Policies

The Australian Migrant Resource Centre (AMRC) is committed to fostering a culture of excellence and integrity. Our Workplace Excellence and Ethical Conduct Policy Statement is the cornerstone of our commitment to uphold the highest standards of professionalism and ethical behaviour. This policy statement is a guide for all employees to conduct business professionally, treat one another with respect, and work collaboratively to achieve our shared goals. We at AMRC believe that a strong ethical foundation is essential for our success and reputation. We expect every team member to contribute to an environment where excellence is the norm, and ethical conduct is valued above all.

AMRC is guided by a set of fundamental core values that shape our culture and inform our actions. Our commitment to these values enables us to perform effectively and conduct ourselves ethically in all aspects of our work.

Integrity: We act with honesty and ethics without compromising the truth.

Accountability: We take responsibility for our actions and outcomes.

Respect: We value diversity and unique contributions, fostering a trusting, open, and inclusive environment.

Excellence: We strive for the highest quality and continuous improvement.

Collaboration: We work together to achieve collective and individual goals.

Innovation: We embrace change and creativity to deliver the best solutions.

Stewardship: We manage our resources responsibly to ensure long-term sustainability.

In adherence to our commitment to ethical conduct and workplace excellence, AMRC requires all employees to comply with all applicable Australian laws and regulations. This includes but is not limited to, the Fair Work Act 2009, anti-discrimination laws, health and safety legislation, and privacy laws. Our operations and business practices are designed to ensure full legal compliance and uphold the principles of fairness, honesty, and respect for the rights of all individuals. Employees are expected to understand and abide by these legal standards in their professional conduct and are encouraged to seek guidance if they encounter any uncertainty regarding legal obligations.

AMRC is dedicated to maintaining a professional and respectful work environment. All employees are expected to conduct themselves in a manner that contributes positively to our workplace and which is in accordance with the AMRC Code of Conduct. This includes treating colleagues, clients, and partners with respect, courtesy, and consideration. Discrimination, harassment, or any inappropriate behaviour will not be tolerated. We are committed to creating an inclusive environment where diversity is celebrated, and every individual is valued and empowered to contribute to our collective success.

AMRC is committed to conducting business with the highest level of integrity. Employees are expected to avoid personal, financial, or other interests that impact their capability or willingness to perform their duties impartially. Employees must disclose any situations that may be interpreted as a conflict of interest with AMRC. Upon disclosure, AMRC will work with the employee to resolve the conflict ethically and transparently. All employees are required to act in the best interests of AMRC, ensuring that business decisions are not influenced by personal considerations.

AMRC is committed to transparency and accountability. To uphold our standards of workplace excellence and ethical conduct, we provide secure and accessible channels for reporting any concerns or violations of this policy statement. Employees are encouraged to report any misconduct, unethical behaviour, or conflicts of interest through the following mechanisms:

• Direct Reporting: Employees may report concerns directly to their immediate supervisor, manager or CEO.
• Anonymous Reporting: For those who wish to maintain anonymity, AMRC offers an anonymous feedback boxes and online submission form.
• Protection from Retaliation: AMRC prohibits retaliation against any employee who reports a concern in good faith. We ensure that all reports are treated with the utmost confidentiality and discretion.

We are dedicated to promptly addressing and investigating all reports to maintain the integrity of our workplace.

In the event of non-compliance with our policies, disciplinary actions may be taken, depending on the severity and frequency of the violation. All disciplinary actions will be documented, and employees can respond to allegations of non-compliance. AMRC ensures that all disciplinary procedures are conducted fairly and transparently, following applicable Australian laws and regulations and aligned with the AMRC Disciplinary policies and procedures.

This Policy Statement shall be subject to an annual review no later than the anniversary of the policy’s effective date. A review may be conducted sooner if applicable, such as in response to regulatory changes, significant organisational shifts, or other pertinent circumstances, at the discretion of the CEO.

The Australian Migrant Resource Centre (AMRC) is committed to keeping information that it collects about its staff, volunteers, clients, members, donors and board members safe and secure protecting their privacy.

The AMRC will only collect information that is required to fulfil its ethical and legal responsibilities and provide appropriate and timely services.

This privacy policy sets out how the AMRC complies with its obligations under the Privacy Act 1988 (Cth) (the Privacy Act). This Policy applies to all personal information collected by the AMRC.

The Privacy Act sets out 13 Australian Privacy Principles (APPs) which regulate the collection, use, disclosure and storage of personal information and how individuals can access and correct personal information held about them. The AMRC is legally bound by the APPs.

The AMRC provides a comprehensive range of settlement services to refugees and migrants in South Australia.

In performing its functions the AMRC may collect, hold, use or disclose personal information. The AMRC takes privacy seriously and will only collect, hold, use and disclose personal information in accordance with the Privacy Act.

“personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

“sensitive information” means information or an opinion about an individual’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of professional/trade associations, membership of a trade union, sexual orientation/practices, criminal record, health information or genetic information.

“health information” means information or an opinion about:

• the health or a disability (at any time) of an individual;
• an individual’s expressed wishes about the future provision of health services to him or her;
• a health service provided, or to be provided, to an individual;
• personal information collected to provide, or in providing, a health service;
• an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances; or
• genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.

You should read this privacy policy if you are:

• an individual whose personal information may be given to or held by the AMRC;
• a contractor, consultant, supplier or vendor of goods or services to the AMRC;
• a donor to the AMRC;
• a person seeking employment with the AMRC;
• a person who is or was employed by the AMRC; or
• a person seeking to be or who is a volunteer with the AMRC.

The AMRC only collects the personal information that is reasonably necessary for, or directly related to the services that it delivers.

When the AMRC collects personal information, the AMRC is required under the Privacy Act to notify you of a number of matters. These include the purposes for which the information is collected, whether the collection is required or authorised by law and any person or body to whom the information will be disclosed. The AMRC generally provides this notification by having Privacy Notices on relevant forms.

The personal information collected and held by the AMRC for clients of our programs may include:

• information about your identity (e.g. name, date of birth, country of birth, passport details, visa details, drivers licence, birth certificates, ATM cards);
• contact details (eg address, telephone number, email address);
• information about your background (e.g. educational qualifications, the languages you speak and your English proficiency, employment history);
• information about your racial or ethnic origin;
• bank details;
• health and medical information; and
• information about personal circumstances (e.g. marital status, age, gender, accommodation and relevant information about your partner or children).

The AMRC generally uses forms and other electronic or paper correspondence to collect this information. Personal information will be obtained by employees of the AMRC during direct client interaction or through documentation.

Government authorities including the Department of Human Services and Department Home Affairs provide clients’ personal information to the AMRC in its capacity as service provider.

Personal information about AMRC staff and volunteers is collected when staff submit an application in response to an advertised position and when requested to provide updated information about qualifications and professional development. This information is stored in staff personnel files.

The AMRC holds personal information in a range of paper-based and electronic records.

The AMRC ensures that only those staff that need to access personal information have access to that information. Only limited information is provided to volunteers.

The personal information you provide will be used only for the purpose for which it was submitted unless we specifically disclose other uses and obtain your consent.

The AMRC collects certain personal information about you in order to:

• Assess what services you may require and whether we can provide those services;
• Verify your identity and eligibility;
• Evaluate ongoing services provided to you;
• Assess your application to become a volunteer, contractor or employee;
• Perform approved research and analysis;
• Complete funding applications and statistical reporting to comply with service agreements;
• Process donations;
• Comply with AMRC Human Resources policies and procedures (for staff only);
• Communicate with you;
• Comply with any legal or contractual obligations; and
• Improve our services.

The AMRC will only use your personal information for secondary purposes where it is able to do so in accordance with the Privacy Act.

By giving your personal information to the AMRC you are consenting to the use of that personal information in accordance with the principles outlined in this policy.

The AMRC will obtain written consent from you before any personal information is collected from you.

The AMRC will not disclose or pass on your personal or sensitive information to a third party without your prior consent, except where that disclosure is authorised or required by law, is reasonably necessary to enforce the law, or necessary to investigate a suspected unlawful activity.

The AMRC does not use or disclose your personal information for the purpose of direct marketing.

All AMRC employees and volunteers must keep all personal, health and sensitive information about clients, staff, volunteers, members, donors, board members and information gained during the course of their employment with the AMRC private and confidential and sign a Confidentiality Agreement. All AMRC employees and volunteers are given a copy of this privacy policy and must acknowledge that they will act in accordance with this policy.

The Information Sharing Guidelines for promoting safety and wellbeing (ISG) provide a consistent state-wide process for information sharing between relevant government agencies and with non-government agencies where there is a risk to the safety or wellbeing of a person. The ISG defines a process for information sharing that promotes early and effective service coordination to respond to safety risks facing vulnerable people. The AMRC ISG Appendix sets out the procedure that supports implementation of the ISG within AMRC.

The ISG and the AMRC ISG Appendix must be followed by all AMRC staff and volunteers.

Under the ISG a worker may share information while maintaining the balance between people’s right to safety and wellbeing and their right to privacy.

The ISG and the AMRC ISG Appendix do not alter a mandatory notifier’s legal obligation to report suspicion of abuse or neglect on reasonable grounds to the Child Abuse Report Line (CARL).

The ISG can be accessed via the SA Ombudsman Website at
www.ombudsman.sa.gov.au/wp-content/uploads/ISG-Guidelines1.pdf

The AMRC collects email and mail address details if you have provided them for our event mailing lists. This information is only used for the purpose of sending updates and invitations to AMRC events and activities.
You may opt out of receiving any information about events and activities at any time. The AMRC does not provide email or mail lists to any third parties.

The AMRC will take seriously and deal promptly with any accidental or unauthorised disclosure of personal information.

If a staff member or volunteer has breached this privacy policy the AMRC will refer to the relevant staff member’s contract and disciplinary action will be taken.

The AMRC aims to ensure that all personal information that it holds is accurate.
You have a right under the Privacy Act to access personal information the AMRC holds about you.

You also have a right under the Privacy Act to request corrections to any personal information that the AMRC holds about you if you think the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.

However, the Privacy Act sets out circumstances in which the AMRC can decline access to or correction of personal information.

To access or seek correction of personal information we hold about you, please contact the AMRC using the contact details set out at section 21 of this Policy.

The AMRC has a public website, www.amrc.org.au. The AMRC does not collect any personal information from its website.

If you visit the AMRC website to read or download information, a range of technical information which does not reveal your identity is recorded. This information is used for statistical and development purposes.

The AMRC takes all reasonable steps to protect your personal information from misuse, loss and unauthorised access or disclosure to third parties.

These steps include password protection for accessing our electronic IT systems, limiting the use of portable storage devices, securing paper files in locked cabinets and applying physical access restrictions. Only authorised personnel are permitted to access our systems and controlled premises. All AMRC employees and volunteers are obliged to respect the confidentiality of any personal information held by AMRC.

The storage and destruction of personal information is managed according to contractual obligations with funding bodies and in conjunction with other legal requirements. When Personal Information is no longer required, it is destroyed in a secure manner, or will be de-identified.

Under the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) the AMRC is required to notify particular individuals and the Office of the Australian Information Commissioner (OAIC) about ‘eligible data breaches’. A data breach is eligible if it is likely to result in serious harm to any of the individuals to whom the personal or sensitive information relates. AMRC will make an objective assessment of whether a data breach is likely to result in serious harm and take remedial action according to the AMRC Data Breach Response Plan.

If you wish to make a complaint about how the AMRC has handled your personal information, you should make a complaint, in writing, addressed to the AMRC Privacy Officer. If you require assistance to make a complaint you should contact the AMRC.

The AMRC will respond to your complaint or request promptly if you provide your contact details. The AMRC is committed to quick and fair resolution of any complaints and will ensure your complaint is taken seriously.

If AMRC takes more than 30 days to respond to a privacy complaint, or if the outcome is not satisfactory, a complaint can be made to the Privacy Commissioner at the OAIC. The OAIC can be contacted on 1300 363 992 or at www.oaic.gov.au.

The AMRC does not disclose personal information to overseas recipients.

Where possible, you will be allowed to interact with the AMRC either anonymously or using a pseudonym. It is your choice to provide information to us. Wherever it is lawful and practicable, you have the option not to identify yourself or to use a fictional name when interacting with us. However, it may be necessary for us to collect your personal or sensitive information if you would like to access certain materials or services. If you choose to withhold the information we require, we may not be able to provide the services you have requested.

This Privacy Policy will be reviewed triennially and updated as required.

This Privacy Policy will be made available free of charge upon request and is also available on the AMRC website.

The Privacy Officer is the Chief Executive Officer of the AMRC.  The role of the privacy officer is to:

• Monitor procedures in line with the Privacy Act;
• Process any privacy complaints;
• Process requests for access to information; and
• Ensure induction of staff and volunteers on this privacy policy.

This Child Safe Environment policy has been developed to demonstrate the strong commitment of AMRC to protect children and young people that come into contact with the organisation and to establish and maintain child safe and child friendly environments.

It aims to ensure that all employees, volunteers and contractors engaged by the AMRC are aware of the AMRC’s commitment to creating an organisational culture of child safety and outlines the roles and responsibilities for everyone involved in the AMRC in relation to child safety.

AMRC is committed to the protection, safety and wellbeing of all children and young people that access our services. AMRC recognises the importance of establishing and maintaining a

safe, child friendly environment where all children and young people are valued, respected and encouraged to participate and reach their full potential. The safety and protection of children and young people accessing our services will always be our first priority.

This policy complies with AMRC’s obligations under the National Principles for Child Safe Organisations, the Child Safety (Prohibited Persons) Act 2016(SA) and the Children and Young People (Safety) Act 2017 (SA), including in particular, sections 114 and 115, which requires organisations to establish and periodically review policies and procedures to ensure that:

• Child safe environments are maintained within the organisation; and
• Appropriate reports of risk of harm are made under Section 30 of the Act.

All children and young people who come to AMRC have a right to feel and be safe regardless of their ability, sex, gender or social economic or cultural background. Bullying or harassment in any form either by or against children and young people is not tolerated by AMRC. We display publicly information about services that can assist children and young people (such as the Kids Helpline on 1800 55 1800 and Youth Helpline on 1300 13 17 19) in areas accessed by them.

The following definitions apply in this policy:

Child or young person – persons under 18 years of age.

Complainant – person who makes a complaint.

Harm – Section 17 of the Children and Young People (Safety) Act 2017 defines ‘harm’ to mean physical or psychological harm (whether caused by an act or omission), including harm caused by sexual, physical, mental or emotional abuse or neglect.

National Police Check – a summary of an individual’s offender history in Australia and a record of their criminal history relating to convictions, finding of guilt or pending court proceedings. They are available from South Australia Police (SAPOL) or organisations accredited by the Australian Criminal Intelligence Commission.

Working with Children Check – People working or volunteering with children in South Australia must, by law, have a valid, not prohibited Working with Children Check. A Working with Children Check is an assessment of whether a person poses an unacceptable risk to children. As part of the process, the Screening Unit will look at criminal history, child protection information and other information.

This policy applies to all AMRC sites and all persons working within AMRC, including:

• Employees (full time, part-time and casual)
• Volunteers
• Board members
• Contractors who come into contact with children and young people
• Work experience students

All the persons listed above must agree in writing to accept and act in accordance with this policy.

The Board

• Ensure that appropriate and effective internal control systems are in place
• Ensure that appropriate policies, procedures and Code of Conduct are in place

Chief Executive Officer

• Provide leadership that models and reinforces attitudes and behaviours that value children and young people
• Ensure the organisation makes a public commitment to child safety, child wellbeing and cultural safety
• Ensure the policy is implemented, monitored, reported and evaluated
• Ensure mandatory reporting requirements, procedures and associated legal responsibilities are adhered to.
• Support activities that embed the National Principles for Child Safe Organisations.

Managers

• Model leadership that reinforces attitudes and behaviour that values children and young people, and promotes child safety at all times
• Understand mandatory reporting requirements, procedures and associated legal responsibilities.
• Ensure employees have appropriate training and supervision to understand and fulfil their obligations as mandated notifiers, have appropriate skills and knowledge to identify children or young people at risk and provide a child safe environment for children and young people.
• Ensure all employees receive regular training sessions that include a focus on ongoing learning regarding child protection
• Ensure staff apply risk assessment processes as required and feel supported to make mandatory notifications.
• Ensure safe recruitment and selection practices are adopted
• Ensure all National Police Checks and Working with Children Checks obtained for employees and volunteers are dealt with in a manner that reflects associated legal responsibilities
• Support activities that embed the National Principles for Child Safe Organisations.

Employees and volunteers

• Abide by the principles in this policy and the Child Safe Code of Conduct
• Notify the Child Abuse Report Line (CARL) if they suspect, on reasonable grounds, that a child has been harmed or at risk of harm.
• Ensure they are aware of their obligations as a Mandated Notifier under the Children and Young People (Safety) Act 2017 and the consequences of the obligations and the consequences of failure to comply
• Ensure they are able to identify, report and respond to children and young people at risk of harm.
• Support activities that embed the National Principles for Child Safe Organisations.

Work experience students

• Abide by the principles in this policy and the Child Safe Code of Conduct
• Notify the Child Abuse Report Line (CARL) if they suspect, on reasonable grounds, that a child has been harmed or at risk of harm. The supervisor to the work experience student can support the student to make the notification if required.
• In addition to the CARL reporting requirements, to report to their supervisor any suspicion of harm or risk of harm to a child or young person (or, if their supervisor is involved in the suspicion, to a responsible person in the organisation).

Contractors

• Abide by the principles in this policy and the Child Safe Code of Conduct
• Notify the Child Abuse Report Line (CARL) if they suspect, on reasonable grounds, that a child has been harmed or at risk of harm. The contractor’s AMRC contact person can support the contractor to make the notification if required.
• In addition to the CARL reporting requirements, report to their AMRC contact person immediately any suspicion of harm or risk of harm to a child or young person (or, if their contact person is involved in the suspicion, to a responsible person in the organisation);

AMRC encourages and respects the views of children and young people who access our services. We involve children and young people in making decisions that affect them and communicate using age, cultural and developmentally appropriate language. AMRC values the opinions of children and young people and has used their views to develop this policy.

AMRC ensures that children, young people and their families/carers know their rights and how to access services and complaints and feedback processes. We teach children and young people about what safety and wellbeing means, and what they can do if they feel unsafe. We listen to and act upon any concerns, disclosures, feedback or complaints that children, young people or their families/carers raise with us.

The AMRC Child Safe Environment Policy is available on the AMRC website. AMRC also has signage about the AMRC Child Safe Environment Policy and hard copies available in the AMRC reception. AMRC provides to clients the Client Services Charter which contains information about how to provide feedback to AMRC. Anonymous feedback boxes are also in AMRC reception areas. AMRC has signage in reception areas on Children’s Rights that is adapted from the Convention on the Rights of the Child.

All members of the governing body, management, staff, volunteers, and contractors must adhere to the AMRC’s Child Safe Code of Conduct (Appendix 1). The Child Safe Code of Conduct is more specific than the general AMRC Code of Conduct and specifies standards of care when dealing and interacting with children and young people. It establishes professional boundaries, ethical behaviour, unacceptable behaviour, and consequences for breaching the code.

The Child Safe Code of Conduct is an appendix to the Child Safe Environment Policy. AMRC employees and volunteers are given a copy of the Child Safe Code of Conduct during induction, and whenever it is updated and are required to sign a written statement indicating that they have read, understood and will abide it.  We retain a copy of all signed statements. The Child Safe Code of Conduct is available on the AMRC Sharepoint, AMRC website and in AMRC reception and creche.

AMRC ensures that it engages only the most suitable and appropriate people to work and volunteer with children and young people through vigorous human resource selection and checking

processes to safeguard children and young people. For further detail see the AMRC Human Resources Policy. The following strategies are in place:

• Position descriptions contain a statement indicating AMRC’s commitment to child safety and wellbeing
• Face to face interviews that include behavioural questions in relation to providing safe environments for children and young people
• Referee checks (minimum of two)
• That the applicant has provided a current National Police Check (within the last 12 months) That the applicant has provided a current not prohibited Working With Children Check that has been verified as accurate in the DHS Screening unit portal
• That the applicant has provided a current not prohibited Vulnerable person-related employment check
• Qualifications check to ensure the applicant has the appropriate qualifications for the position
• That the applicant has a current Child Safe Environment Certificate
• If working in Aged Care, an Aged Care Sector Employment Screening (less than 3 years old) or NDIS worker check (less than 5 years old) and if working in NDIS, a NDIS worker check (less than 5 years old).
• Proof that the applicant is eligible to work in Australia

AMRC ensures that it meets the requirements under the Child Safety (Prohibited Persons) Act 2016 and requires all employees and volunteers have a current, ‘not prohibited’ Working with Children Check issued by the DHS Screening Unit which is verified as accurate before the person is employed, and for existing employees that this is renewed  and verified every 5 years, and the status remains as not prohibited. Verification is done online through the Organisation Portal via the DHS Screening Unit.

AMRC will advise the DHS Screening Unit when it becomes aware of certain information regarding any person involved with the AMRC, including any serious criminal offence, child protection information, or disciplinary or misconduct information pursuant to the Child Safety (Prohibited Persons) Act 2016.

AMRC provides ongoing supervision, training and support to employees and volunteers to ensure they are equipped and supported to enhance and maintain child safe environments. Through education and ongoing professional development, employees and volunteers are equipped with the required skills, knowledge and attitudes to meet the requirements of their position insofar as it relates to their interaction with children and young people.

Strategies we have implemented include:

• Employee and volunteer induction programs include orientation of the AMRC’s Child Protection Policy, Child Safe Code of Conduct, risk management and mandatory reporting
• All new employees and volunteers receive a copy of our Child Protection Policy, Child Safe Code of Conduct and Code of Conduct and Grievance Resolution Policy and are guided through the application of these policies and procedures
• All employees and volunteers with contact with children and young people undertake Safe Environments: Through their eyes training, and refresher training at least every 2 years to understand their mandatory reporting obligations and their responsibilities to create a child safe environment.
• All employees receive regular training sessions that include a focus on ongoing learning about child safety practices and requirements and other matters that affect children and young people.
• Ensuring employees have access to relevant information resources such as:
  • Mandatory Reporting Guide https://www.childprotection.sa.gov.au/__data/assets/pdf_file/0008/107099/mandatory-reporting-guide.pdf
  • Department for Child Protection website https://www.childprotection.sa.gov.au/reporting-child-abuse
• Annual performance appraisals

The AMRC shall ensure children and young people are kept safe from harm and risk of harm. All employees and volunteers working with children are responsible for reporting a reasonable belief that a child or young person has been harmed or is at risk of harm.

All employees and volunteers within the AMRC are mandated notifiers and have a legal obligation to report a reasonable belief that a child or young person has been harmed or is at risk of harm through Child Abuse Report Line (CARL) on 13 14 78 as soon as practicable or if at immediate risk, report to South Australia Police on 000.

Further information about making a report is available from https://www.sa.gov.au/topics/education-and-learning/health-and-wellbeing/child-abuse/report-child-abuse

It is the responsibility of the individual who identifies the harm or risk of harm to make the report to CARL/SAPOL. It is not reported internally for another staff member to determine if it is a reportable matter at first instance.

Once a notification has been made to CARL/SAPOL this must be reported through the relevant channels as an incident to the individual’s manager. The incident is recorded on AMRC’s internal incidents register (which is maintained by the operations team and the CEO is copied into every incident reported), in which the incident is outlined and the action taken in response. A copy of the incident report is kept in the client’s case file.

AMRC also has obligations as a service provider to report incidents involving relevant clients to the relevant funding Department. The particular reporting requirements for these programs are set out in the operational procedures manuals for each program. Relevant staff are trained in specific reporting requirements for each program.

Where a notification has been made based on the reasonable belief that a child or young person has been, or may be, at risk of harm by a member of the organisation (including but not limited to an employee, volunteer or Board Member), following a report having been made to authorities, this must be reported to the AMRC CEO immediately to ensure the ongoing safety to all children and young people. In response, the AMRC will take action in accordance with the AMRC Code of Conduct and Grievance Resolution Policy and relevant legislation. Depending on the circumstances this may include immediate termination of the volunteer, suspension of an employee during the investigation, and reporting to the Chairperson of the Board. The primary consideration is always ensuring the safety of children and young people.

AMRC will be guided by the relevant authority (Department for Child Protection/SA Police) about how to proceed after a notification. However, we ensure that support is also available for the employee making the report, particularly where an ongoing service is provided to the child, young person and their family. An Employee Assistance Program (EAP) is also available to employees.

Where applicable, AMRC will support children, young people and their families by providing family and relationship counselling and where necessary, external referrals to appropriate services and liaising with other service providers, in accordance with the Information Sharing Guidelines (ISG). We also display information about services that can assist children and young people (such as the Kids Helpline and Youth Helpline) in areas they access.

Any failure to report a reasonable suspicion that a child has or is being harmed or is at risk of harm is in breach of the Child Safe Environment Policy and may result in disciplinary action being initiated against the relevant employee/volunteer in accordance with the AMRC Code of Conduct and Grievance Resolution Policy. Failure by mandated notifiers to report is also an offence under the Children and Young People (Safety) Act 2017 and carries a maximum penalty of a $10,000 fine. Failure to report suspected child sexual abuse is an offence under section 64A of the Criminal Law Consolidation Act 1935 (SA) with a maximum penalty of 3 years imprisonment. Failure to protect a child from sexual abuse is an offence under section 65 of the Criminal Law Consolidation Act 1935 (SA) with a maximum penalty of 15 years imprisonment.

The AMRC takes seriously all concerns, complaints, and feedback from people accessing our services. Each complaint is handled in line with the organisation’s complaints and feedback procedure. The AMRC explains to all clients, including children, young people and their families the Client Services Charter and Complaints Procedure which includes details of how they can provide feedback or make a complaint. A copy of the Client Services Charter is provided to clients in their own language. Feedback can also be provided through the feedback boxes located in the AMRC reception.

AMRC is committed to dealing with all complaints and feedback promptly, sensitively and fairly. The AMRC Complaints Procedure includes the following elements:

• listen to the complaint/feedback and make a record of it
• advise the time expected for an outcome
• respond to the complainant with an outcome
• clearly document and securely store decisions and actions taken in response to complaints and feedback in accordance with privacy obligations
• make sure that procedural fairness is followed at all times
• ensure feedback is recorded in AMRC incidents/complaints/compliments register

Note: If a complaint or feedback is received that relates to harm to a child or young person it should be handled as per the section above ‘Reporting and responding to the reasonable belief that a child or young person may be at risk of harm’.

AMRC will identify, assess and monitor all potential and actual sources of harm and take steps to minimise the risk to children and young people who use our services. Risk assessment tools are used where appropriate to determine if a child or young person is at risk. This includes risks in physical and online environments relevant to the services provided by the AMRC, people in contact with children and young people, and any specific vulnerabilities of children young people. All employees and volunteers dealing with children and young people shall endeavour to reduce the risk of harm to children and young people and identify ways to promote child protective factors in the context of the organisation.

AMRC has the following policies and procedures to assist in managing risk and safeguarding children and young people:

• Risk Management Policy and Child Safe Risk Register
• Information Sharing Guidelines
• Child Safe Code of Conduct (Appendix 1)

Strategies to minimise risks to children and young people occur as part of AMRC’s ongoing risk management process. AMRC has implemented the following strategies to minimise risk:

• The organisation meets the requirements of the Children and Young People (Safety) Act 2017 (which mandates child safe environments) and the Child Safety (Prohibited Persons) Act 2016 (which mandates Working with Children Checks)
• Strategies are in place to make sure that child safety (through the National Principles for Child Safe Organisations) are embedded across the organisation
• The organisation uses inclusive, developmentally- appropriate language and resources to help children and young people to feel valued, respected and included
• Strategies to embed a child safe organisational culture are reviewed and updated regularly
• The Child Safe Environment policy is reviewed at least once in every 3-year period. When this happens a new child safe environments compliance statement is lodged with the Department of Human Services.
• Support through training and supervision is provided to employees and volunteers
• Working with Children Checks (WWCC) are undertaken to make sure that people working with children and young people are assessed as suitable. Those who are not suitable (‘Prohibited’ WWCC) cannot work with children and young people in our organisation. All employees and volunteers must hold a valid Working with Children Check (WWCC) and National Police Check
• Recruitment processes including undertaking referee checks to ensure the suitability of persons before they are employed/volunteer with our organisation is completed
• All employees and volunteers are required to read and sign the Child Safe Environments Policy and Child Safe Code of Conduct during induction
• Supervision of children and young people at all times
• When taking images of children and young people, must have consent of child or young person and parent/guardian
• Complaints processes are in place and promoted to children, young people and their families to make sure that they feel safe reporting to the organisation
• Cyber safety and social media guidelines in place and provided to all staff and volunteers
• Appropriate supervision is provided for all online activities
• Our Child Safe Environment Policy (including Child Safe Code of Conduct) are made available to employees, volunteers, children, young people and their families electronically on the AMRC Sharepoint and AMRC website and in hard copy in the AMRC reception.
• Children, young people and their families are encouraged to participate in our organisation and provide feedback in accordance with grievance and complaints resolution procedures
• If children and young people are harmed, we support them and their families by following our reporting and responding to harm/risk of harm procedure which clearly sets out the process for reporting to CARL and connecting those impacted with appropriate support services
• All employees and volunteers working with children undertake Safe environments: Through their eyes training to understand their obligations to report harm and risk of harm and refresher training every two years
• Employing staff in senior management positions that are authorised to deliver Safe environments: Through their eyes training and Domestic Violence Alert Training and who are experts in understanding reporting requirements
• Providing Domestic Violence Alert Training to employees that work with families, children and young people
• Families requiring case work support services are allocated to female case workers where possible
• Appointment of two Child Safety Officers whose role is to:
  • be a first point of contact to provide advice and support to children, young people, parents, staff, volunteers regarding the safety and wellbeing of children when dealing with the organisation;
  • identify and liaise with the management team to raise awareness of child safety in the AMRC;
  • be aware of the specific needs of children and young people that AMRC works with;
  • keeping skills up to date and provide trauma informed training to staff about their obligations and to children and young people about their rights;
  • support referrals for staff and children and young people who need additional support;
  • assist staff and children and young people to make complaints about harm or risk of harm to a child or young person;
  • keep accurate written records of complaints and referrals;
  • ensure staff, children and young people have access to and understand child safe policies and procedures; and

promote trauma informed training opportunities for staff working with children and young people.

Evaluation of these strategies and the development of additional strategies to minimise and control risks to children and young people occur as part of our ongoing risk management processes.

AMRC will ensure that everyone to whom this policy applies is aware of and has had an opportunity to read the policy, and knows how to access it.

AMRC employees and volunteers are given a copy of the Child Safe Environment Policy during induction, and whenever it is updated and are required to sign a written statement indicating that they have read, understood and will abide by the policy.  We retain a copy of all signed statements. The policy is available on the AMRC Sharepoint.

We remind employees and volunteers regularly of their obligations in relation to incident reporting and child safety at team meetings. Incident reporting is a standard agenda item for all team meetings.

AMRC intends to ensure that children, young people and adults who access its services, know what is considered acceptable behaviour, their obligations towards the care and protection of their children, Australian laws and who to talk to if they have concerns through orientation sessions and ongoing group sessions. Children and young people and their parents and carers can access the Child Safe Environment Policy on the AMRC website and in hard copy in AMRC reception and creche.

Code of Conduct and Grievance Resolution Policy

Child Safe Framework

Human Resources Policy

Privacy Policy

Risk Management Policy and Risk Register

Information Sharing Guidelines

Complaints and Feedback Policy

The AMRC shall review this policy and the related procedures every 3 years, or more frequently if required. The policy will also be reviewed where:

• new or added risks are identified for children or young people, which may require a change in the policy or procedures
• a critical incident has occurred where a child or young person has experienced harm through involvement in the organisation
• concerns are raised by anyone involved in the organisation about child safety or welfare in the organisation
• awareness or compliance to the child safe environment policy and/or procedures is low
• AMRC expands the services they offer to children and young people
• AMRC undergoes a substantial change to the responsible or managing authority

Any changes made to the policy will be approved by the CEO.

AMRC will lodge a new child safe environments compliance statement with Department of Human Services each time the policy is reviewed and updated.

CHILD SAFE CODE OF CONDUCT

Caring for children and young people brings additional responsibilities for employees and volunteers of AMRC. All employees and volunteers of our organisation are responsible for promoting and protecting the safety and wellbeing of children and young people by:

• complying with the organisation’s child safe environment policy at all times and taking all reasonable steps to ensure the safety and protection of children and young people
• treating everyone (this includes staff, volunteers, students, children, young people and parents) including those of different race, ethnicity, gender, gender identity, sexual orientation, age, social class, physical ability or attributes and religious beliefs with respect and honesty and ensure equity is upheld
• being a positive role model to children and young people in all conduct with them
• setting clear boundaries about appropriate behaviour between yourself and the children and young people in our organisation – boundaries help everyone to understand their roles
• listening and responding appropriately to the views and concerns of children and young people
• being alert to bullying behaviours and responding promptly and appropriately
• ensuring another adult is always present or in sight when conducting one to one coaching, instruction or other activity
• being alert to children and young people who are, or may be at risk of harm, and reporting this quickly to the Child Abuse Report Line (13 14 78)
• responding quickly, fairly and transparently to any complaints made by a child, young person or their parent/guardian
• encouraging children and young people to ‘have a say’ on issues that are important to them.

Employees and volunteers must not:

• engage in rough physical games
• develop any ‘special’ relationships with children and young people that could be seen as favouritism such as the offering of gifts or special treatment
• do things of a personal nature that a child or young person can do for themselves, such as toileting or changing clothes
• discriminate against any child or young person because of age, gender, cultural background, religion, vulnerability or sexuality.

Reporting a Breach of the Code of Conduct

Anyone who suspects, or becomes aware that this Child Safe Code of Conduct may be being breached, must report the matter to the Chief Executive Officer and or Chairperson immediately, including any information or evidence that they have. This obligation is in addition to any reporting requirements as outlined in the Child Safe Environment Policy.

Where an employee or volunteer is unsure of their own conduct in relation to the operation of this Child Safe Code of Conduct, they must bring the matter to the attention of their manager/supervisor or the CEO for discussion and clarification of the Policy and its application to their particular circumstances, as soon as they become aware of a breach, or potential breach.

A copy of this Child Safe Code of Conduct is to be published electronically and the signed copy kept by each employee to allow all employees to become aware of their responsibilities and to enable compliance with its terms and conditions.

Consequences of Breaching the Child Safe Code of Conduct

Employees or volunteers who have breached, or are suspected to have breached this Child Safe Code of Conduct will be dealt with in accordance with the AMRC Code of Conduct and Grievance Resolution Policy. A breach of this Child Safe Code of Conduct by any employee or volunteer will result in disciplinary action being taken, and may include immediate termination. It will also include referral to police where criminal conduct has occurred.