6.2 Policy Development Procedure
1. Introduction
1.1 Preamble
Catalpa’s policies establish a framework of principles and standards that inform, guide, regulate and protect the behaviour and activities of Catalpa.
While other core documents such as Catalpa’s Strategic Plan set the general direction for Catalpa as an organisation, it is the principles and standards set out in Catalpa policies that shape the way in which we operate in striving to achieve our desired impact.
In short, Catalpa policies set the ground rules that regulate the way in which Catalpa carries out our work.
1.2. Statement of intent
It is the intention of Catalpa that policies are to be developed, formatted, approved, issued, maintained and reported on in a consistent manner, with the engagement of appropriate Catalpa stakeholders, and be made widely available to Board members, staff, contractors and where required partners in order to enhance compliance and understanding of Catalpa’s operations.
1.3. Policy Linkages
This procedure is relevant for all Catalpa policies as it informs their development and their later review. A current list of all Catalpa policies can be found at the Register of Catalpa Policies and Compliance Requirements.
2. Purpose
The purpose of this procedure is to ensure that Catalpa policies and procedures extend our mission, are developed and implemented in accordance with required laws, principles and standards, with a standardised process, and with the engagement of appropriate stakeholders.
3. Scope
This Policies Procedure provides the structure for developing, maintaining and disseminating the policies of Catalpa. It covers policies relating to:
Governance
How we work (from a digital and international development perspective)
Marketing and Communications
Operations including Administration, Finance and Compliance
People and Culture
Safety and Security
Project specific policies
This procedure does not cover the development of issue-based policies/ discussion papers i.e a position paper on localisation or cyber-security in the development sector.
If in question, all other policy documents are subject to the requirements of this Policy Development
procedure.
This procedure applies to all Board members, employees, contractors and subcontractors of Catalpa, and to downstream partners where applicable.
4. Procedural requirements
4.1 Principles for all policy development
Inconsistent Policies and related documents. No procedures or practices are to be adopted that are inconsistent with an existing official Policy without addressing this inconsistency. In the event of a conflict between an existing Catalpa Policy and any document, the existing Catalpa Policy supersedes as default. However if it has been identified that the existing Catalpa Policy needs to be updated and amended, that can be done following the process contained in this document; however it is not permitted to develop conflicting and/or inconsistent Catalpa documents.
Periodic Review of Policies. The personnel delegated to develop a new policy (see section 4.2.1 below) are responsible for keeping the Policy current and for the performance of periodic reviews to ensure that the Policy complies with and reflects current laws, regulations, quality and accountability standards, and practices.
Withdrawal of Policies. A Policy may be withdrawn by the Catalpa Directors. Such withdrawal must be communicated to employees and others engaged in implementing using the policy.
Policy Implementation. Catalpa policies inform our procedures and guidelines, and are disseminated in various ways including through staff and partner workshops, on our website and through relevant signage. Policy indicators relating to successful implementation of key policies will be monitored and reported to the Catalpa Board and Management Team on an agreed schedule. Implementation of policies is addressed in Catalpa’s Handbook.
Interpretation of this Policy. The Catalpa Board on advice from the People and Culture Manager is responsible for determining if a Policy has been properly approved and is in effect. The Director’s adoption, reaffirmation, and or revision date on the front page of the Policy indicates final approval.
4.2 Considerations prior to developing a new policy
The need for a new policy, or review of an existing policy can be generated by:
Catalpa Board request
Catalpa Staff request
Other stakeholders, including institutional donors, regulatory and compliance bodies or others.
Policies created at Catalpa should address an identifiable need in the organization. Policies don’t need to be created for every unforeseeable event or hypothetical scenario.
4.2.1 Delegations for developing new policies
Policies should only be developed by Catalpa personnel where approved by the Catalpa People and Culture Manager in consultation with the relevant Senior Manager. Permission should be received from the People and Culture Manager, with detail as to who needs to be involved as stakeholder / reviewers of the draft Policy.
The policy should then be recorded as under-development in the Register of Catalpa Policies and Compliance Requirements, including the ‘level of priority’ for this policy’s development.
4.2.2 Considerations when developing a new policy
All new policies or policies being revised must consider:
The laws, regulations and legal requirements in the countries we work in
International best practice
Catalpa’s vision and values and principles as adopted in the Strategic Plan
Related Catalpa policies
Anyone developing a new policy should first check the Register of Catalpa Policies and Compliance Requirements to see what existing policies or new / revised policies are in the pipeline that would intersect and interact with the new policy, and to insert the details of the proposed new policy in the Register (at link above).
Major Institutional Donor requirements as relevant (i.e. DFAT, Managing Contractors, Private Sector donors ect.)
Regulatory and legal requirements from ASIC/ACNC and relevant standards where applicable (AICD ect.) - noting that Catalpa is a business registered in Australia and any operating requirements for the jurisdictions which cover various country based operations. As we work across multiple geographies with varying stances on regulatory requirements, authors need to consider the policy stance to be taken. As a general rule of thumb, in terms of development of policy Catalpa takes the ‘highest bar’ and applies this in all countries we work in.
It is important to ensure policies:
Adequately address Catalpa obligations
Clarify implications of the policy for Catalpa and our downstream partners (where applicable)
Reflect adequate stakeholders consultation and ‘end user’ ownership
Confirm how progress toward policy commitments can be measured - measuring progress can be done through policy indicators which can be monitored and reported on to understand progress in implementing the policies (e.g. an indicator for the Child Safeguarding Policy could be % of Catalpa personnel trained in safeguarding).
Are clearly written and concise. Policies should be written in clear, concise plain english language so they are easily readable and understood by our staff, for many of whom English as a second language. However, they should also have flexibility built into their wording and structure, to ensure ease of application when different situations arise. Terms like “generally,” “typically,” and “usually” give readers more room to interpret and apply policies.
When crafting policies, it’s best to avoid:
Rigid language, like stating that the business will “only” or “always” act in a certain way except in circumstances when explaining a compliance or legal obligation
All-inclusive lists
4.3. Process for drafting and seeking approval for a new policy
4.3.1. Outline/structure for use in drafting policies
Policies should be set out in the same format / structure as other Catalpa policies, as per Annex One.
4.3.2. Process for drafting
Draft policies should be saved in the ‘Sandbox’ shared drive in the ‘documents in creation’ folder until they are ready for review – access can be granted by the People & Culture Manager.
After a draft policy has been developed, it should be reviewed by the stakeholders / reviewers that were allocated when approval for policy development was granted (see section 4.2.1. above).
When all relevant stakeholders have reviewed, a version of the draft should be kept retaining all comments / inputs and a fresh “clean” version should be saved into the Sandbox “documents ready for review” drive folder. An email should be sent to the drafter’s line manager and the relevant Director that the policy is ready for their final review.
4.3.3. Process for seeking approval for the new policy
Once the policy is endorsed by the People and Culture Manager, they will forward to the Management Team for their information and comment within a reasonable timeframe.
All governance related policies must be reviewed / signed off by the Directors.
4.3.4. Process for reviewing policies and ensuring they are kept up to date
When drafting a new policy or updating an existing policy, the first page of the Policy should identify the policy author and state how frequently it needs to be reviewed. It is the responsibility of the policy owner to review the policy within the required time. This information should also be inserted into the ‘register of Catalpa policies’ to enable tracking of these reviews.
The schedule of reviews should be determined in reference to any overarching legal, operational, back donor or stakeholder requirements.
Reviews can occur more frequently than indicated in the schedule of reviews in the policy, as needed.
Within the policy review process there are two primary levels of revision:
Substantive Policy Revision: Any revision to a policy which has a bearing on decision making processes, or is otherwise deemed a change material enough to alter the policy significantly. These can include, but are not limited to major changes to the rationale, goal and implementation of the policy.
Non-substantive Policy Revision: Any revision to a policy which does not have a bearing on decision making processes, or is otherwise deemed a change which does not alter the policy significantly. These can include, but are not limited to, factual or grammatical changes, and formatting.
Substantive policy revision should be communicated to all relevant stakeholders during the revision process (see ‘process for drafting’ in section 4.2.1).
4.3.5. Process for communicating a finalised policy
A process for communicating the finalised policy should be agreed on approval of the final policy by the Management Team as advised by the People and Culture Manager and the policy author.
Depending on the nature of the policy, consideration should be given to how both Catalpa staff and partners who may be impacted by the policy are informed and whether Catalpa operational documentation (handbook, onboarding guidance, contracts, operations manuals etc. need to be updated).
Consideration should also be given to whether a translated version of the policy needs to be developed or communication of the policy needs to be provided in the local language.
All Catalpa wide policies must be published in the Catalpa handbook.
Annex One. Suggested Outline / structure for Catalpa policies to guide development
Date of development
Dates of reviews
Date of next review
Introduction
Preamble (optional)
Statement of commitment
Policy review and approval
Policy linkages
Purpose and Scope
Purpose
Scope
Glossary (optional)
Policy principles
(insert heading as needed specific for the policy)
(insert heading as needed specific for the policy)
Communicating the policy
Policy monitoring and review
Annex – definitions
Annexes (add as needed)
Annex Two. Definitions and Explanations
Types of policies:
Organisation-wide Policy: an essential part of Catalpa’s governance, a written plan or general course of action, having broad application throughout Catalpa, intended to govern the actions of our Board, staff, contractors etc. A Catalpa Policy helps ensure compliance with applicable laws and regulations; promotes the mission of Catalpa; contains guidelines for governance; and/or sets limits within which stakeholders are expected to operate.
Project-specific policy: establish a framework of principles and standards that inform, guide and regulate the behaviour and activities of Catalpa and its staff and our ‘downstream partners where applicable). These are specific to one project although should be reflective of and aligned with any relevant organisation-wide Policy i.e. if there is a project-specific gender policy it should align with Catalpa’s organisation-wide Gender Policy. Before a project policy is developed the question should be asked if an organization wide policy is required instead.
Issue-specific policy: This can be a position paper or another document outlining Catalpa’s views and approach to an issue. An example would be a position paper or policy on localisation.
Principles are fundamental norms, rules or values that represent what Catalpa and Catalpa’s governing body believe is desirable and positive for Catalpa’s staff and partners, and any associated volunteers, consultants, and partners that help to determine what is right and wrong.
Procedures are closely linked to policies and are a sequence of steps, actions, decisions, and processes that should be followed consistently to accomplish an end result. Together, policies and procedures are used to facilitate, guide and empower a process with the direction and consistency necessary to achieve high quality results. Procedures are included in Catalpa’s Handbook. Catalpa’s operational procedures do not need to be endorsed by Catalpa’s governing body as they are operational and designed to help staff and partners fulfil their obligations.
Guidelines, while an essential part of Catalpa governance, are designed to make the actions of Catalpa staff and partners more predictable and ensure greater quality and accountability. Guidelines are not mandatory. They are highly advised and serve to recommend ‘how’ actions should be undertaken to achieve desired results. Catalpa’s operational procedures do not need to be endorsed by the Board as they are operational level and designed to help staff and partners fulfil their obligations.
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