1. Purpose & Commitment

Privacy is not treated as a compliance obligation at CONVI. It is treated as a condition of the relationship between provider and participant — fundamental to trust, safety, and professional integrity.

2. Legislative Framework

This policy is governed by and implemented in accordance with:

• Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)
• Health Records Act 2001 (Vic) and the Health Privacy Principles (HPPs)
• NDIS Act 2013 (Cth) and the NDIS (Provider Registration and Practice Standards) Rules 2018
• NDIS Practice Standards — Core Module, including requirements for participant privacy and dignity
• Disability Act 2006 (Vic)
• Relevant mandatory reporting legislation applicable in Victoria

Where these frameworks impose different or additional obligations, CONVI applies the higher standard.

3. What Information CONVI Collects

3.1 Participant Information

CONVI collects personal and sensitive information about participants to deliver safe, appropriate, and compliant support services. This includes:

• Full name, date of birth, address, and contact details
• NDIS participant number and plan details
• Disability, health, and medical information relevant to support delivery
• Emergency contact and nominee/guardian details
• Support goals, progress notes, and outcome observations
• Incident and near-miss records
• Financial information required for billing and invoicing
• Risk assessments and behaviour support plans

3.2 Worker Information

CONVI collects personal information about current and prospective workers including:

• Identity, contact, and employment eligibility information
• Qualifications, certifications, and credential records (including screening checks)
• Employment and performance records
• Bank and superannuation details for payroll purposes
• Incident and complaint records where relevant

3.3 How Information Is Collected

Information is collected directly from the individual where practicable — through service agreement discussions, onboarding processes, assessment and intake, and ongoing service delivery. CONVI may also receive information from NDIS plan managers, support coordinators, treating professionals, or other providers where the participant has consented to this exchange.

4. Consent

CONVI will obtain informed consent before collecting sensitive information. Participants, nominees, and guardians are informed at intake of the types of information collected, how it will be used, and to whom it may be disclosed.

Consent to collect information is documented in the CONVI Service Agreement. Separate consent is obtained for any secondary use or disclosure not covered by the service agreement.

Participants retain the right to withdraw consent. CONVI will advise where doing so may limit its ability to safely deliver supports.

5. Use of Personal Information

CONVI uses personal and sensitive information only for the primary purpose for which it was collected, or for a secondary purpose that is directly related and the individual would reasonably expect. This includes:

• Designing and delivering support services aligned to participant goals
• Billing, invoicing, and financial administration
• Incident management and mandatory reporting
• Quality review and continuous improvement
• Staff management and supervision
• Regulatory compliance and audit response

6. Disclosure of Personal Information

6.1 Permitted Disclosures

CONVI may disclose participant information without additional consent where:

• The disclosure is to the NDIA, a plan manager, or a support coordinator acting in the participant's interest
• The participant has consented to sharing with a treating professional or other provider
• Disclosure is required by law (e.g., mandatory reporting, NDIS Commission investigation)
• There is a serious and imminent threat to life, health, or safety

6.2 Disclosures Requiring Separate Consent

CONVI will not disclose participant information to:

• Family members or carers without the participant's explicit consent (or nominee authorisation)
• Other service providers without a documented referral or information-sharing consent
• Any commercial or research entity
• Media or third parties

6.3 Worker Information

Worker personal information is shared only for employment purposes (payroll, superannuation, credential verification). CONVI does not disclose worker information to third parties except as required by law.

7. Information Security & Storage

CONVI stores all personal and sensitive information securely using Microsoft Dynamics 365 Business Central and associated Microsoft 365 services, which provide enterprise-grade security, access controls, and audit logging. Physical documents are stored securely and are not left accessible in common areas.

Access to participant information is restricted to authorised CONVI staff on a need-to-know basis. System access is controlled through individual user accounts with role-based permissions.

Information is not transmitted via SMS, social media, or unsecured email. CONVI uses Microsoft Teams and encrypted email for internal and participant communication involving personal data.

8. Records Retention & Disposal

CONVI retains records in accordance with applicable legislation and NDIS requirements. As a minimum:

• Participant service records are retained for seven (7) years following the end of the service relationship
• Records relating to a child participant are retained until the person turns 25 or for seven years, whichever is later
• Worker employment records are retained for seven (7) years following the end of employment

Records are disposed of securely. Physical documents are shredded. Digital records are permanently deleted from all systems including backups where practicable.

9. Participant Access to Their Information

Participants (and authorised nominees or guardians) have the right to request access to personal information held by CONVI. Requests should be made to the Director in writing.

CONVI will respond to access requests within 30 days. CONVI will not charge for access requests but may charge a reasonable administrative fee for large or complex requests.

CONVI may decline access in limited circumstances (e.g., where providing access would unreasonably affect the privacy of another individual, or where required by law). Any refusal will be explained in writing.

10. Accuracy & Correction

CONVI takes reasonable steps to ensure personal information is accurate, current, and complete. Participants and workers are encouraged to notify CONVI of any changes to their information promptly.

Requests to correct information should be made to the Director. CONVI will respond within 30 days.

11. Privacy Breaches

11.1 Identification

A privacy breach occurs when personal information is accessed, disclosed, lost, or altered in an unauthorised manner. All staff are required to report suspected privacy breaches to the Director immediately.

11.2 Response

CONVI will:

• Contain the breach (prevent further unauthorised access or disclosure)
• Assess the risk and impact on affected individuals
• Notify affected individuals where required or where it is in their interest
• Notify the Office of the Australian Information Commissioner (OAIC) if the breach is a Notifiable Data Breach under the Privacy Act
• Document the breach, response, and outcome
• Review systems and processes to prevent recurrence

12. Staff Obligations

All CONVI staff, contractors, and volunteers are required to:

• Handle personal and sensitive information only for authorised purposes
• Not disclose participant or worker information outside authorised channels
• Protect physical and digital records from unauthorised access
• Report suspected privacy breaches immediately to the Director
• Complete privacy training as part of induction and ongoing professional development

13. Complaints About Privacy

Any person who believes CONVI has mishandled their personal information may make a complaint to the Director at complaints@convi.au. CONVI will acknowledge the complaint within 5 business days and aim to resolve it within 30 days.

If the complaint is not resolved to the person's satisfaction, they may escalate to:

• Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au
• NDIS Quality and Safeguards Commission: 1800 035 544
• Health Complaints Commissioner (Vic): 1300 582 113

14. Privacy Officer

The Privacy Officer for CONVI is the Director. All privacy enquiries, access requests, and complaints should be directed to:

Alex Attard — Director, CONVI

Email: support@convi.au

Phone: +61 494 574 786

15. Policy Review

This policy is reviewed annually, or whenever relevant legislation, NDIS Practice Standards, or organisational circumstances change. Changes are version-controlled and authorised by the Director. All staff are notified of material changes.

This policy is an authoritative CONVI document. It supersedes any prior privacy guidance, informal practices, or undocumented understandings. Questions about the application of this policy should be directed to the Director.

16. Acknowledgement

Staff and contractors must acknowledge receipt and understanding of this policy as part of induction. Participants and nominees receive a summary of CONVI's privacy practices through the service agreement and Participant Handbook.

1. Purpose

This Code of Conduct defines the professional standards expected of everyone who works with or for CONVI. It gives clarity about how staff are expected to behave — with participants, with each other, with families, and with external organisations.

The Code is not aspirational. It describes the minimum standard of professional conduct required to work at CONVI. Anything below this standard has consequences.

2. The NDIS Code of Conduct

The NDIS Code of Conduct applies to all NDIS providers and their workers — registered and unregistered. Every CONVI worker is personally bound by the NDIS Code of Conduct, which requires workers to:

• Act with respect for individual rights to freedom of expression, self-determination, and decision-making in accordance with applicable laws and conventions
• Respect the privacy of people with disability
• Provide supports and services in a safe and competent manner, with care and skill
• Act with integrity, honesty, and transparency
• Promptly take steps to raise and act on concerns about matters that might have an impact on the quality and safety of supports provided to people with disability
• Take all reasonable steps to prevent and respond to all forms of violence, exploitation, neglect, and abuse of people with disability
• Take all reasonable steps to prevent and respond to sexual misconduct

Breaches of the NDIS Code of Conduct may be reported to and investigated by the NDIS Quality and Safeguards Commission, with potential consequences including prohibition from working in the disability sector.

3. CONVI Professional Standards

3.1 Participant-Centred Conduct

Every interaction with a participant must reflect:

• Genuine respect for the participant's dignity, culture, identity, and autonomy
• Recognition that participants direct their own support — workers do not make decisions for participants without their agreement
• Patience and consistency, regardless of the participant's behaviour or communication style
• Honesty — never promising outcomes you cannot deliver or making statements you cannot stand behind
• Sensitivity to vulnerability — recognising that participants are placing trust in CONVI and its workers

3.2 Boundaries

Professional boundaries are non-negotiable. Workers must not:

• Develop personal, romantic, or financial relationships with participants or their immediate families
• Accept gifts of more than nominal value (items under $20 are acceptable with Director awareness)
• Share personal contact details (personal phone numbers, personal email, home address)
• Attend a participant's home or community in a personal capacity outside scheduled work hours
• Discuss personal problems, relationships, or financial matters with participants
• Use participant information or access for personal benefit

Boundary violations — even those initiated by a participant — must be reported to the Director immediately. Reciprocating or concealing a boundary violation compounds the seriousness of the issue.

3.3 Communication Standards

All communication in relation to CONVI business must:

• Occur through CONVI-approved channels (email, Microsoft Teams, phone via CONVI work number)
• Never occur via personal SMS, WhatsApp, Facebook, or other unofficial channels
• Be professional in tone — not casual, personal, or informal in a way that blurs professional distance
• Protect participant privacy — no case discussions in public settings or with unauthorised parties
• Be documented where it relates to participant care, incidents, or decisions

3.4 Honesty & Integrity

CONVI workers are expected to act with complete honesty in all work-related matters. This includes:

• Accurately recording delivery, time, and evidence — never inflating hours or fabricating notes
• Reporting incidents, near misses, and concerns promptly and truthfully
• Disclosing conflicts of interest before they affect decisions
• Not making claims about qualifications, experience, or capacity that are false or misleading
• Not entering into any financial arrangement with a participant (e.g., lending or borrowing money)

3.5 Reporting Obligations

Workers must report to the Director — promptly and without delay:

• Any incident, near miss, or safety concern during or related to a session
• Any concern about a participant's safety, welfare, or living situation
• Any behaviour by another worker that appears to breach this Code
• Any criminal charge, conviction, or investigation involving the worker themselves
• Any relationship, financial interest, or other conflict that may affect their objectivity
• Any adverse finding by the NDIS Commission or other regulatory body

3.6 Conduct in the Community

CONVI workers are representatives of the organisation in the community. Workers must:

• Behave professionally in all settings where they are identifiable as a CONVI worker
• Not consume alcohol or be under the influence of any substance during work hours or immediately before a shift
• Not smoke during a session or at a participant's property (including grounds)
• Dress appropriately for the support context — clean, safe, and respectful of participant and cultural expectations

4. Social Media & Technology

Workers must not:

• Post any content related to participants, their families, or their situations on social media — including indirect or anonymised posts that could identify a participant
• Connect with participants or their families on personal social media accounts
• Use CONVI or participant information for personal content creation
• Record, photograph, or film participants without explicit written consent

CONVI's social media presence is managed by the Director. Workers do not represent CONVI publicly without authorisation.

5. Conflict of Interest

A conflict of interest exists where a worker's personal interests could influence — or appear to influence — their professional decisions. Workers must:

• Disclose actual or potential conflicts of interest to the Director before they affect decisions
• Withdraw from any decision where a conflict exists
• Not use CONVI relationships or access to participant information for personal or commercial gain

6. Workplace Conduct

CONVI maintains a workplace free from harassment, discrimination, bullying, and intimidation. This applies to interactions between workers, and interactions with participants and their families. Workers who experience or witness such conduct should report it to the Director immediately.

CONVI does not tolerate:

• Harassment or discrimination on any basis (disability, age, gender, race, religion, sexuality, or any other protected attribute)
• Bullying — repeated unreasonable behaviour directed at a worker
• Intimidation, threats, or coercion
• Victimisation of anyone who raises a concern or complaint in good faith

7. Consequences of Breach

Breaches of this Code are taken seriously. Consequences are proportionate to the severity of the breach and may include:

• Verbal or written caution
• Formal warning
• Suspension pending investigation
• Termination of employment or engagement
• Referral to the NDIS Commission or relevant professional body
• Referral to police where a criminal act has occurred or is suspected

Some breaches — particularly those involving participant harm, dishonesty in records, or serious boundary violations — may result in immediate termination without prior warning, and mandatory referral to the NDIS Commission.

8. Acknowledgement (Required)

All CONVI workers must sign this acknowledgement upon commencement and whenever a new version of this Code is issued.

I have read and understood the CONVI Code of Conduct (POL-02 v1.0). I understand that this Code represents the minimum professional standard required for my role at CONVI. I agree to comply with its requirements and to raise any questions or concerns with the Director.

1. Purpose & Philosophy

CONVI treats complaints and feedback as a direct line of sight into how well services are working. A complaint is not a failure — it is information. An organisation that does not receive complaints is not providing a safe environment for them; it is not an organisation free of problems.

This policy ensures that every person who has a concern about CONVI's services has a clear, supported pathway to raise it — and that CONVI responds in a way that is fair, prompt, and transparent.

This policy aligns with the NDIS Practice Standards (Core Module — Rights and Responsibilities) and the NDIS Code of Conduct requirement that providers take reasonable steps to act on complaints.

2. Scope

This policy applies to complaints and feedback about:

• Any aspect of support delivery by CONVI staff or contractors
• The conduct or behaviour of any CONVI worker
• CONVI's administrative or billing processes
• Any decision made by CONVI that affects a participant
• The quality, safety, or appropriateness of supports

3. Who Can Make a Complaint

Any of the following may raise a complaint with CONVI:

• A participant currently or previously receiving CONVI supports
• A parent, carer, guardian, or nominee acting on behalf of a participant
• A support coordinator or plan manager representing a participant
• A member of the public with a genuine concern about CONVI's services
• A CONVI worker (regarding workplace conduct or service quality concerns)

No person will be disadvantaged, penalised, or treated differently for making a complaint in good faith. Raising a concern is actively encouraged.

4. How to Make a Complaint

4.1 CONVI Complaint Channels

Complaints may be made through any of the following channels:

• In person: directly to the Director or designated staff member
• Email: complaints@convi.au (subject line: Complaint — [brief description])
• Phone: +61 494 574 786
• Written letter addressed to the Director, CONVI

If a participant needs assistance to make a complaint (e.g., due to communication needs), CONVI will support them to do so — including engaging a support person, interpreter, or advocate of their choosing.

4.2 Anonymous Complaints

Anonymous complaints are accepted. CONVI will investigate where sufficient information is provided, noting that resolution and follow-up may be limited where the complainant cannot be contacted.

5. CONVI's Response Standards

5.1 Acknowledgement

CONVI will acknowledge every complaint within 2 business days of receipt. Acknowledgement will:

• Confirm the complaint has been received
• Provide the name of the person managing the complaint
• Outline the expected timeframe for resolution
• Advise of the right to external escalation at any stage

5.2 Investigation

CONVI will conduct a fair, impartial, and thorough investigation of every complaint. The Director is responsible for complaints investigation unless they are directly implicated, in which case an independent reviewer will be appointed.

Investigation will involve:

• Reviewing all relevant records, documentation, and evidence
• Speaking with the complainant and relevant staff members
• Assessing whether service delivery met CONVI's standards and the NDIS Code of Conduct
• Identifying what occurred, why, and what should happen as a result

5.3 Resolution Timeframes

If a complaint will take longer than 30 days to resolve, the complainant will be kept informed with regular updates.

5.4 Outcomes

At the conclusion of investigation, CONVI will provide the complainant with:

• A clear explanation of findings
• What action CONVI has taken or will take in response
• Any changes made to services, processes, or staff conduct as a result
• Information about how to seek external review if they are not satisfied

6. External Escalation Rights

At any stage, a complainant may escalate their concern externally. Making a complaint directly with CONVI is not a precondition of external escalation, though CONVI encourages giving it the opportunity to resolve matters first.

External bodies include:

NDIS Quality and Safeguards Commission

• Phone: 1800 035 544
• Web: www.ndiscommission.gov.au
• Role: Complaints about registered and unregistered NDIS providers

National Disability Abuse and Neglect Hotline

• Phone: 1800 880 052
• Role: Reports of abuse, neglect, or exploitation of people with disability

Victorian Disability Services Commissioner

• Phone: 1800 677 342
• Web: www.odsc.vic.gov.au
• Role: Complaints about disability service providers in Victoria

Office of the Australian Information Commissioner (privacy-related complaints)

• Web: www.oaic.gov.au

7. Complaints Involving Allegations of Abuse, Neglect, or Exploitation

Where a complaint involves an allegation of abuse, neglect, financial exploitation, or a restriction on a participant's rights, CONVI will treat the matter as a potential NDIS reportable incident and apply the Incident Management Policy (POL-04) in addition to this policy.

Allegations of this nature will be escalated to the NDIS Commission and/or relevant authorities as required by law and NDIS Rules, regardless of whether an internal investigation is also underway.

8. Record Keeping

CONVI maintains a secure complaints register documenting:

• Date received and acknowledgement date
• Nature and category of complaint
• Parties involved
• Actions taken during investigation
• Outcome and resolution
• Any systemic improvements identified

Complaints records are retained for a minimum of seven (7) years. They are reviewed quarterly by the Director for patterns, systemic risks, and improvement opportunities.

9. Staff Conduct During Complaints Processes

All CONVI staff involved in a complaints process are required to:

• Cooperate fully and honestly with investigation
• Not attempt to influence the complainant or other witnesses
• Not access, alter, or destroy records relevant to the complaint
• Maintain confidentiality about the complaint and those involved
• Continue to deliver professional, unbiased services to the participant during the process

Retaliation against a person making a complaint, or against a worker participating in a complaints investigation, is a serious breach of CONVI's Code of Conduct and may result in disciplinary action including termination.

10. Continuous Improvement

Every resolved complaint is reviewed to identify whether it signals a systemic issue requiring a policy, process, or training response. Recurring complaint themes are formally reviewed and addressed within 60 days of identification.

CONVI's complaints trends are reviewed annually as part of the policy review cycle and inform the continuous improvement register.

11. Policy Review

This policy is reviewed annually or following any complaint that reveals a significant gap in the policy's provisions. Changes are version-controlled, authorised by the Director, and communicated to all staff.

1. Purpose

CONVI has a zero tolerance approach to preventable harm and a clear obligation to respond to and report incidents in accordance with the NDIS framework and Victorian law. This policy tells workers and the Director what constitutes a reportable incident, what must happen in each scenario, and how CONVI distinguishes genuine reportable obligations from routine operational events.

2. Definitions

3. What Is a Reportable Incident

CRITICAL PRINCIPLE: A reportable incident must be connected to CONVI's provision of supports or services. Events that occur independently of CONVI's involvement follow the safeguarding obligations in Section 5, not the reportable incident pathway.

The following are reportable incidents under the NDIS Rules where they occur in connection with CONVI's service delivery:

4. Pre-Existing Injuries — What to Do

Scenario: Worker Arrives and Discovers a Participant Has an Injury from a Prior Period

Where a worker arrives for a session and observes an injury on a participant that did not occur during CONVI's service delivery:

• This is NOT a reportable incident under the NDIS Rules — the event did not occur in connection with CONVI's service delivery.
• However — assess whether the injury raises a safeguarding concern. Ask: Is this injury unexplained? Is the participant's account inconsistent or implausible? Are there other signs of harm, neglect, or an unsafe home environment?
• If YES — this triggers CONVI's safeguarding obligations under POL-07 and, for child participants, mandatory reporting obligations under Section 7 of this policy. Contact the Director immediately.
• If NO reasonable safeguarding concern — document the observation factually in the session note (what you observed, what explanation was given, if any) and notify the Director at the end of the session. Do not diagnose, speculate, or assign blame in the note.
• Deliver or proceed with the session based on the participant's condition and consent. If the participant is in acute pain or distress, provide first aid if trained and facilitate appropriate support (contact family, GP, emergency services if required).

When in doubt about whether an observed injury raises a safeguarding concern — call the Director before proceeding. It is always better to over-escalate than to leave a concern undocumented.

5. Immediate Response — All Incidents

6. Unexplained Absence — Critical Distinction

This section exists because "unexplained absence" is a reportable incident type — but it does not apply to every no-show, forgotten session, or avoidance behaviour. The distinction is important and workers must understand it.

6.1 NOT a Reportable Incident — Routine No-Show or Avoidance

The following are NOT unexplained absences requiring Commission notification:

• Participant texts to cancel before the worker arrives
• Participant does not answer the door but can be reached by phone or through a family member
• Pattern behaviour — participant regularly forgets, avoids, or declines sessions without prior notice
• Worker arrives, participant is not home, family member or carer confirms the participant is safe and has simply gone out or forgotten the session
• Any situation where the participant's safety is not in question

Document these as no-shows or short notice cancellations per SOP-SD-03. Apply cancellation billing rules if applicable. No Commission notification is required.

6.2 IS a Reportable Incident — Genuine Safety Concern

An unexplained absence becomes a reportable incident when ALL of the following apply:

• The participant is known to have been at or near the residence and cannot be located
• Attempts to contact the participant and their emergency contacts have failed
• There is genuine, reasonable concern for the participant's immediate safety based on their known history, presentation, or circumstances

Examples of scenarios that trigger the reportable absence pathway:

• A participant with active suicidal ideation or a recent self-harm episode does not answer the door and cannot be reached — no one knows where they are
• A participant with ASD who cannot self-manage in the community is not at home and has been missing for an extended period with no explanation
• A participant with known elopement risk is not present and family members are also unable to locate them

Response steps for a genuine unexplained absence:

• Search the immediate vicinity — call the participant's name
• Contact all emergency contacts from the participant's Emergency Management Plan (PART-08)
• If not located within 10 minutes of arrival — call 000 and report as a missing person
• Notify Director immediately: +61 494 574 786
• Notify the NDIS Commission within 24 hours as a reportable incident — per SOP-INC-01 and SOP-INC-02

7. Mandatory Reporting — Child Participants

Mandatory reporting is a personal legal obligation under the Children, Youth and Families Act 2005 (Vic). It operates independently of the NDIS reportable incident framework. Where a worker forms a reasonable belief that a child participant has been, or is at risk of being, abused or neglected:

• Call Child Protection immediately: 131 278 (business hours) | 13 12 78 (after hours)
• You do not need Director authorisation before calling. The obligation is personal and immediate.
• Notify the Director on the same day — after the report has been made, not instead of making it
• Document the report in the session note: date, time, Child Protection officer's name, reference number

Mandatory reporting obligations are separate from NDIS reportable incidents. Both may apply to the same event. For the detailed mandatory reporting guide, see HR-12 — Mandatory Reporting Obligations Training Document.

8. NDIS Commission Notification

Reportable incidents under Section 3 must be notified to the NDIS Commission within 24 hours of CONVI becoming aware. The 24-hour clock starts from when the Director (or any CONVI representative) became aware — not from when the incident occurred.

Initial notification and written report (within 5 business days) are governed by SOP-INC-01 and SOP-INC-02. These SOPs contain the step-by-step portal submission process.

9. Worker Support Following an Incident

• Director offers a debrief within 24 hours of any significant incident
• Employee Assistance Program (EAP) available to all CONVI workers — details provided in employment documentation
• Workers are never penalised for reporting an incident in good faith
• Concealing an incident, providing a false account, or tampering with records is a serious breach of the Code of Conduct (POL-02) and grounds for termination and possible Commission referral

10. Related Documents

• SOP-INC-01 — Incident Response, Reporting & Review (step-by-step execution)
• SOP-INC-02 — Critical Incident — NDIS Commission Notification (portal submission)
• POL-06 — Child Safe Policy
• POL-07 — Safeguarding & Abuse Prevention Policy
• HR-12 — Mandatory Reporting Obligations Training Document
• PART-08 — Emergency Management & Escalation Plan (per participant)

1. Purpose & Commitment

CONVI is committed to providing a safe working environment for all workers, participants, and visitors. This commitment operates within the reality that disability support is delivered in people's homes and community settings — environments that are inherently variable and cannot be controlled like a fixed workplace. CONVI's WHS approach is proportionate: robust where the risk is real, practical where the risk is low.

2. Legislative Framework

This policy operates under the Occupational Health and Safety Act 2004 (Vic) and OHS Regulations 2017. CONVI's duties include: providing and maintaining safe systems of work, identifying and controlling hazards, and providing information, instruction, supervision, and training.

3. Hazard Identification & Control

Hazards are identified and managed at the participant level through the Participant Risk Assessment (PART-05), which is completed before the first session and reviewed at minimum every six months. The Risk Assessment covers: home environment hazards, participant-specific risks, manual handling, and emergency procedures.

Workers are required to report any new or changing hazards to the Director immediately — not at the next scheduled contact. If a hazard is assessed as creating immediate risk, the session is suspended until the hazard is controlled.

4. Lone Worker Safety

Support workers at CONVI typically work alone with participants — this is normal operating practice, not an exception. The lone worker protocol is proportionate to risk, not applied uniformly to every shift.

4.1 Standard Session Protocol (Most Sessions)

For standard support sessions where no heightened risk indicator is documented in the Participant Risk Assessment:

• Worker logs shift start time in Microsoft Teams Shifts at session commencement
• Worker logs shift end time in Teams Shifts at session conclusion
• Worker contacts Director immediately by phone if any safety concern arises during the session

The Teams Shifts record constitutes the lone worker check-in for standard sessions. No additional mid-session contact is required.

4.2 Heightened Risk Protocol (Specific Participants Only)

Where a Participant Risk Assessment (PART-05) documents a specific lone worker safety concern — for example, a participant with a history of aggressive behaviour, a participant in active mental health crisis, or a session in an isolated location — the Risk Assessment will specify an additional protocol. This is participant-specific and documented. It applies to that participant only and is not a blanket requirement.

4.3 Worker Right to Withdraw

A worker always has the right to withdraw from a session or environment they have assessed as unsafe. The worker:

• Ensures the participant's immediate safety before withdrawing (stays in a safe distance, contacts family/emergency services if required)
• Contacts the Director immediately by phone
• Does not return to that session or environment until the Director confirms it is safe to do so

Workers are never penalised for withdrawing from an unsafe situation in good faith. If a worker is subsequently told they should have stayed — that direction is wrong and should be reported to the Director in writing.

5. Manual Handling

Manual handling assistance (transfers, repositioning, physical assistance with mobility) is only delivered by workers who have completed relevant training appropriate to the task. The Participant Risk Assessment documents manual handling requirements and equipment for each participant. Workers do not assist with physical activities beyond their training and the documented support plan without Director authorisation.

6. Worker Wellbeing & Psychosocial Safety

Disability and mental health support is emotionally demanding work. CONVI takes worker wellbeing seriously and provides:

6.1 Debrief After Difficult Incidents

Any worker who experiences a difficult, distressing, or traumatic incident during service delivery is offered a debrief with the Director within 24 hours. This is not optional — the Director will initiate it.

6.2 Supervision

Regular formal supervision (monthly during probation, minimum quarterly ongoing — see HR-10) provides a structured opportunity to discuss workload, wellbeing, challenging cases, and professional development.

6.3 Wellbeing Resources

CONVI provides access to the following wellbeing and mental health support resources:

CONVI intends to engage a formal Employee Assistance Program (EAP) as the team grows. Many Management Liability insurance policies include EAP access — check with the insurance broker at renewal. Until a formal EAP is in place, the resources above are the primary wellbeing referral pathway.

6.4 No Adverse Action for Wellbeing Concerns

Workers who raise a wellbeing concern, request a debrief, or access support resources will not be penalised, disadvantaged, or have their employment affected. Psychological safety at work is a legal obligation under Victorian OHS law and a CONVI commitment.

7. Incident Reporting

Workers report all work-related injuries, incidents, and near misses to the Director immediately. Workers' compensation obligations are governed by WorkSafe Victoria. Serious workplace injuries must be notified to WorkSafe. See POL-04 for the full incident reporting framework.

1. Commitment Statement

CONVI is committed to the safety, wellbeing, and protection of all children who access its services. This commitment is not conditional — it applies in every context, at every stage of service delivery.

CONVI recognises that children with disability are at heightened risk of abuse, neglect, and exploitation and that this risk is increased in environments where professional boundaries are unclear, oversight is low, or reporting culture is weak. This policy directly addresses those risk factors.

Every child who comes into contact with CONVI has the right to feel safe, to be treated with dignity and respect, and to have their concerns taken seriously.

2. Legislative Framework — Victoria

This policy is implemented in compliance with:

• Child Wellbeing and Safety Act 2005 (Vic) — Child Safe Standards (Ministerial Order 1359, effective January 2023)
• Working with Children Act 2005 (Vic) — Working with Children Check requirement
• Children, Youth and Families Act 2005 (Vic) — mandatory reporting obligations
• NDIS Practice Standards — Safeguarding requirements
• NDIS Code of Conduct — obligations to provide safe and respectful support

3. Child Safe Standards — Victoria

The Victorian Child Safe Standards require organisations working with children to embed child safety into their culture, governance, and operations. CONVI implements the following standards:

Standard 1: Organisations establish a culturally safe environment in which the diverse and unique identities and experiences of Aboriginal children and young people are respected and valued.

Standard 2: Child safety and wellbeing is embedded in organisational leadership, governance, and culture.

Standard 3: Children and young people are empowered about their rights, participate in decisions affecting them, and are taken seriously.

Standard 4: Families and communities are informed and involved in promoting child safety and wellbeing.

Standard 5: Equity is upheld and diverse needs are taken into account in policy and practice.

Standard 6: People working with children and young people are suitable and supported to reflect child safety and wellbeing values in practice.

Standard 7: Processes for complaints and concerns are child-focused.

Standard 8: Staff and volunteers are equipped with the knowledge, skills, and awareness to keep children and young people safe through ongoing education and training.

Standard 9: Physical and online environments minimise the opportunity for abuse or harm to occur.

Standard 10: Implementation of the Child Safe Standards is regularly reviewed and improved.

Standard 11: Policies and procedures document how the organisation is safe for children and young people.

4. Screening Requirements

4.1 Working with Children Check (WWCC)

Every CONVI staff member, contractor, or volunteer who has direct contact with a child participant must hold a current Working with Children Check (employee card) issued by the Victorian Department of Justice.

The WWCC must be:

• Verified before any worker begins direct contact with a child participant
• Current at all times (monitored via CONVI's credential tracking system)
• An employee-type card (not volunteer) for paid workers
• Renewed before expiry — CONVI provides 30-day and 7-day advance alerts

Delivering any support to a child participant without a current WWCC is a serious breach of this policy and Victorian law. There are no exceptions.

4.2 NDIS Worker Screening Check

All CONVI workers must also hold a current NDIS Worker Screening Check. This is a separate requirement from the WWCC and must be maintained concurrently.

5. Code of Conduct for Working with Children

All CONVI workers interacting with children must:

• Treat every child with dignity, respect, and sensitivity to their individual needs
• Communicate with children in age-appropriate language that they can understand
• Maintain clear professional boundaries at all times
• Avoid physical contact that is not necessary, consented, or culturally appropriate
• Never be alone with a child in a closed, private environment without a parent, carer, or second worker present (where practicable)
• Never share personal contact details (personal phone, email, social media) with a child participant
• Never communicate privately with a child via social media or personal messaging apps
• Never photograph or film a child without explicit written consent from a parent, guardian, or nominee
• Report immediately any behaviour by another worker that raises child safety concerns

6. Recognising & Responding to Child Safety Concerns

6.1 Signs of Abuse or Neglect

Workers are trained to recognise indicators of potential abuse or neglect, including:

• Unexplained physical injuries or marks
• Significant changes in behaviour or emotional state
• Expressions of fear, withdrawal, or distress in relation to a specific person or environment
• Disclosures — direct or indirect — of abuse or harm
• Neglect of basic needs (hygiene, nutrition, clothing)

6.2 If a Child Discloses Abuse

If a child discloses abuse or harm, the worker must:

• Listen calmly and without interrupting
• Acknowledge what the child has shared without making promises you cannot keep
• Do not investigate further, seek detailed information, or express disbelief
• Notify the Director immediately (same day)
• Document what was said, in the child's words, as accurately as possible
• If there is immediate danger, call 000

Never promise a child that you will keep what they have told you a secret. A child disclosing abuse requires that the information be shared with appropriate people.

6.3 Mandatory Reporting Obligation

Under the Children, Youth and Families Act 2005 (Vic), workers who provide health, disability, or education services to children are mandatory reporters. This means that if a worker forms a reasonable belief that a child has suffered or is at risk of suffering child abuse (including physical abuse, sexual abuse, serious emotional or psychological harm, or serious neglect), they must report to:

Child Protection — Department of Families, Fairness and Housing

Phone: 131 278 (business hours) | 13 12 78 (after hours)

This obligation is personal. It cannot be delegated. A worker is not required to tell their employer before making a report, though they should notify the Director as soon as practicable.

7. Family & Carer Involvement

CONVI actively involves parents, carers, and nominees in decisions about how supports are delivered. Families receive clear information about:

• What workers will do and won't do in session
• How to raise a concern or make a complaint
• Their child's rights under the NDIS and CONVI's Child Safe Policy
• CONVI's communication standards and channels

8. Safe Physical & Online Environments

CONVI takes practical steps to minimise opportunity for harm:

• Sessions with children are scheduled with parental/carer awareness of location, duration, and worker
• Support workers do not transport children without explicit written consent from a parent or guardian
• CONVI does not use informal communication channels (SMS, WhatsApp, personal social media) with child participants or their families
• Any change to a child's scheduled arrangement is communicated to the family before it occurs

9. Complaints Involving Children

Complaints involving the safety or wellbeing of a child participant are escalated immediately to the Director and treated as critical matters. The Complaints Policy (POL-03) and Incident Management Policy (POL-04) are applied together with this policy.

Where a complaint involves an allegation of abuse or harm by a CONVI worker, the worker is suspended from contact with children pending investigation. This is a protective measure — not a finding of guilt.

10. Training & Awareness

All CONVI staff complete child safety training as part of induction and annually thereafter. Training covers:

• Recognising signs of abuse and neglect
• Mandatory reporting obligations and process
• Professional boundaries with child participants
• CONVI's Code of Conduct for working with children
• How to respond to a child's disclosure

11. Policy Review

This policy is reviewed annually or when changes occur to Victorian Child Safe Standards, relevant legislation, or CONVI's service delivery model. Reviews are documented and actioned by the Director.

1. Purpose & Commitment

CONVI has a zero-tolerance position on abuse, neglect, exploitation, and any violation of participant rights. This policy establishes how CONVI prevents, identifies, and responds to safeguarding concerns — including those arising from the conduct of CONVI workers.

People with disability are disproportionately affected by abuse, neglect, and exploitation. CONVI recognises that this risk is heightened in environments where power imbalances exist, oversight is limited, and reporting is discouraged. CONVI actively designs against these conditions.

2. Definitions

3. Types of Abuse & Neglect Recognised

3.1 Physical Abuse

Any non-accidental act that causes physical harm — including hitting, restraining, overmedication, or inappropriate physical intervention.

3.2 Sexual Abuse & Misconduct

Any sexual act or behaviour directed at a participant without full, informed, and freely given consent. This includes any sexual conduct between a worker and participant regardless of apparent consent, which is always prohibited given the power imbalance inherent in the worker-participant relationship.

3.3 Emotional & Psychological Abuse

Actions or words that cause psychological harm — including intimidation, threats, humiliation, isolation, and control.

3.4 Financial Abuse & Exploitation

Unauthorised use of a participant's money, property, or resources — including coercing a participant to give gifts, money, or access to their accounts.

3.5 Neglect

Failure to provide adequate food, water, shelter, supervision, medical care, or personal care that a participant requires and CONVI has agreed to provide.

3.6 Restrictive Practices

Under the NDIS Rules, any use of a restrictive practice must be authorised in accordance with state/territory law and the NDIS Rules. CONVI does not use any restrictive practice without explicit authorisation, a current behaviour support plan, and appropriate training. Any use of an unauthorised restrictive practice is a reportable incident.

4. Prevention — How CONVI Designs Against Abuse

4.1 Pre-Employment Screening

Every person working with CONVI participants must, before commencing:

• Hold a current NDIS Worker Screening Check (clearance — not just application)
• Hold a current Working with Children Check where working with child participants
• Provide references that are verified by the Director
• Acknowledge and sign the Code of Conduct (POL-02)
• Complete CONVI's induction including safeguarding training

4.2 Supervision & Oversight

• All workers receive regular formal supervision with the Director
• The Director conducts unannounced reviews of documentation for quality and integrity
• Workers are never isolated from CONVI oversight — the Director is contactable at all times during work hours

4.3 Participant Empowerment

• Participants are informed of their rights at intake and through the Participant Handbook
• The complaints process is explained clearly and participants are supported to use it
• Participants are encouraged to have a trusted person involved in service reviews

4.4 Professional Boundaries

CONVI's Code of Conduct (POL-02) establishes strict professional boundaries that reduce opportunity for abuse. Key boundaries include: no personal financial dealings with participants, no private communication channels, no alone time with child participants in enclosed spaces without appropriate oversight.

5. Identifying Safeguarding Concerns

Workers must be alert to signs that a participant may be experiencing abuse or neglect — including:

• Unexplained injuries, bruising, or physical changes
• Signs of malnutrition, poor hygiene, or inadequate clothing or shelter
• Significant changes in behaviour, mood, or engagement
• Expressions of fear about a specific person or environment
• Direct or indirect disclosures of abuse or harm
• Evidence of financial stress or exploitation
• Withdrawal from family, friends, or activities they previously enjoyed

Workers must not wait for certainty before reporting a concern. A reasonable belief is sufficient. Acting on a genuine concern that turns out to be unfounded is far less harmful than failing to report abuse.

6. Reporting a Safeguarding Concern

6.1 Internal Reporting

• Report to the Director immediately — same day, same hour for urgent concerns
• Document what was observed or disclosed in factual, objective language
• Do not investigate independently, confront the alleged perpetrator, or discuss with other workers
• The Director will determine the required response and notifications

6.2 External Reporting

Depending on the nature and urgency of the concern, reporting may be required to:

• NDIS Commission: 1800 035 544 (reportable incidents within 24 hours)
• Victoria Police: 000 (immediate danger) or 131 444 (non-urgent)
• Child Protection (DFFH): 131 278 — where the concern involves a child
• National Disability Abuse and Neglect Hotline: 1800 880 052

Workers are never required to obtain Director approval before calling 000 or reporting to Child Protection. Safety comes first. Report to the Director as soon as it is safe to do so.

6.3 If the Alleged Perpetrator Is a CONVI Worker

Where the concern involves a CONVI worker:

• The Director immediately suspends the worker from all participant contact pending investigation
• This is a protective measure — not a finding of guilt
• The Director manages the NDIS Commission notification
• An independent investigation process is applied
• Affected participant(s) are supported and informed as appropriate

7. Restrictive Practices

CONVI does not authorise the use of restrictive practices without:

• A current behaviour support plan prepared by an NDIS-registered Behaviour Support Practitioner
• Approval from the NDIS Commission and compliance with Victorian state authorisation processes (Senior Practitioner approval for regulated restrictive practices)
• Specific training for each worker who may be involved
• Written consent from the participant or their authorised representative

Any use of a restrictive practice that is not authorised under these conditions is a reportable incident and will be immediately notified to the NDIS Commission.

8. Whistleblower Protection

A worker who reports a safeguarding concern in good faith is protected from retaliation. CONVI does not and will not penalise, disadvantage, or dismiss a worker for raising a genuine safeguarding concern — even if the concern is ultimately not substantiated.

Any retaliation against a worker who reports a concern is itself a serious breach of the Code of Conduct and may be referred to the NDIS Commission.

9. Policy Review

This policy is reviewed annually and following any safeguarding incident. The Director is responsible for ensuring all workers are trained on this policy at induction and whenever it is significantly updated.

1. Purpose

Medication management is a high-risk activity in disability support. Errors can cause serious harm. This policy defines the conditions under which CONVI workers may assist with medications, what that assistance looks like, and what must be documented. It protects participants from harm and workers from liability.

CONVI workers do not administer medications independently. All medication assistance occurs within a clear, documented authority framework. When in doubt — do not proceed. Call the Director.

2. Levels of Medication Assistance

CONVI workers only operate at the level explicitly authorised in the participant's Support Plan and as consistent with their training. A worker is never required to operate at a level beyond their training or authority.

3. Authority Requirements

Before any medication assistance occurs:

• The participant's Support Plan or Health Action Plan must explicitly describe the level of assistance authorised
• The treating medical practitioner or prescriber must have been involved in the care plan where Level 3 or Level 4 assistance applies
• The participant (or their nominee/guardian) must have consented to medication assistance from CONVI workers
• The worker must have completed the relevant training for the level of assistance required

CONVI does not provide Level 4 medication administration (administering medications to a participant who cannot self-administer) without: specific worker training, a current Medication Administration Plan signed by a prescriber, and Director approval. This is a High Intensity support activity.

4. Medication Documentation Requirements

For every medication assistance interaction, the worker records in the BC session note (Project Notes):

• Medication name(s) and dose(s) involved
• Level of assistance provided
• Participant response (no adverse response, or describe any observed reaction)
• Time administered / time prompt provided
• Any refusals, missed doses, or variations — and the outcome

CONVI does not maintain a Medication Administration Record (MAR) for standard prompting and assisted self-administration — this remains the responsibility of the participant's medical team and family/care network. For Level 4 administration, a separate MAR is maintained by the participant's prescribing team and CONVI records its role as directed.

5. Medication Storage

CONVI workers must confirm that medications are stored appropriately at the participant's home:

• Medications requiring refrigeration are stored in a suitable fridge — not with food
• Medications that are dangerous in overdose are stored securely — not accessible to children or other household members
• Medications are in original packaging with current prescription labels

If a worker identifies an unsafe medication storage situation, they report this to the Director the same day. The Director escalates to the participant's GP or nominee as appropriate.

6. Medication Errors

A medication error includes: administering the wrong medication, wrong dose, wrong time, wrong participant, or missed dose where administration was required. If a medication error occurs or is suspected:

• Stop. Do not administer further medication.
• Assess the participant for immediate adverse effects — call 000 if any concern
• Notify the Director immediately: +61 494 574 786
• Notify the participant's emergency contact
• Contact the participant's GP or the Poisons Information Centre: 13 11 26
• Document the error accurately and completely in the BC incident log — same day
• Director assesses whether NDIS Commission notification is required

Do not delay reporting a medication error for any reason. The participant's safety is the only priority.

7. Medication Refusal

If a participant with capacity refuses medication, the worker respects the refusal. Capacity to refuse is assumed unless a legal determination says otherwise. The worker documents the refusal in the session note and notifies the Director where the medication is prescribed for a serious condition.

If a participant without capacity refuses, or if a participant's behaviour puts them at risk of harm from medication refusal, the Director is notified immediately and the matter is escalated to the participant's GP, nominee, or clinical team.

8. PRN (As-Needed) Medications

PRN medications may only be prompted or administered when:

• A clear prescriber instruction exists defining when the PRN is to be used and at what dose
• The worker has been trained on the specific PRN and its indications
• The Support Plan authorises the worker's role in PRN management

Workers do not independently decide to administer PRN medications based on their own clinical judgement. They follow the documented criteria. If the situation is unclear — call the Director.

9. Policy Review

Reviewed annually or when: a participant's medication needs change, a medication error occurs, or legislative/clinical guidelines are updated.

1. Purpose

CONVI delivers support in participants' homes and community settings — environments where infection transmission is a real risk, particularly for participants with disability or complex health needs. This policy establishes standard infection control precautions that all workers must apply in all support settings, regardless of whether an infection is known to be present.

2. Standard Precautions — Always Apply

Standard precautions assume that any person may carry an infection and take steps to prevent transmission regardless. These precautions apply in every session:

2.1 Hand Hygiene

Hand hygiene is the single most effective infection control measure. Workers must:

• Wash hands with soap and water for minimum 20 seconds: before and after personal care, after contact with body fluids, after removing gloves, before handling food, and before and after medication assistance
• Use alcohol-based hand sanitiser (minimum 60% alcohol) when soap and water are not available
• Not wear hand jewellery (rings, bracelets) during personal care activities
• Keep fingernails short and clean

2.2 Personal Protective Equipment (PPE)

Gloves are single-use. Never wash and reuse gloves. Remove gloves before touching non-contaminated surfaces. Wash hands after removing gloves.

2.3 Sharps Safety

Workers rarely encounter sharps in disability support settings. If a participant uses insulin pens, lancets, or other sharps:

• Never recap a needle after use
• Participants who self-administer are responsible for their own sharps disposal
• Where CONVI workers assist with sharps disposal, a sharps container must be provided by the participant's medical team
• Needlestick injury: wash immediately with running water, do not squeeze, report to Director immediately, seek medical advice same day

2.4 Body Fluid Spillage

Where body fluid is spilled on surfaces:

• Put on gloves
• Absorb spill with disposable paper towel and dispose in sealed bag
• Clean surface with household detergent and water
• Disinfect with diluted bleach solution (1:10) or appropriate disinfectant
• Remove gloves and wash hands thoroughly

3. Worker Health — When Not to Work

Workers must not attend work if they have symptoms of an infectious illness that could be transmitted to a vulnerable participant. This includes:

• Fever (temperature above 37.5°C or subjective fever)
• Diarrhoea or vomiting — do not return until 48 hours symptom-free
• Symptoms of COVID-19 or other notifiable respiratory illness
• Active cold sore (herpes labialis) — avoid contact around participant's face or food
• Any open, weeping skin lesion on hands or arms — cover adequately or do not attend

Workers who are unwell notify the Director as early as possible on the day of the shift so rescheduling arrangements can be made. Workers are not penalised for staying home when unwell.

Never attend a session when unwell to 'push through'. Participants with disability or complex health needs are often immunocompromised. An infection that is mild for a support worker can be serious for a participant.

4. Participant Illness

Where a participant is unwell at the start of or during a session:

• Assess whether it is safe to continue the session based on the nature of the illness
• For respiratory symptoms: apply mask, maintain hand hygiene, and discuss with participant whether to continue
• For gastrointestinal symptoms: use PPE for all personal care, heighten hand hygiene
• Document participant illness in session notes and notify Director where significant
• Do not leave a participant who requires support without an alternative arrangement confirmed

5. Equipment & Environment

• Participant equipment (including mobility aids, continence items, and adaptive devices) is cleaned in accordance with manufacturer instructions
• Shared equipment between participants is disinfected between uses
• CONVI workers do not use personal care items (towels, washers) shared between participants
• Workers report inadequate hygiene in the participant's environment to the Director — do not document this in session notes without Director guidance

6. Outbreak Management

Where a notifiable disease or significant outbreak is identified (e.g., COVID-19, influenza, gastroenteritis) affecting a participant or household:

• Director is notified immediately
• Director assesses risk and may issue enhanced PPE requirements or suspend sessions
• Workers follow current health department guidance for the relevant disease
• Participants and families are informed of any changes to service delivery

7. Training

All CONVI workers complete infection control training as part of induction (at minimum, the NDIS-required infection control online unit) and annually thereafter. Workers who deliver personal care or high-intensity supports receive additional practical training.

8. Policy Review

Reviewed annually or following any infection-related incident, outbreak, or change in public health guidance.

1. Purpose

A conflict of interest exists where a person's private interests could influence — or appear to influence — their professional decisions at CONVI. This policy ensures that conflicts are identified early, disclosed formally, and managed before they affect participant care, business decisions, or organisational integrity.

2. What Is a Conflict of Interest

A conflict may be actual (private interest has already influenced a decision), potential (could do so), or perceived (a reasonable person would believe it could). All three types require disclosure.

2.1 Common Examples in Disability Support

• A worker is a friend, family member, or former intimate partner of a participant
• A worker has developed a personal relationship with a participant outside of the professional context
• A director or worker receives gifts, benefits, or hospitality from a participant, their family, or a supplier
• A worker is providing unsanctioned private support to a participant outside of CONVI arrangements
• A contractor or consultant referred to CONVI has a personal relationship with the Director
• A director or worker has a financial stake in a competing provider
• A current participant is being considered for employment or financial partnership with CONVI

3. Disclosure Obligations

All CONVI staff and directors must disclose actual, potential, or perceived conflicts of interest to the Director in writing as soon as they become aware. Disclosures are recorded in the CONVI Conflict of Interest Register (REG-05). Where the conflict involves the Director, disclosure is recorded in REG-05 and noted to CONVI's accountant or legal adviser.

Failure to disclose a conflict of interest is a serious breach of the Code of Conduct and may result in disciplinary action, including termination.

4. Managing Conflicts of Interest

5. Gifts & Benefits

Workers and directors may accept gifts of nominal value (under $20) from participants or families — home-baked items, cards. Recurring gifts or gifts creating an obligation require disclosure. Workers must not accept: cash or cash equivalents of any value; gifts over $20; gifts from suppliers or commercial parties that could influence decisions; invitations to events or meals that could create an obligation.

A gift that cannot be declined without causing significant offence is accepted, disclosed to the Director within 24 hours, recorded in the Gifts Register section of REG-05, and its treatment determined by the Director.

6. Conflict of Interest Register (REG-05)

The Director maintains the Conflict of Interest Register (REG-05) in SharePoint: 08_Registers/. REG-05 records: the person involved, nature of the conflict, date disclosed, management response, and outcome. REG-05 is reviewed annually and whenever a new disclosure is made.

REG-05 contains two sections: (1) Conflict disclosures; (2) Gifts and benefits register. Both sections are completed by the Director — they are not self-reported by workers.

7. Personal Relationships with Participants Outside Service Delivery

Disability support relationships sometimes evolve over time. A participant and a worker or director may develop a genuine friendship that extends beyond the professional context. This does not automatically end the professional relationship — but it must be disclosed and managed.

7.1 Disclosure Requirement

Any CONVI worker or director who develops a personal relationship with a current participant — including a friendship that extends to social contact outside of CONVI-delivered sessions — must disclose this to the Director (or, where the Director is involved, to CONVI's accountant or legal adviser) in writing.

7.2 Personal Social Contact That Is Not NDIS Service Delivery

Where a director or worker and a participant engage in personal social activities outside of the NDIS service delivery context (for example, attending the same gym, a social catch-up, or similar) and no NDIS hours are claimed for these activities, this is a personal matter. The following conditions apply:

• The personal activity must not be claimed as an NDIS session under any circumstances
• The personal relationship must be disclosed in REG-05 and reviewed regularly
• The Director must assess whether the personal relationship creates a risk of actual or perceived influence on clinical decisions, billing decisions, or advocacy positions
• Where a perceived conflict exists, the Director considers whether the formal NDIS service relationship should be transitioned to another provider while the personal relationship continues

7.3 Assessing Ongoing Service Delivery Where a Personal Relationship Exists

A personal relationship with a current participant does not automatically require cessation of service delivery. The Director assesses: Is there actual or perceived influence on session frequency, goals, billing, or notes? Is the participant's NDIS plan being used optimally, or is the personal relationship affecting clinical objectivity? Would a reasonable external observer view the arrangement as compromised?

If any of these questions produce a "yes" or "possibly" — consider transitioning the participant to another provider, or bringing in a second worker to deliver sessions independently while the Director retains an oversight role.

8. Participant to Employee or Business Partner Pathway

A CONVI participant may, over time, be considered for employment as a support worker or for a business relationship with CONVI. This is a legitimate pathway — people with lived experience of disability support are often excellent support workers. The following process governs this transition:

8.1 Employment Pathway

• The person must cease all NDIS service receipt from CONVI before employment commences. Transition to another provider where ongoing supports are required.
• A minimum period of one full NDIS plan period — or three months, whichever is longer — should pass between the end of the service relationship and commencement of employment or formal employment discussions.
• The Director discloses the prior participant relationship to CONVI's accountant before employment commences.
• Employment proceeds on standard terms — the prior participant relationship does not create special entitlements or exceptions to standard HR practices.
• The Director manages any workplace relationship dynamics that arise from the prior personal or professional history.

8.2 Financial Investment or Business Partnership Pathway

• No financial arrangement — investment, partnership, shareholding — is entered into while the person remains a CONVI participant. This is absolute.
• After the service relationship ends and a minimum separation period of three months: financial discussions may proceed.
• Any financial arrangement requires independent legal advice for both parties before execution.
• The Director consults Jonathan Stebbing (accountant) before entering any arrangement.
• The arrangement is disclosed in REG-05 and noted to CONVI's insurer.

9. Participant Financial Transactions

Workers must not: lend or borrow money from a participant or their family; accept payment outside CONVI's billing arrangements; be named as a beneficiary in a participant's will or estate; assist a participant to change their will, power of attorney, or financial arrangements.

1. Purpose

Professional communication standards protect participant privacy, create auditable records, and prevent the boundary issues that informal digital channels create in care relationships. This policy establishes approved channels and prohibited channels for all CONVI business communications.

2. CONVI's Approved Communication Channels

2.1 Email — Preferred Channel

Email (support@convi.au) is CONVI's preferred channel for all formal communication with participants, representatives, plan managers, support coordinators, and referrers. Email creates a permanent, searchable, date-stamped record. Use email for:

• Formal enquiries and responses
• Service agreement distribution and return
• Invoice distribution
• Formal complaints and responses
• Any communication involving sensitive health, legal, or financial information
• Communications that need to be retrieved or referenced later

2.2 SMS to Director's Phone — Permitted for Everyday Matters

SMS to the Director's phone (+61 494 574 786) is permitted and welcome for:

• Session scheduling, changes, and cancellations
• General enquiries from participants or their families
• Quick updates or questions that do not require a formal record
• Initial contact from new enquirers

SMS is permitted to the Director's phone only. It is not an approved channel for CONVI staff or workers to communicate with participants. SMS does not replace the formal complaint process or incident reporting process — those must use email or phone respectively. Where an SMS conversation contains significant information (a participant health update, a change in circumstances, a cancellation that triggers billing), the Director documents the relevant details in BC or D365 same day.

2.3 Phone — Urgent or Time-Sensitive Matters

+61 494 574 786 — for urgent matters, incidents, or situations requiring immediate response. Workers must be able to reach the Director by phone during business hours and via voicemail/SMS outside hours for urgent matters.

2.4 Microsoft Teams — Where Established

Teams is available for participants and their families where set up at onboarding. It is the primary internal communication tool for Director-to-worker communication.

3. Channels That Are NOT Approved

The following are not approved for CONVI business communications:

• SMS to any CONVI staff phone other than the Director's phone
• WhatsApp — for any CONVI business purpose
• Personal social media messaging (Facebook Messenger, Instagram DM, Snapchat, TikTok DM, etc.)
• Personal email accounts (i.e., any email other than @convi.au)

If a participant or family member contacts a CONVI worker through an unapproved channel, the worker acknowledges receipt politely, does not discuss support matters through that channel, and directs them to the Director via approved channels.

4. Worker Personal Social Media — Restrictions

4.1 What Workers Must Never Post

• Any content identifying or capable of identifying a participant, their family, or their circumstances
• Any description of, or reference to, a session, incident, or participant interaction — even anonymised
• Photos, video, or audio of participants, their homes, or their support environments
• Negative, disparaging, or judgmental commentary about participants, families, or other providers
• Content claiming to represent CONVI

4.2 Personal Social Media Connections

Workers must not connect with participants or their family members on personal social media accounts, accept follow requests from them, or follow their accounts. If a request is received, decline without comment and notify the Director.

5. Photographing and Filming Participants

Workers must not photograph, film, or record audio of participants without documented written consent and a specific, Director-approved purpose. Even where consent exists, material is never shared on personal social media and must be stored securely.

6. Professional Communications Standard

All communications made in connection with CONVI business — including email, Teams, phone, and SMS — must be professional in tone, must not disclose participant information to unauthorised parties, and must not include discriminatory, offensive, or inappropriate language.

7. Breach

Breach of this policy — including sharing participant-identifiable content, communicating with participants through unapproved channels, or inappropriate social media conduct — is a serious breach of the Code of Conduct (POL-02) and may result in disciplinary action, including termination and referral to the NDIS Commission.

1. Purpose & Position

CONVI has a strong commitment to positive, rights-respecting support. The use of restrictive practices is a serious matter with significant legal and ethical implications. This policy establishes that CONVI does not use restrictive practices without explicit authorisation through the NDIS framework and applicable Victorian law.

CONVI currently does not operate with any participant who has an authorised restrictive practice in their plan. If this changes, the Director must confirm full compliance with this policy before services commence.

2. Definition of Restrictive Practices

Under the NDIS Rules, a restrictive practice is any practice or intervention that has the effect of restricting the rights or freedom of movement of a person with disability. The five types are:

Regulated restrictive practices under Victorian law require authorisation from the Senior Practitioner (Office of the Senior Practitioner, VIC DHHS) in addition to NDIS framework requirements. These are serious legal obligations.

3. CONVI's Position

• CONVI does not use any form of restrictive practice without: a current Behaviour Support Plan (BSP) prepared by an NDIS-registered Behaviour Support Practitioner, NDIS Commission reporting and approval, Victorian Senior Practitioner authorisation for regulated restrictive practices, and worker-specific training
• Workers must never use physical restraint, seclusion, or other restrictive practices as an independent response to behaviour — regardless of how distressing or unsafe the situation appears. The correct response is to de-escalate, create safety distance, and call for support
• Where a worker believes a restrictive practice is being used without authorisation (by them or another person), they report to the Director immediately

4. What Workers Must Do Instead

CONVI supports participants using evidence-based positive behaviour support strategies. Workers are trained to:

• Identify early warning signs and antecedents to behaviour of concern
• Apply participant-specific de-escalation strategies from the Support Plan
• Create space and reduce stimulation where escalation is occurring
• Call for support — CONVI Director, participant family/nominee, or emergency services (000)
• Withdraw from situations where their own safety is at risk — participant safety is managed through support networks, not worker self-sacrifice

5. If CONVI Is Asked to Use Restrictive Practices

If a participant, family member, or other provider requests that CONVI use a restrictive practice, the Director must:

• Decline to implement the practice until full authorisation is in place
• Advise the requesting party of the legal requirements
• Contact an NDIS-registered Behaviour Support Practitioner to develop or review the BSP
• Contact the Victorian Senior Practitioner's office if regulated practices are involved
• Not proceed with services involving the restrictive practice until all authorisation is confirmed in writing

6. Reporting Obligations

Any use of a restrictive practice — authorised or otherwise — must be:

• Reported to the NDIS Commission as a reportable incident if it was unauthorised
• Reported to the Victorian Senior Practitioner if it involved a regulated restrictive practice
• Documented in the CONVI incident register within 24 hours
• Reviewed by the Director and relevant BSP practitioner within 5 business days

7. Policy Review

This policy is reviewed annually and whenever CONVI begins working with a participant whose plan includes an authorised restrictive practice. Any worker delivering support where authorised restrictive practices are in place receives specific training before commencement.

1. Purpose & Principles

CONVI delivers support to participants who may present behaviour that is challenging — behaviour that is, at its core, communication. Our approach is built on positive behaviour support (PBS) principles: understanding the function of behaviour, addressing unmet needs, and building skills and environments that make behaviour of concern unnecessary.

CONVI's core principles:

• All behaviour is communication — our first question is always "what is this behaviour trying to tell us?"
• Participants have the right to appropriate support, not containment
• Restrictive practices are a last resort — not a first response
• Workers are supported, trained, and not expected to manage serious behaviour without appropriate tools and backing

2. Behaviour Support Plans (BSPs)

Where a participant has a Behaviour Support Plan prepared by an NDIS-registered Behaviour Support Practitioner:

• Workers read and acknowledge the BSP before their first session — recorded on the Induction Checklist (HR-08)
• BSP strategies are implemented exactly as described — not adapted informally
• Departures from BSP strategies (even with good intent) are documented and reported to the Director
• BSP effectiveness is tracked via BC session notes (Progress Score dimension and clinical content)
• Workers report to the Director when the BSP does not appear to be working, or when behaviour escalates beyond BSP scope

Where no BSP exists but a participant presents behaviour of concern: the Director is notified. CONVI does not implement informal behaviour management strategies that have not been approved through the appropriate framework.

3. De-escalation Principles

De-escalation is CONVI's primary response to escalating behaviour. Workers are trained to:

• Regulate themselves first — a calm worker is the most powerful de-escalation tool
• Reduce environmental stimulation — noise, demands, proximity, pace
• Use language that reduces not increases pressure — low, slow, non-confrontational
• Offer choices where possible — autonomy reduces escalation
• Apply participant-specific strategies from the Support Plan or BSP — not improvised techniques
• Give the participant space and time — de-escalation cannot be rushed
• Know when to withdraw — if a situation is escalating despite de-escalation: remove yourself to a safe distance and call for support

4. Worker Obligations in Response to Behaviour of Concern

• Do not respond with physical intervention unless you are trained and an authorised restrictive practice is in place — see POL-12
• Do not raise your voice, make threats, or use confrontational language
• Do not impose your own informal consequence — workers do not "discipline" participants
• Remove yourself to safety if the situation requires it — participant safety is managed through the support network, not through worker self-sacrifice
• Document every incident or near miss accurately in BC and notify the Director same day

5. Post-Incident Support

Following any incident involving behaviour of concern:

• Worker is offered a debrief with the Director within 24 hours
• Participant Support Plan and Risk Assessment are reviewed to determine if updates are required
• If the incident was reportable: NDIS Commission notification process per SOP-INC-01 and SOP-INC-02
• Patterns of behaviour are reviewed at the next available supervision session
• If the existing BSP is not preventing or managing the behaviour: referral to a Behaviour Support Practitioner is initiated by the Director

CONVI | POL-14 — Diversity, Inclusion & Disability Rights

CONVI | POL-14 — Diversity, Inclusion & Disability Rights

1. Purpose

CONVI serves a diverse community of participants. Disability intersects with culture, gender, sexuality, age, religion, and every other dimension of identity. This policy establishes that CONVI delivers support that is respectful, safe, and equitable for every participant and every worker — regardless of who they are.

2. Disability Rights Framework

CONVI's approach is grounded in the UN Convention on the Rights of Persons with Disabilities (UNCRPD) and the social model of disability. This means:

• Disability is understood as the interaction between a person's characteristics and barriers in the environment — not as a personal deficit to be fixed
• Participants are presumed capable, competent, and worthy of respect — language and attitude reflect this
• The NDIS is a rights-based scheme — participants are not receiving charity, they are exercising a right to support
• Workers use the language participants prefer for their own disability — ask, do not assume

3. Equal Opportunity & Anti-Discrimination

CONVI does not discriminate in service delivery or employment on the basis of:

• Disability — including type, severity, visibility, or label
• Race, ethnicity, national origin, or cultural background
• Gender, gender identity, or gender expression
• Sexual orientation
• Age
• Religion or spiritual belief
• Pregnancy or carer status
• Physical appearance or other protected attributes under Victorian law

Any worker who discriminates against a participant or colleague on the basis of a protected attribute is in breach of the Code of Conduct (POL-02) and may be subject to disciplinary action and complaint to the Equal Opportunity and Human Rights Commission.

4. Cultural Safety

CONVI acknowledges that Aboriginal and Torres Strait Islander peoples are the First Peoples of Australia and are the Traditional Custodians of the lands on which we operate. CONVI is committed to delivering culturally safe support to Aboriginal and Torres Strait Islander participants.

Cultural safety for all participants means:

• Asking participants about cultural, religious, and community practices relevant to their care
• Accommodating cultural preferences in support delivery where possible — meal times, prayer times, gender preferences for workers, dress requirements
• Not imposing assumptions about what a participant believes, values, or practices based on their background
• Seeking guidance when working with communities CONVI has limited experience with — Director consults relevant community organisations or advocates where required

5. LGBTIQ+ Inclusion

CONVI delivers respectful, affirming support to LGBTIQ+ participants and employs LGBTIQ+ workers without discrimination. This means:

• Using a participant's correct name and pronouns without exception — if unsure, ask once respectfully
• Not questioning, challenging, or expressing disapproval of a participant's or worker's gender identity or sexual orientation
• Not referring to a participant's identity as something to be "managed" or "accommodated" — it is simply who they are
• Reporting to the Director any situation where a participant's LGBTIQ+ identity creates a safety risk in their home environment (e.g., unsupportive household) — this is treated as a safeguarding concern

6. Disability Language Standards

7. Reporting Discrimination or Breach

Any participant or worker who believes they have experienced or witnessed discrimination contrary to this policy may raise a concern:

• Direct to Director: support@convi.au | +61 494 574 786
• NDIS Commission: 1800 035 544
• Victorian Equal Opportunity and Human Rights Commission: 1300 292 153
• Australian Human Rights Commission: 1300 656 419