Policy & Procedure
Complaints Policy & Procedure
Name of Author Chief Executive Officer
Approved by Board of Directors
Approval dates November 2012 (version 1)
September 2015 (version 2)
October 2017 (version 3)
April 2020 (version 4)
Review Date October 2021
POLICY and PROCEDURES
Hockey Wales is responsible for setting and maintaining standards within the sport and for ensuring that a complaints policy and associated procedures are in place. All members are responsible for being aware of and abiding by the Hockey Wales rules and regulations and for maintaining high standards. Any complaints that arise will be dealt with as promptly as possible and appropriate action will only be considered when the facts have been established. Any action will always be appropriate to all the circumstances of the complaint in question and processes and procedures will be applied in a consistent manner.
Hockey Wales Policy and Procedures for dealing with Complaints
Hockey Wales is responsible for setting and maintaining the standards of service delivery to our members and stakeholders and is committed to dealing with any complaint equitably, comprehensively and in a timely manner.
Dealing with Complaints
The emphasis of the Complaints Procedures of Hockey Wales will be on the early resolution of problems with a minimum of disruption to members.
All complaints will be dealt with sympathetically, fairly and honestly
Responses to complaints will be as full and detailed as possible
If Hockey Wales, its staff, volunteers or usual processes are found to be at fault that will be acknowledged, and the complainant will be informed of any future action to be taken to prevent similar problems occurring again.
A complaint that is not linked in any way to an action that might be associated with a criminal, disciplinary, anti-doping or safeguarding offence is defined as:
an expression of dissatisfaction about an action (or inaction) or decision (or policy) of Hockey Wales as a corporate body, or by one of its staff, or by a Director or other volunteer acting in any capacity on behalf of the Company
a complaint may initially be made verbally (the complainant will be asked to follow it up in writing in the majority of cases) or in writing, either by letter or e-mail
Who will deal with complaints
In all cases the complaint will be directed to the most appropriate person:
Person/body against whom complaint is made
Response to the Complaint
Additional/subsequent response if complaint not satisfied
Hockey Wales as a corporate body or one or more of its Directors
Letter or email confirming receipt of complaint and name of person to whom the complaint has been referred
Chief Executive Officer (CEO)
Chief Executive Officer
Chair or CEO Line Manager
CEO unless the CEO is the Line Manager then the matter will be referred to the Chair
Person working on behalf of Hockey Wales in self-employed capacity, or as a volunteer e.g. coach, tournament official, committee member
The member of staff responsible for the relevant area
e.g. performance, development, events
Chair or other Director with lead responsibility
All complaints will be acknowledged in writing by letter or email usually within 3 working days of receipt. The acknowledgement will confirm the person to whom the complaint has been directed and inform the complainant of the procedure that will be followed in dealing with the matter and if possible, the likely timescale. A standard initial response format should be used.
The person receiving the complaint will either deal with it themselves or pass it to the appropriate person to deal with, as shown above.
The person dealing with the complaint will:
Determine the facts of the matter as required – actions to determine the facts will vary on a case by case basis
Keep the complainant informed of progress with regard to their complaint, particularly important if there is likely to be a delay in answering the complaint for any reason
Write to the complainant answering their concerns and giving explanation(s) where appropriate within 10 working days unless a longer period is required in order to obtain information
If the complainant is not satisfied with the response the person who has dealt with the complaint will endeavour to resolve any further issues raised and will respond again in writing.
In the event that the complainant is still not satisfied the complaint will be referred to the subsequent responder as indicated above or their equivalent. Any subsequent correspondence will be dealt with within the same timescales.
Hockey Wales should not enter into lengthy and extended correspondence with the complainant once the original complaint and any subsequent substantive issues have been answered and/or resolved as far as Hockey Wales is concerned. The CEO or Chair as appropriate should bring the matter to a close, in the most amicable way possible, if they believe that nothing will be gained by either party through continuance of the discussions.
Unreasonably Persistent or Vexatious Complaints
Hockey Wales does not expect employees or key volunteers to tolerate unacceptable behaviour by complainants at any time during the general complaints’ procedure. Unacceptable behaviour includes behaviour which is abusive, offensive or threatening and may include
Using abusive or inappropriate language on the telephone or face to face
Abusive or inappropriate text messages
Abusive or inappropriate use of Social Media
Sending multiple emails
Leaving multiple voicemails
Raising legitimate queries or criticisms of the complaints procedures as it progresses, e.g. if agreed timescales are not met, should not in itself lead to someone being regarded as a vexatious or an unreasonably persistent complainant.
Similarly, the fact that a complainant is unhappy with the outcome of a complaint and seeks to challenge it once, or more than once, should not necessarily cause him or her to be labelled vexatious or unreasonably persistent.
Hockey Wales will take action to protect employees and key volunteers from inappropriate behaviour. If a complainant behaves in a way that is unreasonably persistent or vexatious, these procedures will be followed.
Hockey Wales defines unreasonably persistent and vexatious complainants as those complainants who, because of the frequency or nature of the complaints, they hinder the work of the organisation. The description ‘unreasonably persistent’ and ‘vexatious’ may apply separately or jointly to a particular complainant. Examples include the way or frequency that complainants raise their complaint with employees or how complainants respond when informed of a decision about their complaint.
Features of an unreasonably persistent and/or vexatious complainant include the following and may result from a combination of some or all of these features (the list is not exhaustive, nor does one single feature on its own necessarily imply that the person will be considered as being in this category):
have insufficient or no grounds for their complaint and be making the complaint only to annoy (or for reasons that he or she does not admit or make obvious)
refuse to specify the grounds of a complaint despite offers of assistance
refuse to co-operate with the complaints investigation process while still wishing their complaint to be resolved
refuse to accept that issues are not within the remit of the general complaints policy and procedures despite having been provided with information about the scope of the policy and procedures
refusal to accept that issues are not within the power of Hockey Wales to investigate, change or influence (examples could be a complaint about Sport Wales, or something that is the responsibility of another organisation)
insist on the complaint being dealt with in ways which are incompatible with the complaint’s procedures or with good practice (e.g. that there must not be any written record of the complaint)
make what appear to be groundless complaints about the person dealing with the complaint and seek to have them dismissed or replaced
make an unreasonable number of contacts by any means in relation to a specific complaint or complaints
make persistent and unreasonable demands or expectations of staff and/or the complaints process after the unreasonableness has been explained to the complainant (an example of this could be a complainant who insists on immediate responses to numerous, frequent and/or complex letters, telephone calls or emails)
raise numerous subsidiary or new issues whilst a complaint is being addressed that were not part of the complaint at the start of the complaint process
introduce trivial or irrelevant new information whilst the complaint is being investigated and expect this to be taken into account and commented on
change the substance or basis of the complaint without reasonable justification whilst the complaint is being addressed
adopt an excessively ‘scattergun’ approach, e.g. pursuing a complaint or complaints not only with Hockey Wales, but at the same time with Sport Wales, the Welsh Government, a Member of Parliament, their local council, elected councillors, the police, solicitors and/or any other body
refuse to accept the outcome of the complaint process after its conclusion, repeatedly arguing the point, complaining about the outcome and/or denying that an adequate response has been given
make the same complaint repeatedly, perhaps with minor differences, after the complaints’ procedure has been concluded and insist that the minor differences make these 'new' complaints which should be put through the full complaints’ procedures
persistently approach Hockey Wales through different routes about the same issue
persist in seeking an outcome which has been explained is unrealistic for legal or policy (or other valid) reasons
refuse to accept documented evidence as factual
complain about or challenge an issue based on a historic and irreversible decision or incident
If it is suggested that a complainant is acting in an unreasonably persistent or vexatious way the CEO will ensure that the complaint is being, or has been, investigated properly according to the complaints procedures before any further action is taken.
The CEO will contact the complainant either by telephone, in writing or by email to explain why their behaviour is causing concern and ask them to change this behaviour. The CEO will explain the actions that Hockey Wales may take if the behaviour does not change.
If the disruptive behaviour continues, the CEO will issue a reminder letter to the complainant advising them that the way in which they will be dealt with by Hockey Wales in future will be restricted. The CEO will make this decision following consultation with the Chair and inform the complainant in writing of what measures have been put in place and for what period.
Any restriction that is imposed on the complainant’s contact will be appropriate and proportionate and the complainant will be advised of the period of time the restriction will cover. In most cases restrictions will apply for between 3 and 6 months but in exceptional cases may be extended. In such cases the restrictions would be reviewed on a quarterly basis.
Restrictions will be tailored to deal with the individual circumstances of the complainant and may include:
prohibiting the complainant from making contact by telephone except through a third party acting on their behalf
prohibiting the complainant from sending emails to individual and/or all employees and insisting they only correspond by letter
requiring contact to take place with one named member of staff only
restricting telephone calls to specified days / times / duration
requiring any face to face contact to take place in the presence of an appropriate witness
letting the complainant know that Hockey Wales will not reply to or acknowledge any further contact from them on the specific topic of that complaint (in this case, a designated member of staff should be identified who will read future correspondence)
When the decision has been taken to apply this policy to a complainant, the CEO will contact the complainant in writing (and/or as appropriate) to explain:
why Hockey Wales has taken the decision
what action(s) are being taken
the duration of that action
the review process of this policy and
the right of the complainant to contact the Board of Directors about the fact that they have been treated as a vexatious/persistent complainant
Where the behaviour is so extreme, or it threatens the immediate safety and welfare of staff and/or volunteers Hockey Wales will consider other options e.g. reporting the matter to the police or taking legal action. In such cases, Hockey Wales may not give the complainant prior warning of that action.
In every case, full and complete records of all decisions and actions will be maintained in line with the Hockey Wales Data Retention procedures or equivalent.
For further information about any aspect of the Hockey Wales Complaints Policy and Procedures, please contact:
Sport Wales National Centre