ACC Board Complaints Policy
adopted on 28 November 2013
COMPLAINTS
Purpose
1.
The purpose of this policy is to ensure that when a Board Member receives, directly or
indirectly:
(a)
any complaint or allegation relating to ACC, or
(b)
any request for the Board Member to intervene in relation to any ACC matter
("
complaint"), the complaint is dealt with in accordance with ACC policies and
procedures, including the ACC Issues Management Process and ACC's "business as
usual" complaints procedures. Complaints made to Board Members are not accorded
substantively different treatment to other ACC complaints.
This policy protects ACC and the Board from allegations of unequal treatment of
complainants, and protects Board Members from allegations of improper interference in
management of ACC's operations, or failure to disclose actual or potential conflicts of
interest.
Process
2.
Board Members should remain alert to the circumstances in which a perceived conflict
of interest may arise (see section 4.4 of the Board Governance Manual - Management
of Interests and Conflicts of Interest). In general, a Board Member should decline to
engage in a direct dialogue with individual complainants and should seek to direct
complaints to the appropriate channels within ACC. A Board Member should not make
arrangements to hear or discuss a person's complaint without obtaining the Chair's prior
approval. However, from time to time, Board Members will nonetheless receive
complaints. Board Members should disclose all such approaches.
3.
The following process, coordinated by the Company Secretary, should be followed when
a complaint is made to a Board Member:
4.
Step One - Forwarding of complaint: A Board Member who receives a complaint
should notify the Company Secretary of the complaint as soon as practicable. The
Board Member should also, if appropriate, inform the complainant at the time that they
will not be able to deal with the complaint personally, but will ensure that it is considered
by ACC. If the complainant is identifiable, the Company Secretary shall send a standard
form letter on the Board Member's behalf stating that the complaint has been referred to
them by the Board Member and that the complaint will be considered in due course and
following standard ACC complaint procedures.
5.
Step Two - ACC complaint procedures: The Company Secretary shall, as soon as
practicable and in consultation with the Corporate Issues Manager, ensure that the
impact, likelihood and urgency of the complaint is evaluated in accordance with the
Strategic Risk Rating Framework and that the complaint is then assigned to a
responsible manager within ACC's Issues Management Process or ACC's "business as
usual" complaints procedures at an appropriate level.
6.
Step Three - Reporting: The Company Secretary shall, in respect of each complaint:
(a)
confirm to the Board Member and the Chair that the complaint is now being
considered under the appropriate ACC procedures, and
(b)
once the complaint has been finally dealt with, "close the loop" by informing the
Board Member.
7.
Board Members will not normally be involved in the investigation or resolution of any
complaint they have received, and will not normally be briefed on the ongoing progress
of such complaint simply because it was made to them. Should the Board Member wish
to know such information, he or she should raise the request with the Chair.
8.
Under ACC's Strategic Risk Rating Framework and Issues Management Process, the
Board will be advised of all "severe" and "extreme" risks, including those arising in
relation to complaints. Management will also periodically brief the Board on complaints
received by ACC, and their resolution, which may include those received by Board
Members directly.
9.
Step Four: To ensure transparency, when the Company Secretary is notified of a
complaint received by a Board Member, he or she will record the details in a
"Complaints Register", will record the process that has been determined for the
complaint to be considered by ACC, and will note when the complaint has been finally
resolved.
Review
10.
This policy should be reviewed as part of the Governance Manual review on an annual
basis.