COMPLAINTS HANDLING POLICY ORIGINAL FRENCH VERSION ADOPTED BY THE BOARD OF DIRECTORS MARCH 30, 2015 *English translation provided for information purposes only. Complaints Handling Policy (Adopted 2015-03) Page 1 of 8
TABLE OF CONTENTS 1 GUIDELINES... 3 1.1 OBJECTIVE... 3 1.2 SCOPE... 3 1.3 DEFINITION OF TERMS... 3 1.3.1 COMPLAINTS... 3 2 HANDLING COMPLAINTS... 4 2.1 RECEIVING COMPLAINTS... 4 2.1.1 MINIMUM INFORMATION REQUIRED FOR A FORMAL COMPLAINT... 4 2.2 ACKNOWLEDGEMENT OF THE COMPLAINT... 4 2.3 PROCEDURE FOR HANDLING COMPLAINTS... 5 2.4 PROCEDURE FOR APPEALING COMPLAINT FINDINGS... 6 2.5 PREVENTIVE ACTION... 6 3 ACCOUNTABILITY... 6 3.1 COMPLAINT FILE... 6 3.2 REPORTING TO THE BOARD... 7 4 RESPONSIBILITIES... 7 4.1 BOARD OF DIRECTORS... 7 4.2 BOARD CHAIR... 7 4.3 HUMAN RESOURCES COMMITTEE... 7 4.4 GENERAL MANAGEMENT... 8 5 LIST OF CHANGES... 8 Complaints Handling Policy (Adopted 2015-03) Page 2 of 8
1 GUIDELINES 1.1 OBJECTIVE This policy aims to ensure the adequate response to comments, suggestions and recommendations issued by internal and external parties related to the organization and thus improve the organization s response within the community. The policy covers complaints from all parties, including Elder Friends, volunteers, donors, employees and people of the community who are served by the organization. It establishes a fair and efficient procedure to handle all complaints. More specifically, it is intended to support the receipt of complaints, the creation and progress of the complaint file, and the satisfactory resolution and compiling of the complaints to enable constant improvement and prevent further occurrence of the cause of the complaint. 1.2 SCOPE This policy applies to all employees and volunteers of the organization and extends to all activities, teams and chapters. 1.3 DEFINITION OF TERMS 1.3.1 COMPLAINTS A complaint expresses dissatisfaction with a physical person or legal entity regarding an action that was taken or omitted by members of the organization. A complaint may be formulated verbally or in writing. For policy purposes, a complaint constitutes the expression of at least one of the following three elements: An allegation involving a Little Brothers member, employee or volunteer The identification of potential or real harm that may have been sustained by the complainant A claim for corrective action. An informal procedure aimed at correcting a particular problem, when in fact the problem is handled and resolved within the context of the organization's regular activities, without the individual having to file a formal complaint, does not constitute a complaint. A complaint is considered to be informal when it is formulated verbally, unless the complainant specifies otherwise or is unable to file the complaint in writing. Complaints Handling Policy (Adopted 2015-03) Page 3 of 8
A complaint is considered to be formal when it is submitted in writing to a team leader (coordinator or manager) or to General Management. 2 HANDLING COMPLAINTS 2.1 RECEIVING COMPLAINTS The individual who wishes to file a complaint may do so by mail at the following address: Little Brothers Head Office 4624 Garnier Street, Montreal, Quebec H2J 3S7 by email: generalmanagement@littlebrothers.ca by telephone: 1-866-627-8653 ext. 229 If the complaint concerns General Management, it may be forwarded to the Chair of the Board of Directors at boardchair@littlebrothers.ca. Complaints will be handled in the strictest confidence. Employees who receive a formal complaint must forward the complaint to the General Management as soon as it is received, together with a completed incident report form to provide background information regarding their receipt of the complaint. 2.1.1 MINIMUM INFORMATION REQUIRED FOR A FORMAL COMPLAINT A formal complaint must include the following information about the situation and the person filing the complaint: First and last name, or official name in the case of a legal entity; Mailing and email address (if possible); Telephone number; Subject of the complaint; A description of the cause of the complaint, the persons involved, and when it occurred (date and time if possible), if applicable; A description of the harm or possible harm sustained, the allegation made and the corrective measure requested, if applicable; The signature of the person filing the complaint or their representative; The date the complaint was filed. 2.2 ACKNOWLEDGEMENT OF THE COMPLAINT Complaints Handling Policy (Adopted 2015-03) Page 4 of 8
Within three business days following the receipt of a formal complaint, General Management will send an acknowledgement to the complainant that includes the following elements: A summary of the contents of the complaint as received; In the case of an incomplete complaint, a request for additional information that must be answered by the complainant within a determined timeline, failing which the complaint will be considered to be discontinued; The name and contact information of the person in charge of handling the complaint; A copy of the Complaints Handling Policy; A notice advising the complainant of their right to appeal if they are not satisfied with the resolution or handling of the complaint. A copy of the acknowledgement will also be forwarded to Human Resources for monitoring and follow-up purposes. 2.3 PROCEDURE FOR HANDLING COMPLAINTS As soon as a complaint is received, a complaints handling process is initiated. The person responsible for handling the complaint must make sure they have all the relevant information on hand, including the policies and guidelines currently in effect and all other documents related to the reported complaint. The complaint handler may ask the complainant for additional information if they deem the complaint to be incomplete. The complaint handler will then gather information from the persons involved in the situation to better understand all the facts and to be able to render an informed decision. If the information is deemed unsatisfactory, further interviews or analysis may be undertaken to ensure that all relevant information has been collected. In certain cases and to better manage the situation, the complaint handler may request assistance from specialists. The complaint handler must also make sure that appropriate measures have been implemented to contain the situation and inform other parties who may be affected by the complaint. The complaint handler may also request swift, complementary action if required, such as restraining measures or information gathering measures for other potentially affected parties. The complaint handler will then determine if other action is required to adequately respond to the complaint. After examining the complaint, the complaint handler will identify the corrective and preventive actions to be implemented in order to prevent the situation from recurring or escalating. The complaint handler will prepare a response to the complainant and submit the report to General Management and Human Resources Management. Once the process is complete, the complaint handler will send a written response to the complainant, listing the reasons for the decision. Complaints must be handled within a reasonable amount of time, i.e., 15 business days following receipt of the necessary information. Should it prove impossible to prepare a reply Complaints Handling Policy (Adopted 2015-03) Page 5 of 8
within this timeframe, the complaint handler will advise the complainant and Human Resources Management in writing and provide a new date for resolving the complaint. 2.4 PROCEDURE FOR APPEALING COMPLAINT FINDINGS If the complainant is not satisfied with the reply or the way the complaint has been managed by the complaint handler, they may file an appeal with General Management or the Board Chair if the former was the object of the complaint. General Management or the Chair will either grant this request and review the decision or refer the person to an external authority. The decision resulting from the appeal will be conveyed to the complainant in a letter. 2.5 PREVENTIVE ACTION When an improper or high-risk situation is detected, the complaint handler must address the problem as soon as possible in order to rectify the situation in the short term and prevent the circumstances from recurring or escalating. However, this action may be insufficient in preventing recurrence over the long term. To permanently eliminate the causes of an improper or high-risk situation, preventive action is required. While investigating the complaint and preparing the incident report, the complaint handler will, jointly with designated colleagues as needed, determine: The appropriate preventive action to permanently eliminate the cause; The person who will apply this action; The timeline for application. Within this timeline, the complaint handler will assess the outcomes in collaboration with the person responsible for implementing the preventive action and determine whether the results are satisfactory, i.e., whether the cause has been permanently eliminated. 3 ACCOUNTABILITY 3.1 COMPLAINT FILE An incident report must be prepared for every complaint and included in a file containing: The complainant's written complaint, including the three elements of the complaint (the allegation and the person(s) involved, the resulting potential or real harm, and the requested corrective action); The incident report summarizing the complaint, along with the other elements related to the complaint handling process, including the preventive and corrective measures implemented; Complaints Handling Policy (Adopted 2015-03) Page 6 of 8
The outcome of the complaint handling process (analysis and supporting documents); The final written response to the complainant, listing the reasons for the decision. All complaint files will be forwarded to and stored by Human Resources Management. Human Resources Management will keep a record of these files. 3.2 REPORTING TO THE BOARD The Human Resources Committee and/or Board of Directors must be alerted in a timely manner of any complaints that involve major or systemic issues or represent a risk to the organization s reputation. Once a year, regardless of whether or not any complaints have been filed, Human Resources Management must submit a report logging the number and nature of all complaints received to the Human Resources Committee. 4 RESPONSIBILITIES 4.1 BOARD OF DIRECTORS The Board of Directors is responsible for: Approving this policy and subsequent amendments; Ensuring that General Management takes every precaution to promote an environment conducive to the disclosure of wrongdoing; As a last resort, taking action in the event a person is unsatisfied with the handling of a complaint filed under this policy or the disciplinary measures taken as a result; Reviewing reports and ratifying the findings of initial and formal investigations. 4.2 BOARD CHAIR The Chair of the Board of Directors is responsible for: Handling all complaints that directly involve General Management. 4.3 HUMAN RESOURCES COMMITTEE The Human Resources Committee is responsible for: Evaluating and proposing to the Board any required changes to this policy; Reporting to General Management and the Board on complaints received and how they were handled and resolved. Complaints Handling Policy (Adopted 2015-03) Page 7 of 8
4.4 GENERAL MANAGEMENT General Management is responsible for: Ensuring that all employees, volunteers and Elder Friends are informed of the existence of this policy and of the recourses available to them if a complaint is received; Handling and ensuring the handling of all complaints that do not directly involve General Management; Preparing an annual assessment for the Human Resources Committee on how this policy is enforced; Proposing recommended changes in this policy to the Human Resources Committee and the Board. 5 LIST OF CHANGES EFFECTIVE CHANGES DETAILS 2015-03 Effective Complaints Handling Policy (Adopted 2015-03) Page 8 of 8