Guidelines for compliance with DFAT Minimum Standards
Partnering with DFAT
DFAT PSEAH Policy Minimum Standards
Griffith has a range of policies and procedures in place to address prevention, reporting and responding to SEAH incidents, as well as to set the expectations of staff; however, compliance with DFAT’s PSEAH Policy requires the University to manage risk in line with the Policy and its Minimum Standards.
To help staff identify the additional control measures required by DFAT for a specific project, the following guidelines can be applied. These additional control measures will ensure that Griffith remains compliant with the requirements of the Policy and its Minimum Standards and will build on the University’s own ethos, policies and procedures to prevent sexual exploitation, harassment and assault at Griffith.
For more information about Griffith’s existing PSEAH control measures and risk management processes, please refer to the second table further below.
Additional control measures
LOW RISK: Minimum Standards 1 and 2
Apply the following additional control measures for Minimum Standards 1 and 2
- Refer all personnel deployed and/or interacting with DFAT program participants and host communities to Griffith's dedicated PSEAH resource webpage. This website outlines the PSEAH related policies and procedures that are in place at Griffith as well as the expectations of the DFAT PSEAH Policy, including reporting and investigation information.
- Project/funding applications and tender documentation must contain appropriate wording in relation to Griffith’s compliance with DFAT’s PSEAH Policy.
- Contracts and agreements with University partners, including downstream partners and third-party providers, must contain a clause regarding adherence to the DFAT PSEAH Policy including that SEAH risk will be monitored and regularly re-assessed and that Griffith will report incidents as well as conduct a review of their operations.*
*Note: The University’s current agreements with exchange partners, institutional partners, and third-party providers, and vetted by Griffith Global Mobility and the International Development Unit, are in the process of being updated.
MEDIUM RISK: Minimum Standards 1 - 3
Apply the following control measures for Minimum Standards 1 and 2, plus:
- The SEAH risk assessment for the project must be approved by the relevant Head of Element prior to signing the contract or agreement with DFAT or a managing contractor. Note. If you use the risk assessment tool, approval from the Head of Element is built into the process for ensuring each project is suitably approved.
- Continually monitor risks and complete additional risk assessments using the risk assessment tool, particularly when there is a significant change to the context, environment or other risk factors that impact on the level of or change the SEAH risk.
HIGH RISK: Minimum Standards 1 - 5
Apply the additional control measures required for Minimum Standards 1 - 3, plus:
- All Griffith personnel (and students, when applicable) deployed and/or interacting with DFAT program participants and host communities need to complete the following:
» Griffith's Harassment and Discrimination and Fraud and Corruption Awareness training modules online, and then every 1-2 years for longer-term projects
» Complete the Recognise. Respond. Refer. module via Learning@Griffith
» Additional or specific training may be available from the Student Wellbeing and Safety team, but training needs are to be discussed initially with the Manager, International Partnerships.
- Ensure (and document) that University partners, including downstream partners and third-party providers, involved in project delivery have completed appropriate PSEAH training.
- Ensure (and document) that Griffith staff and students deployed and/or interacting with DFAT program participants and host communities: 1) Agree to undertake a criminal history check, if one has not already been completed within the last five years. For longer-term projects (i.e. > five years), criminal history checks must be completed again at the five-year mark. Alternatively, this could be a vulnerable people check or location-specific equivalent providing assurance that reasonable SEAH precautions have been taken. To determine an appropriate process to follow to ensure criminal history checks are completed and checked, it can be discussed with the relevant Head of Element and then with Human Resources and Safety; and 2) Ensure that local requirements are followed in relation to the appropriate vetting of Griffith staff and students.
- Ensure (and document) that University partners, including downstream partners and third-party providers, involved in project delivery will do the same as outlined above to vet their personnel and have processes in place to suspend or transfer implicated staff to other duties while under investigation and/or ensure that another appropriate University partner can be procured to continue project delivery if termination of the partnership/contract becomes necessary.
VERY HIGH RISK: Minimum Standards 1 - 7
Apply the additional control measures required for Minimum Standards 1 - 5, plus:
- Contact the Integrity and Privacy Officer in Griffith Legal Services’ about high exposure training for staff and students involved in very high-risk settings for project delivery.
- Undertake (and document) additional due diligence checks for University partners, including downstream partners and third-party providers, involved in project delivery to ensure they are aware of and comply with Minimum Standards 6-7 and that these apply to their staff working in very high-risk settings.
- Include specific wording about Minimum Standards 6-7 in agreements and contracts being entered into with University partners for project delivery.
Existing control measures
LOW RISK: Minimum Standards 1 and 2
Griffith's existing control measures that comply with Minimum Standards 1 and 2
General
- The University’s expectations for student and staff conduct, which include the prevention of discrimination, harassment and bullying, sexual harassment and assault, are outlined within the Student Charter and staff Code of Conduct.
Reporting and investigation
- Griffith investigates complaints including PSEAH non-compliance within its relevant policies and in accordance with anti-discrimination and other applicable laws.
- SEAH incidents can be reported via the Safe Campuses website. Incidents that occur throughout the delivery of any DFAT related business will be flagged and reported in line with PSEAH Policy reporting requirements.
- The University's Staff Harassment, Bullying and Discrimination Policy and Limit on Confidentiality statements are being updated to include DFAT’s PSEAH Policy mandatory reporting requirements.
- Griffith's Recognise. Respond. Refer. for SASH responder network training and Discrimination and Harassment Contact Officer network training is being updated to include DFAT’s PSEAH Policy mandatory reporting requirements.
- Griffith International will produce regular compliance reports for members of the senior executive and key stakeholders as a key risk management and evaluation activity and to communicate regularly with staff about the expectations of this Policy.
Student and HDR candidate mobility
- Griffith students participating in outbound student mobility and DFAT funded scholarship programs, including the New Colombo Plan (NCP), undertake PSEAH training as part of their compulsory online pre-departure program, facilitated by Griffith Global Mobility, and sign a mobility specific Code of Conduct confirming their completion of the training and that they will comply with DFAT’s PSEAH Policy by upholding appropriate behaviours, ensuring reporting obligations are met, and upholding the PSEAH requirements of Griffith.
- The above requirement also applies to Griffith students involved in research projects that are funded by DFAT.
- Staff delivering pre-departure and orientation information to DFAT scholarship or grant awardees, including Australia Awards Scholarship recipients and short course program participants, are made aware of their obligations in relation to DFAT’s PSEAH Policy. The materials provided to awardees and participants include links to SEAH reporting channels via the Safe Campuses and Partnering with DFAT websites. They are also provided with information about the key support services that are available to them, if experiencing, responding to or being a bystander to, disclosing, or reporting an incident of SEAH.
MEDIUM RISK: Minimum Standard 3
- Griffith has a SEAH risk assessment tool and risk register in place for DFAT projects. A risk assessment using the tool is completed and approved by the relevant Head of Element prior to signing the contract/agreement with DFAT or a managing contractor.
- The tool also allows for additional risk assessments to be completed for the same project for ongoing risk monitoring and re-assessment, particularly when there is a significant change to the context, environment or other risk factors that impact on the level of or change the SEAH risk.
- Members of the Griffith Senior Executive have access to the risk register and may request additional information and/or that changes be made to the personnel deployed, downstream partners, and/or to the control measures to further mitigate and manage SEAH risk.
Griffith's existing control measures that comply with Minimum Standard 3
HIGH RISK: Minimum Standards 4 and 5
Griffith's existing control measures that comply with Minimum Standards 4 and 5
Training
- Across several Griffith policies, all staff and students are encouraged to participate in PSEAH training and awareness activities.
- Consent, consensual behaviour, and bystander intervention related training is available to all staff and students via the MATE Bystander Program organisation on Learning@Griffith.
- All commencing students, as part of myOrientation, must complete a ‘Consent Matters' online module. This module addresses issues of sexual consent and is a compulsory requirement.
- All staff, including those with supervisory and management roles, have a responsibility to prevent and, if necessary, respond to behaviour such as bullying, harassment and discrimination.
- All staff are expected to complete Griffith’s online Harassment and Discrimination training, both on commencement at the University and then at least every two years, as well as the University’s Fraud and Corruption Awareness training. The University maintains a register of staff who have completed these training programs.
- All staff, particularly those in roles which are likely to hear disclosures of sexual assault or harassment are expected to complete the Recognise. Respond. Refer. module on Learning@Griffith.
- Mandatory PSEAH training is a requirement for new research, masters and PhD supervisors to increase their understanding of the boundaries of supervision, appropriate behaviours and power imbalance which can occur in supervisor-candidate relationships.
- Resources to proactively assist staff and students to deal with such behaviours are available online via the Human Resources and Safety and Safe Campuses websites.
- Refer to Minimum Standards 1-2 for training information in relation to DFAT funded student and HDR candidate mobility activities.
Recruitment and screening
- Criminal history checks are completed at the time of appointment for key positions and critical roles. Corporate Services engages an external provider, National Crime Check, to conduct criminal history checks for roles within Corporate Services. For other positions, criminal history checks are not compulsory. Staff, students and HDR candidates planning to participate in higher-risk settings to deliver DFAT-funded projects will be asked to undertake a criminal history check prior to participating in the project and in accordance with the 5-year timelines stipulated by the DFAT PSEAH Policy. As part of the criminal history check process, SEAH related offences are disclosed.
- As part of the University’s recruitment and selection process, 2 – 3 references are sought from the preferred candidate’s referees (normally including one from the current or most recent supervisor).
- The University’s Letter of Offer for the appointment of staff includes the conditions of their employment covered by the enterprise agreement, which covers unsatisfactory work performance and dealing with misconduct/serious misconduct.
- Letters of Offer include links to key policies such as Code of Conduct and Conflict of Interest policy.
- Performance reviews for Griffith staff are conducted in accordance with the University’s policies and procedures.
VERY HIGH RISK: Minimum Standards 6 and 7
- The policies that cover the University prohibiting transactional sex and fraternisation include: Staff Code of Conduct; Personal Relationships in the Workplace; Griffith Health Code of Professional Practice; Staff Harassment, Bullying and Discrimination Policy; Staff Sexual Assault and Sexual Harassment Policy; Fraud and Corruption Control Framework; and the Enterprise Risk Management Framework.
- The Griffith Integrity Program initiative offers high exposure training for critical roles in Fraud and Corruption Control as well as requiring employment screening for staff who may have high exposure to related risks.
Griffith's existing control measures that comply with Minimum Standards 6 and 7
MORE INFORMATION
For more information on DFAT's PSEAH policy, please contact the Manager, International Relations