Raising a Concern

Introduction

1. Understanding, responding to and learning from complaints and concerns is an essential part of HERA-XXI’s transparency and accountability processes. Complaints, concerns and feedback allow HERA-XXI as an organization to reflect on and identify how HERA-XXI needs to change and to adapt. HERA-XXI views this process as a positive opportunity to learn, develop and improve.

2. HERA-XXI is committed to protecting its governing bodies, volunteers, members and staff from any detriment, victimization, harassment or bullying as a result of raising a concern (whistleblowing). Complaints of any such behaviour will be taken seriously and managed appropriately through the relevant disciplinary process.

1. HERA-XXI is committed to supporting good management practice and a culture of being able to speak up, where volunteers, members, trustees and staff can raise concerns about their colleagues’ and supervisor’s conduct informally with them in the first instance and that these concerns will be listened to and taken on board without victimization.
2. This policy is intended to set out the guiding principles and values applicable to all elements of HERA-XXI. These guiding principles and values need to be implemented through the relevant policies and procedures.

Purpose and Scope

3. This policy applies to all volunteers, members, trustees and staff of HERA-XXI. Collaborative partners and other partners are required to adhere to this Policy in addition to their own policies and procedures which shall be aligned with this Policy.

Definitions

4. A complaint is an expression of dissatisfaction. It can relate to malpractice, the standard of service received from HERA-XXI, action or lack of action by HERA-XXI, or the behaviour of HERA-XXI volunteers, staff or anybody directly involved in the delivery of HERA-XXI’s work, including contractors.

5. “Whistleblower” is the term used to describe a person who raises public interest concerns about malpractice whether in their workplace or otherwise, using appropriate procedures.

Malpractice

6. Malpractice includes, but is not limited to, the issues listed below:

1. Financial wrongdoing including theft, bribery, fraud, money laundering andaid diversion;
2. Failure to comply with any legal obligations;

• Bullying and harassment including sexual harassment;

1. Abuse or exploitation, including sexual, of children, vulnerable adults or beneficiaries;
2. Breach of HERA-XXI Code of Conduct;
3. Danger to the health and safety of individuals or damage to theeenvironment;

• Improper conduct or unethical behaviour;
• Activity which would bring the organization into serious disrepute; How to raise a concern

Incident Reporting Service

7. Where possible, complaints and concerns should be submitted through HERA-XXI Safe Report, HERA-XXI ’s incident reporting service. Contact details are made easily accessible on HERA-XXI’s website.⁴
8. Whistleblowing concerns can also be raised with the executive director.

9. To ensure oversight and effective monitoring and learning, complaints will be processed by the executive director and distributed to the board members annually.

Anonymous complaints and concerns

10. HERA-XXI faces limitations in investigating complaints and concerns that are submitted anonymously, particularly when they lack sufficient substantiation.
11. Individuals concerned about being identified are encouraged to request confidentiality.

Guiding principles

12. HERA-XXI is committed to ensuring that it responds to the actions of individuals who raise concerns or complaints or bring grievances as follows:

Fair

• HERA-XXI will listen to the person raising the complaint or concern and take the time (up to one month) to understand what the complaint or concern is about, the reasons for it and the outcome the person expects.
• Complaints and concerns will be dealt with consistently and the persons investigating and making decisions will be impartial. HERA-XXI will ensure that all its processes pay due regard to the needs of anyone who may have been subject to ill- treatment or abuse and that where a complaint or concern relates to such conduct the needs of its recipient remain at the forefront of any investigation process.
• No volunteer, members, staff or governing bodies members will be subject to any detriment, victimization, harassment or bullying as a result of raising a concern.
• If the person is receiving a service from HERA-XXI, making a complaint or raising a concern will not affect the service they receive.

Confidential

• Information about a complaint or concern will be provided only to those people who need to know about it, in order for the complaint or concern to be actioned properly. Personal details about the complainant or whistleblower and any alleged perpetrators will remain confidential.
• Where confidentiality is requested, every effort will be made to maintain this and identities will not be disclosed without prior consent, unless required by law.
• Where any identities are likely to or do become known, the implications of this, and any protection or support requirements which flow from it, will be discussed with the individualconcerned.

• HERA-XXI recognises that non-disclosure agreements do not prevent individuals from makingdisclosures in the public interest.

Transparent and Accountable

• HERA-XXI will ensure that the process to be applied to, and the possible outcomes of, the complaint/concern are clearly explained to those involved. HERA- XXI will give clear, evidence-based explanations, and reasons for any decisions made.
• All complaints/ concerns will be logged and monitored, and anonymized data concerning complaints will be included in HERA-XXI’s annual reporting. The types of complaints/concerns received by HERA-XXI, and any implications thereof, will be reviewed by the Executive Director and reported to the Governing Bodies annually.
• HERA-XXI will ensure that all feedback and lessons learnt from complaints and concerns contribute to service improvement and staff welfare. HERA-XXI will share information about learning with volunteers, members, governing bodies and staff in a confidential manner through a report summary.

Accessible

• HERA-XXI is committed to making the process of submitting a complaint/concern as easy aspossible. HERA-XXI’s incident reporting service, HERA-XXI SafeReport, is available in a number ofdifferent formats: Online on website: https://hera-youth.ge/ and anonymous boxes in front of the service providers rooms.

Efficient and timely

• HERA-XXI will acknowledge and aim to resolve complaints and concerns in a timely manner,in linewiththetimelines in theappropriateprocedure. HERA-XXIwill keep all parties informed of the process and of any delays.

Implementation

• It shall be the responsibility of the Governing Bodies, and ExecutiveDirector to ensure that Raising a Concern policies that meet the above-mentioned minimum standards are in place and that they are implemented, monitored and reviewed within a timeframe agreed by management.

• HERA-XXI will:

1. Ensure their governing bodies, members, staff, volunteers, and beneficiaries and local communities are aware of this policy and know how to use HERA-XXI SafeReport.

1. Ensure all leaders and managers lead by example and promote an environment where raising concerns is encouraged and welcomed.

1. Ensure all complaints are appropriately logged and recorded.

1. Ensure that responses to complaints and concerns pay due regard to the needs of anyone who may have been subject to ill-treatment or abuse and that where a complaint or concern relates to such conduct the needs of its recipient remain at the forefront of any investigation process.

1. Ensure that support is available to survivors (victims) of harm caused bystaffor anyone associated with HERA-XXI, regardless of whether a formal investigationis carried out.

Appeal Process

• The decision of the executive director can be appealed to the board members of the organization and the decision of the board can be appealed to the general meeting members.

Complaints and concerns involving the officers at the highest level of organization.

• the Governing Bodies and the Executive director are dealt with in line with policy of the Independent complaints panel , which is composed of three members from general meeting members. (One board member, one volunteer and one staff member)

Complaints and concerns involving collaborative partners and other partners

• Substantiated malpractice or failure of any partner to ensure the implementation of the outcomes and recommendations of an investigation shall be considered a breach of HERA- XXI’s contractual agreement with this partner. This may incur sanctions and termination of contract.

Reviewed& Approved Date: 2021