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FIRMS Procedure for Complaints
(Alleged breach of Codes of Conduct)

Version No. 1        Date of Issue: 29 June, 2015

Complaints regarding an alleged breach of, or a non-compliance with, either of the FIRMS Codes of Conduct (CoC) must be made in writing and must comply with this procedure.

The written complaint must specify the part, or parts, of the relevant CoC breached or not complied with.

In the first instance complaints shall be submitted to the Chair alone and in confidence, unless the Chair is the subject of the complaint.

If the Chair is the subject of the complaint, either solely or jointly, then the complaint shall be submitted in confidence to the most senior member of the FIRMS Steering Group (SG) alone. Seniority may be determined by reference to the list of Steering Group members. If two or more members have equal seniority then a choice may be made.

If the complaint is received by some other member of the FIRMS SG then the recipient shall pass the matter in confidence to the Chair or the most senior SG member as appropriate.

The leader of the enquiry, either the Chair or the most senior SG member, will appoint a CoC sub-committee of two. The members of that sub-committee will be drawn from those SG members with the most relevant expertise and the least exposure to the matter(s) at issue; i.e. greatest independence. 

The CoC sub-committee will aim to establish the facts and determine whether or not there is substance to the complaint.

The CoC sub-committee will report its findings and recommendations in writing.

In the first instance the CoC sub-committee report will be submitted to the enquiry leader alone and in confidence.

If the CoC sub-committee determine that there is little or no substance to the complaint and the leader of the enquiry agrees then the leader shall write to the complainant reporting no further action and giving reasons. The leader will also report the matter briefly to the SG being sure not to expose FIRMS to any unnecessary risks.

In all other circumstances the CoC sub-committee report will be distributed to the SG (excluding members who are directly involved, e.g. the complainant, or the subject(s) of the complaint) for its consideration. A final decision on what action to take will be made by the SG and communicated in writing to the complainant and the subject(s) of the complaint by the leader of the enquiry on behalf of the SG.

Actions open to the SG shall include, but are not limited to:

  • No further action;
  • Requiring remedial action within a specified timeframe; and
  • Suspension of FIRMS membership, Approved Practitioner status or both either temporarily or permanently.