The Action plan

Recommendation from a specialist HR consultancy

Action taken

The person or person(s) conducting an investigation has no involvement or decision-making ability in any subsequent disciplinary process.

We have a clear and concise complaints and disciplinary process. This is published on our website and accessible to the public. Within the procedure the individual/s conducting the investigation are not involved nor hold decision making ability in subsequent disciplinary proceedings – please see point 8.

The Chief Executive does not act as the investigating officer nor make initial enquiries and delegates this to either a trained person or person(s) within the organisation or to an external HR consultancy. The Chief Executive may still retain the ability to suspend a member pending an investigation. This also has the benefit of ensuring that the person or person(s) conducting the investigation has no involvement in any suspension.

A Head of Professional Conduct was appointed in 2021 with responsibility for handling any concerns raised and expertise to support complainants through the process. The roles and responsibilities of the Head of Professional Conduct and the disciplinary panel are outlined clearly within the attached links. Due to the differing nature of our members, there are defined and specific procedures stipulated. Please read from point 6.  

Where suspension is necessary, the reasons should be kept confidential. The Chartered Institute of Fundraising should control the communication about a member’s suspension. It is also suggested that there is a point of contact given to the suspended member who can also answer any enquiries from other members and/or parties.

In the first phase of the recruitment for the Professional Conduct Committee, we were successful in recruiting a lay person from a legal background who has assisted as an external advisor and independent perspective. The second phase of recruitment in Spring 2023 was much more successful by sharing cross sector to widen the scope of potential applicants with relevant experience. The Professional Conduct Committee is now established.

The Head of Professional Conduct provides a supportive role as point of contact for the suspended member.

Since 2023, the Chartered Institute have been members of the Misconduct Disclosure Scheme. As a member, we participate in the sharing of misconduct data. The scheme helps to prevent perpetrators of sexual misconduct moving unknown between organisations. 

A disciplinary panel conducts disciplinary hearings and makes disciplinary decisions. No disciplinary sanctions or warnings should be issued prior to a disciplinary hearing being held.

The Professional Conduct Committee has been established and the Disciplinary Panel process is set out at 8.13 and 8.17 onwards in the Complaints and Disciplinary Rules.

Consider including criteria for publicising complaints resulting in disciplinary sanctions and how they are publicised.

Since 2023, the Chartered Institute have been members of the Misconduct Disclosure Scheme that works to prevent individuals, who have allegations of sexual misconduct upheld against them, from moving between organisations. We are now able to lawfully share and receive information, further information shared publicly here.

Following this recommendation, we have included the publicising of complaints in our complaints rules, (point 12). The decision to do so will be taken on a case-by-case basis, overseen by the Board, for those with substantiated allegations against them, and will be considered on a risk basis.

It is suggested that the wording is revised so that members understand that they can report complaints of sexual harassment anonymously and confidentially via the HR consultancy hotline in the first instance.

The Head of Professional Conduct is responsible for the management of the complaints process and ensures all complaints are appropriately addressed.

The Chartered Institute offers anonymous reporting through a third-party tool, Talk to Spot. This is available 24 hours a day, 365 days a year. It provides a sophisticated system that is designed to help achieve best evidence in terms of the documentation of reporting.

You can review Talk to Spot here, and are welcome to trial our reporting system 

Make it clear in the policy to whom within the Institute of Fundraising members can raise complaints and/or concerns about sexual harassment.

Staff and volunteers are required to undertake safeguarding training, which is clear and concise around who to contact in the event of a concern/complaint relating to harassment, abuse or discrimination.

The disciplinary and grievance procedure is published and clearly states to whom any complaints or concerns should be addressed to please see point 3 to 3.5. Information about raising a complaint or concern is available on our website.

The Chartered Institute have reviewed and updated key policies including the Safeguarding Policy and the Equity, Diversity and Inclusion Policy. These policies, alongside the disciplinary and grievance procedure, make clear to all staff and volunteers who they can raise complaints to and how

Allow complaints to be initially submitted verbally and informally, a record of which can then be made during any subsequent investigation process, or acknowledged in writing, should the member wish to withdraw the complaint at a later date.

Complaints can be submitted informally or formally, and every single one is recorded. Complainants can report anonymously via Talk to Spot and can also chose to record their complaint/concern and choose when this is shared.

Change any wording to make it explicit that any allegations of sexual harassment will be fully investigated before any disciplinary action is taken.

Implemented, and set out in section 8 of the Complaints and Disciplinary Rules.

Consider detailing a separate process for complaints about sexual harassment.

Implemented, and set out in points 3.3 and 8.5 of the Complaints and Disciplinary Rules.

Offer anonymity only if requested and there is a good reason. Members are still able to raise anonymous complaints via the HR consultancy hotline.

The Chartered Institute now offers anonymous reporting through a third-party tool, Talk to Spot. This is available 24 hours a day, 365 days a year.

Consider adding to the Code of Conduct a requirement by all members to promote an inclusive environment that is free from harassment, bullying and discrimination.

Implemented, and included in the updated Code of Conduct from 2021.

The Chartered Institute have also reviewed and updated their Equity, Diversity and Inclusion policy this is made available to all staff and volunteers

Similar to a Safeguarding Officer role, it is suggested that the organisation appoints a designated person or person(s) to whom disclosures are made/reported.

We developed this post into a more senior role – Head of Professional Conduct, bringing in significant experience and expertise in safeguarding to this key role. 

The Head of Professional Conduct is a registered social worker specialising in safeguarding and is registered  as a Counsellor with the British Association of Counselling and Psychotherapy and is able to support a trauma informed approach to all parties. Where a conflict is identified, alternative arrangements will be made.

As a disclosure may be made to another member, it is important that all members know who to go to if a disclosure has been made to them and they are not in a position to deal with the complaint.

Information about how to raise/report concerns is regularly shared with members through newsletters, on our website and at events. All staff and volunteers are required to complete the mandatory safeguarding training. It is made clear both in this training and through support from the Head of Professional Conduct the actions that staff and volunteers need to undertake if and when a disclosure is made to them. Our reporting system, Talk to Spot, is accessible 24/7, 365 days a year for anyone to make a report as a complainant, or indeed a witness.

During 2024, all Chartered Institute events will have a designated safeguarding lead at all events, to ensure a consistent approach to safeguarding.  The Head of Professional Conduct, will be working with our groups and internally to support this initiative.  

Provide education and training on initial steps to take upon a disclosure of sexual harassment.

The initial steps to take upon a disclosure of harassment is covered in our training for staff and volunteers and on the Head of Professional Conduct will be further developing the training. Our reporting system Talk to Spot also has a suite of anti-harassment training for all and including specific training for those with supervisory responsibilities. Training is ongoing and will be provided for all staff and volunteers.

Review any historic complaints that were not investigated as complainants did not wish to make a formal complaint, or put it in writing, to assess whether there is any further action required.

All historic complaints have been reviewed and were also considered as part of the Independent Review.

Provide training to any person or person(s) conducting investigations or appoint the HR consultancy to conduct investigations. the HR consultancy can also provide HR consultancy to help manage initial complaints at any part of the process.

Action taken and ongoing process: The Head of Professional Conduct is a registered social worker and is skilled and experienced in undertaking adult safeguarding and sexual harassment/abuse investigations. There may still be occasions whereby independent investigation is required due to the level of complexity, specialism, or is required because of any conflict of interests. On these occasions the Chartered Institute would be lead by the Head of Professional Conduct and the Professional Conduct Committee who would identify the most appropriate external specialist to carry out the investigation. 

Consider introducing a member assistance programme to support members mental health during the investigation process.

All staff have access to an employee assistance programme and support for mental health and wellbeing that can be accessed by all staff. The Professional Conduct Committee will review the support available to members, volunteers and staff in 2024 alongside the recommendations from the Independent Review when they receive the report.

The role of the Head of Professional Conduct supports and/or facilitates access to emotional and wellbeing services ensuring all involved parties involved in an investigation are given person centred support.

Clarification in relation to the difference between the informal and formal process.

We have a flow chart which sets out the complaints and reporting process and the requirement for all concerns raised to be recorded regardless of whether formal or informal. This ensures consistent, fair and impartial and balanced actions are taken.

We also have in place legal guidance surrounding the management of complaints.  

Concerns whether formal or informal can report either directly via the complaints process or can share information informally and anonymously via our reporting system Spot.

Develop and adopt a broader and more powerful single safeguarding policy.

We have developed a broader Safeguarding Policy that specifically covers all forms of harassment, discrimination and abuse as part of significant work on safeguarding during 2021/22. The policy was approved by the Board in December 2022.

Recognition that different legal systems operate across the UK.

The Safeguarding Policy recognises and incorporates the different legislative systems across the UK. We ensure that all procedures, policies and guidance are relevant for each legislative system.

Complaints about members NOT related to sexual harassment, bullying or discrimination.

The Head of Professional Conduct will work with the Professional Conduct Committee to review all complaints processes, alongside recommendations from the Independent Review after they receive the report. We are members of the Professional Associations Research Network and have access to relevant research on best practice.  

We have had legal challenges in relation to pursuing former members.