As with Steps 5 and 6, Step 7 is related to the direct interaction between agency
staff and users of the CM. For this reason, extensive involvement in the decisions
taken is recommended.
»1.The decisions taken in Step 5 and Step 6, the concrete procedure for the CM
user to follow will to some extent be self-explanatory.
»2.Based on the entry points decided, it may be advisable to set up a 3-5 person
working group to describe procedures guided by initial input from plenum. This
group should preferably have representation from field staff and potential users.
»3.If possible, the recommendations provided by this working group could be sub-
ject to comments from a larger forum. Be aware not to make a too extensive and
resource demanding system though this will often be the easiest compromise!
NOTES:
STEP 8
Decide on the procedures for investigating complaints
Decide on the procedures and persons for investigating com-

Objective
plaints.
By considering the input and presented aspects in the Step

Means
description.
Outcome An initial mapping of who should investigate which complaints.
Tools Annex 5B – Mapping complaints
Reading Non specific
Deciding on the exact procedures for investigating complaints differs from whether
they are sensitive or non-sensitive, and of course on how the system is set up. This
Step will provide some important considerations as well as draw attention to some
general objectives that should be achieved.
The Output to comply with is mainly number 4, stipulating that complaints are proc-
essed by a competent body guided by the concepts of transparency, confidentiality
and impartiality, which is relevant for both sensitive and non-sensitive complaints
alike. The difference is related to the emphasis on the four key words (listed in the
table below).
Below, please find a few general considerations about their importance vis a vis
investigation of complaints.
Sensitive Complaints Non-sensitive Complaints
The competency of the The competency of mainly

Complaints Handling System the Complaints Board in
stems from its ability to re- terms of having (access to)
Competency main confidential and whether the necessary (e.g. techni-
it has the necessary power to cal) qualification and power
take appropriate action. to decide and enforce their
decision.
It is difficult to describe a fixed Transparency is mainly

procedure for dealing with relevant in the sense that
sensitive complaints. These the complaints are proc-
Transpar- complaints are complex. A essed against publicised and
ency person’s decision to complain beneficiary-known criteria,
will often be an issue about along with the transparency
trusting persons more than of procedure and Complaints
the system. Board composition.
Confidentially is of extreme Confidentiality is relevant,

importance when dealing with but often not significantly.
sensitive complaints as it is The system should respect
Confidential-
related to the protection of the basic principles of protect-
ity
complainant. The protection of ing names and information,
names during the investiga- but no extraordinary effort is
tion process is critical. required.
Impartiality is critical. Sensi- Impartiality is important in

tive complaints are serious terms of the Complaints
and potentially with severe Board not being biased in its
consequences for the com- decision. Too complex a sys-
Impartiality
plainant and the subject of tem increases the danger of
the complaint. It is important unnecessary breaches within
that only relevant persons are the system.
involved in the investigation.
When reviewing the comparison of sensitive and non-sensitive complaints against

these four concepts, it is striking to see that whereas the non-sensitive complaints
are processed by a system, the sensitive complaints are processed by a person.
Whereas the complainants addressing a sensitive issue put his/her trust in a person,
the non-sensitive complainants put their trust in a system.
When examining this aspect of investigating complaints, the necessity of differenti-
ating between sensitive and non-sensitive complaints is again relevant. Investigating
these two categorise of complaints will be dealt with separately.
Investigating non-sensitive complaints

As mentioned above, the investigation of non-sensitive complaints is very much an
issue about ensuring the integrity of the system, with key values of objectivity, trans-
parency and competency. The setting up and composition of the Complaints Board
has already been addressed in Step 5 and normally the board will be able to decide
on a complaint amongst themselves without additional investigation.
The details in terms of who undertakes additional investigation, if an issue cannot be
decided by the Complaints Board, depends on the complaint. Such circumstances,
the problem will be either a lack of information or a need for the agency to verify the
correctness of the information provided by the complainant, for example, by confirm-
ing that the person fits the vulnerability criteria, or by checking that the installation
of the sink in the bathroom indeed is done inappropriately and needs to be redone.
In order to undertake additional investigation, it is important that key basic informa-
tion on the complaints form is recorded, allowing the agency to find the person once
again. As the system becomes operational and the most typical kinds of complaints
form a pattern, the system can be made more effective by carefully considering
which questions to be asked in the complaints form and how to better formulate
these (see Step 6). It will, though, probably always remain necessary to be able to
dispatch, for example, a two-person team to verify or check the claims put forward by
the complainant. An important aspect to respect is that at least one of the investiga-
tors should be independent from the issue to be investigated.
Investigating sensitive complaints

Investigating sensitive complaints is more difficult and on several issues it is impor-
tant to have a clear understanding between the agency and the complainant prior
to an investigation.
» What does the complainant expect the outcome of the process to be? (Does the
complainant simply wish to draw attention to a problem or to have compensation/
remedy?)
» Clarification of the implications of an investigation. (Persons necessary to in-
volve, exposure / role of the complainant in the investigation.)
» Aspects of sensitivity (that could potentially be jeopardised, is the person pre-
pared to step forward to publicly announce the accusations of e.g. assault)
» Clarification about what the agency is prepared to do and potentially how far it is
prepared to go.
» What is the likeliness of the investigation being successful?
» Under which circumstances would the complainant not wish to go any further?
Under which would the agency need to stop the investigation?
For many, it may have been a significant and important decision to put forward
their complaint. The implications and consequences of initiating an investigation
can be extensive, and it is important that both parties are aware of the process and
have made clear what they each are prepared to invest. Initiating the investigation
could potentially endanger the safety of the complainant, but may often also have
serious consequences for other persons who were maybe not willing to have this
issue advertised. Though difficult, the agency representative and the complainant
will need to try to foresee the process and the outcome to know the full extent of
the consequences.
The investigation necessary to undertake differs based on the great variety of types
and circumstances.
The main aim of this Step is to provide input for the necessary considerations
related to investigating sensitive and non-sensitive complaints. At this stage, it
could be relevant to revisit the information generated in Annex 5B, simply to see
which kinds of complaints are possible. Consider the following questions:
» When additional information is requested from the complainant, or the informa-

tion provided needs to be verified, how will this be achieved?
» Who should undertake this in order to ensure an effective and impartial sys-
tem?
» Is this team able to address all the types of non-sensitive complaints or which set
up is needed?
» Who should deal with sensitive complaints?
» Can the organisation uphold such complaints?
Based on the description above, the first step has been taken in learning how to
investigate complaints. When the system is operational, it will be easier to improve
the system, not least in terms of improving the complaints format to be used.
Facilitation
User involvement ;
Method
This Step does not result in a concrete product, but is food for thought on how
to investigate complaints and the differences between sensitive and non-sensitive
complaints.
» 1.The facilitator makes a presentation of the general considerations and chal-
lenges mentioned in the description of Step 8. In terms of the difference between
sensitive and non-sensitive complaints, the presentation can draw as well from
Tool 4D and Reference 2A, section 3.
» 2.In plenum, the facilitator opens for discussion an issue to be aware of, in this
particular context, that could influence how the agency investigates complaints.
Main conclusions can be listed on a flip chart or via a projector.
NOTES:
STEP 9
Decide on the response given to complaints
Decide what and how to respond to complaints, after having

Objective
processed them.
By considering the input and aspects presented in the Step

Means
description.
Outcome Input to staff members on issues to consider.
Tools Non specific
Responding to a complaint has two aspects. HOW to respond and WHAT to re-
spond. These will be dealt with separately.
1.HOW to respond to a complaint

Responding to a complaint should ideally be done both verbally and in writing.
The outcome is explained to the complainant on the basis of a written deci-
sion, which is given to the complainant afterwards. This is important to avoid
any misunderstandings as well as to provide a proper explanation as to why a
specific decision has been made. It is the responsibility of the agency to make
sure that the response is communicated and understood by the complainant.
In many contexts, though, the actual complaints received by the agency are
very similar and related to non-sensitive issues that are better communicated
in a wider forum.
A response may be accepted by the complainant or not:
» Response accepted
When the decision is communicated and accepted, the complainant e.g. signs on
the complaints form (two copies – one for complainant and on for the agency) that
the response has been provided and accepted. This is relevant for the Agency in or-
der to close the case and prevent the issue from continuing to pop up, thereby using
up a lot of resources / time. The case is then filed and closed.
» Response not accepted
As part of the response, it is the Agency’s responsibility as well to provide informa-
tion on appeals opportunities, in case of dissatisfaction. If the beneficiary does not
accept an outcome, an appeal must be offfered unless new information is provided
that changes the circumstances and leads the Complaints Board to reconsider the
case.
If the complainant is allowed to appeal, the procedure is explained on the basis
of Annex 5D mapping the appeals body based on the type of complainant and
complaint. Most often (non-sensitive) in the case of complaints submitted by benefi-
ciaries, the complaints form will simply be given to the appeals body along with the
outcome of a potential investigation.
2. WHAT to respond to a complaint

What the response will be is closely related to the description in the information
campaign (ref. Step 10) with regard to the commitment that the agency wishes
to be held accountable. It is obviously important that the decision reached by
the Complaints Board is based on the criteria communicated and as part of the
information provided to the user of the CM.
» Negative response
If the complainant is not supported in their claim and the complaint is rejected /
not substantiated, the case is either closed or appealed. The way and reasoning by
which the message is conveyed is obviously important and should respect potential
aspects of sensitivity and dignity.
» Positive response
A positive outcome can be trickier. In the exercise linked to Annex 5B, possible rem-
edies were identified and listed against likely complaints. If a potential beneficiary
was wrongly bypassed during the assessment, the appropriate remedy in case of
an NFI distribution could be to provide him with the very same items. Sometimes,
though, all items have been distributed or funding has been used, so this is not an
option. The reply will be up to the Complaints Board to decide.
The timing of receiving a complaint influences very much the agency’s options for
remedy. Under Step 10, on how to communicate, the issue is addressed further, but
it is key to underscore in this section that the access to file a complaint and having
it considered objectively is important in terms of ensuring the dignity of the com-
plainant and hence the agency’s accountability. Even if the only remedy offered is a
recognition of the mistake make.
In the complaints form shown in Annex 5F, the user is encouraged to indicate their
own expectations to the response or remedy provided. If the complainant expects
simply an acknowledgement of a certain issue, they may feel insulted if offered
what they perceive as redemption. In another situation, the complainant may have
unrealistic expectations and may need to be explained more thoroughly the re-
sources available to the project. The danger of having the complainant indicate their
expectations is that it may raise expectations.

This Step is thought of as both input and inspiration, but does not as such generate
a concrete product as output.
Facilitation
Method
As above, this Step does not generate a concrete output. Rather, it is a chance for
users and national staff to create input on how the affected population reacts when
receiving a response.
» 1.The facilitator makes a small presentation of the issue based on the descrip-
tion of Step 9.
» 2.In plenum, potential conflicts in terms of responding to complaints should be
raised. These could include:
- How do beneficiaries react when they receives a negative response?
- How should positive and negative responses be communicated?
- What will the reaction be if the complainant is supported in their claim, but
that e.g. resources do not enable the agency to provide proper remedy?
- Is the safety of agency staff endangered when responding? (A change of
set up may be necessary.)
» 3.It will be valuable for the staff members dealing with complaints to have some
kind of guide on how to respond. Based on these discussions, a list is made of
the issues discussed that can contribute to the development of such a guide.
Furthermore, some of the challenges raised can be addressed when discussing
the CM in the communities. This will be discussed in Step 10.
NOTES:
STEP 10
Design the information campaign
Design an information campaign including how and what to com-

Objective
municate
By considering the input and aspects presented in the Step

Means
description.
A description of what to be communicated to users of the CM,

Outcome
and input and inspiration about how best to do it
Annex 5G – Means of communication as per potential user

Tools
Annex 5H – What to communicate to the user
Accountability, transparency and communication are closely related. Various aspects

of communication have received special attention in HAP Benchmark 2 reading:The
agency shall make the following information publicly available to its intended benefi-
ciaries, disaster-affected communities, agency staff and other specified stakehold-
ers: (a) organisational background; (b) humanitarian accountability framework; (c)
humanitarian plan; (d) progress reports; and (e) complaints handling procedures5.
All these aspects are relevant to beneficiaries, but obviously request different media.
Some information is provided verbally or through posters in the communities, while
other is made available though the agency’s website or provided in print. Though
this description will focus on information and communication relevant mainly for the
CM, the issue should be addressed more holistically and integrated into the existing
systems and procedures of the programme. Keep it simple and build upon existing
systems when possible!
Output 1 requests that the procedure, purpose and parameters of the CM have
been communicated and made available to relevant stakeholders. When designing
an information campaign, it is hence relevant to consider both WHAT to communi-
cate and HOW to communicate. These aspects will be dealt with separately.
WHAT to communicate.
What to communicate is related to all the information necessary for the beneficiary
to know in order to identify the gap between the assistance provided against the as-
sistance promised. Qualitatively and quantitatively. It is this gap that the complainant
could be interested in complaining about and at the same time that the agency feels
responsible for.
However obvious it may be for the experienced humanitarian worker to see what
constitutes temporary shelter assistance, for instance, the beneficiary may expect
that they were to decide on issues such as the number of windows, design, col-
our, size, electrical installations and ownership relations. He might as well have
thought that everybody in the community would receive a house and that his cous-
in would be allowed to build it. When in fact he got plastic sheeting and four wooden
beams.
If the agency wishes the user of the CM to know what he can complain about,
there mus be an explaination of both the promises and commitments that the
agency will be held accountable for and what the agency is prepared to provide as
response / remedy if the defined commitments are not met. Output 1 recommends
that procedure, purpose and parameters of the CM are the minimum requirements
to be communicated. With that in mind, it will be relevant to share the following
information with the users of the CM:
» Presentation, Agency
- Presentation of the organisation.
- Presentation of the principles, standards, assistance frameworks, codes
(incl. those applicable to staff), accountability etc. to which the organisa-
tion commits – or are prepared to be held accountable to. (Supported and
inspired by Annex 5B and Reference 2A chapter 3.1)
» Presentation, Project
- In the presentation of the project and objective, it is crucial to have included
selection / vulnerability criteria, approach and stages of beneficiary involve-
ment, description of assistance or services offered (e.g. supported by pic-
tures), funds and resources allocated and to identify donor, partners, etc.
This part should enable the beneficiary in detail to know what to expect
and the terms for becoming a beneficiary as a basis to consider whether he
wishes to or can be part of the project. It will enable the potential complain-
ant to present his concerns prior the initiation of the project and complain if
deviation is detected. As priorities, approach or else are changed during im-
plementation, the information communicated should obviously be updated.
It is important to highlight that such changes can occur. Most of this should
be reflected in the donor application, but translated into a concrete output
terminology.
» Presentation, CM
- Why. Explaining the purpose of the CM (e.g. related to accountability, im-
proving the system by learning from ones mistakes or to ensure optimal us-
age of resources – see Step 1) and the right of beneficiaries to complain.
- What. Explaining in detail what it is possible to complain about (see Step

2) as well as possible remedies (including limitations). This should be as
concrete as possible (see Step 9) - both in terms of what is provided, and
how (beneficiary involvement, consultation etc.). The scope of the CM has
already been identified under Step 2.
- Who is allowed to complain?
- How, where and when. Procedures (including how, where and when to com-
plain and receive response / remedy (e.g. explained in a simple figure), the
Complaint Handling System including the composition of the Complaints
Board (and maybe how it is chosen), how the complaint is processed and
appeals possibility, etc). In Step 4, you defined sensitive and non-sensitive
complaints. This should be reflected as well in order for the users to know to
which complaints handling board each type of issue should be addressed.
- The policy of non-retaliation against and confidentiality towards the com-
plainant. In order to comply with HAP Benchmark 5.2e (see Reference 2C),
the agency is required to formulate a “confidentiality and non-retaliation pol-
icy for complainants”. In terms of communication, it is sufficient to commit to
these principles and to communicate this commitment to the user popula-
tion.
It is important not to communicate too much to beneficiaries. Not that they do not
have a right to know, but too much information can blur the key message. If the op-
eration and the CM is building upon a solid pillar of accountability, the fundamental
trust that beneficiaries have to the agency will remain more important than an ex-
tensive amount of information.
The information and the details to be communicated differ from one CM to another,
based on the level of ambition. The overall standard highlights aspects of relevance
and control, but the minimum requirements aside from that are limited. Though it
could be advisable to start with a relatively concrete level of ambition in terms of
what the country programme wishes to be held accountable to, one has to consider
the relevance of, for example, signing up to the code of conduct if the agency is
not prepared to be held accountable to it before their beneficiaries. (HAP members
striving for certification need to argue why not if organisational commitments are
not reflected in the CM, as they are requested to inform HAP about organisational
commitments).
As part of the CM information campaign, it could be relevant to encourage the user
to complain as soon as an issue arises. This will enable the agency to better correct
the mistake and provide the appropriate remedy. It is often difficult to do an addi-
tional distribution if one or two families, for instance, have been missed during the
assessment, but much easier to assess the missed part of the community if alerted
in advance.
All kinds of complaints that may be regarded as legitimate, but were received at too
late a stage for the organisation to provide the proper remedy, should give reason to
consider whether the information shared with beneficiaries is sufficient, whether the
correct means was used, and whether provided at the correct time. In some situa-
tions, it could be an option to allow certain complaints access only at certain stages
of the implementation cycle, but this rarely helps the complainant very much!
Rather, the agency should encourage the donor to allow for the necessary flexibility
within the budget if the unfortunate situation occurs where, for instance, a family
was wrongly missed in the beneficiary selection process. This will obviously not
solve every instance, but an explanation on why the expected remedy could not be
granted is both a dignifying response, and not least educational for the agency in
terms of process and approach.
HOW to communicate
The best way to communicate and inform beneficiaries necessitates good guidance
from local staff members and preferably from the beneficiaries themselves. Com-
munication should build upon existing structures and traditions, and not over-rely on
entities such as the internet.
In Output 1, reference is made both to communication and availability. For some-
thing to be communicated, an active effort is requests in addition simply to e.g.
posting information on the warehouse wall (as entailed in simply making something
available). By committing to communicate the procedure, purpose and parameters
of the CM to its users, the agency accepts the responsibility for ensuring that the
information conveyed has been understood. This responsibility is highlighted in the
HAP Benchmark 5.3.
Important issues to consider include the levels of literacy, gender issues and access
to different forms of media, but the actual size of the project, area of operation and
the demographics all set limitations to the applicable means of communication too.
Many of the thoughts related to this step have already been covered as part of Step
5 and the effort to identify appropriate means of submission and very often, infor-
mation, will be presented in the same place as for submission. Different ways and
media applicable for communication include:
» Written communication
Written communication is central in making information available, but does not alone
ensure that information has been communicated (and understood). Written means
of communication include:
- Internet Often not a possibility for the beneficiaries, but could be a good sup-
plementary means of facilitating complaints from national staff members,
other agencies, donors etc. if the subject of the complaints makes the exist-
ing system and the Country Director unable or unfit to deal with a certain
issue.
- Newsletters Maybe the organisation produces a newsletter. This is often not
shared with beneficiaries, but helps to inform of potential users of the CM.
- Posters Posters seem applicable, especially in community-based approach-
es, targeting large segments of the population.
- Pamphlets Pamphlets allow for a more targeted audience, and could be
given out in relation to signing of contracts, when beneficiaries have been
selected and in general shared with relevant stakeholders as well for visibility
purposes and documentation.
» Verbal communication
Verbal communication allows for a dialogue and better ensures that the information
is understood and that misunderstanding is avoided. Verbal communication, though,
is best supported with written communication with regard to, for instance, the con-
crete presentation of the procedure and criteria for acceptable complaints. Verbal
means of communication include:
- Meetings Information meetings held regularly (e.g. bi-monthly and / or prior
to every new intervention) during which all aspects of the CM are presented
and explained. This would as well constitute a good opportunity to receive
input from the beneficiary population on various aspects of the CM including
entry points, procedure, means of communication, composition of the com-
plaints board etc. Involvement of this kind is in itself a way to demystify the
concept of a CM, and increase its legitimacy and likeliness of being used.
- Desks If the entry point of the CM consists of an information / complaints
desk manned by staff members, this serves as a very good and safe op-
portunity for the users, both when seeking information (to facilitate a smooth
submission of complaints) and to avoid submission of invalid complaints.
Programmes often already have some kind of manned presence in the ar-
eas of operation. The field office (opened at fixed time or days) is an obvious
location.
- Focal point Same values are achieved in the suggested procedure for
processing complaints explained in Step 6 where a person can be found at
a known place and time.
All communication – both verbal and written – should be in local language(s) used
by the complainant.
One important factor to be aware of is that some groups may fear for their personal
safety due to the exposure that an extensive information campaign could generate.
Please see Reference 2A chapter 3.2.

WHAT. You are now ready to produce your information material both in terms of
what it needs to contain and how to present it. With regard to the latter, language and
form must be as easy and straightforward as possible. With regard to the content, it
is important to have your own purposes before you when deciding what is relevant
for the user to know. The balance to be achieved is of course as simple and precise
as possible.
HOW. Based on local traditions and existing systems within the agency, develop a
means of communicating that will facilitate the different kinds of users. Creativity in
finding means to reach the targeted groups should guide this process. Share what
you come up with, and find inspiration in the Best Practises on www.drc.dk/cm.
Facilitation
Method
The whole issue of communication is extremely important to ensure that a consist-
ent, precise and sufficient message is sent to potential users of the CM. Though all
decisions in this respect cannot be taken in plenum, it is important to facilitate an
inclusive process in terms of considering what and how to communicate.
» 1. The facilitator introduces the issue based on the description in Step 10. This
presentation should emphasise the importance of communication, and detail the
two overall issues that are important to draw attention to.
» 2. Two groups are formed to address the following issues:
How to communicate?
- How can we integrate the communication about the CM into the agency’s
existing approach to communication with beneficiaries and other stakehold-
ers / potential users?
- Means of communication and proposed languages.
- Discussions can be inspired by the suggestions provided as part of Step
9. Annex 5G is used in the groups and will be the basis for the subsequent
presentation.
What to communicate?
- Use the head lines from above on 1) Agency, 2) Project and 3) CM.
- The group will only provide guidelines for a more detailed information cam-
paign, which will be made in a different and smaller forum. Discussions can
be inspired by the suggestions provided as part of Step 7. Annex 5H should
be used in the groups and will be the basis for the subsequent presenta-
tion.
» 3. When returning, each group should make a presentation of their discussions.
NOTES:
STEP 11
Develop an LFA for the CM
Develop an LFA for the CM providing a general view on how the

Objective
mechanism respects the minimum requirements of a CM.
Analysing and fine-tuning the decisions taken in the past 10

Means
Steps.
An LFA summarising the objectives, indicators and activities as

Outcome
per output.

Tools
Tool 4E – Suggested Indicators, MoV and activities.
Reading Reference 2B – Standards and Indicators.
During the past 10 Steps, relevant questions have been asked in terms of design-
ing a CM adapted to the specific local context and the level of ambition. Step 11
constitutes a final and overall analysis of all the completed matrices and tables
with the aim of summarising the decisions that collectively contribute to fulfilling the
minimum requirements. This is done via an LFA matrix.
One of the main benefits of developing an LFA, which matches the minimum re-
quirements against concrete indicators and activities, is that it constitutes a mutual
reference document within the office. This is important in order to ensure a common
understanding on what is to be achieved, but the LFA is also the concrete reference
point on which to base monitoring of how the CM is conducted and as a measure
of impact. The LFA is easy to attach to funding applications and reports to donors,
as documentation of the organisation’s commitment to strengthening accountability
and resources that is required. Finally, the LFA can serve as documentation to HAP
and as part of internal annual reviews from donors or HQ to provide a brief and
concise view of the initiatives taken to comply with the minimum standards under
the CM.

Find in Annex 5I an LFA format that can be used. The standard and the four outputs
are mandatory and have already been filled, while the next step is to develop indi-
vidual indicators, activities, means of verification and inputs. When identifying and
choosing these, a number of tools developed, and thoughts made during the past
Steps, can be used.
What is meant by an individually-designed indicators, activities and MoVs? In Out-
put 1, it is requested that relevant stakeholders are consulted in, for example, the
development of procedures, purpose and parameters. Whether, though, this entails
a workshop with donors, the host community and beneficiaries, or simply a ques-
tionnaire to selected groups of beneficiaries, is up to the individual programme to
decide. Both choices can be said to live up to the output, though with different levels
of ambition. Furthermore, relevant stakeholders would always be beneficiaries, but
whether potential beneficiaries, staff, donors, partners, local authorities as well are
included is optional.
In Tool 4E, suggested indicators, activities and means of verification have been list-
ed for each of the four Outputs to provide inspiration for the development of more
context specific ones. The column references made below refers to the columns in
the Annexes:
Column 1 Aspects to be reflected. This column lists different aspects to be

reflected in the indicators. Part of complying with the Output is to reflect in the
indicator all of these aspects. These are of course different for the four Outputs.
Column 2 Possible indicators. Column 2 is a suggestion of how to phrase

the concrete indicator. The suggested indicators should be as concrete and
measurable as possible. Which indicators are developed is fully dependent on
context and how the the CM has been set up throughout the former 10 Steps. The
relevant material and documents to review when developing indicators for the four
Outputs are:
» Output 1 The procedure, purpose and parameters of the CM have been commu-
nicated and made available to relevant stakeholders
- Tool 4E-1 provides suggested indicators for Output 1.
- Step 10 – Designing an information campaign and how and what to com-
municate.
- Steps 4, 5, 6 and 6 – Procedure of the CM. How and in which form can
people complain and what will the internal procedures be and set up for
processing the complaint.
- Step 1 – Purpose of the CM.
- Step 2 and 3 – Parameters of the CM. Who can complain and what can they
complaint about.
» Output 2 Intended users have safe and easy access to use the CM
- Reference 2A, section 4.2 – When filing a complaint
- Step 3 – Defining intended users.
- Step 5 – Defining entry points for the complainant

See as well Reference 2A, section 3.1, 3.2 and 3.4 for sensitive issues and the pro-
tection of users.
» Output 3 Logical and easily-understood procedures developed for submission,
processing and response / redress of complaints
- Reference 2A, section 4.3 and 4.4 – Processing a complaint and providing
redress.
- Step 4, 5, 6 and 6 – Procedure of the CM. How and in which form can people
complain and what will the internal procedure and set up for processing the
complaint be.
- Step 9 – How and what to respond to complaints.
» Output 4 Complaints are processed by a competent body guided by transpar-
ency, confidentiality and impartiality
- Annex 4E-4 provides suggested indicators for Output 4.
- Reference 2A, section 4,3 – Processing a complaint.
- Step 4 – Designing the Complaints Handling System, including Tool 4D on
setting up the Complaints Boards and considering sensitive issues.
- Step 8 – Investigating complaints.
Column 3 Activities. This column should list possible activities under the indicators.
Based on the indicators made and inspired by the material referred to above, list
the concrete activities per Output.
Column 4 Means of verification. This column should list possible means of

verification to document the impact related to the indicators. It could be beneficial
to indicate the MoV as per indicator.
Facilitation
User involvement ;
Duration of exercise (not suitable for involvement of a large group)
Method
Summarising all the information generated after having gone through the Steps is
difficult to achieve in a large forum, but if the LFA will be used actively, and against
which monitoring is done, it is valuable to have input from national staff in terms of
indicators. Use Annex 5I.
Notes
1) The users constitute mainly the beneficiary population, but could include other groups. Please refer to Step 3.
2) When establishing a CM for staff members, the Agency “Staff Code of Conduct “constitute an concrete, logical and a clear
reference against which staff members are allowed to complaint though it may be very value-based.
3) This could be in the form of a whistle blower function. Such, though, does not invite for communication, but is sometimes
used for unsubstantiated rumours and accusations among colleagues. The anonymity allowed under a whistle blower
function (e.g. an email directly to HQ), though, may be what is required to invite the most serious kinds of accountability
breaches.
4) Transparency means not that all complaints and decisions are advertised publicly as this could jeopardise the safety of
the complainant. The requirement of transparency is related to the way the Complaints Handling System functions and
who is members of the Complaints Boards.
5) For agencies committed to comply with the HAP standards, a Humanitarian Accountability Framework (HAF) should be
developed that includes a description of the complaints handling procedure. It could be relevant to consult HQ / HAP focal
point as an agency template may be available.
NOTES:
Chapter 4 TOOL BOX | 89
chapter 4A - tool box

THE CONCEPT OF COMPLAINING IN
PERSPECTIVE
As introduction to the concept of a complaining, it is important to establish a posi-
tive entry point that all can relate to. Some may be sceptical as to why the agency
should have a CM, but most people – when they come to think about it – have been
in a situation where they were dissatisfied, but did not complain. The reasons why
people do not complain can vary.
Tool 4A constitutes a short exercise, which will reveal some of the positive aspects
of complaining and having ones complaints dealt with - especially if handled in an
open manner!
1. Remember a 2. Face the person

3. Participants feed
situation where you sitting next to you
their reasons in
would have liked to and explain why
plenum based on
complain, but did you did not com-
their discussions
not. plain.
» 1. Each workshop participant is asked to remember a situation where they would

have liked to complain, but did not.
This could be:
- A newly bought telephone that turned out to have a scratched display.
- Poor treatment in a clothing store or restaurant.
- A colleague who made an unjustified verbal outbreak directed at you.
» 2. All the participants are asked to share their reasons why they did not complain
(e.g. best done in pairs). This should take 5-10 minutes.
The reasons could be anything, such as:
- Fear that maybe I misunderstood something.
- Not wanting to escalate the conflict.
- Was not prepared to go all the way in the complaints handling system.
- Fear of retaliation.
- Not having the time.
- Not feeling the need to complain until later.
- Not knowing how to complain.
» 3. Participants then share from their discussions the reasons why they chose not
to complain. These are listed on a flip-chart by a support facilitator.
Points to be drawn from the plenary discussions and for the facilitator to make:
» The reasons why people wish to complain are many, and not obvious to the given
situation. For the agency, being directly of indirectly the subject of the complaint,
this means that staff members may be doing everything correctly, but maybe a
minor issue in the approach annoys some beneficiaries. Maybe the staff thought
that, for example, it was a good thing to involve women in the design of the water
stations, but actually they prefer not to be involved.
» The subject of the complaint (the staff member) may not be aware about your
dissatisfaction.
» All complaints are legitimate. Even though you may have misunderstood some-
thing and thus your complaint turns out to be groundless, your dissatisfaction was
relieved by the fact that the issue was voiced. This issue challenges the narrow
CM based on the idea that some complaints are more important than others.
» The dissatisfied customer not able to complain will simply choose a different
shop the next time as their own small means of “evening the score”. The benefici-
ary does not have that option or the power. They are stuck with you – happy or
not. So much stronger is the obligation to facilitate complaints!
» If the user of the CM trusts that their complaint is dealt with in an objective and
positive manner, he /she are more likely to complain. And as you know that your
agency is trying their sincere best, it is likely that the complaint is actually a mis-
understanding or has a logical and fair explanation. In order for you to be able to
provide this explanation, and hence tackle the dissatisfaction, it is important for
the agency that people make complaints.
Conclusion
The overall outcome of the exercise should preferably be that the participants re-
alise that complaining can have positive aspects related to fairness, dignity, equality,
transparency and accountability. A CM is a formalised means of strengthening com-
munication between the agency and those whom we claim to assist.
Having access to complain empowers the beneficiary against the agency in a man-
ner where the power balance between agency and beneficiary is limited. Empower-
ment is in itself a valuable impact of humanitarian assistance. Not having access to

complain and being left with one’s dissatisfaction generates frustration and leads to
a feeling of disempowerment.
chapter 4b - tool box

Choosing Sectors for the Complaints
Mechanism
This Tool is developed to assist in identifying exactly which areas or sectors of the
programme the CM should address. The number of areas or sectors included in the
CM can easily be extended at a later stage, but it is important to get a good and
manageable start.
Whereas Tool 4C focuses on areas where the population and the beneficiaries are
de facto complaining, Tool 4B is most applicable in relatively new operations or for
new sectors / activities where the programme is not familiar with the type of com-
plaints received. Tool 4C is more relevant for established programmes with a benefi-
ciary population already addressing complaints to the agency.
As mentioned in 2A Concept Paper, a CM is understood as a set of “simple proce-
dures and mechanisms that give beneficiaries access to a safe means of voicing
complaints on areas relevant and within the control of the agency”. This definition
emphasises the importance of a balance between relevance and within the con-
trol.
Relevance. Relevance is important as a complainant would not be interested

in filing complaints that the agency neither can nor will react to. Furthermore,
relevance is related to the fact that the CM should be designed to address areas
or sectors where potential accountability problems are the most prominent, and
where beneficiaries actually have something to complain about. The CM has no
value to beneficiaries or to an agency if it does not address areas of potential
accountability breaches.
Control. The Agency has – through contracts with donors, beneficiary criteria,
adherence to various standards etc – made many promises and commitments
to which it holds itself accountable. Beneficiaries should be able to voice their
complaints about all of these commitments as one means of ensuring compliance.
On the other hand, if the CM gets over-burdened with too many complaints and
cannot provide proper response or compensation, the CM loses its value and the
agency’s trustworthiness becomes undermined.
The CM should balance these aspects carefully and – towards the users – be very
clear on the scope of the CM by informing about possible limitations to acceptable
complaints.
With these considerations in mind, the following description constitutes a simple
guide (or mini SWOT analysis) for choosing which sectors / projects / areas the CM
applies to.
Annex 5A comprises a basic matrix to be used in the process.
1.Programme Analysis
» This first step is to make an exhaustive list of the agency’s activities / projects:
 - Food distribution in district X.
 - NFI distribution in district Y.
 - Temporary shelter assistance to village Z.
 - ToT in the village school.
List the identified bullet points in the right-hand side of the matrix.
2.Relevance to a CM
On the basis of each of the listed components, consider the relevant1 elements
within each of the activities / projects where accountability is likely to be threatened
and in relation to which beneficiaries hence could be interested in filing a complaint.
These are the ones the agency potentially would wish to set up a CM for.
The relevant areas that the Agency wishes to be held accountable to are principally
those in which promises and commitments have been made. These are first and
foremost concrete issues directly related to beneficiaries, but could as well be com-
mitments made as an organisation and to donors. These issues are related both to
what is provided and how it is provided:
» Promises made to beneficiaries
Beneficiary vulnerability / selection criteria, implementation approach (e.g. participa-
tory), quality and quantity of the output, aspects of volition, unfortunate side-effects,
quality or access to proper information, appropriateness of approach, product or
service etc.
» External codes of conduct
Code of Conduct, SPHERE, Assistance Framework etc. These could include com-
mitments to participation and the use of local resources, misuse of funds, gender
balance, attitude of staff (e.g. harassment, threats), the CM-procedure itself, a digni-
fied approach, impartiality etc. These commitments need to be defined / explained if
complaints are accepted on them.
» Contractual agreements
Commitments may have been made in the application / contract or as part of being
an implementing partner to, for example, ECHO and UNHCR.
You will need to find a realistic level of detail and try to be thematic. The challenge
when making this analysis is that a CM has the added benefit of making the agency
aware of unintended side-effects of its activities. By establishing a narrow margin

for acceptable complaints, the benefit in identifying unintended side-effects is often
lost. Often, the users are not only actual, but potential beneficiaries – persons that
the agency’s assessment missed when locating, for instance, beneficiaries for the
NFI distribution (to be decided in Step 3). These as well should have access to com-
plain when a needs-based approach to assistance is adopted.
3.Control
Prior to choosing which are the appropriate for the CM, it is important to try to fore-
see some problems of establishing a CM for this particular project in this particular
/ local context. It may be worth considering, for example, what the realistic reaction
could be to a specific accountability breach.
The next step is to re-consider the possible type of relevant complaints against the
threats and difficulties that they pose. Aspects to consider include the local con-
text, security environment, gender issues, the number of complainants, who should
have access to complain etc., which complaints could become uncontrollable for the
agency, the threats posed to the beneficiary population or even whether complaints
jeopardise the operation in general. Some reasons that complaints can become
uncontrollable include:
- The agency cannot properly investigate the issue (too complex to investi-
gate e.g. who said what).
- The Agency cannot provide redress.
- The Agency simply cannot manage masses of people.
- Too sensitive in this country / context.
Furthermore, please refer to Reference 2A Part 3, listing some of the challenges
and risks related to establishing a CM.
These considerations may deter an agency from choosing a particular sector as
subject for a CM – but rarely. Most often, a simple re-design of the CM can address
the problem. Maybe an alternative stakeholder could host a system to deal with the
complaint, maybe the CM could be designed to manage the challenge.
4.Choosing one or more sectors

In the last column, it is relevant to draw some general points or considerations with
regard to the input provided throughout the discussion. (Tool 4C will take you more
into a detailed analysis of the specific areas that you have chosen for the CM to
address.) The outcome of this exercise should mainly be to choose one or more
sectors or projects for which the agency wishes to establish a CM.
Beneficiaries have a right to complain to a humanitarian agency, if it is claim-

ing to be accountable to them!
You may choose to establish and design a very specific CM that addresses a very
particular problem (sexual abuse, misuse of funds, distribution of NFI in a certain
areas or the local community centre etc.). In other contexts, a more general CM
covering a range of activities would be preferable. There could be a reason why
one would like to start with very concrete and less complex sectors (e.g. distribution
activities) to become better familiar with the concept, but naturally as well a wish to
focus on the sectors with the highest risk of accountability breaches.
In some humanitarian contexts, a CM is not related or based on the specific activity,
but more in addressing the approach of staff. This guide contains activities as points
of departure (the external link to beneficiaries), while the need may be specifically to
address internal procedures. Both are important aspects of being accountable.
Notes
1) Relevant for the agency meaning something that it is in fact able and willing to do something about.
chapter 4c - tool box

MAPPING Complaints
Tool 4C is a mapping exercise, based on which the agency can then develop a
clearer view of the complaints received and hence decide what areas the CM must
address. By allowing a discussion about the types of complaints received, it is easier
to decide how the complaints procedure should function, who should sit on the com-
plaints board, alternative means of complaints etc.
Whereas Tool 4B has been developed to assist in identifying which areas or sectors
of the programme the CM should address, 4C focuses on areas where the popu-
lation and the beneficiaries are de facto complaining. Tool 4C is most applicable
for existing programmes with a beneficiary population maybe already addressing
complaints to the agency.
Below is a step-by-step introduction. Please use Annex 5B for the exercise.
1.Valid complaints.
List in column 1 all the complaints that staff receive (from beneficiaries, in the lo-
cal communities, potential beneficiaries, authorities, partners, staff etc.). This is best
achieved as a brain-storming exercise. For larger operations, it could be a good idea
to focus on one sector or area of the programme at the time – e.g. the sectors or
areas chosen through following the exercise linked to Tool 4B – or let the audience
split into teams based on the sectors in which people are working (shelter, income
generation, capacity building etc).
It is important to remember the great variety of complaints in addition to those di-
rectly related to the product / service rendered. The relevant areas an agency wish-
es to be held accountable for are principally the promises and commitments made.
These are first and foremost concrete issues directly related / made to beneficiaries,
but could as well be the obligations made as an organisation and to donors. These
issues are related both to what is provided and the how it is provided:
» Promises made to beneficiaries
Beneficiary / vulnerability / selection criteria, implementation approach, quality and
quantity of product or service, aspects of voluntary work, unfortunate side-effects,
quality or access to information, appropriateness of approach and output etc.
» External codes of conducts
Code of Conduct, SPHERE, Assistance Framework etc. These could include com-
mitments to participation and use of local resources, misuse of funds, gender bal-
ance, attitude of staff, the CM procedure itself, dignified approach, impartiality etc.
These “soft” commitments needs to be defined / explained if complaints are ac-
cepted related to these.

» Contractual agreements
Commitments may have been made in the application / contract or as part of being
an implementing partner to e.g. ECHO and UNHCR (procurement, procedures, code
of conduct for staff, etc).
Describe the complaint as specifically as possible in a few words. Use flipcharts or
projectors as facilitation tools.
2.Categorisation of Complainants
It is a good idea to group the complaints according to who raises them, i.e. the com-
plainant groups (in column 2). This categorisation will be important during design
of the CM at a later stage (the complaints boards dealing with complaints from
beneficiaries may not be the same as that dealing with complaints from donors or
authorities). After having listed all the complaints, it is easier to deal only with those
from beneficiaries, potential beneficiaries and the host community, and agree that
all other complaints should go directly to the Country Director / another complaints-
handling system. Here is a list of the types of people who are likely to complain.
- Agency beneficiaries (whether NGOs, vulnerable groups etc.).
- Potential beneficiaries.
- Host community / displacement affected community (of the beneficiaries).
- Neighbours / non-displacement affected population.
- Internal agency staff.
- Partners, donors, authorities and others.
The beneficiary complaints are the most relevant ones. It may be an idea to return
to column 1 as additional complaints are remembered after having grouped the
complainants.
3.Relevance
Is the complaint relevant in the sense that the agency will and can influence this
issue? If the agency cannot or will not address the issue, the CM will not provide a
remedy to these types of complaints1. As an accountable agency concerned with
the dignity of the beneficiaries, it is an important function of the CM and a good op-
portunity for the agency to explain to the complainants why the agency will not, or
cannot, comply with their request.
State “yes” for relevant complaints and “no” for not relevant complaints in column 3.
4.Control – remedy / response offered

Based on whether the response is “yes” or “no”, do the following:
NO . Very often, it is relevant to provide referral possibilities that the complainant

can use (other agencies, donors, authorities, local community committees etc) if
available. Based on the complaints that the agency cannot or will not influence,
consider whether it is possible to refer the complainant to a relevant responsible
authority to have their complaint handled.
List the relevant authorities (in reality) to whom the agency can tell the beneficiary
to turn to for an answer.
YES.The consideration on whether the complaint can become uncontrollable is

as well related to the response or the remedy that the agency is able to provide,
and whether this will be accepted by the complainant. At this stage, it is valuable to
consider possible responses (answers) or remedies (e.g. compensation or change
of procedure) to generate an idea about the aspects necessary to consider in
relation to the design of the CM.
List possible remedies or responses the agency is realistically able and willing to
provide AND that the agency expects the complainant to accept. Though maybe
only an apology is offered, it is often accepted and is better than the alternative of
not being able to voice one’s dissatisfaction.
5.Level of sensitivity
When considering the level of sensitivity of the complaint it is important to decide
who can handle / address the complaint. Whereas complaints related to the quality
of the items distributed, status on a beneficiary list or beneficiary criteria, are gen-
erally non-sensitive issues, complaints about a staff member due to misbehaviour,
abuse, neglect etc. may be very sensitive for the complainant to raise.
Aspects of sensitivity are important when designing the complaints procedure. In
general, the majority of complaints are non-sensitive and can easily be handled by a
complaints board consisting of national staff (and maybe as well beneficiary repre-
sentatives) making decisions based on the published criteria. Other more sensitive
complaints, though, should be dealt with e.g. expatriate staff or the Country Director
directly. The principle to be observed here is that the person handling the complaint
should be removed from the subject of the complaint.
Obviously, it should always be the user of the mechanism who decides whether
the complaint is sensitive or not. It is important that the system of receiving and
processing complaints has the necessary degree of confidentiality and integrity to
protect the user (if the CM regards sensitive complaints as valid).
In column 5, state whether the various types of complaints should be regarded as
“sensitive” or “non-sensitive”
6. Should our CM deal with this issue?

Sometimes it is relevant to comment on the limits of the CM, which can be mapped
in column 6. Issues to consider may include:
» When the answer is “no”. Why is the agency not prepared to respond to this com-
plaint. This is important to generate a full view of the argumentation surrounding
possible limitations of the CM.
» Issues of concern under this complaint.
» This column can as well be used to grade from 1 to 3 on how important it is for
the agency to deal with these complaints (this could generate constructive dis-
cussions among staff).
On the basis of this analysis, a clear impression is provided on the types of com-
plaints received, and hence what a CM should address. The list of complaints identi-
fied through the exercise, though, cannot exclusively be used in the setting up a CM,
but provides only the basis. As the outcome of the exercise is used throughout the
11 Steps, it is worth being exhaustive when identifying both complainants and dif-
ferent types of complaints.
Notes
1) “Cannot’s” could be that the complaint is related to issues external to the agency (complaints about other stakeholders),
while the “will not’s” could be that compliance would request going against fundamental operational principles, ethics
etc)
chapter 4D - tool box

Setting up a Complaints Handling System
The Complaints Handling System is the agency apparatus that decides on the com-
plaint and remedy. The Complaints Handling System is indicated with a circle in
Figure 1.
The Complaints Handling System consists of one or more Complaints Boards (CB),
which is the specific person or group of persons dealing with a set / type of com-
plaint. The Complaints Boards are normally hierarchically structured, where one
level functions as appeal to the other (indicated as squares). The Complaints Board
at level 1 forms the main body and level 2 is the secondary and appeals body.
Figure 1
Appeal
Tool 4D will provide guidance on how to set up a proper and adequate Complaints
Handling System capable of dealing both with the different types of complainant as
well as the variety of complaints, be they sensitive or non-sensitive.
1. Composition of the Complaints Boards and aspects of sensitivity

Considering the differences in complainants and complaints, a general set of rec-
ommendations can be provided in terms of which types of Complaints Boards are
judged as qualified to deal with complaints. The Complaints Handling System will
most often consist of multiple levels (as in Figure 1), and will need to be composed
on the basis of available resource and the local context / requirements. Below are
a few general considerations on the various stakeholders that could be part of a
Complaints Board:
» Senior Management / Country Director. Assuming overall responsible for the op-
eration, the Country Director has overall responsibility; if the Country Director is
not the complaints body (Level 1) itself (for very small systems), then often he/
she will constitute the appeals body (Level 2). Staff members, though, could have
direct access to complaint to HQ. One of the ambitions is to balances the desire
of having an effective system that doesn’t rely on senior management too exten-
sively.
» Immediate manager to the complainant. For internal staff complaints, it is often
the immediate manager who is the first entry point to complaints from his / her
subordinates. Often with sensitive issues or complaints about his / her manager,
agency staff members may wish to turn to senior management or even HQ.
» National staff. A system comprising of national staff members could be effective
in dealing with large numbers of complaints. Often they have a better under-
standing of the context in the field, but may not have the necessary information
and authority to deal with more technical issues, or to decide on the remedy.
Another issue is that national staff may be the subject of the complaint. Finally,
confidentiality could be an issue on very sensitive issues.
» Beneficiary representatives. Often a very legitimate and trusted stakeholder (in
the eyes of the beneficiaries) and may also contribute positively to transpar-
ency. Beneficiary representatives, though, may not have the authority, knowledge
and sometimes realism on the types of remedy available. In some contexts, the
beneficiary representatives may not in fact be equally representative of all the
beneficiaries or affected populations.
»Authorities. In some contexts, authority representation could strengthen the pos-
sibility to use the CM actively as an advocacy tool, especially if complaints are
related to the legislative framework. Access for authorities, and hence to informa-
tion about beneficiary concerns / complaints, could be positive.Yet in some cases,
involving authorities could jeopardise the protection of some groups. For the
CM, a means of ensuring transparency and involvement of authorities is another
positive aspect. One more option is to call in an authority representative when
relevant complaints are being processed.
» Donor or Partner NGO. As an external and unbiased stakeholder who is inde-
pendent from the event, the donor or NGO partner representatives could contrib-
ute to the legitimacy of the decisions. Donor representation could facilitate more
flexibility in terms of possible remedy as some decisions could call upon the
re-allocation of funds (or the allocation of more).
The obvious conclusion from considering the characteristics of the stakeholders
is that a combination is needed to respect the necessary requirements indicated
in Output 4 stating that complaints are processed by a competent body guided by
transparency, confidentiality and impartiality. At the same time, too complex a set
up / composition may challenge the effort to ensure, for example, the integrity and
impartiality of the Complaints Boards.
» The system needs to be legitimate in the eyes of the user. To facilitate this, there
often needs to be an appeals option. Furthermore, persons who are potentially
subject of the complaint or having a personal interest / bias should never be deal-
ing with or deciding on the complaint.
» The Complaints Board needs to hold the necessary competences to process the
complaint (e.g. to be able to call upon technical issues).
» The system (including the appeals board) needs to have the power to decide, for
example, on the appropriate remedy and to say who is right and who is wrong.
It is almost impossible to set up a system which accommodates all complaints per-
fectly. The complexity of the many types of complaints that such a system needs to
be able to process is a reason why it is worth reviewing the number of acceptable
complaints and of the stakeholders granted access to use the system. The integrity
of the system should under no circumstances be compromised, especially if the
system is designed to address sensitive complaints.
Aspects of sensitivity
A core requirement when talking about the competency of the Complaints Handling
System refers to aspects of sensitivity and the ability of the CM to protect its users.
This aspect deserves particular attention since an improperly designed and man-
aged CM has the potential to endanger those it supposes to benefit and protect. For
this reason, it is important to be aware about the potential risks that the user may
take when using the CM.
This is especially the case when working in contexts where the safety of the indi-
vidual is at stake, and / or when the safety of the individuals or the group rests on
the fact that the subject of their complaint remains unknown to external parties.
Disrespect for the basic confidentiality of the complainant could result in sensitive
information being leaked, leading to a deterioration in the complainant’s situation.
An example is that of a rape victim, who, if widely known as having been raped,
could cast a shade over her family and jeopardise her ability to marry.
If the complainant is uncertain about the system and its ability to respect confiden-
tiality, the system will obviously not be used. For this reason, it is important in the
information campaign (see Step 10) to state the agency’s commitment to confiden-
tial processing of complaints by providing a description of the procedure including
who the members of the Complaints Boards are. The worst case scenarios are of
course situations where the complainant has trusted the agency with their sensitive
complaint, and the system does not comply with its own internal procedures and
sensitive information is consequently leaked.
It is the responsibility of the agency to consider these aspects and ensure protec-
tion, no matter who is using the CM. These problems can be solved by carefully ana-
lysing how the complaints are solicited and handled, but serve as well to highlight
the importance of ensuring a sound and carefully considered CM. It is always the
user who decides if an issue is sensitive or not. Though seemingly non-confidential
to the agency, individual or personal circumstance may make the issue sensitive for
the complainant.
In many instances, the CM does not accept sensitive complaints and it is worth con-
sidering whether the CM should allow submission of sensitive complaints if it is not
certain whether the system can provide the necessary protection. These types of
violations often constitute the most extreme forms of accountability breaches and
need the attention that a properly set up and managed CM can offer.
In terms of the difference between investigating sensitive and non-sensitive com-
plaints, please refer to Step 8.
2. Multiple levels within the Complaints Handling System

Having considered the qualification of different kinds of stakeholders and how they
contribute to the transparency, confidentiality and impartiality of the Complaints
Boards, the issues of the differing types of complaints and complainant still re-
main.
Complainants. In the discussion generated from Step 3, a number of different

types of users (beneficiaries, potential beneficiaries, staff etc.) was identified.
While it may give sense for one group to direct their complaints to one type of
system (e.g. complaints boxes in the field), others may wish to complain in a
different way (e.g. staff members going directly to the Country Director).
Complaints. While the complainants can be different, so can the complaints. From
the exercise in Tool 4C, complaints were divided into the sensitive and non-
sensitive. While one Complaints Board consisting of, for instance, a national staff
member, may be qualified to deal with one type of complaint (non-sensitive ones),
other types of complaints may need to be addressed by senior management to
ensure the proper protection of the complainant.
In some contexts, one single Complaints Board is adequate to deal with and decide
on the incoming complaint, and in many programmes the Country Director is the
only formal person dealing with complaints.
One of the main downsides of such a system is limited transparency and the in-
ability to appeal decisions – in effect a dictatorial system, where everything is left
with one person. More often, a combination of two or more systems is necessary to
deal with the variety of complaints and complainants, but as well the large number
of complaints. See Figure 2.
The standard Complaints Handling System constitutes a two-level complaints body.
Level 1 is the main body with representation from, for example, agency staff mem-
bers, beneficiary representatives and a third, external party. The main body deals
with an expected 80-90% of the total number of complaints, comprised of all the
non-sensitive issues from beneficiaries, potential beneficiaries and host communi-
ties.
The secondary body (level 2) will consist, for example, of a Country Director and po-
tentially one expatriate staff member. Users of the CM can turn directly to this level
with sensitive issues, or if the user have substantial reasons to question the compe-
tence or integrity of the first level Complaints Board in dealing with their complaint.
Figure 2.
To HQ, donor or HAP
Appeal
e Complaints Board Level 2

sitiv
s en
Complainant
no Appeal
n-
se
ns
itiv Complaints Board Level 1
e
Such would often (but not exclusively) be complaints about agency staff, misuse of
funds, abuse of power, activity that generates security problems in the community
and these more complex types of issue. To other users of the CM, it may only be
sensible to direct their complaints directly to the top management. This could be the
case for local authorities, partner organisations etc.
Based on this composition, the incoming complaints and complainants are indicated
in the table over the page, including appeals possibilities. This, though, is only an
example that needs to be adapted to the local context.
In addition to ensuring the principles of transparency, confidentiality and impartiality
primarily to the agency’s beneficiaries, the system should allow for the complainant
to bypass the main body with sensitive complaints as indicated in Figure 2 and Ta-
ble 1. As also indicated, legitimacy is facilitated by ensuring a possibility for appeal
if the complainant can give grounds for the complaints body being unqualified or
biased with regard to their specific complaint, or within a set of criteria that allows
complaints to go directly to the secondary Complaints Board (level 2).
Table 1.
Type of complaint
Appeals body
Non-sensitive Sensitive
Secondary Secondary
Beneficiaries Main Body
body body
Secondary Secondary
Potential beneficiaries Main Body
body body
Complainant
Secondary Secondary
Host community Main Body
body body
Immediate Secondary Secondary

Agency Staff
manager body/ HQ body/ HQ
Secondary Secondary Secondary

Partners, authorities
body body/ HQ body/ HQ
It is important to stress, though, that other compositions of complaints bodies and

structures of the Complaints Handling Systems may fit better to the specific context.
Based on the input provided in this Tool, you should design your own Complaints
Handling System. The format to be used is found in Annex 5D. For suggested action
to be undertaken, please turn to Step 4 in the Step by Step section.
chapter 4E - tool box

Suggested Indicators, MoV and Activities
The following four tables provide inspiration for the decelopment of your own CM
LFA based on the four outputs.
» Tool 4 E-1 Output 1 - The procedure, purpose and parameters of the CM have
been communicated and made available to the relevant stakeholders.
» Tool 4E-2 Output 2 - Intended users have safe and easy access to use the CM.
» Tool 4E-3 Output 3 - Logical and easily-understood procedures developed for
submission, processing and response / redress of complaints
» Tool 4E-4 Output 4 - Complaints are processed by a competent body guided by
transparency, confidentiality and impartiality
Tool 4E-1 Output 1 - Suggested indicators for an extensive and small CM
Output 1:The procedure, purpose and parameters of the CM have been communicated and made available to the rel-
evant stakeholders.
Aspects to be reflected in Means / Sources of

Possible Indicator Activites
the indicators verification
• Procedure, purpose and • Procedure, purpose and parameters • Dissemination of pamphlets • Material produced.
parameters. (To be defined of the CM are published in English and other information mate- • Attendance sheets
and described.) and Arabic at all offices and CM rial introducing and explain- (training and work-
• Communicated (and under- boxes. ing the CM. shops).
stood). (Proactive steps must • Introductory meetings are held every • Setting up a website. • Employment records.
be taken to explain directly three month presenting and explain- • Arranging workshops, train- • Vouchers.
to relevant stakeholders and ing the CM. ing, information meetings
ensure that the message has • Agency partners and donors have etc.
been understood.) been informed about the CM. • Employing an information
• Availability (Procedure, pur- • Workshops have been undertaken manager.
pose and parameters made for agency staff to develop the • Questionnaires.
available to relevant stake- procedure, purpose and parameters
holders to seek additional • Meetings with relevant stake-
of the CM.
information.) holders regarding means of
• 80% of agency beneficiaries are communication.
• Relevant stakeholders (To aware about the access to complain.
be defined, but must at least
• 80% of the village leaders / intended
include beneficiaries and
users understand the procedure
agency staff.)
for submission, processing and
• Participation and consultation response / redress of complaints.
with beneficiaries.
• Community leaders have been
consulted on appropriate means of
communication related to procedure,
purpose and parameters of the CM.
Output 2: Intended users have safe and easy access to use the CM.

• Intended users. (To be de- • One session has been held with • Meeting with relevant • Minutes of meetings.
fined, but including benefici- representative(s) from each benefi- stakeholder(s) to discuss • Maps / grids.
aries and potential benefici- ciary community to identify optimal locations.
• Survey reports.
aries at the very least.) locations of the complaints office(s). • Interviewing beneficiaries.
• Questionnaires.
• Safe access (user per- • Beneficiaries have been consulted in
ceived). the appropriate means of complain-
• Easy access (user per- ing.
ceived). • Beneficiaries have max 3 km / 1 hour
• Participation and consulta- walking to nearest CM box / office.
tion with beneficiaries. • Intended users report satisfaction
with the location of the complaint
boxes.
Tool 4E-3 Output 3 -Suggested indicators for an extensive and small CM
Output 3: Logical and easily-understood procedures developed for submission, processing and response / redress of
complaints.

• Logical and easily-under- • 10% of users misunderstood the • Interviews, consultation meet- • Reports.
stood procedures. (User and procedure related to submission, ings. • Degree of misunder-
DRC staff perceived.) processing and response / redress • Statistics of procedural standing related to
On: of complaints. mistakes. procedure.
• Submission. (How and where, • 90% of the users find the means of • Setting up of a database. • Statistics.
in writing.) submitting complaints appropriate.
• A ToR is developed describ- • Questionnaires
• Processing. (Steps that the • 90% of the users condone the proce- ing the procedure.
complaints go through from dure of providing response / redress
submission to response – to their complaints.
including appeals options.) • 90% of the users find the complaints
• Response / redress. (What process appropriate.
can DRC provide as answer • Community leaders / beneficiary rep-
or compensation, how is it resentatives have been consulted on
provided etc.) procedures around handling submis-
• Participation and consultation sion, processing and response /
with beneficiaries. redress to complain.
Output 4: Complaints are processed by a competent body guided by transparency, confidentiality and impartiality

• Competent body. (NGO and • Beneficiary representative is a mem- • Meetings / hearings. • Minutes of meetings.
user perceived – they have ber of the complaints board. • Establishing a database of • Statistics from the
authority to act, no field staff • The complaints and appeals board complaints. database
members in the appeals have the necessary authority to • Mapping possible complaints
board.) decide and act. as a means to identify ap-
• Guided by transparency. • Staff and sensitive complaints di- propriate persons to be on
(Access to see reasoning rected directly to Country Director, to the appeals board.
behind the decisions taken). HQ or immediate expatriate.
• Guided by confidentiality. (Es- • Beneficiaries have accepted the
pecially when dealing with make-up of the complaints and ap-
sensitive complaints.) peals board.
• Guided by impartiality. (Deci- • The CM processing system is devel-
sions taken are founded on oped to keep names and sensitive
objective and beneficiary- information confidential.
known parameters and
• Beneficiaries have access to read
grounds.)
decisions of the complaints and ap-
• Participation and consultation peals board (where the name of the

with beneficiaries. complainant has been removed).
• All decisions taken by the com-
plaints and appeals board are filed /
computerised including reasoning /
grounds.
chapter 4F - tool box

Internal Presentation Material of CM
The PowerPoint Presentation of Tool 4G constitutes an easy introduction to the
main aspects of setting up a CM. The presentation has been made on the basis
Reference 2A.
The presentation consists of 24 slides split into five main sections.
» 1. Introductory Exercise (3 slides). A brief exercise where all the participants act
as a means to facilitate a common point of departure and where all assume the
point of view of the complainant.
» 2. Benefits ofa CM (7 slides). A closer examination of some of the positive
aspects and benefits of setting up a CM and allowing people to voice their com-
plaints.
» 3. Minimum Requirements (4 slides). Introduces the difference between a CM
and the daily informal communication between beneficiaries and agency, and
presents the mandatory requirements that consist of a standard and four out-
puts.
» 4. General Characteristics (6 slides). Presents five basic steps from when the
complaint has been submitted to after the response / remedy stage, and lists
some of the main necessary considerations when setting up and running a CM.
» 5. Three Types of CM (1 slide). Three different types of CM are described to
indicate to the participants the variety of types of CM, based on the operational
context.
Below, please find the references relevant for each slide where more information
can be found. Based on the level of information and knowledge, the presentation
may be too extensive. Slides can easily be removed from the presentation.
Introduction
» 1st Slide - Introduction
- Introduction 1A - General considerations related to CMs.
- 3A Step 1 - The importance of ensuring commitment from staff and benefi-
ciaries / users of the CM.
1. Introductory exercise
» 2nd Slide - Why did you not complain?
- Tool 4A Introduces the exercise in detail.
» 3rd Slide - Reasons why we do not complain (categories of reasons).
- Tool 4A Introduces the exercise in detail.
» 4th Slide - Reasons why we do not complain (concrete reasons).
- Tool 4A Concrete suggestions on conclusions to reach.
2. Benefits of a CM
» 5th Slide - Why would we want people to complain? Introduction.
- Reference 2A, 2 All the bullet points are presented separately below.
- Introduction 1A Talk about and explain accountability as a desire to establish
a forum for communication an decrease the distance between agency and
user / beneficiary.
» 6th Slide - CM as a mechanism to strengthen the dignity of the user.
- Reference 2A, 2.1 Describing this aspect of the CM in more detail.
» 7th Slide - CM constitutes a separate project component.
» 8th Slide - CM as an early warning indicator.
» 9th Slide - CM as seen from a cost-benefit perspective.
» 10th Slide - CM complementing impact monitoring.
» 11th Slide - Statistics and documentation
» 12th Slide - What are the risks of a CM.
- Reference 2A, 3
3. Minimum requirements
» 13th Slide - Everybody has a CM!
- Reference 2A, 2 The figure is explained in more detail.
- Reference 2A, 5 Describing why the CM needs to build on existing structures
and initiatives.
» 14th Slide - Why are minimum requirements necessary?
- Reference 2A, 1
- Tool 2B More general and elaborate considerations on the need for minimum
requirements.
» 15th Slide - The CM standard
- Reference 2A, 1 Having read 2A in full, the comments on the slide related to
the standard should make sense. See as well the links to slides 16-21.
- Tool 2B
» 16th Slide - The CM outputs
- Tool 2B
4.General characteristics of a CM
» 17th Slide - Introduction to the general characteristics
- Reference 2A 3.1-3.5
» 18th Slide - Step 1 – Internal capacity analysis and considering the scope of the
CM.
- Reference 2A, 3.1 Issues worth considering are bulleted.
- 3A Step 2 (parameters and scope of the CM).
» 19th Slide - Step 2 – Filing a Complaint
- 3A Step 5 (Agency-staff interface) and Step 7 (Information management).
» 20th Slide - Step 3 – Processing a complaint
- 3A Step 4 (Setting up a complaints handling system) and Step 6A (Process-
ing a complaint)
» 21st Slide - Step 4 – Redress / response to a complaint
- 3A Step 6 (Responding to complaints) and Step 7 (Information campaign)

» 22nd Slide - Step 5 – Learning from a complaint
5.Three different types of CM

» 23rd Slide - Three different types of CMs?
- Reference 2A, 5 The three different types and their characteristics are de-
scribed in detail.
Conclusion
» 24th Slide - Conclusion and final remarks.
- Suggestions for final remarks:
- To express concern over the risk of not being able to control the programme
when opening for complaints. Talk about the importance of “keeping things
simple and starting out with minor areas of the programme”.
- To talk under the heading: “What are the commitments of the agency (e.g. to
the Code of Conduct) worth if we are not prepared to be held accountable
to them?”
- The next step for the agency to establish a CM!
chapter 4g - tool box

powerpoint Presentation of CM
In electronic version only
Chapter 5 ANNEXES / TEMPLATES | 117
chapter 5
annexes / templates
Annexes / Templates
» 5A Choosing sectors for the complaints mechanism
» 5B Mapping complaints
» 5C Who will have access to complain?
» 5D User and appeals matrix
» 5E User entry points to complain
» 5F Complaints form
» 5G Means of communication as per potential user
» 5H What to communicate to user
» 5I Developing a LFA
ANNEX 5A – Choosing Sectors for the CM
Annex linked to Tool 4B
Activities / Project Components Relevance Control Conclusion
Distribution of temporary shelter 1. Poor quality material. Discuss the point by focus- Important issues to con-
in Village A. 2. Wrong selection criteria. ing on which problems sider while setting up of
and solutions (in terms of the CM.
3. Preferential treatment of redress and/or response)
specific groups by agency available when addressing
staff. concrete challenges.
4. etc
School construction in village B.

ANNEX 5B – Mapping Complaints
Annex linked to Tool 4C - In the electronic copies, the Annex is found in Excel allowing filtering the data e.g. based on Complain-
ants or Relevance!
Complaint Complainant Relevance Remedy Sensitivity Comments
What is the con- Who is filing the Is the complaint Which response Is the complaint (Important issues
crete complaint complaint, based relevant in the or remedy is the sensitive. to consider while
(word it!) on the categoris- sense that the agency able to setting up of the
es of complain- agency will and offer, and whether CM.)
ants can influence this this will be ac-
issue. (Yes or no)! cepted by the
complainant.
Why am I not on Beneficiary Yes Offered to be put Not sensitive

the distribution on the distribu-
list tion list for next
round.
Why am I not on Potential Yes Explain selec- Not sensitive

the distribution beneficiary tion criteria. No
list compensation.
Your food Local business Yes Could be

distribution is man sensitive
undermining my
business
Received wrong Beneficiary from No Refer to relevant

tools kit other NGO NGO
ANNEX 5C – Who has Access to Complain
Annex linked to Step 3
User/ Positive reasons for access to Negative reasons for access to

Result
Complainant complaint complain
List the different List the reasons why this stake- List the reasons why this stake- Result. State “accepted” or
potential users holder should be allowed to com- holder should NOT be allowed to “rejected”.
plain and use the agency’s CM. complain and use the agency’s
CM.
Direct
beneficiary
Potential
beneficiary
Host Community
Agency staff
Other
stakeholders
ANNEX 5D – User and Appeals Matrix
Annex linked to Tool 4D

Exercise – Based on your analysis, register the user of the CM, the bodies to deal with their complaints and the appeal bodes.
Type of complaint
Appeals body
Non-sensitive Sensitive
complainant (user)
ANNEX 5E – User entry points analysis
Exercise
1.Each group focuses on one type of user only (beneficiaries, host community, agency staff members etc.). Write the complainant
group in the designated cell.
2.Based on the considerations already made during Step 2 and Step 4, potential entry points are listed in the left column.
3.The strengths and weaknesses for each entry point for the users are analysed.
4.Specific issues needing special attention (e.g. in terms of how the entry points is designed or located) is mentioned in the com-
ments section.
Complainant:
Strengths Weakensses Comments

Type of entry point

ANNEX 5F - COMPLAINTS FORM
AGENCY COMPLAINTS FORM No:
1. COMPLAINT / USER - to be filled in by complainant
Name
Address
Other relevant information necessary to ID user / complainant
2. COMPLAINT - to be filled in by complainant
Type of complaint: (Often it can be relevant to categorise complaints based on the substances, sector,
district, user etc)
Shelter Assistance Income Generation Social Community Project Other
Description of complaint: (please annex additional paper or drawing if requested)
Describe your expected outcome / response: (please annex additional paper or drawing if requested)
3. SIGNATURE -to be signed by complainant
By signing and submitting this complaint, I accept the procedure by which the complaint will be proc-
essed and the composition of the complaints board dealing with this complaint. I have been informed
of the terms for appeal.
Date: Complainant
4. RESPONSE AND APPEAL - to be filled by the agency
Response / remedy to the complaint: (please annex additional paper if requested)
Response / remedy was: 

Accepted Not accepted Not appealed  Appealed to: _________________
Date: Complainant: Agency:
5. RECEIPT - to be filled by the agency, and cut off and given to complainant
Complaint number: (Unique, same and registered on the upper-right side of the paper)
Expected date of response: Place to receive response:
Agency Signature: Date:

ANNEX 5G – Means of Communication per Potential User
Exercise (If the table is too small, use a blank page for each type of potential user. )
1. In the left column all the accepted users are listed. Consider only the national ones and focus mainly on beneficiaries.
2. At the top of the table, list the entry points, as identified in Step 5 (Annex 5E)
3. Based on discussions within the group around the local context, list the best / realistic means of communicating. These include
both written means (internet, posters, pamphlets) and verbal (meetings or workshops, face-to-face, radio), but it is important to
consider how such information is communicated. The suggestions need to ensure that the information is both made available and
is communicated.
4. Specific issues needing special attention (e.g. if a certain group is difficult to reach by the identified complaints entry points) is
mentioned under comments.
Entry Point Entry Point Entry Point: Entry Point Comments
Beneficiaries
Potential user
Potential user
Potential user
Potential users
Potential user
Potential user
ANNEX 5H – What to Communicate to the Use
Making a communication plan is an extensive task, and even once finished, the plan
is something that needs to be revised and updated continuously. In this group ses-
sion, it is valuable to have guidance from the group on what is relevant to include in
this specific context (a final formulation of the context of an information campaign
would be too comprehensive).
Exercise
1. The list of points relevant to communicate to potential users is of a general char-
acter. Inspired by this, make a new list adapted to your local context - what is impor-
tant to inform about with regard to the 1) Agency, 2) the project and 3) the CM. Many
of the issues to be communicated are related to the issues already addressed and
decided in the former Steps of section 3A. Please follow these decisions carefully.
2. Please use the same three headlines on a blank piece of paper and bullet point
the issues based on the discussion in the group.
3. Results should be presented in plenum.
» Presentation, Agency
- Presentation of the organisation.
- Presentation of the principles, standards, assistance frameworks, codes incl.
those applicable to staff, accountability etc. to which the organisation com-
mits – or are prepared to be held accountable to. (Supported and inspired by
Annex 5B and Reference 2A Chapter 3.1)
- Brief presentation of the CM (based on the purposes and values identified
under Step 1) and stating the fact that the agency invites complaints and that
beneficiaries and other identified groups have the right to complain.
» Presentation, Project
- Presentation of the project and objective, selection / vulnerability criteria, ap-
proach and stages of beneficiary involvement, description of assistance or
services offered (e.g. supported by pictures), funds and resources allocated
and donor, partners, etc.
This part should enable the beneficiary in detail to know what to expect, terms
for receiving and as a basis to consider whether he wishes to be part of the
project. It will enable the potential complainant to present his concerns prior
to initiation of the project and complain if deviation is detected. As priori-
ties, approach or else are changed during implementation, the information
communicated is updated. It is important to highlight that such changes can
occur. Most of this should be reflected in the donor application, but translated
into a concrete output terminology
» Presentation, CM
- Why. Explaining the purpose of the CM (e.g. related to accountability, improv-
ing the system by learning from past mistakes or to ensure optimal usage of
resources – see Step 1)
- What. Explaining in detail what it is possible to complain about (Step 2)
as well as possible remedies on offer (incl. limitations!). This should be as
concrete as/if possible (see Step 9) - both in terms of what is provided, and
how (beneficiary involvement, consultation etc!). The scope of the CM has
already been identified under Step 2.
- Who is allowed to complain?
- How, where and when. Procedures (incl. how, where and when to complain
and receive response / remedy (e.g. explained in a simple figure), the Com-
plaint Handling System incl. the composition of the complaints board (and
maybe how it is chosen), how the complaint is processed and appeals possi-
bility, etc). In Step 4, you defined sensitive and non-sensitive complaints. This
should be reflected as well in order for the users to know to which complaints
handling board the issues should be addressed.
- The policy of non-retaliation against and confidentiality towards the com-
plainant. Please note that in order to comply with HAP Benchmark 5.2e (see
Reference 2C), the agency is required to formulate a “confidentiality and
non-retaliation policy for complainants”. In principle, it is sufficient to commit
to these principles and to communicate this commitment to the user popula-
tion.
ANNEX 5I – Developing an LFA
Agency objectives for establishing a Complaints Mechanism:

1. xxxxx
2. xxxxx
3.
Means / source of
CM standard to be achieved Indicators
verification
Simple procedures and mechanisms give (Discuss the point by focusing on which (Important issues to consider
potential and intended beneficiaries access problems and solutions (in terms of redress while setting up of the CM.)
to a safe means of voicing complaints on and/or response) available when addressing
areas relevant and within the control of the concrete challenges.)
agency.
Outputs to be achieved Indicators Means / source of

verification
The procedure, purpose and parameters

1 of the CM have been communicated and
made available to relevant stakeholders.
Intended users have both safe and easy

2 access to use the CM.
Logical and easily-understood procedures

3 developed for submission, processing and
response / redress of complaints
Complaints are processed by an independ-
4 ent and competent body guided by trans-
parency, confidentiality and impartiality.
Action points / Activities Inputs / resources Assumptions
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Chapter 1 INTRODUCTION | 3

Objective of the handbook

How to use this handbook

complete introduction of the Tools and Annexes in the next chapter.

How this handbook was developed

Christian Jacob Hansen

Step By Step Description

Tools and Annexes

» 1. Introduction: An introduction to the handbook (1A) followed by a more thorough

- Tool 4A The Concept of Complaining in Perspective. This is a small exercise

• Objective: To design the systems capable of handling the different types of

• Objective: Based on analysis of the local context, to decide how and

• Objective: To decide in which form the complaints can be submitted – writ-

• Objective: To decide on the procedure and persons to investigate com-

• Objective: To consider how and what to communicate when responding to

• Objective: To decide on what and how to communicate to the users of the

• Objective: To develop an LFA summarising how the CM respects the mini-

CHAPTER 2a - Reference material

1. Definition of a Complaints Mechanism

that members commit themselves to abide by the Principles of Accountability.

1.The procedure, purpose and parameters of the CM have been communi-

3.Logical and easily-understood procedures are developed for submission,

4.Complaints are processed by a competent body guided by transparency,

2. What are the benefits of a complaints mechanism?

“A CM seeks to provide a safe opportunity to raise a valid concern and to have

Beneficiary wishes A more serious

2.1 CM - a dignifying mechanism

promises, principles and products / services given to their consumers.

2.2 CM as a separate project component

2.3 CM as an early warning indicator

2.4. CM from a cost-benefit perspective

2.5 CMs are complementing impact monitoring

2.6 CM as statistic documentation

3 What are the risks of a complaints mechanism?

3.1 Security considerations

low profile needs to sometimes operate through remote management.

The beneficiaries of humanitarian assistance in volatile and dangerous en-

The beneficiaries of humanitarian assistance in volatile and dangerous situations

3.2 Protecting the users when dealing with sensitive issues

A country is home to a number of Iraqis without a legal permit to stay and

It is the responsibility of the agency to consider these aspects of sensitivity and

3.3 Resources to manage a Complaints Mechanism

3.4 Complaints Mechanism is a Western concept.

3.5 Fear of being over-burdened

An agency is distributing NFI-kits to refugees scattered throughout the coun-

reason why a CM cannot be established; rather, that over-burdening is a matter of

4. General Characteristics of a Complaints Mechanism

4.1. Internal capacity and scope of the Complaints Mechanism

- How and where to publicise information on how to file a complaint.

In an operation in North Caucasus, it is possible to complain about 8 very spe-

Promises made to beneficiaries

4.2 Filing a complaint

semination are often necessary, including information meetings etc.

4.3 Processing a complaint

4.4 Redress for the complainant

Having investigated a complaint of a family, the Agency recognises that it falls

4.5 Learning from a complaint

5. Three Examples Of Complaints Mechanisms

5.2 Sexual abuse of vulnerable groups (specific and sensitive issues)