Many of us understand the importance of having a Will in place to distribute our assets when we die.

But what happens if we lose the ability to make our own decisions for financial, personal and medical matters?

A Will only comes into effect when you die, so it is equally important to also have documents in place authorising a person or persons to make decisions for you if you are unable to make them for yourself during your lifetime.  This is where Enduring Powers of Attorney and Appointments of Medical Treatment Decision Makers fill that gap.

What are Enduring Powers of Attorney?

In Victoria, there are three types of powers of attorney which you can put in place.

Enduring Power of Attorney (Financial)

In this document, you can appoint one or more people to deal with your financial matters on your behalf. Financial matters can include dealing with banks and investment companies, buying and selling assets, paying bills and buying and selling property. You can choose when your attorney’s power commences to provide greater flexibility for yourself and your attorneys. For example, if you are overseas, you can instruct your attorney to act on your behalf while you are out of the country.

Enduring Power of Attorney (Personal)

In this document, you can appoint one or more people to deal with personal matters on your behalf. Personal matters can include deciding where you live (i.e. whether you move into aged care), how you dress, what you eat, when you get a haircut and who you associate with. Given these matters are very personal in nature, your attorney’s power generally only commences if you were to lose capacity, as evidenced by a letter from a medical practitioner.

Appointment of Medical Treatment Decision Makers

Although medical decisions are also personal in nature, this document differs from the Enduring Power of Attorney (Personal) because it only deals with consenting or withholding consent to medical decisions.

In this document, you can only appoint one person at a time (not jointly) to make medical decisions on your behalf. Your medical decision maker, by law, is required to make decisions that they would reasonably believe is a decision that you would have made if you had capacity.

To ensure that your medical decision makers know your preferences, you can complete a document called an Advanced Care Directive. This assists your chosen medical decision makers to make a medical decision for you based on your beliefs and values. You can elevate it from a values directive to a binding directive in which you specify what medical procedures you consent to or what you withhold consent to.  Binding directives require witnessing by a doctor. 

Isn’t my next of kin automatically entitled to make decisions for me?

For financial and personal matters, this is not the case.

Although it may seem practical that, for example, your spouse, or your adult child can automatically sign off on financial and personal decisions for you (as long as they provide medical evidence of your lack of capacity), the law in Victoria prevents next of kin from making those decisions without being validly appointed.

However, for medical matters, yes, the law in Victoria does allow next of kin to make medical decisions for you.

There is a set hierarchy of people in your life who have legal final say on your medical treatment, if you cannot give the doctor your decision yourself. This set hierarchy is only applicable if you do not have a valid Appointment of Medical Treatment Decision Maker document in place.

The Medical Treatment Planning and Decisions Act 2016 (Vic) at section 55 (3) provides the following order of medical treatment decision makers:

  1. Spouse/domestic partner;
  2. Primary carer;
  3. Your adult child (and if more than one, the eldest);
  4. Your parent (and if more than one, the eldest); and
  5. Your adult sibling (and if more than one, the eldest).

Although the law states that the people listed above are to be in a close and continuous relationship with you, in some cases, the prescribed hierarchy of medical decision makers may not be suitable in your circumstances. This is a strong reason for you to consider putting in place your own hierarchy via an Appointment of Medical Treatment Decision Maker document.

What happens if I do not have Enduring Powers of Attorney in place?

If you lose capacity without Enduring Powers of Attorney for financial and personal matters in place, a person may make an application to the Victorian Civil and Administrative Tribunal (VCAT) to become an administrator (who deals with financial matters) and/or a guardian (who deals with personal matters).

Under the Guardianship & Administration Act 2019 (Vic) section 32, VCAT can appoint an administrator or guardian who is:

  • Over the age of 18;
  • Someone who VCAT is satisfied will act in accordance with the duties imposed at law on an administrator and guardian;
  • Not in a position of conflicting interests with you;
  • Is a “suitable person” to act for you; and
  • For administrative matters, has sufficient expertise to make decisions about your financial matters.

When considering whether someone is a suitable person to act for you, VCAT must take into consideration the following:

  • Your will and preference, as far as they can be ascertained;
  • Preserving any existing relationships that you have which are important to you;
  • Desirability of appointing a relative of yours, or someone who has a personal relationship with you, rather that someone who you do not have such relationship with; and
  • Whether the proposed administrator/guardian will be available and able to meet and communicate with you.

If VCAT deems that there is nobody appropriate in your life to fulfil the role of guardian or administrator, they can appoint the Office of the Public Advocate as your guardian, and State Trustees Limited or a private trustee company as your administrator.

The process a family member or friend is required to go through in order to be appointed as your guardian or administrator can be time consuming, stressful and even costly, and ultimately, VCAT has the final say on who is appointed. This is why it is important to have Enduring Powers of Attorney in place while you have capacity, so you have peace of mind knowing that you have made the decision as to who looks after your affairs, yourself. 

How we can help

The Wills, Estate Planning and Structuring team at Moores is one of the largest in Australia and can assist you in preparing your Will and Enduring Powers of Attorney to ensure that your assets are not only looked after in the event of your death, but in the event of your incapacity to make decisions.

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Marriage and divorce are significant life events that can have important implications for estate planning.

Fundamentally, a Will remains in force until it is revoked. This is most often done by the execution of a new Will to replace a pre-existing one.

But did you know, marriage or divorce can also affect the validity of a Will? 

What is the effect of marriage on a Will?

In Victoria, any Will created before the marriage will be automatically revoked when a person marries. Certain clauses of the Will which may continue to have effect notwithstanding – for example, gifts for a spouse or appoints a spouse to certain roles such as executor. However, the rest of the Will including any provisions made to other people will generally cease to have effect, leaving them out of the estate distribution altogether.

The incorporation of a “contemplation of marriage” clause can help avoid this automatic revocation issue. The contemplation is generally understood to mean that the Willmaker expects or intends to marry. The effect of this clause is to ensure that the Will continues to have operative effect even after the solemnisation of the marriage.

If a person marries without preparing a new Will or there is no contemplation of marriage clause contained in the pre-existing Will and they then pass away, the deceased’s estate will be distributed according to the laws of intestacy in Victoria.  

Additionally, a person entering into de facto relationships should note that these relationships do not automatically revoke a will. However, a de facto partner in Victoria may still have legal claims to the estate under family provision laws.

What is the effect of divorce on a Will?

Divorce also affects Wills in Victoria, but it does not revoke them in the same way as a marriage.

Under Section 14 of the Wills Act 1997 (Vic):

  • any gifts made to the divorced spouse in the will are revoked;
  • any appointments of the divorced spouse as executor, trustee or guardian are revoked, other than the appointment of the divorced spouse as trustee of property left upon trust for children of the spouse; and
  • the rest of the Will remains valid unless otherwise specified.

In other words, if a person has a pre-existing Will that leaves assets to their spouse and later gets divorced, the provisions benefitting the former spouse are automatically revoked but the rest of the Will remains in effect.

However, if that is not the Willmaker’s intention, then careful drafting of the Will is required to ensure that the former spouse is not inadvertently excluded from benefiting from the deceased’s estate.

Importantly, legal separation does not have the same effect on the Will. Until a divorce is legally finalised, the Will remains valid, meaning that a separated spouse may still inherit under a Will. This highlights the importance of updating a Will immediately after separation to reflect new intentions.

Marriage and divorce have significant legal consequences on Wills. Marriage generally revokes a Will unless it was made in contemplation of marriage, while divorce revokes specific provisions benefiting the former spouse but does not invalidate the entire Will. 

Given these automatic legal effects, individuals should review and update their estate planning whenever their marital status changes. Failing to do so can lead to unintended outcomes and the potential for disputes among surviving family members.

How we can help

The Wills, Estate Planning and Structuring team at Moores is one of the largest in Australia and can assist you in preparing your Will to ensure that your assets do not end up somewhere unexpected.

Contact us

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Are you an attorney or administrator tasked with selling a principal’s family home to fund their aged care, but facing challenges from a co-occupant claiming rights as a ‘protected person’?

This guide is designed to help you grasp the fundamental aspects and successfully navigate the complexities of this situation with confidence.

1. Understanding the Basics

As an enduring power of attorney or administrator, you may need to sell the family home to cover the principal’s aged care refundable accommodation deposit. However, this process can be complicated if someone is living in the home, such as a spouse, child, or carer.

2. Protected Persons and Exempt Assets

A property is not considered an asset for aged care assessment if it is occupied by a ‘protected person’. It’s crucial to determine if an individual qualifies as a protected person, as this affects how the family home is assessed. If a protected person resides in the property, the home is considered an ‘exempt asset’ for aged care purposes. This is different to the rules that apply to considering pension eligibility.

3. Key Distinction: Protected Person vs. Right to Stay

While a protected person status means the home is excluded from aged care assessment, it does not grant an inalienable right to stay in the property and prevent its sale. This distinction is critical for attorneys and administrators to understand.

While in many instances family members are cohabiting so one or more can provide the others with care and support, in other cases they can be arrangements of convenience, or exploitive.

Our elder financial abuse team too often sees adult children trying to rely on their asserted status as a protected person to justify staying in the family home and continuing the rent-free lifestyle they have become accustomed to without any history of providing care, even when doing so is financially damaging to their parent/s.

4. What is an Exempt Asset?

An exempt asset is disregarded for aged care assessment, meaning the principal’s aged care costs would be lower as they are assessed as a ‘non-homeowner’. The home care assessment is different from tests that apply to pension eligibility.

5. Who is a Protected Person?

A protected person can be:

  • A partner or dependent child of the principal.
  • A carer eligible for an Australian Government income support payment who has lived in the home with the principal for at least two years.
  • A close relative eligible for an Australian Government income support payment who has lived in the home with the principal for at least five years.

A protected person can remain in the property indefinitely, and while they do, the home remains an exempt asset. They typically need to complete forms with Centrelink to confirm their status.

6. No Protected Person in the Home?

If there is no protected person in the home, it becomes an assessable asset for aged care purposes up to the home exemption cap, which is $197,735 as of January 1, 2024. This means the principal may face significantly higher aged care fees unless the property is worth less than the cap.

7. Selling the Family Home with a Co-Occupant

If a non-protected person is co-occupying the property, selling the home depends on various factors, including any asserted rights to remain (e.g., equitable rights). Selling the home may attract scrutiny, so obtaining legal advice is prudent. Attorneys or administrators can seek advice from VCAT to protect themselves from liability if the decision is disputed.

8. Enforcing the Sale

If you are an administrator or attorney and issues arise removing a family member from a property, there are a range of legal options, including commence legal proceedings to recover possession and force an eviction. It is important to get legal advice before making a demand to vacate or commencing court proceedings.

9. How Moores Can Help

At Moores, we specialise in Powers of Attorney, guardianship, administration, and applications in VCAT and the Supreme Court of Victoria, including elder financial abuse issues. We are here to discuss any actions regarding the status of a protected person and the sale of the family home to fund a refundable accommodation deposit or other expenses.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Content warning: This article contains information in relation to sexual assault and child abuse. If you or someone you know require support, we encourage you to contact Lifeline on 13 11 14 or 1800 Respect.

A judgment recently handed down by the High Court of Australia has clarified the extent to which institutions will be vicariously liable for the historical sexual abuse and/or criminal conduct of its members.

In Bird v DP (a pseudonym) [2024] HCA 41, the High Court unanimously held that vicarious liability cannot be imposed without an employer/employee relationship. This means that institutions will not be vicariously liable for the historical and/or criminal conduct of its members where they are not strictly engaged as employees, including those engaged as independent contractors, volunteers or relationships ‘akin to employment’.

Background of the case

In this case, DP (a pseudonym) was assaulted and sexually abused on two separate occasions by Father Bryan Coffey (now deceased) (“Coffey”), a priest from DP’s local church. In 2020, DP commenced proceedings claiming damages for psychological injuries he had suffered as a result of Coffey’s abuse. DP alleged the Roman Catholic Diocese of Ballarat (“Diocese”) was vicariously liable for Coffey’s conduct.

At first instance, a single judge of the Supreme Court of Victoria found the Diocese was vicariously liable for Coffey’s conduct, even though that judge also found that Coffey was not an employee of the Diocese. The Diocese then appealed to the Supreme Court of Victoria Court of Appeal, which unanimously dismissed that appeal. The Diocese then applied to the High Court for special leave to appeal, which was granted.

At common law, generally, an employer can be vicariously liable for the wrongful acts or omissions of its employees in the course or scope of employment. This is based on the principle that employers knowingly accept the risks of hiring employees, including the possibility that employees might cause injury or damage to others while performing their job. However, employers are not always vicariously liable for the actions or inactions of its employees – there must be a sufficient connection between the wrongful act and the employment.

What was the issue?

The central issue before the High Court was whether the principle of vicarious liability could or should be extended to the relationship between Coffey and the Diocese, which was not an employment relationship. To put it another way, the High Court had to consider whether in the absence of an employment relationship, a Diocese or Bishop could be vicariously liable for the unlawful conduct of a priest.

Vicarious Liability

A majority of the High Court held that vicarious liability cannot be imposed without an employer/employee relationship. As there was no employment relationship between the Diocese and Coffey, the Diocese could not be liable for Coffey’s sexual abuse.

On the question of whether it should expand the boundaries of vicarious liability to include independent contractors or relationships ‘akin to employment’, the majority answered firmly in the negative. Although the High Court acknowledged the harshness of requiring an employment relationship for vicarious liability, it reasoned that expanding this requirement would create uncertainty and indeterminacy for the following reasons:

  • The ‘akin to employment’ test has led to results overseas which have expanded liability to relationships which previously would not have been understood to involve one party being liable for another’s wrongs;1 and
  • It would further complicate the already fraught distinction between employees and independent contractors.2

In light of these reasons, the High Court found that the requirement for an employment relationship in vicarious liability should remain and that any reformulation of the law in this area is a matter for parliament.

Agency

The majority also examined whether the Diocese was liable for Coffey’s acts on the basis of agency. However, as the unlawful acts committed by Coffey were not done with the Diocese’s or the then Bishop’s express, implied or apparent authorisation, the majority reasoned that Coffey could not be a ‘true agent’ of the Diocese.

“Non-Delegable Duty of Care”

Separately, DP also asked the High Court to rule on whether the Diocese owed a non-delegable duty of care to DP to protect him from the risk of sexual abuse by its priests, including Coffey. As the issue was not pleaded at first instance, or on appeal to the Victorian Supreme Court, the High Court declined to rule on this issue.

However, Jagot J (in obiter) observed that a personal or non-delegable duty of care may arise where the provision of care, supervision or control is required to be exercised by the defendant for the safety of the plaintiff in circumstances where the plaintiff would reasonably expect the exercise of due care for their safety. With the path to vicarious liability now requiring a strict employment relationship, it may be that claimants increasingly focus on negligence claims based on non-delegable duties of care, as these claims don’t always require an employment relationship to be established.

There also remains various statutory duties which impose liability for child abuse. For example, in Victoria, there is a duty on “relevant organisations” to take reasonable care to “prevent the abuse of a child by an individual associated with the relevant organisation while the child is under the care, supervision or authority of the relevant organisation.” An individual associated with a relevant organisation includes a minister of religion, a religious leader, an officer or a member of the personnel of the religious organisation.3

What does this mean for employers?

While common law and statutory duties of care remain, the High Court has made it clear that organisations will not be vicariously liable for the actions of their independent contractors or volunteers.

Although Bird v DP will the ability of victim survivors to obtain compensation for abuse perpetuated by people who were not employees through vicarious liability, individuals may still be liable for civil and criminal offences for failing to report child abuse.

It is unclear whether the decision will prompt calls for legislative change regarding the expansion of vicarious liability to include volunteers and independent contractors.4

How we can help?

Our Workplace Relations team can assist with managing risks associated with engaging and managing your workforce, including volunteers and other types of relationships. Our Safeguarding team can help organisations design and implement frameworks to prevent and respond to child abuse, and train your people on preventing and responding to child abuse and harm.

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Please contact us if you would like further information on how we can assist.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to your organisation.

  1. The Majority cited Cox v Minister of Justice (Where a prison service was vicariously liable for injuries caused to a prison catering manager by the negligence of a prisoner) and Armes v Nottinghamshire County Council (where a local council was vicariously liable for physical and sexual abuse allegedly carried out by foster parents) as examples of where the principle may have been overextended. ↩︎
  2. Bird v DP (a pseudonym) [2024] HCA 41 66. ↩︎
  3. Wrongs Act 1958 (Vic), ss 90(1)(b), 91(2). ↩︎
  4. The Civil Liability Act 2002 (NSW) has expanded the definition of ‘employee’ for the purposes of statutory vicarious liability under that Act. ↩︎

A long-awaited measure to allow superannuation members drawing legacy pensions to exit these more restrictive income streams has become law.

On 7 December 2024, Treasury Laws Amendment (Legacy Retirement Product Commutations and Reserves) Regulations 2024 came into effect.

After announcing these measures in in the 2021-22 Budget, practitioners, advisors and clients alike have been waiting on Government to enact the ‘amnesty’ procedure to ‘get out’ of these historical non-commutable income streams.

These Regulations now allow superannuation fund members, who have otherwise non-commutable pensions a five-year period in which they may fully commute that pension into accumulation phase within a self managed superannuation fund (SMSF). 

Such pensions include:

  • lifetime defined benefit pensions
  • life-expectancy defined benefit pensions
  • market-linked pensions (which are widely referred to as ‘legacy pensions’ in the SMSF sector).

Prior to the introduction of the new regulations, if a member with a legacy pension sought to restructure their restrictive pension accounts, the result would often leave an unallocated reserve in the SMSF, which could not be allocated to the member without being assessed against the members contributions caps.

This five-year window will permit members to have more flexible access to their superannuation benefits, allowing them to retain funds in accumulation phase, commence an account-based pension, or withdraw as a lump sum (subject to the rules of their fund). Importantly, the flexible access applies only to living members, and not reserves created as a result of the death of a legacy pensioner.

Whether a member chooses to obtain the benefit of the regulations or retain their legacy pension is a decision that should be carefully considered with advice from a licenced financial advisor. These changes (if the five-year window is utilised) may mean that a change to the strategy of death benefits as part of an SMSF member’s estate plan needs to be considered.

How we can help

For expert advice or guidance regarding Estate Planning and self managed superannuation funds, please do not hesitate to contact us.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

As the threat of bushfires continues to rise in Australia, especially during the warmer months, it is crucial for schools to implement robust bushfire preparedness strategies. The Victorian Registration and Qualifications Authority (VRQA) has released comprehensive Guidelines for schools on how to become bushfire-ready in accordance with new bushfire preparedness guidelines, which come into effect on 1 January 2025. While existing schools have until 1 July 2025 to comply with the updated Guidelines, it is never too early to review and update your bushfire preparedness strategies.

This article will explore the key elements of the VRQA’s updated guidelines, emphasising the importance of proactive measures in safeguarding students and staff.

Understanding the bushfire risk

Victoria’s unique climate and geographical features make it particularly susceptible to bushfires. Schools located in or near bushfire-prone areas face heightened risks, which can endanger lives and homes; and disrupt all aspects of life, not least educational activities.

Understanding the risks associated with bushfire season is the first step in effective preparation. The VRQA encourages schools to assess their vulnerability by reviewing local bushfire risk maps and historical data.

Developing an Emergency Management Plan

A well-structured Emergency Management Plan (EMP) is at the heart of a school’s bushfire preparedness strategy. All schools are required to have EMPs in place in relation to bushfire risks. Even inner-city schools go on excursions in the bush occasionally and as such, must be prepared to respond appropriately to the bushfire risk.

Schools that are located in high-risk areas (and are as such listed on the Bushfire-at-Risk Register (BAAR)) are subject to additional requirements; such as increased planning and communication obligations, and undertaking consultation with local fire authorities on their bushfire preparedness. If your school is located in or near a bushfire-prone area, you should ensure school leadership is aware of and compliant with these requirements. 

The VRQA outlines essential components that should be included in an EMP:

  • Risk assessment: Identify potential hazards, such as nearby bushland or unmaintained areas, and assess the likelihood and potential impact of bushfires.
  • Emergency procedures: Establish clear protocols for staff and students in the event of a bushfire. This includes evacuation routes, communication plans and designated assembly points. The new Guidelines include clarification about the requirements of on-site shelter facilities for schools listed on the BAAR.
  • Roles and responsibilities: Clearly define the roles of staff members during a bushfire emergency. Assign responsibilities for communication, student supervision and first aid.
  • Regular training and drills: Conduct regular training sessions and evacuation drills to ensure that all staff and students are familiar with the procedures outlined in the Bushfire Management Plan.

Communication strategies during a bushfire emergency

Effective communication is vital during a bushfire emergency. Schools should develop a communication plan that includes:

  • Emergency contacts: Maintain an updated list of emergency contacts, including local fire services, emergency services and school leadership.
  • Parental communication: Inform parents about the school’s bushfire policies and procedures. Ensure they know how to receive updates and instructions during an emergency.
  • Community engagement: Engage with local emergency services and the community to stay informed about bushfire risks and response strategies. Establishing relationships can lead to better support during crises.

Infrastructure and environment management

Maintaining the school environment can significantly reduce bushfire risk. The VRQA suggests several strategies:

  • Clearing vegetation: Regularly clear dry leaves, branches and other flammable materials from around school buildings.
  • Creating defensible spaces: Establish defensible zones around school premises by maintaining low vegetation and creating barriers to slow down the spread of fire.
  • Infrastructure resilience: Ensure that buildings are designed or retrofitted to withstand fire. This can include using non-combustible materials and installing fire-resistant windows and doors.

Engaging students and staff

Creating a bushfire-ready culture within the school community is essential. Involve students and staff in bushfire preparedness initiatives through:

  • Education programs: Implement educational programs that teach students about bushfire safety, the environment and emergency response.
  • Student leadership: Encourage student involvement in bushfire planning committees, allowing them to contribute ideas and foster a sense of responsibility.
  • Community projects: Engage in community projects focused on bushfire awareness and preparedness, helping students understand the broader implications of bushfire risks.

Review and continuous improvement

Bushfire preparedness is not a one-time effort; it requires ongoing evaluation and improvement. The VRQA advises schools to:

  • Regularly review plans: Revisit and update the Bushfire Management Plan annually or after significant incidents to incorporate lessons learned.
  • Gather feedback: Solicit feedback from staff, students and parents on the effectiveness of bushfire procedures and training sessions.
  • Stay informed: Keep up-to-date with changes in bushfire risk assessments, regulations and best practices for bushfire preparedness.

Conclusion

Preparing for bushfires is a shared responsibility that involves the entire school community. By following the VRQA’s guidelines, schools can develop comprehensive EMPs that engage students and staff, and ensure continuous improvement in their preparedness efforts.

With proactive measures in place, schools can significantly reduce the risks associated with bushfires, ultimately ensuring the safety and well-being of students and staff. As bushfire seasons become more frequent and intense, it is imperative that schools take action now to be bushfire-ready.

How we can help

Our specialist Education Law team is here to assist you to assess your school’s compliance with the existing and updated VRQA bushfire preparedness Guidelines. We can help you develop your EMP, and ensure that it meets all the requirements set out by the VRQA.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Our article Transgender protections in the spotlight: What it means for your organisation discussed the implications and significance of Roxanne Tickle v Giggle for Girls on clarifying the protections under Sex Discrimination Act 1984 (Cth) (Act). The Federal Court has now handed down its decision which confirms that transgender people are protected under the Act.

Background of the case

Roxanne Tickle is a transgender woman who was removed from the mobile app, Giggle for Girls (Giggle) which is an online communication app for women that does not allow men to join or use the app. The CEO, Sally Grover, removed Ms Tickle’s account on the basis that Ms Grover considered her to be male upon review of her photograph.

Ms Tickle lodged a discrimination claim against Giggle with the Federal Court on the basis of her gender identity.

In defending the claim, Giggle argued that:

  • Ms Tickle was discriminated on the basis of her sex which they considered to be male as her ‘sex’ could not be changed; and
  • Giggle was a ‘special measure’ to promote the substantive of women, which is an accepted form of lawful discrimination.

Federal Court Decision

The Federal Court found that Giggle engaged in indirect discrimination towards Ms Tickle on the basis of her gender identity. Under the Act, indirect discrimination occurs when a person imposes or a requirement, condition or practice which has or is likely to have the effect of disadvantaging persons who have the same identity as the aggrieved person (in this case, the same gender identity as Ms Tickle). It was found that Giggle imposed a condition that users were required to appear as a cisgendered female in order to be permitted access the app. This requirement had the effect of disadvantaging transgender women in comparison to cisgendered women.

The discrimination was not considered to be direct discrimination as direct discrimination required Ms Grover to have actual knowledge that Ms Tickle was a transgender woman and there was no evidence of this.

The Federal Court did not accept Giggle’s argument that there was discrimination on the basis of sex. The Court confirmed that ‘sex’ takes a broader ordinary meaning as opposed to a biological concept referring to whether a person at birth has male or female physical traits. It accepted that a person’s sex could change and refers to a person being male, female or another non-binary status. The definition of ‘sex’ takes into account a range of factors including biological and physical characteristics, legal recognition and how they present themselves and are recognised socially. The Court recognised Ms Tickle’s sex as being female and therefore it could not be that she was discriminated on the basis of her sex as argued by Giggle.

It was also not accepted that the special measure exception applied. As Giggle argued that its purpose was to achieve substantive equality between men and women, the exception would only apply if it was discriminating against a male on the basis sex. It did not apply in the present situation as Ms Tickle is a transgendered woman.

Additionally, the Federal Court rejected Giggle’s argument that relevant provisions of the Act were unconstitutional.

The Federal Court ordered that Giggle pay Ms Tickle compensation in the sum of $10,000 and pay her costs. Giggle is currently seeking to appeal the decision.

How we can help

The decision confirms that the Act protects transgender people on the basis of their gender identity and provides clarification as to the definition of ‘sex’ in the Act. The case highlights that organisations should carefully consider whether their practices and conduct in relation to single sex spaces and services are lawful and reasonable, and whether an exception, exemption or special measure could apply.  

Our safeguarding and discrimination team can assist organisations to understand how state and federal anti-discrimination laws apply to their operations, and the extent to which exceptions or exemptions may apply.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Don’t let your end of year celebrations snowball into misconduct. Keep the balance of professionalism and sensibility during your end of year celebrations.

As the festive season approaches, many organisations and businesses are preparing for their end of year celebrations and festive season parties. While this is undoubtedly a time to celebrate the ‘wins’ of the year, individual and collective achievements, and also unwind and ‘let your hair down’, employers need to be mindful of the ongoing challenges and risks these parties present. Employers must be vigilant in both anticipating and mitigating against those challenges, and reminding employees of their ongoing obligations to ensure a safe and disaster-free celebration.

Key risks to be aware of, and mitigate against

Employers should be particularly mindful of issues relating to conduct, harassment, and safety when it comes to end of year celebrations. Often, these celebrations involve the presence of alcohol that may not otherwise be permitted in the work environment. This informal environment presents a sense of relaxation which is much needed, but may also mean employees let their guard down and engage in conduct that they would not normally engage in at the office or in a work or professional setting. While these moments can often be embarrassing, there can also be legal consequences.

The circumstances in which “out of hours” misconduct may constitute a valid reason for dismissal were set out in Rose v Telstra. This includes:

  • conduct that is likely to cause serious damage to the relationship between the employer and employee;
  • conduct that damages the employer’s interests; and
  • conduct that is incompatible with the employee’s duties.

Some of the key risks that employers should be thinking about include:

  1. Alcohol: Alcohol is commonly permitted to be consumed at end of year parties and other work-related functions. A small amount of alcohol can help conversation flow, and relaxes everyone’s moods.. However, intoxication can lead to poor decision-making and the risk of inappropriate behaviour. This may include offensive comments, inappropriate physical contact, and workplace harassment. Banning all alcohol may not be the solution, but employers should remind employees to drink responsibly, know their limits, and that end of year parties (and even after-parties or kick-ons) are still subject to workplace policies on acceptable behaviour and Occupational Health and Safety (OHS)  obligations. Further, it should be clear in any applicable policies (and even communications to employees about the event) that disciplinary action may be taken where behaviour falls short of the expectations set out by an employer.
  2. Harassment and discrimination: The casual environment of parties can often blur the lines of professional conduct and communication. Jokes, comments, and behaviour that may seem harmless in the moment, can still be interpreted as harassment, discrimination, and bullying.  
  3. Employee safety: Even where parties and functions are hosted off-site, employers must be mindful of employees’ safety and take reasonable steps to identify, assess and control OHS risks. Driving under the influence of alcohol or accidents caused by employees leaving the event after consuming alcohol can expose employers to liability if they have not taken the proper steps to ensure safe transportation or have not enforced policies related to impaired driving. Likewise, where alcohol is involved, spillages and breakages are more likely to occur, leading to slips and cuts. As these parties and functions are still part of the work environment, employees may also be eligible to make a worker’s compensation claim where they suffer an injury while at one.
  4. Damage to reputation: A work holiday party, if not handled properly, can result in negative publicity. In the age of social media, a single inappropriate action or controversial comment can quickly spread, damaging the organisation’s reputation and potentially leading to long-term consequences, particularly where the incident is not managed appropriately by the employer or ‘swept under the rug’. 

What employers can do to discharge their obligations and mitigate against the risks posed by Christmas parties

To ensure end of year parties and functions remain celebratory events, and minimise the risk of misconduct, here are a few tips to manage your events responsibly:

  1. Remind employees of workplace policies prior to the party: it’s important to remind employees that workplace codes of conduct and policies regarding harassment, alcohol consumption, and general behavior still apply during the holiday event (and even to after-parties). Make it clear that inappropriate behavior, even in a social setting, will not be tolerated and breaches or unacceptable behaviour may lead to disciplinary action.
  2. Set clear expectations: communicate the expectations for behaviour at the event. Employers should outline what constitutes appropriate behavior and provide examples of actions that could lead to disciplinary measures (real life cases always help). This includes the consumption of alcohol in moderation, respectful interactions with colleagues, and avoiding behaviors that could be construed as harassment or discrimination.
  3. Control alcohol consumption: To avoid excessive drinking, employers should consider offering drink tickets, limiting the number of alcoholic beverages per person, or offering a selection of non-alcoholic options. Encouraging moderation helps to maintain a respectful and safe atmosphere.
  4. Beware of social media: It may be a good idea to direct employees not to post photos from the event on social media during the function. Often, an impromptu snap posted in real time can later lead to reputational damage for the employer, and also sexual harassment claims. Encourage employees to seek consent from others in the picture before posting, and query the appropriateness of certain photos.
  5. Provide safe transportation options: If alcohol will be served at the party, employers should ensure that employees have access to safe transportation options. This can include arranging for taxis or rideshare services, offering designated drivers, or even providing accommodation for employees who may be too intoxicated to drive home.
  6. Lead by example: Leaders and managers should set the tone by modeling the behaviour they expect from others. By demonstrating professionalism and respect, they help to reinforce a positive atmosphere and set expectations for the rest of the team.
  7. Review your insurance policies: Employers should review their insurance coverage to ensure they are adequately protected against potential liabilities related to the event. This may include reviewing alcohol liability coverage, worker’s compensation policies, and ensuring that any incidents that occur during the event are covered.
  8. Manage incidents quickly and sensitively: If in the unfortunate, but not uncommon, event that something does go wrong, employers should treat any complaints raised seriously and confidentially, and follow its processes and procedures around investigating and resolving the complaint. 

How we can help

Our Workplace Relations team are here to specialist advice and assistance to set up best practice policy and procedure frameworks as a proactive approach to holding and managing work-related functions, and help employers deal with incidents after they occur.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Case law has consistently demonstrated the importance of procedural fairness when conducting workplace investigations. Workplace investigations which are not carried out in a robust and thorough way can result in headaches for employers, irrespective of their best intentions to address inappropriate behaviour, or cultural or systemic issues within their organisation. Where misconduct is reportable to a regulator such as the Victorian Institute of Teaching or Commission for Children and Young People, organisations may face additional scrutiny of investigation findings and whether the process was procedurally fair. In this article we highlight some key cases that demonstrate the pitfalls for employers when investigations are not carried out with using a robust, objective and thorough investigation process.

Robert Crook v CITIC Pacific Mining [2023] FWC 2446

Mr Crook alleged he was unfairly dismissed by CITIC Pacific Mining Management Pty Ltd (CITIC) after one of his female colleagues made a complaint alleging that during an end of shift bus ride, Mr Crook initiated an explicit conversation with other employees in the area where she was sitting. She further alleged that:

  • Mr Crook exposed her to explicit images on a mobile phone while passing it to another male colleague; and
  • on a separate occasion, Mr Crook stared at her in a ‘lewd manner’ and remarked to other employees, ‘Cooore look at that’,
    (together referred to as ‘the Allegations’).

Mr Crook was asked to provide an immediate written response in an initial meeting. Following an investigation and two further meetings, his employment was terminated.

The Fair Work Commission (FWC) found that the process followed by the employer was “deeply flawed”, “deficient” and “lacked rigour”, and therefore the employer did not have a valid reason for termination. In reaching this finding, Deputy President O’Keefe noted the following:

  • the complainant and a witness were interviewed together, which had the potential to taint the evidence;
  • the Allegations put to Mr Crook were somewhat imprecise;
  • witnesses named by Mr Crook were not interviewed;
  • CITIC did not seek to gather and review data which may have assisted with its investigation, including swipe card data, and relied heavily on the complainant’s account;
  • Mr Crook sought to provide evidence, some of which supported his position and none of which corroborated the Allegations, however CITIC said he was not allowed to provide it;
  • there was over three months between the date of the alleged incident and the investigation; and
  • the evidence available to CITIC did not support the findings upon which the decision to terminate Mr Crook’s employment was made.

The FWC found Mr Crook was unfairly dismissed and ordered reinstatement, continuity of service and restoration of lost pay.

Kumar v Opal Packaging Australia Pty Ltd [2023] FWC 2090

Mr Kumar worked as a machine operator for Opal Packaging (Opal) for almost 30 years. Opal alleged that Mr Kumar failed to follow the proper ‘lock out tag out’ (LOTO) procedure when operating conveyor belt machinery, and that a failure to comply with this procedure could have had significant safety implications, such as injuring or even killing Mr Kumar or other workers.

Opal conducted an internal investigation into the alleged conduct. Following a week-long investigation conducted by an internal workplace specialist, Opal concluded that Mr Kumar had not complied with the LOTO procedure and terminated his employment on the basis of serious misconduct. Mr Kumar made an unfair dismissal application to the FWC.

The FWC found that Opal did not have a valid reason for Mr Kumar’s dismissal and identified a number of deficiencies with the investigation process. Those deficiencies included that the investigator:

  • relied on unreliable records including witness interviews that were incorrectly recorded;
  • posed leading questions that presupposed that Mr Kumar had engaged in wrongdoing and/or assumed that a breach had already taken place;
  • relied on an apology made by Mr Kumar to his manager as an admission of wrongdoing without further context;
  • failed to provide Mr Kumar with relevant material forming the basis for his decision before making findings, which was a requirement of the process set out in the applicable enterprise bargaining agreement;
  • relied on several previous breaches of the LOTO procedure to suggest a pattern of behaviour that increased the likelihood of Mr Kumar engaging in the breach that was the subject of the investigation, without providing Mr Kumar an opportunity to contextualise the previous breaches. These breaches were found to have been unlikely to have occurred, which highlighted the risks of relying on tendency evidence as part of an investigation; and
  • made errors in relation to the date of the alleged LOTO procedure breach which the FWC found demonstrated a lack of attention to detail given the seriousness of the allegation.

These deficiencies undermined the reliability of the investigator’s report and findings. As such, the FWC found Mr Kumar’s dismissal was unfair and ordered reinstatement and restoration of lost pay.

Mark Andrawos v MyBudget Pty Ltd [2018] FWC

Mr Andrawos was employed by MyBudget as a Personal Budget Specialist. Over a period of time, Mr Andrawos struck up a friendship outside of work with a man named James, who in December 2017 received a large inheritance. Mr Andrawos became concerned about James’ spending. He encouraged James to sign up for a MyBudget account, and subsequently advised him to transfer the remaining $90,000 of his inheritance into a MyBudget account with him as a co-signatory, so James could not access or spend that money on his own.

MyBudget undertook an investigation following a complaint by James’ mother. Mr Andrawos’ employment was subsequently terminated for serious misconduct. Mr Andrawos made an unfair dismissal application to the FWC.

The FWC found breaches of the Code of Conduct and Mr Andrawos’ employment duties were valid reasons for termination. However, the Commission found there was evidence that MyBudget had already decided to terminate Mr Andrawos’ employment before the investigation had taken place, and Mr Andrawos was given an opportunity to respond in form and not in substance. That evidence included the following:

  • at the time Mr Andrawos was suspended pending investigation into the complaint, the Human Resources Manager had formed the view that the conduct was likely to be serious and wilful misconduct;
  • Mr Andrawos was prevented from providing information about his relationship with James and his mother before he was suspended;
  • MyBudget initially gave Mr Andrawos only 24 hours to respond to the allegations, which indicated it had only a ‘limited interest’ in his explanation;
  • despite Mr Andrawos requesting them, MyBudget failed to provide him with copies of telephone recordings and the transcriptions of those recordings that it relied on as evidence of misconduct. While it may not always be appropriate to share recordings due to obligations related to privacy and surveillance, here, the FWC found that the recordings provided evidence of breach but also evidence of mitigation, and MyBudget’s failure to make them available was evidence of the employer’s propensity to focus on breach at the expense of explanation and mitigation;
  • the investigator was not made aware of Mr Andrawos’ claim that James’ mother had made accusatory and threatening statements to him the night before she made her complaint;
  • MyBudget did not seek out further information after it interviewed Mr Andrawos, even though he provided information that was not known to it at the time, which the Commission described as a “poor decision”; and
  • at no stage did MyBudget speak to James, which the FWC criticised as “especially unfair”.

Having found substantial mitigating factors and that the failure to provide procedural fairness had a ‘material impact’ on the decision-making process, the FWC ultimately concluded that the dismissal was harsh, even if it was not unjust or unreasonable.

Key Takeaways

These cases show why it is critical that employers undertake a robust and thorough investigation into alleged misconduct. This is particularly relevant where the investigation findings may lead to disciplinary action up to dismissal.

When considering potential misconduct, employers should take care to:

  • gather all relevant available evidence;
  • consider that evidence with an open mind;
  • avoid making pre-determined decisions until the investigation is complete and findings have been made;
  • ensure all relevant evidence is provided to the respondent in a timely manner having regard to relevant policies and industrial instruments (unless there is a lawful and reasonable excuse for not providing that information e.g. due to breaches of privacy or surveillance laws);
  • ensure that investigators have the appropriate skills or qualifications to consider the relevance and weight of evidence, including tendency evidence.

How we can help

Our Workplace Relations and Safeguarding teams can assist with managing workplace and safeguarding investigations into allegations of potential misconduct in a procedurally fair manner with minimal risk.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.

Is your not-for-profit (NFP) contemplating a merger? This is part three of a five-part article series that will offer some practical guidance to your board or merger advisory committee. Subscribe to receive the remaining articles in the series.

While each not-for-profit (NFP) merger is unique, most NFP mergers will tend to follow some, or all of the steps set out below. This article provides an overview of those steps, which help NFPs navigate the complexities of a merger whilst ensuring purpose alignment, legal compliance and operational continuity throughout the process.

1. Confirm alignment

Ensuring purpose and cultural alignment is a crucial step for parties considering a merger.

  • Purpose: As a preliminary step, NFPs and registered charities proposing to merge must consider whether there is purpose alignment. An organisation’s purpose is principally ascertained from the purpose (sometimes referred to as “objects”) set out in its governing document. Registered charities must be able to demonstrate that they are meeting the requirements of Governance Standard 1 – which includes working towards their charitable purpose. Similarly, NFP’s that are not registered charities must act within the scope of their purposes.

If there is insufficient purpose alignment, merger types that maintain separate incorporation of the merging parties may be appropriate (such as one entity becoming a subsidiary of the other entity). Purpose alignment will be more important if the merger is likely to involve a significant transfer of assets from one entity to another (such as where one entity transfers its assets, operations and employees to the other before closing).

Additionally, NFPs that are endorsed as a Deductible Gift Recipient (DGRs) must ensure they are acting in a manner that is consistent with the conditions of their endorsement. For example, if a DGR is wound up in the course of a merger, it is prohibited from transferring its assets to another entity that is not endorsed as a DGR.

  • Culture: A merger can look great on paper but fail due to lack of cultural alignment. Culture encompasses an organisation’s values, management practices, and operational norms. Parties that propose to merge should evaluate how each NFP’s mission and vision are reflected in the NFP’s daily practices and decision-making processes. The assessment of cultural alignment includes both a structured and an informal element. The structured element is discrete and involves obtaining and reviewing formal data such as staff surveys, retention rates, exit interviews and net promoter scores. The informal element is continuous and will be ongoing until any merger agreement becomes unconditional. This informal assessment includes observations (both at board and management level) gleaned from engagement with the prospective merger partner through the merger process – Is there transparency? How is conflict resolved? How are challenges addressed? Are behaviours consistent with the organisation’s espoused values?

2. Identify the appropriate merger type

The next step is to consider and agree on an appropriate merger type. The appropriate merger type will depend on factors including: the current legal structure of each party; the nature and extent of each party’s assets, operations and employees; the role each party will have post merger; and the appropriate governance framework for the merged entity. More information on common merger types can be found in part two of our article series.

Depending on the preferred merger type, parties may need to make preparatory changes including: changes to governing documents, changes to director appointments and changes to membership.

3. Set clear expectations

Before time, resources and energy are invested, it is important for the parties to articulate their expectations for the merger. This helps to guide critical decisions during the merger process, as well as informing the final assessment of whether the merger will be beneficial and should proceed. This process involves:

  • defining non-negotiables upfront. This might include continuity of certain services, continuing to service particular client groups, requirements around geographic reach, branding changes, how redundancies will be managed and who will hold key leadership roles in the new entity.
  • developing shared merger principles that guide critical decisions aligned with the collective vision and goals.

These expectations should be documented in a letter of intent or memorandum of understanding.

4. Conduct due diligence

Thorough due diligence is essential to mitigate risks and ensure informed decision-making by the board of each NFP. While the primary role of due diligence is to assist the boards to determine whether or not the merger should proceed, it also has a secondary role in identifying issues that may need to be prioritised and addressed as soon as practicable following the merger. The due diligence process should include:

  • defining the scope and objectives of the due diligence process (this is dependent on the size and complexity of each organisation and the proposed merger type).
  • coordinating efforts among the board, executive team, legal advisors (particularly those with expertise in dealing with NFPs), accountants, and other consultants to efficiently review the documents and information disclosed.
  • assessing potential risks, including legal, operational, strategic, and reputational risks, to evaluate the feasibility and benefits of the merger. These risks should be assessed in the light of each organisation’s risk appetite and objectives for the merger.

More information on the due diligence process will be in part four of our article series.

5. Document the merger

Formalise the merger agreement once due diligence is complete and all conditions are met:

  • include conditions precedent that must be fulfilled before the merger can proceed. These could include: the establishment of a merger advisory committee; obtaining regulatory approvals; member support; and obtaining agreement from key funders to the assignment of contracts.
  • define completion obligations that must be carried out at completion to give effect to the merger. These could include: delivery of documents to demonstrate that conditions precedent have been satisfied or waived; necessary board or member resolutions taking effect; asset transfers, and regulatory filings.
  • allow for a trade-out period post-completion to manage any remaining contractual obligations or transitions smoothly.

A comprehensive completion checklist that includes provision for conditions precedent, completion obligations and post completion obligations is invaluable. The checklist can provide a structure for regular meetings with the other NFP (and any steering group) until completion to ensure that everything remains on track for a successful merger.

How we can help

The Charity and Not-for-profit Law team at Moores regularly assists NFP and charitable clients through all stages of the merger process, from preliminary assessment, to due diligence through to effecting the merger.

Contact us

Please contact us for more detailed and tailored help.

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Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.