Complaints Policy and Procedure

Talent Acquisition Association of Australia

The purpose of this Policy is to establish a fair, transparent, proportionate and consistent process for managing complaints concerning conduct that falls within the limited jurisdiction of the Talent Acquisition Association of Australia (TAAA).

TAAA is a professional membership association. It is not a court, tribunal, government regulator, law-enforcement body, employment authority, recruitment regulator or industry-wide disciplinary body. TAAA does not police, regulate or adjudicate the conduct of the Talent Acquisition or recruitment industry generally.

TAAA’s role under this Policy is limited to considering conduct by persons or organisations subject to TAAA’s governance framework where that conduct has a sufficient connection with TAAA membership, representation, or an event, training program, meeting, gathering or other activity organised, hosted, endorsed or formally conducted by TAAA.

TAAA is committed to promoting high standards of professionalism, integrity and ethical behaviour. Wherever appropriate, TAAA will seek to address concerns through education, guidance, mentoring, professional development or other proportionate measures before considering suspension, removal of status or termination of membership.

This Policy is intended to ensure complaints are managed confidentially, efficiently and in accordance with procedural fairness.

Subject to section 3, this Policy may apply to complaints concerning:

  • Individual Members;
  • Fellow Members and Foundation Fellows;
  • Corporate Members;
  • Vendor Members, Sponsors and Commercial Partners where they are subject to applicable TAAA terms or standards;
  • members of the National Advisory Council;
  • Board Directors and office holders;
  • Committee or working-group members;
  • volunteers acting on behalf of TAAA; and
  • any other person expressly authorised to represent TAAA in an official capacity.

The fact that a person is employed in Talent Acquisition, recruitment or human resources does not, of itself, bring that person’s conduct within TAAA’s jurisdiction.

For the avoidance of doubt, membership of TAAA does not give TAAA general jurisdiction over a member’s employment, recruitment decisions, workplace conduct or professional activities undertaken for an employer, client or other organisation. TAAA will only exercise its complaints function where the alleged conduct has the connection with TAAA described in this Policy.

TAAA may consider a complaint where the alleged conduct has a sufficient connection with TAAA and concerns, for example:

  • an alleged breach of the TAAA Code of Professional Conduct occurring in connection with TAAA membership or a TAAA activity;
  • misconduct occurring at, or directly connected with, a TAAA event, training program, webinar, meeting, Council or committee activity, networking function, gathering or other TAAA-organised activity;
  • conduct by a person while formally representing, speaking for, volunteering for, or exercising a responsibility on behalf of TAAA;
  • misuse of TAAA membership, Fellow status, rosettes, branding, intellectual property or professional designations;
  • conduct which may materially damage the integrity, safety or reputation of TAAA in circumstances sufficiently connected with TAAA; or
  • a breach of TAAA Membership Terms, event terms or another applicable TAAA governance requirement.

TAAA will not ordinarily determine whether a member has complied with broad or subjective professional practice standards arising solely in the member’s external employment or recruitment work (for example, whether an assessment methodology used by an employer was appropriate for a particular role). Such matters are ordinarily for the relevant employer, client, regulator, court, tribunal or other competent body. TAAA may only consider such conduct where there is a direct and material TAAA connection and the alleged conduct is capable of being assessed against a sufficiently clear TAAA obligation.

Without limiting the matters that may fall outside TAAA’s jurisdiction, TAAA will generally not investigate or adjudicate complaints relating to:

  • recruitment or hiring decisions made by an employer or recruitment provider;
  • candidate selection, assessment or shortlisting outcomes;
  • unsuccessful job applications or decisions not to progress a candidate;
  • the design or appropriateness of an employer’s recruitment or assessment methodology;
  • employment contracts, remuneration, employment offers or negotiations;
  • workplace grievances or performance-management matters;
  • unfair dismissal, adverse action or other employment-law claims;
  • discrimination claims;
  • bullying, harassment or other conduct occurring solely within a workplace and without a sufficient TAAA connection;
  • alleged breaches of employment, workplace, privacy, discrimination or other legislation that are properly matters for an employer, regulator, court or tribunal;
  • commercial or contractual disputes between parties unrelated to TAAA’s own contractual arrangements; or
  • matters currently before, or more appropriately dealt with by, a court, tribunal, police, government regulator or other competent authority.

The above list is illustrative and is not exhaustive. TAAA may decline to deal with any matter that it reasonably considers falls outside its objects, powers, expertise, resources or jurisdiction, or where another body is better placed to determine the matter.

Where appropriate, TAAA may recommend that a complainant raise the matter with the relevant employer or recruitment provider, the Fair Work Commission, the Fair Work Ombudsman, the Australian Human Rights Commission, a relevant State or Territory anti-discrimination or equal opportunity body, police, another regulator or other appropriate authority.

Nothing in this section prevents TAAA from taking steps reasonably necessary to manage the safety or integrity of a TAAA activity, or from considering whether conduct occurring within TAAA’s jurisdiction breaches an applicable TAAA obligation.

A complaint must:

  • be made in writing;
  • identify the complainant, unless TAAA agrees to accept an anonymous complaint under this section;
  • identify the person or organisation against whom the complaint is made (the Respondent);
  • provide sufficient particulars of the alleged conduct, including relevant dates, locations and the connection with TAAA;
  • identify, where reasonably possible, the TAAA standard, term or obligation said to have been breached;
  • include any supporting documents or other evidence reasonably available to the complainant; and
  • be lodged within a reasonable period after the events giving rise to the complaint.

Complaints must be submitted through the complaints or members contact channel published on the TAAA website, or to such other email address or submission method as TAAA may nominate from time to time. This approach avoids this Policy becoming inaccurate if TAAA changes its administrative email address.

Anonymous complaints will generally not be investigated unless TAAA considers the alleged matter sufficiently serious, capable of fair assessment and supported by reliable independent information.

TAAA may request further information before deciding whether a complaint can proceed.

TAAA will acknowledge receipt of a complaint as soon as reasonably practicable and will ordinarily aim to do so within five (5) business days.

The Chief Executive Officer, Membership Manager or another person authorised by the Board or National Advisory Council will conduct an initial assessment to determine whether:

  • the complaint falls within TAAA’s jurisdiction under this Policy;
  • sufficient information has been provided to understand and assess the complaint;
  • the alleged conduct, if established, is capable of constituting a breach of an applicable TAAA obligation; and
  • it is fair, proportionate and reasonably practicable for TAAA to consider the complaint further.

The initial assessment is a jurisdictional and threshold assessment only. It is not a finding that the complaint is substantiated or that the Respondent has breached any TAAA obligation.

TAAA will ordinarily aim to notify the complainant of the outcome of the initial assessment, or provide a progress update, within twenty-one (21) days of receiving sufficient information to assess the complaint.

These timeframes are targets only and may be extended where the matter is complex, further information is required, relevant persons are unavailable, external proceedings are underway, or for other reasonable operational reasons.

Where a complaint is outside the scope of this Policy, TAAA will advise the complainant in writing and may identify a more appropriate organisation or authority. TAAA is not obliged to make a referral or to determine which external body has jurisdiction.

A person who is the subject of a complaint, is materially involved in the alleged circumstances, or has an actual, potential or perceived conflict of interest must not administer, assess, investigate or determine that complaint.

Where a complaint concerns the Chief Executive Officer, Chair, a Director, National Advisory Council member or another person who would ordinarily administer the complaint, the matter must be referred to an unconflicted Director or other person authorised by the Board.

Where the complaint concerns all Directors, a majority of Directors, or circumstances in which the Board cannot form an appropriately independent process, the Board or any unconflicted Director may appoint an independent external person or a panel of suitably qualified and unconflicted persons to conduct the initial assessment, investigation and/or make recommendations.

Where a complaint concerns a National Advisory Council member or other office holder, that person must stand aside from any Council, committee or panel discussion concerning the complaint.

TAAA may obtain independent legal, governance, human resources or other professional advice where reasonably necessary.

If a complaint proceeds beyond initial assessment, TAAA will determine a process proportionate to the nature and seriousness of the allegations. TAAA may, where appropriate:

  • seek to resolve the matter informally, including through clarification, facilitated discussion, education, guidance or an agreed remedial action;
  • provide the Respondent with a written summary of the allegations and relevant supporting information;
  • give the Respondent a reasonable opportunity to respond, ordinarily within twenty-one (21) days;
  • request additional information from the complainant, Respondent or relevant witnesses;
  • seek independent expert advice where the subject matter requires expertise not reasonably available within TAAA;
  • establish a Professional Standards Review Panel under section 10; or
  • pause, defer or discontinue the process where an external investigation or proceeding should take precedence.

TAAA is not bound by formal rules of evidence. Any process undertaken by TAAA must nevertheless be fair, impartial, proportionate and reasonable having regard to TAAA’s status as a professional membership association and its available resources.

TAAA is not required to undertake a forensic investigation or resolve disputed questions that cannot reasonably or fairly be determined within its limited membership jurisdiction.

Where a complaint may result in an adverse membership, office-holder or other TAAA-related outcome, TAAA will apply procedural fairness appropriate to the circumstances. This will ordinarily include:

  • providing the Respondent with reasonable notice of the substance of the allegations;
  • providing a genuine and reasonable opportunity to respond;
  • ensuring persons materially involved in assessing or determining the matter are impartial and free from relevant conflicts of interest;
  • considering relevant information before making a determination;
  • not treating an allegation as established merely because a complaint has been made; and
  • communicating the outcome and any material action to the Respondent in writing and, subject to confidentiality and privacy obligations, advising the complainant that the matter has been concluded.

A determination under this Policy is a determination for TAAA membership, governance or participation purposes only. It is not a finding of legal liability, professional negligence, unlawful conduct, discrimination, employment wrongdoing or criminal responsibility and is not binding on any employer, court, tribunal, regulator or other third party.

Where TAAA reasonably considers that an allegation is sufficiently serious and that temporary action is necessary to protect participants, preserve the integrity of a TAAA process, manage an actual or perceived conflict, or protect TAAA from material risk, TAAA may impose proportionate interim measures while the complaint is assessed or investigated.

Interim measures may include temporarily:

  • restricting or suspending a person’s representative, speaking, committee, Council, volunteer or other TAAA responsibilities;
  • restricting attendance at a particular TAAA event, training program, meeting or gathering;
  • requiring alternative reporting, supervision or communication arrangements; or
  • taking another reasonable administrative step necessary to manage the identified risk.

An interim measure is precautionary only and does not constitute a finding that the allegation is substantiated. TAAA will review any interim measure periodically and remove or vary it when it is no longer reasonably necessary.

The Board may establish a complaints committee (from within the National Advisory Council) to consider a complaint referred to under this Policy.

The committee will ordinarily comprise one unconflicted Director appointed by the Board and not fewer than two suitably experienced, unconflicted members of the National Advisory Council or other independent people appointed by the Board.

All committee members must declare any actual, potential or perceived conflict of interest before participating. A person with a material conflict must not participate, and an alternative member may be appointed.

The committee acts in an advisory capacity to the Board unless decision-making authority has been validly delegated by Board resolution and is consistent with TAAA’s Constitution, Membership Terms and other governing documents.

Where a complaint is substantiated for TAAA purposes, the Panel or other authorised decision-maker may recommend or, where validly authorised, impose one or more proportionate outcomes, including:

  • taking no further action;
  • providing guidance, education or recommendations;
  • issuing a written warning;
  • requiring specified professional development, mentoring or coaching;
  • requiring an apology, correction or other reasonable remedial action connected with TAAA;
  • restricting participation in specified TAAA activities for a defined period;
  • suspending membership for a specified period;
  • removing or suspending Fellow status, Council, committee or other TAAA appointments, where TAAA has authority to do so;
  • terminating membership in accordance with TAAA’s Constitution, Membership Terms and applicable law; or
  • referring or reporting a matter to an external authority where required by law or where TAAA reasonably considers this appropriate and lawful.

In determining an appropriate outcome, TAAA may consider the seriousness and nature of the conduct; whether it was intentional or repeated; any prior relevant conduct; mitigating circumstances; acceptance of responsibility; steps taken to remedy the conduct; impact on other persons; impact on TAAA; and the need for a proportionate response.

TAAA cannot award compensation or damages, overturn an employer’s recruitment or employment decision, compel an employer or third party to take action, or determine legal rights or liabilities.

Where the Membership Terms, Constitution or another governing document provides a right of review or appeal in relation to a decision made under this Policy, that right will apply in accordance with the applicable governing document.

Subject to the paragraph above, a Respondent may request a review of a final adverse decision under this Policy within twenty-one (21) days after receiving written notice of the decision. A review is not a complete rehearing and must identify one or more of the following grounds:

  • a material failure to provide procedural fairness;
  • a material error in applying this Policy or an applicable TAAA obligation;
  • significant new information that was not reasonably available during the original process and could materially affect the outcome; or
  • an outcome that is manifestly disproportionate to the conduct determined for TAAA purposes.

The Board will determine the appropriate review mechanism, having regard to TAAA’s Constitution and Membership Terms. Any review must be conducted by persons who were not materially involved in the original decision and who are free from relevant conflicts of interest.

The reviewer or Review Panel may uphold, vary or set aside the original decision, or remit the matter for reconsideration.

The outcome of the review will be final within TAAA’s internal complaints process, subject always to any rights that cannot lawfully be excluded.

If there is any inconsistency between this Policy and TAAA’s Constitution or mandatory law, the Constitution or mandatory law prevails. TAAA should ensure its Membership Terms are maintained consistently with this section.

TAAA will not tolerate retaliation, victimisation or adverse treatment of a person because that person has, in good faith, made a complaint, provided information, acted as a witness or otherwise participated in a process under this Policy.

Retaliation or victimisation connected with TAAA may itself constitute a breach of the TAAA Code of Professional Conduct or Membership Terms and may result in action under this Policy.

This section does not prevent TAAA from taking action in relation to a complaint that is knowingly false, malicious, vexatious or otherwise made in bad faith.

TAAA will handle complaint information as confidentially as reasonably practicable, subject to procedural fairness, TAAA’s Privacy Policy, the need to administer this Policy, the need to obtain professional advice, and any legal obligations.

Persons involved in a complaint must not improperly disclose confidential information obtained through the complaints process. Information may be disclosed where required or authorised by law, reasonably necessary to administer the complaint, authorised by TAAA, or reasonably necessary for a person to obtain legal or professional advice.

TAAA cannot guarantee absolute confidentiality because information may need to be provided to the Respondent, witnesses, advisers, insurers, regulators or other persons in order to fairly or lawfully deal with a matter.

TAAA will not ordinarily publish the outcome of an individual complaint.

The Board may approve publication of a de-identified or aggregated summary where it reasonably considers this would educate members, improve professional standards or clarify the operation of the Code of Professional Conduct, provided publication is consistent with applicable privacy, confidentiality and legal obligations.

Given the specialist nature of the Talent Acquisition community, TAAA will take reasonable care to avoid publishing details that could readily identify the parties.

TAAA will maintain appropriate confidential records of complaints, assessments, investigations, decisions and outcomes in accordance with its Privacy Policy, governance requirements and applicable law.

Access will be restricted to persons with a legitimate need to know or who are otherwise authorised by TAAA. Records will be retained only for such period as TAAA reasonably considers necessary for legal, governance, insurance, professional standards or operational purposes, subject to applicable legal requirements.

TAAA encourages concerns to be raised honestly and in good faith. A complaint may be declined or dismissed where TAAA reasonably considers it to be frivolous, vexatious, malicious, knowingly false, primarily intended to harass or disadvantage another person, or otherwise an abuse of this process.

Where a member knowingly makes a false or malicious complaint, that conduct may itself be considered under the TAAA Code of Professional Conduct or Membership Terms. A complaint will not be regarded as made in bad faith merely because it is not substantiated.

TAAA will seek to deal with complaints without unreasonable delay. Any timeframes stated in this Policy are indicative service standards rather than strict contractual deadlines and may be extended where reasonably necessary. Where there is a material delay, TAAA will endeavour to keep affected parties appropriately informed.

The Board may approve procedures, forms, registers and administrative guidelines to support this Policy, provided they are consistent with this Policy and TAAA’s governing documents.

This Policy should be reviewed periodically and may be amended by TAAA in accordance with its governance arrangements..

TAAA Membership Manager
Level 7, 10 Yarra Street,
South Yarra,
Melbourne, VIC, 3141
E: members@taaa.au

Updated: September 2026

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