Oxebridge files complaints on behalf of specific clients, industry stakeholders or in the interest of public safety. Oxebridge complaints are formally written, contain significant objective evidence, and cite specific clauses of the particular accreditation standards where we feel there have been violations. A typical Oxebridge complaint can be more than 10 pages, and can intimidate some recipients who are not used to such formality.
What To Do
There are simple and proper ways to respond to such complaints that do not make the situation worse. Instead, stick to the rules defined in ISO 17021 (for CBs) or ISO 17011 (for ABs) and to ISO 10002 (for everyone.)
- Acknowledge receipt. Oxebridge will usually send the complaint via email to the appropriate individual. If that becomes problematic, we will send a hardcopy. No matter what, acknowledge receipt.
- Process the complaint formally. Use your internal complaints processing procedures — required by the accreditation standards — to process the complaint. Do not attempt to resolve the complaint impersonally, by phone, or through casual conversations. Oxebridge will not discuss formal complaints over the phone because this leaves no record. If a phone conversation is required, it will be recorded.
- Involve your Impartiality Committee in the response. For now, IC’s are required by accreditation rules. Use them; this can only help.
- Respond to each allegation. Oxebridge complaints feature specific allegations, each of which needs to be addressed. Unfortunately, recipients tend to offer broad-brush denials or explanations that do not address the specific allegations. This allows Oxebridge the right to escalate the problem while adding a new grievance for failing to properly respond to the original complaint.
- Respond in writing. Email is fine, but again, responses cannot be via phone call. Put everything in writing.
- Recuse yourself. If you are named in the complaint, you may certainly respond to it, but recuse yourself from the investigation process. This is a requirement under accreditation rules, and failing to do so will invalidate any subsequent actions.
- Use your internal corrective action system. Accreditation rules require the complaint be processed through your internal CAPA or CAR system. Failing to do so can give the appearance that you were attempting to avoid keeping records of the complaint.
- Take both immediate containment and long term corrective action. Often, recipients of complaints take a quick action to resolve the specific evidence provided, but then fail to take holistic corrective action that provides confidence the problem won’t resurface. You have to do both. “Risk based thinking” and all that.
- Keep Oxebridge updated. Some complaints can take a long time to process. We know this, but it’s a good idea to keep us updated as your work progresses, so we don’t come to believe the issue was dropped.
Note: In some cases, the problem actually lies with the higher authority (AB or IAF) however their rules allow them to dismiss a complaint that was not formally filed with the lower body first. For such cases, the first level of complaint is merely a “check box” activity. We will try to advise you of when this is the case, so you do not waste resources on a drawn-out complaint process if the actual intent is to pursue the issue with the AB or IAF.
What Not To Do
There are a few things you should not do. We see these all the time, unfortunately, and are very skilled in responding to them. Nothing good will come of these, and such actions will only help Oxebridge present a case to the world stage that the system is broken, and may result in litigation or the involvement of law enforcement. Avoid the temptation to engage in the following reactions:
- Do not be dismissive of the complaint. Oxebridge has, in the past, received “snarky” responses from CB or AB officials who felt the complaint was beneath them. No matter what you think of the complaint, you must process it formally. Sarcastic or dismissive responses only go into the record and worsen the matter.
- Do not invoke your AB as a defense. Often, Oxebridge uncovers activities that ABs miss or, worse, have approved. Responding to a complaint by saying “our AB has not found a problem” is not a defense in and of itself. That issue will be taken up with the AB or IAF directly.
- Don’t deny the complainant outright. Often a recipient will try to bypass the complaint entirely by claiming the complainant (such as Oxebridge) is not a “stakeholder” and so has no rights to file the complaint to begin with. This argument never wins, and only worsens the situation. The complaint will include, in its Preamble, justification for the complainant’s role.
- Do not react with threats of legal action. To date, Oxebridge has received 15 threats of litigation by CBs or others, and all 15 were defeated before they ever went to court. We are very good at this. You should attempt to exhaust all options before jumping to the courts. If you do feel you have actionable cause, have your attorney or legal department officially notify us. We will reject random legal threats from those named in complaints, and instead jump to immediate escalation. Some informal threats of litigation may be actionable by us in and of themselves.
- Do not institute an email server ban, client blacklist or some other punitive measure against Oxebridge or its clients. This only worsens the situation, and eventually gets reversed anyway. It also makes you look really, really bad.
- Don’t begin an internal email “hate campaign” against Oxebridge. These emails tend to get leaked by employees within your organization who are sympathetic to the reform efforts Oxebridge is engaged in, and can become legal entanglements later. For heaven’s sake, don’t accidentally “BCC” such internal emails to Oxebridge directly. You wouldn’t believe how many times that’s happened.
- Do not react with hostility. Oxebridge has received various types of threats — including death threats — from individuals named in its complaints who felt personally insulted. Some of those people have lost their jobs. Do not react in this manner, as it only allows Oxebridge to bypass the processing of the complaint at your level and jump to an immediate escalation. It also allows Oxebridge to involve law enforcement.
Often, Oxebridge will simultaneously report on the complaint and then update that reporting as the complaint proceeds. In doing so, op-ed pieces will clearly be tagged as “Opinion” and will avoid potentially defamatory false statements of fact. Where items are tagged as “News” the statements of fact will be supported by evidence. Avoid the temptation to have such reporting removed or shut down by either claiming defamation or intellectual property infringement. If you feel the facts reported are wrong, send a statement with the correct facts and we will update the reporting or issue a formal retraction. If you feel your IP has been infringed, file a DMCA act takedown notice. For more, see our Site Policies and Legal page.