Proposed COMPLAINTS HANDLING POLICY
(January 27, 2011)
•1. It is not the function of TTTI to undertake investigations of individual allegations of corruption. TTTI’s main role is the promotion of institutional reform and raising public awareness, which can only be achieved with the support of coalitions of civil society, private business and government. Becoming involved with individual cases could adversely affect the formation of such coalitions, by deterring individuals and organizations from becoming involved. It could also distract from TTTI’s primary focus, and tie up resources needed for the drive for reform.
•2. However, TTTI will monitor the effectiveness with which existing investigative authorities handle complaints and make recommendations to strengthen the available processes and organizations.
•3. No Member shall take any action which might prejudice the interests of the TTTI movement in achieving its main objective of building coalitions to support institutional reform. In particular, no member shall make public statements in the name of TTTI involving specific allegations of corruption. TTTI will only comment on individual cases when reported in the press, in order to use the particular incidents to draw lessons or place messages pointing to loopholes in the law or weaknesses in institutions which may have enabled instances of corruption.
•4. Upon receipt of a complaint of alleged corrupt activity from any individual including a member of TTTI, the board of Directors will consider
•(a) Whether such complainant is acting in good faith,
•(b) Whether there are reasonable grounds to suspect that an offence may have been committed, or whether such complainant is in need of advice and if so,
•(c) Which is the appropriate organization, individual, firm or body to which the matter should be referred,
and refer it accordingly for further investigation and/or advice.
•5. TTTI will then continue to monitor the effectiveness with which the complaint is being handled with a view toward making recommendations for reform of the process, if it is found to be inadequate.
•6. TTTI will keep a Register of Complaints outlining the nature of the complaint, the action recommended by the Board and all relevant information pertaining to the complaint. This information can then be used to support anti-corruption research and inform the strategies and approaches of the Board in achieving its objectives. This notwithstanding, there shall be no need to record the source of the Complaint or referral.