Australian Rural Leadership Foundation Limited (ACN 056 874 787) (ARLF, we, us) recognises that your personal and sensitive information is important to you and that you are concerned with its collection, use, and disclosure. We have in place policies to comply with the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth) which sets clear standards regarding these activities.

Generally, you can deal with ARLF without identifying yourself. In certain circumstances however, you will be required to provide personal and sensitive information where it would be impractical to deal with you anonymously. These circumstances include where you have applied for employment with ARLF, enrol in one of our programs, request a service, utilise our products or services, or where we are required by Australian law to collect such personal information.

ARLF collects your information to enable us to: 

• facilitate the provision of ARLF’s programs; 

• facilitate payments;  

• measure the impact of ARLF leadership development and its contribution to community and industry;  

• facilitate networking opportunities for program alumni and participants; 

• facilitate engagement opportunities for alumni to be involved in ARLF activity and programs; 

• distribute membership notices, and regular newsletter subscriptions 

(together all of the above are Services). 

You do not have a legal obligation to provide any personal information to ARLF. However, the consequences if all or some of the personal and sensitive information is not collected by ARLF include, but are not limited to: 

• being unable to use any of ARLF’s Services; 
• ARLF being unable to offer you employment; 
• ARLF being unable to pay wages into your bank account;  
• ARLF being unable to contact a family member, or emergency contact in the event of an emergency; and 
• ARLF being unable to include you in networking activity and services including but not limited to the alumni online portal. 

To the extent required by law, ARLF may disclose personal information of this kind to organisations that provide services to us in connection with the Services including experiential learning sessions, travel and accommodation bookings, customer support, payment processing, administration, archival, data storage, hosting, mail and delivery, financial and legal advisory, banking, debt collection, security or technical services and the operation of our website, and data storage platforms including (but not limited to) Hubspot and Xero. The ARLF may disclose personal information to overseas recipients in New Zealand for the purpose of delivery the Services.  

All personal and sensitive information is held by ARLF and its staff in accordance with our Privacy Policy.

The Privacy Policy includes information on how you may request access to and correction of your personal information or complain about a breach of the Australian Privacy Principles. 

1. Introduction

1.1 Australian Rural Leadership Foundation (ARLF) Code of Conduct provides a set of standards
for everyone involved with the ARLF to ensure it is a safe, respectful and positive environment.

1.2 Responsibilities fall under four categories:
(a) respect for the law and the governance of the ARLF;
(b) the fair treatment of people;
(c) personal and professional behaviour; and
(d) exercising care and diligence.

1.3 It also outlines the procedures for reporting and complaint handling.

2. Who does this Code apply to?

2.1 The Code applies to:
(a) ARLF directors and committee members;
(b) ARLF members;
(c) ARLF employees;
(d) ARLF associates;
(e) external facilitators and contractors and their staff or subcontractors, who provide
work or services to the ARLF; and
(f) all participants involved in ARLF activities whether in a paid or voluntary capacity.

2.2 If this Code applies to you, it applies to you in all ARLF dealings with colleagues, program
participants, host communities, other stakeholders and when you represent ARLF.

2.3 The Code stands beside but does not exclude or replace the rights and obligations that directors, staff members, external facilitators and contractors may have under applicablelaws or contractual obligations.

3. Code of Conduct

3.1 Respect for the law and the governance of the Foundation
You must:
(a) observe and comply with relevant Australian, State, and Territory laws;
(b) comply with the ARLF Constitution as applicable;
(c) act in accordance with ARLF’s objectives, values, policies and procedures and
respond appropriately to any lawful and reasonable directions given by persons
who are authorised to give such a direction;
(d) report actual or suspected fraud or corrupt conduct to appropriate ARLF
leadership or authorities; and
(e) comply with the ARLF Privacy Policy.

3.2 Fair Treatment of People
You must:
(a) treat others fairly and with respect, courtesy, and equity;
(b) engage in conduct that is respectful of differences;
(c) not engage in conduct that is discriminatory on the basis of sex, race, sexuality,
disability, cultural background, religion, marital status, age, union affiliation,
political conviction or family responsibilities; and
(d) not engage in conduct that may be reasonably perceived as bullying or
harassment or sexual harassment.

3.3 Personal and professional behaviour
You must:
(a) be honest;
(b) maintain appropriate professional relationships in your dealings with ARLF;
(c) not make any public comment that is critical of ARLF or detrimental to the best
interests of the ARLF;
(d) not act in a way that may adversely affect or reflect on, or bring you or ARLF into
disrepute or discredit;
(e) avoid actual, potential or perceived conflicts of interest between private and
professional interests and ARLF responsibilities;
(f) ensure you do not receive material benefits to yourself, your family, relatives or
close associates due to your ARLF responsibilities or position;
(g) disclose any relationship where there is, or has been, a personal, commercial,
familial or other significant relationship;
(h) ensure your conduct does not pose a risk to the health and safety of others;
(i) refrain from any conduct including alcohol or substance abuse or misuse, which
could adversely affect personal work performance or the safety and well-being of
others; and
(j) ensure that any use of social media does not breach this Code of Conduct.

3.4 Exercising care and diligence
You must:
(a) carry out your duties and responsibilities in a professional, responsible and
conscientious manner;
(b) ensure decisions are reasonable, fair and appropriate to the circumstances;
(c) keep confidential and not use or disclose any confidential information obtained as
a result of your position;
(d) ensure that any ARLF information is not used, including its intellectual property,
without authorisation, and, or to gain a financial or other benefit for themselves
or any other person or group;
(e) maintain adequate security over ARLF property, facilities and resources and
information; and
(f) ensure you use ARLF resources in a proper manner.

4. Concerns

4.1 You can report concerns with respect to an alleged breach of this Code of Conduct to
the Chief Executive and Board Chair if applicable.
4.2 Concerns will be treated seriously and acted on promptly.
4.3 Concerns that arise under this Code of Conduct will be addressed using the processes
outlined in the following:
(a) Management of Grievance or Dispute Policy
(b) relevant employee/associate/consultant contract
(c) Whistleblower Policy

1. Rationale

1.1  The Australian Rural Leadership Foundation (ARLF) is committed to ensuring the health and safety of its Board Members, employees, volunteers, participants, associates, contractors and visitors and supports all persons to be responsible and exercise their duty-of-care to keep yourself safe and help mitigate the risk of infection to others.

1.2  This policy outlines the ARLF’s approach to minimising the risk of exposure to Transmissible or infectious illnesses/ diseases (including COVID-19) for all Board Members, Employees, Volunteers, Associates, Participants, Contractors and Visitors working at ARLF Workplaces.

1.3  This policy is subject to any Public Health Order which affects the ARLF and its activities and programs in Australia and overseas. In the event that any State, Territory, Australian or foreign government mandates that a workplace must close, that employees isolate at home, wear a mask or be vaccinated at work (Public Health Order) then such directives override this policy to the extent of any inconsistency.

1.4  The ARLF is mindful of taking steps to minimise the risk to vulnerable individuals. From time to time the ARLF interacts with people and communities with an elevated risk of the being infected with a transmissible illness or disease, for example people with a reduced immune system, medical professionals, flight crew, and Aboriginal and Torres Strait Islander individuals and communities. Individuals that this policy relates to have a duty to consider their personal health and wellbeing and the desires of others to help minimise the impact of COVID-19 and other transmissible illnesses or diseases in the community.

1.5 Please refer to the ARLF Work Health and Safety Policy for more details regarding providing a safe and healthy work environment and key responsibilities. A copy of this policy can be found on the ARLF website or by emailing info@rural-leaders.org.au.

1. Rationale

1.1 Participants and their individual engagement and interaction during an Australian Rural Leadership Foundation Leadership Program supports the success and outcomes of the program for all.

Full attendance and active participation in this program directly relate to the value of the experience for all participants.

Participants are selected not only for their own abilities and strengths, but for their contribution to the diversity of the group.

ARLF leadership development programs are experiential, designed to rapidly build trust in cohorts of participants and explore diverse perspectives. As such an absence can compromise this experience for an individual participant and entire cohorts.

This makes it critical for each participant to commit to program attendance and the opportunity for learning from the outset.

1.2 The requirement for the participant to complete all learning requirements of an Australian Rural Leadership Foundation (ARLF) leadership program is emphasised during the selection and acceptance process and is specifically set out in the Contract/ Acceptance of Offer signed by the participant. This is also emphasised to applicants in readiness calls and in webinars during the onboarding phase of a program.

1.3 Due to the financial investment by and for each participant, and the importance of each session to the overall educational process, attendance in all learning opportunities is mandatory.

1.4 Places on the program are funded through scholarships and as such, there needs to be a commitment to the sponsors and donors who believe in the value of investing in leadership for rural Australia. Sustained absence in the program compromises the participant’s and the ARLF’s relationship with the sponsor and can place funding at risk.

1.5 This policy sets out the expectations in regard to participant attendance at all aspects of a program.

2. Definitions

3. Policy statement

3.1 Attendance for all stipulated days is compulsory for all participants.

3.2 Non-attendance may force a re-evaluation of the participant’s place on the program.

3.3 Participants are required to arrive on time for planned learning and to stay until the completion to avoid disruption to other participants and others.

3.4 Non-attendance, tardiness, early departures and changes to itineraries at the request of a participant that result in expenses incurred by the ARLF on the participant’s behalf will be billed to the participant.

3.5 Failure to attend without a valid reason may lead to termination from the Program.

• • 3.5.1 Regardless of the reason, if stipulated learning is missed, the participant is required to discuss with the Manager, Learning.
• • 3.5.2 The Manager Learning is responsible for managing participant attendance.
• • 3.5.3 All decisions will be made in consultation with a delegate of the Partnerships team and may include the scholarship sponsor or funding partner.
• • 3.5.4 In the event a resolution is not reached with the Manager Learning, the Director Learning will decide. Depending on the circumstances, the participant’s place on a program may be terminated.
• • 3.6 Permission to undertake alternative learning remains at the complete discretion of the ARLF.
• • 3.7 Participant financial contributions are non-refundable.
• • 3.7.1 All learning requirements of the Australian Rural Leadership Program must be completed to graduate, receive a certificate of completion and become a fellow of the ARLF.

4. Scope and application

This policy applies to all participants undertaking an Australian Rural Leadership Foundation leadership program.

5. Responsibilities and ownership of this policy 

6. Resources

No additional resources will be needed, although some changes in work practices may be required.

7. Review schedule

8. Related documentation

Participant Guide, Participant Contract

1. Introduction

1.1. The Australian Rural Leadership Foundation Limited (ABN 80 056 874 787) (“ARLF”, “We”, “Us”, “Our”) is committed to protecting Your Personal Information.

1.2. This document sets out how ARLF may collect, store, use and disclose personal information. Any person who provides Personal Information to ARLF consents to ARLF using, storing, and disclosing that Personal Information in accordance with this Privacy Policy.

1.3. This Privacy Policy is available for free on ARLF’s website, at rural-leaders.com.au, or by contacting ARLF directly and requesting a copy.

1.4. We may revise this Privacy Policy from time to time by publishing a revised version on Our website. That revised version takes effect from the time it is published.

2. Definitions

3. Why does ARLF collect Personal Information

3.1. The Personal Information You provide is important to Us as it can be used to identify You, make it easy for Us to contact You, and to allow Us to efficiently carry out Our functions and activities.

3.2. ARLF only accesses and uses Personal Information for the purposes for which it was collected and for purposes directly related to that purpose.

3.3. Subject to clause 2.4 when dealing with ARLF, You may ask to not identify yourself or not use or disclose, or not let ARLF use or disclose, Your Personal Information. Alternatively, when dealing with ARLF, You may use a Pseudonym, and require ARLF to use a Pseudonym when dealing with You, in lieu of providing Your Personal Information.

3.4. You acknowledge and accept that ARLF cannot practically provide services to a person who wishes to engage ARLF but who is not prepared to provide his or her Personal Information. You acknowledge and accept that for ARLF to perform or provide You with services, Your Personal Information must be provided and must be correct and up to date so as to enable ARLF to verify Your identity and provide such services.

3.5. There may be circumstances where ARLF requires You to provide Your Personal Information and is unable to deal with You in a particular manner in the absence of Your Personal Information, including where:

• ARLF is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or 
• It is impracticable for ARLF to deal with individuals who have not identified themselves or who have used a Pseudonym.

4. What information does ARLF collect?

4.1. We collect and hold Personal Information from Our program applicants, program participants, program graduates, sponsors, donors, supporters, volunteers, contractors, stakeholders, service providers, members, employees, and other individuals. 3 pRIVACY POLICY  Australian Rural Leadership Foundation

4.2. We will not collect any Personal Information unless it is reasonably necessary for Us to complete one or more of Our functions or activities.

4.3. Personal Information We collect and hold may include Your name, address, e-mail address, phone number, medical details, employment details, education details, credit card or bank account details. From time to time, We may collect more detailed Personal Information from You to assist Us with Our program evaluations, marketing material, for producing detailed reports and for enabling Us to meet requests for alumni to contact one another. You may also use ARLF’s Alumni Portal to update Your Personal Information at any time.

5. How is Personal Information collected?

5.1. We collect Your Personal Information directly from You via Our website, email, phone calls or in person. We may also collect Personal Information when You:

• enter into an agreement with ARLF; 
• enrol in one of Our programs or join one of Our networks; 
• subscribe to any publication of ARLF; 
• enter Personal Information into one of ARLF’s forms or systems; 
• contact ARLF by email, telephone, mail or social media; or 
• apply for employment or a volunteer position with ARLF. 

5.2. From time to time We may obtain Personal Information from third parties. When We do so, We will take reasonable steps to ensure that We make You aware of the collection of Your information in accordance with the Act.

5.3. ARLF will only collect information from You and not from other individuals or organisations, unless it is unreasonable or impracticable to do so.

5.4. Once ARLF no longer has a need for Your Personal Information then We will either destroy or de-identify the information when it is reasonably practicable to do so.

5.5. Where ARLF receives Personal Information about You from a third party which was not solicited, then that information will be dealt with in accordance with this Privacy Policy and the Act. 4 pRIVACY POLICY  Australian Rural Leadership Foundation

6. Sensitive information

6.1. We may collect Sensitive Information related to Your health and wellbeing which is likely to be shared with Our program providers. We will comply with the Act whenever We handle sensitive information.

6.2. ARLF will only collect any Sensitive Information about You where:

• 6.2.1. You provide consent for Us to do so, and if it is reasonably necessary for Us to carry out one or more of Our functions or activities;
• 6.2.2. the information relates to the activities of ARLF and to the members of ARLF, or to individuals who have regular contact with the organisation in connection with Our activities;
• 6.2.3. the collection is required or authorised by or under an Australian law or a court/tribunal order; or
• 6.2.4. ARLF is otherwise permitted by the Act or at law.

6.3. ARLF may disclose Your Sensitive Information, to a range of third party organisations which include, but are not limited to:

• those entities that obtain services from ARLF, where appropriate; 
• individuals or entities that ARLF engages to carry out functions and activities on ARLF’s behalf; 
• external service providers that provide ARLF with financial, legal, administrative, information technology, banking, travel, publications or other services; or 
• in other circumstances permitted by law.

6.4. Where possible, We destroy Sensitive Information after it is no longer required by Us.

7. Links to other websites

7.1 ARLF is not responsible for the privacy practices or content of the linked web sites and the other pages hosted by ARLF on behalf of non-ARLF agencies and organisations.

8. Use of Personal Information

8.1. We use Your Personal Information primarily to:

• complete all administration for Your participation in Our programs; 
• communicate with You during Your participation in Our programs and once You have completed a program; 
• communicate with Our network of sponsors, partners, members and supporters; 
• process payments and donations; and 
• enable all other activities and functions of the ARLF. 

8.2 We may also make ancillary use of Your Personal Information, in addition to those matters set out above, where:

• You would reasonably expect Us to use or disclose the Personal Information; 
• You have consented to Our ancillary use or disclosure of Your Personal Information; or 
• the use or disclosure is authorised by the Act, any other Australian law or Court order.

8.3 ARLF may use or disclose Your government related identifier if:

• the use or disclosure of the identifier is reasonably necessary for Us to verify Your identity for the purposes of Our activities or functions; 
• the use or disclosure of the identifier is reasonably necessary for Us to fulfil Our obligations to an agency or a State or Territory authority; 
• the use or disclosure of the identifier is required or authorised by or under an Australian law or a court/tribunal order; 
• in other circumstances permitted by the Australian Privacy Principles.

8.4 We do not sell Your Personal Information to third parties.

9. Disclosure of Personal Information

9.1 We generally do not disclose Personal Information to other organisations unless:

• We believe it is reasonably necessary to conduct the functions and activities of ARLF; 
• You give Your consent; or 
• it is required or authorised by law including in emergency situations or to assist law enforcement.  

9.2 ARLF may use or disclose Your Personal Information, in order to:

• manage and administer the services We provide to You; 
• enable third parties engaged by Us to provide services on Our behalf; 
• assist You with enquiries; 
• charge You for the services We provide and collect any amounts You may owe to Us, including any debt recovery action; and 
• ensure that Our internal business operations are running smoothly including any reporting or legal requirements We may be required to fulfil. 

9.3 ARLF may from time to time disclose Your Personal Information, that is not Sensitive Information, to a range of third party organisations which include, but are not limited to:

• those entities that obtain services from ARLF, where appropriate; 
• individuals or entities that ARLF engages to carry out functions and activities on ARLF’s behalf; 
• external service providers that provide ARLF with financial, legal, administrative, information technology, banking, travel, publications or other services; or 
• in other circumstances permitted by law. 

9.4 Where You participate in an ARLF program session overseas, We will disclose Your Personal Information with the international parties assisting with conducting the program. The country where information may be disclosed is New Zealand. ARLF will take such steps as are reasonable to ensure that any overseas recipient does not breach the Australian Privacy Principles in relation to the Personal Information. 

10. Security and storage of Personal Information

10.1. Information may be stored in hard copy or electronic format in facilities that ARLF owns and operates itself, or that are owned or operated by ARLF’s service providers. 

10.2. If contract service providers are used, they will be bound by Our Privacy Policy. We require Our employees, contractors, and third party service providers to respect and protect the confidentiality of Personal Information We hold. 7 pRIVACY POLICY  Australian Rural Leadership Foundation 

10.3. Our electronic database is secured by a firewall and anti-virus software to ensure, so far as practicable, that it is not accessed by unauthorised parties. This website has security measures (minimum 128-bit secure sockets layer encryption) designed to protect against the loss, misuse and/or alteration to Your Personal Information under Our control. Secure pages on Our website are protected by a 128-bit Secure Sockets Layer certificate. A security icon visible on Your screen, for example a padlock, confirms that Your browser supports SSL security. You should click on the security icon to verify the security certificate on Our website. 

10.4. All unencrypted information exchanged via the internet may be accessed and used by people other than those for whom it is intended; if You send Us any Personal Information by email it is sent at Your own risk. 

10.5. ARLF may retain Personal Information, for the longer of: 

• 7 years after ceasing to provide products or services to You; 
• until We no longer need the information for any purpose for which the information may be used or disclosed; or 
• in perpetuity if it is a Commonwealth record,after which time ARLF will take such steps as are reasonable in the circumstances to destroy the Personal Information or ensure that the Personal Information is de-identified. 

11. Marketing 

11.1. Where ARLF has collected Your Personal Information directly from You, ARLF will only use or disclose Your Personal Information for the purposes of Direct Marketing if: 

• You would reasonably expect that Your Personal Information would be used for the purposes of Direct Marketing; 
• You have not advised ARLF that You do not want Your Personal Information to be used for the purposes of Direct Marketing; and 
• it is required in accordance with the Act. 

11.2. This Clause 10 is subject to the operation of other Direct Marketing legislation including the Do Not Call Register Act 2006 (Cth) and the Spam Act 2003 (Cth). 

11.3. We will not disclose any Sensitive Information about You, unless You have provided express consent for Us to do so. 

12. Access to Personal Information

12.1. Under the Australian Privacy Principles, You have a right to access Your Personal Information held by Us free of charge, unless a permitted exception exists at law. If You would like to access the Personal Information that ARLF holds, please let ARLF know by making a request directly to the ARLF through the contact details provided in this Privacy Policy. ARLF will provide You with access to Your Personal Information within a reasonable period after the request, unless exempted by the Australian Privacy Principles. 

12.2. We take reasonable steps to ensure that Personal Information We collect, hold, use and disclose is complete, accurate, relevant and up-to-date. If however You find that the Personal Information ARLF holds about You is inaccurate, please contact ARLF and We will amend Your Personal Information free of charge. 

12.3. When You update any Personal Information held by Us, We will upon request, take such steps as are reasonable in the circumstances to correct any Personal Information that We have previously disclosed to another party. 

12.4. If You wish to have Your Personal Information removed from Our database, We will take reasonable steps to comply with Your request unless We need to keep Your information for legal, auditing or internal risk management reasons. 

12.5. You may also use ARLF’s Alumni Portal to update Your Personal Information at any time. This portal is accessed by ARLF staff and alumni. 

13. Complaints 

13.1. Any issues or complaints in relation to the collection, use, disclosure, quality, security of and access to Your Personal Information should be made to the ARLF directly, via the contact details in clause 13. Any complaints will be dealt with in accordance with Our grievance policy, a copy of which is available on request. 

13.2. ARLF will respond to Your complaint within a reasonable period, and try to resolve Your complaint for You. If We are unable to resolve Your complaint or You are unhappy with the outcome, You may be able to lodge a complaint with the relevant regulator, such as the Office of Australian Information Commissioner via its enquiries line on 1300 363 992, or via its website.

14. Contact Details 

14.1. If You would like to request access to or amend Your Personal Information, would like to make a complaint regarding ARLF’s conduct in relation to Your Personal Information, or have any general enquiries in relation to Your Personal Information, please contact the ARLF via the following details: 

Phone: +612 6281 0680 

Email: info@rural-leaders.org.au 

Post: PO Box 298, Deakin West ACT 2600

1. Rationale

1.1. The purpose of this policy is to establish the Australian Rural Leadership Foundation’s (ARLF) policies and procedures concerning the acquisition of goods and services

1.2. The arrangements for securing the services of providers must reflect the ARLF’s values which include:

• Respect and engage with First Nations cultural Knowledge systems
• Embrace a diversity of views, perceptions, backgrounds and cultures
• Challenge entrenched ideas
• Foster collaboration and act beyond self
• Pursue lifelong learning

1.3. The ARLF’s procurement activities will ensure timely, efficient, and economic procurement, within the guidelines of good business practices that facilitate competition, guarantee the performance of the contract, and eliminate the possibility of unfair competitive advantages.

2. Definitions

3. Policy Statement

3.1. The ARLF will use three basic approaches to procurement:

• full and open competition
• solicitation through preferred providers
• a sole source basis

3.2. The ARLF’s approach to the procurement of goods and services, whether it is procuring goods and services from open, restricted or selected markets, or procuring services from individuals with long standing relationships with the ARLF, will address the following principles:

• obtaining the best value for money
• encouraging competition by ensuring non-discrimination in procurement and using competitive procurement processes
• promoting the use of environmentally sustainable practices using resources in an efficient, effective and ethical manner
• promoting the use of suppliers that demonstrate ethical practice for positive social outcomes
• promoting the use of First Nations providers and contractors
• preferencing the use of regional and local suppliers
• making decisions in an accountable and transparent manner

3.3. The principles will be implemented within the context of:

• the nature of the market
• the performance history of the supplier
• the relative risk of each proposal
• the flexibility to adapt to possible change and contract options
• financial considerations including all relevant direct and indirect benefits and costs over the whole procurement cycle

3.4. The processes for securing goods and services will be structured to ensure:

• fairness and impartiality
• consistency and transparency of process
• use of an appropriately competitive process
• appropriate security and confidentiality arrangements
• identification and management of actual and potential conflicts of interest

3.5. The approval and execution of procurement transactions on behalf of the ARLF will reflect the authorities endorsed by the Board in the Delegations Framework

3.6. The Chief Executive is responsible for bringing any potential conflicts related to the procurement of goods and services to the attention of the Board of Directors.

3.7. The ARLF will procure goods and services as determined time to time as approved by the CE.

3.8. The ARLF will use a consultant agreement:

• to engage providers (i.e. consultants or independent contractors in business for themselves, not ARLF employees) who perform specialised work that cannot (either because of time or skill level) be performed by ARLF employees
• to clearly specify the scope of work, rate and terms of compensation, time period, performance management, deliverables, and terms of the agreement.

3.9. The ARLF will use project contracts for project-related services which clearly describe the scope of work, the rate and terms of compensation, the period of performance, deliverables, and terms of the agreement when:

• other procurement instruments are not appropriate
• when the contract has specific requirements or when the scope of the work is significant where each party is seeking terms and conditions that will protect both parties.

3.10. A cost/price analysis is to be conducted for most procurement actions, particularly those that are considered significant, and those that are filled on a sole source basis. It will comprise of:

• an evaluation of the proposal to determine its appropriateness, effectiveness and quality
• an evaluation of the provider’s capacity to meet each element of a proposal
• an assessment of the provider’s capability, knowledge of Foundation’s programs and prior history of fulfilling contracts
• a comparison of cost, quotations, market prices, and other cost-related elements
• a minimum of two written quotes for procurements to the value of $10,000 and greater

3.11. The ARLF reserves the right to award purchase orders, consultant agreements, or project contracts on a sole source basis when there is:

• a predominate capability, significant prior knowledge of the ARLF’s programs and program philosophy
• a prior history of fulfilling similar assignments in a successful and timely manner

3.12. The ARLF will prepare, maintain and regularly update a list of qualified and capable providers and contractors with the skills required to contribute to its programs from the open market and among its Fellows.

• 3.12.1. The Providers List may be used to solicit the provision of goods and services from preferred providers.

3.13. For most procurement actions, the ARLF shall maintain a secure record that contains:

• a signed copy of the procurement instrument (e.g., contract, consultant agreement or purchase order);
• any amendments to the procurement instrument;
• copies of all bids and offers
• all purchase specifications including delivery requirements
• cost/price analysis that was the basis for the award cost or price;
• as applicable, a written justification as to why sole source or minimum competition approach to procurement was used
• explanation as to why the winning provider was selected.

3.15. When dealing with procurement, the ARLF requires full and open disclosure from its employees and board members in order to avoid any conflict of interest or the appearance of a conflict of interest.

• 3.15.1. If there is the doubt as to the propriety of a procurement action, the Chief Executive should be advised immediately.
• 3.15.2. ARLF employees and board members must at all times provide full disclosure of their actions or relationships with prospective vendors, contractors, or consultants.
• 3.15.3. ARLF employees and board members shall not engage in conduct resulting in a real, potential, or apparent conflict of interest. A conflict of interest may arise, whether isolated, recurring, or continuous, when a procurement option provides a direct or indirect financial advantage to the employee, their spouse, parent, child, friend or business partner.
• 3.15.4. Employees and board members shall not participate in the selection, final choice, or management of a contract, if a real, potential, or apparent conflict of interest is involved.

4. Scope and application

This policy applies to employees and board members of the ARLF.

5. Responsibilities and ownership of this policy

5.1. It is the responsibility of the Chair of the Board to manage the conflicts of interest of Board members.

6. Resources

No additional resources will be needed, although some changes in work practices and program guidelines may be required.

7. Review schedule

8. Related documentation

ARLF Conflict of Interest Policy
Corporations Act 2001
Trade Practices Act
Freedom of Information Act
Anti-discrimination and Equal Opportunity
National Competition Council Guidelines
Independent Commissions against Corruption Guidelines

1. Rationale  

1.1 The Australian Rural Leadership Foundation (ARLF) values appropriate standards of behaviour and conduct across all its dealings and activities. 

1.2 ARLF encourages and supports Whistleblowers to disclose actual or suspected instances of conduct that may be illegal, unethical or have the potential to bring ARLF into disrepute. 

1.3 This Policy: 

1. explains the scope of protection available to individuals wishing to become Whistleblowers; 
2. the circumstances in which an individual may be protected as a Whistleblower;  
3. provides a framework for how ARLF will handle instances of protected disclosures in order to meet ARLF’s legal and regulatory obligations; and 
4. details the process from the initial disclosure and investigation through to addressing allegations and importantly, protecting Whistleblowers from detriment.  

2. Definitions 

3. General Protection 

3.1 An individual making a disclosure will be protected in accordance with the Act and this Policy if the: 

1. individual has one or more of the connections to ARLF set out in clause 5; 
2. individual makes the disclosure to an eligible Recipient; and 
3. disclosure is about one or more of the Protected Disclosures outlined in clause 6. 

4. Public Interest and Emergency Disclosures  

4.1 An individual can also make a Protected Disclosure in limited circumstances to a member of parliament, or an Australian State or Territory legislature, or a journalist where a matter is a public interest, or an emergency interest disclosure.   

4.2 ARLF encourages individuals to contact the Whistleblower Protection Officer or an independent legal adviser to ensure they understand the criteria for making a public interest or emergency disclosure. 

4.3 Whistleblowers who make public interest or emergency interest disclosures qualify for protection under the Act. 

5. Who can make a disclosure

5.1An individual is only protected as a Whistleblower if they have, or previously, had one or more of the following connections to ARLF:  

1. a director or the company secretary of ARLF; 
2. an employee of ARLF; 
3. an individual who supplies services or goods to ARLF (whether paid or unpaid); 
4. an employee of a person that supplies services or goods to ARLF (whether paid or unpaid); 
5. an associate of ARLF; or 
6. a relative, dependant, child, or spouse of an individual referred to above. 

5.2 A Whistleblower does not include ARLF’s customers, clients or competitors unless they are otherwise eligible under clause 5.1. 

6. Disclosable matters 

6.1 An individual is only protected as a Whistleblower if they make a disclosure about their actual knowledge of, or reasonable grounds to suspect, a director, officer, contractor, advisor, supplier, associate, patron or any other person who has dealings with ARLF has engaged in misconduct or an improper state of affairs. This may include but is not limited to:  

1. illegal, fraudulent or unethical behaviour; 
2. unsafe or potentially destructive behaviour which may pose a health and safety risk to others; 
3. breaching ARLF’s policies including Code of Conduct or Conflict of Interest policies; 
4. discrimination, bullying or harassment; 
5. negligence or attempts to cover up serious wrongdoings; or 
6. any behaviour that may bring ARLF into disrepute or impact it financially. 

6.2 An individual may also be protected as a Whistleblower if they make a disclosure about their actual knowledge of, or reasonable grounds to suspect, ARLF or an officer or director of ARLF has engaged in conduct that represents a danger to the public or the financial system whether or not it is illegal, or conduct that breaches:  

1. the Act;  
2. the Australian Securities and Investments Commission Act 2001 (Cth); 
3. the Banking Act 1959 (Cth); 
4. the Financial Sector (Collection of Data) Act 2001 (Cth); 
5. the Insurance Act 1973 (Cth); 
6. the Life Insurance Act 1995 (Cth); 
7. the National Consumer Credit Protection Act 2009 (Cth); 
8. the Superannuation Industry (Supervision) Act 1993 (Cth); 
9. or any instrument made under the above acts;  
10. a Commonwealth law where the offence is punishable by 12 months imprisonment; or 
11. the Regulations. 

6.3 Disclosures that relate to matters outside those listed in this Policy may not qualify for protection under the Act or this Policy.  ARLF encourages individuals who are considering making a disclosure to contact the Whistleblower Protection Officer or other Recipient under this Policy for more information. 

6.3 A Whistleblower still qualifies for protection if their disclosure turns out to be incorrect. However, individuals who intentionally make false disclosures will not be able to access the protections under the Act. 

6.5 Further information on Protected Disclosures is available on the ASIC website at: 

https://asic.gov.au/about-asic/asic-investigations-and-enforcement/whistleblowing/. 

7.    Personal Work-related Grievances 

7.1 A personal work-related grievance generally will not qualify for protection under the Act and this Policy. Personal work-related grievances should be dealt with under the ARLF Management of Grievances or Disputes Policy. 

7.2 Generally, a personal work-related grievance is a grievance regarding an individual’s current or former employment and tends to have implications only for the individual affected.   

7.3 Examples of work-related grievances which are not protected include interpersonal conflicts between an individual and another employee, or ARLF decisions regarding terms and conditions of employment or termination of employment. 

7.4 A personal work-related grievance may qualify for protection if: 

1. a grievance has or is likely to have significant implications for ARLF;  
2. a grievance relates to any actual or alleged conduct about a disclosable matter; or 
3. an individual seeks legal advice regarding the operation of whistleblower protections in relation to their grievance.  

7.5 Personal work-related grievances that fall outside the protections available under this Policy may be protected under other legislation such as the Fair Work Act 2009 (Cth). 

7.6 If an individual is unsure if the work-related grievance qualifies for protection under the Act and this Policy, ARLF encourages them to contact the Whistleblower Protection Officer.   

8.  Who can disclosures be made to? 

8.1 An individual will only be protected as a Whistleblower if the Protected Disclosure is made to a one of the following types of Recipient: 

1. an officer, a director or company secretary of ARLF;  
2. a senior member of management of ARLF such as the chief executive; 
3. an internal or external auditor, or a member of an audit team conducting an audit, of the company or related entity; 
4. an actuary of ARLF or a related entity;  
5. a person authorised by ARLF to receive Protected Disclosures that may qualify for protection, including the Whistleblower Protection Officer; or 
6. externally to a person or body under clause 0. 

8.2 However, in the interests of a timely investigation, ARLF encourages individuals to make disclosures to the Whistleblower Protection Officer by one of the below methods:   

Australian Rural Leadership Foundation 

Whistleblower Protection Officer 

Name: Philippa Woodhill 

Address: 24 Napier Close, DEAKIN ACT 2600 

Email address:  compliance@rural-leaders.org.au  

Phone Number: +61 410 606449 

8.3 Disclosures can be made to the Whistleblower Protection Officer or other Recipients via a third party or by any other means appropriate or necessary. 

9.    Anonymity 

9.1 Disclosures can be made anonymously or by using a pseudonym. 

9.2 Any Protected Disclosure that does not reveal an individual’s identity will be treated as anonymous. 

9.3 Anonymous Whistleblowers should consider maintaining ongoing communication to aid an investigation and enable feedback to be provided. 

10. External disclosures 

10.1 Whistleblowers can make Protected Disclosures externally to: 

1. ASIC, or other Commonwealth body prescribed by the Regulations; or 
2. a legal practitioner for the purposes of obtaining legal advice or representation about the operation of the whistleblower protections. 
3. Information on how to make Protected Disclosure to external to ASIC is available at:  http://asic.gov.au  

11.  Tax Related Disclosures 

11.1 There are also protections available to Whistleblowers under the Tax Act. 

11.2 If Whistleblower considers they have information that may assist the Australian Taxation Commissioner (Commissioner) to perform their functions or duties under a taxation law, disclosure of the information to the Commissioner will be protected. 

11.3 If the Whistleblower reasonably suspects they have information that indicates misconduct or an improper state of affairs relating to ARLF’s tax affairs, disclosure to the following will be protected: 

1. ARLF’s auditor or a member of the audit team; 
2. ARLF’s registered tax agent or BAS agent; 
3. a director, company secretary, or senior manager of ARLF;  
4. a person authorised by ARLF to receive disclosures that may qualify for protection, including the Whistleblower Protection Officer; or 
5. an employee of ARLF that has functions or duties that relate to its tax affairs. 

11.4 If a Whistleblower considers that have information to would reasonable assist any of the people set out in clause 11.3 to perform their functions or duties in relation to ALRF, the disclosure of that information will also be protected. 

11.5 Further information of tax related whistleblower protections is available at: https://www.ato.gov.au/General/Gen/Whistleblowers/. 

12.  Protection and support for Whistleblowers and other individuals 

12.1 If an individual is protected as a Whistleblower: 

1. the individual is protected from the time they make the disclosure; 
2. the individual is not subject to any civil, criminal or administrative liability for making the disclosure; and 
3. no contractual or other remedy may be enforced, and no contractual or other right may be exercised, against the individual on the basis of the disclosure. 

12.2 A Whistleblower or individual affected by a disclosure is entitled to protection from detriment or threat of detriment including:  

1. dismissal;  
2. injury of the individual; 
3. alteration of an individual’s employment position or duties to their disadvantage; 
4. discrimination, including between the individual and other employees of ARLF; 
5. harassment or intimidation, including threats; 
6. harm or injury, including psychological harm; 
7. damage to the individual’s property; or 
8. damage to the individual’s reputation, business or financial position. 

12.3 When the individual is an employee, detrimental conduct for an employee does not include: 

1. any reasonable administrative action taken to protect a Whistleblower from detriment; or  
2. any action taken against a Whistleblower where it relates to performance management or a breach of company policies. 

12.4 ARLF will protect a discloser from detriment by: 

1. complying with this Policy; and 
2. taking advice from the Whistleblower Protection Officer on the steps to be taken to protect a Whistleblower from detriment. 

12.5 A Whistleblower or individual affected by a Protected Disclosure can seek compensation and remedies through a court: 

1.  if they suffer loss, damage or injury because of a Protected Disclosure; and 
2. where the ARLF has failed to prevent the detriment.  

12.6 ARLF will offer fair treatment to an individual who is mentioned in a Protected Disclosure or to whom a Protected Disclosure relates, including. 

1. handling Protected Disclosures confidentially (where appropriate); 
2. conducting an unbiased and objective investigation based on evidence;  
3. providing updates on the investigation where relevant; 
4. giving full and proper consideration as to whether matters warrant being referred to ASIC or the Federal Police; and 
5. providing a summary of the outcome of the investigation. 

13. Confidentiality

13.1 ARLF has a legal obligation to protect the confidentiality of a Whistleblower’s identity and to not disclose the identity of a Whistleblower or information likely to lead to the identification of the Whistleblower where a Whistleblower has requested anonymity.  

13.2 Subject to below, ARLF will maintain confidentiality of the Whistleblower’s identify at all stages from initial disclosure, through to investigation and after finalisation of the investigation. 

13.3 A Whistleblower’s identify can however be disclosed by ARLF: 

1. to ASIC, APRA, or a member of the Australian Federal Police (within the meaning of the Australian Federal Police Act 1979);  
2. to a legal practitioner (for the purposes of obtaining legal advice or legal representation about the whistleblower provisions in the Act); 
3. to a person or body prescribed by Regulations; or  
4. with the consent of the Whistleblower. 

13.4 If a Whistleblower’s identity is disclosed illegally, a complaint can be lodged with ARLF or a regulator, such as ASIC, APRA or the ATO, for investigation. 

14. Investigating disclosable matters

14.1 On receiving notice of a disclosure, ARLF will conduct an investigation as soon as practical and within 1 month from the date the disclosure is made. The process to be followed and the progress of the investigation will be dependent on the nature of the issue. Updates will be provided where appropriate where the Whistleblower has agreed to be identified. 

14.2 The process for investigating a disclosure is as follows: 

1. ARLF will acknowledge a disclosure within 5 business days, provided ARLF can contact the Whistleblower; 
2. ARLF will assess whether a disclosure falls under this Policy and whether a formal investigation is required; 
3. ARLF will determine the nature and scope of the investigation, timeframe and additional resources that may be required; 
4. investigations will be conducted by a suitably qualified person appointed by ARLF who is at arm’s length of the investigation; 
5. investigations will focus on evidence gathering to support or refute the Protected Disclosure with appropriate records maintained; 
6. investigations will be conducted confidentially, fairly and without bias having regard to the nature and circumstances of the Protected Disclosure; 
7. Whistleblowers will be kept informed at least monthly on the process, timeframes and outcome where possible;  
8. unless otherwise requested by the Whistleblower, updates will be provided by email; 
9. at the end of the investigation, the Whistleblower will receive a summary report on the findings, including actions to be taken (where relevant) and avenues for review; and 
10. a report will be made available to ARLF’s board, where necessary preserving confidentiality. 

14.3 ARLF will ensure that information contained in a Protected Disclosure or obtained through investigations relating to a Protected Disclosure will be kept securely and will only be accessed by those managing and investigating a disclosure.  This includes: 

1. ensuring email addresses, computers or printers used in an investigation cannot be accessed by other employees or officers; and 
2. only those handling or investigating a disclosure will be made aware of a discloser’s identity or information that may identify a discloser (where relevant). 

14.4 ARLF may be unable to provide updates in situations where the Whistleblower has refused or failed to provide a means of contacting them. 

14.5 Disclosures will be made available to the ARLF board as well as external stakeholders where required as part of the investigation where: 

1. the Whistleblower has given consent; or 
2. it is reasonably necessary for investigating the disclosure and where the information does not include the identity of or is likely to identify, the Whistleblower.  

15.  Further information and Review 

15.1 Other ARLF policies may be relevant to the operation of this Policy, however where the provisions in this Policy are inconsistent with another policy, this Policy will prevail. 

15.2 This Policy can be requested by contacting the Whistleblower Protection Officer and is also available Policy will also be available on the ARLF website at https://rural-leaders.org.au/ . 

15.3 The Whistleblower Protection Officer or other Recipients can be contacted if an individual wants to further information regarding any aspects of the Policy. 

15.4 This Policy will be incorporated into ALRF’s employee induction process.  Current employees will be provided with training on this Policy, and periodically as required. 

15.5 ARLF is committed to monitoring the effectiveness of this Policy, and its processes and procedures and will ensure this Policy is reviewed and updated where necessary, but at least annually, by the ARLF audit and risk committee, with changes approved by the board to ensure the Policy reflects regulatory standards and appropriately manages risk.  

16. Review schedule 

17. Resources 

No additional resources will be needed, although some changes in work practices and program guidelines may be required.    

18. Related documentation 

 1. Rationale 

1.1 This policy recognises the Australian Rural Leadership Foundation’s (ARLF) duty to comply with WHS Acts and Regulations.  

1.2 The purpose of the ARLF’s Work Health and Safety Policy (WHS Policy) is to promote health, safety and welfare in all ARLF work-related settings and to implement a best practice approach of regularly monitoring WHS risks and hazards and taking actions to remove or address hazards and to seek continuous improvement in management of a safe work environment. 

 2. Definitions 

3. Policy statement 

The ARLF is committed to ensuring the health and safety of its Board Members, Employees, Associates, Participants and Volunteers as well as the safety of Visitors and Contractors. We do this by ensuring: 

• a culture where individuals take responsibility for their own safety and where harm through work is unacceptable; 

• compliance with all relevant legislation, including state or territory WHS Acts and Regulations; and 

• the development and implementation of a WHS Management System with the plans, policies and programs necessary to support and implement this WHS Policy.  

3.2 The ARLF views WHS initiatives as an investment in business productivity and innovation.  By maintaining high standards in WHS, we support our own success by demonstrating respect and integrity, both in working with others, and in complying with the law.   

3.3 Each Board Member, Employee, Associate, Participant and Volunteer has a role in assuming a responsible and active interest in a healthy and safe workplace.  Good health and safety management is achieved by everyone working in partnership, ‘thinking ahead’, ‘doing it right’ and ‘doing it now’. 

3.4 Accordingly, it is the ARLF’s position, reflected in this WHS Policy, that Employees must carry out their respective responsibilities for compliance with the ARLF’s WHS policies and procedures diligently and conscientiously at all times. 

3.5 No job is so urgent or important that it requires anyone to take unacceptable risks.  If there are any doubts as to health and safety, the manager in charge must err on the side of caution so that all necessary safeguards under the relevant Risk Management Plan(s) are fully adhered to. 

3.6 Adequate first aid equipment must be provided in each work area. 

3.7 Employees chosen by the ARLF will receive first aid training, with refresher training provided as required.  The ARLF’s objective is to ensure that all Employees have reasonable access to a trained first aider in the event of illness, accident or emergency.   

3.8. In providing and maintaining a safe and healthy work environment, the ARLF will: 

• understand our legal obligations and the hazards and risks associated with work and that resources are provided to enable full implementation of ARLF’s WHS Policy and WHS Management System. Where ARLF does not have the necessary in-house knowledge or expertise to achieve this, ARLF will ensure that advice and guidance are obtained from competent WHS professionals;  

• establish processes to continuously improve WHS performance. This shall include workplace inspections, practices to support cultural safety and diversity in the workplace, the prompt control of identified hazards, monitoring of control measures and the recording of incidents; 

• identify and eliminate, isolate or minimise workplace hazards 

• provide training to all Board Members, Employees, Associates, Participants, Contractors and Volunteers to ensure they work in a safe and healthy manner and are aware of their responsibilities under this WHS Policy; 

• ensure there is effective Employee and Contractor consultation on WHS matters which shall include ‘two-way’ communication of relevant information, near miss reporting and feedback mechanisms.    

• Employees are encouraged to continuously improve WHS practices and procedures; 

• prevent Serious Injury through early intervention and support all injured employees through appropriate rehabilitation;  

• ensure all Contractors and Visitors are aware of the appropriate Risk Management Plan(s);  

• ensure compliance with prevailing WHS Acts and Regulations and codes of practice; 

• ensure all Board Members, Employees, Associates, Participants and Volunteers who are injured receive appropriate medical treatment and complete any necessary documentation in relation to the incident; and 
• ensure first aid equipment and training is made available. 

4. Responsibilities 

4.1 Creating a healthy and safe work environment is the responsibility of everyone at every level of ARLF. ARLF has delegated general and specific health and safety responsibilities applicable to the various levels of ARLF as set out below. Every level participates in the establishment and maintenance of the WHS controls as well as assisting in WHS planning.  

 4.1.1 The Chief Executive , Director Corporate Services and HR Representative will: 

• investigate all injuries/incidents; 

• review and monitor overall organisational health and safety performance; 

• ensure all affected by this WHS Policy are inducted and receive regular training as required to perform jobs safely;  

• facilitate rehabilitation including offering support or counselling as required;  

• participate where required in the resolution of safety issues; 

• review Serious Injury incidents and monitor corrective actions;  

• ensure organisational compliance with health and safety legislation; 

• demonstrate commitment to health and safety through participation in formal and informal discussions, workplace visits and hazard inspections; 

• participate, where required, in the resolution of safety issues; 

• ensure liaison with all affected under this WHS Policy, particularly on any workplace changes which have a health and safety component; 

• initiate actions to improve health and safety; 

• actively monitor the workplace to determine presence of hazards and take appropriate action to rectify any hazards found; and 

• participate in consultation as and when is deemed necessary. 

4.1.2 All Board Members, Employees, Participants, Contractors, Associates and Volunteers must: 

• comply with this WHS Policy; 

• adhere to all safe working procedures in accordance with instructions; 

• take reasonable care of themselves and others who may be affected by their actions; 

• participate in all training as requested; 

• participate in consultation processes as and when is deemed necessary; and 

• consider health and safety as an integral part of your work. 

4.1.3 Visitors must: 

• take reasonable care for his or her own health and safety; 

• report any hazards identified to an ARLF Employee; 

• take reasonable care that his or her acts or omissions do not adversely affect the health and safety of other persons; and 

• comply, so far as the person is reasonably able, with any reasonable instruction that is given by the ARLF to allow the ARLF comply with the WHS Acts and Regulations. 

4.2 Incident and injury 

• Serious injuries must be reported to the CE or an Executive team member (if CE is not available) as soon as possible. The CE or Executive team member will notify the relevant SafeWork authority as soon as possible by phone or email after the injury occurs. 

• Incidents, injuries and work-related illnesses must be reported by all in accordance with the necessary procedure using a Hazard/Incident Report Form and submitting the form to the line manager and Manager, Governance & HR  

• Incidents where a person could have been injured or equipment damaged (also referred to as a ‘near miss’) must also be reported. 

4.3 Workplace Representatives/Committees 

ARLF Health and Safety Representatives will be elected at an ARLF all-staff meeting and will hold office for up to three (3) years. 

4.4 Staff relevant ARLF Policies, Procedures and Resources 

For ARLF employees, this WHS Policy should be read in conjunction with the following documents: 

• ARLF WHS Management Plan 

• ARLF Emergency Management Procedure 

• ARLF Working From Home Policy 

• ARLF Hazards Register 

• ARLF program specific risk management plans (discuss with Project Lead) 

• Communicable and Infectious Diseases Policy 

• Employee Assistance Program 

• Travel policy and checklists 

• Incident reporting form [if link is not active email info@rural-leaders.org.au for a copy). 

5. Scope and application  

This policy applies to Employees, Board Members, Associates, Volunteers, Participants and Contractors. 

6. Responsibilities and ownership of this policy 

7. Review schedule