Policy on Grievance Process
Complaints may be transmitted to CFRE International in any manner by any individual or entity, but must be in writing. Inquiries or submissions other than complaints may be reviewed and handled by CFRE International Staff at its discretion. Formal complaints must be marked as such, and will be immediately forwarded to the Chair of the Grievance Committee for review. The Chair of the Grievance Committee may also self-initiate a complaint. A complaint must be:
- Specific to a section of the International Statement of Ethical Principles in Fundraising or CFRE Accountability Standards;
- In writing by the individual lodging the complaint;
- Supported by definitive and specific evidence of such accusation; and
- Made against a current holder of CFRE certification.
Upon receipt and preliminary review of a submission meeting the above requirements, the Chair of the Grievance Committee may conclude, in the Chair’s sole discretion, that the submission: (1) contains unreliable or insufficient information, or (2) is patently frivolous or inconsequential. In such cases, the Chair may determine that the submission does not constitute a valid and actionable complaint that would justify bringing it before the CFRE Grievance committee under these Procedures. If so, the submission is disposed of by notice from the Chair to its submitter, if the submitter is identified, within 30 days of the receipt of the complaint. All such preliminary dispositions by the Chair are reported to the CFRE Board of Directors.
If a submission is deemed by the Chair to be a valid and actionable complaint, the Chair shall see that written notice is provided to the certificant whose conduct has been called into question. The certificant shall also be provided with a copy or summary of the complaint and a copy of these Procedures, and advised that he or she may submit any information in response to the complaint in writing, within thirty (30) days of receipt of the notice. The Chair also shall ensure that the individual submitting the complaint receives notice that the complaint is being reviewed by the CFRE Appeal and Grievance committee.
All complaints received by CFRE International will be reviewed and responded to within 30 days of receipt. If, for any reason, the normal deadlines are not met, the complainant must receive a progress report of the status of their complaint.
Review of Complaint
For each submission that the Chair concludes is a valid and actionable complaint, CFRE International authorizes an investigation into its specific facts or circumstances to whatever extent is necessary in order to clarify, expand, or corroborate the information provided by the submitter. The Chair makes an appropriate determination with respect to each such valid and actionable complaint to the Appeal and Grievance Committee. No one on the Grievance Committee may also serve on the CFRE Board of Directors when it deliberates with respect to a determination and sanction to be imposed. The Committee initially determines whether it is appropriate to review the complaint under these Procedures or whether the matter should be referred to another entity engaged in the administration of law or licensure of personnel. The Committee may be assisted in the conduct of its investigation by other members of the CFRE Board of Directors or by CFRE International staff or legal counsel. The Chair of the Grievance Committee exercises general supervision over all investigations. These investigations may not last longer than 90 days.
Both the individual submitting the complaint and the certificant who is the subject of the investigation may be contacted for additional information with respect to the complaint. The time for providing such additional information shall be established by the Committee. The Committee may, at its discretion, contact such other individuals who may have knowledge of the facts and circumstances surrounding the complaint.
All investigations and deliberations under these Procedures are conducted in confidence, with all written communications sealed and marked “Personal and Confidential,” and they are conducted objectively, without any indication of prejudgment. An investigation may be directed toward any aspect of a complaint which is relevant or potentially relevant. Formal hearings are not held and the parties are not expected to be represented by counsel, although the Committee and/or the National Board may consult their own counsel. The rules of evidence do not apply, and there are no witnesses, cross-examination, or other features of a court trial. The Chair may permit the certificant to address the Committee or the CFRE Board of Directors by telephone or video conference, at the discretion of the Chair.
Members of the Grievance Committee shall be reimbursed for reasonable expenses incurred in connection with the activities of the Committee.
Determination of Violation
Upon completion of an investigation, the Committee recommends whether the CFRE Board of Directors should make a determination that there has been a violation of the CFRE certification program, Accountability Standards, the International Statement of Ethical Principles in Fundraising, or other conduct warranting disciplinary action under these Procedures. When the Committee recommends that the CFRE Board of Directors find a violation, the Committee also recommends imposition of an appropriate sanction. If the Committee so recommends, a proposed determination report with the Committee’s findings and rationale, with a proposed sanction, is prepared under the supervision of the Chair and is presented by a representative of the Committee to the CFRE Board of Directors along with the record of the Committee’s investigation. A copy of the determination report will be sent to the certificant and shall advise the certificant that he/she has thirty (30) days in which to respond to the Committee’s determination report. If the Committee recommends against a determination that a violation has occurred, the complaint is dismissed with notice to the certificant and the individual or entity who submitted the complaint; a summary report is also made to the CFRE Board of Directors.
The CFRE Board of Directors meets by telephone or video conference and reviews the recommendation of the Committee based upon the record of the investigation. The CFRE Board of Directors may accept, reject, or modify the Committee’s recommendation, either with respect to the determination of a violation or the recommended sanction to be imposed. If the CFRE Board of Directors makes a determination that a violation has occurred, this determination and the imposition of a sanction are promulgated by written notice to the certificant, and to the individual submitting the complaint, except to the extent the sanction is private.
In certain circumstances, the CFRE Board of Directors may consider a recommendation from the Committee that the certificant should be offered an opportunity to submit a written assurance that the conduct in question has been terminated and will not recur. The decision of the Committee to make such a recommendation and of the CFRE Board of Directors to accept it are within their respective discretionary powers. If such an offer is extended, the certificant at issue must submit the required written assurance within thirty (30) days of receipt of the offer, and the assurance must be submitted in terms that are acceptable to the CFRE Board of Directors.
Sanctions
Any of the following sanctions may be imposed by the CFRE Board of Directors upon a certificant whom the CFRE Board of Directors has determined to have violated the CFRE certification programme, Accountability Standards, the International Statement of Ethical Principles in Fundraising , or other conduct warranting disciplinary action under these Procedures, although the sanction applied must reasonably relate to the nature and severity of the violation, focusing on reformation of the conduct of the member and deterrence of similar conduct by others:
- private or public written reprimand to the certificant;
- suspension of the certificant for a designated period; or
- termination of the certificant’s certification.
For each of these three sanctions, a summary of the determination and the sanction with the certificant’s name is published by the CFRE Board of Directors at its discretion, except with respect to any private sanction. The sanction is not imposed until such time as the opportunity for appeal has expired or the appeal process has been concluded.
Certificants who have been terminated shall have their certification revoked and may not be considered for CFRE certification in the future. If certification is revoked, any and all certificates or other materials requested by the CFRE Board of Directors must be returned promptly CFRE International.
Appeal
The determination of staff or Grievance Committee is appealable and the Appeals policy shall apply.
Resignation
If a certificant who is the subject of a complaint voluntarily surrenders his or her CFRE certification at any time during the pendency of a complaint under these Procedures, the complaint is dismissed without any further action by the Committee, the CFRE Board of Directors, or an Appeal Board established after an appeal. The CFRE Board of Directors may authorize the Chair to communicate the fact and date of resignation, and the fact and general nature of the complaint which was pending at the time of the resignation, to or at the request of a government entity engaged in the administration of law or professional licensure. Similarly, in the event of such resignation, the person or entity who submitted the complaint is notified of the fact and date of resignation and that CFRE Board of Directors has dismissed the complaint as a result. In the event of such resignation, the certificant shall not be eligible to re-apply for certification for five years from the date of resignation.
