INTRODUCTION

The Board of ASHM is committed to high standards of ethical conduct and accordingly places great importance on making clear any existing or potential conflict of interest.

Whilst ASHM recognises that individuals hold a range of legitimate interests outside the immediate workplace, identifying and dealing with any such conflicts of interest is an integral part of establishing an ethical culture at ASHM.

To comply with good governance practice, to maintain its peak body status and to comply with the ACFID Code of Conduct, ASHM needs to be able to have transparent processes which demonstrate its independence to all relevant stakeholders.

PURPOSE

This policy has been developed to provide a framework for all board members, employees, committee members or contractors:

  • in declaring conflicts of interest; and
  • when determining how to deal with situations of conflict.

DEFINITIONS

A conflict of interest is a situation in which a person (an ASHM Bboard member, employee, committee member, contractor) can derive personal benefit from actions or decisions made in their official capacity.

A conflict of interest can be actual, potential or perceived.

Examples of relevant conflicts of interests that should be disclosed include, but are not limited to;

  • Holding shares in a company that ASHM is considering contracting for services
  • Presenting at a conference where Industry has sponsored your attendance
  • Sitting on the Board of another organisation in which ASHM has dealings

POLICY

  • all board members, employees, committee members and contractors must remain independent, impartial and unbiased in performing their duties
  • it is the responsibility of board members, employees, committee members and contractors to take reasonable steps to avoid creating a conflict of interest or a perception of a conflict of interest
  • where a conflict of interest may exist or arise, it is the responsibility of board members, employees, committee members and contractors to disclose any such conflicts of interest in a timely manner
  • if there is any doubt as to whether a conflict exists then, in order to protect the individual and ASHM, a disclosure should be made
  • if any board member, employee, committee member or contractor becomes aware of any non-disclosed conflict by another board member, employee, committee member or contractor, then they will notify the ASHM CEO.
  • If any board member, employee, committee member or contractor becomes aware of any non-disclosed conflict by the ASHM CEO then they will notify the ASHM President and also the Chair of the ASHM Finance, Risk Management and Audit Committee
  • ASHM will maintain a register of conflicts of interest across all programs and this register will be available for inspection by relevant stakeholders upon request.

This policy also relates to:

  • a partner or family member of a board member, employee, committee member or contractor
  • any partnership of which a board member, employee, committee member or contractor (or a partner or family member) is a member
  • any corporation in which a board member, employee, committee member or contractor (or a partner or family member) is a director or owns or controls 25% or more of the issued shares.

Conflicts of interest must be disclosed by a board member, employee, committee member or contractor in a timely manner as follows:

  • each new board member, employee, committee member or contractor will, at the time of their appointment, be required to provide ASHM with a signed declaration disclosing any current conflicts of interest. In addition, during the recruitment process, AHSM will seek information about conflicts of interests from applicants
  • Board members and committee members will also complete an annual declaration confirming their current conflicts of interest
    • failure to provide either of these signed declarations in a timely manner may forfeit the individual’s ability to remain in the position
  • once a conflict of interest, or a perception of a conflict of interest, arises for an employee or contractor they will advise their Division Manager as soon as possible
  • once a conflict of interest, or a perception of a conflict of interest, arises for a board member or committee member, they will advise their fellow board/ committee members as soon as possible and be directed by the Chair of the relevant Board/ Committee as to how to proceed. If the conflict arises for the Chair of the meeting, then the Deputy Chair will advise how to proceed
  • all Board and Committee meetings must commence with a standing agenda item for a declaration of any conflicts of interest.

 

AUTHORISATION

ASHM Board, April 2018

INTRODUCTION

This policy provides guidelines around the organisation’s aid and development and non-aid and development objectives and activities. ASHM is committed to ensuring that we accurately represent our activities to the people we work with, our donors and the public.

PURPOSE

This policy reflects accountability to all stakeholders, building trusting relationships with communities and honesty & transparency.

The purpose of this policy is to guide ASHM and our partners to make a clear separation between development and humanitarian and non- development objectives and activities. This policy addresses our ACFID compliance obligations when communicating with or soliciting donations from private donors and the public, including fundraising for restricted and unrestricted purposes from aid agencies, sponsors and supporters, and fundraising from the general public.

This policy is intended to apply to all ASHM activities. The policy is applicable to all ASHM employees and volunteers. The policy also extends to ASHM partners and associated implementing organisations.

DEFINITIONS

From ACFID’s Code of Conduct – Aid and development refers to activities undertaken in order to reduce poverty and address global justice issues.  In the non-government organisation sector, this may occur through a range of engagements that includes community projects, emergency management, community education, advocacy, volunteer sending, provision of technical and professional services and resources, environmental protection and restoration, and promotion and protection of human rights.

ASHM is committed to ensuring that funds and other resources designated for the purpose of aid and development are used only for those purposes. The concept of aid and development activities can be distinguished by the following principles:

a. Strengths based approaches which encourage people and communities to create solutions for themselves

b. Processes that seek to address the causes of poverty

c. Processes that seek to empower rights holders to claim their rights and ensure that duty bearers exercise their duties

d. Supporting systems and structures which enable people to move out of poverty

e. Humanitarian response and emergency relief, disaster recovery and meeting the immediate needs of refugees and internally displaced people.

POLICY

Funds and other resources designated for the purpose of aid and development will be used only for those purposes and will not be used to promote a particular religious adherence or to support a political party, or to promote a candidate or organisation affiliated to a particular party.

The separation of development activities from non-development activities will apply in each of the following areas:

  • Programming
  • Expenditure reporting
  • Fundraising
  • Advocacy campaigns
  • Communications
  • Choice for donors
  • Partners

This policy applies to ASHM and its sector partners and collaborators in either contracts or Memorandum of Understandings. ASHM will extend this policy and its attendant agreements to its development partners through MOUs or similar documents.

This policy provides a framework for ASHM’s compliance with the Commitment to accountability to our stakeholders in the ACFID Code of Conduct, in particular Compliance Indicator 7.3.2 which states that Members development initiatives constantly demonstrate the separation of development activities from non-development activities.

AUTHORISATION

ASHM Board, June 2018

INTRODUCTION 

ASHM's Child Protection Policy and Procedure reflects the principles and implementation of the Department of Foreign Affairs and Trade (DFAT) Child Protection Policy, January 2018 and Child Protection Guidance Note, February 2018.  

ASHM’s Child Protection Policy and Procedure is consistent with the Department of Foreign Affairs and Trade Minimum Child Protection Standards (Appendix A DFAT Child Protection Policy, January 2018)  

ASHM is committed to promoting and protecting the interest and safety of children. We have zero tolerance for child abuse.  

SCOPE 

This child protection policy applies to all ASHM personnel which includes: 

  • staff/volunteers/interns/contractors/visitors to projects/Society representatives 
  • ASHM partner’s downstream personnel 
  • Subcontractors engaged by ASHM to perform any part of ASHM project activities 

PURPOSE 

The purpose of this policy is to: 

  1. prevent any child abuse occurring within ASHM and its projects. 
  2. work towards an organisational culture of child safety. 
  3. ensure that all parties are aware of their responsibilities for identifying possible occasions for child abuse and for establishing controls and procedures for preventing such abuse and/or detecting such abuse when it occurs. 
  4. provide guidance to ASHM personnel as to action that should be taken where they suspect any abuse within or outside of the organisation 
  5. provide a clear statement to ASHM personnel forbidding any such abuse. 
  6. provide assurance that any and all suspected abuse will be reported and fully investigated. 

The purpose of this policy is to help eliminate the risk of anyone working for and with ASHM being involved in child abuse. 

DEFINITIONS  

Child.  For the purposes of this policy, a child is defined as any person under the age of 18. 

Child abuse is defined as “All forms of physical or mental violence, injury or abuse, maltreatment or exploitation, including sexual abuse”. 

Child Protection is the term used to describe the responsibilities and activities undertaken to prevent or stop children being abused or maltreated.  

Physical abuse is the use of physical force against a child that results in harm to the child. Physically abusive behaviour includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning 

Emotional abuse refers to a parent or caregiver’s inappropriate verbal or symbolic acts toward a child, or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Such acts have a high probability of damaging a child’s self-esteem or social competence. 

Neglect is the failure by a parent or caregiver to provide a child (where they are in a position to do so) with the conditions that are culturally accepted as being essential for their physical and emotional development and wellbeing 

Sexual abuse occurs when a child or young person is used by an older or bigger child, adolescent or adult for his or her own sexual stimulation or gratification - regardless of the age of majority or age of consent locally. These can be contact or non-contact acts and includes fondling genitals; masturbation; oral sex; vaginal or anal penetration by a penis, finger or any other object; fondling breasts; voyeurism; exhibitionism; and exposing the child to, or involving the child in, pornography.   

Child pornography is defined as “any representation, by whatever means, of a child engaged in real or simulated explicit sexual activities or any representation of the sexual parts of a child for primarily sexual purposes”. 

Exploitation - Commercial or other exploitation of a child refers to the use of the child in work or other activities for the benefit of others that are to the detriment of the child’s physical and mental health, education, or moral and social-emotional development. It includes, but is not limited to: 

- child labour 

- child trafficking  

- child sexual exploitation  

- committing or coercing another person to commit an act or acts of abuse against a child 

- possessing, controlling, producing, distributing, obtaining or transmitting child exploitation material 

- committing or coercing another person to commit an act or acts of grooming or online grooming 

- using a minor for profit, labour, sexual gratification, or some other personal     or financial advantage 

’ASHM personnel’ includes all staff, Board, volunteers, interns, contractors, committee members, visitors to projects, society representatives, ASHM partners’ downstream personnel and subcontractors engaged by ASHM to perform any part of ASHM project activities. 

POLICY  

Policy Principles  

  • Zero tolerance: ASHM has zero tolerance for child abuse. Everyone working for ASHM is responsible for the care and protection of the children within our care and reporting information about suspected child abuse. 
  • Best interests of child: ASHM is committed to upholding the rights of the child and Australia’s obligations under United Nations Convention on the Rights of the Child. In all actions concerning children, the best interests of the child shall be a primary consideration. 
  • Natural justice: All investigations concerning suspicions and allegations of child abuse will be conducted according to the rules of natural justice. In line with this principle, ASHM will ensure that personnel must be fully aware of their responsibilities to protect children and how to report concerns or allegations about child exploitation and abuse. 
  • Procedural fairness: ASHM will apply procedural fairness when making decisions that affect a person’s rights or interests. ASHM’s partners are expected to adhere to this principle when responding to concerns or allegations of child exploitation and abuse. 
  • Risk assessment approach: Child safety risk assessment is a part of ASHM’s overall risk assessment for all projects and partnerships. This assessment will identify risks, and document steps being taken to reduce or remove those risks. 
  • Shared responsibility for child protection: ASHM requires the commitment, support and cooperation of partner organisations and individuals who help to deliver programs to effectively manage risks to children in all of our projects and activities. 

General policy statements 

ASHM is always committed to promoting and protecting the best interests of children involved in its programs.  

ASHM is committed to preventing a person from working with children if they pose an unacceptable risk to children. 

ASHM is committed to immediate reporting of child exploitation or abuse suspicions or allegations to   DFAT where DFAT funds are involved. 

All children, regardless of their gender, race, religious beliefs, age, disability, sexual orientation, or family or social background, have equal rights to protection from abuse. 

ASHM has zero tolerance for child abuse. Everyone working for ASHM is responsible for the care and protection of the children within our care and reporting information about suspected child abuse. 

Child protection is a shared responsibility between the ASHM, all employees, workers, contractors, associates, and members of the ASHM community. 

Wherever necessary, ASHM will consider the opinions of children and use their opinions to develop child protection policies. 

ASHM supports and respects all children, staff and volunteers. ASHM is committed to the cultural safety of Aboriginal and Torres Strait Islander children, and those from culturally and/or linguistically diverse backgrounds, and to providing a safe environment for children living with a disability. 

ASHM is committed to the protection of children from harm, abuse and exploitation. Children have a right to survival, development, protection and participation as stated in the United Nations Convention on the Rights of the Child. 

Child Protection Code of Conduct 

ASHM has developed a Child Protection Code of Conduct to provide clear guidance to personnel and associates about ways to minimise risk to children and make clear the standards of behaviour and practice required of them at all times when they are in contact with children. These behaviours are not intended to interfere with normal family interactions.  

All ASHM personnel are required to read and sign the Child Protection Code of Conduct, which is located at the end of this policy. 

Reporting 

It is mandatory for all those under the Scope of the ASHM Child Protection Policy to confidentially report any witnessed, suspected or alleged incidents of child abuse or any breach of the Child Protection Policy or Child Protection Code of Conduct using the process outlined in the flowchart over-page. 

Children and community members with whom ASHMs works will be provided with information about how to report any child protection concerns about ASHM personnel members and associates. 

Disciplinary action 

If it is alleged that a member of staff, contractor, visitor to project or a volunteer may have committed an offence or have breached the organisation’s policies or its Code of Conduct the person concerned may be stood down (with pay, where applicable) while an investigation is conducted. 

If the investigation concludes that on the balance of probabilities an offence (or a breach of the organisation’s policies or Code of Conduct) has occurred then disciplinary action may follow, up to and including dismissal or cessation of involvement with the organisation. The findings of the investigation will also be reported to any external body as required.  

Flowchart  

AUTHORISATION

ASHM Board
 

INTRODUCTION 

The Board of ASHM is committed to ensuring that fundraising activities are carried out in an ethical manner.  

This policy applies to the Board, casual, permanent and contract staff and volunteers. 

PURPOSE 

The purpose of this document is to identify ASHM’s position on fundraising practice and to document the standards expected in raising funds from the community.  

DEFINITIONS 

None 

POLICY 

ASHM’s guiding fundraising principle is that we will only use techniques that we would be happy to be used on ourselves. 

In doing so, the organisation will adhere to the following standards: 

  • Fundraising activities carried out by ASHM will comply with all relevant laws. 

  • Any communications to the public made in the course of carrying out a fundraising activity shall be truthful and non-deceptive. 

  • All monies raised via fundraising activities will be for the stated purpose of the appeal and will comply with the organisation’s stated mission and purpose. 

  • All personal information collected by ASHM is confidential and is not for sale or to be given away or disclosed to any third party without consent. 

  • Nobody directly or indirectly employed by or volunteering for ASHM shall accept commissions, bonuses or payments for fundraising activities on behalf of the organisation. 

  • No general solicitations shall be undertaken by telephone or door-to-door. 

  • Fundraising activities should not be undertaken if they may be detrimental to the good name or community standing of ASHM.  

  • Financial contributions will only be accepted from companies, organisations and individuals the Board considers ethical.  

  • Free, prior and informed consent will be obtained for use of all images and stories in fundraising activities. 

 

Acceptance or Rejection of Donations  

Any decision to accept or reject funds must be based on:  

  • the relevance of the donation to ASHM's objectives and  

  •  supporting our charitable purposes, where the donation is made as a tax deductible donation.  

To the extent to which it is possible to determine, ASHM will not accept funds which have been derived from:  

  •  illegal purposes,  

  • conduct which is not condoned by the organisation, including through the sale of tobacco, and  

  • other activities which the Board would deem to be out of step with ASHM philosophy, code of conduct or which might realistically be seen to be disreputable.  

Fundraising Materials 

All fundraising materials will be truthful and: 

  • Include the organisations identity, including name, address, ABN and purpose; 

  • Accurately represent the context, situation, proposed solutions and intended meaning of information provided by affected people; 

  • Clearly state if there is a specific purpose of each donation; 

  • Avoid material omissions, exaggerations, misleading visual portrayals and overstating the need or what the donor's response may achieve. 

If outsourcing fundraising activities, ASHM will ensure that: 

  • Contracts are in place which meet all relevant legislative and regulatory requirements; 

  • Specific expectations, responsibilities and obligations of each party are clear and in writing; 

  • ASHM is identified as the beneficiaries of the funds; and 

  • Contractors are clearly identified. 

Images and messages used for fundraising will not: 

  • Be untruthful, exaggerated or misleading; 

  • Be used if they may endanger the people they are portraying; 

  • Be used without the free, prior and informed consent of the person/s portrayed, including children, their parents or guardians; 

  • Present people in a dehumanised manner; 

  • Infringe child protection policies and in particular show children in a naked and/or sexualised manner; 

  • Feature dead bodies or dying people. 

AUTHORISATION 

ASHM Board, April 2018

INTRODUCTION 

This policy covers ASHM’s office-based operations as well as its development and humanitarian initiatives. ASHM’s Conference, Sponsorship and Events Division has a Green Events policy which governs the organisation of ASHM events and conferences, meetings and events ASHM is contracted to arrange for other organisations. 

The earth’s environment is under severe stress from uncontrolled human activity, threatening the survival of our society and the performance of ASHM’s mission.  

ASHM accepts that it must work to preserve the environmental sustainability of the planet, at all levels of its operations – in its own practice, as a participant in a community of practice, and as a participant in the Australian social discourse. 

ASHM aspires to minimise its impact on our environment and maximise the effective use of resources. We strive to achieve this by increasing communication and awareness of our efforts in accordance with this policy and fostering responsible environmental behaviour amongst staff, volunteers, and users at all levels.  

ASHM is committed not only to complying with applicable law in all of its operations but to minimise risks and impacts through the development of robust and documented systems to implement, measure, monitor, and disseminate excellent environmental performance both within its operations and to the broader community. 

PURPOSE 

This Environmental Management Policy aims to integrate a philosophy of sustainable development into all the organisation’s activities and to establish and promote sound environmental practice in our operations. 

DEFINITIONS 

None 

POLICY 

ASHM commits itself to minimising its impact on our environment through  

  • Providing a safe and healthful workplace;  

  • Having an environmentally sustainable aware culture, where responsibility is assigned and understood; 

  • Being an environmentally responsible neighbour in our community; 

  • Conserving natural resources by reusing and recycling; 

  • Using, in our own operations, processes that do not adversely affect the environment; 

  • Ensuring the responsible use of energy throughout the organisation; 

  • Participating in efforts to improve environmental protection and understanding; 

  • Taking steps to improve environmental performance continually; 

  • Conducting rigorous audits, evaluations, and self-assessments of the implementation of this policy; 

  • Working with suppliers who promote sound environmental practices; and 

  • Enhancing awareness among our employees, volunteers, and users – educating and motivating them to act in an environmentally responsible manner including walking or cycling to work.   

AUTHORISATION 

ASHM Board, April 2018
 

INTRODUCTION 

ASHM believes that all people should work in an environment free from bullying.  

ASHM understands that workplace bullying is a threat to the health and wellbeing of its staff, volunteers, advisors, interns, consultants and Board members.  

Accordingly, ASHM is committed to eliminating, so far as is reasonably practicable, all forms of workplace bullying by maintaining a culture of openness, support, and accountability. 

This policy applies to all employees of ASHM, unless otherwise specified. 

PURPOSE 

The purpose of this document is to communicate that ASHM does not tolerate any form of workplace bullying and to set out the process which is to be followed should any instances of workplace bullying be reported.  

DEFINITIONS 

Employee is defined as staff, volunteers, advisors, interns, consultants and Board Members. 

This policy also relates to, but is not limited to the following types of communication: 

  • Verbal 

  • Written 

  • Electronic - such as email, skype, social media and text messages 

“Bullying” is repeated and unreasonable behaviour directed towards a person or group of persons that creates a risk to health and safety. It includes behaviour that could be expected to intimidate, offend, degrade, humiliate, undermine or threaten. 

“Repeated behaviour” refers to the persistent nature of the behaviour and can involve a range of behaviours over time.  

“Unreasonable behaviour” is behaviour that a reasonable person, having considered the circumstances would see as unreasonable, including behaviour that is victimising, humiliating, intimidating or threatening.  

Examples of behaviour, whether intentional or unintentional, that may be considered to be workplace bullying if they are repeated, unreasonable and create a risk to health and safety include but are not limited to: 

  • abusive, insulting or offensive language or comments 

  • unjustified criticism or complaints 

  • deliberately excluding someone from workplace activities 

  • withholding information that is vital for effective work performance 

  • setting unreasonable timelines or constantly changing deadlines 

  • setting tasks that are unreasonably below or beyond a person’s skill level 

  • denying access to information, supervision, consultation or resources to the detriment of the worker 

  • spreading misinformation or malicious rumours 

  • changing work arrangements such as rosters and leave to deliberately inconvenience a particular worker, or workers. 

Workplace bullying can occur between workers (sideways), from managers to staff (downwards), or staff to supervisors/managers (upwards).  

Reasonable management action is not considered to be workplace bullying if it is carried out lawfully and in a reasonable manner in the circumstances. Examples of reasonable management action include but are not limited to: 

  • setting reasonable performance goals, standards and deadlines 

  • deciding not to select a staff member for promotion where a reasonable process is followed 

  • informing a staff member about unsatisfactory work performance in an honest, fair and constructive way 

  • taking disciplinary action, including suspension or terminating employment. 

Differences of opinion and disagreements are generally not considered to be workplace bullying.  

Bullying that directly inflicts physical pain, harm, or humiliation amounts to assault and should be dealt with as a police matter (see below).  

POLICY 

This policy is not limited to the workplace or working hours and covers all work-related events which includes, but is not limited to – lunches, meetings, conferences, as well as Christmas parties.  ASHM has a duty of care to provide a safe workplace, and ensure, so far as is reasonably practicable, that staff and other people are not exposed to health and safety risks.  

ASHM accepts and acts on its duty of care.  Any reported allegations of workplace bullying will be promptly, thoroughly, and fairly investigated. 

Bullying complaints will be handled in a confidential and procedurally fair manner. Where confidentiality cannot be guaranteed this will be clearly communicated to the relevant parties. 

All parties will be treated with respect.  

The person against whom the allegation is made has the right to natural justice (the right to know what is alleged against them, the right to put their case in reply, and the right for any decision to be made by an impartial decision-maker).   

AUTHORISATION 

ASHM Board, April 2018

INTRODUCTION 

This policy applies to all Board members, employees, consultants, mentors and contractors of ASHM, unless otherwise specified. 

PURPOSE 

ASHM may discipline any who engages in unacceptable behaviour. 

The purpose of this policy is ensure that employees are aware of behaviour that could amount to misconduct and that all relevant parties are aware of ASHM's policy for dealing with misconduct.  

DEFINITIONS 

For the purpose of this policy, all ASHM’s Board members, full time and part time employees, contractors, consultants, mentors and volunteers will be referred to as an ‘ASHM representative’. 

POLICY 

ASHM expects its representatives to observe acceptable standards of behaviour. 

ASHM representatives must not engage in behaviour that amounts to misconduct (including serious misconduct) at the workplace. This includes where representatives are working on site or off-site, attending a work-related conference or function, or attending a client or other work-related event, including retreats and social events. 

Misconduct 

Where an ASHM representative engages in misconduct or alleged misconduct, the processes in this policy will be followed.   

Behaviour amounting to misconduct includes, but is not limited to, the following: 

  • failing to obey lawful and reasonable instructions of ASHM; 

  • failing to follow defined policies, procedures and rules; 

  • failing to share relevant information with ASHM; 

  • unacceptable disruptive behaviour; 

  • unauthorised absence from the workplace; and 

  • repeatedly being late for work without lawful excuse.  

When proven, misconduct may provide a valid reason for termination of an ASHM representative's employment with notice.  

Serious misconduct 

Whether misconduct amounts to serious misconduct depends on the particular circumstances of a given case. Supervisors/managers should consider the circumstances fully as they apply to the particular representative when determining whether or not the representative has engaged in conduct that could be considered serious misconduct.  

Behaviour amounting to serious misconduct includes, but is not limited to: 

  • wilful or deliberate behaviour that is inconsistent with the representative's contract of employment; 

  • theft; 

  • fraud; 

  • assault; 

  • intoxication at work or at an ASHM related event; 

  • use of derogatory, violent or abusive language; 

  • fighting; 

  • failure to observe safety rules; 

  • concealment of a material fact on engagement; 

  • obscenity and other forms of sexual misconduct; 

  • dishonesty in the course of the employment; and 

  • criminal conduct including conduct that, if proven, renders the representative completely unfit for work. 

AUTHORISATION 

ASHM Board, June 2018

INTRODUCTION  

This policy relates to the way in which ASHM deals with complaints by: 

  • service users about its goods and services 
  • ASHM members 
  • other ASHM stakeholders.   

All ASHM personnel (including governing body members, staff, volunteers, representatives, contractors, visitors to projects and partners) are expected to comply with the principles and reporting requirements specified in this policy. 

This policy refers to complaints originated from the general public, agencies, providers, partners and stakeholders in Australia and overseas. 

PURPOSE  

ASHM welcomes constructive critical feedback on its activities, as well as formal complaints, to help improve delivery of services to service users.  

A negative comment about any aspect of ASHM services is not a complaint unless the person making the complaint indicates this and follows the procedures in this policy for making a complaint.   

A negative comment in an informal setting, such as an anonymous negative comment on an evaluation sheet at a training course, is not a complaint for the purpose of this policy. 

DEFINITIONS  

Complaint means an expression of dissatisfaction made to ASHM, related to its products or services, or the complaint handling process itself, where a response or resolution is explicitly or implicitly expected.  

Complainant means a person, organisation or its representative, making a complaint.  

Enquiry means a request for information or an explanation  

Feedback means opinions, comments, suggestions and expressions of interest in the products or services of ASHM  

Stakeholder or interested party means a person or group having an interest in the performance or success of ASHM 

 

POLICY 

Principles 

Accountability: ASHM provides information to all stakeholders, including to members of the communities where its activities are implemented, about the reporting and complaints procedure. 

Accessibility: ASHM’s External Complaints policy is readily accessible on ASHM’s website. ASHM provides information in a clear and easily understandable manner in appropriate forms and through appropriate media. 

Confidentiality: ASHM’s External Complaints policy provides a safe and discrete point of contact for stakeholders in Australia and countries where ASHM work is conducted, to raise concerns or complaints about the organisation.  

Fairness: ASHM ensures that requirements for filing a complaint take into consideration the needs of the most vulnerable and considers minority and disadvantaged stakeholders. 

Responsiveness: ASHM’s complaints process is responsive. Key steps undertaken in the management of complaints as they are received, include how a complaint is identified, confirming and recording details of complaints received, and expected responsiveness. (See Procedures below) 

People-focussed Approach: ASHM commits to providing appropriate assistance and referrals to survivors (e.g. providing assistance to complainants might include medical, social, legal and financial assistance, or referrals to such services.) 

No retaliation: a person who, in good faith, reports misconduct or suspected misconduct will not suffer retaliation. 

ASHM’s External Complaints policy is consistent with its Prevention of Sexual Exploitation, Harassment and Abuse Policy and its Child Protection Policy. It recognises:  

  • Gender equality  
  • Zero tolerance of inaction on incidents of SEA  
  • Victim/survivor centred responses 

General policy statements 

ASHM is committed to efficient and fair resolution of complaints by people in the organisation at all levels. ASHM acknowledges customers’ and stakeholders’ right to complain and we positively invite feedback from customers and stakeholders about the goods and services we provide. 

ASHM will provide a safe and discrete point of contact for stakeholders in Australia and countries where ASHM work is conducted, to raise concerns or complaints about the organisation. 

In handling complaints, we will be fair to both the complainant and the service or person against whom the complaint is made. Complainants will be treated courteously. 

ASHM will endeavour to provide appropriate assistance and referrals to complainants/survivors which may include: 

  • medical 
  • social 
  • legal and 
  • financial assistance or  
  • referrals to such services. 

Any complaint or dispute about an aspect of ASHM's operations or practices will be dealt with confidentially, effectively and with the appropriate degree of urgency.  

All complaints concerning Child Protection and Prevention of Sexual Exploitation, Abuse and Harassment must be reported immediately to the ASHM CEO and follow reporting guidelines described in those policies. 

All complaints will be managed to ensure there is procedural fairness to all parties, there is no conflict of interest by either party, there is no victimisation or retaliation and confidentiality is assured throughout the process.  

ASHM commits to: 

  • providing an induction on complaints handling to all personnel and partners to ensure they are equipped to understand and implement the policy, including expected standards of conduct; 
  • providing ongoing and refresher training as needed for all personnel and partners on a regular basis; 
  • developing communications materials about complaints handling, expected staff behaviours, and complaints processes for communities in appropriate language and media. 

There is no fee for lodging a compliant or having it processed by Society staff. 

ASHM is a signatory to the Code of Conduct for Australian aid and development agencies, which is administered by the Australian Council for International Development (ACFID). ASHM is committed to full adherence to the ACFID Code of Conduct. 

As an ACFID Code of Conduct signatory, ASHM complies with policies that include child protection, non-development activity and conflict of interest. 

ASHM welcomes inputs and feedback from all stakeholders. Comments should be directed to ashm@ashm.org.au   

 

AUTHORISATION  

ASHM Board 

 

INTRODUCTION  

ASHM recognises the right of every employee, volunteer and representative to be able to attend work and to perform their duties without being subjected to any form of sexual exploitation, abuse or harassment. This policy therefore applies to all ASHM Board members, sub-committee members, consultants, services providers, employees and volunteers. 

It is the obligation and responsibility of every ASHM representative, employee and volunteer to ensure that the workplace is free from sexual exploitation, abuse or harassment.  

ASHM is fully committed to its obligation to eliminate sexual exploitation, abuse and harassment in the workplace. 

PURPOSE  

The purpose of this document is to  

  1. prevent any cases of sexual exploitation, abuse or harassment occurring within ASHM and its projects; 
  2. work towards a respectful working culture; 
  3. ensure that all parties are aware of their responsibilities for identifying possible occasions for sexual exploitation, abuse and harassment and for establishing controls and procedures for preventing such incidents and/or detecting them when it occurs. 
  4. provide guidance to ASHM personnel as to action that should be taken where they suspect any incidents within or outside of the organisation 
  5. provide a clear statement to ASHM personnel forbidding any such abuse. 
  6. provide assurance that any and all suspected incidents will be reported and fully investigated. 

The ultimate purpose of this policy is to help eliminate the risk of anyone working for and with ASHM being involved in sexual exploitation, abuse and harassment. 

DEFINITIONS  

Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially, or politically from sexual exploitation of another. 

Sexual abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual offences including but not limited to: attempted rape (which includes attempts to force someone to perform oral sex); and sexual assault (which includes non-consensual kissing and touching). All sexual activity with someone under the age of consent (in the law of the host country or under Australian Capital Territory law [16 years], whichever is greater) is considered to be sexual abuse. 

Sexual harassment: A person sexually harasses another person if the person makes an unwelcome sexual advance or an unwelcome request for sexual favours, or engages in other unwelcome conduct of a sexual nature, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated or intimidated.  

Sexual harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated or one-off and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against beneficiaries, community members, citizens, as well as staff and personnel. 

Survivor-centred approach: where the rights, needs, wishes and empowerment of survivors of sexual exploitation, abuse and harassment are prioritised, in both the prevention of and response to sexual exploitation, abuse and harassment. 

ASHM personnel includes all staff, volunteers, interns, contractors, committee members, visitors to projects, society representatives, ASHM partners’ downstream personnel and subcontractors engaged by ASHM to perform any part of ASHM project activities. 

SCOPE 

This prevention of sexual exploitation, abuse and harassment policy applies to all ASHM personnel which includes: 

  • staff/volunteers/interns/contractors/visitors to projects/Society representatives 
  • ASHM partner’s downstream personnel 
  • Subcontractors engaged by ASHM to perform any part of ASHM project activities 

This policy applies to conduct that takes place in any work-related context, including conferences, work functions, social events and business trips. 

POLICY

Policy principles  

  • Zero tolerance: ASHM has zero tolerance for sexual exploitation, abuse or harassment. Every ASHM personnel is responsible for reporting incidents and growing awareness of prevention of sexual exploitation, abuse and harassment and for the care and protection of the people within our care and reporting information about suspected abuse. 
  • Survivor approach: ASHM will exercise its commitment to the prevention of sexual exploitation, abuse and harassment through a survivor-centred approach. Wherever possible, all reporting of alleged sexual exploitation, abuse and harassment should de-identify the victim/survivor, consistent with a survivor-centred approach. This approach prioritises the rights, needs, wishes and empowerment of survivors of sexual exploitation, abuse and harassment in both the prevention of and response to sexual exploitation, abuse and harassment 
  • Shared responsibility for prevention of sexual exploitation, abuse and harassment: ASHM requires the commitment, support and cooperation of partner organisations and individuals who help to deliver programs to effectively manage risks to people in all of our projects and activities. 
  • Promotion of a gender equality culture: Engagement with intended beneficiaries should be based on respect for diversity, promotion of gender equality and social inclusion, accountability, and a strong “do no harm” focus. 
  • Procedural fairness: ASHM will apply procedural fairness when making decisions that affect a person’s rights or interests. ASHM’s partners are expected to adhere to this principle when responding to concerns or allegations of sexual exploitation abuse and harassment. 
  • Natural justice: All investigations concerning suspicions and allegations of sexual exploitation, abuse or harassment will be conducted according to the rules of natural justice. In line with this principle, ASHM will ensure that personnel must be fully aware of their responsibilities to protect the survivor and how to report concerns or allegations about sexual exploitation, abuse and harassment. 
  • Risk assessment approach: People safety risk assessment is a part of ASHM’s overall risk assessment for all projects and partnerships. This assessment will identify risks, and document steps being taken to reduce or remove those risks. 

 

General policy statements 

ASHM will not tolerate sexual exploitation, abuse or harassment under any circumstances.  

Prevention of sexual exploitation, abuse and harassment is a shared responsibility between the ASHM, all employees, workers, contractors, associates, and members of the ASHM community.  

Both federal and state Equal Employment Opportunity legislation provide that sexual exploitation, abuse or harassment is unlawful and establish minimum standards of behaviour for all employees. 

All cases of suspected and actual sexual exploitation, abuse and harassment must be reported by all ASHM personnel to their supervisors or managers. 

ASHM strongly encourages any representative, employee or volunteer who feels they have been sexually harassed to take immediate action.  

No ASHM representative, employee or volunteer at any level should subject any other representative, employee, volunteer, customer or visitor to any form of sexual exploitation, abuse or harassment. 

The alleged harasser also has the right to have support or representation during any investigation, as well as the right to respond fully to any formal allegations made.  

There will be no presumptions of guilt and no determination made until a full investigation has been completed. 

No ASHM representative, employee or volunteer will be treated unfairly as a result of rejecting unwanted advances.  

All representatives, employees and volunteers have the right to seek the assistance of the relevant tribunal or legislative body to assist them in the resolution of any concerns.  

AUTHORISATION

ASHM Board 

INTRODUCTION

The ethical climate of an organisation is an essential element in establishing its credibility and furthering its mission. An organisational culture that takes ethical considerations into account at every point is supported and expressed through an organisation’s code of conduct; ethical principles determining workplace behaviour must arise from consultation with and responsiveness to the organisation’s members, clients, employees, volunteers, and stakeholders.  

PURPOSE

This policy is designed to provide guidelines for procedures that will allow ASHM’s staff and representatives to adopt a professional code of conduct and workplace behaviour which protects and reflects ASHM’s credibility and ethical principles.  

POLICY 

This Code of Conduct seeks to guard our standards of workplace behaviour. It specifies the values and expectations of professional conduct of all staff and volunteers.  

  • ASHM’s Code of Conduct is described in the following Policies and Procedures 

  • Conflict of Interest Policy 

  • Ethical Fundraising Policy 

  • Environmental Management Policy 

  • Gifts and Benefits Policy 

  • Bullying Policy 

  • Misconduct Policy 

  • Anti-discrimination Policy 

  • Sponsorship Policy 

  • Child Protection Policy 

  • External Complaints Policy 

  • Ethical Investment Policy 

  • Participation of Primary Stakeholders Policy 

  • Whistleblowing Policy 

  • Non-development Activity Policy 

  • Gender Policy 

  • Staff Grievance Policy 

  • All staff and representatives of ASHM, including Board members, employed staff, contractors, consultants, mentors and volunteers are required to adopt the behaviours set out in these policies. 

In addition, ASHM staff and representatives are to: 

  • Ensure that any communication regarding another NGO or ASHM partner is factually accurate, respectful and does not intentionally or otherwise mislead. 

  • Be familiar with the ACFID Code of Conduct and act in accordance with that Code of Conduct. 

  • Refrain from making statements about other ACFID members with the intention of creating reputational or other advantage. 

  • Be familiar with and adhere to ASHM’s Child Protection Policy and Procedure and Child Protection Code of Conduct Agreement. 

  • Be familiar with and adhere to ASHM’s Prevention of Sexual Exploitation, Abuse and Harassment Policy and Procedure noting prevention of transactional sex, bullying and all forms of sexual harassment. 

  • Report all instances of wrongdoing in line with procedures described in ASHM’s Staff Grievance and External Complaints policies and procedures. 

AUTHORISATION 

ASHM Board 

 

 

INTRODUCTION 

ASHM recognises the right of every employee, volunteer and representative to be able to attend work and to perform their duties without being subjected to any form of sexual exploitation, abuse or harassment. This policy therefore applies to all ASHM Board members, sub-committee members, consultants, services providers, employees and volunteers. 

It is the obligation and responsibility of every ASHM representative, employee and volunteer to ensure that the workplace is free from sexual exploitation, abuse or harassment. ASHM is fully committed to its obligation to eliminate sexual exploitation, abuse and harassment in the workplace. 

PURPOSE 

The purpose of this document is to outline ASHM’s position on sexual exploitation, abuse and harassment and to document the process which is to be followed should any grievances arise. 

DEFINITIONS 

Sexual harassment includes all forms of sexual exploitation and abuse. It means any unwelcome sexual advance, unwelcome request for sexual favours, or other unwelcome conduct of a sexual nature which makes a person feel offended, humiliated or intimidated, and where that reaction is reasonable in the circumstances.  

Examples of sexual exploitation, abuse and harassment include, but are not limited to: 

  • staring or leering 
  • unnecessary familiarity, such as deliberately brushing up against you or unwelcome touching 
  • suggestive comments or jokes 
  • insults or taunts of a sexual nature 
  • intrusive questions or statements about your private life 
  • displaying posters, magazines or screen savers of a sexual nature 
  • sending sexually explicit emails or text messages 
  • inappropriate advances on social networking sites 
  • accessing sexually explicit internet site 
  • requests for sex or repeated unwanted requests to go out on dates 
  • engaging in transactional sex or fraternalization 
  • behaviour that may also be considered to be an offence under criminal law, such as physical assault, indecent exposure, sexual assault, stalking or obscene communications. 

Behaviour that is based on mutual attraction, friendship and respect is not sexual harassment. 

A survivor-centred approach prioritises the rights, needs, wishes and empowerment of survivors of sexual exploitation, abuse and harassment in both the prevention of and response to sexual exploitation, abuse and harassment. 

POLICY 

ASHM will not tolerate sexual exploitation, abuse or harassment under any circumstances.  

ASHM will exercise its commitment to the prevention of sexual exploitation, abuse and harassment through a survivor-centred approach. 

Wherever possible, all reporting of alleged sexual exploitation, abuse and harassment should de-identify the victim/survivor, consistent with a survivor-centred approach. 

Responsibility lies with every Manager, Supervisor and employee/volunteer to ensure that sexual exploitation, abuse or harassment does not occur.  

All cases of suspected and actual sexual exploitation, abuse and harassment must be reported by all ASHM representatives to their supervisors or managers. 

The Human Resources Manager is the focal person for prevention of sexual exploitation, abuse and harassment. 

Both federal and state Equal Employment Opportunity legislation provide that sexual exploitation, abuse or harassment is unlawful and establish minimum standards of behaviour for all employees. 

This policy applies to conduct that takes place in any work-related context, including conferences, work functions, social events and business trips. 

No ASHM representative, employee or volunteer at any level should subject any other representative, employee, volunteer, customer or visitor to any form of sexual exploitation, abuse or harassment. 

A breach of this policy will result in disciplinary action, up to and including termination of employment.  

ASHM strongly encourages any representative, employee or volunteer who feels they have been sexually harassed to take immediate action.  

If a representative, employee or volunteer feels comfortable in doing so, it is preferable to raise the issue with the person directly with a view to resolving the issue by discussion. The representative, employee or volunteer should identify the harassing behaviour, explain that the behaviour is unwelcome and offensive and ask that the behaviour stops. 

Alternatively, or in addition, they may report the behaviour in accordance with the relevant procedure. Once a report is made the organisation has the right to determine how the report should be dealt with in accordance with its obligations and this policy.  

Any reports of sexual exploitation, abuse or harassment will be treated seriously and promptly with sensitivity. Such reports will be treated as completely confidential up to the point where a formal or informal complaint is lodged against a particular person, at which point that person must be notified under the rules of natural justice. 

Complainants/survivors have the right to determine how to have a complaint treated, to have support or representation throughout the process, and the option to discontinue a complaint at any stage of the process. 

The alleged harasser also has the right to have support or representation during any investigation, as well as the right to respond fully to any formal allegations made.  

There will be no presumptions of guilt and no determination made until a full investigation has been completed. 

No ASHM representative, employee or volunteer will be treated unfairly as a result of rejecting unwanted advances. Disciplinary action may be taken against anyone who victimises or retaliates against a person who has complained of sexual exploitation, abuse or harassment, or against any representative, employee or volunteer who has been alleged to be a harasser or has made a false accusation of sexual exploitation, abuse or harassment. 

All representatives, employees and volunteers have the right to seek the assistance of the relevant tribunal or legislative body to assist them in the resolution of any concerns. 

Managers or Supervisors who fail to take appropriate corrective action when aware of sexual exploitation, abuse or harassment of a person will be subject to disciplinary action. 

Employment of New Personnel  

ASHM undertakes a comprehensive recruitment and screening process for all workers and volunteers which aims to: 

  • Promote and protect the safety of all people under the care of the organisation; 
  • Identify the safest and most suitable people who share ASHM’s values and commitment to PSEAH; and 
  • Prevent a person from working at ASHM if they pose a risk to PSEAH.  

ASHM requires all workers/volunteers to pass through the organisation’s recruitment and screening processes prior to commencing their engagement with ASHM. 

ASHM will undertake thorough reference checks as per the approved internal procedure. Once engaged, workers/volunteers must review and acknowledge their understanding of this Policy. 

Reviewing

Every two years, and following every reportable incident, a review shall be conducted to assess whether the organisation’s PSEAH policies or procedures require modification to better protect the stakeholders under the organisation’s care. 

ASHM will familiarise its staff and representatives with this policy and its procedures on an annual basis.  

Risk Management

ASHM will ensure that PSEAH is a part of its overall risk management approach. ASHM has a Finance Risk Management and Audit Committee (FRMA) to identify and manage risks at ASHM. Whenever necessary, FRMA committee members will receive appropriate training in relation to PSEAH. 

AUTHORISATION

ASHM Board 

INTRODUCTION 

ASHM is committed to being transparent in our work and accountable to our stakeholders and community. We are committed to disclosing timely, relevant and accurate information in an accessible format. 

PURPOSE 

The purpose of this policy is to demonstrate how ASHM practices transparency and accountability.  

DEFINITIONS 

Transparency implies openness, communication, and accountability. Transparent business and financial activities are done in an open way without secrets, so that people can trust that they are fair and honest. 

Transparency is the practice of openly and honestly disclosing information to stakeholders in an organisation, such as the public, employees and customers. 

Transparency does not mean all information should be made publicly available. There are certain types of information that may not be provided publicly such as private information (such as client records) and ‘commercial in confidence’ material (such as tender submissions). 

POLICY 

ASHM is committed to disclosing timely, relevant and accurate information in an accessible format, with any exceptions clearly and reasonably explained (such as privacy and data protection issues).  

This applies to ASHM dealings with staff, members, funders, regulatory bodies and all other internal and external stakeholders 

ASHM has a range of policies that demonstrate its commitment to transparency. The aim of this policy is not to repeat transparency requirements that are documented in other policies, but to confirm its commitment to transparent operations. A list of relevant policies is included below. 

Staff who become aware of any areas in which ASHM can improve its transparency should advise their division manager. 

 

AUTHORISATION  

ASHM Board