The lessons learnt from the recent case of Re Marsella; Marsella v Wareham (No 2) [2019 VCS 65)] are two-fold:

  • one, the case highlights the importance of SMSF trustees being aware of their duties and responsibilities when paying death benefits in the exercise of discretion; and
  • two, it brings to the forefront how proceedings like this can be avoided by a superannuation fund member proactively addressing their estate planning before it’s too late!

What happened?

Helen Marsella (“Helen”) and her daughter Caroline were the trustees of a SMSF.  Helen was survived by her husband Riccardo and her two children from her previous relationship, including Caroline.  Riccardo was the executor of Helen’s Will.

Caroline resolved as the surviving trustee to pay all of Helen’s death benefits to herself. Helen had no valid binding nomination in place. On the same day, Caroline also appointed her husband, Martin, as a co-trustee of the fund and there was a further resolution by Caroline and Martin to distribute the death benefits to Caroline solely. The resolutions stated that the trustees had given due consideration to “the possible interests of all Dependants of the deceased member, the potential eligible Beneficiaries of the Member, and the Member’s Estate”.

Riccardo sought to have:

  1. Caroline and Martin replaced as trustees; and
  2. the repayment to the fund of the amount distributed as death benefits together with interest. 

Riccardo argued that the trustees did not give “real and genuine consideration to the interests of the dependants of the fund and the distribution made from the fund should be set aside”.

Of particular note in this case is that Caroline had been advised to seek specialist advice. She had been made aware of:

  1. the importance of paying out the death benefits “as soon as practicable”; and
  2. the need to consider the interests of all of Helen’s dependants as defined in the fund trust deed.

The Court was asked to consider:

  1. Whether the trustees properly exercised their discretion in resolving to distribute the death benefits; and
  2. Whether Caroline and Martin should be replaced as trustees. 

The Decision:

In setting aside the exercise of discretion, Justice McMillan held that the trustees failed to exercise their discretion with a real and genuine consideration of the beneficiaries of the fund in determining to pay the death benefits to Caroline.

Justice McMillan stated that whilst it wasn’t the Court’s role to consider the fairness or reasonableness of the outcome of the exercise of discretion or usurp the role of the trustee, if the result is “grotesquely unreasonable”, the outcome may form evidence that the discretion was never properly exercised, or was exercised in bad faith. Relevant factors for consideration included:

  1. the intention of the deceased;
  2. the relationship between the dependant and the deceased; and
  3. the financial circumstances and needs of the dependant.

Here, the trustees ignored Riccardo’s and Helen’s substantial relationship and his relatively limited financial circumstances.   

In the judgment, Justice McMillan was particularly scathing of Caroline noting that she had proceeded with the appointment of a co-trustee and distribution of benefits in the context of uncertainty, significant conflict and lack of recommended specialist advice.

Her Honour also determined that in the context of an improper exercise of discretion, conflict and personal acrimony between the parties, Caroline and Martin should be removed as trustees.

Riccardo was required to make submissions to appoint a replacement trustee or corporate trustee.

Key case lessons

With cases on death benefit payments becoming more common, there are some key lessons from this decision:

1. Trustee Discretion

Trustees need to be aware that their responsibilities extend to decisions required to be made when paying out death benefits, as part of accepting their appointment as trustee or director of the trustee company.  In the absence of a valid binding nomination, factors that are relevant in determining whether the discretion of the trustee is exercised in good faith and upon real and genuine consideration include:

  • The inquiries the trustee made, and the information they had;
  • Whether the trustee has informed her or himself of the matters relevant to the decision, including seeking specialist advice in light of the size of the fund and complexities surrounding the fund deed and compliance with the SIS Act;
  • The intention of the deceased;
  • The relationship between the deceased and the dependants;
  • The financial circumstances and needs of the dependants; and
  • Whether the trustees acted in the context of uncertainties and/or misapprehensions.

2. Proper and current estate planning

For superannuation fund members who want certainty about who receives their superannuation benefits (particularly in the context of a second relationship where there may be different objectives for different assets and interests), this case illustrates the significance of having a valid binding nomination or reversionary pension in place. 

Most people still believe that it is their Will that is the most important document when dealing with the passing of assets on deal and will often prioritise updating or seeking advice on their Will, without thinking about who their superannuation is to end up with. 

Thinking about succession to control of a SMSF is also important so as to ensure that the fund has the right people in control on death (and even on incapacity). For example, it is likely that there would have been a different outcome in the exercise of trustee discretion in Re Marsella had there been a company as trustee, of which Helen (as the sole member) was the sole director. Riccardo may have taken control of the SMSF in his capacity as Helen’s legal personal representative and determined to pay all of the death benefits to himself. In this instance, it may also be prudent to have an express authority in the Will for a spouse to claim and receiving death benefits personally and not in his or her capacity as legal personal representative.

Conclusion

Whilst a trustee’s discretion is absolute and unfettered, this case highlights the willingness of the Courts to remove trustees and set aside decisions in instances where trustees have not acted in good faith. 

To avoid this, it is recommended that trustees seek advice particularly where there may be some uncertainty or complexity. Proactively though, fund members should regularly review their estate planning to ensure that their documentation accords with their intentions. Where there is a SMSF involved, this potentially includes a current binding nomination, pension documentation, Will and super fund deed.

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

In our last issue (What use is a Trust when Family Law gets involved? Part 1 of 2) we focussed on the ability of the Family Court to set aside transactions involving trusts as occurred in Kennon & Spry.

In this issue, we consider the Court’s approach to more ‘routine’ discretionary trust cases and what factors apply when deciding if trust property is property of the relationship for the sake of a family law split.  

Bailey involved sixth generation farmers.  The trust was held to be for the benefit of the wider family and not property divisible in the marriage.  Crucially, the accountant was the trustee and gave evidence that the husband’s deceased Dad, who established the trust in the ‘60’s, had told him the trust was for all the generations in perpetuity, so he would definitely not distribute capital to the husband. 

Therefore, the court simply took into account the income stream of the trust as a financial resource available to the husband in the family law split. 

Differently, in Goodwin, the husband as appointor effectively controlled the trust for his benefit.  In the circumstances that trust was treated as property of the parties available for division between them.

Ward involved the husband’s mother establishing a testamentary trust for him and his children.  The husband in the witness box admitted that his mother had removed him as trustee and executor two days before she died – to make sure the wife didn’t get a share of her money! 

The new trustees were his sister and a solicitor, so the judge was satisfied that in reality they would make sure the husband got the trust money; therefore this was treated as property in the family law split.

In Bailey, two helpful checklists detail the considerations relevant to treating trust property as property of the parties’ relationship, including: 

  1. The history of the parties’ treatment of the trust property (see Goodwin);
  2. The history of exercising powers and making variations to the trust (Kennon & Spry);
  3. The benefits derived from the trust by the parties such as drawings, loans, salaries, payment of expenses, use of motor vehicle;
  4. Capacity to borrow trust funds;
  5. Contributions by the parties to the trust property (Kennon & Spry);
  6. One party’s ability to transfer assets to either spouse; and
  7. Whether a party has responsibility for the daily administration of the trust, including payment of accounts, etc.

The other checklist to consider relates to the control-of-trust factors:

  1. Holding office as trustee;
  2. Legal control of the trustee (through a corporate trustee) or personal appointment;
  3. Power to replace the trustee (Goodwin);
  4. Practical control (e.g. the trustees are friends, relatives or trusted advisors who act on the request of the controlling spouse – Ward).

Planning Tips

How trusts are set up, and how they are administered will be relevant to the Family Court’s powers and how they are exercised. At the set up phase relevant considerations should be around who controls the trust and who can benefit from it and to what extent. Broadly, the less control or benefit a party to the marriage can receive the better.

It is not just the set up of trusts that will be relevant. How the trust is used and who routinely benefits, is also an important factor.

Having said that, if certainty is required, the best planning tool is the use of Binding Financial Agreements or Inheritance Protection Agreements.

How we can help

If you or your clients have any questions about any of these matters, our expert Family Law team would be delighted to assist. Please do not hesitate to contact us.

On 19 December 2018, the Guardianship and Administration Bill 2018 (“the Bill”) was introduced. An overview of the Bill can be found in our first article of the series here.

This article is the third in our series, and will focus on the new regime of supported decision-making, a key change under the Bill.

What is supported decision-making?

Supported decision-making is a concept of growing importance in line with changing views on disability. 

As distinct from “substituted” decision-making – where a third party makes a decision for the represented person – supported decision-making enables encourages individuals with disabilities to make their own decisions about their lives with the support of others. It offers an alternative to guardianship or administration orders, which recognises that individuals with a disability can often preserve their autonomy with support.

Supported decision-making is becoming preferred over substituted decision-making where possible. The provisions of the Bill reflect similar reforms implemented in several pieces of recent legislation including the Powers of Attorney Act 2014 (Vic) (POA Act) and the Medical Treatment Planning and Decisions Act 2016 (Vic) (MT Act).

New powers in the Bill

The Bill introduces the concept of supportive guardians and supportive administrators. VCAT will have the power to appoint these supportive roles under orders.

When making supportive orders, VCAT will need to consider the following:

  1. Decision-making capacity – VCAT will only be able to make supportive orders if it is satisfied that the power will ensure that the support given will enable the supported person to have decision-making capacity in relation to the relevant personal or financial matters.
  2. Scope of powers – the orders can confer a range of powers including allowing a person to access and collect information on behalf of another, communicate information and decisions and give effect to decisions.

Unlike guardianship and administration orders, supportive roles will only be able to take action to support the individual to make decisions as opposed to making decisions on their behalf.

Duties of supportive guardians and supportive administrators

Supportive guardians and administrators have a broad range of duties which include a duty to:

  1. act honestly, diligently and in good faith;
  2. exercise reasonable skill and care;
  3. not use the position for profit;
  4. not act where there is or may be a conflict and if there is a conflict, ensuring that the interests of the supported person are the primary consideration;
  5. discuss anything relating to a supported decision with the supported person in a way that the supported person can understand and that will assist them in making the decision;
  6. not assist the supported person to conduct any illegal activity; and
  7. not coerce, intimidate or any way unduly influence the supported person.

Supportive guardians and administrators cannot be remunerated for their role.  They must also advise VCAT of the death of the supported person in writing as soon as practicable.

Supportive guardians and administrations that act dishonestly to obtain a financial advantage or cause loss to the supported person or another person are liable for a maximum of 5 years imprisonment or 600 penalty units or both.

When is a supportive order more suitable? 

A supportive order may be more suitable than a guardianship or administration order if the supported individual has the capacity to make decisions, albeit with the support of others. 

This could include individuals suffering from early cognitive decline who might need help accessing accounts or remembering passwords or individuals with a physical disability that require assistance in collecting information or enacting decisions.

The process for determining and applying for a supportive order is complex and individuals should consider obtaining legal advice.

If an individual has decision-making capacity, they can continue to appoint a “supportive attorney” of their choosing, without going to VCAT.  For information about “supportive attorneys”, please see our previous article here.

How we can help

If you seek further advice about these matters, please do not hesitate to contact us.

This article is part of our Guardianship and Administration Bill series:
Click here for Guardianship and Administration Bill 2018 – Overview
Click here for Guardianship and Administration Bill 2018 – Administrator liability and new offences

Schools registered in Victoria must be not for profit and not be party to prohibited arrangements in order to maintain registration –  Education and Training Reform Regulations 2017 (Vic)

Consistent with its new Guidelines to the Minimum Standards, the VRQA is prioritising audit of matters relating to:

  • Not for profit school – the requirement that all funds are applied solely towards conduct of the school (r7); and
  • Prohibited Arrangements – the requirement that schools are not party to these (which involve diversions of funds or excessive payments to other entities, including loans made for purposes not connected to the School).

Schools which are up for review might consider that they are on notice from the VRQA that many arrangements with ELCs and school systems are considered to be in contravention of the above requirements.

Other schools should consider their arrangements, consistent with the requirements of the new Guidelines to the Minimum Standards which take effect from 1 July.

ELCs

ELCs are not considered to be schools under the legislation (Education and Training Reform Act 2006 (Vic)), so payments to them are treated as payments to third parties.  (“Schools” provide education to children aged 5 to 17, which are the compulsory school attendance ages in Victoria).

Evidence that ELC arrangements are not in contravention will need to include:

  • Proper accounting;
  • Agreement which meets the requirements of the Regulations, between the school and ELC regarding service and payments in both directions.

School Systems

Payments to school systems can also contravene the Regulations, if payments made are used for other schools in the School system and are not otherwise able to be justified as consistent with the system’s permitted activities under the Regulations.

Evidence that system arrangements are not in contravention will need to include:

  • Proper accounting;
  • The policy of the system regarding use of school funds; and
  • Agreement which meets the requirements of the Regulations, between the schools and system regarding service and payments in both directions.

How we can help

If you would like further information about the required agreements, policies and accounts matters, please do not hesitate to contact us.

Is there recourse against an administrator or guardian who fail to appropriately manage a represented person’s affairs? The answer is yes.  The existing law of negligence allows a claim in damages to be brought against an administrator. The Guardianship and Administration Bill 2018 (“the Bill”) will also bring in new compensation provisions and offences where a guardian or administrator dishonestly uses their powers to obtain a financial advantage. 

Guardians and administrators are appointed by the Victorian Civil and Administrative Tribunal (VCAT). A guardian makes lifestyle decisions (where to live, medical treatments) and an administrator makes financial and legal decisions on behalf of a represented person. This article deals with administrators’ liability.

Compensation Claims Against Administrators

A represented person is and remains entitled at common law to claim compensation from an administrator in negligence. There are few reported Court decisions of claims against an appointed administrator – the majority resolve prior to issuing proceedings or prior to hearing.  In practice, examples of administrators’ breaches of duty of care include a failure to secure a represented person’s assets, failure to adequately manage a represented person’s estate or failing to invest their assets in their best interests.  

The Bill will in some respects now make it simpler for compensation claims to be brought against an administrator, whether the claim is made by the represented person or by an interested party. Interested parties will include an executor of the represented person’s deceased estate, the nearest relative of the represented person, the Public Advocate or any other person determined to have a special interest in the represented person’s affairs. The compensation provisions in the Bill will apply even if an administrator is convicted of an offence, the represented person has died, or the order appointing the guardian or administrator is no longer in force. 

Section 181 will allow the Supreme Court or VCAT to order an administrator to compensate a represented person for losses caused by them by contravening the Bill when acting as administrator. This provision mirrors the attorney compensation provision (section 77 of the Powers of Attorney Act 2014 (Vic)). An administrator will be entitled to seek to be excused from personal liability if they establish that they were acting honestly and reasonably and ought fairly be excused.

Specific Transactions Undertaken by Administrators

Section 78 of the Bill allows the represented person themselves or an interested person to apply to VCAT on “any matter arising out of a dealing or transaction in relation to that financial matter” and VCAT will have broad powers to “make any order in relation to the application which VCAT considers appropriate”. An interested person can include anyone who would be entitled to the property of the represented person, or a share of that property under any law.

Take Away Points

Individuals or organisations that are involved with represented persons or their family members should note:

  1. A represented person or their family or friends can apply to VCAT on any matter arising out of a specific dealing or transaction in respect of that financial matter.
  2. If a represented person or their family or friends are concerned about the management of their affairs by an administrator generally, they should take steps to investigate what has occurred.
  3. If, following an investigation, a breach of duties resulting in loss is identified, a represented person or their family or friends are entitled to bring a compensation claim against an administrator.
  4. Individuals or organisations currently appointed as administrators should make themselves aware of the new obligations, offence and compensation provisions incorporated in the Bill.

If you have any questions regarding a guardian or administrator abusing their powers for their financial advantage or any other matter mentioned in this article, please do not hesitate to contact us.

This article is part of our Guardianship and Administration Bill series:
Click here for Guardianship and Administration Bill 2018 – Overview.
Click here for Guardianship and Administration Bill 2018 – Supported Decision-Making

Sometimes trusts are great at protecting assets during family law disputes, other times not. This two part series will start with a High Court case involving variations to a trust deed, and conclude with details of exactly what factors are important in deciding if trust assets are in or out of the matrimonial pool. 

As a starting point, the Family Law Act says that the Court can only make orders in relation to “property” of the parties to the relationship (married or not). Hence the trust assets must be effectively property of a party if both parties are to clearly get a share.

The Family Court has a number of powers that can be used when trusts are involved including:

  • the ability to set aside transactions;
  • the ability to determine whether trust assets are in the pool of property available for division; and
  • the ability to make orders against third parties (including trustees of trusts).

The High Court case of Kennon v Spry is a significant decision that predated the ability of the Court to make orders against third parties. The issue in this case was around setting aside transactions.

The case involved Dr Ian Spry – a famous barrister who wrote textbooks on trust law. Dr Spry first created his trust in 1968 by declaring an “oral trust”. After the marriage in 1978, he formalised this with a trust deed in 1981. He was the trustee, and the beneficiaries were himself, the wife and their 4 children. He could alter the trustee in his absolute discretion.

In 1983 he removed himself as a beneficiary of the trust. In 1998, when the marriage was in trouble, he amended the trust deed again, appointing two daughters as trustees and irrevocably excluding himself and his wife from any further distributions.

In 2001 they separated and Dr Spry then established another four trusts, controlled respectively by the four children, and he distributed the assets of the original trust equally between those four trusts.

Consequently, the trust could no longer be property of the parties as it was out of their control. However, the Court then looked as section 106B of the Act. This provides that if someone has made an instrument or disposition, which may have the effect of putting assets out of the reach of a Family Law Court order, whether intentionally or not, then the Court can set aside the instrument or disposition.

The Court easily decided that this had indeed happened. They set aside the variations of trust made in 1998 and 2002, leaving in place the 1983 variation with the wife a beneficiary and the husband the trustee. The Court then said, since he had control of the trust and had the power to appoint all the trust property to the wife, the trust property could be treated as property of the parties and divided pursuant to the Family Law Act.

Planning Issue: Restructuring and other transactions taking place during a relationship are more likely to be at risk of being set aside by the Family Court. 

In our Next issue, we will describe the characteristics of trusts which make them more or less open to family law assault. Click here to read Part 2 of 2.

How we can help

If you have any questions about any of these matters, or if your client needs to explore this, please do not hesitate to contact us.

In the last year or so, how many of your family, friends, clients, colleagues or acquaintances have got married? And of those newlyweds, was reviewing their estate planning at the forefront of their minds, as something they should attend to before or soon after the nuptials?  Would they be aware that the act of getting married could drastically affect what happens to their estate if they die?

Some recent statistics on Marriage

The Australian Bureau of Statistics (ABS) reported in November 2018, that there were a total of 112,954 marriages registered in Australia in 2017, with 30,129 of these being registered in Victoria. The figures from previous years are around the same, give or take a few thousand.

However, the total number of marriages taking place each year could be expected to increase in the future, now that marriage is no longer limited to heterosexual couples. In just the first six months after the amendment in December 2017 to the Marriage Act 1961 (Cth), allowing marriage between two persons regardless of their gender, the ABS reported that 3,149 same-sex marriages took place across Australia. 

What could this mean?

Subclause 13(1) of the Wills Act (Vic) 1997 (“the Wills Act) states that marriage revokes a Will, the entire Will. This could mean that the minute they “tie the knot”, over 224,000 people each year (regardless of their gender) could be joining the ranks of those in Australia who don’t have a valid Will in place.

One exception in the Wills Act is that, a marriage that was contemplated in the Will does not revoke the Will. This gives couples the chance to plan well in advance.

There are some further exceptions in the Wills Act, including that if you make a gift to someone to whom you are not married to at the time of making your Will or appoint them as your executor, the gift or appointment will not be revoked if you are married to that same person at the date of your death.

However, unless the Will is made in contemplation of marriage, all gifts to any other people or appointments of other people as the executor will instantly be revoked by the marriage.

If a person either dies without a valid Will in place or their Will does not dispose of their entire estate, the assets not effectively dealt with become subject to the “intestacy rules” in the Administration and Probate Act (Vic) 1958. The intestacy rules set out who receives the estate of someone who dies without a valid Will.

Where a Will has been revoked due to marriage, this could mean that loved ones such as children from the relationship or other family members or friends, could miss out entirely on an intended gift.

Whilst children from a previous relationship may still receive some benefit under the intestacy rules, it could be far less (or perhaps far greater) than what was intended.

What to do?

The happy couple should preferably consult an estate planner and a wedding planner at the same time. If this doesn’t happen, they should take steps to ensure that they have a valid Will in place as soon as possible after the marriage.

How we can help

We have specialised estate planning lawyers who can advise and assist anyone who has recently married or is preparing to marry.  Please do not hesitate to contact us.

The team at Moores recently delivered a highly topical seminar on the issue of challenging school enrolments and the growing complexity between interactions with parents and students. During this seminar, our team carefully guided our clients through an engaging session with information to equip Schools to effectively deal with problem parents, tricky enrolments, discrimination and school building funds.

Challenging Enrolments

Many independent and Catholic schools have great stories to tell about the increasing complexities of enrolments. Not only are families becoming more complex, many parents are growing in their willingness to assert their position and challenge schools regarding enrolment decisions. 

We are seeing a high level of activity from parents in the areas of waitlist jumping, illusory sibling priorities and discounts, breaches of scholarships terms and conditions, claims of discrimination, and plain old bad behaviour.

What we also see is that many schools are not equipped with robust documentation which allows them to assert their position.

Given that the VRQA has mandated the online publication of enrolment documents with effect from 1 July 2019, now is the time to review and upgrade any documents which may contain ambiguity or lack of compliance.

Our key tips are:

  • Ensure your enrolment policy is clear on waitlists and sibling priorities and discounts, but ensure you retain an ultimate discretion;
  • Ensure your scholarship terms and conditions are clear on:
    • The expectations on the student in order to retain the scholarship; and
    • If you expect parents to “re-pay” foregone fees on breach or early departure:
      • Your terms clearly state this expectation; and
      • You can actually support the fact that the School has foregone fees to provide the scholarship.
  • Re-calibrate your enrolment documents to appear in the Enrolment Trifecta of policy, terms and conditions and parent code of conduct;
  • Ensure you make the parent code of conduct enforceable and sufficiently clear on termination of enrolment (many are too vague and therefore do not assist);
  • Ensure any payment plans for fees are well documented, including the implications of breaching the plan; and
  • Noting schools can lawfully discriminate against current and prospective students if an exception applies, but these are very limited, consider adopting a structured framework to assess prospective students against your ethos.

Lastly, the VRQA Guidelines will require boards, management and compliance to implement new documentation by 1 July 2019.  Please see our article here for more information.

School Building Funds

The ATO are reviewing school building funds, here are our top tips:

School Building Fund:-

  • Can’t be used to pay for things that are not ‘fixtures’ of the building, such as furniture, computers and lab equipment.
  • Can be used to pay for the administration costs of the fund, such as bank fees, accounting costs and reasonable remuneration for the fund’s administrator and staff.
  • Must be registered as a charity or operated by a registered charity.  Rule of thumb – if there is a separate trust deed, the fund itself needs to be registered as a charity.
  • If the School requires parents to pay a compulsory levy to the fund, the parent cannot claim a tax deduction – the payment must be made voluntarily to be deductible.
  • The fund must be controlled or administered by a majority of people who have a degree of responsibility to the community – eg principal, lawyer, doctor, pastor.

How we can help

If you have any questions or would like more information on navigating the new VRQA Guidelines and School Building Funds, please do not hesitate to contact us .

Feedback from the seminar

“...it was engaging and informative“- Risk and Compliance Leader, Independent School in Melbourne

Thanks for the briefing today, it was one of the best I have attended…” – Corporate Services Manager, Independent School in Melbourne

Your sessions are always so valuable and helpful. You are all so warm and welcoming and don’t speak ‘legal jargon’ that we can’t understand!” – Enrolments Manager, Independent faith-based School in Victoria

Following on from Part 1 & Part 2 we conclude with summarising how NFP directors can protect themselves:

How can directors protect themselves?


Indemnity:

Many organisations indemnify their directors against any liability incurred in good faith by the director in the course of performing his or her duties.

Of course, an indemnity is only effective to the extent that the organisation has sufficient assets to cover the loss. This is where Director and Officer Insurance is important.

Director and Officer Insurance:

Director and Officer Insurance (D&O Insurance) is designed to protect directors and officers against personal liabilities, in relation to claims that arise from decisions they make while carrying out their roles (and in the scope of their authority).

The coverage will vary depending upon the policy obtained, will generally contain limits and will exclude loss resulting from certain conduct (such as dishonest breaches of duties).

An insurance broker will be able to clarify what is and is not covered in a particular policy.

Other protections:

Avoiding any breach in the first place is the best protection against personal liability. Some important ways of avoiding a breach is to:

  • Take the time to understand what laws apply to the organisation.
  • Encourage a culture of compliance.
  • Encourage a culture where breaches can be reported.
  • Exercise independent judgement and interrogate information that you are given. In particular, don’t simply rely on another director to read relevant material and understand information relevant for decisions.
  • Have the right skills on the board, and where there are skills that are lacking, or where otherwise appropriate, seek expert advice.
  • Have strong risk management processes. This can include having a risk register which allows the organisation to identify current and potential risks and find ways to mitigate those risks.
  • Have good compliance policies and processes.

Click here for Part 1 – Introduction and duties and liabilities of directors

Click here for Part 2 – Tax and superannuation, Occupational Health and Safety Laws (OH&S Laws),Employment laws, Child safety laws, Competition and Consumer Laws

Contact us

For more information or not-for-profit legal advice, please do not hesitate to contact us.

Following on from Part 1, we continue to summarise the key duties of a NFP director based on the standards in Victoria. Directors should ensure they are familiar with the rules in their states, which may vary.

Tax and Superannuation:

Directors should always take reasonable care to ensure that the tax affairs of the organisation are in order. While NFPs do not generally pay income tax, there are other tax obligations that may apply.

In particular, directors should ensure that the organisation is meeting its obligation to pay superannuation and pay as you go withholding tax (PAYGW). In certain circumstances, the ATO can require a director to pay for outstanding superannuation and PAYGW liabilities.

Directors may also be liable where the organisation is found to have committed a tax offence (such as making false or misleading statements to the ATO). This will generally only occur where the director was involved in the offence, including by aiding, abetting, counselling or procuring the act or omission that led to the offence.

Occupational Health and Safety Laws (OH&S Laws):

Broadly, the organisation, as an employer, has obligations to eliminate or minimise the risk of harm to the health and safety of workers.

Directors should take steps to make sure that the organisation is complying with its OH&S obligations. For example, by understanding the risks and hazards associated with the organisation’s operations and making sure that it is properly resourced to eliminate or minimise those risks.

If the organisation breaches that duty because a director failed to take reasonable care, the director may be guilty of an offence.

Breaches of OH&S laws can lead to civil or criminal penalties as well as personal liability for any loss suffered and imprisonment in very serious cases.

Employment laws:

Directors should be aware of laws regarding the responsibilities of employers and the rights of employees.

The Fair Work Act 2009 (Cth) covers a range of employment issues, including unfair dismissal, the National Employment Standards, adverse action and redundancy.

Generally, a board is not directly involved in the daily considerations of work conditions and pay. However personal liability may arise where a director is involved in a contravention (e.g. by aiding, abetting, inducing or being knowingly concerned with the contravention).

Child Safety Laws:

In Victoria, organisations that exercise care, supervision or authority over children have a responsibility to reduce the risk of child abuse. Broadly, if a person knew of a substantial risk of child abuse by someone associated with the organisation; and had the power or responsibility to reduce or remove the risk, but negligently failed to do so, that person may be charged with a criminal ‘failure to protect’ offence.

Competition and Consumer Laws:

There are various protections for consumers under Australian consumer laws including prohibitions on price fixing, cartel conduct or engaging in false or misleading conduct.

A director may be liable where they were in some way involved in the contravention (for example, if they aided or abetted, induced or were knowingly involved in the contravention).

To read more…

Click here for Part 1 – Introduction and Duties and liabilities of directors

Click here for Part 3 – How can directors protect themselves?

How we can help

For more information or not-for-profit legal advice, please do not hesitate to contact us.