Community-based complaints mechanisms
Community-based complaints mechanisms aim to facilitate SEA reporting and referral of allegations, and help known and potential SEA survivors to access assistance and services. A community-based complaints mechanisms (CBCM) are jointly developed with a community of concern, preferably in an interagency framework if applicable, and make use of the community's resources and structures. CBCMs should therefore be culturally and gender sensitive and remove barriers that hinder members of the communities from reporting SEA incidents to appropriate stakeholders for follow up. Well-functioning CBCMs that are implemented properly help raise awareness of SEA among affected populations and also humanitarian staff. They enable an efficient response to SEA in emergency situations.
Interagency collaboration on setting up a CBCM: the example of Jordan
In Jordan, the Network on Protection from Sexual Exploitation and Abuse (PSEA Network) was established with UNHCR leadership in 2015. It assists humanitarian organizations involved in the inter-sectoral refugee response to fulfil their commitment to protect persons of concern from sexual exploitation and abuse by humanitarian personnel. The PSEA Network is composed of focal points from more than 45 international organizations and national and international NGOs. It is currently co-coordinated by UNHCR and INTERSOS. While each UN agency and NGO is responsible for its own PSEA commitments, policies and response, and for reporting and investigating complaints, the Network has enabled humanitarian response agencies to jointly evaluate the measures that have been put in place to prevent and respond to SEA, including community complaint mechanisms. These measures include the Mechanism itself, guiding principles, complaint reporting requirements, referral pathways, and risk mitigation measures for complainants and witnesses.
The Mechanism was developed after extensive consultation with refugees, PSEA Network members and agencies providing humanitarian services. Over 700 refugee women, girls, men and boys from different backgrounds living in and outside camps were consulted. More than 30 agencies have signed the Mechanism. The PSEA network assists organizations to adhere to monitoring and compliance mechanisms, and to refer complaints in accordance with the Mechanism's norms.
Underlying policies, principles and/or standards
UNHCR, Age, Gender and Diversity Policy, 2019
Best Practice Guide, Inter Agency Community Based Complaint Mechanisms
Good practice recommendations
- Ensure that all UNHCR staff and partner agencies (including Government partners) are aware of PSEA and relevant principles.
- Ensure that Representatives, programme and human resources colleagues, in addition to protection staff, support the development and implementation of SEA prevention and response activities.
- Engage with partners (including Government partners) across agencies and sectors. Although protection often leads, a multi-sectoral approach is required to implement CBCMs successfully. If the operation includes an inter-cluster or inter-agency working group, PSEA issues should be raised there, as well as in other multi-sectoral coordination fora.
- Designate PSEA focal points with sufficient seniority, and include their PSEA-related responsibilities in the E-Pad.
- Establish (or participate in) an interagency PSEA network to support the development and implementation of a coherent and effective complaint mechanism.
- Integrate CBCMs in general community-based feedback and misconduct complaint mechanisms.
- Make sure the community participates throughout when CBCMs are established and implemented.
- Integrate and coordinate SEA complaint mechanisms and SGBV and Child Protection (CP) responses.
- UNHCR or the best placed agency should liaise with the authorities to seek access to justice and other forms of protection for SEA survivors.
- Liaise with the Inspector General's Office (IGO).
Considerations for practical implementation
Key steps in setting up an interagency CBCM
1. Raise the awareness of staff and partners, at all levels, and build their capacity.
2. Appoint official PSEA focal points in UNHCR and inter-agency fora. Establish / participate in an interagency PSEA network.
3. Design and apply a PSEA self-audit check list and develop a joint action plan with humanitarian and development actors working with persons of concern (PoC).
4. Map country, regional and global SEA mechanisms (with the support of Inter-agency coordination structures if they exist).
5. Map CBCMs and consult PoC on their use to address SEA.
6. Consolidate the findings of community consultations and discuss them with the PSEA network.
7. Draft an inter-agency SEA complaints mechanism and referral system, which draws in humanitarian agencies and community-based structures, and link it with other operational protection systems, particularly those that address SGBV and child protection.
8. Consult other PSEA focal points and Representatives, reflect their advice in the draft CBCM, and seek their approval for it.
9. Develop information materials to publicise the existence of, and guidance on the functioning of the CBCM among PoC, UNHCR staff, and service providers working with PoC.
10. Test the information materials with PoC, UNHCR staff, partners and service providers.
11. Incorporate the feedback from PoC, partners, service providers in the information materials.
12. Develop an implementation and dissemination plan (preferably interagency).
13. Launch the CBCM at a[n] (interagency) signature ceremony.
Key aspects that Standard Operating Procedures (SOPs) should cover
- Roles and responsibilities.
- Guiding principles.
- Receiving and reporting complaints.
- Inter-agency referral.
- Supporting the needs of survivors, complainants and witnesses.
- Mandatory reporting.
- Recording and reporting SEA complaints throughout the PSEA network.
- Awareness and dissemination materials.
Resources and partnerships
Staff. Make sure that PSEA focal points are appointed in UNHCR and partner organizations. Establish terms of reference for PSEA focal points which clarify their responsibilities and the experience and competencies they should possess.
Partners. Develop (or participate actively in an existing) interagency PSEA task force to plan joint PSEA activities. Set up an effective and culturally sensitive interagency CBCM to receive sensitive complaints, including SEA ones.
Materials. Design and develop outreach materials on SEA to inform PoC, staff and partners about complaint mechanisms and their remits.
Financial. Make sure PSEA activities are planned and budgeted.
- UNHCR Ethics Office at: [email protected].
- UNHCR Division of International Protection (DIP).