External Complaints & Feedback Policy & Procedure 

Purpose 

Brave Foundation (Brave) is committed to providing high quality services to participants and our organisational partners, and seeking to understand and support their rights and what is important to them. 

The purpose of this Policy is to provide all Brave employees with guidance on the management of complaints and feedback received by the organisation from external parties. 

Policy Statement 

Brave is committed to fostering an organisational culture of remaining open to receiving feedback and complaints. 

Receiving such information enables Brave to reflect on its service offerings and processes, improve the quality of its organisational operations. It also gives opportunities to enhance trust and confidence with stakeholders and identify areas of service delivery that need to be improved upon, and forms part of Brave’s commitment to continuous improvement. 

This Policy seeks to ensure that those that provide feedback or make a complaint to Brave: 

• Have their complaint or feedback acted upon 
• Receive a timely and respectful response to their concern/s 
• Be kept informed throughout the process and be advised of the outcome (including how their feedback has led to service improvement) 
• Ensure that they understand their options if they are dissatisfied with the process or an outcome 

This Policy also reaffirms the recognition of ‘Lived Expertise’, as documented via the Model of Participation, and recognises the right of our participants to seek, receive and impart information about the services they are receiving, and allow for feedback from those experiences to further inform the way in which Brave designs and delivers its programs. 

Scope 

This policy applies to the Board of Directors and all employees of Brave (including casual/seconded/contractual staff/apprentices /trainees/placements/interns) and key volunteers, and to any external complaint, regardless of who makes it. 

This Policy is not intended to cover internal complaints made by Brave staff in relation to the organisation. For information regarding internal complaints and grievances please refer to the Internal Grievance Policy and Procedure. It is also not the intention of this Policy to cover allegations made of fraud or corruption; for information regarding these types of complaints please refer to the Fraud and Corruption Policy. 

Some external complaints may fall under the protection of ‘Protected Disclosure’, or ‘Whistleblowing’. For further information regarding what may constitute a protected disclosure, the process for making a disclosure, and the rights and responsibilities of a person making a Protected Disclosure, please refer to the Protected Disclosure Policy. 

Complaint	A registered expression of dissatisfaction with a service or person, communicated verbally or in writing, with the intention of seeking resolution.
Whistleblower/ whistleblowing	A person who makes a disclosure or a report about a person or organisation regarded as engaging in an unlawful or immoral activity. For further information on what constitutes unlawful or immoral activity, please refer to the Protected Disclosure Policy.
Report/ disclosure	Sharing information of a sensitive or concerning nature, or information that relates to an act of Reportable Conduct, Emergency Interest Disclosure, or Public Interest Disclosure, with another person. For further information on what constitutes Reportable Conduct and the different types of Disclosures, please refer to the Protected Disclosure Policy.
Allegation	A claim or assertion that someone has done something illegal or wrong, typically one made without proof.
Complainant	The person or entity lodging the complaint.
Confidentiality / confidential	Protection of the identify of a complainant and other parties involved in a complaint, or the details of a complaint, where required or requested.
Feedback	Information shared between parties that provides insight and reflection on how a service/interaction/incident may have been experienced. Feedback can be positive, negative, or neutral.
Misconduct	Unacceptable or improper behaviour, or behaviour otherwise in breach of one of Brave’s policies or procedures.

Authorities & Responsibilities

Title	Authorities	Responsibilities
Board of Directors	To approve the External Feedback and Complaints Policy and Procedure.  To authorise the engagement of outside resources to investigate serious claims, where required and brought via the Strategy and Governance Committee and CEO.	To maintain oversight of and comply with External Feedback and Complaints Policy and Procedure.  To manage cases of serious complaints and feedback received by Brave as brought via the Strategy and Governance Committee.
Strategy and Governance Committee	To endorse the External Feedback and Complaints Policy and Procedure.  To recommend to the Board the engagement of outside resources to investigate serious claims, where required.	To maintain oversight of and comply with External Feedback and Complaints Policy and Procedure.  To manage cases of serious complaints and feedback received by Brave, brought via the CEO, and report on and or/escalate to the Board where required.
Chief Executive Officer	To manage the engagement of outside resources to investigate serious claims, where required and decided via the Board and Strategy and Governance Committee.	Comply with and ensure implementation of External Feedback and Complaints Policy and Procedure within the organisation.  Oversight of all complaints and feedback of a serious nature received by the organisation and bring to  the Strategy and Governance Committee where appropriate.
Senior Leadership Team (SLT)	To manage the relationships with outside resources to investigate serious claims, where required and decided via the CEO	Comply with and ensure  To manage the resolution of any complaints and feedback received, brought via Team Leaders or other staff, and refer on to CEO where appropriate.  To report any serious complaints and feedback received, and any resolutions sought, to the CEO.  staff are aware of an comply  with External Feedback and  Complaints Policy and  Procedure.
Team Leaders		Comply with the External Feedback and Complaints Policy and Procedure.  To assist their staff members in the resolution of feedback and/or complaints they have received, or to refer to SLT where appropriate.
Employees (including SLT, SEED staff, volunteers and contractors)		Comply with the External Feedback and Complaints Policy and Procedure.  To communicate any feedback or complaint received to immediately to their manager, and to assist in its resolution where appropriate.

Procedure 

1. Lodging a complaint or feedback 

Brave recognises that there may be circumstances where participants, organisational partners or stakeholders are dissatisfied with either the services being offered or an individual employee’s performance and wish to make a formal complaint, or otherwise provide feedback. 

All participants in Brave programs are provided with hardcopy information regarding their rights and the process for lodging a complaint or giving feedback in their Welcome Pack (See Appendix 1: Give Feedback or Make a Complaint). 

It should be noted that feedback can be positive, negative, or neutral, but is viewed as equally critical to the organisations learning and continuous improvement. Feedback differs from a complaint in that it is provided as information only and the person providing the information expressly states that they do not wish for any follow up or other resolution, and the matter does not involve an issue of misconduct. 

A formal complaint, or feedback, can be lodged via any of the following methods: 

• Phoning Brave Head Office (on 0448 088 380) 
• In person by speaking, emailing, or phoning any employee 
• Writing either by email () or hardcopy letter addressed to: 

Brave Foundation 

PO Box 990 

Ringwood, Vic, 3134 

In all cases, the person making the complaint or feedback has the right to keep their identify confidential if they so choose (see: Section 4: Confidentiality) 

2: Acknowledgement of Feedback 

On the occasion feedback is received, it should always be acknowledged and discussed by all relevant parties to fully understand the nature of the information and to ascertain if the information is intended as feedback or constitutes a potential complaint. It will then be determined: 

• How the feedback will be recorded (e.g., on the participant file, verbally to the recipient or another staff member, written and lodged with the senior leadership team) 
• If the feedback requires an outcome to be implemented in response to the information received (e.g., reviewing a process or procedure within the organisation) 
• If the person lodging the feedback would like to be kept informed about how their information is being used; and 
• What information the person lodging the feedback is giving permission to be shared. 

3: Acknowledgement of a complaint 

All complaints received by Brave will undergo the following steps to seek resolution to the issues raised, and to keep the complainant informed of the process: 

• Complaints should be responded to by the recipient of the complaint, verbally within 24 hours of receipt; 
• A written acknowledgement of receipt should be sent within 3 days of receipt of the complaint; 
• All conversations with the complainant should be documented as part of a record of the investigatory process; 
• Where a Brave employee is the first point of contact, they should seek to resolve the issue raised where possible, and within the scope of their role. Where an issue is unable to be resolved, a more formal complaints process will be followed (see section 7: escalation); 
• The recipient of the complaint should notify their manager, and if appropriate, the relevant member of the Senior Leadership team. 
• If the complaint relates to a matter of serious misconduct, the Chief Executive Officer should be notified immediately (for more information on what constitutes misconduct, please refer to the Code of Conduct) 

4: Confidentiality 

Brave will protect an individual’s identity when they raise an issue and indicate they do not wish for their identifying information to be disclosed. It should be understood, however, that complaints of a serious nature may require the source of the information to be identified to verify the claims. Furthermore, a statement by the individual may be required to be collected as part of the evidence. In this case, Brave will communicate this to the individual and gain their consent before their identify is made known. 

For more information on how Brave handles privacy and identifying information, please refer to the Privacy Policy. 

5: Investigating a Complaint 

Depending on the nature of the complaint, an investigation of the issues raised may be required. Usually, this will take the form of an internal inquiry, however, in some cases, the CEO, Strategy and Governance Committee and/or Board may deem it necessary to engage an external investigator to investigate the complaint. 

When Brave Foundation receives a complaint, an investigation of the complaint will occur based on the information received. Brave Foundation will rely on the information provided by the complainant and may refer to other relevant information on record as appropriate. 

To assist in the investigation and to address the complaint quickly and efficiently, Brave may ask the complainant for the following information: 

• Complainant’s name and contact details; 
• Name of the employee or the service being provided; 
• Nature of the complaint; 
• Details of any steps that the complainant has completed to resolve the issue; 
• Details of any conversations held with Brave relating to the issue; and 
• Copies of any documentation which supports the complaint. 

The complainant should be advised that there may be occasions throughout the investigation where they will be contacted for further information and/or provided with an update on progress of inquiries. 

Team Leaders, and where appropriate, the relevant member of the SLT and CEO, should be kept updated with discussions and actions taken throughout an investigation. 

6: Resolving a complaint 

Following the completion of an investigation, Brave will ensure that all parties involved are advised of the outcome and any actions taken regarding the complaint. The complainant will be advised verbally in the first instance, and then provided with a letter outlining the actions taken and the outcome of the investigation into the complaint. 

Brave is committed to resolving all complaints within 28 days of a complaint being made, however, recognises that more serious complaints (e.g., those regarding misconduct) may take longer to investigate and resolve. 

Brave will ensure that the complainant is kept informed of progress and any delays and will endeavour to provide timelines on when the matter may be resolved. 

7: Escalation of a Complaint 

There may be occasions when a matter is unable to be resolved to the satisfaction of the complainant. In these circumstances, a matter may be escalated via the pathway below. 

Stage 1

• Brave staff member recieves a complaint. The staff member seeks any necessary clarification of the nature or details of the complaint and commences documenting details of the complaint.
• The staff member verbally acknowledges the receipt of the complaint to the complainant within 24 hours, and provides written receipt within 3 days.
• The staff member takes details of the complaint to their direct manager for discussion and seeking of resolution to the matters raised in the complaint, documenting all details of the process.
• The staff member will keep the complainant regularly updated with the progress of their complaint.
• The staff member will advise the complainant of the resolution of their complaint within 28 days, and document the resolution.
• Where a complainant is unsatisfied with the resolution offered to the complaint, the direct manager will be notified, and the complainant advised of the escalation process.

Stage 2

• The direct manager will contact the complainant directly within 3 days to seek to further resolve the issues raised.
• The direct manager will document any discussions held and resolutions sought and/or reached.
• If resolution is unable to be sought at this stage, the relevant member of the SLT will be advised, and the complainant advised of the escalation process.

Stage 3

• The member of the SLT will contact the complainant directly within 3 days to seek to further resolve the issues raised.
• The member of the SLT will document any discussions held and resolutions sought and/or reached.
• If resolution is unable to be sought at this stage, the CEO will be advised, and the complainant advised of the escalation process.

Stage 4

• The CEO will contact the complainant directly within 3 days to seek to further resolve the issues raised.
• The CEO will document any discussions held and resolutions sought and/or reached.
• If resolution is unable to be sought at this stage, the CEO will refer the matter to the Strategy and Governance Committee, and the complainant advised of the escalation process.

Stage 5

• The Strategy and Governance Committee will discuss the complaint received and review all documentation of the resolution process up until that point.
• The Strategy and Governance Committee will decide if they conduct their own investigation or engage an external investigator, or further seek the advice of the Board on the matter.
• The Strategy and Governance Committee will keep the complainant updated regarding the progress of the investigation.
• If resolution is unable to be sought at this stage, please refer to Section 7: When a complaint is unable to be resolved

In all instances where a matter is escalated, the Head of Operations must be notified within 24 hours of notification of the request for escalation, at each stage of the escalation process. 

8: When a complaint is unable to be resolved

Whilst Brave will make all reasonable attempts to resolve an issue and provide a satisfactory outcome, it is acknowledged that there are occasions where a complainant may not be satisfied with the resolution of their complaint. In this instance, the complainant is able to communicate their dissatisfaction to Brave, and allow the organisation to offer further solutions to the issue raised as per the escalation process.
Should a resolution still not be able to be reached by all parties, the complainant may be provided with information about external bodies that they can contact for further information, including but not limited to:

• Relevant Ombudsman in each State and Territory
• Privacy body in each State and Territory
• Civil Administrative Tribunal in each State and Territory
• Disability Services Commissioner

9: Keeping records
Brave will retain digital records detailing all interactions in relation to received feedback or complaints, including their resolution, and archive these securely in accordance with its Information Technology and Security Policy. Records will be securely maintained for a period of 7 years.
In the case that a complainant or other person involved in the complaint process has requested to remain anonymous, any identifying information will be omitted from the records.

10: Breach of Policy

Where there are breaches of this Policy, Brave may escalate the breach to management and/or the CEO which may result in disciplinary action, up to and including termination of contract.