The purpose of this policy is to ensure transparency and accountability to all stakeholders in relation to complaints regarding WHI and its operations. It seeks to make clear the mechanisms available for making complaints and the way in which complaints will be handled and resolved.

WHI acknowledges the value of feedback as an important tool in understanding and responding to stakeholder’s expectations. We therefore welcome feedback and will respond constructively and in a timely manner to complaints.

Complaints may come from our supporters, donors, the general public, beneficiaries, official bodies and our partners. This policy deals only with external complaints and does not cover internal issues and/or complaints by staff, interns or volunteers. These are dealt with in accordance with the WHI Grievance Policy.

The Whistle blower Policy can be used by either internal or external complainants, where the issue is considered to be of a serious nature. This policy can be found on the WHI website.

WHI is committed to the following principles in relation to complaint’s handling:

• Confidentiality: WHI is committed to ensuring that all information related to complaints and their resolution will remain confidential. The privacy of individuals will be maintained and personal information will not be divulged.

• Accessibility: complaints procedures should be easily accessible and well publicised to the people we work with and other stakeholders. Information relating to the process is accessible and options exist to make a compliant to ensure no complainants are disadvantaged.

• Partners must ensure that projects overseas have local processes for dealing with complaints that articulate with those detailed in this policy, and that these processes:

o Are available in local languages
o Are provided in accessible formats (eg. a photograph of the person to raise a complaint with, display of complaint’s flow chart)
o Detail appropriate contact information for all levels of complaints (including contact information for two local partners and two WHI personnel.
o The use of the Complaint’s Pictorial Book is accessible.

• Objectivity: complaints are treated with respect in a fair and equitable manner. Conflicts of interest will be identified to ensure objectivity.

• Responsiveness: complaints are dealt with in a manner that is timely, responsive and will be taken seriously. Complainants will be kept informed on the progress of their complaint through the process.

This policy is intended as our minimum standard and to apply to any complaint, regardless of who makes it. Complaints may relate to our employees (permanent, temporary, casual, contractors and volunteers) and our in-country partners.

Complaints may be made by any community member.

Complaint: an expression of dissatisfaction about the standards of service, actions or lack of actions by WHI. It could be:

• Concern about the behaviour of staff, volunteers, Board members, suppliers, partners or others acting on WHI’s behalf,
• Criticism about a fundraising campaign or action,
• Concern over inappropriate use of funding,
• Any breach of the ACFID Code of Conduct,
• Organisational practices, policies or procedures
• Complaints about WHI’s supported programs and/or operations of partner Country Offices

A response or resolution is explicitly or implicitly expected.

Complainant: any person, organisation or its representative, making a complaint.

Complaint handling/management system: All policies, procedures, practices, staff, hardware and software used by us in the management of complaints.

Concern: does not meet the definition of a complaint: Relates to a question regarding how an organisation or its partners have provided a service, however a response is not required. A response may not be provided.

Dispute: An unresolved complaint escalated either within or outside of our organisation.

Inquiry: means a request for information or an explanation.

Feedback: opinions, comments, suggestions and expressions of interest in the products or the complaint handling process.

Grievance: A clear, formal written statement by an individual staff member about another staff member or a work-related problem.

Policy: A statement of instruction that sets out how we should fulfil our vision, mission and goals.

Outcome: The Resolution of a complaint. The resolution may or may not meet the expectations or requirements of the complainant. The outcome should be fair and just, and in line with this policy.

Remedy is action taken to correct or rectify a situation for an individual where it identified he/she has been treated poorly or unfairly by the system. Remedy may involve one or more of:

• providing explanation and reasons if not previously provided
• dismissing the complaint if the decision accords with relevant policy or procedure
• concluding that the complaint has been substantially resolved
• reaching a compromise solution
• giving an apology or providing a service not previously provided
• addressing or referring the issue for system improvement.

Retaliation: means any direct or indirect detrimental action threatened or taken against an individual. Any person who retaliates against someone who has reported misconduct will be liable for disciplinary action up to and including termination of employment.

Stakeholder or interested party: means a person or group having an interest in the performance or success of the organisation.

Systems improvement: is an opportunity to improve policies, procedures, organisational culture, or similar issues to prevent future problems. Systems improvement may involve one or more of:

• referral for consideration of policy change;
• policy development or revision;
• process improvement, such as changes to procedures and workplace practices;
• program review;
• expert assistance, staff development or performance improvement;
• improved implementation, such as issuing updated documentation or reminders;
• monitoring compliance; and
• other action to ensure that the matter is handled appropriately in future.

WHI expects staff at all levels to be committed to fair, effective and efficient complaint handling. For the full policy email request to admin@worldhope.org.au 

The consequence of not complying with the policy and procedures ranges from disciplinary action to performance management to cessation of employment or contract agreement, dependant on the seriousness of the non-compliance. 

As an Institution based on a Biblical foundation, WHI recognises that it is imperfect and from time to time errors, failures and shortcomings will occur. We also value honesty through feedback from community members. When we fail people our response is that which Jesus commands, that is to seek forgiveness. This will be done by acknowledging our errors and apologising to those who have brought these to our attention. WHI will respond as commanded by Jesus, by accepting feedback and complaints with humility (Phil 2:3).

The ‘right to redress’ is a basic Biblical truth. An important part of a complete accountability framework is the ability for community members to report or lodge a complaint about conduct that breaches WHI’s promises. This dimension of accountability enables community members to hold WHI to account for its actions or decisions by providing a process where these can be queried and a response obtained. However, this type of accountability is only as effective as WHI’s commitment to learning from the complaint and the robustness of both the process and its accessibility.

WHI seeks to have any complaint or dispute raised and received in a constructive and open manner and resolution achieved in a timely and effective way. Any complaint or dispute about an aspect of WHI’s operations or employment practices will be dealt with confidentially, effectively and with the appropriate degree of urgency. All complaints will be managed to ensure there is procedural fairness to all parties, there is no conflict of interest by either party, there is no victimisation or retaliation and confidentiality is assured throughout the process.

A person who, in good faith, reports misconduct or suspected misconduct will not suffer retaliation. Any person who retaliates against someone who has reported misconduct will be liable to disciplinary action up to and including termination of employment. Individuals who believe that retaliatory action has been taken against them because they have reported misconduct should forward all information and documentation to support their belief to the CEO or the Chair of the Board. If the retaliation involves the CEO or the Chair of the Board, the report may be made directly to the Chair of the Finance and Audit Committee complaints@worldhope.org.au.

Anyone making a complaint alleging misconduct must act in good faith and have reasonable grounds for believing the information disclosed indicates wrongdoing. Allegations which prove to have been made maliciously or knowingly to be false could result in disciplinary action.

The Complaints Policy provides an overarching framework for making and assessing all complaints, however there are complementary policies and procedures that will apply to managing the complaint depending on the nature and seriousness of the specific complaints.

All staff managing complaints are empowered to implement our complaint management system as relevant to their role and responsibilities.

We will assess each complaint on its merits and involve people making complaints and/or their representative in the process as far as possible.

Staff are encouraged to provide feedback on the effectiveness and efficiency of all aspects of our complaint management system.

These guidelines provide information for managing all complaints and include how to make a complaint and how to respond to a complaint.

Any person can make a complaint, including staff, community members, partners, beneficiaries and stakeholders of WHI.

At WHI we welcome feedback from our stakeholders, and we take complaints very seriously. All stakeholders should be clear on how to raise a complaint with the organisation.

Complaints may be received in the following formats:

• Telephone
• Letter
• Facsimile
• Email
• In person
• Any format deemed culturally appropriate within an in-country partner’s context.

Once a complaint is received, no matter the nature or relevance of the complaint, all reasonable steps will be taken to ensure the gathering of all necessary information for the ultimate resolution of the complaint.

WHI’s Complaints Policy and Form are published on our website (www.worldhope.org.au) and highlights the following central points for all complaints:

• To make a verbal complaint contact our Supporter Relations Team on (07) 3624 9977
• Written complaints can be sent to the e-mail address: complaints@worldhope.org.au or alternatively send to our address at 519 Mt Petrie Road Mackenzie Qld 4156 Australia
• Complaints regarding suspected breaches of the ACFID Code of Conduct can be made to the ACFID Code of Conduct Committee. Information on how to make a complaint can be found on the ACFID website: https://acfid.asn.au/content/complaints

To ensure no disadvantages or barriers to making a complaint, where necessary, language interpreters may be required to help establish the nature of the complaint.

When we take an oral complaint we will:

• Identify ourselves, listen, record details on our Complaint’s Form, and determine what the client wants;
• Confirm that we have understood and received the details;
• Show empathy for the complainant, but not attempt to take sides, lay blame, or become defensive;

For all complaints we will:

• Seek from the complainant the outcome/s they are expecting;
• Consider whether the complainant needs assistance in making the complaint; and
• We will assure the complainant that the complaint will receive our full attention without creating false expectations.

To ensure no disadvantages or barriers to making a complaint, where necessary, language interpreters may be required to help establish the nature of the complaint.

When a complaint is received, an assessment must be made about the appropriate course of action:

1. The staff member will determine if no action is required as there is no real basis for the complaint. The reasoning will be communicated clearly to the person making the complaint; or

2. If the complaint is about a service, procedure or system, Remedy & Systems Improvement will apply; or

3. If the complaint is about a person but is less serious, Informal Resolution will apply; or

4. If the complaint is serious then the Discipline Policy will apply; or

5. If the complaint is about fraud the Anti Fraud Policy will apply; or

6. If the complaint is between staff then the Grievance Policy will apply; or

7. If the complaint relates to conduct with children then the Child Protection Policy will apply; or

8. If the complaint alleges what could be criminal conduct then the matter will be referred to the Police following consultation with the CEO or Chair of the Board.

A matter is considered less serious if it involves a minor breach or complaint and is not seen to be part of a pattern of conduct that would lead to disciplinary/remedial action. A serious breach is one which, if proven, could amount to serious misconduct and could include:

• a breach of policy, procedure or contract likely to lead to disciplinary/remedial action, or
• conduct of a criminal nature.

We will address each complaint with integrity and in an equitable, objective and unbiased manner.

We will ensure that the person handling a complaint is different from any staff member whose conduct or service is being complained about.

Conflicts of interest, whether actual or perceived, will be managed responsibly. In particular, internal reviews of how a complaint was managed will be conducted by a person other than the original decision maker.

We will make every reasonable effort to investigate all the relevant circumstances and information surrounding a complaint. The level of investigation will be commensurate with the seriousness and frequency of the complaint.

We will acknowledge written complaints within 5 days.

We will acknowledge oral complaints immediately.

We will aim to resolve complaints as quickly as possible and within 30 days unless there are exceptional circumstances. If a complaint is not resolved within 30 days we will inform the complainant of progress and keep them informed of progress every two weeks.

Once the complaint has been resolved, the complainant will be advised of the outcome as soon as is practical ensuring the privacy of any individual involved in the matter.

Our communication will be in writing in the appropriate language by email and/or post. However, where appropriate such as in the case of a complaint being made by a local community member (in the field) we will also communicate our decision orally and again in the appropriate language.

We will encourage the complainant to respond and advise whether or not they are satisfied with our decision. In our decision we will advise that if a complainant is not satisfied we will be prepared to consider any additional information they may provide and to review our decision.

In all cases we will advise that the complaint may be referred to the Code Committee of ACFID. We will provide all necessary information for referral to the Code Committee and offer to assist in referral.

At times, remedy and systems improvement may arise out of complaints dealt with under either Informal or Formal Resolution. This procedure will be initiated by the relevant staff member or CEO using the following steps. It also applies to suggestions.
1. Assess if remedy and/or systems improvement is warranted or no action is required.
2. Implement immediate remedy/system improvement or plan future implementation of remedy/system improvement.
3. Inform complainant of outcome

Informal resolution
Informal resolution can be used for any matter that is assessed as ‘less serious’, such as minor complaints and differences of opinion. The CEO has specific responsibilities for managing the resolution of such matters. However for informal resolution to succeed, both parties need to recognise that there is a problem, be prepared to be conciliatory and accept that resolution may require compromise on both sides. Policy 1.01.6 clarifies the standards of behaviour that are expected of staff members in the performance of their duties. The following procedure is a framework for negotiation which can be used as a form of informal resolution. It is suggested is that the parties be provided the opportunity to:

• State the cause of their concern.
• Exchange facts and beliefs.
• Clarify events.
• Listen.
• Apologise for any behaviour that may have distressed the other party.
• Explain their point of view.
• Consider the other person’s point of view.
• Recognise this is an opportunity to change behaviour that is perceived as unsuitable or hurtful to another.

When negotiation is used, then confidential notes of the agreed outcomes should be kept.

A pictorial Complaints Policy and Procedure is available for any person who has learning difficulties, cognitive difficulties or when their first language is not English. Email complaints@worldhope.org.au for this document.

All complaints dealt with, whether verbal or written are initially recorded on our Complaint’s Form, then recorded on the Complaints Record log. We will ensure the following information is contained:

• Date of receipt.
• A description of the complaint and relevant supporting data.
• The requested remedy.
• The service(s) and/or good(s) and/or practice or procedure complained about.
• The due date for a response, and
• Immediate action taken (if any) to resolve the complaint.

These records will be used to ensure complaints are dealt with effectively, to monitor trends and to ensure continuous improvement of the complaints handling process and our work.

All complaints will be reported at WHI’s board meetings.

WHI’s partners will report on complaints or feedback they have received on a quarterly basis. Serious Complaints must be notified immediately to WHI’s CEO or Chair of the Board.

We will not reveal a complainant’s name or personal details to anyone in or outside our organisation other than staff involved in handling the complaint without obtaining the complainant’s permission.

If the complainant is unhappy about the responses received from WHI or if they believe action has not being implemented they may appeal to CEO or Chair of the Board. If the complaint involves the CEO, it should be referred to the Chair of the Board. If the complaint involves the Chair of the Board, it should be referred to the CEO.

If a complainant believes WHI has breached the ACFID Code of Conduct and has not satisfactorily resolved his/her complaint, the complainant can report the complaint to ACFID:

Australian Council for International Development (ACFID)
Website: http://www.acfid.asn.au/code-of-conduct
Telephone: Code Management Team + 61 2 6281 9222.

This Policy applies to all WHI staff, volunteers, partners & contractors.

Cash

Under no circumstances is cash personally acceptable as a gift – all cash received must be banked as a donation to WHI and the giver informed of this.

Token Gifts

These are acceptable as personal tokens of appreciation provided there is no inducement to act more favourably in the giver’s interests in the future.

Supplier Prizes/Gifts

These are deemed to be inducements, cannot be accepted by an individual and must be treated as a donation to WHI.

> $100 value

Politely decline the gift or benefit explaining that it is not permitted under our Gifts & Benefits Policy

>$25 value

Notify your supervisor and register the gift or benefit in the Gifts & Benefits Register by sending an email to admin@worldhope.org.au stating:

1. Date gift given
2. Gift recipient’s name
3. Description of gift
4. Gift giver’s name
5. Name of supervisor informed about the gift

Multiple Gifts & Benefits

Where multiple gifts under $25 in value are provided within a year from the same source the values are too aggregated and treated as one gift for the purposes of this Policy.

Promotional gifts

Promotional products can be distributed fairly and transparently amongst staff, volunteers & contractors and are not required to be included in the Gift & Benefits Register.

Conference Draw/Prizes

These may be kept by the individual or treat it in the manner of a gift > $100.

Other than CASH as described above, an exception to this policy may be granted by written approval from the CEO. A ‘blanket’ approval cannot be granted. All such exceptions must be documented and recorded in the Gifts and Benefits Register.

Board members will declare any conflicts of interest either at the start of the board meeting concerned or when a relevant issue arises. The nature of this conflict of interest should be entered into the meeting minutes. The interest should also be documented in board minutes or a conflict of interest register.

A board member who believes another board member has an undeclared conflict of interest should specify in writing the basis of this potential conflict.

Where a conflict of interest or potential conflict of interest, as defined below, is identified and/or registered, the board member concerned will leave the room as soon as that item comes up for discussion. The concerned board member will not vote on that issue, nor initiate or take part in any board discussion on that topic (either in the meeting or with other board members before or after the board meetings) unless expressly invited to do so by unanimous agreement by all other members present. The board may supplement the statutory definition of conflict of interest if it so wishes, in which case the same procedures will apply.

If a person declares themselves to have an existing or potential conflict of interest, confidentiality will be respected. If a person alleges that another person has a conflict of interest, whether existing or potential, and that person does not agree, and if the board cannot resolve this allegation to the satisfaction of both parties, the matter will be referred to an ethics subcommittee. This committee will make a recommendation to the board as to what action will be taken.

A conflict of interest is defined in response to a particular law or statute, or where a board member stands to gain financially from any business dealings, programs or services of the organisation, other than where

• the board member falls into the class of people benefited by the organisation and the financial gain is of a nature common to other beneficiaries, or
• the person is an employee of the organisation, and the financial gain is of a nature common to other employees.

All WHI personnel and partners have the responsibility to protect children from all forms of physical and mental violence, injury or abuse, neglect, maltreatment or exploitation, including sexual abuse. We are committed to ensuring that all possible and necessary steps are taken to realise the rights of children and to actively safeguard all children that we work with both in Australia and overseas from harm.

To create a safe environment for children who participate in and benefit from WHI and its implementing partners’ programs.

This policy applies to all WHI activities whether in Australia or overseas. As such it applies to all WHI representatives: full-time, part-time and casual board members; employees and volunteers; contractors and consultants irrespective of which country the project is situated in; implementing partner organisations; project participants; and WHI supporters. As part of WHI’s organisational continuous improvement process, this policy will be reviewed every three years.

Children and young people make up a third of the world’s population, but being present in large numbers does not guarantee their safety. WHI’s vision of a world where poverty has ended and all people enjoy the fullness of life God intends cannot be realised until all children experience the freedom of living in a world where abuse and exploitation are absent. WHI affirms the principles proclaimed in the Convention on the Rights of the Child, which has a vision of ending all forms of violence against children. Article 19 states:

State parties will … protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse …

(UN Convention on the Rights of the Child, 1989, Article 19)

Furthermore, WHI acknowledges that each year natural and human-caused disasters affect an estimated 231 million people worldwide. During an emergency, the rights, safety, and well-being of children, and girls especially, are at risk of being seriously compromised. Effective protection of disaster-affected populations is of central concern to WHI. Therefore emergency response projects follow international codes to protect children at risk.

Children and young people are particularly vulnerable and require protection from the effects of poverty, abuse, homelessness and neglect; from unequal access to essential services; and from justice systems that do not recognise their special needs. As well as these generalised forms of abuse, children are in danger of specific forms of abuse from adults or other children, including physical, emotional and sexual abuse, and neglect. This policy aims to address and prevent these specific forms of abuse against children who are in contact with WHI representatives.

All people—including children— have been created in God’s image and are equally loved by God. WHI understands development as the process by which people are able to realise right relationships with God, with one another and with the earth, all of which witness to the reality of God’s Kingdom breaking through to the here and now. This will mean all people, and especially children, will live in households where they feel safe and loved; where they have the opportunity to learn, grow and mature; where they experience intimate, loving interpersonal relationships; and, where there is adequate provision for their most important needs. It also means people living in communities where they are physically and emotionally safe; where they feel welcomed, valued and loved; and where social structures ensure justice, equity, and opportunity to participate in social life and decision making.

The discrimination and the exclusion frequently experienced by children means they often fail to experience this security. Wherever this occurs, we should be working towards the restoration of the patterns of right relationships that God intends, affirming children’s dignity and, due to their particular vulnerabilities, the special need to respect and protect them. In the gospel narratives, we see Jesus modelling this; he consistently acted to affirm the value of children and their unique strengths that others can learn from. He recognised the vulnerability of children and the duty of adults to protect them.

These fundamental implications of the gospel frame WHI’s approach to child rights and building a child protection environment in all spheres of influence.

WHI acknowledges that a human rights approach to child protection nurtures the dignity of children. We reject the notion that children are of intrinsically lower status than adults, and a legitimate receptacle for adult rage. Protecting children from all forms of abuse is a human rights imperative. WHI affirms the principles set forth in the document Setting the Standard: A Common Approach to Child Protection for International NGOs. (This document was produced by an international consortium including Christian Aid, NSPCC, Save the Children, People in Aid, EveryChild and TEAR Fund, and is based on the UN Convention on the Rights of the Child.) The principles include the following:

• All children have equal rights to protection from abuse and exploitation.
• All children should be encouraged to fulfill their potential and inequalities should be challenged.
• Everyone has a responsibility to support the care and protection of children.
• NGOs have a duty of care to children with whom they work and with whom their representatives work.
• If agencies work through partners they have a responsibility to meet minimum standards of protection for the children in their partners’ programs.

WHI is committed to contributing to an environment where children are respected and where they are encouraged to discuss their concerns and rights. Therefore, it is paramount that the responsibilities of WHI representatives are clear.

It is the responsibility of the board and CEO to ensure that all WHI representatives in their area of responsibility are aware of, sign on to, and agree (where required) to abide by the policy and applicable procedures. Ultimately, a child protection officer and a child protection committee will support the implementation of this policy.

WHI representatives are required to do the following:

• sign on to, and agree to abide by the WHI child protection policy
• sign on to the WHI child protection code of conduct (found at the end of this policy)
• respond to concerns or allegations of child abuse or exploitation in accordance with WHI policy and procedures
• cooperate fully and confidentially in any investigation of concerns or allegations

Implementing partners are required to do the following:

• adhere to WHI’s child protection policy & code of conduct.
• respond to concerns or allegations of abuse in accordance with their organisation’s child protection policy
  follow WHI’s complaints handling procedure when
• reporting any concerns or allegations of child abuse or exploitation

These are mandatory requirements and failure to fulfill them may result in cessation of the partnership

No policy can ensure that children participating in development programs will not be abused. Therefore it is crucial that preventative measures are in place such as ensuring that risk management processes, behavioural guidelines, training and education, and child protection recruitment practices are developed and implemented.

Duty of Care
WHI takes its duty of care very seriously and is committed to the safety and best interests of all children who access our services and programs or are involved in campaigns, voluntary support, fundraising, work experience or employment. In particular, WHI is committed to minimising the risk of abuse.

Risk Management

WHI recognises there are potential risks to children in programs funded by WHI, and therefore manages these risks by undertaking the following preventative measures:

• identifying activities that constitute ‘working with children’ and supporting implementing partners to develop a child protection policy; as a minimum, implementing partners will be expected to develop a child protection code of conduct
• proactively assessing and managing risks to children in programs we support, by reviewing the project design during the proposal assessment process and conducting regular checks throughout the project cycle
• proactively assessing and managing risks to children in internal systems and procedures
• implementing new preventative measures when gaps are identified
  

Child Protection Code of Conduct
In order to protect children WHI has a child protection code of conduct. WHI employees, board members, volunteers, contractors, and consultants will sign on to and agree to abide by the child protection code of conduct. All WHI personnel who come into contact with children will comply with all legal obligations including mandatory police checks where available.

Department Foreign Affairs & Trade Definition:

Child Protection – An activity or initiative designed to protect children from any form of harm, particularly that arising from child exploitation and abuse

Child Safeguarding – The broad obligation on staff and partners to ensure that the design and delivery of DFAT programs and organisational operations do not expose children to adverse impacts, including the risk of abuse and exploitation, and that any concerns about children’s safety within the communities where they work are appropriately reported

Contact with children – Working on an activity or in a position that involves or may involve contact with children, either under the position description or due to the nature of the work environment (also see Working with children definition)

Use of Visual Images and Personal Information

WHI personnel and Delivery Partners will ensure that permission is obtained from relevant parents and guardians before making or using images (including photographs and videos) and personal information of children who are engaged in the activities of WHI or its partners. The form of permission should clearly indicate the intended use of the images.

In Australia

WHI is committed to maintaining the confidentiality of the personal information of children and to portraying children and local people in a positive manner in all our promotional materials. WHI will at all times portray children in a dignified and respectful manner and not as vulnerable or submissive. Photographs, films of children and website publications will respect and be in the best interests of the child.

Implementing Partners

Delivery Partners are committed to maintaining confidentiality of the personal information of children and to portraying children and local people in a positive manner in all our promotional materials. Delivery Partners will at all times portray children in a dignified and respectful manner and not as vulnerable or submissive. Photographs, films of children and website publications will respect and be in the best interests of the child.

Refer to Privacy Policy

Training

In Australia

All employees, board members, volunteers and contractors will be trained so that they understand why it is necessary to protect children. As a part of the induction process all WHI personnel will be informed of WHI child protection policy and procedures. Job-specific child protection training is available and can be arranged by the relevant departmental director. The child protection officer and child protection committee are to ensure that training for all staff is ongoing and relevant.

Implementing Partners

To ensure that children are protected, and employees and volunteers understand the importance of putting a child protection mechanism into place, it is required that implementing partners conduct regular training with employees and volunteers.

Recruitment

In Australia

WHI follows strict guidelines in the recruiting of its representatives, including behavioural interviewing questions, pre-interview screening and written and verbal reference checks, working with children checks, as well as a national police check. These are reviewed and updated regularly to ensure that they accurately reflect current child protection recruitment practices. WHI recruitment guidelines are outlined in Policy no. 7.02 Recruitment.

Implementing Partners

Implementing Partners must follow strict guidelines in the recruiting of its personnel, including behavioural interviewing questions, pre-interview screening and written and verbal reference checks, working with children checks, as well as a national police check. These are reviewed and updated regularly to ensure that they accurately reflect current child protection recruitment practices. WHI recruitment guidelines are outlined in Policy no. 7.02 Recruitment.

WHI recruitment guidelines are outlined in Policy No. 7.02 Recruitment.

Supporter Engagement in International Programs

WHI recognises the need to implement specific guidelines to manage the child protection risks when allowing supporters to engage with international programs. WHI proactively manages these risks by undertaking the following preventative measures:

• Supporter visits must have a clear National Police Check and a Working with a Children Check pass.
• All visits are organised and chaperoned by WHI staff.
• Protocols manage how photos and video recordings of sponsored children are used and letters are opened and vetted.
• conducting briefing meetings to provide supporters with an overview of the child protection policy
• ensuring all supporters participating in field visits sign on to the child protection policy code of conduct
• advising the implementing partner in the event the supporter visit is cancelled due to a supporter not providing a national police check, or if a check contains information that would disqualify the supporter from visiting the program

The development, implementation, and monitoring of a complaints handling system are vital in protecting children and ensuring that their best interests are central to the decision making process regarding concerns or allegations of abuse or exploitation. It is essential that WHI has clear and transparent procedures in place to ensure those project participants, implementing partners, staff and other stakeholders can report concerns or allegations of child abuse and/or inappropriate behaviour.

Reporting

It is mandatory for WHI personnel, member, volunteer, contractor and partner to report immediately concerns or allegations of child abuse that relate to a child to the appropriate child protection service or the police.  Their Supervisor and CEO or WHI Chairperson should also be advised about their concern. 

In situations where the supervisor or WHI CEO is suspected of involvement in the activity, or if the person having the suspicion does not believe that the matter is being appropriately addressed or dealt with, the matter should be reported to the next highest level of supervision.

Supervisors must report complaints of suspected abusive behaviour or misconduct to the CEO or WHI Chairperson, and also to any external regulatory body such as the police. 

WHI will keep all complaints documentation (whether electronic or hard copy) confidential and secure.

Investigating

If the appropriate child protection service or the police decide to investigate a report, all employees, contractors, volunteers or partners must co-operate fully with the investigation.  

Whether or not the authorities decide to conduct an investigation, the CEO will consult with the authorities to determine whether an internal investigation is appropriate. If it is decided that such an investigation will not conflict with any proceeding of the authorities, the CEO may decide to conduct such an investigation.  All employees, contractors, volunteers and partners must co-operate fully with the investigation.

Any such investigation will be conducted according to the rules of natural justice.

The CEO will make every effort to keep any such investigation confidential; however, from time to time other members of staff may need to be consulted in conjunction with the investigation.

After an initial review and a determination that the suspected abuse warrants additional investigation, the CEO shall coordinate the investigation with the appropriate investigators and/or law enforcement officials. Internal or external legal representatives will be involved in the process, as deemed appropriate.

Please refer to Policy no. 4.04.5 Responding to complaints.

Responding

If it is alleged that a member of staff, contractor, volunteer or partner may have committed an offence or have breached WHI’s policies or its Code of Conduct the person concerned may be stood down (with pay, where applicable) while an investigation is conducted. 

If the investigation concludes that on the balance of probabilities an offence (or a breach of WHI’s policies or Code of Conduct) has occurred then disciplinary action may follow, up to and including dismissal or cessation of involvement with WHI. The findings of the investigation will also be reported to any external body as required.

Privacy

All personal information considered or recorded will respect the privacy of the individuals involved unless there is a risk to someone’s safety. WHI will have safeguards and practices in place to ensure any personal information is protected.

Everyone is entitled to know how the personal information is recorded, what will be done with it, and who will be able to access it.

In Australia

Child abuse is a difficult and emotional subject for the child victim and for the staff dealing with the issue. WHI will support staff who disclose abuse, refer concerns or are involved when an incident has happened through our employee assistance program.

Implementing Partners

WHI encourages implementing partners to develop and implement support systems to ensure that staff who have disclosed abuse, referred concerns or are involved when an incident occurred, are referred to an organisation that can offer the required counselling or treatment. Where possible, WHI will provide support and guidance through the support process.

Related Documents

The following documents are relevant resources to guide WHI policy:

• Convention on the Rights of the Child: adopted and opened for signature, ratification, and accession by UN General Assembly resolution 44/25 of November 1989 (available at http://www2.ohchr.org/english/law/crc.htm)
• Setting the Standard: A Common Approach to Child Protection for International NGOs (Tearfund UK)
• The Code of Conduct for the International Red Cross and Red Crescent Movement and NGOs in Disaster Relief (drawn up the Steering Committee for Humanitarian Response in 1992) 

Definitions

Child: A person under the age of 18 years. This is the UN definition of a child.

Physical injury: May involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child including fabricating the symptoms of, or deliberately causing, ill health to a child.

Neglect: The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development, such as failing to provide adequate food, shelter, and clothing, or neglect of, or unresponsiveness to, a child’s basic emotional needs.

Emotional abuse: Persistent or emotional ill-treatment of a child that adversely affects their development. May involve conveying to a child that they are worthless, unloved, and inadequate, there only to meet the needs of another; or where inappropriate expectations are imposed upon them. In addition, it includes children who are regularly frightened, exploited or corrupted.

Sexual abuse: Involves forcing or enticing a child to take part in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative or non-penetrative acts. This may also include involving children in looking at, or in the production of, pornographic material, or encouraging children to behave in sexually inappropriate ways.

Personnel: Personnel of or connected to WHI including employees, volunteers, office bearers, board and committee members, contractors and, where practical, comparable personnel of our implementing partners.

WHI personnel have a responsibility to take reasonable steps to ensure the safety and welfare of the children in our care, and in particular, will comply with the following:

• not abuse children
• not administer corporal punishment to children
• not make available to children any prohibited material
• not knowingly allow a person who is currently charged with or convicted of an offence against a child to participate in WHI activities involving children
• report in writing to their immediate superior and to the CEO if they know or reasonably suspect that a child is at risk of harm from child abuse

WHI will seek to ensure the implementation of child protection by ensuring the following:

• in all contracts involving WHI, all parties agree to abide by the requirements of this policy
• child protection risks are included in all project and activity risk assessments
• preventative child protection measures are implemented to the highest standard
• comprehensive child protection recruitment and screening processes are employed
• child protection training is regularly provided to relevant WHI employees and representatives
• culturally specific issues relevant to child protection will be incorporated into project specific risk management strategies, training and response procedures
• a child protection code of conduct exists and is understood and signed, wherever applicable, by all WHI employees and representatives that are bound by it
• clear and current reporting procedures exist and are known by WHI employees, volunteers and representatives
• national laws and processes and local resources are taken into account within reporting and response mechanisms
• a documented child protection management procedure exists and is operational
• a documented policy compliance regime exists which outlines sanctions for breaches
• no person is permitted to work with children if they pose an unacceptable risk to children’s safety or wellbeing
• all employment contracts involving WHI outline that WHI has the right to dismiss or transfer to other duties personnel who breach the child protection code of conduct
• the highest levels of confidentiality and sensitivity are employed pending an official investigation of an incident
• If it is alleged that a member of staff, contractor, delivery partner or a volunteer may have committed an offence or have breached the organisation’s policies or its Code of Conduct the person concerned may be stood down (with pay, where applicable) while an investigation is conducted. 
• If the investigation concludes that on the balance of probabilities an offence (or a breach of the organisation’s policies or Code of Conduct) has occurred then disciplinary action may follow, up to and including dismissal or cessation of involvement with the organisation. The findings of the investigation will also be reported to any external body as required.

WHI’s child protection policy has been developed to provide a practical guide to prevent child abuse in WHI’s funded activities. It outlines a range of risk management strategies that will be implemented which will reduce the risk of children being harmed.

The policy demonstrates our commitment to protect children from harm and abuse. It aims to create an open and aware environment where concerns for the safety and well-being of a child can be raised and managed in a fair and just manner, which protects the rights of all.

Additionally, the policy will provide guidance on how to respond to concerns and allegations of child abuse. It provides guidance to staff and others on how to work respectfully and effectively with children. This will provide all stakeholders, including staff and others with a safe working environment.

This obligation will be extended to all of WHI operations and activities. WHI is also bound by the policies on child protection and safe ministry promulgated by the WMCA.

WHI is also obliged to adhere to local and international child protection criminal laws, which prohibit the abuse and exploitation of children. These include local laws where our programs exist, and international laws and conventions in relation to all forms of child abuse and child exploitation, including child sex tourism, child sex trafficking, child labour, and child pornography.

I,  . . . . . . . . . . . . . . . . . . . . . . . . . . . acknowledge that I have read and understood WHI’s child safety policy, and agree that in the course of my association with WHI, I will comply with the following:

• Be understanding about the importance of submitting to our screening requirements (such as criminal record checks).
• treat children with respect and dignity in accordance with our Core Values regardless of race, colour, gender, language, religion, political or other opinions, national, ethnic or social origin, property, disability, birth or another status.
• not use language or behaviour towards children that are inappropriate, harassing, abusive, sexually provocative, demeaning or culturally, respecting their privacy and keeping information about them confidential.
• Do not shame, humiliate, oppress, belittle or degrade children or young people.
• Do no Unlawfully discriminate against any child.
• Do not initiate unnecessary physical contact with a child, or do things of a personal nature for them that they can do for themselves.
• Do not develop a “special” relationship with a specific child for their own needs.
• Do not show favouritism through the provision of gifts or inappropriate attention.
• Do not arrange contact, including online contact with children outside of WHI’s program and activities.
• Do not work with children while under the influence of alcohol or illegal drugs.
• Listen to children, be sensitive to the signals they send you about how comfortable they are with you (their language, conversation, and physical intimacy) and respond accordingly.
• Stop any interaction with a child if a child says stop or if the child appears uncomfortable with the interaction.
• Always ask permission from a child and the child’s parents or carer (as appropriate) if you wish to take photos or videos, making sure you explain carefully how you will use them (your use of images must be expressly agreed with WHI, especially considering risks of displaying images online). 
• The use of any computers, mobile phones, video cameras, cameras or social media must never exploit or harass children or access child exploitation material through any medium.  Such images must be expressly agreed with WHI.
• Be culturally appropriate in how you speak act and dress.
• Not become involved sexually with a child whether by direct contact, exposing them to sexual materials or other non-contact sexual activity (grooming), including paying for sexual services or acts.  In many countries including Australia, such conduct can be a serious offence, often punishable by imprisonment.,
• Always ensure that another adult is present or in view when working in the proximity of children. That is, don’t be along with a child unless it is unavailable or the child is in immediate danger.  This is for the child’s protection and to protect you from possible false accusation. Where you are visiting (or working as a contractor) a WHI project, you must be accompanied by a designated WHI staff member at all times.
• Not hit or abuse any child. WHI does not support corporal punishment but recommends alternative methods of discipline. Abuse can happen through your physical actions, words or emotional messages you send.
• not invite unaccompanied children into my home, unless they are at immediate risk of injury or in physical danger
• not sleep close to unsupervised children unless absolutely necessary, in which case I will obtain my supervisor’s permission, and ensure that another adult is present
• not hire children for domestic or other labour which is inappropriate given their age or developmental stage, which interferes with their time available for education and recreational activities, or which places them at significant risk of injury. Children have a right to education and play.
• make myself familiar with the WHI child protection policy and comply with all relevant Australian and local legislation, including labour laws in relation to child labour
• immediately report concerns or allegations of child exploitation and abuse and policy non-compliance in accordance with appropriate procedures
• immediately disclose all charges, convictions and other outcomes of an offence, which occurred before or occurs during my association with WHI that relate to child exploitation and abuse

When photographing or filming a child or using children’s images for work-related purposes, I will:

• assess and endeavour to comply with local traditions or restrictions for reproducing on images before photographing or filming a child
• obtain informed consent from the child and parent or guardian of the child before photographing or filming a child and I will explain how the photograph or film will be used
• ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner and that children are adequately clothed and not in poses that could be seen as sexually suggestive
• ensure images are honest representations of the context and the facts
• ensure file labels, metadata or text descriptions do not reveal identifying information about a child when sending images electronically or publishing images in any form
• Do not do anything in contravention of WHI’s policies, procedures or this Code of Conduct. 

Remember

You are always responsible for your behaviour towards a child, even when the child’s behaviour can be interpreted as inappropriate (eg. seductive behaviour).

You must comply with all applicable local, national and international laws about child protection.

You must immediately report any suspicions of inappropriate behaviour to your WHI contact.

There are processes for investing accusations which respect all involved.

Non-compliance with this Code of Conduct will be taken very seriously.  In the case of employees, it may be grounds for termination of employment.  Where considered necessary or appropriate, non-compliance will be reported to relevant authorities.

I understand that the onus is on me, as a person associated with WHI, to use common sense and avoid actions or behaviours that could be construed as child exploitation and abuse.

Signature:                                                                                Date:

This policy addresses our ACNC compliance obligations when communicating with or soliciting donations from private donors and the public, including fundraising for designated and undesignated purposes from sponsors and supporters, as well as fundraising from the general public.

This policy is intended to apply to all our activities—our personnel, our partners and our in-country implementing churches and agencies.

WHI is a faith-based agency whose philosophy of development is derived from a biblical and theological response to the source of injustice and poverty in the world today. Development is understood as a process of transformation that leads to improvement in the whole of human life—materially, socially and spiritually. WHI is committed to ensure that funds and other resources designated for the purpose of aid and development will be used only for those purposes and will not be used to promote any particular religious or denominational adherence, or to support a political party, or to promote a candidate or organisation affiliated to a political party.

WHI understands aid and development activities as being those undertaken in order to reduce poverty and address global justice issues via direct engagement through community projects, emergency management, community education, advocacy, volunteer-sending, provision of technical and professional services and resources, environmental protection and restoration, and promotion and protection of human rights.

WHI is therefore committed to ensuring that funds and other resources designated for the purpose of aid and development are used only for those purposes. The concept of aid and development activities can be distinguished by the following principles:

• strengths-based approaches which encourage people and communities to create solutions for themselves
• processes that seek to address the causes of poverty
• processes that seek to empower rights holders to claim their rights and ensure that duty bearers exercise their duties
• supporting systems and structures which enable people to move out of poverty
• emergency relief, disaster recovery and meeting the immediate needs of refugees and internally displaced people

WHI take a holistic approach to development and this includes support for the spiritual aspects of human transformation. For the purposes of making a distinction between aid and development and non-aid and development activities as required by the ACFID Code of Conduct, any activity whose objectives include the promotion of religious adherence will be considered as a non-aid and development activity and will be managed and accounted for separately.

WHIdoes not provide support for partisan political activities which are those that are associated with facilitating or supporting specific political individuals to gain power.

Implementation of this policy will be evidenced by the following:

• WHI will appraise all project proposals to determine whether they include non-aid and development components.
• WHI will record any issues, which will then be followed up to ensure that the policy requirements are satisfied before the project is approved.
• WHI will record any aspects of the project that should be closely monitored over the life of the project to ensure compliance with this policy
• WHI will identify whether our partner is engaged in non-development activities, and if so, how it is able to manage and account for them separately to aid and development activity. (This factor will be especially relevant where the implementing partner is an in-country church or church-related NGO.)

This policy provides a framework for WHI compliance with principle B.1.5 of the ACFID Code of Conduct. This principle outlines four obligations for signatories to the ACFID Code of Conduct:

1. Signatory organisations will have a clear separation between aid and development and non-aid and development objectives and activities based on the definitions of aid and development and non-aid and development in section F (Definitions) of the Code.
2. This separation will be clear in all fundraising, programs and other activities, in public communications and in all reporting including annual reports.
3. Any fundraising solicitations that include references to both aid and development and non-development activities will provide donors with the choice of contributing to aid and development activity only.
4. Signatory organisations will ensure that any such separation in fundraising, programs and other activities, in public communications and in reporting, extends to partner and implementing organisations and is documented.

WHI supports and is committed to abiding by the following principles:

• to ensure accurate representation of our activities to the people we work with, donors and the public
• to ensure that funds raised for aid and development purposes are not used to exploit people and communities who are vulnerable and do not place any conditions or obligations on recipients in terms of non-development, religious or political outcomes that would affect their access to services being offered
• Where there are components of partner programs which involve evangelical or partisan political activities, these will be promoted and accounted for separately.

WHI ensures that we and our partners can differentiate between development and non-development activity and communicate this appropriately to stakeholders, donors and the public.

The in-country partner agency agreement, Memorandum of Understanding (MoU) or equivalent will include clear definitions of aid and development activity and non-development activity and will require the partner to agree that WHI funds designated for aid and development purposes will not be used to fund any non-development activity.

WHI will review this policy on a regular basis and at least every two years.