Safeguarding and Abuse Prevention Policy

This policy explains how Feed Talk prevents, identifies and responds to risks of abuse, neglect, exploitation and other harm. It is designed with reference to the current Australian aged care regulatory framework, including the Aged Care Act 2024, Aged Care Rules 2025, the Statement of Rights, the Aged Care Code of Conduct, the strengthened Aged Care Quality Standards and the Serious Incident Response Scheme (SIRS). It also applies with any relevant state or territory law. If this policy conflicts with applicable law, the law prevails. This policy is not legal advice.

1. Purpose and scope

1.1 The purpose of this policy is to ensure that every older person who receives a service coordinated through Feed Talk is treated with dignity, respect and safety, and can make choices, express views and seek help in an environment free from violence, abuse, neglect, exploitation, discrimination and inappropriate restriction.

1.2 This policy applies to Feed Talk directors and managers, employees, service managers, contractors, independent support workers, volunteers, partner organisations and any person who represents Feed Talk or has contact with an older person through the platform. It covers matching, introductions, communication, service arrangements, service delivery, complaints and incident follow-up.

1.3 Feed Talk currently operates as a platform and service coordinator. Unless separately stated in writing, Feed Talk does not itself provide direct personal care, nursing or clinical services, and this policy does not replace the legal responsibilities of a registered aged care provider for care, screening, incident management, SIRS reporting or other regulatory obligations. Anyone arranging services through Feed Talk must comply with the legal and professional obligations that apply to their role, service and location.

2. Our safeguarding commitments

Feed Talk has zero tolerance for any form of abuse, neglect, exploitation, violence, discrimination, harassment, retaliation or inappropriate restriction. We commit to:

• Respecting each older person's dignity, privacy, identity, culture, religion, gender, sexual orientation, disability, language and lifestyle choices;

• Putting the older person's rights, wishes, preferences and safety at the centre, including supported decision-making, informed consent and reasonable risk-taking;

• Communicating in a language and manner the older person can understand, and helping them access an interpreter, support person, advocate or representative when needed;

• Taking every concern, disclosure, allegation, indicator, near miss and suspected incident seriously, without delaying protection or reporting because complete evidence is not yet available;

• Providing accessible feedback and complaint pathways that are free from retaliation;

• Protecting anyone who raises a concern, makes a complaint or reports an incident from threats, punishment, discrimination or reduced service as retaliation.

3. What abuse, neglect and harm can include

Abuse or harm may be caused by a worker, contractor, family member, another service recipient, acquaintance or any person with access to an older person, and may also occur through an act or failure to act. It includes, but is not limited to:

• Physical abuse or unreasonable use of force, such as pushing, hitting, rough handling or causing unnecessary injury;

• Sexual abuse, unlawful sexual contact, sexual harassment or any sexual activity without consent;

• Psychological or emotional abuse, including threats, intimidation, humiliation, verbal abuse, bullying, controlling behaviour, isolation or persistent belittling;

• Financial abuse or economic exploitation, including theft, coerced payments, unauthorised use of funds, pressured transfers or inappropriate requests for gifts;

• Neglect, including failing to provide agreed, reasonably required or legally required support, or failing to respond to health, safety, nutrition, hygiene, medication, mobility or communication needs;

• Discrimination and cultural or linguistic harm based on race, language, culture, religion, gender, sexual orientation, disability or age;

• Inappropriate use of restrictive practices, unauthorised restriction of liberty, or any restriction used as punishment or for staff convenience;

• Family and domestic violence, coercive control, exploitation, trafficking or any other conduct that places an older person in an unsafe situation.

4. Risk prevention and safe services

4.1 Risk identification and matching

Before introducing or arranging a service, we will, so far as reasonably practicable, understand the older person's needs, preferences, communication style, cultural background, support network, mobility or cognitive needs, known risks and service boundaries. Risks will be reassessed during the service and when circumstances change. If a risk cannot be reasonably controlled, we will not continue or maintain the arrangement and will recommend an appropriate registered provider or professional support.

4.2 Suitability and screening

We will take reasonable steps required by applicable law, the service arrangement and any registered provider to verify identity, work rights, qualifications, experience, references, insurance and any applicable police certificate and aged care worker screening clearance. A person must not perform work requiring screening without a current clearance. Screening is not the only safeguard; we will also consider ongoing conduct, professional boundaries, complaint history and risk information, and may suspend matching, restrict access or end an arrangement where suitability, conflict or safety concerns arise.

4.3 Conduct, training and supervision

Where applicable, workers must comply with the Aged Care Code of Conduct and Feed Talk requirements for conduct, privacy, professional boundaries and incident reporting. Feed Talk will provide or require appropriate training for relevant people on older people's rights, signs of abuse, cultural safety, communication, consent, privacy, financial boundaries, restrictive practices, complaints and incident reporting. Supervision, review and support will be proportionate to the risks of the role.

4.4 Professional boundaries and financial safety

Workers must not borrow from or lend money to an older person, manage bank accounts, passwords, wills, powers of attorney or property without lawful authority, seek or accept inappropriate gifts, benefits or estate arrangements, or charge unagreed fees. Workers must not photograph, record, film or publish information about an older person without consent. Every service must have a clear scope, consent and boundaries, and no person may exploit dependency, isolation, cognitive impairment or language barriers for personal gain.

5. Immediate response to a concern

5.1 If there is immediate danger, serious injury, a crime, a missing person or a need for urgent medical care, call 000 in Australia immediately. Where safe, separate the older person from the suspected source of risk and prioritise first aid or medical assistance. Do not delay contacting police or seeking medical care for an internal process.

5.2 Workers should remain calm, listen and take the older person seriously, use a language they understand, avoid blame, avoid challenging credibility, do not lead or interrogate, and do not conduct their own investigation. Do not promise absolute confidentiality; explain that information may need to be shared to protect a person or meet legal obligations.

5.3 Report any concern, disclosure, allegation, indicator, near miss or suspected incident as soon as possible to the Feed Talk service manager or via hi@feedtalk.com. If the concern involves a service manager, Feed Talk manager or the reporting channel itself, contact police, the Aged Care Quality and Safety Commission, an advocacy service or another appropriate external body directly.

5.4 Without putting anyone at further risk, preserve relevant records, messages, photographs, documents and other evidence. Do not delete or alter original material or discuss the incident with people who do not need to know.

6. Incident management and regulatory reporting

6.1 Feed Talk will record and assess all concerns, complaints, disclosures, allegations, near misses, injuries, missing-person events, unauthorised restrictions and other safety incidents, take immediate risk-control actions, and notify the older person, their support person, the relevant registered provider, police or regulator where required. An internal review must never prevent an external report.

6.2 Where a service is subject to SIRS or another mandatory reporting scheme, the relevant registered aged care provider must manage and report reportable incidents as required by law. SIRS incident categories include:

• Unreasonable use of force;

• Unlawful sexual contact or inappropriate sexual conduct;

• Psychological or emotional abuse;

• Unexpected death;

• Stealing or financial coercion by a worker;

• Neglect;

• Inappropriate use of restrictive practices;

• Unexplained absence from care or a missing older person.

6.3 For an applicable Priority 1 incident, the Commission must be notified as soon as possible and within the 24-hour timeframe required by law. A Priority 2 incident must be reported within the 30-calendar-day timeframe required by law. If there are reasonable grounds to believe a crime has occurred, or an older person is in immediate danger, police must also be contacted. Alleged or suspected incidents must be assessed under applicable law even where the facts are not yet fully established.

6.4 If Feed Talk is not the registered provider for the service, we will promptly refer the incident to the relevant registered provider and, to the extent permitted by law, assist with investigation, risk control, record keeping and regulatory reporting. Feed Talk does not use this policy to replace a registered provider's incident management system or statutory reporting duties.

7. Complaints, advocacy and protection from retaliation

An older person, family member, representative, support person, worker or any person with relevant information may raise a complaint or safeguarding concern with Feed Talk. Complaints may be made in English or Chinese and may be supported by an advocate, representative or support person. We will handle complaints fairly, promptly, without conflicts of interest and in a way the older person can understand, and will provide progress and outcome information to the extent permitted by law.

Anyone may also contact:

• Aged Care Quality and Safety Commission: general complaints on 1800 951 822 or info@agedcarequality.gov.au;

• Serious Incident Response Scheme enquiries: 1800 081 549 or sirs@agedcarequality.gov.au;

• Older Persons Advocacy Network (OPAN) Aged Care Advocacy Line: 1800 700 600;

• 1800 ELDERHelp national elder abuse phone line: 1800 353 374;

• Immediate danger, crime or urgent assistance: 000.

Making a complaint or report must not affect an older person's right to receive services. Retaliation, threats, preventing a report, destroying evidence or punishing a complainant breaches this policy and may be reported to police or a regulator.

8. Privacy, records and information sharing

We collect and handle only the information necessary to protect an older person, respond to an incident, meet legal obligations and improve services, and apply reasonable security measures under applicable privacy law and our Privacy Policy. Information will be shared only with consent, to protect an older person or another person, to handle a complaint, manage risk, comply with law or meet a regulatory requirement. Incident records must be accurate, timely and complete, and retained in accordance with applicable legal, contractual and record-keeping requirements.

9. Accountability, review and continuous improvement

Feed Talk management is responsible for promoting this policy, providing resources, monitoring risks and ensuring relevant people understand their reporting obligations. We will keep appropriate training and screening records, review complaint and incident trends, learn from events and update controls. This policy will be reviewed at least annually and promptly after a serious incident or a material change to regulation, service models or law.

10. Contact

To report a safeguarding concern, request an accessible version of this policy or ask a question, contact hi@feedtalk.com. For an emergency, call 000 first. For external aged care complaints or advocacy support, contact the organisations listed above. This policy should be read with Feed Talk's Privacy Policy, Terms of Use, Refund Policy, complaints process and the policies of any relevant registered aged care provider.