External Complaints and Whistleblowing

ITTO acknowledges the value of receiving complaints as an important tool in understanding and responding to stakeholder’s expectations where the ITTO Secretariat will respond to all complaints in a prompt, fair and sensitive manner. We therefore welcome complaints and will respond constructively and in a timely manner. Complaints may be submitted by our supporters, donors, the general public, beneficiaries, official bodies and our partners.


1. Procedures

1.1 Complaints Handling Process

ITTO will receive and respond to all complaints irrespective of who makes them or the nature of the complaint. It is acknowledged that some complaints are of a more minor nature and can be resolved quickly and informally (informal resolution).
Where a complaint cannot be resolved easily and informally, the Complaints Handling Process described below should be followed.

1.1.1 Making a complaint

How can a complaint be made?
Complaints should be made through the online contact form located on ITTO’s website, which is the central point for all complaints.
Complaints can be forwarded in the three official ITTO languages.

1.1.2 Receiving a complaint

Who can receive a complaint?
Complaints lodged electronically will be received through the ITTO’s general administration e- mail at itto@itto.int and logged through ITTO’s established general internal administration procedures. Upon initial assessment by the Division of Operations on the veracity of any complaint received, a complaint will be referred to the manager responsible for the relevant area for appropriate action. In the event of a complaint being made verbally, it is important the staff member clarifies the issues, listens to what the complainant has to say and makes a brief and accurate written summary of the complaint. The staff member should also establish if the complainant needs assistance in making the complaint.
The employee receiving the complaint will record the following details:
  1. The name of the person/s making the complaint
  2. The date, time and location the complaint is received
  3. A brief description of the complaint and the expectations of the complainant
The primary officer in charge of investigating legitimate complaints will be the Director of Operations (dop@itto.int) or alternatively, the head of any other division (dti@itto.int / dfm@itto.int) if the complaint relates to a particular division/staff member. If a complaint is made against the Executive Director, the complaint will be referred to the ITTC Chairperson who will decide on appropriate action as necessary, including referring the complaint in a neutral and factual manner to an appropriate professional investigative entity (such as consultants and/or a legal entity).
A complaint lodged through an ITTO member shall be sent by the member to the ITTO Executive Director, who will take the necessary action as appropriate and report back to the ITTO member. If the complaint lodged by an ITTO member is against the Executive Director, the complaint will be referred to the ITTC Chairperson who will determine in consultation with the ITTO Officials on appropriate action to be taken, if any, including referring the complaint in a neutral and factual manner to an appropriate professional fraud investigative entity (such as consultants and/or a legal entity).
In some instances, a complainant may request that their identity is not divulged however it should be acknowledged this may restrict the resolution of the complaint.

1.1.3 Acknowledging a complaint has been received

Each complaint must be acknowledged as it is received. Acknowledgement will also include an outline of the next steps. If an oral complaint is received, the staff member should take the name and contact details so the outcome can be communicated without breaching privacy or confidentiality.

1.1.4 Registering Complaints

All complaints dealt with under the Complaints Handling Process, whether verbal or written are to be recorded in a Complaints Record log. These records will be used to ensure complaints are dealt with effectively, to monitor trends and to ensure continuous improvement of the complaints handling process.

1.1.5 Assessing and reviewing a complaint

Once a complaint has been received and acknowledged, the Director of Operations will make a preliminary assessment as to whether the issue raised merits further examination. In this context, the Director will take into account:
  • The identity of the party concerned and its interest in the matter;
  • Whether the issue is material and substantiated;
  • Whether there seems to be a link between ITTO activities and the issue raised;
  • How similar issues have been, or are being, treated in other domestic or international proceedings.
Following its preliminary assessment, the Director of Operations will respond to the parties concerned. If it is decided that the issue does not merit further consideration, the parties will be informed of the reasons for this decision.
If the Director of Operations determines that the complaint does merit further investigation, it will be referred to the manager responsible for the relevant area for appropriate action. Depending on the nature of the complaint, appropriate action can either constitute direct action by the relevant manager or potentially a more formal process by a third-party, independent investigator with appropriate expertise for the circumstances.

1.1.6 Remedy or System Improvement

At times, remedy and systems improvement may arise out of complaints dealt with under either Informal Resolution or under the Complaints Handling process. This procedure will be initiated by the relevant manager using the following steps.
  1. Assess if remedy and/or systems improvement is warranted or no action is required.
  2. Implement immediate remedy/system  improvement or plan future implementation of remedy/system improvement.
  3. Inform complainant of outcome
Remedy is action taken to correct or rectify a situation for an individual where it identified he/she has been treated poorly or unfairly by the system.
Systems improvement, where appropriate, is an opportunity to improve policies, procedures, organizational culture, or similar issues to prevent future problems.

1.1.7 Informing complainant of outcome

Once the complaint has been resolved, the complainant will be advised of the outcome ensuring the privacy of any individual involved in the matter.

1.1.8 Timeframe for Response

ITTO will seek to resolve complaints as quickly as possible and ensure complainants are regularly updated as to the progress or outcome of their complaint.

1.1.9 Appeals Process

  1. If the complainant is dissatisfied with the responses received from ITTO or if they believe action has not been taken, they may appeal to the next management level. If the matter involves a Director, it should be referred immediately to the Executive Director (ED). If the complaint involves the Executive Director, it should be referred to the Council Officers.
  2. Any response provided to an external complainant should be from the ED on behalf of the organization.  External complainants dissatisfied with the outcome are permitted to appeal to Council Officers.


  1. To ensure that the International Tropical Timber Organization (ITTO) functions in an open, transparent, ethical and equitable manner, with the objective of enhancing protection for individuals who report misconduct or cooperate with duly authorized investigations.


  1. It is the duty of staff members to report any breach of ITTO’s Regulations and Rules to the officials whose responsibility it is to take appropriate action. An individual who makes such a report in good faith has the right to be protected against retaliation.
  2. It is also the duty of staff members to cooperate with duly authorized and transparent investigations. An individual who cooperates in good faith with an investigation has the right to be protected against retaliation.
  3. Retaliation is defined for the purposes of this Policy as any direct or indirect detrimental action recommended, threatened or taken because an individual is engaged in an activity protected by the present policy. When established, retaliation is by itself misconduct.
  4. Consultants, contractors or their employees, agents or representative or any other individual engaged in business dealings with ITTO have a duty to report any breach of ITTO’s Regulations and Rules to the officials whose responsibility it is to take appropriate action.


  1. Protection against retaliation applies to ITTO Staff members who may use the procedures established in this Whistleblower policy to submit confidential complaints to:

    (a) Report the failure of one or more staff members to comply with his or her obligations provided in the ITTO Staff Regulations and Rules or other relevant administrative issuances, the Financial Rules and Rules relating to projects of the ITTO, including any request or instruction from any staff member to violate the above-mentioned regulations, rules or standards. In order to receive protection, the report should be made as soon as possible and not later than one (1) year after the individual becomes aware of the alleged misconduct. The individual must make the report in good faith and must submit information or evidence to support a reasonable belief that misconduct has occurred; or

    (b) Cooperate in good faith with a duly authorized and transparent investigation.
  2. The Whistleblower Policy is without prejudice to the legitimate application of regulations, rules and administrative procedures, including those governing evaluation of performance, non- extension or termination of appointment. However, the burden of proof shall rest with ITTO, which must prove by clear and convincing evidence that it would have taken the same action in the absence of the protected activity referred to in section 3.1 above.

False complaints

  1. A whistleblower who intentionally makes a false, fraudulent, malicious or frivolous complaint and which is subsequently found to be false shall be subject to disciplinary or other appropriate action.


Reporting misconduct through established internal/external mechanisms

  1. Reports of misconduct should in practice be made through the established internal mechanisms of ITTO. It is the duty of the Administration to protect the confidentiality of the reporting individual’s identity and all communications through those channels to the maximum extent possible.
  2. Protection against retaliation will be extended to an individual who reports misconduct to an entity or individual outside of the established internal mechanisms of ITTO, where the criteria set out in subparagraphs (a), (b) and (c) below are satisfied:

    (a) Such reporting is necessary to avoid: Substantive damage to ITTO’s operations; or Violations of national or international law; and

    (b) The use of internal mechanisms is not possible because:

    At the time the report is made, the individual has grounds to believe that he/she will be subjected to retaliation by the person(s) he/she should report to pursuant to the established internal mechanism; or

    It is substantially likely that evidence relating to the misconduct will be concealed or destroyed if the individual reports to the person(s) he/she should report to pursuant to the established internal mechanisms; or

    The individual has previously reported the identical information through the established internal mechanisms, and ITTO has failed to inform the individual in writing of the status of the matter within six(6) months of such a report; and

    (c) The individual does not accept payment or any other benefit from any party for such report.
  3. Individuals unable or unwilling to make a report of misconduct due to the circumstances described in paragraph 5.1 or 5.2 are encouraged to make the report to one of the Council officers (Council Chair, Council Vice-Chair or the Chairperson, Committee on Finance and Administration). Current contact information for Council Officers shall be maintained and posted in a place accessible to all ITTO staff members.

Reporting Retaliation

  1. Individuals who believe that retaliatory action has been taken or may be taken against them because they have reported misconduct or cooperated with a duly authorized and transparent investigation should forward all information and documentation available to them substantiating their complaint to one of the Council Officers (Council Chair, Council Vice- Chair or the Chairperson, Committee on Finance and Administration (CFA) as soon as possible. Complaints may be made in person, by regular mail, fax or by e-mail.
  2. The functions and responsibilities of the Council Officers described in paragraph 6.1 with respect to protection against retaliation for reporting misconduct or cooperating with a duly authorized investigation are as follows:

    To receive complaints of retaliation or threats of retaliation; To keep a confidential record of all complaints received; and
    To conduct a preliminary review of the complaint to determine if (i) the complainant engaged in a protected activity; and (ii) there is a prima facie case that the protected activity was a contributing factor in causing the alleged retaliation or threat of retaliation.
    These processes will be undertaken in a collaborative manner.
    Individuals making the disclosure will be offered and afforded confidential liaison with the Council Officer to whom the disclosure was first made. That Council Officer will serve as the principal point of contact for the duration of these actions.
  3. The Council Officers will seek to complete a preliminary review within 45 days of receiving the complaint of retaliation.
  4. All officers and staff members shall cooperate with the Council Officers and provide access to all records and documents requested by the Council Officers, except for medical records that are not available without the express consent of the staff member concerned.
  5. If the Council Officers find that there is a credible case of retaliation or threat of retaliation, they will normally refer the matter in writing to the Executive Director for investigation and will immediately notify in writing the complainant that the matter has been so referred. The Executive Director will seek to complete his investigation and submit a report to the Council Officers at the next session of the Council. If the Council Officers have concerns that the Executive Director cannot or will not act impartially, the case will be referred to the Council Chair and Vice-Chair.
  6. Pending the completion of the investigation, the Council Officers may recommend that the Executive Director take appropriate measures to safeguard the interests of the complainant, including but not limited to temporary suspension of the implementation of the action reported as retaliatory and, with the consent of the complainant, temporary reassignment of the complainant within or outside the complainant’s office or placement of the complainant on special leave with full pay.
  7. Once the Council Officers have received the investigation report, they will inform in writing to the complainant of the outcome of the investigation and make their recommendations on the case to the Executive Director. The recommendations may include disciplinary actions to be taken against the retaliator.
  8. If the Council Officers find that there is no credible case of retaliation or threat of retaliation but finds that there is an interpersonal problem within a particular office, they will advise the complainant to seek recourse via informal mechanisms of conflict resolution within ITTO.
  9. If the Council Officers determine that there is a managerial problem based on the preliminary review of the complaint they will advise the Executive Director accordingly.
  10. Where, in the opinion of the Council Officers, there may be a conflict of interest in ITTO conducting the investigation, they may recommend to the Executive Director that the complaint be referred to an alternative transparent investigating mechanism.

Protection of the person who suffered retaliation

  1. If retaliation against an individual is established, the Council Officers may, after consultation with the individual who has suffered retaliation, recommend to the Executive Director appropriate measures aimed at correcting negative consequences suffered as a result of the retaliatory action. Such measures may include, but are not limited to, the rescission of the retaliatory decision, including reinstatement, or, if requested by the individual, transfer to another office or function for which the individual is qualified, independently of the person who engaged in retaliation. If requested, the individual shall be provided with professional counseling to be paid for by ITTO.

Action against the person who engaged in retaliation

  1. Retaliation against an individual because that person has reported misconduct on the part of one or more ITTO officials or cooperated with a duly authorized investigation of the ITTO constitutes misconduct which, if established, may lead to disciplinary action and/or transfer to other functions in the same or a different office.

Prohibition of retaliation against outside parties

  1. Any retaliatory measures against a Consultant, Contractor or its employees, agents or representatives or any other individual engaged in any dealings with the ITTO because such person has reported misconduct by ITTO staff members will be considered misconduct that, if established, will lead to disciplinary or other appropriate action.

Staff Regulations and Rules

Rule 801
Joint Disciplinary Committee
  1. A Joint Disciplinary Committee shall be established by the Executive Director and will be available to advise him in disciplinary cases involving staff members.
  1. The Joint Disciplinary Committee will consist of three members, namely:
  1. The Head of Administration
  2. The Head of one other division to be appointed by the Executive Director
  3. One member elected by the staff.
Rule 802
Disciplinary Measures
Disciplinary measures that may be imposed include written censure, suspension without pay, demotion or, in the case of serious misconduct, dismissal.
Rule 803
Suspension Pending Investigation
If a charge of misconduct is made against a staff member and the Executive Director so decides, the staff member may be suspended from duty pending investigation, the suspension being
without prejudice to the rights of the staff member. Suspension pending investigation shall not be considered a disciplinary measure. Such suspension shall be with pay unless, in exceptional circumstances, the Executive Director, based on the advice of a Joint Disciplinary Committee, decides that suspension without pay is appropriate.

Rule 804
Joint Disciplinary Committee Procedure
In considering a case the Joint Disciplinary Committee shall act with maximum dispatch, while ensuring the staff member’s ability to prepare an adequate defense. As a general rule, consideration of a case by the Joint Disciplinary Committee shall be completed and a report made to the Executive Director within thirty (30) days from the time a charge of misconduct is made. The Executive Director shall make a decision within one week after receiving the report and recommendation of the Joint Disciplinary Committee.
Charges of misconduct and supporting evidence shall be presented in writing to the staff member no later than two weeks prior to a hearing before the Joint Disciplinary Committee. The staff member may present a defense either orally or in writing. A staff member shall be permitted to appear before the Joint Disciplinary Committee or may arrange to have his or her case presented by any other staff member. The Joint Disciplinary Committee shall maintain a record of its proceedings.
Rule 805
An appeal against the Executive Director’s decision on disciplinary action including termination of appointment under Regulation 7.1 (b) may be addressed to the Chairman of the Council within one month from the time the staff member received notification of the decision in writing. The Chair of the Council will refer the appeal to a five member panel composed of himself/herself, the Vice-Chair of the Council, and the Chairs of three of the Committees (to be chosen jointly by the Council Chair and Vice-Chair). The decision of this panel, which shall be taken within thirty (30) days, shall be final
Governance and compliance

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