A grievance procedure for a company with no HR department
Ganesh HS ·
In brief
Without a written route, what happens to a complaint depends on who hears it first — and employees work that out quickly.
A small company needs two things: a named alternative to the person's own manager, and a written record of what was decided.
Grievances and disciplinary matters are different routes. Running them through the same process is how a complainant ends up feeling investigated.
Complaints of harassment sit outside the ordinary route and need qualified advice, not a general procedure.
An employee comes into your cabin and says his supervisor has been singling him out. You listen, you say you will look into it, and you probably do. Three weeks later he has not heard anything, the supervisor has heard about the complaint from somewhere, and the employee is now certain that raising it was a mistake.
Nothing improper happened. You did look into it. But nothing about the process was written down, so the employee could not know it was happening, the supervisor learnt about it informally, and there is no record of what you concluded. The next person with a complaint will go to a colleague instead, and you will hear about it after they resign.
Two routes, kept separate
The commonest structural mistake is running everything through one process. A grievance and a disciplinary matter move in opposite directions and mixing them does real harm.
A grievance is raised by an employee about their work, their treatment or their conditions. The company is responding to them.
A disciplinary matter is raised by the company about an employee's conduct or performance. The company is acting on them.
They must not share a form or a route. When a complainant is put through a process that feels like an investigation of themselves, they stop complaining — and so does everyone they tell.
What a small company actually needs
Not a manual. Four decisions, written on one page and told to everybody.
1
Who receives a complaint
Name a role, and name an alternative that is not the person's own manager. This second name is the whole point: a complaint about a supervisor cannot be routed through that supervisor. In a company with no HR, the alternative is usually a founder or a specific senior person.
2
What happens within how long
Acknowledged within a set number of working days, looked into within a further period, outcome communicated by a stated point. Write the numbers down and make them realistic, because a missed commitment is worse than a longer one.
3
What gets recorded
What was raised, when, by whom, what was checked, what was decided and what was communicated. Half a page. This is what makes the second similar case consistent with the first.
4
What the employee is told at the end
An outcome, in a conversation, even where the outcome is that no action is being taken. The single largest source of grievance about grievances is silence.
A one-page procedure
Grievance procedure — one page
RAISING
Any employee may raise a concern about their work, treatment
or conditions. Verbally or in writing.
Receive: <role>. Alternative if the concern involves that
person or the employee's own manager: <named role>.
ACKNOWLEDGEMENT
Within <N> working days, in writing, confirming what was
understood and what happens next.
LOOKING INTO IT
Within <N> working days. Speak to the people involved.
Keep a written note of what each said.
The person complained about is told what has been raised
and given a chance to respond.
OUTCOME
Communicated to the employee in a conversation, then in
writing. An outcome of 'no further action' is still an
outcome and is still communicated.
IF THE EMPLOYEE IS NOT SATISFIED
One review, by <named role>, whose decision closes it.
RECORD
Held by <role>, separately from the employee's personnel
file, accessible to <named roles> only.
One review stage, not three. Small companies that copy a large-company procedure with multiple appeal levels end up with a process nobody completes.
The part most people get wrong
Telling the person complained about. It feels like escalation, and the instinct is to look into it quietly first. But a supervisor who learns from the floor that a complaint was made about them will behave worse, not better — and the complainant is the one who pays for it.
Tell them what has been raised, in a controlled conversation, and give them the chance to respond. That is both fairer and, in practice, safer for the complainant than the informal route.
Consistency is what you are actually buying
The test of a grievance procedure is not the first case. It is the second similar one, eighteen months later, handled by a different person — and whether the two outcomes can be explained side by side.
That is why the record matters more than it looks. Two employees who did much the same thing and received different treatment will find out, and the difference is only defensible if somebody wrote down at the time why it was different. Getting that discipline in place is the substance of grievance and disciplinary process work — two routes, named receivers, and a record that survives the person who made the decision.
Tell people it exists
A procedure nobody has been told about is a document. Brief it at induction, put it in the handbook, and say the alternative name out loud — because the entire value of that second name is that an employee knows it before they need it.
It belongs in the same controlled set as your other policies, with one current version and one owner, which is what HR documentation work is for. And where the same grievance keeps arriving from the same team, the answer is usually not a better procedure but a manager who has never been shown how to have a difficult conversation — which is leadership and people management territory rather than process.
What to do with the first real case
The first complaint raised after the procedure is written is the one that decides whether anybody uses it again. Two things matter more than the outcome: that the stated timings are met, and that the employee hears the conclusion from a person rather than by inference.
If the timings cannot be met — and sometimes they genuinely cannot — say so before the date passes, with a new date. A missed commitment that is explained costs very little. A missed commitment followed by silence costs the whole process.
Write the case up while it is fresh, in the half page the procedure calls for. It will feel unnecessary at the time. It becomes essential eighteen months later when a similar case arrives and somebody asks what was done last time, which is the entire reason grievance and disciplinary process work insists on the record rather than only the route.
When the same complaint keeps arriving
A procedure handles individual cases well and tells you nothing about patterns unless you look. Once a year, read the records together: which team they came from, what they were about, and how they were resolved. Three complaints from one team of eight is not three cases, it is one.
The record you keep when nothing is upheld
Most grievances in small businesses are not upheld, and the handling of that outcome is what determines whether anyone uses the procedure again.
A concern that is investigated and found not to be substantiated still needs a written outcome: what was looked at, what was concluded, and why. Not a finding against the person who raised it. A complainant who receives nothing in writing concludes the process was theatre, and tells colleagues so.
The record matters for a second reason that emerges later. Three unsubstantiated concerns about the same individual, over two years, raised by different people, is a pattern that no single investigation would have found. Without written outcomes, each is handled in isolation and forgotten, and the pattern only surfaces when something serious happens.
Keep the outcomes somewhere durable and restricted, held by role rather than by the individual who happened to handle it. The commonest failure in businesses without an HR function is that the record lives in the mailbox of whoever dealt with it, and leaves when they do — which means the business is repeatedly handling a first occurrence.
That reading is usually uncomfortable and almost always more valuable than the individual outcomes were.
Questions we are asked
At twenty people it is one page and takes an afternoon, and it is far easier to establish before the first difficult case than during it. The size at which it becomes necessary is usually the size at which the founder is no longer present for every conversation.
Name someone else in advance — another director, a senior person, or an external adviser — and say so in the procedure. A route that has no alternative when the complaint reaches the top is a route employees will not use.
Accept them, but be honest that an anonymous complaint is harder to look into and may limit what can be done. Most businesses find that the option existing matters more than the option being used.
Keep them for a defined period, held separately from the personnel file and accessible to named roles only. How long is a question for your legal adviser, and worth settling once rather than case by case.
That is a legitimate outcome and should be communicated as clearly as any other, with the reasoning recorded. What causes damage is not an unfavourable outcome but an outcome the employee never actually receives.
Most settlement disputes are sequencing failures, not calculation errors. The order the steps must run in, who owns each one, and where the delay actually comes from.
Most exit interviews are held, filed and never read again. How to run one that produces findings a business can act on, and what to do with what it tells you.