If your charity has just taken on its first member of staff — or a member of staff has just raised something that feels bigger than a grumble — the grievance policy suddenly stops being paperwork and becomes the thing everyone reaches for. Most small charities discover at that exact moment that they either don't have one, or have one written for a company with an HR department they don't possess. If that's you, there is less to catch up on than you fear: the law here is stable, the fair procedure is short, and a sound policy fits on three or four pages.
A charity grievance policy is the written procedure a member of staff uses to raise a concern about their own treatment at work — their workload, working conditions, or how a manager or colleague has behaved towards them — and it sets out who they raise it with, how the charity will respond, and how they can appeal. It is a staff-facing document. It is not the route for complaints from beneficiaries or the public, and it is not the whistleblowing route — more on that trio below, because muddling them is the single most common mistake.
The direct answer to the question that probably brought you here: if your charity employs anyone at all, you need a grievance procedure in writing. If it is run entirely by volunteers, you don't — though a simple problem-solving route for volunteers is still wise.
Is a grievance policy legally required for a charity?
For any charity with staff, the legal position has three layers, and it is worth being precise about each.
First, statute. Section 3 of the Employment Rights Act 1996 requires the written statement of employment particulars — the document every employee and worker must receive — to specify "a person to whom the worker can apply for the purpose of seeking redress of any grievance relating to his employment" and the manner in which that application should be made. So the essentials of a grievance route are not optional good practice; they are a required part of the written statement — the s.3 note may lawfully follow within two months of the start, but the tidy course is to include it from day one. The tidiest way to satisfy this is a short grievance policy the statement can point to.
Second, the Acas Code of Practice on disciplinary and grievance procedures. The Code is not legislation, but section 207A of the Trade Union and Labour Relations (Consolidation) Act 1992 lets an employment tribunal move an award by up to a quarter in either direction depending on who unreasonably ignored it — up to 25% more where the employer failed to follow the Code, up to 25% less where the employee did. A charity that handles a grievance without a fair procedure is therefore risking a quarter more on any award it loses, on top of the reputational cost.
Third, the right to be accompanied. Under section 10 of the Employment Relations Act 1999, a worker who reasonably requests it must be allowed to bring a trade union official, a certified union representative or a fellow worker to a formal grievance hearing (the statutory right covers grievances about duties the employer owes the worker — in practice, almost all of them). This applies whether or not your policy mentions it — but your policy should mention it, so nobody finds out mid-dispute.
One clarification that saves confusion: the Charity Commission's Annual Return (2023–26) asks charities about 13 named policies, and a grievance policy is not one of them — but a bullying and harassment policy is. The two work together, as the harassment section below explains. For where the grievance policy sits in the wider set, see our pillar guide to what policies a charity needs.
Grievance, whistleblowing or complaint? Get the trio right
Searchers — and, in fairness, plenty of boards — routinely reach for the wrong policy here. The test is who is raising it and what it is about.
- A grievance is raised by a member of staff about their own treatment: pay, workload, working conditions, the behaviour of a manager or colleague towards them. It follows this policy.
- A whistleblowing disclosure is about wrongdoing that affects others or the public interest — fraud, a safeguarding cover-up, danger to health and safety, a breach of a legal obligation. Workers who raise these are protected by the Public Interest Disclosure Act 1998, and the concern should follow the whistleblowing route, which typically allows escalation past line management to a named trustee.
- A complaint comes from outside the staff team — a beneficiary, donor, volunteer or member of the public unhappy with the charity — and follows the complaints policy.
Real situations straddle the lines: a staff member alleging their manager is bullying them (grievance) may also allege the manager is falsifying expense claims (whistleblowing). A good grievance policy says explicitly that where a concern is really a public-interest disclosure, it will be handled under the whistleblowing procedure, and that raising it under the wrong heading will never count against the person. Route the issue to the right procedure; don't bounce the person.
What your charity grievance policy must include
Here is the anatomy of a grievance policy that works for a small or medium England and Wales charity — the sections to include and what good looks like in each.
Purpose and scope
Say what the policy is for and who it covers: employees, and normally other workers, of the charity. State plainly that volunteers are not covered and are directed to the problem-solving route in the volunteer policy instead. This exclusion is deliberate: applying an employment procedure to volunteers can blur their status and imply an employment relationship neither side intends.
Informal resolution first
The Acas Code expects issues to be resolved informally where possible, and in a team of four that is doubly true. Encourage staff to raise concerns with their line manager early, and allow a quiet conversation or facilitated discussion before anything is put in writing. But state clearly that informal resolution is an option, never a gate: a member of staff may go straight to the formal stage, and serious matters — harassment above all — should not be pushed through an informal filter.
The formal grievance: in writing, to whom
This is the clause section 3 of the ERA 1996 exists for. The formal stage starts with a written grievance — a letter or email setting out the facts — and the policy must name the recipient. In most small charities: grievances go to the line manager; if the grievance concerns the line manager, to the CEO or most senior staff member; and if it concerns the CEO, to the chair of trustees. That last line is the distinctly charity-shaped one, and it is the line most borrowed corporate templates lack. Without it, a grievance about the CEO lands on the CEO's own desk.
The grievance meeting
Commit to holding a meeting without unreasonable delay — many charities promise to aim for five working days from receipt, which is realistic for a small team — and to giving the person a genuine chance to explain their grievance and how they think it should be resolved. State the right to be accompanied by a trade union official, certified union representative or fellow worker under section 10 of the Employment Relations Act 1999, and what the companion may do: put and sum up the case, respond to views expressed, confer with the worker — but not answer questions on their behalf.
Investigation
Say that the charity will investigate as needed before deciding — speaking to people named, reviewing documents — and that the meeting may be adjourned to allow this. In a small charity the same person often hears the grievance and investigates it; that is acceptable at the first stage, provided the appeal goes to someone fresh.
The outcome, in writing
The decision goes to the member of staff in writing, without unreasonable delay, stating what was decided, what action the charity will take, and the right of appeal with a deadline (commonly five working days) and the person to write to.
Appeal — to someone not previously involved
The Acas Code expects appeals to be heard, wherever possible, by someone not previously involved. In a three-person staff team that person will usually be a trustee, and many charities name a small panel of two or three trustees as the appeal body — which also handles appeals where the chair heard a grievance about the CEO at the first stage. The appeal outcome is confirmed in writing and is final.
Collective and overlapping grievances
Two short clauses save real headaches. Where several staff raise the same grievance, the charity may handle it as one process with a shared outcome — though note the Acas Code itself does not apply to collective grievances raised on members' behalf by a recognised trade union representative. And where a grievance is raised during a disciplinary process — a common collision — the charity may pause the disciplinary to deal with the grievance, or run the two concurrently where they are related, as the Acas Code envisages. Cross-refer to your disciplinary policy so the two documents use the same names and timescales.
Harassment cases and the prevention duty
Since 26 October 2024, every employer — charities included — has been under a proactive legal duty to take reasonable steps to prevent sexual harassment of its workers, under the Worker Protection (Amendment of Equality Act 2010) Act 2023, with tribunals able to uplift sexual harassment compensation by up to 25% where the duty is breached. A working grievance route is one of the reasonable steps: it is often the channel through which harassment first surfaces. Your policy should say that complaints of bullying, harassment or discrimination may be raised under it, will be treated seriously and confidentially, and where the charity has a separate bullying and harassment policy — one of the 13 the Annual Return asks about — will be handled under that policy's procedure. Never let a harassment complaint stall because it arrived under the "wrong" heading.
Records
State that a confidential written record is kept of formal grievances — the written grievance, meeting notes, outcome and appeal — held in line with your data protection policy and retention periods, separate from the general personnel file and accessible only to those who need it.
Review
Name the policy's owner (usually the CEO or the trustee holding the HR brief) and a review date. Every two to three years is a sensible cycle for a grievance policy, with earlier triggers listed below.
Download our free charity grievance policy template (Word) — openly licensed, written for small charities in England and Wales, and yours to adapt with no sign-up.
Acas also publishes a free grievance procedure template in Word under the Open Government Licence, along with its wider set of templates — an excellent generic starting point, though you will need to add the charity plumbing yourself: the chair as recipient for CEO grievances, the trustee appeal panel, and the volunteer exclusion.
Adopting it properly
A grievance policy takes effect when the board adopts it, not when a file lands in a shared drive. Tailor the template first — real names or roles at every stage, timescales your team can actually meet, and the routes for grievances about the CEO or involving a trustee thought through before you need them. Then put it to a trustees' meeting, record the adoption decision in the minutes with the version date, and minute the owner and review date at the same time. If you're refining how decisions like this get recorded, our guide to chairing a charity meeting covers taking clean decisions in small boards. Trustee Meetings keeps your policies, owners and review dates alongside your agendas and minutes and resurfaces each policy when its review falls due — free to try, no card needed.
Finally, close the ERA 1996 section 3 loop: check every written statement of employment particulars names the grievance recipient and the manner of applying, or points to the policy that does.
Common mistakes in charity grievance policies
- No route for grievances about the CEO. The commonest gap. If the policy's only recipient is "your line manager or the CEO", a grievance about the CEO has nowhere lawful to land. Name the chair.
- No untouched person left for the appeal. If the CEO hears the grievance and the chair hears the appeal, what happens when the grievance was about the CEO and the chair helped investigate? Keep a small trustee panel in reserve.
- Copying a corporate template wholesale. "Refer the matter to your HR Business Partner" is a promise a four-person charity cannot keep. Every named role must exist in your charity.
- Sweeping volunteers in — or leaving them with nothing. Volunteers shouldn't use the employment procedure, but they need a stated problem-solving route somewhere, or their concerns arrive as safeguarding incidents and resignations.
- Treating a whistleblowing disclosure as a personal grievance. A worker who reports fraud is not "having a workplace issue", and handling a protected disclosure badly engages the Public Interest Disclosure Act 1998. Route it correctly and say so in the policy.
- Timescales nobody can meet. Promising a hearing within 48 hours reads well and fails in week one of the CEO's annual leave. Promise "without unreasonable delay" with realistic working-day targets.
- Trustees improvising when a grievance involves a trustee. Rare, but combustible. A line saying the chair (or vice-chair, if the chair is involved) will decide who hears it keeps the process out of board politics.
When to review your grievance policy
Review the policy every two to three years as a matter of course. Bring the review forward when employment law moves (as it did with the October 2024 prevention duty), when the Acas Code is revised, when your staffing structure changes — a first CEO, a new tier of managers, recognition of a union — after any formal grievance that exposed a gap in the procedure, and whenever the named roles no longer match real people. The review, like the adoption, belongs in the minutes; a dated minute trail is what turns a policy from a document into evidence that your charity actually governs itself. Logging the review as an action with an owner — the approach in our trustee action log guide — is the simplest way to make sure it happens, and our free template includes a version-control table ready for exactly that.
If you're building out the full policy set, start with the pillar guide to what policies a charity needs, then the near neighbours of this one: the disciplinary policy that shares the Acas Code and the 25% adjustment, the complaints policy for concerns from outside the staff team, and the volunteer policy that houses the problem-solving route this policy deliberately leaves out.