Child Safety and Allegation Management Policy

Safe Fellowship

Our fellowship is committed to keeping children and young people safe. We seek to be a caring, understanding, and supportive community for survivors of child sexual abuse or other harm to children, where compassion and safety guide our actions.

When there is an allegation of child sexual abuse or related harm, our priority will always be the safety and well being of children, young people, survivors (both known and unknown), and the wider community. We will act quickly and appropriately to help ensure they feel safe, believed and supported.

We recognise the importance of the lessons and recommendations from the Royal Commission into Institutional Responses to Child Sexual Abuse, and we commit to following both these recommendations, criminal law and all relevant state and territory legislation.

We also understand that integrity, independence, and trust are essential to protecting children. To that end, any allegation of child sexual abuse will be referred to an independent, not-for-profit investigation firm with expertise in faith-related safeguarding matters (their credentials are found in Appendix A). This firm will help us ensure that we meet all legal and reporting obligations and that each concern is addressed fairly, thoroughly, and without conflict of interest. They will also assist in assessing risks and establishing appropriate boundaries, helping to maintain a safe environment for everyone in our fellowship.

Our Guidelines

1. Our fellowship is committed to the safety and wellbeing of every child, young person, and vulnerable person. We will listen to and believe survivors and take all allegations seriously.

2. Child sexual abuse, grooming, or any form of harm or risk of harm toward children and young people - whether in person or online - is not tolerated.

3. We will comply with all legal obligations, including mandatory reporting to police or Reportable Conduct Schemes or other requirements.

4. All necessary measures will be taken, including maintaining appropriate records regarding individuals who pose a risk, to ensure that children in the fellowship are protected.

5. The safety and voices of children, young people, and vulnerable persons will always be a central concern in decision-making. Listening to them and taking their concerns seriously is essential. We recognise that sexual abuse and related harm have profound and lasting effects on individuals and their families.

6. Responses will be guided by compassion, integrity, and care.

7. Persons of concern will be treated fairly and consistently.

8. Confidentiality is valued, but its limits are acknowledged - particularly where safety is at risk.

9. Confidentiality will be upheld for individuals alleged to have caused harm, except where disclosure is necessary to investigate concerns or protect others.

We are committed to always offering care and support to survivors and ensuring that responsibility rests with the person who has chosen to cause harm. Our focus will remain on creating a safe and supportive environment where survivors are valued and heard.

Child Safety and Allegation Management Policy

For Australian Capital Territory, New South Wales, Northern Territory and South Australia

1.1 This procedure documents our fellowship’s approach to allegations of child sexual abuse and related harm.

Our key priorities are:

1. Prioritising the safety of children, young people, survivors (both known and unknown), and the individual making the allegation.

2. Providing clear guidelines on how allegations of child sexual abuse and harm should be reported, documented, investigated, and resolved.

3. Ensuring a consistent, transparent, fair, and compassionate response.

1.2 This policy covers current and historic concerns.

1. PURPOSE

2. SCOPE

2.1 This document applies to all fellowship members, elders, gospel workers, and activities within Australian Capital Territory, New South Wales, Northern Territory and South Australia. It guides the process from the moment a concern or allegation of child sexual abuse or harm is raised through to the implementation of safety plans and ongoing monitoring in line with recommendations.

2.2 For clarity, “we” and “our” refer to the non-denominational fellowship in Australian Capital Territory, New South Wales, Northern Territory and South Australia.

3. KEY PRINCIPLES

3.1 We will not tolerate any form of child sexual abuse, harm, or risk of harm.

3.2 The rights, safety, and wellbeing of children, young people, and vulnerable people come first.

3.3 We will listen to, believe and take seriously the voices of children, young people and survivors.

3.4 Abuse, grooming, and harm—whether in person or online—are illegal and deeply damaging.

3.5 Confidentiality has limits—protecting people from harm comes before privacy.

3.6 We will follow all legal reporting requirements to police, child protection or other authorities.

3.7 During investigations, information will only be shared on a strict “need to know” basis in line with privacy laws.

4. DEFINITIONS

The following definitions apply:

4.1 Child sexual abuse: Any act that exposes a child to, or involves a child in, sexual processes beyond their understanding or contrary to community standards, including both contact and non-contact acts.

4.2 Child or young person: Anyone under the age of 18.

4.3 Person of concern: Any individual convicted, accused, reasonably suspected, or who has admitted to child sexual abuse, harm, or risk of harm.

4.4 Independent specialists: An external, professional organisation engaged by the fellowship to conduct investigations and advise on safety planning. The investigator is required to follow all statutory and criminal guidelines relating to child abuse, harm, risk of harm, reportable conduct, and sexual offences against minors. Their credentials are found here.

4.5 Allegation: A claim that someone has committed child sexual abuse, harm, or risk of harm.

4.6 Harm or risk of harm: Any act that has a detrimental effect of a significant nature on a child’s physical, psychological, or emotional wellbeing.

4.7 Victim/Survivor: A person who has experienced, or is alleged to have experienced, child sexual abuse, harm, or risk of harm.

4.8 Offender: A person confirmed, convicted, or substantiated as having committed child sexual abuse, harm, or risk of harm.

4.9 Vulnerable person: An individual who, due to factors such as age, disability, or dependence, is at increased risk of abuse.

4.10 Grooming: The process by which an individual builds a relationship and trust with a child or those around them to manipulate, exploit, and abuse the child, often gradually and subtly to avoid detection.

4.11 Reportable Conduct: Certain kinds of behaviour towards children may be reportable to state authority including

1. In NSW under the Children’s Guardian Act 2019 sexual offences or misconduct involving a child, ill-treatment, neglect, or assault of a child, behaviour causing significant emotional or psychological harm, certain criminal offences against children;

2. In ACT defined in the Ombudsman Act 1989 sexual offences or misconduct involving a child, ill-treatment, neglect, or physical offences, conduct causing psychological harm and inappropriate discipline or failure to protect a child from harm.

3. SA does not have a formal Reportable Conduct Scheme. Instead, under the Children and Young People (Safety) Act 2017, mandated notifiers must report to the Department for Child Protection if they suspect a child is, or may be, at risk of harm.

4. The NT does not have a formal Reportable Conduct Scheme. Under the Care and Protection of Children Act 2007, all adults must report to Territory Families or Police if they believe a child has been, or is likely to be, harmed, abused, neglected, or exploited.

4.12 Criminal Law: Most jurisdictions now make it a criminal offence for adults including those in positions of responsibility to fail to report known or suspected child sexual abuse to police or child protection authorities. In addition, some laws create a separate offence of failing to protect a child from the risk of sexual abuse where an adult knew of the risk and had the authority or ability to reduce it.

5. PROTECTING CHILDREN, YOUNG PEOPLE, AND VULNERABLE PERSONS

5.1 Our fellowship is committed to the ongoing safety and wellbeing of children, young people, and vulnerable individuals. Any act of child sexual abuse, harm, or risk of harm—whether online or in person—is unacceptable. Measures to protect children include maintaining appropriate records about individuals who may pose a risk, establish clear boundaries, and implementing formal safety plans when required.

5.2 The voices of children, young people, and survivors are central to our decision-making. Their concerns will always be heard and taken seriously. We recognise that abuse and harm have profound and lasting effects.

5.3 We acknowledge that responding to child sexual abuse is complex and emotionally challenging. Gospel workers or elders may not have the specialist skills needed to handle these sensitive matters. To ensure impartiality, legal compliance, and a trauma-informed approach, we engage with an independent specialist investigation firm (“Independent Specialists”). This helps keep the process transparent, respectful, and in line with best practice—protecting children, supporting survivors, and caring for our fellowship. Each case is unique, so experienced professionals will guide our response with care and skill.

6. REPORTING

6.1 Allegations or concerns about child sexual abuse, harm, or risk of harm can be reported in several ways to ensure timely and appropriate action. All adults have a responsibility to report where they have reasonable belief of any child sexual abuse or harm to the relevant state authorities.

Reporting options include:

1. Directly to police or child protection as found in this section:

2. To the Independent Specialist via phone 1800 135 246.

3. At convention, to the nominated Safety Contact or gospel workers coordinating convention. These names will be provided at the start of each convention.

4. To any gospel worker or elder within the fellowship, who will then ensure the matter is passed promptly to police or our Independent Specialist and as required, to the authorities within the appropriate time frame.

New South Wales (NSW):

• Police Assistance Line: 131 444

• Child Protection Helpline: 132 111 (24/7)

South Australia (SA):

• Police Assistance Line: 131 444

• Child Abuse Report Line (CARL): 13 14 78 (24/7)

Northern Territory (NT):

• Police Assistance Line: 131 444

• Territory Families, Youth and Communities – Centralised Intake: 1800 700 250 (24/7)

Australian Capital Territory

• (ACT):Police Assistance Line: 131 444

• Child and Youth Protection Services (CYPS) Intake Line: 1300 556 729 (24/7)

6.2 All reports will be taken seriously, treated with respect, and managed in a way that prioritises the safety and wellbeing of children, young people, and vulnerable individuals.

7. RECEIVING ALLEGATIONS OR CONCERNS

7.1 Allegations or concerns regarding child sexual abuse, harm, or risk of harm may come from a variety of sources, including:

7.2 Historic cases are treated with the same urgency and care as current concerns. A child does not need to be currently at risk for the matter to be referred to police or other agencies. Any act of child sexual abuse, harm, reportable conduct, or sexual offence against a minor (under 18 years) must be reported immediately to police, even if it occurred in the past. Delays in reporting may place children or vulnerable persons at further risk and may breach legal obligations. Reports should be made without delay, even if all details are not yet known. All criminal law and state-based legislative requirements will always be followed in the first instance.

7.3 We recognise that it can be very difficult for victims and survivors of abuse to come forward and acknowledge that the process of making an allegation can feel daunting and overwhelming. We will respond with care, and survivors will be treated with respect. If there is any doubt, a report will be made to statutory authorities. Independent investigations will only proceed where this is permitted by police or child protection, and only in a way that ensures the safety of children in our fellowship.

7.4 All information received will be carefully assessed. While action will not be taken on the basis of unfounded rumours or hearsay, there may be situations where we must act on any information that indicates a child may be at risk. Anonymous reports may lack sufficient details to substantiate the concern; in these cases, the Independent Specialist will determine whether there is adequate information to pursue an inquiry and, if so, what actions are appropriate. If there is any doubt, a report will be made. Where an adult victim does not consent to being identified, anonymous reports can be made to police, and any available information should still be provided.

7.5 The Independent Specialists we have engaged are an experienced, external, professional organisation specialising in faith-related matters. They are required to follow all statutory and criminal guidelines relating to child abuse, harm, risk of harm, reportable conduct, and sexual offences against minors. Their role is to conduct investigations only where authorised by the appropriate authorities, ensuring full compliance with legislation and criminal codes, while prioritising the safety and wellbeing of children, young people, survivors, and vulnerable persons. They also will provide expert advice to workers and elders, and they will develop documented Safety Plans as required.

1. The person themselves.

2. Friends or relatives of the person.

3. A victim or person making an allegation.

4. Public sources, such as newspapers, media reports, or court records.

5. Statutory authorities.

6. Private information from third parties.

8. SURVIVOR SAFETY

8.1 The ongoing safety, care, and wellbeing of survivors is of utmost importance.

8.2 Throughout this process, survivors will be supported and kept appropriately informed by the Independent Specialist, following the initial communication pathway. This ensures that communication remains thoughtful, respectful, and professional.

8.3 Responding to allegations and managing persons of concern in a fair, consistent, and competent manner supports the healing and wellbeing of survivors. It demonstrates that their experiences are taken seriously, fosters a sense of safety and accountability, and helps rebuild trust.

9. WELLBEING AND COUNSELING SUPPORT FOR SURVIVORS

9.1 Wellbeing and Counseling Support is available to survivors of child sexual abuse or harm throughout the entire process—from initial disclosure, through any legal or investigative proceedings, and after those processes are complete through the Independent Specialist. Survivors will be treated with respect, compassion, and care. Where appropriate, they will be offered referrals to qualified professional counselling and support services to ensure they receive specialised assistance. This support acknowledges the ongoing impact of abuse and the importance of trauma-informed care in promoting healing and wellbeing.

9.2 This support has been generously offered by some of our concerned friends in NSW and SA and will be provided through the Independent Specialist. No information on who is using any counselling services will be available to any workers or friends including those who have provided funding.

9.3 We recognise that some survivors may not feel comfortable attending fellowship or Gospel meetings in person. In these circumstances, we are committed to offering alternative forms of spiritual support. This may include personal visits, one-on-one encouragement outside of meetings, or the option to dial in and listen to gospel meetings remotely. Our aim is to ensure that survivors continue to have access to spiritual care in ways that feel safe and respectful for them.

10. MANAGING ALLEGATIONS AND FAIR PROCESS

10.1 When an allegation is made, we will respond in a way that addresses our duty to protect children and vulnerable persons. Anyone in a role of responsibility who is subject to an allegation is immediately removed from that role while the matter is investigated. We will work with Independent Specialists who will provide advice on these matters.

10.2 Subject to guidance from police or other relevant state-based authorities, investigations will be conducted in a way that is fair by an Independent Specialist.

This means:

1. Investigators will act impartially and without bias and will not participate if they have any conflict of interest.

2. Investigators involved in such matters will be trauma-informed and possess the necessary skills and expertise in handling sensitive cases.

3. The process will involve reasonable inquiry and a genuine effort to understand the circumstances before any decisions are made.

4. All relevant evidence—both that which supports and does not support the allegation—will be carefully considered.

5. The individual will be informed of the substance of the concerns raised against them, including as much detail as can appropriately be shared without necessarily disclosing the identity of the alleged victim/s.

6. They will be given a reasonable opportunity to respond—whether in writing, through conversation with an independent investigator, or by another suitable means.

7. The individual who is the subject of allegations will be advised of the status of the matter at each stage of the process.

8. Every effort will be made to ensure that investigations are carried out in a timely and respectful manner.

9. While fairness is important, it must be balanced with our duty to act decisively where there is serious risk to a child or vulnerable person.

10. The Independent Specialist will ensure that all allegations are reported to the appropriate authority and only investigated subject to instruction from Child Protection and/or Police. This includes allegations of all types of harm and sexual abuse, including grooming. Where an allegation has been reported to a legislated authority (Child Protection or Police), the investigator will not make any contact with the alleged perpetrator and/or parent/caregiver unless instructed by the authorities to do so.

10.3 Throughout the investigation, the safety of children, survivors, and the wider fellowship is always the priority. Protective measures are implemented immediately if any risk is identified, while the principles of fairness and due process are upheld.

11. ASSESSING RISK AND SAFETY PLANNING

11.1 No-one should be permitted to have a trusted relationship with children and young people if there is an unacceptable risk that children may be abused or at risk of harm.

11.2 Any person convicted of a child sexual abuse offence is automatically barred from obtaining a Working with Children Check (WWCC), or equivalent (Ochre Card in the NT or WWVP in the ACT). Under the law, individuals who do not hold WWCC clearance cannot work in any child-related role, including as a gospel worker. Appropriate safeguards must be in place to prevent contact with children and the impact on the broader fellowship community.

11.3 Individuals may also pose an unacceptable risk to children in other circumstances as not all allegations appear on a Working with Children Check. These may include where there is a criminal charge which has yet to be dealt with, an accusation, allegation or complaint currently under consideration or an admission by the person concerned. Such individuals require clearly defined boundaries and may only attend specific gatherings under strict and approved conditions, as set out in a formal Safety Plan defined by our Independent Specialists to ensure there is no contact with children through our fellowship. This Safety Plan may be temporary until such risk has been determined.

11.4 Following our independent investigation or third party confirmation that a risk to children (such as through a police investigation) is present, any person found to have committed child sexual abuse or harm—based on the balance of probability (the standard used by the Australian Royal Commission)—will also require these same boundaries and conditions. Their participation will be limited to defined conditions under a Safety Plan formulated by the Independent Specialist so that children are not at risk.

11.5 If someone is identified as posing a risk to children, they will no longer be in positions of guidance or authority, including gospel workers who live in our friends’ homes. This includes other positions that carry responsibility, such as serving as an elder or elder’s wife, greeting people at gospel meetings, or taking on other volunteer roles that may be seen as positions of trust. These safeguards are in place to ensure that such roles cannot be misused in ways that might place children or vulnerable people at risk.

11.6 Some considerations for a risk assessment will include:

1. Whether abuse or risk of harm has been formally established.

2. The nature of the person’s contact with children.

3. The level of supervision available.

4. How often and what kind of events gave rise to the concern.

5. Any bail or parole conditions in place.

6. Whether victims may be present and the potential impact.

7. The person’s understanding of and commitment to child safety.

8. The environments in which fellowship activities take place.

11.7 Temporary Safety Plans are implemented while investigations are ongoing to ensure protection. These plans may restrict attendance to certain meetings without children, require supervision, or define safe contact boundaries. Following the completion of an independent investigation, a long-term Safety Plan is developed to address the specific risks identified, prioritising the safety and wellbeing of children, survivors, and the fellowship.

12. WRITTEN REPORT FROM INDEPENDENT SPECIALIST

12.1 The Independent Specialist will bring together all relevant discussions and documents into a written report. This report will be provided to at least two overseers and will include an investigation of the allegation, the level of risk involved, and recommended actions to help protect both the survivor and the broader fellowship.

13. SET BOUNDARIES

13.1 A common characteristic of persons of concern is their failure to understand why their movements or activities should be in any way constrained. They will often minimise their past and be overly optimistic about their future. It is important for them to understand the benefit in no contact nor potential contact with children and to take responsibility for past actions.

13.2 The setting of boundaries will take the form of a Safety Plan which will include a written statement of:

1. Which meetings and activities they may and may not attend.

2. The supervision and accountability which has been put in place, as recommended by the Independent Specialist and agreed by at least two overseers.

13.3 While an investigation is ongoing, a temporary Safety Plan will be implemented to manage any potential risk and to uphold the safety of children, young people, and vulnerable individuals. This plan may include restrictions such as limiting or suspending the individual’s attendance at meetings or activities, requiring supervision, and defining appropriate contact boundaries. These measures are precautionary and do not imply a presumption of guilt. They reflect a responsible commitment to safeguarding, ensuring that protective steps are taken while maintaining a fair and impartial process. The Safety Plan may be adjusted in response to new information or advice received during the investigation.

13.4 These Safety Plans are regularly reviewed and updated as needed by the Independent Specialist. Breaches of these plans may result in immediate suspension or permanent exclusion from any fellowship gatherings.

14. ACTIONS TO ENSURE SAFETY

14.1 At least two overseers will carefully review the Independent Specialist report to decide what steps need to be taken to address the risks identified. These decisions will prioritise the safety of victims (both known and unknown), the person who made the report, their families, and the wider fellowship. If either of the overseers have a conflict of interest, they will not be involved in the process and someone else will be involved.

14.2 The actions decided upon will be clearly documented and shared with the person found to have caused harm (the Person of Concern). A summary of the outcome will also be provided to the victim or survivor, where appropriate, in a manner that protects the privacy of others, maintains confidentiality, and supports the wellbeing of all parties involved.

14.3 Where an allegation has been substantiated, the Person of Concern will not be allowed to attend the same meetings, activities, or use the same premises as children, the survivor or their immediate family.

14.4 Elders may sometimes feel motivated by a desire to provide spiritual support. However, regardless of personal feelings, elders must abide by independent professional guidance and a formal Safety Plan. The Royal Commission has made clear that religious communities carry specific responsibilities for ensuring the safety of children and vulnerable people. When people do not have access to all the relevant information, the expertise to assess risk, or the necessary objectivity due to close relationships, it can be difficult to make sound decisions. For this reason, it is vital that these situations are managed with appropriate safeguards in place through engagement with independent expert advice.

14.5 Any person involved in decisions regarding the inclusion of someone with a history of offending will be fully informed about the nature of the concerns or convictions. This ensures that decisions are made with a clear understanding of the risks involved and the protective measures required. Information will be shared in a way that balances confidentiality with the need for safety, so that those responsible for decision-making can act wisely, fairly, and transparently.

15. ONGOING SAFETY

15.1 Once actions have been agreed upon, appropriate measures will be in place for the person of concern, but never at the expense of the safety and wellbeing of children or survivors.

15.2 Any measures provided will only occur in ways that are safe, such as separate spiritual support or one-way online access to gospel meetings or convention, and always in full compliance with the Safety Plan and all legal requirements.

15.3 The Safety Plan will be shared with gospel workers and fellowship members responsible for oversight in the area, so they can help monitor and encourage ongoing compliance.

15.4 Persons of concern remain fully responsible for their own conduct, and any failure to comply will result in immediate review and may lead to exclusion from all fellowship activities.

16. REVIEWING THE SAFETY AGREEMENT

16.1 If circumstances change—for example, if the person does not comply with the existing agreement—a review may be carried out by the overseers and the independent specialist.

16.2 If it appears the level of risk has changed, the matter will be referred to the Independent Specialist for review, following the same process as outlined earlier. Any new actions will be guided by the updated risk profile, and a revised Safety Plan will be documented with ongoing consideration for any survivors.

16.3 Regardless of changes, each safety plan will be reviewed annually.

17. LEGAL COMPLIANCE AND REPORTING

17.1 All statutory obligations, including mandatory reporting to police or other authorities, are strictly followed. The Independent Specialist will assist us in ensuring that all actions comply with criminal codes, child protection legislation, and reportable conduct requirements. This ensures investigations are legally sound, consistent, and safeguard the wellbeing of children, young people, and vulnerable persons.

18. HANDLING INVESTIGATIONS WITH INTEGRITY

18.1 All allegations will be investigated in the same fair and consistent way, regardless of how believable or serious they may initially appear and in accordance with state and legislative guidelines. This ensures integrity and upholds procedural fairness and recognising that some true circumstances may be seen as unbelievable.

19. CONSEQUENCES FOR NON-COMPLIANCE

19.1 Non-compliance with this policy is treated seriously. Elders, gospel workers, or others responsible for managing allegations who fail to comply may be removed from their role. Fellowship members who breach policy or Safety Plans may be suspended or permanently excluded from meetings and activities.

20. CHILD SAFETY AND ALLEGATION MANAGEMENT POLICY CONTROL

This document is approved on 14th of October 2025 by the NSW and SA overseers Graeme Dalton and Trevor Joll. It has been reviewed and approved by ChildSafe Australia.

It will be reviewed annually for currency and compliance with legislative requirements with a full review every 3 years or sooner as required.

Depending on the individual circumstances of the case.

The allegation process may include:​

• Stages 1, 2 and 3​

• Stage 1 and 3 or​

• Stage 2 and 3​

Flowchart: