Compliance: Your opportunity to make a complaint

As a feminist organisation, we appreciate how important a structural framework and processes are for the prevention of violence or abuse of power, and for upholding rights. For this reason, we also need organisational guidelines and complaint channels that clearly indicate how to proceed if any violations have occurred. These need to protect the complainants.

As an internationally active feminist women’s rights organisation from the Global North who works together with partner organisations in conflict regions and who supports them as a funder, we take a self-critical approach to the resulting power imbalances. These power inequalities place a special responsibility on us and make it essential for us to take a critical look at power, especially within our cooperations with partner organisations and in our encounters with target groups in the Global South. We rigorously reject all forms of abuse of power, violence and exploitation.

We have an obligation to the women and girls we work for, our donors, funders, cooperation partners and the public to use our funds efficiently in line with the objects of our association, ensuring no corruption, embezzlement or fraud takes place. We do this in a way which also fulfils our transparency requirements as a member of the Transparent Civil Society Initiative, complies with the VENRO Code of Conduct, and meets the legal requirements of Germany’s Whistleblower Protection Act (HinSchG).

We have put a complaints mechanism and corresponding organisational guidelines in place, including a Safeguarding Policy, an Anti-Corruption Policy, a Security Policy, a Social Media Policy and a Complaints Policy. We are committed to providing the necessary resources (time, finances, know-how, technical means) to ensure that complaints can be submitted and processed at any time.

You can submit a complaint via an encrypted form on our website. This is then processed internally or with the support of external experts (lawyers, auditing firms, conflict mediators, child protection experts) according to a standardised procedure. Internal complaints channels are also available for employees.

It is a high priority for us to ensure safety and protection for those affected and for witnesses. In the event of cases of violence or breaches of protection during our cooperation with partners, we will do everything we can to help protect the people at risk.

We are committed to the European General Data Protection Regulation (GDPR) and the legal requirements for data protection within the framework of Germany’s Whistleblower Protection Act (HinSchG §11). Throughout the entire procedure, only the people directly involved in processing the case have any knowledge of the identity of the complainant, witness or accused. At the end of the investigation and regardless of its outcome, documents are stored in accordance with data protection requirements and the HinSchG, and they are deleted after the retention periods have expired.

Reprisals against whistleblowers are prohibited and it is part of our legal obligation under the Whistleblower Protection Act to ensure no reprisals occur. It is important to us that all our staff, partners and others with whom we work should have no need to fear consequences if they complain or raise concerns about what they have experienced or observed. The entire process, including the identity of the witnesses and the affected or accused persons and their data, has to be conducted confidentially, protecting privacy and obeying any applicable data protection guidelines.

The complaint is sent as an encrypted, confidential message via our complaint form to an external ombudswoman for preliminary examination. It is then forwarded by her either to the person within medica mondiale responsible for compliance or to our Supervisory Board. Each complaint is processed using a standardised procedure. For each complaint, an appropriate case management team is put together to deal with the specific case. This team consists of people who are familiar with the subject of the complaint, the context and/or the facts of the case, but who are not themselves involved or biased.

If a complaint is directed against the Board of Directors, then the case is handled by the Supervisory Board as the elected representative of the association. Where necessary, support is obtained from external compliance managers or legal advisors. It is also possible to submit an anonymised complaint.

Every complainant is free to contact the ombudswoman again after the complaint procedure has been concluded and to apply to the Supervisory Board for a review of the case.

The complaint form is intended for anyone who works at or with medica mondiale or its partner organisations, anyone who is associated with medica mondiale, or anyone who is a beneficiary of its projects and programmes, as well as for external parties who have become aware of a violation of the law by the organisation. The complainant may be affected themselves or they can be a trusted representative of an affected person, or they can submit a complaint as a witness.

A complaint is an official notification of a potential misconduct or unlawful incident in the context of the work of medica mondiale. Complaints can be submitted for issues that are set out in donor guidelines or policies to which medica mondiale is committed, or for cases where a law or regulation has been breached. In particular, it is a priority for medica mondiale that this procedure is applied to incidents related to the protection and safety of survivors of sexualised and gender-based violence and to child protection.