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Step 1 of 7
6
Investigation & Escalation Matrix
Policy Section 7.0
The Designated Officer (7.1)
Role of the Designated Officer (DO)
- Appointed by the Executive Director
- Supported by the Senior Management Team (SMT)
- Assesses severity per Annex 1 classification
- Routes reports per the escalation matrix below
Why a Designated Officer?
Having a single point of contact ensures consistency in how reports are handled, prevents conflicts of interest, and guarantees proper escalation based on severity.
Quick Check
A new staff member asks during orientation: "Who is ultimately responsible for receiving and routing whistleblowing reports at AERC? And who appoints that person?"
Who appoints the Designated Officer?
Escalation Matrix
| Severity | Implicated Person | Report Recipients |
|---|---|---|
| HIGH | Any person | DO + Audit & Risk Committee |
| HIGH | SMT Member | DO + Audit & Risk Committee + ED (excludes implicated) |
| HIGH | Exec Director | DO + Audit & Risk Comm. + Board Chair (excludes ED) |
| HIGH | Board Member | DO + Board Exec Committee + External Oversight |
| MEDIUM | Staff / Manager | DO + SMT + Department Recipients |
| MEDIUM | SMT / ED | DO + Non-conflicted SMT + Board Chair |
| LOW | Any person | DO + General Recipients |
Key principle: The implicated person is always excluded from receiving or handling their own report.
Quick Check
A serious report alleges that the Executive Director is involved in procurement fraud. The Designated Officer must determine who handles the investigation. Clearly, the ED cannot be part of the process.
According to the escalation matrix, who should receive this HIGH-severity report about the ED?
Severity Classification (Annex 1)
HIGH
Severe Impact
Major fraud, safety risks, senior leadership involvement, systemic issues
MEDIUM
Moderate Impact
Policy violations, mid-level misconduct, isolated financial irregularities
LOW
Minor Impact
Minor policy breaches, procedural concerns, low-risk issues
Important: The Designated Officer classifies severity based on the nature, scope, and potential impact of the reported concern. When in doubt, severity is escalated upward.
Final Check
An anonymous report about a Board member accepting bribes from a vendor is received. The DO must route it to the correct recipients according to the matrix.
Who receives a HIGH-severity report about a Board member?
Key Takeaways
- Designated Officer is appointed by the ED, supported by SMT, and is the single point for receiving and routing reports
- Escalation matrix ensures reports go to the right people based on severity and who is implicated
- Implicated persons are always excluded from handling their own reports — no exceptions
Next up: Investigation Steps & Outcomes