Zero tolerance for harm, with robust systems to prevent, detect, respond, and learn
This policy sets out Together Two Limited’s (trading as Rozelle Neighbourhood Centre) absolute commitment to preventing abuse, neglect, and exploitation of participants, and the systems we maintain to detect, respond to, investigate, and learn from any allegation or incident of harm.
Every person has the right to live a life free from violence, abuse, harm, neglect, and exploitation. This right is not conditional on a person’s age, gender, disability, cultural background, communication ability, behaviour, or any other characteristic. For participants with complex communication needs, cognitive disability, psychosocial disability, or autism, this right requires active vigilance, because harm is harder to detect when a person cannot verbally report it.
Together Two supports participants who are among the most vulnerable in our community. Our SIL services provide 24/7 support to 14 participants with complex behavioural and psychosocial needs, many requiring staffing ratios of 1:1, 2:1, or 3:1. The intimacy and intensity of this support creates both opportunity for genuine connection and risk of power imbalance. This policy ensures that our safeguarding systems are proportionate to that risk.
→ Participant Rights Policy: Section 5.5 (Freedom from Violence, Abuse, Neglect, Exploitation, and Discrimination); Risk Register (Form 01): Risks #13 (Worker misconduct) and #18 (Incident management failure).
This policy applies at all times and in all locations where Together Two provides or arranges supports and services. This includes SIL dwellings, the ZigZag Day Program, in-home supports, community-based supports, SLES, support coordination, transport, and any setting where a participant is receiving support from Together Two or its representatives.
It applies to all representatives of Together Two including the Board of Directors, Senior Leadership Team, permanent and casual workers, contractors, volunteers (including Good in the Hood volunteers), and students on placement.
It applies to allegations of abuse, neglect, or exploitation committed by any person, including workers, other participants, family members, members of the public, or unknown persons.
This policy supports compliance with:
National Disability Insurance Scheme Act 2013 (Cth)
NDIS (Provider Registration and Practice Standards) Rules 2018, Core Module: Rights and Responsibilities (Freedom from Violence, Abuse, Neglect, Exploitation, and Discrimination outcome)
NDIS (Incident Management and Reportable Incidents) Rules 2018
NDIS (Code of Conduct) Rules 2018
NDIS (Restrictive Practices and Behaviour Support) Rules 2018
Crimes Act 1900 (NSW)
Children’s Guardian Act 2019 (NSW)
Children and Young Persons (Care and Protection) Act 1998 (NSW)
Disability Discrimination Act 1992 (Cth)
Work Health and Safety Act 2011 (NSW)
Privacy Act 1988 (Cth) and Australian Privacy Principles
United Nations Convention on the Rights of Persons with Disabilities (UNCRPD)
→ Business and Operational Plan 2025–2028: Section 9 (Legislative and Regulatory Framework) and Compliance Register (Form 17).
Understanding what constitutes abuse, neglect, and exploitation is essential for all workers. The following definitions apply in the context of this policy.
Abuse is any act, or failure to act, that causes harm or creates a risk of harm to a participant. Abuse may be a single incident or a pattern of behaviour. Types of abuse include:
Physical abuse: hitting, slapping, pushing, kicking, restraining (outside an authorised behaviour support plan), burning, force-feeding, rough handling, or any other use of physical force against a participant.
Sexual abuse: any sexual act or behaviour directed at a participant without their informed consent, including sexual assault, indecent assault, sexual touching, exposure, grooming, and sexual misconduct in the presence of a participant.
Emotional or psychological abuse: intimidation, threats, humiliation, verbal abuse, isolation, gaslighting, coercive control, or any behaviour intended to cause fear, distress, or psychological harm.
Financial abuse: theft, fraud, misuse, or mismanagement of a participant’s money, property, or NDIS funding. This includes pressuring a participant to change financial arrangements, using a participant’s funds for purposes not intended by the participant, or failing to account for expenditure.
Neglect is the failure to provide the care, support, or supervision that a participant needs, resulting in harm or risk of harm. Neglect may be deliberate or may result from a lack of knowledge, skill, or resource. Examples include:
Failure to provide adequate food, water, clothing, shelter, or hygiene.
Failure to provide prescribed medication or to follow a participant’s mealtime management, epilepsy management, or other clinical support plan.
Failure to respond to a participant’s health needs, including failure to seek medical attention when needed.
Failure to provide adequate supervision, resulting in harm or risk of harm.
Leaving a participant in an unsafe environment or situation.
Failure to implement a participant’s positive behaviour support plan, resulting in harm or escalation.
Ignoring or failing to respond to indicators that a participant is in distress, pain, or danger.
Exploitation is the improper use of a participant’s trust, or the participant’s position of vulnerability, for the benefit of another person. This includes:
Financial exploitation, as described above.
Using a participant for personal or organisational benefit without their informed consent.
Taking advantage of a participant’s cognitive or communication disability to obtain consent that is not truly informed.
Using images, recordings, or information about a participant for purposes the participant has not consented to.
Prevention is the most important element of safeguarding. Together Two maintains the following preventive systems:
All workers undergo pre-employment screening including NDIS Worker Screening Check, Working with Children Check (where applicable), national criminal history check, reference checks, and verification of qualifications.
Workers who fail screening, or who cannot renew their screening clearance, are immediately removed from participant-facing roles.
Recruitment processes are designed to identify candidates who demonstrate the values, attitudes, and behaviours consistent with the NDIS Code of Conduct and a rights-based approach to support.
Contractor and volunteer screening follows the same principles, including Good in the Hood volunteers who interact with participants.
→ Worker Screening Policy; Human Resources Policy.
All workers complete the NDIS Worker Orientation Module as part of induction, which includes content on abuse recognition and the NDIS Code of Conduct.
Induction training specifically covers recognising, preventing, and responding to abuse, neglect, and exploitation, with practical examples relevant to Together Two’s service types (SIL, in-home, community, group programs).
Training addresses the specific vulnerabilities of participants with complex communication needs, cognitive disability, psychosocial disability, and autism, including how abuse may present differently when a participant cannot verbally report.
Refresher training on safeguarding is provided annually and following any significant incident.
Training records are maintained in the Skill and Competency Matrix and Microsoft Dynamics 365.
→ Human Resources Policy; Business and Operational Plan 2025–2028: Section 10 (Workforce Plan).
Workers delivering complex supports receive regular supervision where safeguarding is a standing discussion item.
SIL settings have structured oversight including shift handovers, participant welfare checks, and management site visits.
Performance management includes assessment of the worker’s compliance with the NDIS Code of Conduct and safeguarding practices.
The on-call system is available outside business hours for workers to seek advice when dealing with concerns about participant safety, reportable incidents, or allegations of harm.
The Circles of Support model provides a powerful safeguarding layer that complements organisational systems. Trusted people around a participant, particularly those in the Circle of Intimacy, notice changes in behaviour, mood, physical condition, or wellbeing that may indicate harm. They can raise concerns when the participant cannot.
Together Two actively encourages circle members to raise concerns through any channel: directly with workers, with management, through the Support Circuits AI portal, through the Family and Supporter Committee, or directly with the NDIS Commission or an independent advocate. We will never treat a concern from a circle member as an inconvenience or overreaction.
→ Circles of Support Engagement Framework: Giving Voice to Those Who Cannot Speak.
SIL dwellings are maintained in a safe and appropriate condition, with regular inspections and risk assessments.
Security measures are proportionate to participant needs and do not unreasonably restrict participant freedom (any restriction requires authorisation as a regulated restrictive practice).
Closed-circuit television (CCTV) or surveillance is only used in accordance with privacy legislation and with participant consent, and never in private areas such as bedrooms and bathrooms.
All workers are trained to recognise indicators that a participant may be experiencing or at risk of abuse, neglect, or exploitation. Indicators may include:
Unexplained injuries, bruises, burns, or marks, particularly in patterns or at different stages of healing.
Changes in behaviour, including withdrawal, increased agitation, anxiety, fearfulness, or reluctance to be around a particular person.
Deterioration in physical condition, hygiene, weight, or general health.
Unexplained changes in financial situation, missing money or belongings, or unexplained transactions.
Reluctance to speak or communicate, or signs of distress when certain topics or people are mentioned.
Sexually transmitted infections, injuries to genital areas, or other indicators of sexual abuse.
A participant becoming increasingly isolated from their Circle of Support or from community activities.
Workers or other persons behaving inappropriately with a participant, including boundary violations, secrecy, or attempts to isolate the participant.
The presence of one or more indicators does not confirm that abuse has occurred, but it does require a response. Workers must report concerns to their supervisor or manager immediately.
When abuse, neglect, or exploitation is alleged, suspected, or witnessed, the following response is required:
Ensure the participant is safe and protected from further harm. This is the absolute first priority.
If the participant requires medical attention, call 000 or arrange immediate medical care.
If criminal conduct is alleged or suspected (including physical assault, sexual assault, theft, or fraud), contact NSW Police.
Separate the participant from the alleged perpetrator where this can be done safely.
Preserve and record any evidence, including photographs of the scene and any relevant physical evidence. Do not clean up or alter the scene.
Record what is known about the incident, including the people involved, witnesses, and any immediate observations.
Outside business hours, contact the on-call manager for advice and support.
Notify the relevant Head of Department or the CEO immediately.
The NDIS Quality and Safeguards Commission must be notified within 24 hours of the organisation becoming aware of a reportable incident. Reportable incidents include the death of a participant, serious injury, abuse or neglect, unlawful sexual or physical contact or assault, sexual misconduct, and unauthorised use of a restrictive practice.
NSW Police must be notified where criminal conduct is alleged or suspected.
The NSW Child Protection Helpline (132 111) must be contacted where a child or young person is suspected to be at risk of significant harm.
The participant’s family, guardian, or substitute decision maker must be notified as soon as practicable, unless that person is the alleged perpetrator. Notification is made with sensitivity and with regard to the participant’s privacy.
SafeWork NSW must be notified if the incident involves a workplace injury or death, in accordance with the Work Health and Safety Act 2011 (NSW).
The participant is supported by an independent person, which may include a family member, friend, advocate, or legal practitioner.
The participant is informed about what is happening, what actions are being taken, and what to expect, in a way they are most likely to understand.
Appropriate physical, emotional, and psychological support is made available and easily accessible.
The participant and their support network are informed of their right to access independent advocacy and to make a complaint directly to the NDIS Commission.
The participant’s Circle of Support is kept informed (with the participant’s consent) and involved in planning ongoing support.
All allegations of abuse, neglect, or exploitation are investigated. The scope and method of investigation is proportionate to the severity and nature of the allegation.
Investigations are conducted promptly, objectively, and in accordance with procedural fairness. All parties are given the opportunity to provide their account.
Where an allegation involves a worker, the worker may be stood down or reassigned pending investigation, to protect the participant and ensure the integrity of the investigation.
Where an external investigation is being conducted by NSW Police, the NDIS Commission, or another authority, Together Two cooperates fully and does not interfere with the external process.
Investigation findings are documented, including the evidence considered, conclusions reached, and actions taken.
Where an allegation is substantiated, Together Two takes appropriate action. This may include disciplinary action against a worker (up to and including termination of employment), referral to NSW Police, referral to the NDIS Commission, changes to support arrangements, and review of policies and procedures.
The participant is informed of the outcome of the investigation, in a way they are most likely to understand, and supported through any changes.
All findings and corrective actions are documented in the incident register and the Continuous Improvement Register.
Learnings from the investigation are incorporated into training, supervision, and policy review.
→ Incident Management Policy; Complaint Management Policy; Continuous Improvement Policy; Internal Audit Schedule and CI Register.
The following actions, when undertaken appropriately and in accordance with relevant policies, do not constitute abuse:
Implementing an authorised regulated restrictive practice in accordance with a positive behaviour support plan that has been developed by a qualified behaviour support practitioner, consented to by the participant or their substitute decision maker, and authorised under the relevant NSW scheme.
Taking reasonable steps to disarm a participant who is seeking to harm themselves or others, where there is an immediate risk of serious injury.
Separating participants who are physically fighting, where there is an immediate risk of injury.
Moving a participant out of immediate danger, such as away from a fire, a traffic hazard, or a falling object.
Reasonable use of force in self-defence or in the defence of others, as a last resort, where there is an immediate risk of serious injury.
Any use of physical intervention must be reported as an incident and documented, even where the action falls within these exceptions. The Incident Management Policy applies.
→ Positive Behaviour Support Policy; Restrictive Practices Policy; Incident Management Policy.
All incidents of alleged, suspected, or actual abuse, neglect, or exploitation are recorded in the incident register with full details of the allegation, the response, the investigation, and the outcome.
Records include the date, time, location, people involved, witnesses, actions taken, notifications made, and any evidence collected.
All incident records are stored securely and are accessible only to persons responsible for incident management and investigation.
Records are retained for a minimum of seven years from the date of the incident.
Records are made available to the NDIS Commission, NSW Police, or other authorities upon request.
Together Two maintains a culture where reporting concerns is expected, supported, and protected. No person will ever face retribution, penalty, or adverse consequences for raising a concern, making a report, or cooperating with an investigation, whether internal or external.
This commitment extends to participants, family members, circle members, workers, volunteers, advocates, and any other person. Together Two’s Whistleblower Policy provides additional protections for persons who report wrongdoing.
Any attempt to cover up, conceal, minimise, or fail to report suspected or actual incidents of abuse, neglect, or exploitation is itself a serious breach of this policy and the NDIS Code of Conduct. Such conduct will result in disciplinary action up to and including termination of employment, and may be reported to the NDIS Commission and NSW Police.
→ Participant Rights Policy: Section 10 (Reporting Concerns); Whistleblower Policy.
Provide supports in a manner consistent with the NDIS Code of Conduct, treating participants with respect and dignity at all times.
Recognise indicators of abuse, neglect, and exploitation and report concerns immediately to their supervisor, manager, or the on-call system.
Respond promptly to protect the participant from further harm.
Preserve evidence and record observations.
Cooperate fully with investigations by Together Two, the NDIS Commission, NSW Police, or any other authority.
Never engage in, facilitate, or tolerate abuse, neglect, or exploitation of a participant under any circumstances.
Aisling Scully, Head of NDIS Services (Policy Owner), is responsible for ensuring safeguarding practices are embedded in all NDIS service delivery and that all NDIS workers are trained and supervised.
Sergio Pinzon, Head of HR and Business Improvement, is responsible for ensuring worker screening, induction, and training systems support the prevention of abuse, neglect, and exploitation.
Rei Guzman, Head of Aged Care and Clinical Services, is responsible for ensuring clinical safeguarding, including the recognition of harm indicators during high-intensity support delivery.
Steven Lowrie, CEO, has overall accountability for safeguarding across the organisation and is responsible for ensuring reportable incidents are notified to the NDIS Commission within required timeframes.
The Board receives reports on safeguarding incidents, trends, and outcomes as part of its standing governance, risk, and quality agenda items.
The Board ensures that the organisation’s safeguarding systems are proportionate to the size, scale, scope, and complexity of the services delivered.
→ Business and Operational Plan 2025–2028: Section 3 (Governance Framework) and Section 6 (Risk Management).
Any worker found to have perpetrated, facilitated, or failed to report any form of abuse, neglect, or exploitation will face disciplinary action up to and including immediate termination of employment. Together Two may also:
Report the matter to NSW Police for criminal investigation.
Report the worker to the NDIS Commission, which may result in a banning order preventing the worker from providing NDIS supports.
Report the matter to SafeWork NSW where relevant.
Cooperate with any regulatory or legal proceedings that result from the matter.
This policy directly addresses the Freedom from Violence, Abuse, Neglect, Exploitation, and Discrimination outcome within the NDIS Practice Standards Core Module: Rights and Responsibilities.
| Quality Indicator | How Together Two Demonstrates This | Evidence |
|---|---|---|
| Policies and procedures actively prevent violence, abuse, neglect, exploitation, and discrimination | Worker screening; induction and ongoing safeguarding training; supervision with safeguarding as standing item; Circles of Support as detection mechanism; environmental safeguards in SIL | Screening records; training records (Skill and Competency Matrix); supervision notes; Circle of Support maps; site risk assessments |
| Allegations are acted upon and each participant is supported through the process | Immediate response protocol; NDIS Commission notification within 24 hours; participant supported by independent person; advocacy access; investigation conducted promptly with procedural fairness | Incident register; NDIS Commission notification records; investigation reports; participant support records; advocacy referral records |
| Continuous improvement in safeguarding through review of incidents and incorporation of learnings | Investigation findings feed into CI Register; learnings incorporated into training and policy review; Board oversight of safeguarding trends | CI Register entries; updated training materials; Board reports; policy review records |
| Pathway | Contact | When to Use |
|---|---|---|
| Together Two, internal | Your supervisor, Head of Department, or CEO. After hours: on-call manager. | All concerns about participant safety, all allegations, all suspected or witnessed incidents |
| NDIS Quality and Safeguards Commission | 1800 035 544 or ndiscommission.gov.au | Reportable incidents (within 24 hours); complaints about any NDIS provider |
| NSW Police | 000 (emergency) or local police station | Criminal conduct including assault, sexual assault, theft, fraud |
| NSW Child Protection Helpline | 132 111 | Child or young person at risk of significant harm |
| SafeWork NSW | 13 10 50 | Workplace death, serious injury, or dangerous incident |
| Independent advocacy | Disability Advocacy NSW: 1300 365 085; PWDA: 1800 422 015 | When a participant or family wants independent support to raise a concern |
Key companions: Participant Rights Policy; Incident Management Policy; Worker Screening Policy; Child Safe Policy; Circles of Support Engagement Framework; Complaint Management Policy; Advocacy Policy; NDIS Code of Conduct Policy; Positive Behaviour Support Policy; Restrictive Practices Policy; Human Resources Policy; Whistleblower Policy; Duty of Care and Dignity of Risk Policy; Privacy and Confidentiality Policy; Risk Register (Form 01); Skill and Competency Matrix; Continuous Improvement Policy.
| Version | Date | Author | Change Description |
|---|---|---|---|
| 1.0 | May 2023 | Emma Pollard (Centro Assist) | Initial version, generic template |
| 2.0 | March 2026 | Steven Lowrie, CEO | Complete rewrite. Organisation-specific safeguarding content reflecting Together Two’s specialist SIL services, complex participant cohort, and the Circles of Support model as a safeguarding mechanism. Detailed definitions added. Structured response protocol. NSW-specific reporting pathways. Aligned to NDIS Practice Standards Core Module quality indicators and Risk Register. |