MIDTERM REPORT ON DCA’s COMPLAINTS HANDLING SYSTEMS
1 March – 30 September 2009
DCA’s web based Complaints Handling System was launched as a one-year pilot project in
We have now reached midterm and therefore we have compiled this report to the Senior
Management and the Board on the progress of the system. At the end of the project period,
the system will be evaluated more thoroughly involving different stakeholders.
For your general information, we have received 16 complaints in Copenhagen during the
period from mid March to the end of September 2009. The complaints include both sensitive
(11) and operational (5) complaints and are about our Danish as well as our international
activities. 6 of these complaints have a lessons learned which means that the complaint has
been followed by an adjustment of procedure or an internal discussion with the intent to avoid
In general the system works well, but we have experienced a few limitations that we suggest
should be adjusted:
1. There have been discussions about anonymous complaints both internally in DCA and at
the General Assembly in HAP. Some think that the possibility of raising complaints
anonymously will enhance the credibility of the system – others think the opposite!
We suggest that as a general principle we do not accept anonymous complaints.
However we will accept that stakeholders complain anonymously via a DCA staff
member who then knows the complainer’s identity. In this way we have a better
opportunity to both seek information and pass on information to the stakeholder, thus
enabling us to investigate a case. In extraordinary situations the Complaints Handling
Committee can give consideration to anonymous complaints that is without the DCA
staff member as go-between, if it is evident, that there’re is need and ground for
However it should be clear that the anonymity can be a hindrance for the investigation
and follow up and that the DCA Complaints Handling Committee can decide not to
handle the complaint with reference to the anonymity.
We have one example (before the Complaints Handling System was launched) where
we investigated a case on sexual exploitation based on an anonymous complaint raised
through a staff member. The case would probably not have been raised if the
complainant had not been anonymous.
2. Some corruption cases have been raised by DCA staff members at a very early stage
before there was more substantial evidence in the case. This has created some internal
turbulence amongst colleagues based on the fact that nobody likes to have a more
formal complaint raised about their project or programme. The issue has been
discussed in the Anti-Corruption project group and there is a common understanding
between the members that we have to clarify the obligations.
Therefore we suggest that it is clarified in the Complaints Handling Systems that you
as a staff member are obliged:
To check if there is evidence that support the allegation before you file a
To file a complaint if there is substantial suspicion that something is
Fundraising in Denmark by Gitte Krogh, Human Resource Unit
1.1. Content of the complaint: A man complained about a phone conversation he had
had with a fundraiser (phoner) from DCA. The man had earlier donated money to
DCA. The substance of the complaint was that he felt that conversation took too
long time (perhaps because the fundraiser called in the afternoon and used a script
developed for senior citizens?), which he felt was patronizing. The message from the
fundraiser was that DCA preferred donations of a lower monthly amount instead of a
larger lump sum. He had earlier donated monthly amounts to Amnesty and then
frequently after entering the agreement, experienced attempt of persuasions to
raise the amount, which he experienced to be ‘not very positive’. He wanted DCA to
evaluate the way our fundraisers speak with people.
What did we do: We thanked him for the complaint and for his support, apologized
about his experience with the patronizing tone, explained that our analysis shows
that monthly amounts often sum up to larger amounts than one lump sum, which is
why we encourage people to reconsider their agreements, and explained that we do
not have a strategy to contact people frequently afterwards.
Lessons Learnt: We promised to raise the issue with the fundraisers in order to
improve the content of the conversations and the approach used when we call
1.2. Content of the complaint: A man complained because he had terminated an
agreement of a monthly donation the same day as the agreement had been
entered, but the money had been withdrawn from his account in spite of the
What did we do: We apologized, terminated the agreement and as we had not
received the money, we asked him to contact his bank and ask them to withhold the
money by PBS. If the money had already been transferred, we asked him to contact
us again in order for us to reimburse him the amount.
1.3. Content of the complaint: A man complained about an error in DCA’s report to the
tax authorities regarding his and his wife’s donations. He had earlier raised the issue
in a letter to the Secretary General and received a handwritten note where DCA
promised to correct the mistake, which had been done partly but still not correctly.
He wanted DCA to make a correct report to the tax authorities and raised the issue
of DCA’s ability to handle collected funds when we were not able to correct a small
mistake. In addition to this, he raised a question about trust when a letter to the
Secretary General was answered by a handwritten note from a staff member and
the mistake was still not corrected.
What did we do: We apologized (deeply), explained how our IT systems work and
that the report is a new request from the tax authorities and thus a new procedure
for DCA. We have experienced very few mistakes in the thousands of donations
reported. Finally, we made sure with documentation that the donations were
corrected by the tax authorities.
Lessons Learned: As the letter had never reached the Secretary General, we
changed the procedure for internal mail system so that this will not happen in the
1.4. Content of the complaint: Two women complained about the way they had been
approached by some fundraisers (facers). They felt offended by one of the
fundraisers because he would not accept their refusal to donate money and kept
arguing with them. They felt he gave them a bad conscience because of their
What did we do: We apologized and explained that the fundraiser’s approach was of
course completely unacceptable for DCA. We also referred to our ethical guidelines
for our facers.
Lessons Learned: We promised to raise the issue with the local coordinator for the
facers and make sure that the group recognized that this kind of approach is
1.5. Content of the complaint: A woman complained about the charity buttons that you
can use when you hand in recyclable bottles in Supermarkets. She felt very
offended by this method and considered it to be almost fraudulent and deeply
distasteful. She wanted an explanation of this shady way to cheat people. She did
not want her money back – the complaint was only about the method.
What did we do: We explained the rationale behind our decision to establish the
charity buttons – namely that the button had been tested with very positive
feedback in some supermarkets before we launched the project. We also explained
that we have made the system as secure as possible for people to use, meaning
that you have to press the button twice and confirm your donation to avoid
mistakes. The results and feedback from many citizens are very positive and we
raise a substantial amount every year via the charity button.
Sexual Exploitation by Gitte Krogh, Human Resource Unit
1.6. Content of the complaint:
The complaint was about misbehaviour by a staff member in DCA. Due to the
sensitivity of the case, details will not be reported here, but the staff member
admitted to have behaved improperly towards another staff member and not in
accordance with DCA values. Disciplinary action was therefore taken. The other
We will not publish names of individual persons involved in a complaint. If DCA conclude that public information
about the name of the country will endanger the victims or there is a high risk of further victimization, we will not
publish the name of the country. The reason is that DCA has relatively few employees in each country and it will be
very easy to identify the persons that have raised a case or are victims. The board member Thorkild Høyer, Danish
lawyer, will on behalf of the board, look through specific cases to ensure quality assurance of the procedures.
involved staff member had not complained. A colleague raised the case to a Senior
Management member, who brought the case into the Complaints Handling System.
What did we do: We investigated the case according to the principles and
procedures in the Complaints Handling System.
Lessons Learned: We have changed some internal procedures but due to the
sensitivity of the case the details will not be reported here.
1.7. Content of the complaint: The complaint is about allegations of misbehaviour by a
staff member in DCA. The case is under investigation and therefore we are not able
to report more details here.
Corruption and Fraud by Maja Bjørnskov, Programme Finance Unit and Gitte Krogh
1.8. Content of the complaint: The complaint is about a missing (large) amount of
money and it involves two staff members in DCA. The case is ongoing and therefore
we are not able report more details here.
1.9. Content of the complaint: The complaint was about missing documentation for app.
Text on the DCA webpage: “An investigation is taking place based on irregularities
in monthly cash books. Until these allegations have been investigated no other
information will be published. USD 15.000 is at this time not accounted for; an
investigation will confirm or reject that fact.”
What did we do: An internal investigation committee in DanChurchAid investigated
missing documentation for USD 15.000 on a Regional Office in DanChurchAid. The
investigation showed that no fraud or corruption had taken place, but some
mistakes in the accounting caused the difference of USD 15.000.
Lessons learnt: The above mentioned text was published on DCA-website. This
caused many reactions from the staff involved, who found it premature to expose
the allegations on the website. It was decided that the investigation committee has
to carefully consider what is published and what is not.
1.10. Content of the complaint: In the beginning of 2009 DCA and our sister organisation
Norwegian Church Aid (NCA) reacted toward irregularities in a partner organisation
in Southern Africa. The partner had not been able to submit a financial audit without
What did we do: DCA is now in cooperation with other donor agencies further
investigating the organisation. The managing director was fired, because of the first
suspicion. Our back-donor Danida has been notified.
1.11. Content of the complaint: A partner organisation in Africa is under investigation for
mismanagement and fraud. The management in the partner organisation found
irregularities in a sub-office. The partner contacted DCA immediately and the
manager of the partner’s sub-office was dismissed. Weaknesses were found in four
major areas (management performance aspect, compliance to administrative rules
and procedures, financial and procurement procedures and store and property
handling and management).
What did we do: A further investigation will reveal if there in addition to
mismanagement has been corruption or fraud involved. Danida will be notified
Lessons learnt: The term ‘substantial suspicion of corruption’ was tested in this
case. Because when are we talking about corruption? The first phases of the case
did not show any sign of fraud or corruption. A weak organisation and incompetent
managers is not corruption in itself.
1.12. Content of the complaint: A partner organisation in Central America has for the 2nd
year not been able to perform financial audit without qualifications.
What did we do: This year special attention was paid to the partner as
documentation is missing. The case is under further investigation.
1.13. Content of the complaint: In June 2009 a DCA employee was faced with the
dilemmas of 1) going to detention and get deported out of an African country or 2)
to pay a facilitation payment of USD 300, due to problems with a visa.
What did we do: Managers agreed that it would under no circumstances be
acceptable to take the security risk and therefore the facilitation payment was paid
by DCA own funds.
1.14. Content of the complaint: Procedures for travel statements, per diem and advances
before travelling is being tightened due to possible cases of fraud in a regional
office. The possible case is under investigation.
1.15. Content of the complaint: A partner organisation was accused of possible misuse of
funds. Assessment showed that the problem mainly is one of management and
What did we do: We decided to conduct an extraordinary audit, which has not yet
been finalized. Based on the conclusion from the audit we will determine the next
steps. As the partner is of strategic importance for DCA and because there are
indications that key stakeholders in the partner organisation wants to strengthen
the organisation it has been agreed (of course, subject to more detailed findings)
that the audit is seen as the beginning of a process to improve the financial
management in the organisation.
1.16. Content of the complaint: A report on how facilitation payments are handled in a
specific country was send to the complaint mechanism. DCA is not as such paying
any bribes in the country, but DCA is paying facilitation payments, for example
“fees” to the police - to get permission to drive motorbike, or to operate as
organisation. Another example is that police and military roadblocks require a bottle
of alcohol to let staff through.
What will we do: Facilitation costs are normally hidden and not transparently
registered. With the new DCA anti-corruption policy in hand a process to convince
partners, that they should tell straight forward when facilitation payments are used,
Reports from Malawi, Ethiopia, Cambodia and Humanitarian Mine Action in
We have also asked the Regional Office in Malawi, Ethiopia and Cambodia and the HMA office
in Angola to provide us information about the Complaints Handling Systems established in
each country. We are working on a small report which compiles the lessons learned from these