The Pension Service (TPS), one of the sub-agencies of the Department for Work and Pensions (DWP), found that only 6% of all contacted customers had made a complaint to TPS.<sup>17</sup> Customers who had never complained to TPS were asked if they had ever considered complaining. Seven percent of contacted customers had considered complaining but had never done so.<sup>18</sup> The report included a table of the reasons customers did not complain, with the majority of customers claiming that they ―thought nothing would happen as a result of the complaint.‖<sup>19</sup> While TPS and the DWP as a whole have made efforts to address customer satisfaction and be responsive to their needs, the internal redress procedure currently in place suffers from a lack of legitimacy. A higher percentage of customers who had complaints would probably put in formal complaints if they believed that an independent party would look at them objectively.

Ethiopia‘s Productive Safety Net Program empowers a local appeals committee, which is independent from the targeting and graduation structure of the program, to hear complaints and grievances. The program uses a standardized client card that lists a charter of rights and responsibilities, among which are enumerated the right to appeal a decision and the responsibility to report abuses. A study found that, of households that described the targeting process as unfair, 23% had lodged a complaint.<sup>20</sup>

**_Legality_ .** Redress procedures vary in the extent to which they exhibit legal attributes. These include standards for the kinds of evidence to be presented (including third party verification of the accuracy of the claims and the administrative responses to them), the public availability of both the complaints petitions themselves and the reasoning behind the dispute resolver‘s response, and the incorporation of other trial-like characteristics (such as adversary legalism) into the procedures to be used.<sup>21</sup> Obviously, courts are more likely to exhibit these legal attributes than other redress procedures; but if venues outside of courts are empowered to handle significant harms, such as sexual assault on the part of a medical provider or a teacher, or a significant loss of earnings from the denial of benefits, they will likely need safeguards to ensure the quality of the adjudication process, even if those safeguards are not identical to the legal ideal. In instances such as sexual assault, redress procedures will need credible guarantees of anonymity for the complainants. On the other hand, making complaints public and accessible to NGOs, journalists, and others, wherever possible, will multiply the ―fire alarms‖ monitoring power of redress procedures. Of course, as legal safeguards increase, so do the costs of providing the redress procedures.

> 17 DWP, 2007, The Pension Service Customer Survey 2007, Research Report no. 532, 140.

> 18 _Id._ , at 143.

> 19 _Id.,_ at 144, Table 8.2: ―Why did not complain after considering.‖

> 20 Will Wiseman, Designing and Implementing a Rural Safety Net in a Low Income Country: Lessons Learned from Ethiopia‘s Productive Safety Net program 2005-2009. World Bank.

> 21 See Robert A. Kagan, _Adversarial Legalism: The American Way of Law_ . Harvard University Press 2003.

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