# Nkwenkwezi Foundation
## Complaints, whistleblowing & protection from retaliation

Document: NKF-POL-06 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft covers concerns from participants, caregivers, donors, volunteers, staff, partners and members of the public. It includes service complaints, misconduct, suspected fraud, conflicts of interest and safeguarding concerns. Urgent safety matters require immediate protective action and appropriate external assistance.

### 2. Accessible reporting

Provide clear contact routes, a designated handler and an alternate who can receive concerns about the handler or leadership. Accept a first report without demanding unnecessary personal information. Permit a reporter to request a private follow-up. An anonymous report should be assessed on the information available, while recognising that follow-up may be limited.

### 3. Triage and acknowledgement

Record the concern securely and assess urgency, safety, conflicts and any legal reporting duty. Acknowledge receipt and explain the next step where a safe contact route is available. Agree realistic response targets before adopting this policy; do not promise an outcome before the facts are assessed.

### 4. Fair handling and confidentiality

Assign a sufficiently independent person to assess the matter. Give affected people a fair opportunity to respond, preserve evidence and limit access to those who need it. Share information lawfully and explain that confidentiality may have limits where safety or reporting duties apply. Do not retaliate against good-faith reporting.

### 5. Outcome, review and learning

Record the findings, action taken and reasons. Communicate an appropriate outcome to the reporter without exposing another person’s confidential information. Provide a review route to a non-conflicted governing-body member or suitable independent person. Track recurring themes and corrective actions.

### 6. Before adoption

Confirm named reporting and escalation contacts, the alternate route, secure registers, response targets, investigation support and external referral contacts. Staff and volunteers should know how to use the process. A public general-contact address alone is not an independent whistleblowing service.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.