Have you covered your bases?

“First base is when you meet someone, second base is when you send a nude image and third base is when you kiss them.”

This is how teenagers are viewing the progression of relationships according to eSafety Commissioner, Julie Inman Grant.  In an eye-opening new report released in September 2019 (the Report), the eSafety Commissioner revealed that since it started accepting reports around 18 months ago, it has received 1,400 reports of image based abuse. In particular, sharing sexual images is a normalised aspect of dating for children and young people.

The new report demonstrates the importance of considering technology when creating a child safe culture. It is a strong message to schools and other organisations that work with children that they must cover all their bases when ensuring the safety of children, including the electronic bases.

Key findings from the eSafety Commissioner’s Report

The Report focused on the attitudes and motivations of individuals who engage in image-based abuse.  It noted that there were generally five types of image based abuse (IBA):

  1. Relationship-based IBA;
  2. Sharing images where the victim is identifiable;
  3. Sharing unsolicited images where the victim is unidentifiable (e.g. on dating apps);
  4. IBA related to child exploitation; and
  5. Taking images of strangers such as ‘upskirting’.

Relevantly for organisations that work with children, sharing images where the victim is identifiable is particularly prevalent amongst young people. This is often done by males as a form of social status. The sexualised image is often shared with the perpetrator consensually but then distributed further without consent.  

Furthermore, organisations that work with children should also be aware of the fourth typology relating to child exploitation. Like all forms of child abuse, this is typically done as an opportunistic form of asserting power and dominance. Organisations will need to ensure they have proper procedures in place to prevent this type of abuse.

Unfortunately, the Report also found that IBA is occurring at increased rates. It was found that 1 in 10 Australians have committed IBA and sadly, due to lack of education and poor understanding of the impact of their actions, perpetrators often show little remorse.

Prevalence amongst young people

IBA is defined by the eSafety Commissioner as when intimate or sexual photos or videos are shared online without consent. It is also commonly called ‘revenge porn’, although this can be misleading as revenge is not always the motive.  IBA should also not be confused with sexting which refers to the sharing of intimate or sexual images, photos or videos and is often done consensually. 

The rates of IBA are rising rapidly, with 21% of people who have experienced IBA stating that it occurred in the last year. 15% of all individuals who have experienced IBA are aged 15 – 17. The reason rates are higher amongst young people is considered due increased rates of sharing of initiate images and videos.

Surprisingly, amongst young people, the most common situation of IBA is where a friend shares an intimate image (29%). This is followed by ex-partner at 13%. Again, this demonstrates that intimate image sharing amongst young people is often due to social factors.  

Child safety concerns for organisations

It can be tempting for organisations that work with children to think that IBA and sexting have nothing to do with the organisation as it occurs in the children’s own time.  However, we know that an organisation’s duty of care is broad and we are seeing technology stretch its application.

For example, in August 2019 a video was posted on Snapchat of a vicious brawl at Berwick Secondary College, including a teacher being attacked. The video was widely circulated. This follows a discovery in April 2019 of Instagram and Snapchat accounts that specifically hosted videos of students fighting and being bullied. 

From a sexting and IBA perspective, apps such as Snapchat are also generally involved. For young girls aged 15 – 17 who have experienced IBA, 47% of these incidents occur over Snapchat. The impact of these incidents for individuals and organisations is well documented in the SBS show “The Hunting” which follows the story of several young people during incidents intimate images shared without consent.

You can read more about how organisation’s duty of care and child safety considerations in a digital world in our previous article.

Key lessons and next steps

Organisations that work with children need to ensure that they are prepared to address child safety concerns in a digital context quickly and effectively. Unfortunately, this is often an area that is not prioritised. 

We recommend that organisations undertake the following steps:

  1. Train your staff on digital trends – it is important that your staff and volunteers are aware of rising child safety concerns such as IBA.  Recently, we were presenting to staff members and upon discussing Yubo (an app advertised as Tinder for teenagers), a teacher realised that her students had been using it in her class.  With that knowledge, she was able to have conversation with her students about the risks associated with that app and how to mitigate them.
  2. Train your students on appropriate social media use – organisations that work with children should be having conversations with them about appropriate social media use.  Often, young people are unaware of the potential repercussions of their actions and how to navigate relationships in a digital world.  Engaging with parents on this topic can also help build a shared understanding.
  3. Review your policies – consider if your policies and procedures currently set out your organisation’s expectations in relation to digital citizenship.  Additionally, it is worth reviewing if your documents currently provide you with enough authority to be able to manage electronic child safety concerns.  For example, can you confiscate a child’s phone?
  4. Prepare to respond and investigate – while responding to all child safety concerns can be challenging, those that involve a digital aspect have the added challenge of trying to quarantine evidence and prevent further spread.  Organisations should review their incident response and investigation procedures and consider if they document key steps to take in a digital incident.  Details for the eSafety Commissioner should also be provided as they are able to assist in removing intimate images shared without consent, quoting a 90% success rate in removing this content.   

How we can help

For more information regarding the eSafety report or for assistance with reviewing your existing policies and procedures, please do not hesitate to contact us.

Background

Testamentary trusts qualify for an income tax concession in respect of income derived and paid for the benefit of minor beneficiaries. This means that children are taxed at adult rates on income they received and that has been derived from the trust, as opposed to the standard penalty rates that apply to children.

In the 2018-19 Federal Budget, it was announced that the Income Tax Assessment Act 1936 (“ITAA”) would be amended to clarify the application of this concession. The existing law does not specify that the assessable income of the testamentary trust be derived from assets of the deceased estate (or assets representing assets of the deceased estate).

A Bill amending the ITAA has recently been introduced to clarify that income derived from assets that “top up” or are “injected” into the testamentary trust do not obtain concessional tax treatment.  

If passed, the legislation will apply in relation to assets acquired by or transferred to the testamentary trust on or after 1 July 2019.

What is the change?

The draft legislation amends s102AG of the ITAA to provide some pre-requisites to the ability to access the concessional tax treatment, namely:

  • The assessable income must be derived by the trustee of the testamentary trust from property which satisfies one of the following three requirements:
    • the property must be transferred from the estate of the deceased person concerned, as a result of the Will, Codicil, intestacy or order of a Court; or
    • the property, in the Commissioner’s opinion, represents accumulations of income or capital from property transferred from the estate of the deceased person; or
    • the property, in the Commissioner’s opinion, represents accumulations of income or capital from previously accumulated income or capital.  This essentially ensures that income on subsequent accumulations of income or capital will generally be able to be concessionally taxed.
  • The explanatory memorandum provides that the property can be converted from one asset type to another, without losing the concession, however the actual legislation is less clear.

The ATO is calling for submissions by the end of October, after which time, the legislation can be expected to be finalised.

Implications – General

On one view this is not a change and merely serves as a reminder as to when income distributions will not be concessionally taxed. Prior to these proposed amendments, Furse’s case suggested that the concessional tax treatment could apply to assets injected into the estate.

There is, however, some uncertainty in respect of certain aspects of the draft legislation, including:

  • It is not clear as to whether superannuation death benefits paid to an estate will lose concessional income tax treatment. From a policy point of view, that doesn’t appear to make sense, as the concessional tax treatment applies to income paid to minors directly; and
  • Much of the new legislation hinges on the Commissioner’s discretion, such that self-assessment may not be appropriate; and
  • although the explanatory memorandum appears to suggest the concession will apply to assets reinvested from original assets, the drafting of the Bill is not clear.

Further, the proposed changes apply to assets acquired or transferred to the testamentary trust on or after 1 July 2019. That appears to mean the current law applies to deceased estates in place prior to 1 July 2019 (but still being administered at that time), which will require a complete review of the status of the assets in testamentary trusts.

What now?

Pending finalisation of the law, it is difficult to be conclusive about how strategies might change.

If however the changes outlined above do come to fruition, then:

  • All existing testamentary trusts will need to be able to separate in their accounts assets from the deceased and after acquired assets. Further separation in some cases could be required if estates were part administered as at 1 July 2019;
  • Testamentary trusts with no power to distribute capital may be problematic in respect of “after acquired” assets;
  • Accurate inventories prepared in any probate application will take on extra significance;
  • It will impact on the investment strategy of each trust, eg, possible investments made from borrowings of the testamentary trust.
  • It will affect the decision about the utility of superannuation death benefits testamentary trusts. They will retain the benefit of control and protection but without access to the income tax concession. It may enliven a review of superannuation death benefits trust created by deed.

How we can help

If you would like further assistance or clarification regarding testamentary trusts and the proposed changes, please do not hesitate to contact us.

Labour hire providers only have until the end of October to hold, or have applied for, a licence to continue to operate in Victoria.

The Labour Hire Licensing Act 2018 (Vic) (Act) was introduced for the purpose of protecting vulnerable labour hire workers from exploitation. The Act, along with the Labour Hire Licensing Regulations 2018 (Vic) (Regulations), requires businesses who supply one or more workers to work in a business owned by another person to have, or have applied for a licence by 29 October 2019.

Who is covered by the Labour Hire Licensing Act?

The Act and Regulations broadly cover businesses outside the traditional concept of labour hire, and extend to businesses that provide an employee to work in and as part of another business or undertaking.

Additionally, the Regulations prescribe certain circumstances where an individual is taken to perform work in and as part of a business or undertaking. This can include where a business supplies workers to work:

  • as a cleaner in a commercial premise;
  • in the horticultural industry, performing certain activities;
  • in a meat manufacturing or processing establishment, performing certain activities; and/or
  • poultry processing establishment, performing certain activities.

Exclusions to the Labour Hire Licensing Act

The Regulations exclude certain individuals from being considered a worker under the Act, including:

  • secondees;
  • providing workers within a group;
  • small body corporate providing a director;
  • public sector employees;
  • students; and
  • vocational placements.

What are the penalties for not having a licence?

If your business is captured by the Act, there are significant penalties for continuing to operate without having applied for or been granted a licence. There are also penalties for organisations that use a labour hire provider who has not applied for or been granted a licence.

How we can help

There appears to be significant uncertainty regarding the breadth of the Act. If you are unsure whether you are required to apply for a labour hire licence, please do not hesitate to contact us.

As we move towards becoming global citizens it is increasingly common to have to deal with assets outside Australia as part of the estate planning process.

While a Will can be drafted to apply to a Willmaker’s worldwide assets, it is important to carefully consider whether this is the most appropriate approach. 

Three golden rules to keep in mind are:

  1. If the overseas asset is real property it is vital to develop the estate plan in conjunction with a lawyer in that country

    Real estate assets are governed by the laws of the country in which they are situated, meaning that it will be the law in that country which dictates whether the Australian Will is recognised as validly dealing with property held there, or if a forced heirship or other regime applies.
     
  2. It may be possible to prepare the Australian Will so it is recognised as valid in other jurisdictions

    Moveable assets (which generally include everything except real estate) are governed by the laws of the country in which the Willmaker is domiciled at death. Domicile is determined as the country which the Willmaker intended to be their long term home, whether or not they were living there at the time of their death.

    For some countries it is possible to prepare the Australian Will in a manner that ensures it will be recognised as validly executed in that jurisdiction, pursuant to an International Wills Convention. However, not all countries are signatories to this convention.
     
  3. Multiple Wills may be most appropriate, but beware of revocation!

    Whilst it is possible for moveable assets overseas to be dealt with under an Australian Will, it may be worth having a Will in place in each country in which significant assets are owned, for the following reasons:

    a) The Will can be made in accordance with the laws of that country and prepared by a lawyer familiar with the succession laws of that country.  This is particularly important in countries where death taxes apply and strategies may be implemented to minimise the impact of such taxes; and

    b) The distribution of assets may be dealt with in a more efficient manner as the executors would only need to apply for probate of the Will in the country that it was made. This avoids the needs for the probate to be resealed in each country in which the Will is required to be proven, which could be time consuming and complicated. 

    If a decision is made to prepare Wills in multiple jurisdictions it will be important to ensure the Wills do not revoke each other, and the overseas Will is potentially limited to the assets in that jurisdiction.

Ideally, an estate plan involving overseas assets will be developed in conjunction with an appropriate legal practitioner in that jurisdiction, so that the best estate planning result can be achieved. 

How we can help

Moores Practice Leader, Krista Fitzgerald has recently completed an Advanced Certificate in Cross-Border Estates through STEP (Society of Trusts & Estates Practitioners) and as a member of this organisation has access to a network of overseas lawyers who practice in this area.

If you or your clients have international estate planning issues, please do not hesitate to contact us.

In response to the current debate around the protection of religious freedoms, the federal Government released a suite of legislative reforms for public consultation recently. The reforms were made up of three Bills:

  • The Religious Discrimination Bill 2019,
  • The Religious Discrimination (Consequential Amendments) Bill 2019, and
  • The Human Rights Legislation Amendment (Freedom of Religion) Bill 2019 (the Reforms).

Politicians, the media and advocacy groups have all added their voice to the chorus of responses – but what would the actual impact of the Reforms be on organisations?

We’ve summarised the Reforms, as well as provided some key takeaways for organisations and not-for-profits.

Summary of the Reforms

The Reforms (if passed) will introduce the Religious Discrimination Act 2019, which will make it unlawful to discriminate on the ground of religious belief or activity in certain areas of “public life”. The proposed legislation mirrors federal discrimination laws in relation to age, sex, disability and race. In doing so, it misses an important opportunity to modernise the patchwork scheme of discrimination laws, which developed in a piecemeal manner over a 45 year period. The result is an overly complex mix of laws that are difficult to use and have unnecessary differences in definitions and coverage between them. This makes it harder for organisations to take measures to comply with the laws, and harder for people who have been discriminated against to receive access to justice.

Discrimination on the grounds of religious belief or activity is broadly defined. It includes protection from direct discrimination (treating someone differently because of the belief or activity) and indirect discrimination (imposing unreasonable conditions, requirements or practices that have the effect of disadvantaging people who engage in certain religious beliefs or activity).

Under the Reforms, treatment of indirect discrimination for large employers (turnover of over $50 million) is contentious – it states that large organisations have to show employee conduct rules that discriminate against religious beliefs will not be “reasonable” unless compliance is necessary to avoid “unjustifiable financial hardship” to the employer.

This is arguably a response to the Israel Folau case, where he has launched court proceedings against Rugby Australia for an unfair dismissal claim. In Folau’s case, Rugby Australia would have to demonstrate that they would suffer “unjustifiable financial hardship” as a result of Folau’s conduct, which was arguably a breach of their social media policy.

The Reforms will make it unlawful to discriminate on the grounds of religious belief or activity in relation to certain areas of public life, relevantly:

  • Employment;
  • Education;
  • Access to premises that the public or a section of the public can enter;
  • Provision of goods, services and facilities;
  • Accommodation;
  • Sport; and
  • Clubs.

There are a number of exceptions and exemptions that apply. For organisations this includes:

  • When the religious belief or activity  promotes or encourages serious criminal offences;
  • Registered charities following their own religious purposes;
  • Statements of belief;
  • Inherent requirements of jobs;
  • Religious clubs; and
  • Religious voluntary bodies.

Organisations and individuals can also apply for an exemption from the application of the law from the Australian Human Rights Commission (AHRC).

The Reforms address religious “statements of belief” and their interaction with other discrimination laws. Under the proposed law, religious statements of belief would not breach discrimination laws unless they are malicious, would harass, vilify or incite hatred or violence, or promote/encourage serious criminal offences. This may be a response to the recent situation in Tasmania where priests were taken to court under anti-discrimination legislation for voicing opposition to same-sex marriage.

Amendments to Charity Laws

The Reforms include an interesting amendment to the Charities Act 2013. The amendment aims to protect charities engaging in or promoting activities that “support a view of marriage as a union of a man and woman to the exclusion of all others” from losing their charity status.

This amendment reflects concerns from some faith-based charities that they would lose their charity status (and associated tax concessions) for advocating “traditional” marriage during and after the 2017 same-sex marriage plebiscite. These concerns followed cases in New Zealand and the UK where this happened, including a New Zealand charity losing its charity status for promoting views about marriage and family that were not seen as being for the “public benefit”.  

A proposal to “clarify” the position of this in Australian charity law was in the leaked Ruddock Report in 2018. Experts at the time indicated this was unnecessary, noting a charity’s right to advocate in pursuit of its charitable purpose has been firmly recognised in Australian law. Regardless, the proposal is now contained in the Reforms and given it is a fairly innocuous clarification it is unlikely to face push-back.

Faith-based charities will appreciate the clarification, otherwise this will have little impact.

Amendments to other Anti-discrimination legislation

Proposed amendments were made to other federal anti-discrimination laws to state that in giving effect to the objects of the legislation, regard is to be given to:

  • “The indivisibility and universality of human rights; and
  • The principle that every person is free and equal in dignity and rights”.

Key lessons for organisations

The effect of this is unclear, but the intention is to put all human rights (including religious freedom) on an equal playing field.

Of interest is the effect of the proposed laws in relation to conscientious objections.  Federal Attorney General Christian Porter has noted that where a state law is silent on conscientious objections, the proposed law would step in and have some work to do.  It states that nurses, doctors and other healthcare providers should not be compelled to provide services where they have a genuine religious objection.

  • Review your employment policies and ask whether they indirectly discriminate against religious beliefs or activities. For example, do your policies unreasonably require employees to work during prayer hours?
  • If you are a large organisation (turnover of more than $50 million), do you limit the ability of employees to express religious beliefs outside of work hours? If you do, then you would need to show that this conduct would cause unjustifiable financial hardship to the organisation.
  • In general terms, the proposed Reforms provide a good opportunity to stop and take stock. Ask yourself the question: how open and appropriate is your organisation for people of faith?

For more information, please do not hesitate to contact us.

The Australian Charities and Not-for-profits Commission (ACNC)’s Annual Information Statement (AIS) provides for charities to disclose whether they intend to fundraise in the next reporting year and if so, in which jurisdiction. Many charities are still unaware of the scope and impact of Australian fundraising laws, which differ in every Australian jurisdiction. Below we have set out some considerations for charities carrying out fundraising activities.

Fundraising reform 

Fundraising regulation is badly in need of reform in Australia. The current patchwork of laws creates an unnecessary compliance burden for fundraising organisations. A coalition of not-for-profits and charities behind the #fixfundraising campaign has called on the federal, state, and territory governments to implement a nationally-consistent, contemporary and fit-for-purpose charitable fundraising regime. However, it appears that any reform is unlikely to occur in the near future. Charities are still required to comply with the current, fragmented system.

Online fundraising is borderless

There is widespread non-compliance across the not-for-profit sector in relation to fundraising outside of a charity’s home State or Territory. This is particularly the case in respect of online fundraising. Although a charity may only intend to fundraise from donors within its home State, its website is visible across Australia and potentially subject to seven different fundraising regimes. Technically, this means that the charity is “fundraising” across Australia and required to separately obtain and comply with a fundraising approval in each State. In practice, compliance may be extremely difficult for a charity whose operations are based entirely within one State. For example, the NSW legislation requires a fundraiser to have a NSW postal address to which correspondence can be sent.

Charities need to weigh the benefits of online fundraising against the burden of and practical impediments to compliance across Australian jurisdictions.

Australian Consumer Law (ACL)

Charities are not only required to comply with State and Territory fundraising regulations – fundraising activities carried out in “trade or commerce” are also subject to the ACL. Importantly, fundraising that is organised, continuous and repetitive is likely to be in trade or commerce. Among other things, the ACL prohibits misleading and deceptive conduct and applies to representations made when seeking a donation, including representations about where the money collected will go, how it will be used and the proportion of a donation directed towards the particular cause. More information about ACL requirements is set out in this guide.

Some fundraisers are exempt

In most jurisdictions fundraising exemptions apply to churches and religious organisations, kindergartens, schools, TAFEs, and tertiary education providers. The detail and scope of these exemptions varies between jurisdictions and should be carefully reviewed by fundraising charities.

Fundraisers may need to be audited

Western Australia, Queensland, South Australia and New South Wales all require certain fundraisers to have their financial statements audited. Charities should ensure that their auditor is aware of their fundraising activities and understands the regulatory requirements of the jurisdictions in which they are fundraising.

Failure to comply with fundraising obligations

Fundraising in breach of the relevant legislation may be an offence – both for the charity and individuals involved. Depending on the jurisdiction, penalties of up to $160,000 or a two year term of imprisonment may apply. Although fundraising prosecutions are extremely rare, regulators will use their enforcement powers in response to significant breaches, as demonstrated by the high profile inquiry into the Returned Services League in New South Wales. Failure to comply may also result in ACNC compliance action.

Next steps

Our Not-for-profit team regularly works with charities to assist them to make an assessment of their fundraising obligations and to comply with those obligations, as well as register and obtain the necessary registrations, licences, permits and approvals.

If you have any questions, please do not hesitate to contact us.

Many employers have operated on the assumption that, because employee records are exempt from the Privacy Act, employers have significant freedom when dealing with employee privacy.

A recent Fair Work Commission decision from the Full Bench has clarified this is limited. The case also gave rise to interesting considerations around an employer’s ability to issue a lawful and reasonable direction for drug and/or medical testing.

Background

In the decision of Lee v Superior Wood[1] the Fair Work Commission found that a direction requiring an employee to consent to having a fingerprint scan was not lawful.

In fact, this insistence infringed the employee’s rights under privacy legislation.

The employee’s dismissal for failing to follow this direction was therefore deemed unfair.

Superior Wood sought to introduce fingertip scanners into the organisation to record employees’ start and finish times. Mr Lee did not consent to registering his fingerprint, and continued to manually clock in and clock out of work.

The employee records exemption is limited: it only applies to records actually held by the employer and does not extend to records that are not yet in existence.

Because Mr Lee did not give consent, and there were actually other means of recording an employee’s start and finish time, the direction to register his fingerprints was not deemed to be lawful and reasonable, and therefore, his refusal to follow it did not constitute an adequate reason for his dismissal. 

Implications for drug and alcohol testing and employee surveillance

This case raises some important issues relating to not just surveillance but also drug and alcohol testing.

The question has now been raised as to the legality behind requiring an employee to attend a medical examination, or a drug or alcohol test. It’s common practice to do so. This may be to ensure adherence to duty of care obligations, or ascertain what ability an employee has to perform the full requirements of their role.

While there is no test case to answer this, Australian Privacy Principal 3 is an exception stating that consent it not required where the collection of such sensitive information is required by law.

This could provide an avenue for employers to argue that a lawful and reasonable direction to undertake a drug or alcohol test, for example, is necessary to protect workplace health and safety. There will no doubt be cases in future applying this reasoning that will help determine the way forward.

What employers need to know

The most important take away is to ensure that any direction given to an employee is not only reasonable, but is lawful. You should be sure to consider the contents of relevant legislation before giving the direction.

Employers who are bound by the Privacy Act should consider:

  1. Do you have a compliant privacy policy in place? This policy should be clear about what, how and when personal and/or sensitive information may be collected, and when consent may be required.
  2. Are your policies and procedures around issues such as drug and alcohol influence in the workplace clear and up to date? Policies and procedures should be flexible enough to ensure that employees abide by all of them and that they can be changed from time to time.
  3. Are employment contracts drafted in a way that protects your organisation, and is in line with legal obligations concerning the collection of personal information? You should also consider including a privacy statement in your employment contracts that state the type of personal and/or sensitive information may be collected.
  4. If you are introducing new technology, such as fingerprint scanning, have you performed a Privacy Impact Assessment to ensure you are compliant with privacy when introducing it?

It’s also important to remember not only privacy laws need to be considered in this context. Depending on what is monitored, collected and stored, employers also need to be aware of applicable surveillance legislation (which differs state by state) and health records legislation.

How can Moores help?

Our privacy and employment law gurus here at Moores can help in a number of ways including reviewing/drafting a compliant privacy policy, employment contracts and other relevant policies and procedures.

We can also provide you with strategic advice and implementation strategies in a variety of different matters. Should you have any questions or queries, please do not hesitate to contact us.

[1] [2019] FWCFB 2946

This article continues our series which explores the investigation process and provides tips to ensure processes and decisions are fair and defensible. Read Part 1 “Workplace Investigations – Getting it right” here.


You are ready to go… you’ve decided to begin a workplace investigation and arrangements have been made but…what now? In this article we look at how to handle some common roadblocks you may face when managing a workplace investigation.

It is vital to maintain the independence and fairness of a process whilst managing some common human responses to a complaint being made. As we have already discussed, where a process is flawed or procedurally unfair, employers can be exposed to claims from all involved and this can lead to uncertainty and risk. In this article, we highlight some issues to consider to assist with choosing the right path.

What if the complainant refuses to participate in a workplace investigation?

You may be dealing with a complaint by one individual or several, and the complaint may involve one Respondent or several.  Complaints can be made in a number of ways, whether verbally to a trusted colleague or HR representative or more formally in writing in accordance with a procedure.

Regardless of how you receive the detail of a complaint, once an organisation is on notice about an issue or potential misconduct, the obligations to manage the situation begin. 

Sometimes complainants do not wish to pursue a complaint, or be involved any further; however this does not mean that you need to drop the investigation.  You will need to decide if the issue is serious enough to warrant an investigation without the involvement of a complainant.  Ask yourself whether the issue is of wider importance to a team or the organisation or if it is confined to a dispute between two individuals.  If it is the latter and the complainant is adamant that they don’t wish to pursue their complaint, we recommend that you satisfy yourself that this decision has been made without undue influence and that there is limited risk to the complainant if the issue is not managed. 

If you decide to place an investigation on hold it is good practice to keep in touch with the complainant and refer them to appropriate supports, such as an Employee Assistance Program.  At this point you may also consider other ways of managing the issue such as:

  • providing training on appropriate workplace relationships;
  • review your code of conduct, bullying and harassment, grievance and whistleblowing policies and procedures (or any other relevant documents);
  • consider if the issue should be handled as an issue of performance management; or
  • whether informal feedback should be provided to those involved.

If you do decide to proceed with a workplace investigation and have sufficient detail of the issue, check whether your policy requires that individuals participate.

If you don’t have a complainant willing to be interviewed, what other evidence do you have to consider?  Were there witnesses to the incident or interaction, is CCTV or other electronic records available, was the issue the subject of documents or email records?

Ultimately, you will have to decide whether the complaint can be pursued without the complainant’s involvement?

How should we manage personal leave during a workplace investigation?

Making a complaint and participating in an investigation can be distressing.  This is true for everyone involved as they consider the potential impact of the investigation and the potential trauma involved in re-telling their version of events to an investigator.

Of course, investigators should be supportive and reassure those participating that the process will be fair and not impact their employment but this does not always prevent individuals feeling unwell during this time.

If an individual requests a period of personal leave or is suffering from a condition connected to their experiences in the workplace it is essential that the relevant manager, or HR representative be supportive and responsive to the information received. 

It is possible that participating in the process could help an individual.  We’ve had individuals report feeling like a weight has been lifted from them by talking about their experience and participating in a supportive and fair investigation process.  However care should also be taken not to exacerbate a mental health issue by encouraging an individual to discuss their experience before they are ready. 

It is difficult to “look behind” a medical certificate and encourage or require participation when a doctor has certified an employee as being unfit for work and this should be handled with care.  There are competing obligations at play in such situations.  Personal leave is an entitlement for those employees who are unfit for work because of their own personal illness or injury but employers owe it to a complainant, and others affected by a situation, to act on reports of misconduct or other damaging workplace issues.

Also relevant to this issue is the ability for an individual to make a workers’ compensation claim for work related injuries or illnesses.  If a claim is made, it is important for employers to assess the claim and consider how it will respond within the relevant timeframes.

Sometimes the taking of personal leave is used by a respondent who is facing potential disciplinary action as a way to delay a process.  If you suspect this is the case, this should be handled carefully to avoid the suggestion that action is being taken against the individual because they have taken leave or have a medical condition or illness.

What if the Respondent refuses to participate in a workplace investigation?

Following on from the possibility that a respondent to a complaint will take personal leave to delay a process, sometimes respondents disengage completely.  They may refuse to respond to correspondence or calls or confirm in no uncertain terms that they will not participate.

At this point it is useful to consider what evidence you have and the scale of the issue; for example, is it essential that you have the respondent’s input? Can you make findings without their response? 

We recommend that you encourage the respondent to participate and reassure them that the process is fair and unbiased.  They may be getting advice from a lawyer or union representative which is encouraging them not to participate and this can be difficult to overcome.

Some tips for how to handle a refusal to participate:

  • make sure that you have been reasonable in giving them an opportunity to have their say;
  • offer the opportunity to respond to allegations in writing, by attending a meeting, or having a phone conference; 
  • invite them to participate more than once to be satisfied that you have been reasonable, and you can satisfy yourself that you have tried everything;
  • make sure that they have received your correspondence by using registered mail and delivery receipts on emails. 

If the respondent is an employee, you could give them a lawful and reasonable direction to participate in the investigation and warn them of the consequence of not participating.  It will be important to also consider relevant policies and employee obligations to participate.

What if a claim or complaint is received during the process?

As discussed above, WorkCover claims are a risk during investigation processes and times when individuals are in conflict or under pressure.  However, other claims open to employees are for an application to stop bullying (in the Fair Work Commission) or that they have been treated adversely in their employment under the general protections provisions of the Fair Work Act. 

The fact that a claim is made does not necessarily stop the investigation process; but we recommend that you consider the claim and how it impacts the process and the individuals involved.

Equally, an investigation cannot override the claim process and so you will need to make sure that all relevant timeframes are managed to protect the organisation.

Finally, if a claim is made by an individual involved in an investigation process, care should be taken to ensure that no action is taken against them which could be perceived as retaliation for them making the claim or asserting their rights.

This is a complex area and we recommend that you seek support if any claim is received against your organisation.

How we can help

Moores regularly advises clients how to respond to misconduct and manage workplace investigations, and can assist with conducting investigations in house or working with an external investigator.  We can also provide training and coaching for your human resources and senior management teams on how to manage the many issues which may arise, in accordance with your organisation’s policies, procedures and values.

If you would like to discuss our services further, or have any questions in this space, please do not hesitate to contact us.

The Australian Charities and Not-for-profits Commission (ACNC) has substantial powers of investigation in support of its compliance functions[1]. Outcomes of investigations can include revocation of charity status or the charity entering into a compliance agreement with the ACNC concerning the future conduct of the charity.

In August 2019 , the charity status of five organisations was revoked, while another charity entered into a compliance agreement with the ACNC. With a broad range of enforcement powers available to the ACNC, how should a charity facing investigation respond to ensure the best outcome for that charity and its beneficiaries?

Understand the framework

All charities are required to comply with the ACNC Governance Standards and, if the charity has overseas operations, the External Conduct Standards (the Standards) in order to remain registered as charities and eligible to receive charity tax concessions. If the ACNC becomes aware of a potential failure to comply with these Standards, it may carry out an investigation. The purpose of the investigation is to obtain and critically review information and documentation from the charity to assess whether the Standards have been breached. If the ACNC finds that there has been a breach of the Standards, it may exercise its compliance powers – including, in the most serious cases, revocation of charity registration – in accordance with the ACNC’s Regulatory Approach.

Take it to the top

Compliance with the Standards is a governance matter, not an operational matter. A charity’s responsible persons (the Board, Committee or Trustees) should be immediately informed of any ACNC compliance action. Any notice of investigation should be circulated to all responsible persons and a meeting convened as soon as possible. A charity’s responsible persons should be actively involved in determining how the charity will respond to an investigation and settling any formal written response to the ACNC.

Get moving

An ACNC notice of investigation typically includes a request for the provision of a detailed and extensive range of documents and information. The deadline for providing this documentation and information is usually short – a matter of weeks – and the ACNC may refuse to grant an extension. It is prudent to instruct trusted administrative staff, professional advisers or volunteers to begin collating this material immediately, even if the charity’s responsible persons have not yet been able to meet.

Be responsive

Due to secrecy provisions, there is limited information available about how the ACNC has managed compliance actions in the past. This can create some uncertainty about how the ACNC will respond to a particular compliance matter. One thing is certain, however – ignore the ACNC investigation, obfuscate or fail to cooperate and the ACNC’s response will escalate. It is critical that a charity facing investigation communicates with the ACNC, meets deadlines (or seeks extensions if absolutely necessary) and provides the information sought in a clear and comprehensive format. Don’t put your head in the sand – an ACNC investigation won’t go away if you don’t address it.

Tell your story

Compliance is, in part, a question of context. There is no universal way to apply the Standards. The Standards are, broadly, principles based. This means that each charity must determine how it should apply the principles set out in the Standards in its particular context, including its purpose, size, operations, beneficiaries and other stakeholders. When responding to an ACNC investigation, the charity’s story and context may be critical to explaining conduct that might otherwise appear to be a breach of the Standards.

Get on the front foot

Most charities that assess their governance and operations closely against the Standards will identify areas for improvement. A prudent charity will proactively make improvements in the course of an investigation. Improvements made can be communicated to the ACNC as part of the response to the investigation, rather than waiting until the ACNC identifies the organisation’s shortcomings and requires them to be addressed.

Involve advisers early

A lot is at stake in an ACNC investigation. An experienced charity lawyer can assist throughout the process – from understanding the scope of any request for documents and information, to assisting the organisation to articulate and explain its context, identifying areas of non-compliance and recommending improvements. For this reason, it’s important to bring any advisers on board early.

A silver lining

An ACNC compliance investigation usually requires a significant investment in terms of time spent collating documents, reviewing an organisation’s operations and governance and preparing a response. Nothing focuses the collective minds of a charity’s responsible persons and executive team quite like an ACNC investigation. When done well, however, a considered and strategic response to an ACNC investigation will not only mitigate the risk of ACNC compliance action, it will result in improvements to the charity that will ensure its good governance well into the future.

How Moores can help

Moores’ For Purpose team provides strategic and practical advice to charities experiencing change and crisis. To find out more, please do not hesitate to contact us.


[1] [see section 70-1 ACNC Act 2012]

Moores is proud to have assisted our client Aussie Helpers to retain its registered charity status following an investigation by the Australian Charities and Not-for-profits Commission (ACNC).  

Today’s release of a joint statement confirms that Aussie Helpers will remain a registered charity and be able to continue to provide support to rural families.

Moores was approached by Aussie Helpers in late 2018 to assist in responding to the ACNC investigation. Like many growing charities, Aussie Helpers’ governance practices and policies had not kept with the expansion in its operation.

Moores worked alongside Aussie Helpers throughout the investigation, identifying areas for improvement, providing governance training, updating the charity’s constitution and recommending changes to internal policies and processes. Moores will continue to assist Aussie Helpers as it implements the remaining requirements of the compliance agreement which will enable their governance infrastructure to grow and keep up with changes to the size, nature and complexity of the charity’s operations in the future.

Aussie Helpers’ gave its full cooperation to the ACNC investigation and was diligent in making improvements. As well as providing all of the information and documentation sought by the ACNC, Aussie Helpers’ team have done extensive work on improving governance policies and practices in the charity.

This is a great outcome for Aussie Helpers that will enable them to continue their valuable work in rural Australia.

How we can help

Moores’ For Purpose team provides strategic and practical advice to charities experiencing change and crisis. To find out more on responding to ACNC investigations – click here.

For more information please do not hestitate to contact us.