Child Safety Code of Conduct

The Portsea Camp

Policy Generated: August 13, 2025 10:46 AM

Child Safety Code of Conduct The purpose of this Code is to promote child safety and wellbeing in the TPC environment, and to safeguard children and young people against sexual, physical, psychological and emotional abuse, neglect, and family violence.

1. Introduction 1.1 The Portsea Camp (TPC) is committed to promoting and protecting the health, safety and wellbeing of all children and young people.

1.2 TPC has no tolerance for abuse or harm to children and young people.

1.3 If any person believes a child is at immediate risk of abuse or harm, telephone 000.

1.4 TPC is committed to providing a supportive, empowering and safe environment where every child and young person has a place, a voice, and their story is known.

1.5 This Child Safety Code of Conduct (Code) has been drafted in consultation with the TPC community and endorsed by the Board. It has been drafted taking into account the diversity of TPC’s environment, including but not limited to the needs of Aboriginal and Torres Strait Islander children, children from culturally and linguistically diverse backgrounds, children who are sexually and gender-diverse, children with disabilities, children who are unable to live at home, and other children who are vulnerable.

1.6 Everyone working at TPC is responsible for the care and protection of children and young people and for reporting information about child abuse and harm to children and young people.

2. Purpose 2.1 The purpose of this Code is to promote child safety and wellbeing in the TPC environment, and to safeguard children and young people against sexual, physical, psychological and emotional abuse, neglect, and family violence. It aligns with TPC’s stance of zero tolerance for child abuse and harm to children and young people.

3. Scope 3.1 This Code applies to all employees, volunteers, contractors, and members of the Board at TPC who are over the age of 18 years (collectively referred to as ‘Staff’ or ‘Workers’). Staff are required to comply with this Code at all times.

3.2 This Code must be read in conjunction with TPC’s Child Safety Policy and Child Safety Procedure and any other applicable TPC, professional or occupational codes of conduct that regulate Staff.

3.3 It applies to all aspects of a Worker’s engagement with or in connection with TPC. Staff must be conscious that their position places significant obligations on them including a requirement to maintain professional boundaries. Interactions with children and young people can extend beyond the TPC setting, Page 1 of 8

including outside of normal TPC hours, outside of TPC premises and by any medium of technology (including social media).

3.4 This Code applies in all areas of the ‘TPC Environment(s)’. The TPC Environment includes any of the following: (a) physical, online or virtual places, including those used during or outside TPC’s hours of operation; (b) TPC offices, locations or sites; (c) online or virtual TPC environments for use by children and young people (including email, intranet systems, software applications, collaboration tools, social media and online services); and (d) any other locations provided by TPC or through a third-party provider for use by a child or young person, including locations used for excursions, delivery of education and training, competitions or other events.

3.5 This Code applies regardless of: (a) the location of where an interaction occurs, whether during or outside TPC environment or during or outside TPC operating hours; (b) the age of a child or young person; (c) a child or young person providing their consent; (d) the consent of parents/guardians and families; and (e) circumstances in which a child or young person initiates an interaction or communication with the Worker.

3.6 Definitions in this Code must be read in conjunction with TPC’s Child Safety Policy and Child Safety Procedure.

4. Standards of behaviour 4.1 The following list of behaviours includes examples of what is acceptable and unacceptable behaviour.

This list is not exhaustive.

4.2 Required behaviours To help ensure the safety and wellbeing of children and young people, all Staff must: (a) contact the police if a child or young person is at immediate risk of danger (telephone 000); (b) work towards the achievement of the aims and purposes of the organisation, including the empowerment and centring of children and young people; (c) conduct themselves in a manner consistent with their position and act as a role model to children and young people; (d) adhere to TPC’s Child Safety Policy, Child Safety Procedure, this Code, and other applicable policies and procedures, as amended from time to time, at all times; (e) take all reasonable steps to protect the children and young people associated with TPC from abuse and/or risk of harm; Page 2 of 8

(f) comply with professional boundaries at all times; (g) promote cultural safety, and actively encourage and support the participation and empowerment of Aboriginal and Torres Strait Island children and young people (for example, by never questioning an Aboriginal and Torres Strait Island child or young person’s self-identification); (h) support and encourage Aboriginal and Torres Strait Island children and young people to express their culture and enjoy their cultural rights; (i) respect the language, customs, religions and cultures of children and young people; (j) promote the empowerment of children and young people about their rights, and encourage and empower their participation in decisions affecting them; (k) promote the safety, participation and empowerment of: (i) children and young people with disabilities; (ii) children from culturally and linguistically diverse backgrounds; (iii) children and young people who are unable to live at home; and (iv) lesbian, gay, bisexual, trans and gender diverse, intersex and queer (LGBTIQ+) children and young people; for example, by having no tolerance for discrimination, racist, bullying and phobic behaviour; (l) listen and respond to the views and concerns of children, particularly if they disclose that they are or another child or young person has been abused or that they are worried about their safety or the safety of another child or young person; (m) swiftly report any allegations of abuse or risks of harm to children and young people, including bullying, discrimination and harassment in accordance with TPC’s policies and procedures; (n) report any suspected breach of this Code to managers, the HR Manager, Child Safety Officers (CSOs), the CEO or the Board; (o) respect the confidentiality and privacy of children and young people and act in accordance with TPC’s Privacy Policy; (p) exercise prudent judgement and intervention consistent when children or young people engage in harmful behaviour towards others e.g. bullying, harassment, discrimination or vilification; (q) be professional in their actions and maintain strict impartiality at all times; (r) comply with relevant professional and employment obligations, including any professional or occupational codes of conduct; (s) only interact online with children and young people connected with TPC for the purpose associated with TPC’s services and in compliance with TPC’s policies and procedures; (t) immediately notify the CEO/HR Manager/Programs Manager if they: (i) become the subject of any investigation in relation to their conduct towards children or young people; (ii) are charged with any offence related to children or young people or family violence; (iii) are named as a respondent on a family violence intervention order or personal safety intervention order; or (iv) are subjected to orders in the Children’s Court; (u) exercise judgment and sensitivity regarding appropriate physical interactions with children and young people, and only engage in physical interactions with children and young people where it may be necessary, beneficial and/or supportive; Page 3 of 8

(v) comply with any lawful and reasonable direction by TPC; and (w) cooperate with any child safety investigation by TPC or any regulatory authority.

4.3 Unacceptable behaviours Workers must not: (a) engage in any form of abuse of any child or young person, including behaviour that could constitute grooming; (b) ignore or disregard any suspected or disclosed abuse or risk of harm to any child or young person; (c) develop any 'special' relationships with any children or young people connected with TPC that could be seen as favouritism, including but not limited to: (i) offering of gifts or special treatment to specific children or young people; (ii) attend parties or socialising with children or young people connected with TPC outside of organised TPC events; (iii) meet with children or young people connected with TPC outside of TPC’s operating hours without permission from TPC; and (iv) engaging in behaviours with children or young people which may be construed as unnecessarily physical, such as children or young people sitting on laps or shoulder massages; (d) engage in conduct towards or in the presence of a child or young person that suggests contempt, ridicule or intolerance, including because of the child’s or young person’s or another person's race, culture, religion, gender, sexual orientation, living arrangements or disability; (e) subject a child or young person to any form of corporal punishment or physical violence; (f) put a child or young person at risk of harm or abuse, for example, by locking doors; (g) initiate unnecessary physical contact with a child or young person or do things of a personal nature that a child or young person can do for themselves, such as toileting or changing clothes; (h) engage in open discussion of a mature or adult nature in the presence of a child or young person; (i) use inappropriate language in the presence of a child or young person (such as swearing, hateful or using sexualised language); (j) express personal views on culture, race or sexuality in the presence of children or young people; (k) discriminate against any child or young person, including because of age, gender identity, race, culture, vulnerability, sexual orientation, ethnicity, religious belief, living arrangements or disability; (l) have contact with a child or young person connected with TPC outside of TPC’s operations without TPC’s knowledge, and/or consent of the CEO/HR Manager/Programs Manager; (m) use any personal communication channels or device such as a personal email account, social media or instant messenger accounts to make contact with children and young people in connection with TPC; (n) exchange personal contact details with children or young people connected with TPC (such as phone numbers, social networking sites or personal email addresses); (o) drive a child or young person in their car unless they have the express consent of the TPC and the child’s or young person’s parent or guardian; (p) become ‘friends’ with, follow or add a child or young person connected with TPC on any social media Page 4 of 8

platform; (q) photograph or video a child or young person connected with TPC: (i) without the consent of TPC and the child’s or young person’s parents or guardians; (ii) in accommodation rooms, shower or toilet facilities; or (iii) in a ‘provocative’ or ‘suggestive’ manner; (r) share or request any photographs, videos, recordings or personal information about children or young people connected with TPC without TPC's consent, including on any of their own social media platforms; (s) engage in any action that is, or may be perceived by a reasonable observer as, grooming behaviour; (t) work with a child or young person while under the influence of alcohol or illegal drugs; (u) consume alcohol or drugs in TPC environment or at TPC events in the presence of children or young people; (v) supply any child or young person with tobacco, drugs or alcohol; (w) smoke tobacco, cigarettes or e-cigarettes in the presence of children or young people; (x) spend time alone with a child or young person connected with TPC without TPC’s knowledge and consent; (y) take a child or young person connected with TPC to their home or encourage meetings outside TPC’s environment, program activities, including both the physical and online environment; (z) engage in rough physical games, hold, massage, kiss, cuddle or touch a child or young person connected with TPC in an inappropriate and/or culturally insensitive way; (aa) show favouritism when building relationships with children and young people connected with TPC; (bb) speak to a child or young person connected with TPC in a way that is or could be construed by any observer as harsh, threatening, intimidating, shaming, derogatory, demeaning, or humiliating, such as yelling at a child or young person, except in an emergency situation where a person’s safety may be in danger; (cc) discourage any person from reporting a complaint or concern of abuse or risk of harm to children or young people; (dd) discuss sexual activities with a child or young person connected with TPC unless it is a specific job requirement or required for TPC’s programs and activities; (ee) be naked in the presence of a child or young person connected with TPC; (ff) sleep in the same beds, sleeping bags or small tents with a child or young person connected with TPC; and/or (gg) engage in sexual conduct with a child or young person connected with TPC, including sexual conduct online.

4.4 For the purposes of this Code, sexual conduct includes physical contact or communication (electronic, written or verbal) of a sexual nature, conduct or communication that is overly personal or intimate, undressing or watching another person undress, inappropriate conversations or communication about an area of the body or a sexual activity, and exposure to sexual activity.

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5. Use of electronic communications 5.1 Electronic communication between a Staff Member and a child or young person connected with TPC and/or their families should only occur for reasons relating to the delivery of TPC’s services.

5.2 Such communication: (a) should relate to issues directly associated with a service, activity or event; and (b) should not be used to promise unauthorised social activity or to arrange unauthorised contact.

5.3 All Staff are reminded: (a) they must continually seek to identify and mitigate risks in the online environment without compromising a child or young person’s right to privacy, access to information, social connections and learning opportunities; (b) never to post images on TPC’s communication channels that offer personal information such as address, phone numbers, email address and instant messaging names; and (c) that it is illegal to create, possess, distribute, post or transfer child exploitation material, and that the law is extremely strict with reference to images of children and young people.

6. Physical contact or touching 6.1 Staff are prohibited from using physical discipline in any way for behaviour support and management of children and young people. This prohibition includes spanking, slapping, pinching, hitting, or any other physical force as retaliation or correction for inappropriate behaviours by children and young people.

6.2 Physical contact may be required in an emergency situation to remove children and young people quickly from danger or threat of danger, but only to the extent that physical contact is reasonable in all the circumstances and no more force is used than is absolutely necessary.

6.3 Some guidelines include the following: (a) Consider the child or young person's age, developmental level, maturity and level of care required. For example, touching a child or young person to gain their attention, guiding or comforting a distressed child or young person. (b) Work in an open environment. For example, in confidential interviews or a one-to-one meeting, the door should be open with visual access. (c) Be alert to cues from children and young people about how comfortable they are in your proximity and respect their need for personal space. (d) Be sensitive when interacting with children and young people connected with TPC, such as those who may have experienced trauma, are more vulnerable, or exhibit sexualised behaviours. (e) Be aware of cultural norms and the needs of: (i) Aboriginal and Torres Strait Islander children and young people; (ii) children with a disability; (iii) children from culturally and linguistically diverse backgrounds; (iv) children who are unable to live at home; and (v) lesbian, gay, bisexual, trans and gender diverse, intersex and queer (LGBTIQ+) children; Page 6 of 8

which may influence the interpretation of your behaviour or what is acceptable in terms of personal space. (f) When you are required to make physical contact in connection with activities (such as fitting harnesses, assisting children and young people on and off equipment): (i) where possible, ask permission before making physical contact; (ii) only make physical contact to the extent that is necessary for the safety of the child or young person; (iii) maintain a safe and appropriate distance otherwise; and (iv) if a child or young person expresses a concern or appears to be uncomfortable with the physical contact then cease the contact immediately and consider alternative options. (g) Physical contact should be made in a way that makes children and young people feel comfortable. For example, shaking hands, a congratulatory pat on the back or rub on the side of their arm for reassurance.

Massaging a child or allowing a child to massage you is inappropriate physical contact. (h) The collection and storage of photographs or images of children and young people connected with TPC must be for a purpose directly related to TPC’s services or professional purposes. Use of social media and posting of images of children and young people by other children or Staff must be authorised by the CEO. (i) Meeting with children and young people connected with TPC for activities and purposes not associated with TPC is not permitted, unless the child or young person is a family member or family friend.

7. Transportation and off-site events 7.1 Other than in an emergency or other situation where no other option could be reasonably foreseen, it is not acceptable to transport children or young people connected with TPC without written permission of TPC and of their parent, carer or guardian.

7.2 Staff must not engage in physical or sexual contact with a child or young person connected with TPC while in a vehicle.

7.3 Children and young people should be transported directly to their destination. No stops should be made other than those that are reasonably scheduled for meals or comfort stops.

8. Confidentiality 8.1 Staff should not discuss confidential matters about children or young people with people outside of TPC in a way that identifies that child or young person except when they have the express consent of the child or young person or their parent or guardian, or the disclosure complies with the Child Safety Procedure.

8.2 In circumstances where Staff believe there is insufficient expertise within TPC to provide the best possible assistance to a child or young person, they may seek expertise external to TPC. When communicating with people outside TPC, the child or young person’s identity should be protected.

9. Related legislation and contacts 9.1 Children, Youth and Families Act 2005 (Vic) 9.2 Child Wellbeing and Safety Act 2005 (Vic) 9.3 Crimes Act 1958 (Vic) 9.4 Department of Families, Fairness and Housing (DFFH) Child Protection – North-eastern rural and Page 7 of 8

regional office 1300 360 391 – After hours 131 278 9.5 Child Protection Crisis Line – 24 Hours, seven days a week. Telephone: 13 12 78 9.6 Commission for Children and Young People (CCYP) – Tel. 1300 78 29 78 9.7 The Orange Door (operated by DFFH and formally the Child and Family Information, Referral and Support Team, or Child FIRST) – Tel. 1300 369 146

10. Related policies and procedures 10.1 Child Safety Policy 10.2 Child Safety Procedure 10.3 Privacy Policy 10.4 Staff Code of Conduct 10.5 Volunteer Code of Conduct

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