Child Safety and Wellbeing Policy

1. Our commitment to child safety

AFX Student Exchange Australia Limited (ABN 60 143 429 154) (AFX) is committed to the safety, wellbeing and empowerment of all children and young people in its care. We have zero tolerance for child abuse and we take all reasonable steps to keep children safe from harm. This commitment applies to every inbound exchange student in Victoria and every outbound Victorian student overseas, and to all our staff, volunteers, contractors, local coordinators, host families and overseas partners.

AFX is a registered charity (ACNC, from 11 December 2023) and an Australian public company (ACN 143 429 154). Our Board of Directors, which includes a Victoria-based director, holds ultimate responsibility for child safety. We comply with the Victorian Child Safe Standards and with our obligations under the Child Wellbeing and Safety Act 2005, the VRQA Guidelines for Student Exchange Programs, and related legislation.

This is our keystone child safety policy. It addresses each of the eleven Child Safe Standards and is supported by the related policies and procedures listed above.

2. Who this policy applies to

This policy applies to all AFX directors, employees, volunteers, contractors, local coordinators, host families, education agents and overseas partner organisations — anyone involved in delivering or supporting AFX’s exchange programs. It applies in all settings, in person and online, in Victoria and overseas.

3. Roles and responsibilities (governance)

Child safety is championed at every level of AFX. Responsibilities are distributed as follows so that there is clear accountability and a local response capability for students in Victoria:

• Board of Directors — holds ultimate governance responsibility for child safety, approves this policy framework, and includes a Victoria-based director.
• Director / Principal Executive Officer — is the operational lead, owns and approves this policy, and ensures the child safe framework is implemented across the organisation.
• Child Safety Officer — australia@afxstudentexchange.com, +61 (0)3 6144 7049 — is the designated person responsible for managing child safety concerns and responses, overseeing reporting (including reports under section 183 of the Children, Youth and Families Act 2005), and notifying the VRQA. Staff, students and families can raise any child safety concern with the Child Safety Officer.
• Victorian Program Coordinator and Victorian School Coordinator — are the local first points of contact for inbound students in Victoria. They respond immediately and in person where needed, contact Victoria Police or emergency services (000) in an emergency, and escalate to the Child Safety Officer.
• All staff, volunteers, coordinators and host families — must read, understand and comply with this policy and the Code of Conduct, complete required child safety training, and report any concern about a child’s safety.

Escalation chain: a child or host family raises a concern → Victorian Program/School Coordinator (immediate local response) → Child Safety Officer (manages response, reporting and VRQA notification) → Director / Principal Executive Officer and Board (accountable).

4. How AFX meets each Child Safe Standard

Standard 1 — Culturally safe environments for Aboriginal children

AFX promotes a culturally safe environment for Aboriginal and Torres Strait Islander children and young people. We encourage children to express and enjoy their culture, we embed respect for Aboriginal cultures in our practice and training, and we do not tolerate racism. Any racism is identified, addressed and met with appropriate consequences. Our Code of Conduct requires staff and host families to respect and never question a child’s cultural identity, and to support the inclusion and participation of Aboriginal children and their families. In practice, AFX asks students and families about cultural needs and identity at the matching stage, so that placements can be made with this in mind and appropriate support arranged from the outset.

Standard 2 — Child safety embedded in leadership, governance and culture

AFX has made a public commitment to child safety (see section 5). Child safety is governed by the Board and led operationally by the Director, supported by the Child Safety Officer. Our Code of Conduct sets clear behavioural standards. Our Critical Incident and Child Safe Risk Management Strategy identifies, prevents and mitigates risks to children across all program settings. Staff understand their information-sharing and record-keeping obligations under the Privacy Policy and applicable law.

Standard 3 — Children and young people are empowered and participate

AFX informs students of their rights — to safety, to information, and to participate in decisions affecting them — in plain, age-appropriate language at orientation and in the Student Safety Card. The Student Safety Card is bilingual (English and French) and is sent to all students prior to the program. It includes:

• Local emergency services: 000 (Australia) and 112 (France)
• The AFX 24/7 bilingual emergency line: +61 3 4422 2831 (from Australia) and +33 9 74 99 12 18 (from France). When a student calls, an automated bilingual triage agent first assesses the situation and level of urgency. If the situation is an immediate danger, the agent directs the student to hang up and call 000 or 112. If it is an emergency, the call is transferred directly to the AFX staff member on call that week (a human, on a weekly rotation managed by the Child Safety Officer). If the matter is non-urgent, a message is sent to the on-call staff member, who reviews the recording and contacts the student the next business day if needed.
• The Child Safety Officer’s contact details
• The VRQA as an independent escalation option outside AFX
• A plain-language statement of the student’s rights, including that they will not get in trouble for raising a concern

Students are given age-appropriate information about staying safe, including recognising and reporting abuse, and child-friendly ways to raise a concern.

AFX also recognises the importance of friendships and peer support in helping students feel safe and less isolated. We encourage students to build positive connections with other exchange students and within their host family, school and community, and our monthly check-in calls give students a regular opportunity to talk about how they are settling in socially.

Wellbeing monitoring during the program:

• Wellbeing forms are sent to the host family, the participant, the participant’s parents, and the school referent at the overseas school hosting the participant — at three points during the stay: the first week, mid-stay, and the final week. Responses are reviewed by the AFX team and any concerns are followed up promptly.
• AFX reaches out to the student directly once a month to offer a phone call with a member of the team. This gives students a regular, low-pressure opportunity to raise any concerns or seek support.
• The AFX 24/7 bilingual emergency line is available at all times for urgent situations (see triage system described above).
• AFX’s conflict and crisis management process is documented in the Crisis Management Manual (Manuel de gestion de crise), a standalone bilingual document shared with students, host families and parents. It sets out a three-tier process — immediate danger, serious concern, and incompatibility without misconduct — with clear timelines, a structured mediation process, and formal decision-making procedures. All parties are informed of this process before the program begins.

Standard 4 — Families and communities are informed and involved

AFX engages openly with families. Parents and guardians participate in decisions affecting their child, including through the written exchange agreement and consent to any program change. We provide families with accessible information about the program, our governance, and our complaints process. Families and, where relevant, communities are given the opportunity to have a say in the development and review of our child safety policies, and we report back on the outcomes of reviews.

To ensure families and children have a meaningful opportunity to contribute to the review, AFX includes two child safety feedback questions in the wellbeing form sent to all host families and students during the exchange. The form is bilingual (English and French). Responses are collated by the Child Safety Officer and presented to the Director / Principal Executive Officer as part of the annual review. The outcomes of each review, including any changes made in response to family or student feedback, are recorded in the policy version history and communicated to staff.

Standard 5 — Equity is upheld and diverse needs respected

AFX understands that children have diverse circumstances and that some are more vulnerable. We provide information, support and complaints processes in ways that are accessible and culturally safe, including in a student’s first language where practicable. We pay particular attention to the needs of children with disability, children from culturally and linguistically diverse backgrounds, children who are unable to live at home, and children who are lesbian, gay, bisexual, transgender, intersex or queer (LGBTIQ+). AFX does not tolerate discrimination on any of these grounds.

Students with a disability or additional needs are identified at the application stage. AFX works with families, host families and schools to ensure appropriate adjustments are in place before the program begins, and reviews these arrangements at each wellbeing check-in point.

AFX’s student-facing materials — including the Student Safety Card, wellbeing forms and the Crisis Management Manual — are provided in both English and French, reflecting the culturally and linguistically diverse backgrounds of AFX students. Where a student or family requires communication in another language or format, AFX makes reasonable efforts to accommodate this.

Standard 6 — Suitable staff and volunteers

AFX applies robust recruitment and screening practices that emphasise child safety, in accordance with our Working with Children Checks Policy (Standard 5.8). Child safety and wellbeing is emphasised throughout recruitment — including in the wording of role advertisements, in referee checks, and in pre-employment and pre-engagement screening — so that a person’s suitability to work with children is assessed from the outset. Everyone working with children, or with access to students’ personal records or information, in Victoria holds a current Victorian Working with Children (WWC) Clearance or current Victorian Institute of Teaching (VIT) registration, verified against the official online register before they commence. Overseas host families are screened through the VRQA-approved alternative vetting procedure (in France, the Bulletin n° 3 criminal record check). Staff and volunteers receive child-safety induction and ongoing supervision.

Standard 7 — Complaints processes are child focused

AFX has an accessible, child-focused Complaints and Appeals Policy (Standard 5.30), explained to students and families in clear language and published on our website. We take all complaints seriously and commence assessment within 10 working days, applying procedural fairness, with the right to a support person. AFX reports concerns to the relevant authorities whether or not the law requires it, and cooperates fully with Victoria Police and child protection authorities. Reporting, privacy and employment-law obligations are met.

Standard 8 — Staff and volunteers are equipped with knowledge, skills and awareness

AFX trains its staff, volunteers and local coordinators in child safety. Training covers: how to implement this policy; how to recognise indicators of child harm, including harm caused by other children; how to respond to and report concerns and support a colleague who discloses harm; how to build culturally safe environments; and Victorian child-protection reporting duties. Training is delivered through AFX’s online learning platform (Trainer Central) and completion is recorded and monitored.

Standard 9 — Physical and online environments are safe

AFX identifies and mitigates risks in physical and online environments without unnecessarily restricting children. Our Internet and Social Media Policy (Standard 5.32) governs online safety, privacy, and protection from grooming and contact by strangers. Our Child Safe Risk Management Strategy assesses risks across all program settings — pre-program, travel, the host family home, school, support contact and online. Where AFX procures facilities or services from third parties, it requires those arrangements to uphold child safety.

Standard 10 — Implementation is regularly reviewed and improved

AFX regularly reviews and improves its child safe practices. We review this policy and our practices at least annually and after any significant incident. Complaints and critical incidents are logged and analysed by the Child Safety Officer to identify causes, patterns and any systemic failures. Findings are reported to the Director / Principal Executive Officer and Board, communicated to staff, and where appropriate shared with families and children. Feedback collected through the post-experience feedback form and monthly student calls feeds directly into this review cycle.

Standard 11 — Policies and procedures document how AFX is safe

This keystone policy, together with the related policies and procedures listed in the document-control table, documents how AFX is a child safe organisation and addresses all eleven Child Safe Standards. The policies are written in plain language, are version-controlled, and are informed by best-practice guidance from the Commission for Children and Young People and the VRQA, and by consultation with families and staff. AFX’s leaders model compliance, and all staff and volunteers are required to understand and implement these policies.

5. Public commitment statement

The following statement is published on the AFX website at afxstudentexchange.com/aboutus/ under the heading “Our Commitment to Child Safety”:

AFX Student Exchange is committed to the safety, wellbeing and empowerment of all children and young people in our care. We have zero tolerance for child abuse. We listen to children, respect their rights, and act on any concern for their safety. Our staff, volunteers and host families are screened and trained, and we report any child safety concern to the appropriate authorities. If you have a concern about the safety of a child in an AFX program, please contact our Child Safety Officer at australia@afxstudentexchange.com or +61 (0)3 6144 7049, or contact the VRQA at vrqa.student.exchange@education.vic.gov.au.

6. Reporting a child safety concern

Anyone who has a concern about the safety of a child in an AFX program must report it. In an emergency, or where a child is in immediate danger, call 000 (in Victoria) or local emergency services (overseas). Otherwise, report to a Victorian Coordinator or the Child Safety Officer as soon as possible.

Where AFX has reasonable grounds to believe an inbound student in Victoria aged under 16 is in need of protection, AFX makes a report under section 183 of the Children, Youth and Families Act 2005. AFX reports every type of abuse to the appropriate authority: sexual or physical abuse, or any matter that may be a criminal offence, to Victoria Police (inbound) or the relevant host-country authority (outbound); and concerns including emotional abuse and neglect to Child Protection. AFX advises the VRQA of any incident or allegation involving an exchange student. The detailed steps are set out in the Reporting Allegations of Abuse Procedure (Standard 5.29).

AFX keeps a confidential written record of each concern, report and the action taken, retained for at least seven years after the student ceases to be an exchange student.

7. Review of this policy

This policy is reviewed at least annually, and after any significant child safety incident, by the Director / Principal Executive Officer in consultation with the Child Safety Officer and the Board. Reviews consider feedback from staff, families and children collected through the post-experience feedback form, and the analysis of any complaints or incidents. The outcomes of each review are recorded in the version history and communicated to staff.