Policy Number:                      MTA017

Date adopted:                          27 July 2021

Authorised by: Board of Directors of Maluk Timor Australia


Date of reviews:                      NA

Date of next review:               July 2023

Reviewed by: Board of Directors of Maluk Timor Australia

Refer to Section 6 below for information on the process for policy review.

Policy Context


Informed by:

(SOCAP) and The Australian Centre for Justice Innovation (ACJ), Monash University


  1. Purpose: Why do we have a Complaints Policy?

This policy is intended to ensure that Maluk Timor Australia handles complaints fairly, efficiently and effectively.

This policy provides guidance to our staff and people who wish to make a complaint on the key principles and concepts of our complaint management system.

  1. Scope

Applies to Maluk Timor Australia.  All Directors, contactors, employees and volunteers will abide by this policy.

  1. Policy statement: Our commitment

This organisation every person at Maluk Timor Australia to be committed to fair, effective and efficient complaint handling. The following table outlines the nature of the commitment expected and the way that commitment should be implemented.

Who Commitment How

And Chair of the governing body

Promote a culture that values complaints and their effective resolution Report to the governing body on complaint handling.

Provide adequate support and direction for handling complaints.

Review complaint trends and issues arising from complaints.

Be alert to complaints and assist those responsible for handling complaints to resolve them promptly.

Encourage recommendations for system improvements.


Who Commitment How
Staff whose duties include complaint handling (may include CEO or chair of the governing body) Demonstrate exemplary complaint handling practices Treat all people with respect, including people who make complaints.

Assist people to make a complaint, if needed.

Comply with our policy and associated procedures.

Provide feedback to Board on issues arising from complaints.

Provide suggestions to management on ways to improve complaints management system.

Implement changes arising from individual complaints and from the analysis of complaint data as directed by management.

All MTA Board Directors, Committee members, staff, contractors and volunteers Understand and comply with our complaint handling practices. Treat all people with respect, including people who make complaints.

Be aware of the complaint handling policies and procedures.

Assist people who wish to make complaints access complaints process.

Be alert to complaints and promptly assist with complaints resolve matters promptly.


  1. Guiding Principles

An effective complaint handling system must be modelled on the principles of fairness, accessibility, responsiveness, efficiency and integration into organisational culture.

4.1.1 People focus

We are committed to seeking and receiving feedback and complaints about our services, systems, practices, procedures and complaint handling.

Any concerns raised in feedback or complaints will be dealt with within a reasonable time frame (as in AS/NZ 10002).

People making complaints will be:


4.1.2 No detriment to people making complaints

We will take all reasonable steps to ensure that people making complaints are not adversely affected because a complaint has been made by them or on their behalf.

4.1.3 Anonymous complaints

We accept anonymous complaints if there is a compelling reason to do so and will carry out a confidential investigation of the issues raised where there is enough information provided.

4.1.4 Accessibility

We will ensure that information about how and where complaints may be made to or about us is publicised, on our website (if available). We will ensure that our systems to manage complaints are easily understood and accessible to everyone, particularly people who may require assistance.

If a person prefers or needs another person or organisation to assist or represent them in the making and/ or resolution of their complaint, we will communicate with them through their representative if this is their wish. Anyone may represent a person wishing to make a complaint with their consent (e.g. advocate, family member, legal or community representative, member of Parliament, another organisation).

4.1.5 No charge

Complaining to Maluk Timor Australia is free.

4.2 Respond to Complaints

4.2.1 Early resolution

When appropriate we may offer an explanation or apology to the person making the complaint.

4.2.2 Responsiveness

We will promptly acknowledge receipt of complaints.

We will assess and prioritise complaints in accordance with the urgency and/or seriousness of the issues raised. If a matter concerns an immediate risk to safety or security the response will be immediate and will be escalated appropriately.

We are committed to managing people’s expectations, and will inform them as soon as possible,  of the following:

We will advise people as soon as possible when we are unable to deal with any part of their complaint and provide advice about where such issues and/or complaints may be directed (if known and appropriate).

We will also advise people as soon as possible when we are unable to meet our time frames for responding to their complaint and the reason for our delay.

4.2.3 Objectivity and fairness

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 not involved in the issue that is the source of the complaint.

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.

4.2.4 Responding flexibly

Maluk Timor Australia will attempt to resolve complaints promptly and with as little formality as possible. We will adopt flexible approaches to enhance accessibility for people making complaints and/or their representatives.

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

4.2.5 Confidentiality

We will protect the identity of people making complaints where this is practical and appropriate.

Personal information that identifies individuals will only be disclosed or used by us as permitted under the relevant privacy laws and any relevant confidentiality obligations.

4.3 Manage the parties to a complaint

4.3.1 Contracted Services

Where our services are contracted out, we expect contracted service providers to have an accessible and comprehensive complaint management system. We take complaints not only about the actions of our staff but also the actions of our service providers.

4.3.2 Managing unreasonable conduct by people making complaints

We are committed to being accessible and responsive to all people who approach us with feedback or complaints.

When people behave unreasonably in their dealings with us, their conduct can significantly affect the progress and efficiency of our work. As a result, we will take proactive and decisive action to manage any conduct that negatively and unreasonably affects us and will support our staff to do the same in accordance with this policy.


4.3.3 Alternative avenues for dealing with complaints

We will inform people who make complaints to or about us about any internal or external review options available to them (including any relevant Ombudsman or oversight regulatory bodies).

The three levels of complaint handling

Level 1

We aim to resolve complaints at the first level, the person receiving the complaint.

Level 2

Where this is not possible, we may decide to escalate the complaint to the Board, a sub-committee of the Board or sub-committee delegates. This second level of complaint handling will provide for the following internal mechanisms:

Level 3

Where a person making a complaint is dissatisfied with the outcome of our review of their complaint, they may seek an external review of our decision (by the Australian Charities and Not-for-Profits Commission for example).

  1. Accountability and learning
    • Analysis and evaluation of complaints

We will ensure that complaints are recorded in a systematic way so that information can be easily retrieved for reporting and analysis by management and the governing body of Directors.

We will continually monitor our complaint management system to:

5.3 Continuous improvement

We are committed to improving the way our organisation operates, including our management of the effectiveness and efficiency of our complaint management system. To this end, we will:

  1. Procedure


When responding to complaints Maluk Timor Australia acts in accordance with complaint handling procedures as well as any other internal documents providing guidance on the management of complaints.

We consider any relevant legislation and/or regulations when responding to complaints and feedback.

The five key stages in our complaint management system are set out below

  1. Receive

All complaints, including those resolved at the outset, will be recorded including supporting information.

The record of the complaint will document:


  1. Acknowledge

We will acknowledge receipt of each complaint promptly, and preferably within 10 working days. When appropriate we may offer an explanation or apology.

Consideration will be given to the most appropriate medium (e.g. email, letter) for communicating with the person making a complaint.

3.1 Initial assessment

After acknowledging receipt of the complaint, we will confirm whether the issue/s raised in the  complaint is/are within our control. We will also consider the outcome/s sought by the person making  a complaint and, where there is more than one issue raised, determine whether each issue needs to  be separately addressed. When determining how a complaint will be managed, we will consider:

3.2 Investigating the complaint

After assessing the complaint, we will consider how to manage it. We may:

We will keep the person making the complaint up-to-date on our progress, particularly if there are any delays. We will also communicate the outcome of the complaint using the most appropriate medium. Which actions we decide to take will be tailored to each case and take into account any statutory requirements.

  1. Determine outcome and provide reasons for decision

Following consideration of the complaint and any investigation into the issues raised, we will contact the person making the complaint and advise them:

  1. Close the complaint: document and analyse data

5.1 Document

We will keep records about:

We will ensure that outcomes are properly implemented, monitored and reported the FRAG and Board




  1. Other related policies and procedures
Policies •       Whistleblower Policy

•       Privacy Policy

•       Associacao Maluk Timor Complaints Policy

Forms or other organisational documents •       The Constitution of Maluk Timor Australia

•       The Articles of Association of Associacao Maluk Timor

•       Agendas and Minutes of meetings of the Board of Directors of Maluk Timor Australia

•       Agendas and Minutes of meetings of the Board of Directors of Associacao Maluk Timor


  1. Review processes


This policy will be reviewed every 2 years, with additional periodic reviews as required.


The Board of Directors is ultimately responsible for reviewing this policy and approving any changes. The Company Secretary is responsible for ensuring the review process is listed for discussion on the Board agenda.


The policy will be reviewed by the Finance, Risk and Governance Committee and then the Board. Notice of the review will be placed on the Board agenda and a copy of the current policy will be attached.


Changes will be included in the minutes of the Board meeting and the soft copy of this policy will be updated accordingly. All hard copies will be retrieved and replaced with an updated policy duly dated. All relevant contractors and volunteers will be provided a copy of the updated policy.

  1. Reference: Key terms and phrases

‘Maluk Timor’ means both Maluk Timor Australia and Associacao Maluk Timor.

‘Maluk Timor Australia’ means the Australian incorporated entity, Maluk Timor Australia (ABN 54 121 715 446).

‘Associacao Maluk Timor’ means the Timor-Leste incorporated entity.

Complaint – An expression of dissatisfaction made to or about Maluk Timor Australia, our services, staff or the handling of a complaint where a response or resolution is explicitly or implicitly expected or legally required. (AS/NZ 10002:2014).

As well as complaints being made directly to our organisation, some complaints (or at least negative comments) made be made on social media.

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

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

Feedback – Opinions, comments and expressions of interest or concern, made directly or indirectly, explicitly or implicitly, to or about us, about our services or complaint handling system where a response is not explicitly or implicitly expected or legally required.

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.

Procedure – A statement or instruction that sets out how our policies will be implemented and by whom.


This document is based on a model complaints policy and procedure developed in a collaborative effort of the following organisations: Australia Council for International Development, Community Council of Australia, Governance Institute of Australia Fundraising Institute Australia, Justice Connect, National Roundtable of

Nonprofit Organisations, Our Community, Philanthropy Australia, Public Fundraising Regulatory Authority and

Volunteering Australia; convenor Dr Sue-Anne Wallace AM. The information is used as follows: © 2018 Sue-Anne

Wallace [email protected]  You may download, display, print and reproduce this material for your personal use, or non-commercial use within your not-for-profit organisation. You may modify this resource. Apart from any use permitted under the Copyright Act 1968 (Cth), all other rights are reserved.