Policies

CONFLICTS OF INTEREST POLICY

Darussalaam Welfare Centre Limited

    1 Purpose
The purpose of this policy is to help board members of Darussalaam Welfare Centre to effectively identify, disclose and manage any actual, potential or perceived conflicts of interest in order to protect the integrity of Darussalaam Welfare Centre and manage risk.
    2 Objective
The board aims to ensure that board members are aware of their obligations to disclose any conflicts of interest that they may have, and to comply with this policy to ensure they effectively manage those conflicts of interest as representatives of Darussalaam Welfare Centre.
    3 Scope
This policy applies to the board members of Darussalaam Welfare Centre.
    4 Definition of conflicts of interests
A conflict of interest occurs when a person’s personal interests conflict with their responsibility to act in the best interests of the charity. Personal interests include direct interests as well as those of family, friends, or other organisations a person may be involved with or have an interest in (for example, as a shareholder). It also includes a conflict between a board member’s duty to Darussalaam Welfare Centre and another duty that the board member has (for example, to another charity). A conflict of interest may be actual, potential or perceived and may be financial or non‑financial.
These situations present the risk that a person will make a decision based on, or affected by, these influences, rather than in the best interests of the charity and must be managed accordingly.
    5 Policy
This policy has been developed because conflicts of interest commonly arise, and do not need to present a problem to the charity if they are openly and effectively managed. It is the policy of the Darussalaam Welfare Centre as well as a responsibility of the board, that ethical, legal, financial or other conflicts of interest be avoided and that any such conflicts (where they do arise) do not conflict with the obligations to Darussalaam Welfare Centre.
Darussalaam Welfare Centre will manage conflicts of interest by requiring board members to:
        ◦ avoid conflicts of interest where possible
        ◦ identify and disclose any conflicts of interest
        ◦ carefully manage any conflicts of interest, and
        ◦ follow this policy and respond to any breaches.
        5.1 Responsibility of the board
The board is responsible for:
        ◦ establishing a system for identifying, disclosing and managing conflicts of interest across the charity
        ◦ monitoring compliance with this policy, and
        ◦ reviewing this policy on an annual basis, to ensure that the policy is operating effectively.
The charity must ensure that its board members are aware of the ACNC governance standards, particularly governance standard 5, and that they disclose any actual or perceived material conflicts of interests as required by governance standard 5.
        5.2 Identification and disclosure of conflicts of interest
Once an actual, potential or perceived conflict of interest is identified, it must be entered into Darussalaam Welfare Centre’s register of interests, as well as being raised with the board. Where all of the other board members share a conflict, the board should refer to governance standard 5 to ensure that proper disclosure occurs.
The register of interests must be maintained by the secretary, and record information related to a conflict of interest (including the nature and extent of the conflict of interest and any steps taken to address it).
    6 Action required for management of conflicts of interest
        6.1 Conflicts of interest of board members
Once the conflict of interest has been appropriately disclosed, the board (excluding the board member disclosing and any other conflicted board member) must decide whether or not those conflicted board members should:
        ◦ vote on the matter (this is a minimum),
        ◦ participate in any debate, or
        ◦ be present in the room during the debate and the voting.
In exceptional circumstances, such as where a conflict is very significant or likely to prevent a board member from regularly participating in discussions, it may be worth the board considering whether it is appropriate for the person conflicted to resign from the board.
        6.2 What should be considered when deciding what action to take
In deciding what approach to take, the board will consider:
        ◦ whether the conflict needs to be avoided or simply documented
        ◦ whether the conflict will realistically impair the disclosing person’s capacity to impartially participate in decision‑making
        ◦ alternative options to avoid the conflict
        ◦ the charity’s objects and resources, and
        ◦ the possibility of creating an appearance of improper conduct that might impair confidence in, or the reputation of, the charity.
The approval of any action requires the agreement of at least a majority of the board (excluding any conflicted board member/s) who are present and voting at the meeting. The action and result of the voting will be recorded in the minutes of the meeting and in the register of interests.
    7 Compliance with this policy
If the board has a reason to believe that a person subject to the policy has failed to comply with it, it will investigate the circumstances.
If it is found that this person has failed to disclose a conflict of interest, the board may take action against them. This may include seeking to terminate their relationship with the charity.
    8 Contacts
For questions about this policy, contact the chair of the board or secretary of Darussalaam Welfare Centre.

PRIVACY POLICY
Darussalaam Welfare Centre Limited

Darussalaam Welfare Centre Limited (DWC) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone and facsimile numbers.

This Personal Information is obtained by interviews, correspondence, telephone and email and from third parties. We do not guarantee website links or policy of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:
•    For the primary purpose for which it was obtained
•    For a secondary purpose that is directly related to the primary purpose
•    With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:
•    Third parties where you consent to the use or disclosure; and
•    Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Darussalaam Welfare Centre Ltd. will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:
e-mail: [email protected]

Darussalaam Welfare Centre Limited
Safeguarding Policy

Policy Statement

    1. All people, regardless of their age, gender, race, religious beliefs, disability, sexual orientation, or family or social background, have equal rights to protection from abuse, neglect or exploitation.
    2. Darussalaam Welfare Centre Limited (DWC) commits to promoting and protecting the welfare and human rights of people that interact with, or are affected by, our work - particularly those that may be at risk of abuse, neglect or exploitation. We have no tolerance for abuse, neglect or exploitation. We will take a survivor-centric approach in all that we do.
    3. All staff, volunteers, partners and third parties of Darussalaam Welfare Centre Limited share responsibility for protecting everyone from abuse, neglect or exploitation. Beyond this, particular people have specific responsibilities, and they must carry out their duties without exception.
    4. Darussalaam Welfare Centre Limited has a process for managing incidents that must be followed when one arises.

Purpose

    5. The purpose of this policy is to:
        a. Help protect people that interact with, or are affected by, Darussalaam Welfare Centre Limited.
        b. Define the key terms we use when talking about protecting people or safeguarding.
        c. Set out and develop the way Darussalaam Welfare Centre Limited manages safeguarding risks.
        d. Set out the specific roles and responsibilities of persons working in and with Darussalaam Welfare Centre Limited.
        e. Facilitate the safe management of incidents.
        f. To support a positive and effective internal culture towards safeguarding.

Definitions

    6. ‘Safeguarding’ means protecting the welfare and human rights of people that interact with, or are affected by, Darussalaam Welfare Centre Limited, particularly those that might be at risk of abuse, neglect or exploitation. This refers to any responsibility or measure undertaken to protect a person from harm.
    7. ‘Abuse, neglect or exploitation’ means all forms of physical and mental abuse, exploitation, coercion or ill-treatment. This might include, for example:
        a. Sexual harassment, bullying or abuse;
        b. Sexual criminal offences and serious sexual criminal offences;
        c. Threats of, or actual violence, verbal, emotional or social abuse;
        d. Cultural or identity abuse, such as racial, sexual or gender-based discrimination or hate crime;
        e. Coercion and exploitation;
        f. Abuse of power.
    8. ‘Reasonable grounds to suspect’ is a situation where a person has some information that leads them believe that abuse, neglect or exploitation has taken place, is taking place, or may take place. It comes with a low burden of proof (in fact, no proof is needed at all), but is based on some information. Questions that may help a person to determine whether they have ‘reasonable grounds to suspect’ might include:
        a. Could you explain to another person why you suspect something? This helps to make sure that your suspicion is based on information, even if you have no proof.
        b. Would an objective other person, with the same information as you, come to the same conclusion? This helps to make sure that your suspicion is as objective as possible.
    9. A ‘survivor-centric approach’ means considering and lawfully prioritising the needs, right and wishes of survivors.

Roles and responsibilities

    10. While the responsibility to protect people is shared by all who work at or with Darussalaam Welfare Centre Limited, some individuals have specific obligations with which they must comply.
    11. The members of the board of Darussalaam Welfare Centre Limited are responsible for:
        a. Protecting all people that interact with, or are affected by, Darussalaam Welfare Centre Limited;
        b. Ensuring that there are appropriate and effective ways for Darussalaam Welfare Centre Limited to do this;
        c. Ensuring that Darussalaam Welfare Centre Limited observes all relevant laws relating to safeguarding;
        d. Ensuring that Darussalaam Welfare Centre Limited takes a survivor-centric approach.
    12. The Chief Executive Officer of Darussalaam Welfare Centre Limited must:
    a. Ensure Darussalaam Welfare Centre Limited has effective and appropriate ways to manage safeguarding and legal compliance;
    b. (If necessary) Ensure the appointment of a Safeguarding Manager with appropriate skills and competency;
    c. Ensure that, within the charity’s approach, reasonable steps are taken to protect people;
    d. Ensure that reports to external parties are made where required.
    13. The Safeguarding Manager of Darussalaam Welfare Centre Limited must:
    a. Manage reports of abuse, neglect or exploitation;
    b. Ensure that all staff, contractors, and volunteers are aware of relevant laws, policies and procedures, and Darussalaam Welfare Centre Limited (DWC)’s Code of Conduct;
    c. Ensure that all staff, contractors and volunteers are aware of their obligations to report suspected incidents of abuse, neglect or exploitation;
    d. Manage reports of abuse, neglect or exploitation;
    e. Provide support for staff, contractors and volunteers in undertaking their responsibilities.
    14. All Managers of Darussalaam Welfare Centre Limited must:
    a. Promote a positive culture towards safeguarding;
    b. Implement this policy in their area of responsibility;
    c. Ensure that the risks of incidents have been considered in their area of responsibility;
    d. Ensure that there are appropriate controls in place to prevent, detect and respond to incidents;
    e. Facilitate the reporting of any suspected abuse, neglect or exploitation;
    f. Take a survivor-centric approach to potential incidents and ensure that any incident is dealt with transparently and accountably.
    15. All Staff and Volunteers of Darussalaam Welfare Centre Limited must:
        a. Familiarise themselves with the relevant laws, the Code of Conduct, policies and procedures for safeguarding;
        b. Comply with all requirements;
        c. Report any incident to the appropriate authority when it is reasonable to suspect that a person’s safety or welfare is at risk
        d. Report any suspicion that a person’s safety or welfare may be at risk to the appropriate authority; and
        e. Provide an environment that is supportive of everyone’s emotional and physical safety.
    16. All partners and contractors of Darussalaam Welfare Centre Limited (DWC) must:
        a. Implement the provisions of this policy and DWC’s procedures in their dealings with Darussalaam Welfare Centre Limited;
        b. Report any suspicion that an incident may have taken place, is taking place, or could take place.

Managing safeguarding risk

    17. The way Darussalaam Welfare Centre Limited (DWC) manages the risks of safeguarding will be:
        a. Holistic. DWC and its stakeholders will work to prevent, detect and take action on incidents.
        b. Risk-based and proportionate. DWC will regularly assess the risks to people in its operations and develop proportionate controls to mitigate those risks.
        c. Survivor-centric. DWC will put survivors at the heart of its approach to safeguarding.
        d. Lawful. DWC will ensure that it understands and complies with the law in everything it does, in all jurisdictions in which it works.
    18. Darussalaam Welfare Centre Limited (DWC) will manage the risk of safeguarding by:
        a. Having up-to-date and documented risk assessments;
        b. Maintaining a register of DWC’s legal obligations for safeguarding and workplace health and safety in all the jurisdictions in which it operates;
        c. Having an action plan that sets out how it will manage safeguarding;
        d. Adhering to this Safeguarding Policy and its Code of Conduct;
        e. Doing due diligence checks of staff, volunteers and third parties;
        f. Implementing policies, procedures and systems that introduce controls to reduce the likelihood and consequence of incidents;
        g. Conducting awareness-raising for stakeholders on risks, expectations, and individual responsibilities;
        h. Maintaining two reporting processes: the confidential reporting process, and the overt reporting process;
        i. Having an incident response plan;
        j. Monitoring and reviewing the effectiveness and proportionality of its safeguarding approach.

Managing Incidents

    19. Harassment, abuse, neglect and exploitation are all serious misconduct and Darussalaam Welfare Centre Limited reserves the right to:
        a. Take disciplinary action against those it believes are responsible, which may include dismissal;
        b. Take civil legal action;
        c. Report the matter to law enforcement.
Reporting suspected incidents
    20. All staff, volunteers and third parties must, as soon as practicable, report any suspicion that an incident has taken place, may be taking place, or could take place.
    21. They may do this through direct reporting to:
        a. Any member of the board;
        b. The Chief Executive Officer;
        c. The Safeguarding Manager;
        d. Their Manager or Supervisor.
    22. If a person wants to report confidentially, including with anonymity, they may use the confidential reporting system, which is:
        a. A dedicated hotline;
        b. Any web-enabled device. Access will be granted through a pre-configured reporting form via a QR code or unique URL
        c. Alternatively, can contact any of the following responsible persons of DWC Ltd:
            i. Chair
            ii. Directors
            iii. Safeguarding Manager
    23. If a person believes that another person is at risk of immediate harm or the victim of a criminal offence, they must dial 000.
Responding to suspected incidents
    24. All suspected, perceived, potential or actual incidents will be managed through the incident response plan.
External reporting
    25. Darussalaam Welfare Centre Limited will:
        a. Report any suspicion of a criminal offence to the police or the relevant criminal judicial body;
        b. Meet all donor requirements regarding the reporting of incidents;
        c. Report any qualifying matter to the ACNC.

Privacy and data protection

    26. All personal information considered or recorded will respect the privacy of the individuals involved unless there is a risk to someone’s safety. Darussalaam Welfare Centre LTD will protect personal information.
    27. Darussalaam Welfare Centre Limited (DWC)’s Privacy Policy applies.

Administration of this policy

    28. This Policy will be reviewed every 2 (two) years. The next review will be on 2 August 2026.

Procedures created by the policy

    29. Darussalaam Welfare Centre LTD’s response to confidential report will involve:
        a. Receiving, acknowledging and assessing the report
        b. Investigation
        c. Determination and outcomes
        d. Timeframe and case closure
        e. Protection of confidential reports
    30. Darussalaam Welfare Centre LTD will take all reasonable steps to protect Confidential Reporters from any retaliation, victimisation, harassment or penalisation that might arise because they made a report. This includes, but is not limited to:
        a. Dismissal or other employment-related sanctions;
        b. Harassment;
        c. Reduced duties or hours;
        d. With-holding of training or promotion;
        e. Loss of status or benefits;
        f. Threats of any of the above.
    31. These protections apply even when an investigation into the matters raised show that there is no case to answer. The burden-of-proof shall be on Darussalaam Welfare Centre Ltd. to show that any change in the employment terms or performance appraisal of a staff member who makes a report is not related to that report. This protection applies to the making of a report, and not to the matters reported. For example, if an individual uses this procedure to report their own involvement in matters, this procedure will not prevent any disciplinary action that might arise from those matters. In all cases, Darussalaam Welfare Centre Ltd. encourages transparency, but reserves its right to make judgements on the facts of the case.

Related policies and procedures

    32. Conflict of interest policy
    33. Privacy policy

CONTACTS

For questions about DWC’s Safe-guarding policy, contact the chair of the board or secretary of Darussalaam Welfare Centre.