When a complaint is submitted to the integrity advisor, a report will be drafted by the advisor and sent to Dynamo International’s management. The report should only be based on objective information directly related to the complaint and strictly necessary for the investigation. The report must also clearly indicate the allegations that have been made.
Management will take all the decisions it deems relevant with regard to the submitted facts. However, regardless of management’s decision, the integrity advisor reserves the right to continue with their investigation.
Informing the accused
The accused staff member must be informed in writing about the complaint when a complaint is submitted via the integrity advisor. The following information must be provided:
- The allegations made against them.
- The staff member’s right to access their personal data.
- How and under what conditions the staff member can contact the integrity advisor in order to exercise their rights.
However, the staff member must only be informed about the facts relating to them or which are sufficient to identify them. The accused staff member should not be informed about the identity of the staff member who submitted the complaint.
The accused staff member should be informed as soon as possible after the testimony or complaint is received.
However, if the integrity advisor has reasonable grounds to believe that the accused person may destroy data, manipulate records, or compromise the inquiry in any way, the accused person may not be informed until the relevant protection measures have been taken.
Informing the staff member or third party who submitted the complaint
If deemed appropriate by the integrity advisor, the staff member or third party who submitted the complaint may be kept informed about the progress and findings of the inquiry.
However, these updates should not compromise the inquiry or involve the disclosure of confidential information.
Inquiry following a complaint
Once a complaint has been made to the integrity advisor, the advisor must determine if there are sufficient grounds to carry out an inquiry into the complaint.
The advisor must take into account the following information, among other factors: the events mentioned in the complaint, the characteristics of the allegations, and whether or not the complaint contains any sources of information, including any details that corroborate the allegations.
The inquiry must be conducted within a reasonable timeframe and in a fully confidential manner.
The integrity advisor can exercise reasonable discretion and decide not to launch an internal inquiry, if, for instance, the complaint does not fall within their remit, if it contains vague or unclear allegations of abusive behaviour, which are not backed up by facts or sources of information, of if other circumstances make an inquiry pointless or impracticable. The integrity advisor will advise management of their decision not to conduct an inquiry.
Once the inquiry has been completed, the integrity advisor sends a full report to Dynamo International’s management. Management will take appropriate and effective measures to correct the abusive behaviour, in line with the organisation’s existing policies and procedures.
Third-party service providers
Dynamo International may utilize third-party services to assist with the management of complaints and questions depending upon the nature of the complaint or inquiry.