Reporting Allegations of Abuse Procedure

1. Purpose

This procedure sets out AFX Student Exchange Australia Limited's (AFX) obligations and step-by-step process for responding to and reporting incidents and allegations of sexual abuse, physical abuse, or any other form of child abuse or neglect involving an exchange student. It applies to all AFX staff, volunteers, local coordinators and host families involved in inbound and outbound programs.

AFX reports concerns to the relevant authorities whether or not the law requires it, and cooperates fully with Victoria Police and child protection authorities. The safety and wellbeing of the student is the paramount consideration at all times.

2. Scope

This procedure applies to all inbound exchange students in Victoria; all outbound Victorian students on AFX programs overseas; and all AFX directors, employees, volunteers, local coordinators, host families and overseas partner staff.

It covers all forms of child abuse, including: sexual abuse and sexual misconduct; physical abuse; emotional or psychological abuse; neglect; abuse or harm caused by another child or young person; and online abuse and grooming.

3. Definitions

4. Roles and responsibilities

5. Immediate response — what to do first

When a disclosure or allegation is made, the first AFX person to receive it must:

1. Stay calm and listen without judgement. Do not express shock or disbelief, or make promises you cannot keep.
2. Tell the child: “Thank you for telling me. I believe you. I am going to get help.”
3. Do not investigate — do not ask probing questions, conduct interviews, or attempt to establish facts beyond what is necessary to ensure immediate safety.
4. Ensure the child is safe and, where necessary, separated from the alleged perpetrator.
5. Contact the Child Safety Officer as soon as possible — within the same working day where practicable.
6. Write down what was said or observed as soon as possible, using the child's own words. Include date, time, location and who was present.
7. Do not inform the alleged perpetrator that a report is being made.

6. Reporting obligations

6.1 Inbound students in Victoria

Victoria Police: AFX reports immediately to Victoria Police (dial 000 or attend the nearest police station) where there is an incident or allegation of sexual or physical abuse, and cooperates fully with any subsequent police investigation.

Child Protection — report under s.183 Children, Youth and Families Act 2005: where AFX has reasonable grounds to believe that a child under 16 is in need of protection from harm, AFX makes a report to Child Protection via the Child Protection Crisis Line 13 12 78 (24 hours).

VRQA notification: the Child Safety Officer notifies the VRQA as soon as practicable of any incident or allegation of abuse involving an exchange student, by email to vrqa.schools@education.vic.gov.au, including a summary of the incident and the steps AFX has taken in response.

Social Services Regulator (SSR): where an allegation, incident or concern may constitute reportable conduct involving an employee, volunteer, contractor, host family member or other person engaged by AFX, the Child Safety Officer and Director/PEO will assess whether notification to the Social Services Regulator. The notification will be made to SSR via an email to contact@ssr.vic.gov.au or by completing the webform. AFX will notify the Social Services Regulator within the required timeframe, cooperate fully with any regulator injury or investigation, provide updates and outcomes as required, maintain records of all notifications and correspondence and implement any recommendations arising from regulatory review.

Reporting to the Social Service Regulator does not replace reporting obligations to Victoria Police, Child Protection, the VRQA or any other authority. Multiple notifications may be required.

During the investigation, AFX will

• act fairly and consistently with principles of procedural fairness;
• maintain confidentiality to the greatest extent possible;
• assess whether temporary suspension, removal from duties, restriction of contact with students, or other risk-management measures are required while inquiries are ongoing;
• comply with applicable employment, workplace, volunteer-management and contractual obligations;
• ensure decisions regarding disciplinary action are made only after consideration of available evidence and advice from relevant authorities where appropriate;
• provide support to affected employees, volunteers and students; and
• document all actions and decisions.

Child safety and student welfare remain the primary consideration. Where there is any conflict between maintaining student safety and the continuation of duties by an employee, volunteer or contractor, AFX will take immediate steps to remove or manage the risk to students while investigations proceed.

Reporting whether or not the law requires it: even where mandatory thresholds are not met, AFX reports any concern about a child's safety to the relevant authorities where it is in the child's best interests to do so.

6.2 Outbound students overseas

For outbound students, AFX reports immediately to the relevant law enforcement authority in the host country. AFX also notifies the VRQA and the student's parents, and contacts the Australian Embassy or Consulate in the host country where appropriate. The Child Safety Officer coordinates the response in consultation with AFX Student Exchange France.

7. Notifying parents and guardians

Parents and guardians of the affected student are notified as soon as practicable, unless doing so would place the child at further risk or compromise a police investigation. The Child Safety Officer makes this judgement in consultation with police or child protection authorities where needed, and keeps parents and guardians informed throughout the response, respecting confidentiality obligations and the student's wishes where appropriate.

8. Confidentiality

All information relating to a report or allegation of abuse is treated as strictly confidential and shared only on a need-to-know basis with those directly involved in managing the response — the Child Safety Officer, Director / PEO, relevant authorities, and the student's parents or guardians. Staff and volunteers must not discuss details with colleagues, host families or other students except as required to ensure the child's safety. The alleged perpetrator must not be informed that a report is being made before police or child protection are notified.

9. Supporting the student

AFX applies a trauma-informed approach, recognising that a child's reaction may be complex, delayed or unexpected — they may minimise, recant, express loyalty to the perpetrator, or show no visible distress. Staff respond with patience, without judgement, and without pressuring a child to disclose more than they are ready to. Throughout the response AFX:

• keeps the student informed in age-appropriate language;
• arranges access to appropriate medical, psychological and pastoral care;
• ensures the student is not left alone with an alleged perpetrator;
• where necessary, arranges alternative accommodation or early return to the student's home country;
• maintains regular contact with the student and their parents or guardians;
• informs the student of their right to have a trusted support person (a parent, guardian or other trusted adult of their choice) present during any discussion or interview about the allegation; and
• provides bilingual support — the AFX 24/7 emergency line (Australia +61 3 4422 2831 | France +33 9 74 99 12 18) is available at all times.

10. Record keeping

The Child Safety Officer maintains a confidential written record of: the initial disclosure or allegation, in the reporter's own words where possible; all steps taken in response to the disclosure or allegaiton, with dates, times and persons involved; all reports made to authorities and their outcomes; all communications with parents, guardians and the VRQA; and any medical, legal or other professional advice received.

Records are retained confidentially for at least 7 years after the student ceases to be an exchange student with AFX, consistent with AFX's obligations under the Privacy Act 1988 (Cth) (APP 11) and its Privacy Policy, and may be used in police or coronial inquiries. Records are stored securely with access limited to the Child Safety Officer and Director / PEO.

11. Review and improvement

Following any report or allegation, the Child Safety Officer and Director / PEO review the response to identify lessons learned and improvements to this procedure or AFX's broader child safe practices. Findings are reported to the Board and, where appropriate, communicated to staff. This procedure is reviewed at least annually as part of AFX's overall child safety policy review cycle.

12. Sexual conduct code

This sexual conduct code applies to all AFX staff, volunteers, local coordinators and host families, and is a condition of participation in any AFX program. Breaches are treated seriously and may result in removal from the program, termination of employment or volunteer status, and referral to police or child protection authorities.

12.1 Prohibited conduct

The following is strictly prohibited at all times, in all settings, in person and online:

• any sexual contact, behaviour or communication with an exchange student;
• showing or sending a student any sexually explicit material;
• making sexual comments, jokes or gestures toward or in the presence of a student;
• photographing or filming a student in a state of undress or in a sexual manner;
• engaging in, or pursuing, any romantic relationship with a student;
• grooming behaviours — excessive one-on-one relationships, gifts without organisational knowledge, private or secret communication channels, or creating situations of isolation;
• requesting or accepting personal social media connections with a student outside AFX-approved channels during the program; and
• allowing a student to be alone with an adult in a private space without another adult present, except where operationally unavoidable and with prior organisational knowledge.

12.2 Online and communication boundaries

All communication between AFX personnel and students must be conducted through AFX-approved channels (email, the AFX platform, or phone calls logged with the AFX office), professional in tone and content, and never through personal social media, private messaging apps or encrypted platforms not visible to AFX. Host families must not communicate with students through personal channels that exclude AFX oversight, except for ordinary household matters (e.g. meal times, transport).

12.3 Physical boundaries

Physical contact with students must be limited to what is appropriate, necessary and culturally safe. Hugging or physical affection must always be student-initiated and never sought by an adult; adults must never enter a student's bedroom without knocking and receiving a response, except in an emergency; students must have access to a private bathroom and changing space at all times; and adults must never be alone with a student behind a closed door.

12.4 Responding to a boundary breach

If any person observes or becomes aware of a breach of this code, they must:

1. remove the student from the situation immediately if it is safe to do so;
2. contact the Child Safety Officer as soon as possible — australia@afxstudentexchange.com | +61 (0)3 6144 7049;
3. document what was observed or reported, using exact words where possible;
4. not confront the alleged perpetrator or discuss the matter with others except as required to ensure safety; and
5. cooperate fully with any subsequent investigation by AFX, Victoria Police or child protection authorities.

Where the breach may constitute a criminal offence, AFX reports immediately to Victoria Police (000) and follows sections 5 and 6 of this procedure.

12.5 Consequences

Any breach of this sexual conduct code will result in immediate suspension from the program pending investigation; referral to Victoria Police and/or child protection authorities where the breach may constitute a criminal offence; termination of employment, volunteer status or host family registration where substantiated; and notification to the VRQA and any other relevant regulatory body.

13. Key contacts