How to Implement a Complaint
Management System

How to Implement a Complaint Management System

The implementation of a digital complaint management system involves three major stages, which are:

• Communicate.
• Organize.
• Manage cases.

Let's take a look at what each of these entails.

Communicate: It's of no use to have a complaint channel if those who should use it are unaware of it or doubt its usefulness or reliability. Therefore, communication is the initial step to the success of a digital complaint management channel.

When communicating, several aspects need to be considered:

• Why communicate? The benefits of informing that the organization has a complaint channel are diverse:
• Regulatory: Increasingly, especially in the United States and Europe, there is a growing requirement for various organizations, both public and private, to have a complaint channel. If it's available, communicating it is a way to demonstrate the organization's commitment to regulatory compliance.
• Reputational: Investors, clients, and suppliers all appreciate integrity as a central quality of the organizations they do business with.
• Work environment: Leading by example matters. If the organization shows an interest in ethical conduct, its members will reinforce these values. Otherwise, ethical standards will weaken, and exposure to fraud and irregularities will increase.

Whom to communicate to? Informing all stakeholders about the existence of the complaint channel is crucial so that the channel comes to life, and those who manage or regulate the organization's affairs make appropriate decisions and file complaints when necessary.

What to communicate? Each stakeholder has different priorities regarding the complaint channel:

Confidentiality and whistleblower protection: It's important that those making complaints know that their information will be protected, and they will not face retaliation.

Educating potential complainants to provide necessary information: A digital channel can allow valuable evidence to be provided, such as photos or videos, which can be captured and transmitted in real-time from a mobile phone.

Ensuring the proper and timely handling of complaints: Assurances that complaints will be duly considered, analyzed, prioritized, and that the organization will take appropriate corrective actions fairly.

Informing about regulatory rights: According to European and U.S. regulations, there are numerous cases where whistleblowers are guaranteed the right to use an external complaint channel (usually administered by regulators or the judiciary) and still be protected.

Organize:

This essentially involves three aspects:

• Establish a team for complaint handling: The team should consist of qualified individuals to assess the reliability of complaints, trained in basic investigative methods, and with responsibilities in the organization that minimize the risk of them being subject to complaints themselves. In the latter case, it should be established that if the accused is one of the members of the complaint evaluation team, they should be immediately removed from the case.

Define procedures for complaint management: At a minimum, procedures should be established for:

• Creating complaint forms that allow categorization from the beginning to guide the consideration of the case and its subsequent investigation. In Shogun, this can be defined for each client through software customization.
• Defining acceptance or rejection criteria for complaints based on their credibility. Establish procedures for initiating further investigation.

Consider legal aspects: There can be various legal aspects related to a complaint channel:

• Whistleblower protection: There is European and U.S. legislation that protects whistleblowers from retaliation and guarantees their right to confidentiality.
• Reporting obligation to regulators and the judiciary: Depending on the nature of the organization, there may be an obligation to report certain complaints, or all of them, to regulators or the judiciary. Non-compliance with this rule can result in severe sanctions and significant reputational damage.

Author: Guillermo Casal
International consultant and trainer in fraud prevention and investigation and anti-money laundering. He is a Certified Public Accountant, holds a Master's degree in Economics and Administration, and has six international certifications, including the CFE (Certified Fraud Examiner), CIA (Certified Internal Auditor), and CISA (Certified Information Systems Auditor).