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Accountability and conduct

Complaints Policy and Procedure

Al-Waris Foundation is committed to providing a high-quality, fair, transparent and accessible service.

Current version 2.0

1. Policy Statement

Al-Waris Foundation is committed to providing a high-quality, fair, transparent and accessible service.

We recognise that sometimes things may go wrong.

Complaints are an important source of feedback and may help the charity:

  • correct mistakes;
  • improve services;
  • strengthen governance;
  • identify safeguarding concerns;
  • identify misconduct;
  • improve communications;
  • learn from recurring problems.

Al-Waris Foundation will treat complaints seriously, fairly and respectfully.

No person will be treated adversely merely because they have raised a genuine complaint.

2. Purpose

This policy explains:

  • what constitutes a complaint;
  • how complaints can be made;
  • how complaints will be recorded;
  • how complaints will be investigated;
  • expected response times;
  • how reviews and escalation work;
  • how confidentiality will be maintained;
  • when another policy or external authority should be used instead.

3. Scope

This policy may apply to complaints concerning:

  • Al-Waris Foundation services;
  • fundraising;
  • project administration;
  • communications;
  • website services;
  • donor support;
  • volunteer activity;
  • conduct of trustees, staff or volunteers;
  • contractors or representatives acting for the charity;
  • failure to provide an expected service;
  • delays;
  • administrative mistakes;
  • accessibility;
  • treatment by the charity;
  • other actions or omissions connected with Al-Waris Foundation.

4. What Is a Complaint?

A complaint is an expression of dissatisfaction about:

  • a service;
  • action;
  • decision;
  • conduct;
  • omission;

where the complainant expects the charity to respond or take action.

A person does not need to use the word "complaint" for their concern to be treated as one.

5. Informal Feedback

Not every criticism or concern requires the formal complaints process.

Where appropriate, a simple issue may be resolved through:

  • clarification;
  • correction;
  • apology;
  • providing information;
  • completing an outstanding action.

If the person remains dissatisfied or the matter is significant, it should be recorded and handled formally.

6. Matters That May Require a Different Procedure

Some concerns should not be dealt with solely as ordinary complaints.

These include:

Safeguarding

Concerns that a child or adult may be at risk of harm must be handled under the relevant safeguarding policy.

Whistleblowing

Serious wrongdoing raised by someone connected with the charity may fall under the Whistleblowing Policy.

Data Protection

Privacy complaints or data-rights requests may require action under the Data Protection and UK GDPR Policy.

Fraud or Financial Misconduct

Suspected fraud, theft, bribery, corruption or financial abuse should be dealt with under the relevant financial and anti-fraud procedures.

Serious Incidents

A complaint revealing a serious incident may require Charity Commission consideration.

Using another procedure does not necessarily prevent the concern from also being recorded as a complaint where appropriate.

7. Who Can Make a Complaint?

Complaints may be made by:

  • beneficiaries;
  • donors;
  • supporters;
  • volunteers;
  • prospective volunteers;
  • members of the public;
  • contractors;
  • partner organisations;
  • parents or carers;
  • representatives acting with appropriate authority;
  • other people affected by Al-Waris Foundation's work.

8. Anonymous Complaints

Al-Waris Foundation may consider anonymous complaints where sufficient information is available to identify a credible risk or problem.

Anonymous complaints can be more difficult to investigate because clarification may not be possible.

A complaint should not automatically be ignored merely because the complainant does not identify themselves.

In particular, anonymous information concerning:

  • safeguarding;
  • fraud;
  • criminal conduct;
  • serious governance failure;

should be assessed on its merits.

9. How to Make a Complaint

Complaints may normally be made:

  • through the website complaints form;
  • by email;
  • by letter;
  • verbally where a reasonable adjustment or circumstance requires assistance.

The current complaints contact route should be published on the Al-Waris Foundation website.

Where a complaint is made verbally, the person receiving it should make an appropriate written record.

10. Accessibility and Reasonable Adjustments

Al-Waris Foundation will seek to make the complaints process reasonably accessible.

Where appropriate, assistance may include:

  • helping a person record their complaint;
  • accepting a complaint by telephone;
  • allowing an authorised representative;
  • providing accessible formats where reasonably practicable;
  • adjusting communication methods.

A person should not be disadvantaged because they require a reasonable adjustment.

11. Information to Include

A complaint should ideally include:

  • complainant's name and contact details;
  • description of the concern;
  • relevant dates;
  • people involved where known;
  • relevant evidence;
  • steps already taken;
  • outcome sought.

A complaint will not automatically be rejected because some of this information is unavailable.

12. Acknowledgement

Al-Waris Foundation aims to acknowledge formal complaints within 5 working days of receipt.

The acknowledgement should normally:

  • confirm that the complaint has been received;
  • provide a reference where appropriate;
  • explain the next stage;
  • identify any further information required;
  • provide an expected response timeframe.

13. Stage 1

Most formal complaints will initially be handled at Stage 1.

The complaint should be allocated to an appropriate person who:

  • was not materially responsible for the matter where reasonably possible;
  • can investigate objectively;
  • has access to relevant records;
  • understands the applicable policies.

14. Stage 1 Investigation

The person reviewing the complaint should, where appropriate:

  • identify the issues raised;
  • review relevant records;
  • speak to relevant people;
  • consider relevant policies;
  • distinguish fact from allegation;
  • assess whether any immediate action is required;
  • consider safeguarding, fraud or regulatory implications.

The investigation should be proportionate to the seriousness of the complaint.

15. Stage 1 Response

Al-Waris Foundation aims to provide a full Stage 1 response within 20 working days of receiving the complaint.

The response should normally explain:

  • what was considered;
  • relevant findings;
  • whether the complaint is upheld, partially upheld or not upheld;
  • any action to be taken;
  • any apology or remedy where appropriate;
  • how to request a Stage 2 review.

16. Extensions

Some complaints may take longer than 20 working days.

Examples include:

  • complex safeguarding matters;
  • overseas enquiries;
  • multiple witnesses;
  • external investigations;
  • substantial documentary evidence;
  • absence of key individuals.

Where additional time is required, the complainant should normally be informed:

  • why more time is needed;
  • what is happening;
  • the revised expected response date.

17. Stage 2 Review

If the complainant remains dissatisfied, they may request a Stage 2 review.

The request should normally explain:

  • why the Stage 1 response is considered unsatisfactory;
  • any significant evidence that was not properly considered;
  • the outcome being sought.

A Stage 2 review is not necessarily a complete reinvestigation of every issue.

18. Independence of Stage 2

Where reasonably possible, Stage 2 should be conducted by someone who:

  • did not make the Stage 1 decision;
  • is sufficiently senior or appropriately authorised;
  • does not have a material conflict of interest.

Depending on the complaint, this may involve:

  • the Chair;
  • an unconflicted trustee;
  • another appropriately authorised reviewer.

19. Stage 2 Acknowledgement

The charity aims to acknowledge a Stage 2 request within 5 working days.

20. Stage 2 Response

The charity aims to provide the Stage 2 response within 20 working days of accepting the review request.

The response should normally explain:

  • scope of the review;
  • findings;
  • whether the Stage 1 outcome is confirmed, changed or partly changed;
  • any further action;
  • whether the internal complaints process is concluded.

21. Complaints Concerning the Chair

Where a complaint materially concerns the Chair, the Chair should not determine the complaint.

The matter should be referred to:

  • another unconflicted trustee; or
  • another appropriate independent reviewer where necessary.

22. Complaints Concerning a Trustee

Where a complaint concerns a trustee:

  • conflicts must be declared;
  • the trustee concerned should not improperly influence the process;
  • another unconflicted person should handle the complaint;
  • serious governance concerns should be considered separately where appropriate.

23. Complaints Concerning Multiple Trustees

Where a complaint concerns several trustees or the independence of the Board itself is reasonably in question, the charity should consider:

  • independent external advice;
  • an independent reviewer;
  • Charity Commission guidance;
  • other appropriate external escalation.

24. Complaints Concerning Volunteers or Representatives

Complaints concerning volunteers, contractors or representatives should be assessed fairly.

Depending on seriousness, action may include:

  • guidance;
  • retraining;
  • supervision;
  • restriction of duties;
  • suspension;
  • termination of involvement;
  • safeguarding referral;
  • other appropriate action.

25. Fundraising Complaints

Fundraising complaints may concern:

  • misleading fundraising;
  • pressure;
  • conduct of collectors;
  • use of personal data;
  • fundraising communications;
  • representations about appeals;
  • handling of donations.

The charity should assess whether any external fundraising regulator or authority also needs to be considered.

Fundraising complaints should be coordinated with the Fundraising Policy.

26. Donation Complaints

Donation-related complaints may concern:

  • incorrect designation;
  • receipt problems;
  • recurring donations;
  • refunds;
  • payment problems;
  • donor communications;
  • misunderstanding about how funds are used.

Donation complaints should normally be coordinated with the donor-support workflow.

The appropriate public contact for donation-specific enquiries is:

donations@alwarisfoundation.org

27. Website and Account Complaints

Complaints concerning:

  • donor accounts;
  • login;
  • website accessibility;
  • website functionality;
  • technical support;
  • security;

should be routed appropriately.

Technical account-support enquiries may be directed to:

support@alwarisfoundation.org

where this is the most appropriate contact.

28. Volunteer Complaints

Volunteer-related concerns may be directed through the volunteer process where appropriate.

The public contact for ordinary volunteering enquiries is:

volunteer@alwarisfoundation.org

However, complaints about volunteer misconduct should still be recorded and investigated through the appropriate complaint or safeguarding process.

29. General Contact

Ordinary general enquiries that are not complaints should normally be directed to:

info@alwarisfoundation.org

The complaints process should not be used merely because a person has a normal information request.

30. Confidentiality

Complaints will be handled confidentially.

Information should normally be shared only with people who need it to:

  • investigate;
  • respond;
  • provide oversight;
  • comply with legal or regulatory requirements.

Absolute confidentiality cannot be guaranteed where information must be disclosed for:

  • safeguarding;
  • legal compliance;
  • fraud investigation;
  • regulatory reporting;
  • protection of another person.

31. Data Protection

Personal data relating to complaints must be handled in accordance with:

  • UK GDPR;
  • Data Protection Act 2018;
  • Data Protection and UK GDPR Policy.

Complaint records may contain sensitive information and should have appropriately restricted access.

32. Safeguarding Complaints

Where a complaint indicates:

  • abuse;
  • exploitation;
  • risk to a child;
  • risk to an adult at risk;

the safeguarding process takes priority.

The ordinary complaint investigation must not delay:

  • emergency action;
  • safeguarding referrals;
  • police involvement;
  • local-authority involvement.

33. Criminal Conduct

Where a complaint suggests criminal conduct, the charity should consider whether:

  • police;
  • Action Fraud;
  • another appropriate law-enforcement authority;

should be contacted.

An internal complaint process must not obstruct a criminal investigation.

34. Serious Incident Reporting

A complaint may reveal circumstances requiring consideration under the Serious Incident Reporting Policy.

Examples may include:

  • serious safeguarding failures;
  • significant fraud;
  • major financial loss;
  • serious governance failures;
  • significant reputational harm.

The Board should consider regulatory reporting separately from resolving the complainant's individual concerns.

35. Conflicts of Interest

Anyone handling a complaint must declare relevant conflicts.

A person should not normally determine a complaint concerning:

  • their own conduct;
  • a close family member;
  • a connected business;
  • another matter in which they have a significant personal interest.

See the Conflict of Interest Policy.

36. Fairness

The charity should seek to treat:

  • complainants;
  • people complained about;
  • witnesses;

fairly.

A complaint is an allegation until appropriately considered.

The charity should not assume guilt merely because a complaint has been made.

Equally, a concern should not be dismissed merely because the person complained about is senior, trusted or well known.

37. Opportunity to Respond

Where a complaint alleges misconduct by a person, that person should normally be given a reasonable opportunity to respond before a final finding is made.

Exceptions may apply where:

  • safeguarding authorities advise otherwise;
  • police involvement requires delay;
  • there is an immediate safety concern;
  • another lawful reason prevents disclosure.

38. Evidence

The charity may consider evidence including:

  • emails;
  • forms;
  • correspondence;
  • financial records;
  • photographs;
  • video;
  • system logs;
  • audit records;
  • witness accounts;
  • policies;
  • meeting records.

Evidence should be assessed objectively.

39. Standard of Assessment

Ordinary internal complaints are generally determined on the available evidence and what is more likely than not to have occurred.

This is not the criminal standard of proof.

Where criminal or regulatory matters arise, the appropriate external authority determines matters under its own legal standard.

40. Outcomes

A complaint may be:

  • upheld;
  • partially upheld;
  • not upheld;
  • unable to be determined because evidence is insufficient;
  • redirected to another procedure.

The decision should be supported by reasons proportionate to the matter.

41. Remedies

Where a complaint is upheld or partially upheld, remedies may include:

  • apology;
  • correction;
  • explanation;
  • completing an outstanding action;
  • changing a process;
  • training;
  • improving communication;
  • restoring access;
  • refund consideration where appropriate;
  • disciplinary or governance action;
  • policy changes.

A remedy should be proportionate to the problem identified.

42. Financial Compensation

The complaints process does not automatically create a right to financial compensation.

Any payment should be:

  • properly authorised;
  • reasonable;
  • documented;
  • consistent with the charity's duties.

Trustees must not use charitable funds for inappropriate personal settlements.

Professional advice should be obtained where necessary.

43. Learning From Complaints

Complaints should be used to identify improvements.

The charity should consider:

  • recurring issues;
  • preventable errors;
  • training needs;
  • policy weaknesses;
  • communication problems;
  • system failures;
  • safeguarding themes;
  • contractor problems.

Significant learning should be incorporated into procedures where appropriate.

44. Complaint Register

Al-Waris Foundation should maintain an appropriate complaints register.

It may record:

  • complaint reference;
  • date received;
  • category;
  • responsible reviewer;
  • status;
  • outcome;
  • response dates;
  • lessons or actions.

Access must be restricted appropriately.

45. Board Reporting

The Board should receive proportionate complaints information.

This may include anonymised information concerning:

  • number of complaints;
  • categories;
  • outcomes;
  • overdue complaints;
  • significant themes;
  • serious incidents arising from complaints.

Trustees should not routinely receive unnecessary identifiable complainant information.

46. Record Retention

Complaint records must be retained according to the Records Retention and Disposal Policy.

Retention periods should reflect:

  • legal risk;
  • safeguarding;
  • regulatory requirements;
  • organisational need;
  • sensitivity.

Records should not be retained indefinitely without justification.

47. Unreasonable Behaviour

Al-Waris Foundation will seek to remain accessible even where a complainant is frustrated, upset or persistent.

However, the charity may take proportionate steps where behaviour becomes:

  • abusive;
  • threatening;
  • discriminatory;
  • seriously harassing;
  • excessively repetitive without new information;
  • deliberately disruptive.

Restrictions should focus on behaviour rather than the fact that someone has complained.

48. Contact Restrictions

Where necessary, the charity may:

  • require communication in writing;
  • nominate one contact person;
  • limit repetitive responses;
  • refuse abusive calls;
  • involve police where threats are made.

Any restriction should be proportionate and recorded.

A person should still be able to raise genuinely new safeguarding or serious concerns.

49. Malicious Complaints

The fact that a complaint is not upheld does not make it malicious.

A complaint should only be treated as malicious where there is reasonable evidence that it was knowingly false and made primarily to cause harm.

Care should be taken not to discourage genuine complainants.

50. Withdrawal of Complaint

A complainant may ask to withdraw their complaint.

The charity may nevertheless continue considering the matter where there are:

  • safeguarding concerns;
  • fraud concerns;
  • regulatory implications;
  • serious misconduct concerns;
  • risks to others.

51. External Escalation

Once the internal process has been completed, the complainant may have the option to contact an external body depending on the nature of the concern.

This may include:

  • Charity Commission;
  • Information Commissioner's Office;
  • Fundraising Regulator;
  • police;
  • local authority;
  • another relevant regulator or authority.

Al-Waris Foundation should not direct every dissatisfied complainant automatically to the Charity Commission.

The appropriate external body depends on the issue.

52. Charity Commission

The Charity Commission is the regulator of charities in England and Wales.

It does not normally act as an appeal body for every service complaint.

However, serious concerns involving:

  • trustee misconduct;
  • misuse of charitable assets;
  • serious governance failure;
  • safeguarding failures;
  • other regulatory matters;

may fall within its remit.

Current guidance should be consulted where necessary.

53. Information Commissioner's Office

Privacy and data protection complaints may be escalated to the Information Commissioner's Office where applicable.

The charity should provide current regulatory information rather than relying on outdated hard-coded contact details.

54. Fundraising Regulator

Where Al-Waris Foundation is subject to the Fundraising Regulator's framework in relation to the activity concerned, eligible fundraising complaints may be capable of external escalation after the charity has had an opportunity to respond.

Current applicable requirements should be checked.

55. No Retaliation

No person should suffer retaliation merely because they have made a genuine complaint or assisted an investigation.

Retaliation may itself constitute misconduct.

56. Staff and Volunteer Support

A complaint can be stressful for both the complainant and the person complained about.

Appropriate support should be considered while maintaining:

  • fairness;
  • confidentiality;
  • independence of the investigation.

57. Policy Breaches

Failure to follow this policy may result in:

  • corrective action;
  • training;
  • governance action;
  • restriction of responsibilities;
  • disciplinary action where applicable;
  • review of procedures.

Significant complaint-handling failures should be escalated appropriately.

58. Related Al-Waris Foundation Policies

This policy should be read alongside:

  • Safeguarding Children Policy;
  • Safeguarding Adults at Risk Policy;
  • Whistleblowing Policy;
  • Serious Incident Reporting Policy;
  • Data Protection and UK GDPR Policy;
  • Confidentiality Policy;
  • Volunteer Policy;
  • Trustee Code of Conduct;
  • Conflict of Interest Policy;
  • Fundraising Policy;
  • Anti-Fraud, Bribery and Corruption Policy;
  • Information Security and Cybersecurity Policy;
  • Equality, Diversity and Inclusion Policy.

59. Review

This policy will be reviewed:

  • at least annually;
  • following a serious complaint-handling failure;
  • following significant recurring complaint themes;
  • following a complaint revealing major organisational weakness;
  • following material changes to the charity's activities;
  • following relevant changes in law or regulatory guidance.

60. Approval

Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027

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