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Complaint Policy and Process

Atlas Assistance Dogs® Complaint and Whistleblower Policy and Process

You may access the Complaint Form here. We strongly recommend you read through this entire policy to understand our policy and process.

Purpose

This policy provides:
  1. A clear, accessible, and transparent process for Atlas stakeholders and the general public to voice their concerns or complaints regarding any aspect of the organization’s operations, conduct, decisions, or impact.
  2. A commitment to protect whistleblowers from retaliation for filing a complaint through this policy or providing information to a law enforcement officer or regulatory body.
  3. An affirmation of Atlas’ core value of honesty, integrity, and transparency.

Scope

Complaints may apply to any Atlas Assistance Dogs:
  • Process, policy, decision, or event
  • Course, publication, or communication/social media channel
  • Representative
  • Partner and collaborator where concerns are related to partnerships, joint initiatives, or shared projects
Complaints specific to whistleblowers may apply to serious concerns regarding:
  • Misconduct
  • Unethical behavior
  • Illegal behavior
  • Misuse or theft of Atlas funds
  • Other serious concerns

Definitions

Stakeholder: An individual or group that has an interest in any Atlas decision or activity, including employees, volunteers, students, donors, contractors, certified trainers, and clients.
Representative: An individual who acts on behalf of Atlas Assistance Dogs, either inside or outside the organization, including but not limited to employees, Board members, advisors, volunteers, clients, Team Facilitators, Atlas Certified Trainers, and independent contractors.
Whistleblower: Any Atlas representative who reports complaints or concerns about suspected ethical or legal violations either to Atlas or to a law enforcement agent.
Acting in Good Faith: Having reasonable grounds for believing the information reported in a complaint is true and acting without malice towards the organization or any individual within the organization.
Impartial Review Officer: An individual who may or may not be on the Board who is designated to oversee the appeals process, ensuring a fair and unbiased evaluation of complaints that have progressed beyond initial resolution attempts.

Policy Statement

It is the policy of Atlas Assistance Dogs that:
  1. All stakeholders should have an opportunity to present complaints and to appeal management decisions through a dispute resolution process that fosters a culture of open communications, continuous improvement, and trust.
  2. Atlas welcomes having issues and problems brought to our attention so that we have an opportunity to correct them and improve the effectiveness and credibility of the organization.
  3. Atlas will attempt to promptly resolve all disputes that are appropriate for handling under this policy.
  4. Atlas will attempt to resolve disputes or complaints by the people closest to the issue.
  5. Atlas will protect whistleblowers from retaliation by any Atlas representative for internal or external reporting of perceived wrongdoing by Atlas Assistance Dogs or any Atlas representative.
  6. So long as the Atlas representative has acted in good faith, Atlas will not take any negative action toward them even if their claim is determined to be unfounded. Moreover, Atlas will not take negative action toward anyone who, in good faith, cooperates in the investigation of a reported violation. Any allegations that prove not to be substantiated and which prove not to have been made in good faith will be viewed as a serious disciplinary offense.
  7. Documents and other records associated with a complaint may not be destroyed or altered in any way if an investigation is underway or if Atlas has been notified by a regulatory agency that an investigation is pending.
  8. Records will be maintained in accordance with the Atlas Record Retention Policy. Access to records will be governed by the Atlas Sensitive Information Policy.

Responsibilities

The Atlas Board has overall responsibility for ensuring this policy is followed and all issues identified through the complaint process are promptly addressed, resolved, and documented. The Board is specifically responsible for addressing issues related to the actions or policies of the Corporation and for issues escalated to the Board through the complaint resolution process. The Board will ensure that the Complaint Policy and process are presented to new Board members during onboarding.

The Director of Operations and Programs (DoOP) is initially responsible for all issues related to operations and programs including academy programs, client certification, Team Facilitators, staff, and volunteer issues. If the DoOP is not available to respond to a complaint, the President will assign someone to act on behalf of the DoOP.

The DoOP is also responsible for ensuring that this policy and the complaint form are available on the Atlas website and that information regarding this policy and the process for filing complaints and issues are explained to new employees, independent contractors, and volunteers during orientation.

Procedures

  1. Receipt of Complaint:
    Anyone who has a complaint against Atlas or a representative of Atlas should promptly report the facts of the complaint or incident and the names of the individuals involved using the Atlas Assistance Dogs Complaint Form, available here.
    All complaints should be acknowledged within two business days of receipt.
  2. Documentation:
    Every complaint will be documented, recording the date received, the nature of the complaint, and the details provided by the complainant.
  3. Initial Assessment:
    Depending on the nature of the complaint, the Director of Operations and Programs and/or a designated member of the Board will assess the complaint to determine its nature and seriousness and to determine whether the complaint can be resolved informally or requires a formal investigation.
  4. Confidentiality:
    Confidentiality must be maintained throughout the process. Information related to the complaint may be shared only with those individuals necessary for the resolution of the complaint. Access to information is governed by the Atlas Sensitive Information Policy.
  5. Investigation:
    If the complaint requires formal investigation, the Board or the Director of Operations and Programs will appoint an unbiased investigator or committee who will gather information, interview relevant parties, and review documents or other evidence. The investigation should be completed within 30 days.
  6. Response:
    If informal resolution is applicable, the complainant will be contacted by the Director of Operations and Programs. In the case of complaints requiring a formal investigation, the complainant will be informed through email that their complaint is being investigated and they will be advised of the process and timeline for the investigation. Once the investigation is complete, the individual or individuals conducting the investigation formulate a response. The response should include a summary of the findings and any actions to be taken.
  7. Resolution:
    A member of the Board of Directors or the Director of Operations and Programs will notify the complainant of the decision. If the decision is not satisfactory to the complainant, they will be informed of their right to appeal the decision to the Board. The Board will Consider feedback for improving policies and practices. A summary of the complaint, resolution, and suggested corrective actions will be reported to the Board at the next Board meeting.
  8. Recordkeeping:
    A record will be kept of the complaint, the investigation process, any documentation provided with the complaint, and the resolution. All documentation must be maintained from initiation through initial resolution and resolution of any appeals plus an additional seven years.
  9. Appeals Process:
    If the complainant and the person investigating the complaint are not able to resolve the issue or if the complainant is dissatisfied with the decision, the complainant may appeal to the Atlas Board. The Board President will appoint a disinterested individual who is not party to the complaint and was not involved in the initial process as an Impartial Appeals Officer. This role is crucial in upholding the fairness and integrity of the complaint resolution process, providing an unbiased review and recommendation to ensure that all parties receive a fair and impartial hearing. In the case that the Board President is party to the complaint, another non-involved officer will appoint the Impartial Appeals Officer with the following duties.
    • Review Documentation: The Impartial Appeals Officer is responsible for a comprehensive review of all documentation related to the complaint. This includes initial reports, evidence submitted by both parties, the initial decision, and any additional materials provided during the appeal process.
    • Ensure Impartiality: They must maintain an unbiased stance throughout the review process, having had no prior involvement or influence in the initial complaint or decision-making process.
    • Conduct Discussions: If necessary, the officer may hold discussions with the involved parties to clarify details, ask further questions, or gather additional insights that could be crucial for the appeal review.
    • Assessment and Recommendation: Based on the review, the officer assesses the validity and fairness of the initial decision and the merits of the appeal. They then formulate a recommendation to the board, which may affirm, reverse, or modify the initial decision.
    • Report to the Board: The officer presents their findings and recommendation to the board in a clear and structured manner, ensuring that the board has all necessary information to make a well-informed final decision on the complaint.
    • Adherence to Policies and Bylaws: Throughout the process, the Impartial Appeals Officer must adhere to the organization’s policies, bylaws, and ethical guidelines to ensure the integrity and fairness of the appeal process.
    • Confidentiality: The Impartial Appeals Officer is responsible for maintaining the confidentiality of all discussions, documents, and decisions related to the appeal process to protect the privacy and rights of all involved parties.
  10. No Retaliation:
    It is contrary to the values of Atlas Assistance Dogs and to Federal Law for anyone to retaliate against any Atlas representative who in good faith files a complaint under this policy or assists in investigating a complaint. An Atlas Representative who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment or removal from Atlas. Removal of Board members is governed by the Atlas Bylaws.
  11. Review and Improvement:
    Atlas Board and the Director of Operations and Programs will review issues identified in the complaint and any corrective actions initiated or recommended as a result of the complaint. They will determine if changes and improvements should be made to relevant Atlas practices and policies. If changes are recommended, they will develop and implement an action plan to implement the changes. Documentation regarding any new processes or changes will be retained with the records related to the complaint.

Monitoring and Compliance

The following metrics will be maintained to measure Atlas’ ability to resolve complaints satisfactorily and in a timely manner as well as to measure the influence of complaints on Atlas operations, policies, and culture.

  1. Number and Type of Complaints Received: Track, and provide to the Board, the total number of complaints received each quarter. Reports will be made at the end of each calendar quarter, and a summary of all complaints received during the year will be reported at the end of the year. Categorize complaints by type (e.g., service quality, employee behavior, harassment, discrimination, operational decisions) to identify areas that may require policy adjustments, additional training, or systemic changes. This metric can help identify trends, areas of concern, and the overall awareness and utilization of the complaint policy. This information is internal to Atlas and is not published outside the organization.
  2. Stakeholder Satisfaction: Conduct surveys or interviews to gauge the satisfaction of complainants and other stakeholders with the complaint process. This could include questions on ease of filing complaints, clarity of the process, perceived fairness, and overall satisfaction with outcomes.
  3. Improvements Implemented: Track the number and nature of policy or operational changes made as a result of feedback or complaints received, which is a direct measure of the policy’s impact on organizational improvement.

By regularly reviewing these metrics, Atlas Assistance Dogs can gain valuable insights into the effectiveness of the Complaint Policy, identify areas for improvement, and ensure that the policy continues to serve the best interests of all stakeholders.

Download our Complaint and Whistleblower Policy Here

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