Read our full complaints procedure (currently under consultation).
1.1 This Complaints Procedure (the “Procedure”) provides a transparent route by which complaints under the Code of Conduct against NCVO Members are made, managed, and considered.
1.2 It facilitates the making of decisions that are fair, transparent, consistent, and explained clearly.
1.3 Through the Procedure, NCVO aims to uphold the Standards set out in the NCVO Member Code of Conduct (“the Code of Conduct”).
1.4 NCVO shall publicise and make available this Procedure to NCVO Members so that anyone who may wish to use it is aware of its existence and contents.
2.1 For the purposes of this Procedure, a complaint is an expression of dissatisfaction about the alleged behaviour of a Member of NCVO or their representatives or controlled organisations which is capable, if proven, of amounting to a breach of one or more of the Standards of the Code of Conduct. NCVO will also use this procedure where it brings a complaint on the basis of best interests and article 17(1)(e) of the Articles of Association.
2.2 A complaint can be made against a Member who:
2.3 A complaint can be made against a Member in connection with the alleged conduct of the Member as an organisation and also in connection with the alleged conduct of:
2.4 In this Procedure, where the context permits, a reference to a Member includes a reference to an organisation included within sub-section 2.3.1 and to a person included within sub-section 2.3.2.
2.5 A complaint may be made against a Member by:
2.6 In this Procedure, a person making a complaint shall be referred to as “the Complainant”.
2.7 A complaint will be determined in accordance with the Procedure in force at the time of the complaint. However, the Member’s conduct will be judged against the version of the Code of Conduct which was in force at the time the alleged conduct occurred.
2.8 A Member’s resignation from, or failure/refusal to renew membership whilst a complaint is being processed by NCVO will not normally invalidate the processing or determination of a complaint by NCVO or terminate the Procedure. For the purposes of dealing with a complaint only, the Member will be considered in continuous membership, until such time as the matter has been resolved or the Procedure terminated.
2.9 Where a Complainant withdraws its complaint at any stage of the procedure, NCVO may, where appropriate, continue to process the complaint.
3.1 Where the Complaints Manager or any other NCVO member of staff or appointee responsible for processing or supporting the processing of complaints under the Procedure is unable to comply with the timeframes specified in the Procedure, they shall inform all affected parties as soon as reasonably practicable, explain why the timeframe(s) cannot be met, and provide an alternative timeframe.
4.1 Complainants and Members shall, throughout this Procedure, otherwise than as required by law, keep all materials and documents relating to the Procedure and/or complaints confidential.
5.1 The NCVO Trustees have ultimate responsibility for the NCVO Member Code of Conduct and the procedures for the handling of complaints of breaches of the Code of Conduct. The NCVO Trustees are advised in this by the Governance and Nominations Committee and, where appropriate, the People, Culture and Inclusion Committee.
5.2 The Complaints Manager is a member of NCVO staff who receives, screens, handles and investigates complaints under this Procedure up to the appointment of a Complaints Panel (if a complaint is not resolved before then), and thereafter supports the Complaints Panel and the Appeal Panel (if an appeal is made) to enable the complaint to be determined in accordance with this Procedure.
5.3 A Complaints Panel determines whether complaints which have not been resolved informally to the satisfaction of the Complainant should be upheld and, if so, whether any sanctions should be imposed.
An Appeal Panel considers and determines appeals from Members against decisions of a Complaints Panel. It appoints an Appeal Examiner, who may be external to NCVO if the Panel considers it appropriate. The Appeal Examiner may (but need not) carry out further investigations and makes recommendations to the Appeal Panel. The Appeal Panel decides whether to uphold the appeal in whole or in part, or to dismiss it, and may modify or impose sanctions imposed on the Member.
5.4 The NCVO Trustees decide whether, on the recommendation of the Complaints Panel, a resolution should be passed to remove a Member from membership.
6.1 A Complaints Panel shall comprise three people from amongst the members of the Governance and Nominations Committee.
6.2 An Appeal Panel shall comprise three people from among the Trustees.
6.3 In appointing a Complaints Panel, the Complaints Manager shall be mindful that an Appeal Panel will need to be appointed if the Complaints Panel’s decision is appealed and that a person may not sit on the Complaints Panel and the Appeal Panel for the same complaint. Similarly, a complaint could result in a recommendation to the Trustees to remove a Member from membership and a Trustee who has sat on the Complaints Panel or the Appeal Panel for a complaint would not be able to take part in Trustee decision-making in relation to the Member concerned.
6.4 If it is not practicable to convene a Complaints Panel or an Appeal Panel in accordance with sections 6.1 or 6.2, as the case may be (for example because availability does not permit it or because Trustees are conflicted or because it is considered appropriate that there should be independent members on either or both Panels), a Complaints Panel or Appeal Panel, as the case may be, may be constituted as a committee comprising such persons as may be considered fit in accordance with Article 14 of NCVO’s Articles of Association, and the proceedings and powers of the committee shall be governed by this Procedure.
6.5 Members of a Complaints or Appeal Panel must declare any possible conflict of interest to the Complaints Manager. The Complaints Manager’s decision will be final as to whether there is a conflict of interest. The Complaints Manager may seek external advice for this purpose.
6.6 A member of a Complaints or Appeal Panel must recuse themselves if there is a conflict of interest which has not been waived.
6.7 Any decision of a Panel taken under this Procedure will be made on a majority or unanimous basis.
6.8 Where a Panel considers it appropriate, it may request that it be supported by a legal adviser who will play no part in the decision making under the Procedure.
7.1 Complaints should, other than in exceptional circumstances, be made within one year of the conduct giving rise to the complaint. Where the alleged conduct complained of consists of multiple instances, complaints should be made within one year of the most recent instance of the alleged conduct complained of.
8.1 Complaints must be made in writing, must identify the Member, must identify the Complainant and must be sent to the Complaints Manager at [EMAIL].
8.1.1 In exceptional circumstances where it is not appropriate to require a complaint to be in writing, a complaint may be accepted in another form.
8.1.2 Anonymous complaints will not normally be considered unless there is a compelling reason to do so and there is enough information in the complaint to enable either informal resolution or further investigation to be carried out. If an anonymous complaint is accepted on this basis, NCVO will take reasonable steps to maintain anonymity but anonymity cannot be guaranteed.
8.2 To be an eligible complaint, a complaint must include the following:
8.3 The Complaints Manager will respond within 10 working days of receipt of the complaint.
8.3.1 Where a complaint is eligible, the Complaints Manager may either:
(a) reject the complaint, if they consider the complaint or its subject matter:
(i) is frivolous or vexatious or otherwise an abuse of process;
(ii) clearly falls outside of the scope of this Procedure;
(iii) is a repetition of a complaint(s) previously considered by NCVO, unless there is substantial new evidence which was not available previously;
(iv) is based on the same facts as those where a Regulator, Police, court, or tribunal charges/investigation against a Member have been discontinued/dismissed, or a not guilty verdict/decision absolving the Member has been reached after investigation into or prosecution of allegations; or
(v) is subject to criminal or civil legal proceedings or to current investigations by the police or a Regulator or subject to proceedings before a Regulator; or
(vi) is being handled under the Member’s own complaint procedures.
(b) refer the complaint for informal resolution, if they consider:
(i) the complaint or its subject matter consist of allegations of minor breaches of the Code of Conduct;
(ii) the complaint requires little or no investigation;
(iii) the complaint could be resolved by the Member providing an explanation and/or an apology and, where possible, explaining what will be done to stop the behaviour alleged of re-occurring in the future; or
(c) refer the complaint for further investigation and consideration by a Complaints Panel.
8.3.2 Where a complaint is not an eligible complaint under section 8.2, the Complaints Manager will notify the Complainant explaining why the complaint is not eligible. Any Complainant will have 10 working days from receipt of this notification to resubmit an eligible complaint otherwise no further action in relation to the complaint will be taken. The Complaints Manager will process any eligible complaint so resubmitted in accordance with sub-section 8.3.1.
(a) Where the Complainant does not agree to keep matters confidential in accordance with sub-section 8.2.5 above, the Complaints Manager may decide to proceed with the complaint but thereafter shall not be required to keep the complainant informed of progress or of the determination of the Complaint.
(b) Where the Complainant does not include in their complaint the outcome sought in accordance with sub-section 8.2.4 above, the Complaints Manager shall list in their notification to the Complainant under this sub-section 8.3.2 the possible outcomes under this Procedure and ask the Complainant to identify their preferred outcome or outcomes. If the Complainant chooses not to identify a preferred outcome or fails to respond but all of the other eligibility criteria in section 8.2 are met, the complaint shall be deemed eligible and may proceed accordingly.
8.4 The Complaints Manager may undertake further research or enquiries to help them determine whether the complaint should be rejected, referred for informal resolution or referred for further investigation and consideration by a Complaints Panel.
8.5 The Complaints Manager may ignore a complaint or any correspondence from a Complainant where they reasonably consider that the complaint or correspondence is abusive or threatening towards them or other NCVO staff or trustees or where it constitutes harassment of the Complaints Manager or NCVO staff or trustees.
9.1 Where the Complaints Manager decides to reject a complaint pursuant to sub-section 8.3.1(a), their response to the Complainant will:
9.2 A Complainant has 10 working days from receipt of the Complaints Manager’s notification of rejection to request a review of the rejection decision by a Complaints Panel. If the Complainant does not request a review within this timeframe, the complaint shall be considered closed and no further action will be taken in relation to it.
10.1 Where the Complaints Manager decides to refer a complaint for informal resolution pursuant to sub-section 8.3.1(b), their response to the Complainant will:
10.2 Where the Complaints Manager decides to refer a complaint for informal resolution, they (or a member of their team) shall promptly notify the Member complained of in writing of the complaint, including:
10.3 On receipt of the Member’s response, the Complaints Manager shall forward it to the Complainant asking if this resolves matters.
10.4 If the Complainant does not consider the matter resolved, they shall have 10 working days to request that the complaint proceed to a determination. Otherwise, it is closed.
10.5 If the Member does not respond or refuses informal resolution, the complaint will proceed to investigation.
11.1 Where a complaint has been referred for further investigation, the Complaints Manager may conduct the investigation themselves, delegate it, or appoint an independent person.
11.2 The Complaints Manager will notify the Member and Complainant (if any) of the investigation and provide the name of the Investigator.
11.3 The Investigator will offer the Member at least 15 working days to respond.
11.4 The Investigator will produce a draft investigation report including:
11.5 The draft report will be shared with the Member and Complainant with at least 10 working days for comment.
11.6 A final investigation report will be prepared.
12.1 The Complaints Manager will appoint a Complaints Panel once the final investigation report is completed.
12.2 The Complaints Panel will determine complaints on paper, without attendance of parties.
12.3 The Panel will consider the final investigation report.
13.1 Findings are made on the balance of probabilities.
13.2 Where adverse decisions of another body exist, they will be accepted as proven save in exceptional circumstances.
13.3 The Panel will decide whether to dismiss or uphold the complaint, in whole or in part, and impose sanctions if appropriate.
13.4 The Member will be notified in writing within 10 working days.
13.5 The Complainant (if any), unless exceptional circumstances apply, will also be notified after 10 working days.
14.1 Where the Complaints Panel has upheld the complaint, it may impose one or more of the following:
14.2 Timeframes for compliance will be specified.
14.3 Where removal from membership is recommended:
14.4 Failure to comply with imposed sanctions may lead to review and possible recommendation for removal.
15.1 A Member may appeal a sanction within 20 working days of notification.
15.2 To be eligible, an appeal must be in writing, specify grounds, and may include new evidence. If not eligible, the Member has 5 working days (or until expiry of appeal window) to resubmit.
15.3 On receipt of an eligible appeal, an Appeal Panel will be appointed:
15.4 The Appeal Examiner will:
15.5 Appeal Panel will consider the final report within 20 working days.
15.6 The Panel may uphold, modify, or dismiss the appeal and impose any sanction available to the Complaints Panel.
15.7 The Member and Complainant (if any) will be notified within 10 days.
16.1 Complaints Manager shall keep full records of complaints, outcomes and reasons.
16.2 Where practicable and appropriate, feedback will be sought from Complainants and Members.
16.3 Governance and Nominations Committee will annually review complaints, trends, learning, and consider changes to the Code or Procedure.
16.4 The Committee shall review decisions to reject complaints. It may overturn and refer for informal resolution or investigation.
16.5 The Committee shall report promptly to the Trustees on compliance with these sections.
Last updated: 25 September 2025