ASHM embraces a risk- based approach to managing compliance, ensuring adequate controls are implemented to combat, detect, and report potential money laundering and financing terrorist activities.
As at August 2017 AUSTRAC and the Australian Charities and Not-for-profits Commission (ACNC) assess Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) risks affecting Australian NPOs as Medium (this assessment remains valid for this 2021 policy review.) This is primarily based on suspicious matter reporting, the number of investigations into predicate crimes involving NPOs, and anecdotal insights from sector representatives regarding levels of criminal exploitation.
The key threats facing the NPO sector are fraud and theft of resources. General factors that increase any NPO's vulnerability to money laundering or terrorism financing include:
- poor understanding of the risks of money laundering and terrorism financing
- poor due diligence on key personnel, volunteers, partners and beneficiaries
- inexperienced staff
- lack of formalised training and ongoing professional development
- poor record keeping
- weak internal controls
- poor transparency and accountability of the end-to-end funding cycle
- beneficiaries or operations in countries with poor AML/CTF regimes
- beneficiaries or operations in conflict or post-conflict regions
- beneficiaries or operations in dispersed ethnic communities in Australia, with strong links to high-risk countries (specific to terrorism financing only).
The purpose of the Policy is to confirm ASHM’s commitment to dealing with AML and CFT risk and to outline the key rules that underpin this commitment.
Money Laundering is the process of concealing the existence, illegal source or application of income from criminal activity and the subsequent disguising of that income to make it appear legitimate. Money laundering is just as serious as the underlying crimes that generate the money that is laundered.
Terrorism financing refers to activities that provides financing or financial support to individual terrorists or terrorist groups.
ASHM generally receives funding from government bodies, well known international agencies or companies with which it has previously done business.
Any money received from sources that do not fit this profile will be investigated in accordance with acknowledged ‘Know Your Customer’ procedures. Specifically, in such cases, checks will be performed against the Criminal Code list of terrorist organisations and the DFAT consolidated list of individuals and entities subject to targeted financial sanctions, as per the following:
(List updated 19 April 2021)
All checks against prohibited entity listing will be documented as part of ASHM’s due diligence checks for new contracts. Where relevant, partner organisations will also be informed of the requirement to perform similar checks.
ASHM will maintain strong controls over its expenditure, as documented in its Fraud Management and Segregation of Duties policies, to ensure it knows where funds are being dispersed and that payments related to approved activities are supported by a contract which has undergone due diligence processes.
Finance staff are trained on AML/CTF risks and threats to assist in identifying any unusual transactions.
Any unusual activities, receipts or payment requests which might indicate AML/CTF activity will be escalated immediately to ASHM CFOO and thence to relevant regulatory bodies for further investigation.
ASHM will adhere to any AML/CTF directives imposed on it by relevant regulators.
ASHM performs police checks on all new employees.
Whilst ASHM provides services in countries with poor AML/ CTF regimes, all staff are based in Australia and the supervision and management of all service contracts, as well as its banking and finance operations, are performed in Australia.
ASHM Board – Approved 17 June 2021
ASHM believes that all people should work in an environment free from bullying.
ASHM understands that workplace bullying is a threat to the health and wellbeing of its staff, volunteers, advisors, interns, consultants and Board members.
Accordingly, ASHM is committed to eliminating, so far as is reasonably practicable, all forms of workplace bullying by maintaining a culture of openness, support, and accountability.
This policy applies to all ASHM’s employees volunteers, advisors, interns, consultants and Board members unless otherwise specified.
The purpose of this document is to communicate that ASHM does not tolerate any form of workplace bullying and to set out the process which is to be followed should any instances of workplace bullying be reported.
Employee is defined as staff, volunteers, advisors, interns, consultants and Board Members.
This policy also relates to, but is not limited to the following types of communication:
- Electronic - such as email, skype, social media and text messages
“Bullying” is repeated and unreasonable behaviour directed towards a person or group of persons that creates a risk to health and safety. It includes behaviour that could be expected to intimidate, offend, degrade, humiliate, undermine or threaten.
“Repeated behaviour” refers to the persistent nature of the behaviour and can involve a range of behaviours over time.
“Unreasonable behaviour” is behaviour that a reasonable person, having considered the circumstances would see as unreasonable, including behaviour that is victimising, humiliating, intimidating or threatening.
Examples of behaviour, whether intentional or unintentional, that may be considered to be workplace bullying if they are repeated, unreasonable and create a risk to health and safety include but are not limited to:
- abusive, insulting or offensive language or comments
- unjustified criticism or complaints
- deliberately excluding someone from workplace activities
- withholding information that is vital for effective work performance
- setting unreasonable timelines or constantly changing deadlines
- setting tasks that are unreasonably below or beyond a person’s skill level
- denying access to information, supervision, consultation or resources to the detriment of the worker
- spreading misinformation or malicious rumours
- changing work arrangements such as rosters and leave to deliberately inconvenience a particular worker, or workers.
Workplace bullying can occur between workers (sideways), from managers to staff (downwards), or staff to supervisors/managers (upwards).
Reasonable management action is not considered to be workplace bullying if it is carried out lawfully and in a reasonable manner in the circumstances. Examples of reasonable management action include but are not limited to:
- setting reasonable performance goals, standards and deadlines
- deciding not to select a staff member for promotion where a reasonable process is followed
- informing a staff member about unsatisfactory work performance in an honest, fair and constructive way
- taking disciplinary action, including suspension or terminating employment.
Differences of opinion and disagreements are generally not considered to be workplace bullying.
Bullying that directly inflicts physical pain, harm, or humiliation amounts to assault and should be dealt with as a police matter (see below).
ASHM does not tolerate any form of workplace bullying.
This policy is not limited to the workplace or working hours and covers all work-related events which includes, but is not limited to – lunches, meetings, conferences, as well as Christmas parties. ASHM has a duty of care to provide a safe workplace, and ensure, so far as is reasonably practicable, that staff and other people are not exposed to health and safety risks.
ASHM accepts and acts on its duty of care. Any reported allegations of workplace bullying will be promptly, thoroughly, and fairly investigated.
Bullying complaints will be handled in a confidential and procedurally fair manner. Where confidentiality cannot be guaranteed this will be clearly communicated to the relevant parties.
All parties will be treated with respect.
The person against whom the allegation is made has the right to natural justice (the right to know what is alleged against them, the right to put their case in reply, and the right for any decision to be made by an impartial decision-maker).
ASHM Board – Approved 16 June 2020
ASHM's Child Protection Policy and Procedure reflects the principles and implementation of the Department of Foreign Affairs and Trade (DFAT) Child Protection Policy, January 2018 and Child Protection Guidance Note, February 2018.
ASHM’s Child Protection Policy and Procedure is consistent with the Department of Foreign Affairs and Trade Minimum Child Protection Standards (Appendix A DFAT Child Protection Policy, January 2018)
ASHM is committed to promoting and protecting the interest and safety of children. We have zero tolerance for child abuse.
This child protection policy applies to all ASHM personnel which includes:
- staff/volunteers/interns/contractors/visitors to projects/Society representatives
- ASHM partner’s downstream personnel
- Subcontractors engaged by ASHM to perform any part of ASHM project activities
The purpose of this policy is to:
- prevent any child abuse occurring within ASHM and its projects.
- work towards an organisational culture of child safety.
- ensure that all parties are aware of their responsibilities for identifying possible occasions for child abuse and for establishing controls and procedures for preventing such abuse and/or detecting such abuse when it occurs.
- provide guidance to ASHM personnel as to action that should be taken where they suspect any abuse within or outside of the organisation
- provide a clear statement to ASHM personnel forbidding any such abuse.
- provide assurance that any and all suspected abuse will be reported and fully investigated.
The purpose of this policy is to help eliminate the risk of anyone working for and with ASHM being involved in child abuse.
Child. For the purposes of this policy, a child is defined as any person under the age of 18.
Child abuse is defined as “All forms of physical or mental violence, injury or abuse, maltreatment or exploitation, including sexual abuse”.
Child Protection is the term used to describe the responsibilities and activities undertaken to prevent or stop children being abused or maltreated.
Physical abuse is the use of physical force against a child that results in harm to the child. Physically abusive behaviour includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning
Emotional abuse refers to a parent or caregiver’s inappropriate verbal or symbolic acts toward a child, or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Such acts have a high probability of damaging a child’s self-esteem or social competence.
Neglect is the failure by a parent or caregiver to provide a child (where they are in a position to do so) with the conditions that are culturally accepted as being essential for their physical and emotional development and wellbeing
Sexual abuse occurs when a child or young person is used by an older or bigger child, adolescent or adult for his or her own sexual stimulation or gratification - regardless of the age of majority or age of consent locally. These can be contact or non-contact acts and includes fondling genitals; masturbation; oral sex; vaginal or anal penetration by a penis, finger or any other object; fondling breasts; voyeurism; exhibitionism; and exposing the child to, or involving the child in, pornography.
Child pornography is defined as “any representation, by whatever means, of a child engaged in real or simulated explicit sexual activities or any representation of the sexual parts of a child for primarily sexual purposes”.
Exploitation - Commercial or other exploitation of a child refers to the use of the child in work or other activities for the benefit of others that are to the detriment of the child’s physical and mental health, education, or moral and social-emotional development. It includes, but is not limited to:
- child labour
- child trafficking
- child sexual exploitation
- committing or coercing another person to commit an act or acts of abuse against a child
- possessing, controlling, producing, distributing, obtaining or transmitting child exploitation material
- committing or coercing another person to commit an act or acts of grooming or online grooming
- using a minor for profit, labour, sexual gratification, or some other personal or financial advantage
’ASHM personnel’ includes all staff, Board, volunteers, interns, contractors, committee members, visitors to projects, society representatives, ASHM partners’ downstream personnel and subcontractors engaged by ASHM to perform any part of ASHM project activities.
- Zero tolerance: ASHM has zero tolerance for child abuse. Everyone working for ASHM is responsible for the care and protection of the children within our care and reporting information about suspected child abuse.
- Best interests of child: ASHM is committed to upholding the rights of the child and Australia’s obligations under United Nations Convention on the Rights of the Child. In all actions concerning children, the best interests of the child shall be a primary consideration.
- Natural justice: All investigations concerning suspicions and allegations of child abuse will be conducted according to the rules of natural justice. In line with this principle, ASHM will ensure that personnel must be fully aware of their responsibilities to protect children and how to report concerns or allegations about child exploitation and abuse.
- Procedural fairness: ASHM will apply procedural fairness when making decisions that affect a person’s rights or interests. ASHM’s partners are expected to adhere to this principle when responding to concerns or allegations of child exploitation and abuse.
- Risk assessment approach: Child safety risk assessment is a part of ASHM’s overall risk assessment for all projects and partnerships. This assessment will identify risks, and document steps being taken to reduce or remove those risks.
- Shared responsibility for child protection: ASHM requires the commitment, support and cooperation of partner organisations and individuals who help to deliver programs to effectively manage risks to children in all of our projects and activities.
General policy statements
ASHM is always committed to promoting and protecting the best interests of children involved in its programs.
ASHM is committed to preventing a person from working with children if they pose an unacceptable risk to children.
ASHM is committed to immediate reporting of child exploitation or abuse suspicions or allegations to DFAT where DFAT funds are involved.
All children, regardless of their gender, race, religious beliefs, age, disability, sexual orientation, or family or social background, have equal rights to protection from abuse.
ASHM has zero tolerance for child abuse. Everyone working for ASHM is responsible for the care and protection of the children within our care and reporting information about suspected child abuse.
Child protection is a shared responsibility between the ASHM, all employees, workers, contractors, associates, and members of the ASHM community.
Wherever necessary, ASHM will consider the opinions of children and use their opinions to develop child protection policies.
ASHM supports and respects all children, staff and volunteers. ASHM is committed to the cultural safety of Aboriginal and Torres Strait Islander children, and those from culturally and/or linguistically diverse backgrounds, and to providing a safe environment for children living with a disability.
ASHM is committed to the protection of children from harm, abuse and exploitation. Children have a right to survival, development, protection and participation as stated in the United Nations Convention on the Rights of the Child.
Child Protection Code of Conduct
ASHM has developed a Child Protection Code of Conduct to provide clear guidance to personnel and associates about ways to minimise risk to children and make clear the standards of behaviour and practice required of them at all times when they are in contact with children. These behaviours are not intended to interfere with normal family interactions.
All ASHM personnel are required to read and sign the Child Protection Code of Conduct, which is located at the end of this policy.
It is mandatory for all those under the Scope of the ASHM Child Protection Policy to confidentially report any witnessed, suspected or alleged incidents of child abuse or any breach of the Child Protection Policy or Child Protection Code of Conduct using the process outlined in the flowchart over-page.
Children and community members with whom ASHMs works will be provided with information about how to report any child protection concerns about ASHM personnel members and associates.
If it is alleged that a member of staff, contractor, visitor to project or a volunteer may have committed an offence or have breached the organisation’s policies or its Code of Conduct the person concerned may be stood down (with pay, where applicable) while an investigation is conducted.
If the investigation concludes that on the balance of probabilities an offence (or a breach of the organisation’s policies or Code of Conduct) has occurred then disciplinary action may follow, up to and including dismissal or cessation of involvement with the organisation. The findings of the investigation will also be reported to any external body as required.
ASHM Board – Approved May 2022
The ethical climate of an organisation is an essential element in establishing its credibility and furthering its mission. An organisational culture that takes ethical considerations into account at every point is supported and expressed through an organisation’s code of conduct; ethical principles determining workplace behaviour must arise from consultation with and responsiveness to the organisation’s members, clients, employees, volunteers, and stakeholders.
This policy is designed to provide guidelines for procedures that will allow ASHM’s staff and representatives to adopt a professional code of conduct and workplace behaviour which protects and reflects ASHM’s credibility and ethical principles and professional conduct.
ASHM staff and representatives means:
- people who are employed by ASHM,
- contractors (including mentors and speakers) working for ASHM, and
- people undertaking or delivering training or education managed by ASHM, who will be referred to as ‘staff‘ throughout the Code.
This Code of Conduct seeks to guard our standards of workplace behaviour. It specifies the values and expectations of professional conduct of all staff.
ASHM is committed to the principles of the Ottawa Charter for Health Promotion and Jakarta Declaration on Leading Health Promotion into the 21st Century, as well as the highest standards of ethical conduct as practised by the medical, scientific and health care professions.
ASHM is committed to continual quality improvement and working in ways that:
- support collaboration, partnership and cooperation,
- reflect best practice in management and service delivery,
- are informed by the latest scientific, clinical, health and policy research,
- maintain transparency, industrial fairness and democratic decision-making,
- strengthen ties with infected and affected populations,
- respect cultural differences and diversity,
- respect privacy and confidentiality, and
- redress social inequities.
ASHM is a signatory to the Code of Conduct for Australian aid and development agencies, which is administered by the Australian Council for International Development (ACFID).
ASHM’s Code of Conduct is described in the following Policies and Procedures:
- Conflict of Interest Policy
General statement of this policy: Conflicts of interest must be disclosed in a timely manner by an ASHM board member, employee, committee member or contractor (or their partner, a family member or a related business interest) . Conflicts of interest can be actual, potential or perceived. ASHM will maintain conflicts of interest register.
- Ethical Fundraising Policy
General statement of this policy: ASHM’s guiding fundraising principle is that we will only use techniques that we would be happy to be used on ourselves.
This policy set the standards for all ASHM fundraising activities, basis of acceptance or rejection of funds, as well as the standards of the fundraising materials.
- Environmental Management Policy
General statement of this policy: ASHM considers the ‘do no harm’ to the environment principle. ASHM recognises the potential impacts of organisational and office activities and wherever possible, seeks to minimise the demands/impacts from such activities. ASHM is committed to monitor and evaluate the risks that derivate from its practices and projects.
- Gifts and Benefits Policy
General statement of this policy: ASHM does not see gifts as warranted or expected in return for the conduct of its work. ASHM does not encourage or expect the giving of gifts. Token gifts and invitations may be accepted depending on the circumstance.
- Anti-Bullying Policy
General statement of this policy: ASHM has zero tolerance to bullying. ASHM accepts and acts on its duty of care. Any reported allegations of workplace bullying will be promptly, thoroughly, and fairly investigated.
- Fraud and Corruption Management Policy
General statement of this policy: ASHM will not tolerate fraud in any aspect of its operations. ASHM has the systems in place that protects the integrity, security and reputation of the organisation, acting proactively against risk, minimising losses and structuring the appropriate pathways of investigation, when required. Where there is evidence or the possibility of fraudulent or corrupt activities, ASHM will deal with them in a firm and controlled manner.
- Anti-Money Laundering and Counter Terrorism Financing policy
General statement of this policy: Any money received from sources that do not fit the profile established in the policy will be investigated in accordance with acknowledged ‘Know Your Customer’ procedures. Specifically, in such cases, checks will be performed against the Criminal Code list of terrorist organisations and the DFAT consolidated list of individuals and entities subject to targeted financial sanctions.
- Misconduct Policy
General statement of this policy: ASHM expects its representatives to observe acceptable standards of behaviour. ASHM may discipline any representative who engages in unacceptable behaviour. Where an ASHM representative engages in misconduct or alleged misconduct, the processes in this
policy will be followed.
- Anti-discrimination Policy and Equal Employment
General statement of this policy: ASHM will not tolerate any form of discrimination or harassment and action will be taken against any person who breaches this policy at any time. ASHM is an equal employment opportunity workplace. Staff will be selected on merit –that is, the best person with the skills and abilities for the job. ASHM is committed to the inclusion and representation of those who are vulnerable and those who are affected by the intersecting drivers of marginalisation and exclusion.
- Industry Sponsorship Policy
General statement of this policy: This policy establishes the fundamental policy of industry sponsorship. ASHM will not enter into any sponsorship agreement with commercial entities whose products or services are incompatible with ASHM’s mission and values or influences its independence. Any sponsorship agreement must provide ASHM with reasonable value in return for the acknowledgement or recognition.
- Child Protection Policy
General statement of this policy: ASHM has zero tolerance for child abuse. Everyone working for ASHM is responsible for the care and protection of the children within our care and reporting information about suspected child abuse. ASHM is committed to upholding the rights of the child and Australia’s obligations under United Nations Convention on the Rights of the Child. In all actions concerning children, the best interests of the child shall be a primary consideration.
ASHM has developed a Child Protection Code of Conduct to provide clear guidance to personnel and associates about ways to minimise risk to children and make clear the standards of behaviour and practice required of them at all times when they are in contact with children. These behaviours are not intended to interfere with normal family interactions. All ASHM personnel are required to read and sign the Child Protection Code of Conduct,
- External Complaints Policy
General statement of this policy: ASHM is committed to efficient and fair resolution of complaints by people in the organisation at all levels. ASHM acknowledges customers’ and stakeholders’ right to complain and we positively invite feedback from customers and stakeholders about the goods and services we provide.
ASHM will provide a safe and discrete point of contact for stakeholders in Australia and countries where ASHM work is conducted, to raise concerns or complaints about the organisation.
- Ethical Investment Policy
General statement of this policy: The Board of ASHM is responsible for maintaining and extending the assets of the organisation, to provide for its long-term financial viability.
In its stewardship of ASHM’s financial assets, the Board has adopted this policy to ensure that any assets not required for the current operating budget will be invested in accordance with ASHM’s Investment Plan.
- Participation of Primary Stakeholders Policy
General statement of this policy: ASHM implements strategies and means through which our primary stakeholders can participate and contribute to ASHM activities and resources through identifying existing strengths and challenges, aspirations and resources; defining project goals and strategies; planning, implementing and evaluating project activities.
- Whistleblowing Policy
General statement of this policy: ASHM is committed to maintaining an environment where legitimate concerns are able to be reported without fear of retaliatory action or retribution. When a person makes such a disclosure they are entitled to expect that a fair and impartial investigation will ensue after a report has been made and their identity remains confidential at all times, they will be protected from reprisal, harassment or victimisation for making the report, and should retaliation occur for having made the disclosure then ASHM will treat it as serious wrongdoing under this Policy.
- Related Party Transactions Policy
General statement of this policy: Potential related party transactions or any questions as to the validity of application of an exemption are to be referred to the Board in the first instance. Where the Board resolves that a proposed transaction is subject to an exemption and does not require shareholder approval, it should ensure that a resolution to that effect is minuted. All Related Party Transactions will be disclosed in the Annual Report as required by Accounting Standards
- Non-development Activity Policy
General statement of this policy: Funds and other resources designated for the purpose of aid and development will be used only for those purposes and will not be used to promote a particular religious adherence or to support a political party, or to promote a candidate or organisation affiliated to a particular part.
- Gender Equality Policy
General statement of this policy: ASHM recognises that gender is not binary, and recognises all sexual orientations, gender identities and gender expressions. ASHM is committed to reduce marginalisation, stigma, and assumptions and expectations of heterosexuality which binary gender norms can accentuate. ASHM is committed to reduce the disadvantage, marginalisation, protection and inequality due to a person’s gender.
- Prevention of Sexual Exploitation, Abuse, Harassment Policy
General statement of this policy: ASHM will not tolerate sexual exploitation, abuse or harassment under any circumstances. All cases of suspected and actual sexual exploitation, abuse and harassment must be reported by all ASHM personnel to their supervisors or managers. There will be no presumptions of guilt and no determination made until a full investigation has been completed.
No ASHM representative, employee or volunteer will be treated unfairly as a result of rejecting unwanted advances.
- Staff Grievance Policy
General statement of this policy: ASHM recognises that an employee may not perform to the best of their ability if they feel they are being treated unfairly or are feeling aggrieved. Accordingly, ASHM will endeavour to provide a fair and just working environment, by aiming to ensure that employees have access to processes for the resolution of genuine personal grievances related to the workplace.
- Advocacy Policy
General statement of this policy: ASHM advocacy will always be characterised by the principle set in the policy
For more information on the policies listed above, visit the Policy Master List.
All staff and representatives of ASHM, including Board members, employed staff, contractors, consultants, mentors and volunteers are required to adopt the behaviours set out in these policies.
In addition, ASHM staff and representatives are to:
- Ensure that any communication regarding another NGO or ASHM partner is factually accurate, respectful and does not intentionally or otherwise mislead.
- Be familiar with the ACFID Code of Conduct and act in accordance with that Code of Conduct.
- Refrain from making statements about other ACFID members with the intention of creating reputational or other advantage.
- Be familiar with and adhere to ASHM’s Child Protection Policy and Procedure and Child Protection Code of Conduct Agreement.
- Be familiar with and adhere to ASHM’s Prevention of Sexual Exploitation, Abuse and Harassment Policy and Procedure noting prevention of transactional sex, bullying and all forms of sexual harassment.
- Report all instances of wrongdoing in line with procedures described in ASHM’s Staff Grievance and External Complaints policies and procedures.
ASHM Board – Approved May 2022
The Board of ASHM is committed to high standards of ethical conduct and accordingly places great importance on making clear any existing or potential conflict of interest.
Whilst ASHM recognises that individuals hold a range of legitimate interests outside the immediate workplace, identifying and dealing with any such conflicts of interest is an integral part of establishing an ethical culture at ASHM.
To comply with good governance practice, to maintain its peak body status and to comply with the ACFID Code of Conduct, ASHM needs to be able to have transparent processes which demonstrate its independence to all relevant stakeholders.
This policy has been developed to provide a framework for all board members, employees, committee members or contractors:
- in declaring conflicts of interest; and
- when determining how to deal with situations of conflict.
A conflict of interest is a situation in which a person (an ASHM Board member, employee, committee member, contractor) can derive personal benefit from actions or decisions made in their official capacity.
A conflict of interest can be actual, potential or perceived.
Examples of relevant conflicts of interests that should be disclosed include, but are not limited to;
- Holding shares in a company that ASHM is considering contracting for services
- Presenting at a conference where Industry has sponsored your attendance
- Sitting on the Board of another organisation in which ASHM has dealings
- All board members, employees, committee members and contractors must remain independent, impartial and unbiased in performing their duties
- It is the responsibility of board members, employees, committee members and contractors to take reasonable steps to avoid creating a conflict of interest or a perception of a conflict of interest
- Where a conflict of interest may exist or arise, it is the responsibility of board members, employees, committee members and contractors to disclose any such conflicts of interest in a timely manner
- If there is any doubt as to whether a conflict exists then, in order to protect the individual and ASHM, a disclosure should be made
- If any board member, employee, committee member or contractor becomes aware of any non-disclosed conflict by another board member, employee, committee member or contractor, then they will notify the ASHM CEO.
- If any board member, employee, committee member or contractor becomes aware of any non-disclosed conflict by the ASHM CEO then they will notify the ASHM President and also the Chair of the ASHM Finance, Risk Management and Audit Committee
- ASHM will maintain a register of conflicts of interest across all programs and this register will be available for inspection by relevant stakeholders upon request.
- This policy also relates to:
- a partner or family member of a board member, employee, committee member or contractor
- any partnership of which a board member, employee, committee member or contractor (or a partner or family member) is a member
- any corporation in which a board member, employee, committee member or contractor (or a partner or family member) is a director or owns or controls 25% or more of the issued shares.
- Conflicts of interest must be disclosed by a board member, employee, committee member or contractor in a timely manner as follows:
- each new board member, employee, committee member or contractor will, at the time of their appointment, be required to provide ASHM with a signed declaration disclosing any current conflicts of interest. In addition, during the recruitment process, AHSM will seek information about conflicts of interests from applicants
- Board members and committee members will also complete an annual declaration confirming their current conflicts of interest
- failure to provide either of these signed declarations in a timely manner may forfeit the individual’s ability to remain in the position
- once a conflict of interest, or a perception of a conflict of interest, arises for an employee or contractor they will advise their Division Manager as soon as possible
- once a conflict of interest, or a perception of a conflict of interest, arises for a board member or committee member, they will advise their fellow board/ committee members as soon as possible and be directed by the Chair of the relevant Board/ Committee as to how to proceed. If the conflict arises for the Chair of the meeting, then the Deputy Chair will advise how to proceed
- all Board and Committee meetings must commence with a standing agenda item for a declaration of any conflicts of interest.
ASHM Board – Approved 17 June 2021
This policy covers ASHM’s office-based operations as well as its development and humanitarian initiatives. ASHM’s Conference, Sponsorship and Events Division has a Green Events policy which governs the organisation of ASHM events and conferences, meetings and events ASHM is contracted to arrange for other organisations.
The earth’s environment is under severe stress from uncontrolled human activity, threatening the survival of our society and the performance of ASHM’s mission.
ASHM accepts that it must work to preserve the environmental sustainability of the planet, at all levels of its operations – in its own practice, as a participant in a community of practice, and as a participant in the Australian social discourse.
ASHM aspires to minimise its impact on our environment and maximise the effective use of resources. We strive to achieve this by increasing communication and awareness of our efforts in accordance with this policy and fostering responsible environmental behaviour amongst staff, volunteers, and users at all levels.
ASHM is committed not only to complying with applicable law in all of its operations but to minimise risks and impacts through the development of robust and documented systems to implement, measure, monitor, and disseminate excellent environmental performance both within its operations and to the broader community.
Also, ASHM is committed to understanding the environmental impact, if any, of our programming and organisational activities and conducting our activities in an environmentally sustainable way.
This Environmental Management Policy aims to integrate a philosophy of sustainable development into all the organisation’s activities and to establish and promote sound environmental practice in our operations
Environmental sustainability is a way in which demands placed on the environment can be met on a long-term basis.
ASHM recognises the potential impacts of organisational and office activities and seeks to minimise the demands/impacts from such activities – where possible.
ASHM recognises the impact that its projects may have on our partner countries and communities, and seeks to mitigate this impact – wherever possible.
ASHM is committed to monitor and evaluate the risks of its practices and projects and ASHM commits itself to minimising its impact on our environment through
Providing a safe and healthy workplace;
- Having an environmentally sustainable aware culture, where responsibility is assigned and understood;
- Being an environmentally responsible neighbour in our community;
- Conserving natural resources by reusing and recycling;
- Using, in our own operations, processes that do not adversely affect the environment;
- Ensuring the responsible use of energy throughout the organisation;
- Participating in efforts to improve environmental protection and understanding;
- Taking steps to continually improve environmental performance;
- Working with suppliers who promote sound environmental practices; and
- Enhancing awareness among our employees, volunteers, partners, and users – educating and motivating them to act in an environmentally responsible manner.
ASHM recognises that integrating environmental sustainability into our international development projects/programs improves their long-term benefits and impact.
ASHM considers the ‘do no harm’ principle in all our international development work and identifies strategies to avoid, minimise, or mitigate any negative impacts of our projects/programs on the environment.
ASHM Board - Approved 28 October 2020
The Board of ASHM is committed to ensuring that fundraising activities are carried out in an ethical manner.
This policy applies to the Board, casual, permanent and contract staff and volunteers.
The purpose of this document is to identify ASHM’s position on fundraising practice and to document the standards expected in raising funds from the community.
ASHM’s guiding fundraising principle is that we will only use techniques that we would be happy to be used on ourselves.
In doing so, the organisation will adhere to the following standards:
Fundraising activities carried out by ASHM will comply with all relevant laws.
Any communications to the public made in the course of carrying out a fundraising activity shall be truthful and non-deceptive.
All monies raised via fundraising activities will be for the stated purpose of the appeal and will comply with the organisation’s stated mission and purpose.
All personal information collected by ASHM is confidential and is not for sale or to be given away or disclosed to any third party without consent.
Nobody directly or indirectly employed by or volunteering for ASHM shall accept commissions, bonuses or payments for fundraising activities on behalf of the organisation.
No general solicitations shall be undertaken by telephone or door-to-door.
Fundraising activities should not be undertaken if they may be detrimental to the good name or community standing of ASHM.
Financial contributions will only be accepted from companies, organisations and individuals the Board considers ethical.
Free, prior and informed consent will be obtained for use of all images and stories in fundraising activities.
Acceptance or Rejection of Donations
Any decision to accept or reject funds must be based on:
the relevance of the donation to ASHM's objectives and
supporting our charitable purposes, where the donation is made as a tax deductible donation.
To the extent to which it is possible to determine, ASHM will not accept funds which have been derived from:
conduct which is not condoned by the organisation, including through the sale of tobacco, and
other activities which the Board would deem to be out of step with ASHM philosophy, code of conduct or which might realistically be seen to be disreputable.
All fundraising materials will be truthful and:
Include the organisations identity, including name, address, ABN and purpose;
Accurately represent the context, situation, proposed solutions and intended meaning of information provided by affected people;
Clearly state if there is a specific purpose of each donation;
Avoid material omissions, exaggerations, misleading visual portrayals and overstating the need or what the donor's response may achieve.
If outsourcing fundraising activities, ASHM will ensure that:
Contracts are in place which meet all relevant legislative and regulatory requirements;
Specific expectations, responsibilities and obligations of each party are clear and in writing;
ASHM is identified as the beneficiaries of the funds; and
Contractors are clearly identified.
Images and messages used for fundraising will not:
Be untruthful, exaggerated or misleading;
Be used if they may endanger the people they are portraying;
Be used without the free, prior and informed consent of the person/s portrayed, including children, their parents or guardians;
Present people in a dehumanised manner;
Infringe child protection policies and in particular show children in a naked and/or sexualised manner;
Feature dead bodies or dying people.
ASHM Board, April 2018
This policy applies to all Board members, employees, consultants, mentors and contractors of ASHM, unless otherwise specified.
The purpose of this policy is to ensure that ASHM representatives are aware of behaviour that could amount to misconduct and that all relevant parties are aware of ASHM's policy for dealing with misconduct.
For the purpose of this policy, all ASHM’s Board members, full time and part time employees, contractors, consultants, mentors and volunteers will be referred to as an ‘ASHM representative’.
Behaviour amounting to misconduct includes, but is not limited to, the following:
- failing to obey lawful (relevant laws to any respective jurisdiction) and reasonable instructions of ASHM;
- failing to follow defined policies, procedures and rules;
- failing to share key relevant information with ASHM (the determination of key relevant information will be reasonably determined by the CEO);
- unacceptable disruptive behaviour;
- unauthorised absence from the workplace; and
- repeatedly being late for work without lawful (relevant laws to any respective jurisdiction) excuse.
Behaviour amounting to serious misconduct includes, but is not limited to:
a breach of ASHM's Code of Conduct;
- wilful or deliberate behaviour that is inconsistent with the representative's contract of employment;
- intoxication at work or at an ASHM related event;
- use of derogatory, violent or abusive language;
- failure to observe safety rules;
- concealment of a material fact on engagement;
- obscenity and other forms of sexual misconduct;
- dishonesty in the course of the employment; and
- criminal conduct including conduct that, if proven, renders the representative completely unfit for work.
Whether misconduct amounts to serious misconduct may depend on the particular circumstances of a given case. Supervisors/managers should consider the circumstances fully as they apply to the particular representative when determining whether or not the representative has engaged in conduct that could be considered serious misconduct.
ASHM expects its representatives to observe acceptable standards of behaviour.
ASHM may discipline any representative who engages in unacceptable behaviour.
ASHM representatives must not engage in behaviour that amounts to misconduct (including serious misconduct) at the workplace. This includes where representatives are working on site or off-site, virtual or in person, attending a work-related conference or function, or attending a client or other work-related event, including retreats and social events.
When travelling for business purposes, an ASHM representative is always representing ASHM, including after work hours and is obliged to act in accordance with this policy and the ASHM Code of Conduct.
Where an ASHM representative engages in misconduct or alleged misconduct, the processes in this policy will be followed.
When proven, misconduct may provide a valid reason for termination of an ASHM representative's employment with notice.
If an ASHM representative believes they have been wrongly charged with misconduct, they may appeal their case to the ASHM Human Resources Manager and the CEO.
ASHM Board – Approved 11 November 2021
This policy provides guidelines around the organisation’s aid and development and non-aid and development objectives and activities. ASHM is committed to ensuring that we accurately represent our activities to the people we work with, our donors and the public.
This policy reflects accountability to all stakeholders, building trusting relationships with communities and honesty & transparency.
The purpose of this policy is to guide ASHM and our partners to make a clear separation between development and humanitarian and non- development objectives and activities. This policy addresses our ACFID compliance obligations when communicating with or soliciting donations from private donors and the public, including fundraising for restricted and unrestricted purposes from aid agencies, sponsors and supporters, and fundraising from the general public.
This policy is intended to apply to all ASHM activities. The policy is applicable to all ASHM employees and volunteers. The policy also extends to ASHM partners and associated implementing organisations.
From ACFID’s Code of Conduct – Aid and development refers to activities undertaken in order to reduce poverty and address global justice issues. In the non-government organisation sector, this may occur through a range of engagements that includes community projects, emergency management, community education, advocacy, volunteer sending, provision of technical and professional services and resources, environmental protection and restoration, and promotion and protection of human rights.
ASHM is committed to ensuring that funds and other resources designated for the purpose of aid and development are used only for those purposes. The concept of aid and development activities can be distinguished by the following principles:
a. Strengths based approaches which encourage people and communities to create solutions for themselves
b. Processes that seek to address the causes of poverty
c. Processes that seek to empower rights holders to claim their rights and ensure that duty bearers exercise their duties
d. Supporting systems and structures which enable people to move out of poverty
e. Humanitarian response and emergency relief, disaster recovery and meeting the immediate needs of refugees and internally displaced people.
Funds and other resources designated for the purpose of aid and development will be used only for those purposes and will not be used to promote a particular religious adherence or to support a political party, or to promote a candidate or organisation affiliated to a particular party.
The separation of development activities from non-development activities will apply in each of the following areas:
- Expenditure reporting
- Advocacy campaigns
- Choice for donors
This policy applies to ASHM and its sector partners and collaborators in either contracts or Memorandum of Understandings. ASHM will extend this policy and its attendant agreements to its development partners through MOUs or similar documents.
This policy provides a framework for ASHM’s compliance with the Commitment to accountability to our stakeholders in the ACFID Code of Conduct, in particular Compliance Indicator 7.3.2 which states that ACFID Members development initiatives constantly demonstrate the separation of development activities from non-development activities.
ASHM Board - Approved 26 August 2021
ASHM recognises the right of every employee, volunteer and representative to be able to attend work and to perform their duties without being subjected to any form of sexual exploitation, abuse or harassment. This policy therefore applies to all ASHM Board members, sub-committee members, consultants, services providers, employees and volunteers.
It is the obligation and responsibility of every ASHM representative, employee and volunteer to ensure that the workplace is free from sexual exploitation, abuse or harassment.
ASHM is fully committed to its obligation to eliminate sexual exploitation, abuse and harassment in the workplace.
The purpose of this document is to
- prevent any cases of sexual exploitation, abuse or harassment occurring within ASHM and its projects;
- work towards a respectful working culture;
- ensure that all parties are aware of their responsibilities for identifying possible occasions for sexual exploitation, abuse and harassment and for establishing controls and procedures for preventing such incidents and/or detecting them when it occurs.
- provide guidance to ASHM personnel as to action that should be taken where they suspect any incidents within or outside of the organisation
- provide a clear statement to ASHM personnel forbidding any such abuse.
- provide assurance that any and all suspected incidents will be reported and fully investigated.
The ultimate purpose of this policy is to help eliminate the risk of anyone working for and with ASHM being involved in sexual exploitation, abuse and harassment.
Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially, or politically from sexual exploitation of another.
Sexual abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual offences including but not limited to: attempted rape (which includes attempts to force someone to perform oral sex); and sexual assault (which includes non-consensual kissing and touching). All sexual activity with someone under the age of consent (in the law of the host country or under Australian Capital Territory law [16 years], whichever is greater) is considered to be sexual abuse.
Sexual harassment: A person sexually harasses another person if the person makes an unwelcome sexual advance or an unwelcome request for sexual favours, or engages in other unwelcome conduct of a sexual nature, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated or intimidated.
Sexual harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated or one-off and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against beneficiaries, community members, citizens, as well as staff and personnel.
Survivor-centred approach: where the rights, needs, wishes and empowerment of survivors of sexual exploitation, abuse and harassment are prioritised, in both the prevention of and response to sexual exploitation, abuse and harassment.
ASHM personnel includes all staff, volunteers, interns, contractors, committee members, visitors to projects, society representatives, ASHM partners’ downstream personnel and subcontractors engaged by ASHM to perform any part of ASHM project activities.
This prevention of sexual exploitation, abuse and harassment policy applies to all ASHM personnel which includes:
- staff/volunteers/interns/contractors/visitors to projects/Society representatives
- ASHM partner’s downstream personnel
- Subcontractors engaged by ASHM to perform any part of ASHM project activities
This policy applies to conduct that takes place in any work-related context, including conferences, work functions, social events and business trips.
- Zero tolerance: ASHM has zero tolerance for sexual exploitation, abuse or harassment. Every ASHM personnel is responsible for reporting incidents and growing awareness of prevention of sexual exploitation, abuse and harassment and for the care and protection of the people within our care and reporting information about suspected abuse.
- Survivor approach: ASHM will exercise its commitment to the prevention of sexual exploitation, abuse and harassment through a survivor-centred approach. Wherever possible, all reporting of alleged sexual exploitation, abuse and harassment should de-identify the victim/survivor, consistent with a survivor-centred approach. This approach prioritises the rights, needs, wishes and empowerment of survivors of sexual exploitation, abuse and harassment in both the prevention of and response to sexual exploitation, abuse and harassment
- Shared responsibility for prevention of sexual exploitation, abuse and harassment: ASHM requires the commitment, support and cooperation of partner organisations and individuals who help to deliver programs to effectively manage risks to people in all of our projects and activities.
- Promotion of a gender equality culture: Engagement with intended beneficiaries should be based on respect for diversity, promotion of gender equality and social inclusion, accountability, and a strong “do no harm” focus.
- Procedural fairness: ASHM will apply procedural fairness when making decisions that affect a person’s rights or interests. ASHM’s partners are expected to adhere to this principle when responding to concerns or allegations of sexual exploitation abuse and harassment.
- Natural justice: All investigations concerning suspicions and allegations of sexual exploitation, abuse or harassment will be conducted according to the rules of natural justice. In line with this principle, ASHM will ensure that personnel must be fully aware of their responsibilities to protect the survivor and how to report concerns or allegations about sexual exploitation, abuse and harassment.
- Risk assessment approach: People safety risk assessment is a part of ASHM’s overall risk assessment for all projects and partnerships. This assessment will identify risks, and document steps being taken to reduce or remove those risks.
General policy statements
ASHM will not tolerate sexual exploitation, abuse or harassment under any circumstances.
Prevention of sexual exploitation, abuse and harassment is a shared responsibility between the ASHM, all employees, workers, contractors, associates, and members of the ASHM community.
Both federal and state Equal Employment Opportunity legislation provide that sexual exploitation, abuse or harassment is unlawful and establish minimum standards of behaviour for all employees.
All cases of suspected and actual sexual exploitation, abuse and harassment must be reported by all ASHM personnel to their supervisors or managers.
ASHM strongly encourages any representative, employee or volunteer who feels they have been sexually harassed to take immediate action.
No ASHM representative, employee or volunteer at any level should subject any other representative, employee, volunteer, customer or visitor to any form of sexual exploitation, abuse or harassment.
The alleged harasser also has the right to have support or representation during any investigation, as well as the right to respond fully to any formal allegations made.
There will be no presumptions of guilt and no determination made until a full investigation has been completed.
No ASHM representative, employee or volunteer will be treated unfairly as a result of rejecting unwanted advances.
All representatives, employees and volunteers have the right to seek the assistance of the relevant tribunal or legislative body to assist them in the resolution of any concerns.
ASHM Board – Approved 24 August 2020
The purpose of this policy is to ensure that ASHM adheres to the requirements set out in the Privacy Act 1988 and the Australian Privacy Principles, which govern standards, rights and obligations for the collection, use and disclosure of personal information.
The purpose of this policy is to inform:
- all ASHM employees
- volunteers, consultants and representatives,
- independent contractors and job applicants, as well as
- individuals who provide ASHM with their personal information of their rights and responsibilities concerning the uses of personal information.
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
(Privacy Act 1988, Registered 25 October 2021)
The Australasian Society for HIV, Viral Hepatitis and Sexual Health Medicine (ASHM) is bound by the Privacy Act 1988 (Cth) and is committed to complying with the Act, including the Australian Privacy Principals, and to protecting the privacy of the personal information that ASHM holds.
This policy applies to all ASHM employees, volunteers, consultants and representatives, independent contractors and job applicants, as well as individuals who provide ASHM with their personal information.
- the relevant page on our website: www.ashm.org.au/privacy
- other websites that ASHM manages and is responsible for
- alert our members, if necessary, in cases where those changes might also affect their membership.
Your right to access and inspect and, where necessary, correct or remove, the personal information that ASHM holds about you
We will take all reasonable steps to ensure that the personal information that we hold is accurate and up to date. If you feel that information about you is not accurate or your details have or are about to change, you can:
- call us on 02 8204 0700 and we will correct or update your personal information
- if you have a login to MyASHM at https://www.ashm.org.au then you can click on Update My Details to change your details, when you are logged in.
If you are unable to access via MyASHM please call ASHM on 02 8204 0700, or email firstname.lastname@example.org to request access to the records you hold.
You have a right to access your personal information, subject to certain exceptions provided for in the Privacy Act. For security reasons, you will be asked to put your request in writing and provide proof of your identity.
All requests to amend or otherwise update information we hold about you will be performed as soon as practically possible.
All requests to remove information we hold about you, or to restrict the way in which ASHM processes your data, will be performed as soon as practically possible, although this may impact ASHM’s ability to communicate with you and provide its suite of services.
Your right not to provide personal information to ASHM
You are not obliged to give us your personal information. If you would like to access any of our services on an anonymous basis, we will take all reasonable steps to comply with your request. However, if you choose not to provide ASHM with personal details, such as your name or address, the range of options available to you or your organisation, may be limited.
For example, in the case of anonymity, ASHM cannot provide the full range of member services or allow you or your organisation to participate in networking functions, seminars and events, or successfully deliver any products and services that you have ordered from the ASHM website.
Your right to have your privacy complaints investigated and resolved.
If you have a complaint about ASHM's privacy practices, including a perceived breach of the Australian Privacy Principles, please contact our Privacy Officer: email@example.com
If the Privacy Officer is not able to satisfactorily address your concerns, then please refer to www.ashm.org.au/about/ for information about ASHM’s general complaint handling process.
Complaints will be handled in accordance with ASHM's Complaints Policy, which is available on the ASHM website. You can request a copy of this policy from us at any time during business hours (9:30am to 5pm AEST).
ASHM Board - Approved March 2022
ASHM embraces the use of social media for the promotion, development, and delivery of services.
ASHM recognises that all employees can communicate online in many ways, such as through social media, professional networking sites, blogs, online news sites and personal websites. However, all employees need to use good judgment about what material appears online, and in what context.
This policy applies to all ASHM employees using or having a need to participate in online social media activity for official ASHM communications and through personal accounts which they have created and administer themselves.
The Social Media Policy outlines protocols for using social media to undertake official ASHM business and provides guidance for employees in their personal use of social media or making public comment online.
The policy provides advice to ASHM employees on how to use social media, both in the course of their official duties, and in the private context. It has been developed to assist employees to be mindful of their obligations and responsibilities, and to remain within ASHM’s guidelines.
The Social Media Policy applies to all ASHM employees, including Board members, volunteers, and contractors.
Social media are websites and applications that enable users to create and share content or to participate in social networking.
This policy will apply to whichever social media channels ASHM chooses to use, which may change from time to time. This includes, but is not limited to:
ASHM will only use its social media to:
manage risk and make key announcements at short notice.
make ASHM’s efforts more visible to the community, the healthcare sector, and the government.
All content used in ASHM’s and ASHM employees' social media posts will follow the ASHM Code of Conduct, Privacy and Promotional Material Policies. A failure to comply with these policies may constitute a breach of the ASHM Code of Conduct.
Members of the public must not make comments that are unlawful, obscene, defamatory, threatening, harassing, discriminatory or hateful to, or about work, colleagues, peers or ASHM, if such a comment or post is found during regular checks ASHM staff should delete the post as soon as practicable and, where possible, ban/block that user from ASHM platforms.
All ASHM posts in ASHM’s social media channels must be professional, neutral, and apolitical.
Staff should not use ASHM platforms to support or malign political parties or figures.
Staff must refrain from making statements about other Australian Council for International Development (ACFID) members with the intention of creating reputational or other advantage.
ASHM’s platforms may call for disagreement with government policies or actions, but the language to be used will be agreed upon by the executive and/or board.
When posting third party information or images ensure that consent is given.
ASHM employees are not authorised to speak on behalf of ASHM unless specifically authorised to do so in their role which is generally limited to staff in the Communications team, who manage the organisation's official social media accounts.
ASHM Board – Approved February 2022
ASHM is committed to being transparent in our work and accountable to our stakeholders and community. We are committed to disclosing timely, relevant and accurate information in an accessible format.
The purpose of this policy is to demonstrate how ASHM practices transparency and accountability.
Transparency implies openness, communication, and accountability. Transparent business and financial activities are done in an open way without secrets, so that people can trust that they are fair and honest.
Transparency is the practice of openly and honestly disclosing information to stakeholders in an organisation, such as the public, employees and customers.
Transparency does not mean all information should be made publicly available. There are certain types of information that may not be provided publicly such as private information (such as client records) and ‘commercial in confidence’ material (such as tender submissions).
ASHM is committed to disclosing timely, relevant and accurate information in an accessible format, with any exceptions clearly and reasonably explained (such as privacy and data protection issues).
This applies to ASHM dealings with staff, members, funders, regulatory bodies and all other internal and external stakeholders
ASHM has a range of policies that demonstrate its commitment to transparency. The aim of this policy is not to repeat transparency requirements that are documented in other policies, but to confirm its commitment to transparent operations. A list of relevant policies is included below.
Staff who become aware of any areas in which ASHM can improve its transparency should advise their division manager.
ASHM Board – Approved 24 August 2020