Commitment 7.3 We are accountable to our stakeholders.

Compliance Indicators

Compliance with the Commitments will be assessed against the following Compliance Indicators. All of the applicable Compliance Indicators must be met by every ACFID Member to be considered compliant with the Code. Each of the Compliance Indicators has one or more compliance Verifiers. Verifiers are the description of evidence that is required to substantiate compliance with each Compliance Indicator. Guidance is also provided.

7.3.1 Members demonstrate an organisational commitment to operating transparently with all stakeholders.


Policy, statement or guidance document (separate, or as part of other guidance such as for communications), that addresses expectations for transparency including what information is made public and when.

Members are required to extend this compliance indicator and verifiers to partners through MOUs or similar.


A transparency policy should outline your organisation’s committing to disclosing timely, relevant and accurate information in an accessible format, with any exceptions clearly and reasonably explained (such as data protection issues). It should outline what information your organisation is committed and prepared to share with the public and how it will respond to requests for information. This is also sometimes referred to as an open information policy.

Information that your organisation is committed to sharing might include, for example, your organisation’s legal status, purpose and governance structure; descriptions of significant program; policy papers, reports and press releases; formal agreements with other organisations; strategic documents; budgets; financial records; research and reports, organizational policies; and records of the environmental impact of activities. An example of a transparency policy can be found in the Resources Section below.

7.3.2 Member development initiatives consistently demonstrate the separation of development and non-development activities

Members are required to extend this compliance indicator and verifiers to partners through MOUs or similar


Policy, statement or guidance document that addresses the separation of development activities from non-development activities in:

  • Programming.
  • Expenditure reporting.
  • Fundraising.
  • Advocacy campaigns.
  • Communications.
  • Choice for donors.
  • Partners.

Development initiatives that consistently show evidence of the separation of development and non-development activities


The policy, statement or guidance document that clearly separates aid and development and non-aid and development activity needs to refer explicitly to both religious adherence promotion and political activity. ACFID has a policy template to assist signatory organisations to develop policy that addresses the separation of development activities from non-development activities, which can be found in the Resources Section below.

7.3.3 Members enable stakeholders to make complaints to the organisation in a safe and confidential manner.

Members are required to extend this compliance indicator and verifiers to partners through MOUs or similar.


A documented, complaints handling policy that:

  • is readily accessible on the organisation’s website
  • provides a safe and discrete point of contact for stakeholders in Australia and countries where work is conducted, to raise concerns or complaints about the organisation
  • is responsive and fair
  • provides information to all stakeholders, including to Members of the communities where activities are implemented, about the reporting and complaints procedure.
  • provides information in a clear and easily understandable manner in appropriate forms and through appropriate media.
  • ensures that requirements for filing a complaint take into consideration the needs of the most vulnerable and considers minority and disadvantaged stakeholders.
  • advises a complainant of the ability to make a complaint regarding an alleged breach of the Code to the ACFID Code of Conduct Committee.
  • provides information on how staff and volunteers are equipped to understand and implement the policy.
  • includes a process for reviewing and analysing complaint information within the organisation.
  • outlines a triage system for escalating serious incidents
  • outlines a referral process for complaints that do not fall within the scope of the policy. (e.g. Complaints that do not fall within the scope of the policy would include, for example, complaints against an employee of another organisation or government department.)
  • commits to providing appropriate assistance and referrals to survivors (e.g. providing assistance to complainants might include medical, social, legal and financial assistance, or referrals to such services.)

A documented investigation procedure, which stipulates that an organisational record must be kept of all misconduct complaints, noting the ability to de-identify complaints at the request of the complainant or survivor.


Having a complaints policy that is clear and readily accessible by all stakeholders is critical to fostering and ensuring accountability. It is a vital part of an organisation’s safeguarding mechanisms.

A complaints policy provides internal guidance to staff on how a complaint must be handled. A triage or prioritisation system for escalating serious complaints ensures that complaints are classified and prioritised according to their seriousness and appropriately handled within the organisation. Providing a clear reporting classification and reporting system ensures complaints are handled by the right people in the organisation, and follow appropriate response protocols. For example, a complaint from a regular supporter about the volume of marketing material they receive would be classified and handled differently to a complaint about the behaviour of staff, such as an act of fraud or sexual exploitation or abuse. The complaints policy should outline what processes should be followed for different types and degrees of complaints – for example, sexual misconduct, financial misconduct, child safeguarding incidents, HR misconduct incidents, and supporter concerns.  The policy should also provide guidance to staff on how to manage complaints that do not fall within the scope of the member’s policy – usually by referral to the entity that is the subject of the complaint.

A policy also provides an important statement of the organisation’s commitment to welcoming and responding to complaints and being accountable to stakeholders. It is used to communicate this commitment to both internal and external stakeholders.  This includes a commitment to providing appropriate assistance and referrals to survivors of sexual exploitation or abuse such as by mapping out key stakeholders and service providers for referrals, and by seeking to provide financial support to the extent practicable.

ACFID’s Guidance for the development of a Complaints Handling Policy is available for members to support their understanding of complaints handling, linked in the Resources section below. Members can also find links to complaints policies of other members by looking at their websites.

7.3.4 Members make information about their organisation and its work available to all stakeholders.


Members will provide the following information on their website:

  • Information on its governance: structure, responsible persons and organisational contact information.
  • ABN.
  • Information on their work, including key projects or programs.
  • Information on partners and their roles.
  • A statement of commitment to adherence to the Code.
  • The scope for and mechanism/process for lodging a complaint against the organisation, and a point of contact.
  • Identification of the ability to lodge a complaint alleging a breach of the Code with the ACFID Code of Conduct Committee, and a point of contact.
  • An Annual Report including the ACFID-Code-compliant financial statement in line with ACFID requirements (as outlined in Compliance Indicators 8.3.1 and 8.3.2).
  • Staff Code of Conduct (or equivalent)
  • Key policies relevant to the public including but not limited to, privacy, complaints, transparency, non-development activity, child protection, prevention of sexual exploitation and abuse, and conflict of interest.

Primary Stakeholder communication:

  • Information is provided to primary stakeholders on the expected behaviour of the organisation’s staff and volunteers, and access to its local complaints mechanism.


Making the information listed above available on your website, ensures it is accessible to a range of stakeholders and makes a public statement about the organisation’s commitment to the policy areas covered such as child protection, PSEA and welcoming complaints. In general, information must be easily accessed, accurate and up to date. It may need to be tailored to increase its accessibility to different stakeholders, such as primary stakeholders (to whom development activities seek to directly benefit), partners, government, regulatory bodies, local leaders and officials, donors, supporters, volunteers, staff, governing body members, and peer organisations. Including the organisations staff code of conduct, enables all stakeholders to familiarise themselves with the behaviours they can expect of staff and makes a public statement about the expectations of the organisation of its staff. Communicating this same information to primary stakeholders also makes a public commitment by the organisation and enables primary stakeholders to understand what is acceptable and unacceptable behaviour. This is a critical component in accountability and the prevention of sexual exploitation and abuse. It is equally important that the organisation ensures that primary stakeholders understand the information provided to them.

7.3.5. Members seek input and feedback from all stakeholders


Policy, statement or guidance document committing the Member to the dissemination of information to all stakeholders and to seeking their inputs and feedback.


The policy, statement or guidance document may be a stand alone document or it might be addressed in other policy and guidance documents, such as in the organization’s policy on transparency (refer to 7.3.1) and its policy on complaints handling (refer to 7.3.3). However, it is important to note that this Compliance Indicator recognises the value of all types of input and feedback from stakeholders, not only complaints.  The important aspects that need to be addressed is the organisation’s commitment to sharing timely, relevant and accurate information in an accessible format; a commitment to providing stakeholders with an opportunity to provide input and feedback which includes compliments, suggestions and complaints; and a commitment to responding to feedback effectively and appropriately.

Good Practice Indicators

The following Good Practice Indicators describe a higher standard of practice than that set out in the Compliance Indicators. While Members do not need to meet the Good Practice Indicators to be considered compliant with the Code, they will self-assess against these indicators once every three years. This provides a clear pathway for Members to strengthen and improve practice over time.

  • Materials outlining organisation vision, mission and values, are available to partners and primary stakeholders in accessible forms.
  • Complaints mechanisms are adapted to local contexts and provided in accessible formats and languages.
  • Consultation with primary stakeholders is undertaken to ensure their perspectives inform the design of community-based complaints mechanisms, particularly in relation to sexual exploitation, abuse and harassment.


Good Practice Guidance

Here are some practical suggestions for your organisation to further deepen and improve practice over time.


  • Publish a clearly defined mission statement
  • Publish information on your governance: structure, decision-making processes, governing body members and contact information
  • Comply with all relevant governance, financial accounting and reporting requirements
  • Publish an annual financial report that conforms with relevant laws and practices and is audited by a qualified independent auditor whose statement accompanies the report
  • Publish an annual report that also describes your NGO’s mission and values, objectives and outcomes achieved in programmes and advocacy work, environmental impact, governance structure, processes and main office bearers, main sources of funding, financial performance, and contact details
  • Maintain an updated website
  • Regularly update donors and supporters through a wide range of communication channels, such as through newsletters and your website and social media channels
  • Information should include organisational activity, including actual performance in relation to previously agreed goals, financial reports showing actual expenditure compared to budget, and any significant changes to programme goals or activities, the budget or key contacts.
  • Publish relevant information in the country of operations. This could include:
    • Background information on your organisation or partners, including the mission and values, country of origin, website, and legal status in country of operations
    • Details of the specific programme, including name, duration, location, goals, activities, target criteria and budget (while ensuring that the safety or wellbeing of any person or child is not compromised in doing so)
    • Contact information, including country office address, name and contact details of the programme manager and other relevant individuals
    • Regular reports of actual performance in relation to previously agreed goals
    • Regular financial reports showing actual expenditure compared to target
    • Any significant changes to programme goals or activities, the targets or key contacts
    • Dates and locations of key events such as meetings and consultations
    • Specific contact details for making comments or suggestions on the program activities or to request additional information
    • Information on how to make complaints about activities, including a named member of staff to contact and contact details
    • Tailor information for it to be readily accessible to the different stakeholders.

Separation of non-development activity

  • Develop and document your organisation’s vision, purpose and values. For signatory organisations that engage in non-development activities, this can be used as the basis for discussion with partners and other stakeholders to develop shared understanding.
  • Signatory organisations that are accredited with the Australian Government ANCP program or have ‘approved organisation status’ under the Overseas Aid Gift Deductibility Scheme (OAGDS) funds raised under this scheme must not used for any purpose other than aid and development activity.  Signatory organisations should be aware that DFAT’s official definition of non-development activity includes welfare activities – refer to the Australian NGO Accreditation Guidance Manual.
  • For governing body members, volunteers or staff who are affiliated with a particular religion or political party in their private or professional lives, it can be challenging to separate this from their engagement in aid and development activities. In this situation you could implement the following:
    • Undertake orientation and training for all new board members, staff and volunteers to distinguish between development and non-developmental activities
    • Develop and disseminate clear guidance for any representatives engaging in field-based activities, such as monitoring or partner engagement, to ensure the distinction between the development and non-development activities is monitored and remains clear in activities, communication and practices
    • Ensure compliance with the separation by taking action where required to address inconsistent behaviour.
    • Help staff and volunteers understand that separating development and non-development activity doesn’t devalue their personal beliefs or affiliations, but can affirm and clarify the motivations that drive their involvement in development and justice.
  • Share your vision, purpose and values, and share and discuss your policy and guidelines on the separation or exclusion of non-development activity with partners and other key stakeholders to facilitate shared understanding
  • If necessary assist partners in training to help their staff and volunteers understand the reasons that separating development and non-development activities is critical for development effectiveness and assist your partner to develop their own policy on the separation or exclusion of non-development activity
  • Include explicit reference to the separation of non-development activities, including clear definitions, in partner agreements (or the equivalent) in order to ensure shared understanding and that such policy extends to partner and implementing organisations. This is a mandatory compliance requirement.
  • Monitor compliance of the clear separation or exclusion of non-aid and development activity through explicit reference in monitoring report templates and progress report templates
  • Where signatory organisation engage in non-development activities:
    • Ensure these dual activities are managed separately and can exists separately in a way that acknowledges the distinction between them
    • Do not incorporate such activities into programs designed to address poverty as this may exploit vulnerabilities[1]
    • Develop reporting tools that assist partners to report on and acquit non-development activities separately to development activities.
  • For signatory organisations that engage in non-development activities allow donors in online or printed fundraising materials to choose for their donation to be used for aid and development activities only or for non-development activities. Donors should be made aware that donations to non-development activities are not tax deductible. This is a mandatory compliance requirement.

[1] Proselytisation and Poverty, Church Agencies Network Statement, February 2014

Accountability to Primary Stakeholders and Complaints Mechanisms

It is vital to ensure accountability to primary stakeholders and that complaints mechanisms are informed by the perspectives of primary stakeholders and readily accessible and responsive to them. This is equally important whether your organisation works directly with primary stakeholders or whether you support the work of your local implementing partners to work directly with primary stakeholders.

If you support the work of your local implementing partners to work directly with primary stakeholders, ensure that they have established information sharing mechanisms, feedback mechanisms, and complaints mechanisms which are readily accessible for primary stakeholders. This may require your organization to provide resources and training to your partner, or link with other organisations who have well established accountability approaches. Whether your organisation is directly implementing or you are supporting local partners, the following practices are important in ensuring accountability to primary stakeholders and strengthening community based complaints mechanisms:

  • Share information as outlined above with primary stakeholders through community meetings or house to house visits to ensure that vulnerable or marginalised people who may not attend community meeting also have access. This could include information about your organisations vision, mission and values, the projects being implemented included budgets, the staff Code of Conduct and information on the expected behaviours of staff and any visitors to their community – including what would constitute unacceptable behaviour.
  • Develop a shared code of conduct in consultation with the community to really embed a shared ownership of acceptable and unacceptable behaviours of visitors and community members alike.
  • Consult with local staff and primary stakeholders to seek their perspectives and opinions on safeguarding or SEA risks which they may face. This involves more than just providing information – to develop a community based complaints mechanism is it important to seek the perspectives of primary stakeholders before designing your complaints mechanisms to ensure that the mechanisms are directly informed and shaped by the perspectives of primary stakeholders.
  • Seek out people who may not provide their opinions at community meetings or similar forums i.e. those who are marginalised or voiceless eg people with disability, the elderly, children, LGBTI. This may require household visits.
  • Ensure that consultations or feedback mechanisms ‘do no harm’ and protect the privacy, safety and security of those involved. For example, it may be necessary to speak to men and women in separate groups.
  • Consult with other agencies including NGOs, UN agencies, government entities to seek their local experience
  • Research the availability of local support or assistance services for the referral of complaints which fall outside of the responsibility or expertise of your organisation. Ensure this information is made available to your local implementing partners and primary stakeholders.
  • Undertake thorough stakeholder, gender and power analysis within communities so you have a good understanding of the risks and context
  • In designing your community based complaints mechanism, consider existing mechanisms within the community – these may or may not be useful depending on existing structures and power dynamics eg women may not feel comfortable reporting an incident to the male community leaders.
  • Ensure a range of accessible options for people to make complaints. These could include email, phone, text and the location of suggestions or complaints boxes placed around the community. These must be locked and only opened by an identified person from your partner or your own organisation.
  • Appoint male and female focal persons for primary stakeholders to communicate with.
  • Once you have designed your complaints mechanisms, reporting and incident management procedures, share this information widely with staff and primary stakeholders. Conduct a range of information sharing forums for staff and primary stakeholders to ensure they are confident and understand that it is confidential, victim/survivor focused, non-retaliatory and fair.
  • Translate this information into national and local languages and place this information in public places around communities. Ensure you consider literacy levels and use graphic symbols as well as text.
  • Refer to the Best Practice Guide Inter-Agency Community Based Complaint Mechanisms Protection against Sexual exploitation and Abuse, in the Resources Section below for more guidance.


DAISI’s C0mmitment to Principle  7.3 We are accountable to our stakeholders.