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All children have the right to be safe.
Pulse Climbing is committed to the safety, wellbeing and empowerment of all children with whom we interact.
We have zero tolerance of child abuse. We will treat all allegations and safety concerns seriously, in line with our robust policies and procedures.
We will be responsive to the needs of all children and young people, including the cultural safety and needs of Aboriginal and Torres Strait Islander children, children from culturally and linguistically diverse backgrounds, children with disability, LGBTQIA+ children, and children with prior trauma. This includes respecting each child’s identity, such as their preferred pronouns, cultural background, and individual experiences.
We listen to children and their families and carers, especially about decisions that affect them.
Child safety and wellbeing is embedded in our organisational culture, reflected in our policies and procedures, and understood and practised at all levels of our work.
The purpose of this Policy is to keep children and young people safe by minimising the risk of abuse, misconduct and misuse of positional power and to inform our community of their obligations and responsibilities in keeping children safe.
This policy applies to all members of our Pulse community, including:
● Board members.
● People in leadership roles.
● Staff members.
● Volunteers.
● Contractors.
● Customers.
● Children and young people.
● Families, carers and community members.
It applies to all our activities that involve children, or that may involve children.
Management team
● Embed child safety into everything we do.
● Model child safe behaviours and openness to feedback.
● Seek feedback on risks, practises and policies related to child safety.
● Ensure the ongoing education of staff and community regarding acceptable behaviour and our policies and procedures.
● Take seriously all feedback, complaints and reports, and keep records associated with these.
● Comply with laws regarding child safety.
● Comply with the Child Safe Standards.
● Report to the relevant authorities in accordance with the law and our policies.
● Focus on child safety when recruiting new employees.
● Manage risks in accordance with the Child Safe Risk Management Plan.
Staff
● Attend child safe training.
● Comply with all child safe policies and procedures.
● Intervene if a child is in danger—but only if it is safe to do so. Staff should use their judgement and avoid placing themselves at risk.
● Being identifiable to minors—e.g. by wearing staff shirts or name badges.
● Ask for help if you are unsure about anything at all in relation to child safety.
● Report all risks and concerns regarding child safety. If you see something, say something.
● Prioritise child safety.
Families
● Become acquainted with our Child Safe Policy.
● Provide feedback.
● Comply with our Code of Conduct.
● Report all risks and concerns regarding child safety. If you see something, say something.
● Prioritise child safety.
Children/Young People
● Become acquainted with our Child Safe Policy (or the child and young person friendly version of our Child Safe Policy).
● Provide feedback.
● Comply with our Code of Conduct (or the child and young person friendly version of our Code of Conduct).
● Report all risks and concerns regarding child safety. If you see something, say something.
● Prioritise their own safety, and the safety of other children and young people.
Other Pulse Climbing community members
● Respect all child safe policies and procedures.
● Provide feedback.
● Help Pulse Climbing be a child safe business.
● Report all risks and concerns regarding child safety. If you see something, say something.
● Prioritise child safety.
Child
A child is defined as any individual under the age of 18 years.
Child contact
Child contact is defined as the various forms of engagement with a child, including:
● Physical contact.
● Face-to-face contact.
● Oral communication.
● Written communication.
● Electronic communication (for example, email, instant messaging, social media and video chats, etc.)
Child harm and abuse
Child harm is defined as any action, or lack of action, that significantly harms the child’s physical, psychological or emotional health and development. Forms of child harm and abuse include:
● Physical abuse
The intentional use of physical force against a child that results in – or has a high likelihood of resulting in – harm for the child’s health, survival, development or dignity.
● Emotional abuse
Emotional abuse refers to a parent or caregiver’s inappropriate verbal or symbolic acts towards a child and/or a pattern of failure over time to provide a child with adequate non-physical nurturing and emotional availability.
● Neglect
Neglect includes both isolated incidents, as well as a pattern of failure over time on the part of a parent or other family member to provide for the development and wellbeing of the child – where the parent is in a position to do so – in one or more of the following areas: (i) health, (ii) education, (iii) emotional development, (iv) nutrition, and/or (v) shelter and safe living conditions.
● Sexual abuse
The involvement of a child in sexual activity that he or she does not fully comprehend, is unable to give informed consent to, or for which the child is not developmentally prepared, or else that violates the laws or social taboos of society. Children can be sexually abused by both adults and other children who are – by virtue of their age or stage of development – in a position of responsibility, trust or power over the victim. This includes grooming (defined below).
● Grooming
The term ‘grooming’ refers to behaviours that manipulate and control a child, as well as their family, kin and carers, other support networks, or organisations in order to perpetrate child sexual abuse. The intent of grooming is to: (i) gain access to the child or young person to perpetrate child sexual abuse, (ii) obtain sexual material of the child or young person, (iii) obtain the child or young person’s trust and/or compliance, (iv) maintain the child or young person’s silence, and/or (iv) avoid discovery of sexual abuse. This can occur online or in-person. Online, grooming is achieved through the internet or other technologies such as phones, social media, gaming, chat and messaging apps.
● Verbal Abuse
Verbal abuse involves the use of words to cause harm, including yelling, insulting, threatening, humiliating, or shaming a child. This can be a one-off incident or a pattern of behaviour that damages a child’s self-esteem, emotional wellbeing or sense of safety.
● Digital/Online Abuse
Digital or online abuse refers to harmful behaviour carried out via digital platforms such as social media, messaging apps, online games or other internet-based tools. This can include cyberbullying, inappropriate contact or messages, grooming, sharing of explicit content, or exploitation. It may be carried out by adults or other children.
● Bullying
Bullying is repeated and intentional behaviour that causes physical, emotional, or psychological harm. It can be verbal, physical, social or online, and involves a real or perceived power imbalance. Bullying can be carried out by individuals or groups and may be subtle or overt. 4
● Institutional Abuse
Institutional abuse occurs when an organisation’s practices, policies, culture, or actions (or inaction) result in harm to children. This can include failure to respond appropriately to disclosures, covering up abuse, enabling unsafe environments, or prioritising the reputation of the organisation over child safety.
● Exploitation
Exploitation involves using a child for personal, financial, sexual or other benefit, often at the expense of the child’s wellbeing or rights. This includes sexual exploitation, child labour, and manipulating children into providing goods, services, or compliance in exchange for attention, affection, or basic needs.
● Cultural and/or Spiritual Abuse
Cultural or spiritual abuse occurs when a child is shamed, ridiculed, excluded, or punished for their cultural or spiritual beliefs, practices or identity—or when these aspects are used to justify abuse or control. This includes forcing a child to abandon their cultural heritage, denying access to cultural practices, or using religious or spiritual authority to harm, isolate, or manipulate.
Children’s rights
Children’s rights is defined as a child’s entitlement to thrive, develop and be safe, participate in decisions that affect them, be free from discrimination and to have their best interests as a primary consideration in all actions concerning them. The United Nations Convention on the Rights of the Child, which Australia ratified in 1990, sets out children’s rights in detail.
General
All Pulse Climbing staff must:
● Comply with this policy and prioritise the prevention of harm to children and young people.
● Uphold the rights of children and actively empower them to participate to the best of their ability.
● Provide a safe and inclusive environment free from discrimination or harassment.
● Report any breach (of this policy, procedure or Child Safe Code of Conduct) to their manager.
● Take steps to ensure all children can actively contribute to the organisation regardless of their ability, race, gender or cultural background.
The following table gives examples of behaviour which is acceptable and unacceptable. Adults and staff at Pulse must behave towards children and young people in an acceptable way and must not act in an unacceptable way.
1. Appropriate Task Levels for Junior Workers
Junior workers should be assigned tasks that are suitable to their level of maturity, experience, and training. These tasks should contribute to their development in a safe and supportive environment and must not include responsibilities beyond their capabilities or legal permissions (e.g. supervising other minors, handling complex customer disputes, or operating dangerous equipment unsupervised).
2. Oversharing by Senior Staff
Senior staff must maintain appropriate professional boundaries with junior workers. Oversharing personal information—particularly regarding relationships, legal issues, work grievances, medical conditions, family matters, or past convictions—is inappropriate and can create discomfort or undue emotional burden on junior staff.
3. Invitations to External Activities
Adults, including senior staff and customers, must not invite junior workers or minors to activities outside of the workplace (e.g. parties, social gatherings, outdoor climbing) unless:
○ It is a formally organised event or activity and has been approved by Pulse Climbing management, or
○ Adults have sought the appropriate consent and permission from parents/guardians of junior workers or minors through the correct channels. Even with parental consent, extra care must be taken to maintain clear professional boundaries.
Adults should also follow these guidelines accordingly:
○ If a junior worker or minor is under 16 years old, parental consent/permission MUST be sought.
○ If a junior worker or minor is between 16 and 18 years old, parental permission is ENCOURAGED to be sought.
○ The activity organised must always be age appropriate (e.g., climbing).
○ Adults should avoid being alone/one-on-one with junior workers or minors (i.e., include others in the organised activity and always have others around).
4. Communication Protocols
All informal communication with junior workers or minors, including emails, phone calls, and messages, should go through their parents or guardian. The only time it is ever acceptable for adults to communicate directly with junior workers or minors via emails, phone calls, and messages is when it is directly work related (e.g., a question regarding their shift, shift swaps etc.) Any inappropriate conversation between an adult and a minor, whether in person or online, is unacceptable and can result in termination of employment.
5. Special Age Circumstance
Where an adult and a minor are within two years of each others’ age (e.g., 16 and 18 or 17 and 19) and have a pre-existing or established friendship due to being close in age, parental permission does not need to be sought to communicate or engage in friendly activities (e.g., climbing together).
Purpose
To help keep children safe, we must create, maintain and improve our child safe reporting practices to ensure they remain effective. Everyone in our organisation must:
a. know what to report, who to report it to and how to report it
b. report any concerns about the safety or welfare of a child or young person immediately
c. feel confident that concerns and allegations will be dealt with honestly and fairly
d. feel confident in reporting unacceptable behaviour around children and young people e. ensure the safety and wellbeing of the child is paramount when an allegation is made.
What to report
All complaints and concerns should be reported. This includes:
a. criminal conduct
b. risk of significant harm (ROSH)
c. disclosures of abuse
d. unacceptable behaviour around children and young people that breaches our Child Safe Code of Conduct reportable conduct
e. suspicion of harm or abuse to a child or young person
f. reportable conduct
Who can report
Everyone in our organisation has the right to make a genuine complaint and won’t be punished if they do. This includes children and young people, staff members, climbers and visitors, and volunteers. Reporting abuse is mandatory and encouraged – it is never obstructed or prevented. The chain of reporting :
1. Pulse Climbing staff member : Report the concern immediately to a manager within the organisation.
2. If necessary : The manager will then assess the situation and may escalate the matter to external authorities (e.g. police, child protection services) if the child is at immediate risk or if legal obligations require such action.
3. Document the incident : Keep a clear and accurate record of the incident, the actions taken, and any communications with the child, their parent/guardian, and other staff members.
Who to report to:
Reporting criminal conduct
Contact NSW Police on 131 444 for anything you consider could be a criminal offence. This includes sexual assault, physical assault, grooming offences, and producing, disseminating or possessing child abuse material.
Note: It is a criminal offence for adults not to report to police if they know or believe that a child abuse offence has been committed. In addition, people employed in child-related work may be subject to a criminal offence if they fail to reduce or remove the risk of a child becoming a victim of child abuse.
Reporting risk of significant harm
Any person who has reasonable grounds to believe that a child or young person is at risk of significant harm (ROSH) can report to the Department of Communities and Justice (DCJ) on 132 111 (this is a 24-hour service).
Reporting allegations and convictions
Relevant entities must notify the Office of the Children’s Guardian of reportable allegations or convictions (that is, reportable conduct). This includes sexual offences, sexual misconduct, ill-treatment of a child, neglect of a child, an assault against a child, failure to protect a child or failure to report if a child has been harmed, as well as any behaviour that causes significant psychological harm to a child.
Reporting Breaches of our Child-Safe Policy and/or Code of Conduct
All breaches must be reported to a gym manager or directly to our General Manager.
QR code links to our complaints and feedback form are displayed prominently at all our facilities. This form can be used to report. If a person would prefer to report in another way, they can do so and staff will complete the form.
What happens when a report is made
Reporting risk management
To ensure the immediate and ongoing safety of the child:
● establish the welfare and safety of the child and take steps to ensure the child is removed from the risk if safe to do so
● reassure them and remain calm
● listen carefully without interrupting
● don’t ask leading questions or any additional questions once you’ve established there is a genuine concern (to not compromise future investigations by NSW Police or DCJ)
● support them, reassuring the child that they have done the right thing, that you believe them and that the abuse is not their fault
● explain what will happen, including timeframes
● don’t make promises you can’t keep
● don’t directly confront (with hostile or argumentative intent) the alleged perpetrator
● seek guidance if you are unsure about what to do.
It is the child safety officer’s role to conduct a risk assessment after receiving an allegation, to ensure the safety of all people involved and maintain the integrity of the investigation.
Procedural fairness and privacy
Any allegation of abuse or unacceptable conduct will be treated in a fair, transparent and timely manner. Workers subject to an allegation will be notified when a disciplinary hearing will take place and what will occur at the hearing. We follow the obligations defined under the Privacy Act 1988 (Commonwealth), and relevant reportable conduct investigations are conducted with the OCG’s Reportable Conduct Directorate.
Additionally:
● all information is recorded on our reporting form for complaints and allegations
● all reporting forms for complaints and allegations are stored securely and only accessed by those in the organisation with responsibility for oversight of the investigation
● information may be exchanged under Chapter 16A of the Child and Young Persons (Care and Protection) Act 1998, with other agencies who have responsibilities relating to the safety, welfare or wellbeing of children or young people
● our organisation maintains the privacy of those involved in accordance with our obligations under the Privacy and Personal Information Protection Act 1998
● If an incident is found to be substantiated, likely outcomes or responses will be determined by HR or from advice given by relevant authorities (police, DCJ or OCG).
Process
Once a complaint has been made, we use this step-by-step process to make sure it’s appropriately followed up:
● steps taken to remove child from harm
● incident recorded
● reporting obligations met
● investigation conducted, keeping everyone involved up to date with what’s happening
● offering ongoing support to the child as needed
● reviewing the incident and updating the organisation’s child safe policies, if necessary.
Debrief and Counselling : Anyone involved in the incident, including staff, the child, and any witnesses, should be offered a debrief session. Subsequent counselling may be available to staff affected, to ensure their wellbeing and address any emotional or psychological impact.
These recruitment, screening and training requirements have been developed to provide a fair, safe, consistent, and comprehensive process to engage personnel at Pulse.
We assess which roles are Child-Related Positions (a Child-related position means a position that involves or may involve regular contact with Child/Young People, either under the position description or due to the nature of the role).
Our job advertisements, position descriptions and selection criteria for Child-Related Positions will all emphasise the primacy of child safe behaviours, for example “Must be able to demonstrate an understanding of appropriate behaviours when engaging with Child/Young People”. Our interview process will include questions related to the suitability of the candidate for work with children and their understanding of child-safe practices.
All adult candidates for Child-Related positions must have their WWCC verified by Pulse before being offered employment.
Pulse will check the references of all candidates for Child-Related positions and will ask the referee questions related to child safety before being offered employment.
Our training and induction process includes:
● Reading and signing our Child-Safe Policy;
● Understanding our Code of Conduct;
● Understanding our reporting obligations;
● Understanding NSW Child Labour Laws;
● Completing the Child Safe Sport e-learning module provided by the NSW Office of the Children’s Guardian.
Junior Staff Recruitment
When recruiting for junior staff, job advertisements and position descriptions will be explicitly included. This ensures transparency of expectations and protects junior staff from potential exploitation. The advertisements will detail job responsibilities, reporting structures, and expected behaviours.
Junior Staff Training
Junior staff training will explicitly include:
● Clear outlines of their roles and responsibilities within the organisation.
● Understanding the importance of child safety in all activities.
● Awareness of workplace boundaries and expectations.
● Understanding NSW Child Labour Laws.
