AHN GENDER-BASED VIOLENCE PREVENTION AND RESPONSE POLICY

1. Public AHN Complaint Management Policy
2. Public AHN COVID-19 Safety Policy
3. Public AHN GENDER-BASED VIOLENCE PREVENTION AND RESPONSE POLICY
4. Public AHN Room Holding Policy
5. Public AHN Sexual Harassment and Abuse Prevention Policy
6. Public AHN Host Reimbursement Policy
7. Public AHN Refund Policy
8. Public AHN Guest Agreement
9. Public AHN Homestay Policy
10. Public AHN Host Agreement
11. Public AHN Guidelines for Interviewing Homestay Hosts
12. Public AHN Privacy Policy
13. Public AHN Critical Incident Policy
14. Public AHN Code of Conduct for U18s in Homestay
15. Public AHN Guest Placement Policy
16. Public AHN Selection Criteria for the Recruitment of Homestay Hosts
17. Public AHN Website Terms & Conditions

Note: This policy is subject to change at any time. Please check all AHN policies on a regular basis for updates.

AUSTRALIAN HOMESTAY NETWORK PTY LTD (ABN 52 124 610 313) (‘AHN’)

Effective Date: 1st July 2025

(1) INTRODUCTION

The purpose of this policy is to set out the principles underpinning AHN’s commitment to preventing and responding to gender-based harm and violence, and to outline the responsibilities of members of the AHN community.

 (2) SCOPE

This policy applies to all members of the AHN community, including staff, guests and hosts. The AHN Group is Australian Homestay Network and its Parent Company, MyStay International Pty Ltd (‘MSI’) and its Operating Franchisees and Licensees.

Third parties are in the scope of this policy where there is a connection with AHN such as contractors, franchisees, licensees, service providers, visitors, international education agents and other partners, and partner organisations in Australia or overseas acting for or on behalf of AHN in relation to AHN guests, hosts and staff.

If gender-based harm and violence is reported outside the scope of this policy, AHN will provide referrals to appropriate support services.

(3) OVERVIEW

This policy establishes a framework to support and enable the prevention of and response to gender-based harm and violence at AHN premises and the AHN arranged places of hosted accommodation, reflecting a commitment to creating a safe place for all staff, guests and hosts where everyone feels included, respected and supported.

The policy defines key concepts such as consent, gender-based harm, gender-based violence, sexual harm, sexual harassment and sexual assault, disclosure and response.

AHN acknowledges that intersectionality can compound the impact of discrimination and that certain groups of people will be more vulnerable to the effects of discrimination and harassment than other groups.

 (4) POLICY

Principles

Collective commitment: AHN is committed to leading long-term social and cultural change to prevent gender-based harm and violence, recognising the urgent need for action.

Zero tolerance: AHN has zero-tolerance for gender-based harm and violence, supported through leadership accountability, clear policies, and comprehensive education.

Leadership: AHN executives oversee the application of this policy, fostering a safe environment and respectful culture, and ensuring continuous improvement of processes to prevent and respond to gender-based harm and violence.

Confidentiality and privacy: AHN is committed to protecting the confidentiality and privacy of individuals involved in gender-based harm and violence cases, in accordance with the Privacy Policy.

Accountability: AHN prohibits the use of its resources for violence and prioritises safety with support to encourage those who cause harm to seek support.

Procedural Fairness: AHN ensures procedural fairness with impartial and transparent processes where all parties can present their perspectives and evidence reinforcing trust and justice.

Human Rights: AHN views all gender-based harm and violence as unacceptable and a violation of human rights.

Inclusive and intersectional approach: AHN acknowledges that diverse identity aspects, such as race, age, and socio-economic background, influence the support needed for addressing gender-based harm and violence. AHN addresses intersectional needs, ensuring tailored support and interventions.

Trauma-informed: AHN adopts a rights-based, victim-survivor centred approach, prioritising safety and wellbeing and ensuring victim-survivors' voices and needs guide all support efforts, fostering an environment of compassion and respect.

Transparency and integrity: AHN maintains evidence-based policies and procedures aligned to best practices, protecting against victimisation and supporting those who disclose or report harms.

Preventing harm: AHN has a dedicated executive team to lead all work associated with the prevention of gender-based harm and violence, sexual harassment and sexual assault, focused on governance, awareness, learning, and innovative projects.

Dedicated and supportive response: AHN provides a dedicated response service for students and staff to seek support for gender-based harm and violence, sexual harassment, sexual assault, or any concerning, unwanted, uncomfortable and/or threatening behaviour.

Responsibilities

All members of the AHN community are required to:

1. role model accountable  and appropriate behaviour in line with the other internal policies of AHN, or its parent company, MSI, and other AHN public policies available at https://au.homestaynetwork.org/policies, particularly the: 
   1. AHN Sexual Harassment and Abuse Prevention Policy;
   2. AHN Guest Agreement;
   3. AHN Homestay Policy;
   4. AHN Host Agreement;
   5. AHN Critical Incident Policy;
   6. AHN Code of Conduct for U18s in Homestay.

100. increase awareness and ensure compliance with relevant policies and procedures; 

The AHN and the executive of its’ parent company MSI is responsible for providing a safe, non-violent, gender equal and inclusive environment for all members of the AHN community. 

The Chief Executive Officer of AHN (CEO) is the central authority for the implementation of this policy and ensuring there is a clear reporting line through to the MSI executive, and effective management and oversight by senior management.

The Chief Executive Officer of AHN (CEO) will regularly examine de-identified data to identify trends and systemic issues and enable AHN to identify opportunities for improvements and implement changes where required. If required, they will provide formal reports and any disciplinary or investigation actions data to the MSI executive.

Managers at AHN are responsible for providing opportunities for their teams to receive education and training about the principles in this policy to supplement the mandatory training, and taking prompt action where needed in accordance with the procedures under this policy.

 (5) COMPLIANCE

Reports of non-compliance with this policy suite should be made to the MSI executive.

A breach of this policy or corresponding procedures may result in disciplinary action. Depending on the nature and impact of the breach, other actions may also be instigated. Alleged or actual conduct by staff or students that constitutes gender-based harm or violence will be handled in accordance with the AHN Critical Incident Policy and the AHN Complaint Management Policy, as applicable. 

This policy supports AHN’s commitment to adhering to sector best practices and is informed by:

1. Australia Human Rights Commission – Guidelines for Complying with the Positive Duty under the Sex Discrimination Act 1984 (Cth) (AHRC)
2. National Plan for Addressing Gender-based Violence in Higher Education 2024
3. Universities Australia Sexual Harm Response Guidelines.

 (6) GENDER-BASED VIOLENCE RESPONSE PROCEDURE

This procedure documents how AHN will support victim-survivors and respond to matters involving gender-based violence and harm.

While people of all genders can experience gender-based violence, harm, or abuse, the terms are most often used to describe harm and violence against women, girls, and LGBTIQA+ people.

Disclosures

A disclosure refers to the sharing of information about an experience of gender-based violence or harm, which can be made to anyone trusted, including to AHN staff, MSI staff, guests or hosts. This procedure refers disclosures made to members of AHN community listed in the scope of this policy.

Anyone connected to AHN, including third parties, is supported to make a disclosure about gender-based violence or harm to someone other than themselves, without fear of sanction or inaction. AHN’s timely response and resolution may depend on the victim-survivor’s willingness to participate in the process.

All AHN staff receiving a disclosure must inform the discloser about available support from AHN. AHN Staff must notify the Chief Executive Officer of AHN (CEO) of the disclosure. AHN Staff must inform the discloser of their obligation to notify the Chief Executive Officer of AHN (CEO) and seek consent on what information can be shared, including anonymity preferences.

If gender-based violence or harm is disclosed or reported as occurring outside the scope of this procedure, AHN will provide referrals to specialist support services as appropriate.

Ways to make a disclosure

In an emergency or in circumstances of immediate danger, disclosers are to contact the relevant state police and emergency services (000) or AHN 24/7 After Hours Call Centre (1300 69 7829).

Individuals wanting to make an informal or formal report of gender-based violence or harm are encouraged to contact AHN for guidance. AHN will provide safety first, inclusive and intersectional support and advice, regardless of:

1. where or when the violence or harm occurred, and
2. whether the person wants to make a disclosure of violence or harm but not a formal report, or
3. whether they want to make a formal report about it. 

AHN may offer information on reporting procedures, which may vary depending on the individual's status (student, host or third party) and the status of the respondent.

Staff may report an incident of gender-based violence or harm under this Policy.

Third parties may report an incident of gender-based violence or harm under this Policy. 

External specialist support and advice services may be engaged if requested or approved by the affected parties.

Disclosures can be made by victim-survivors and third parties directly to the Chief Executive Officer of AHN (CEO) or using the online Homestay Management System (‘HMS’). Reporting though certain channels may not provide an option to remain anonymous unless unavoidable due to nature of the method of the reporting.

All disclosures and reports made through Safer Community will receive a response within 1 business day. This response will acknowledge receipt of the disclosure or report. 

Informal Process

Where a disclosing or reporting person wishes to resolve a matter informally, AHN may utilise processes that focus on the resolution of the issue rather than the substantiation of the report through a full investigation, such as restorative engagement processes.

AHN offers support to all persons who are affected by a disclosure or report of gender-based violence or harm, including persons who make disclosures or reports, as well as the person about whom a report is made. Support may include:

 

Ways to make a formal report

Individuals who disclose gender-based violence or harm may choose to make a formal report, but it is not mandatory. A formal report involves providing a statement about the incident and seeking a formal, timely response and resolution from AHN.

If a person who has experienced gender-based violence or harm wants to make a report to the police, AHN can support a person to make a police report. However, AHN cannot make a police report on that person’s behalf.

If a person who has experienced gender-based violence or harm wants to report to police, no further investigation will be made by AHN while the police investigation is underway, but support from AHN will be ongoing.

In certain circumstances, AHN may have a duty to notify the police in its own name, even if the individual does not wish to. Refer to ‘Investigations’ in this Policy.

A notification to the police by AHN in its own name must be approved by the Chief Executive Officer (CEO) if the respondent is a staff member or a third party, taking into account:

1. evidence of an unacceptable risk to AHN’s community, or the public
2. multiple disclosures, reports, or complaints about the same person
3. advice from the MSI executive
4. advice from Education Providers under their compliance obligations to the ‘ESOS Act 2000’
5. the wishes of the person who has experienced the gender-based violence or harm or who initially made the disclosure or report.

AHN will advise the person who has disclosed or reported the gender-based violence or harm about AHN’s decision to notify the police and, to the extent possible, will keep the person informed of any actions that result from that notification.

Persons who make a report, as well as persons who are the subject of a report, will be provided with information about the steps involved for any formal or informal resolution process, and they will be kept appropriately informed about the progress and outcome of those steps in accordance with the relevant policy and procedure.

Precautionary Measures

AHN may recommend certain temporary or precautionary safety measures in response to a report of gender-based violence or harm whilst an informal or formal investigation into the incident takes place, to protect the wellbeing and safety of all guests, hosts, staff, and third parties, and where there may be an ongoing risk to the broader AHN community. AHN will consult with the appropriate areas within the AHN community in implementing appropriate precautionary measures.

In managing a response to a critical incident, AHN team will provide advice and guidance to any Critical Incident Management Team (or equivalent) in Risk Management, to inform the MSI executive of risks and issues associated with gender-based violence or harm.

Where one or more of the persons involved as respondents or complainants in a report of gender-based harm is an AHN guest or host, precautionary measures that can be directed may include but are not limited to:

1. changes to homestay  arrangement and locations
2. temporary accommodation arrangements
3. temporary restriction of access to the Homestay Management System (‘HMS’)
4. Host remuneration adjustments
5. ‘no contact’ directives
6. a recommendation regarding an MSI executive or AHN staff suspension

Where one or more of the persons involved in a report of gender-based violence or harm is an AHN staff member, precautionary measures that can be implemented through the Policy may include adjustments to working arrangements.

Precautionary measures are not a punitive measure and do not indicate that AHN has concluded that a breach of the contract or policy has occurred.

Investigations

Where a report of gender-based violence or harm involves repeated conduct by a perpetrator, or where the harm or conduct is of a more serious nature, AHN uses formal procedures to establish whether a report is substantiated. AHN may be required to pause or temporarily suspend such investigations if required to do so by police or by other external regulators or authorities.

AHN may appoint an external Specialist Investigator in Gender-Based Violence that may investigate formal reports or disclosures of gender-based violence or harm, with support from AHN. 

There are some circumstances where AHN may take formal action in relation to a disclosure, even if the discloser does not want to make a formal report or have any further action taken. This may occur where there is a serious or imminent risk to the safety of another person or persons, or to meet AHN’s legal obligations. To the extent possible, AHN will take measures to avoid identifying the victim-survivor. Where such matters involve alleged criminal conduct, AHN may contact the police and suspend any action under this procedure pending an investigation by the police.

AHN will complete the investigation, disciplinary action, and outcomes within a reasonable timeframe from the formalisation of the investigation. However, this timeline may be extended when there are extenuating circumstances, such as additional time for coordination and communication when there are external processes and providers, the availability of key participants, the complexity of the case, or any legal proceedings that may impact the timeline. 

AHN will continue to provide appropriate and reasonable assistance and support to prioritise and protect the safety and wellbeing of all parties after the conclusion of any investigative or disciplinary action, including the recovery of any person who has disclosed being sexually harmed or assaulted.

False Reports

Any person who knowingly makes a false report of gender-based harm may be subject to disciplinary action.

Privacy, Confidentiality and Record-keeping

Disclosures and formal reports of gender-based violence and harm will be handled confidentially in accordance with AHN’s Privacy Policy. Information may be shared on a need-to-know basis with appropriate AHN officers or external third-parties and authorities as part of AHN’s duty of care obligations or as required by law.

AHN maintains a confidential register of disclosures and formal reports. All information will be collected, stored, and accessed in accordance with AHN’s Privacy Policy and applicable laws. AHN will also use de-identified, collated data from disclosures and formal reports to provide high-level reporting on known incidents of gender-based violence and harm.

AHN will use de-identified data from disclosures and reports to inform preventive interim safety measures, if necessary, to focus on the level and nature of the risk as part of assessment and proactive ongoing monitoring.

In limited cases information will be provided to the AHN Chief Executive Officer (CEO) and the MSI executive to inform internal decision-making, these may include matters where serious sexual assault has occurred.

Where possible identifying details of the impacted parties will be protected by AHN.

There are some limited circumstances, such as where AHN is required by law to report an incident to the police or a regulator, in which AHN may be required to share identifying information about a person who has made a disclosure or report of gender-based violence or harm or about whom the disclosure or report has been made. This is for the safety and wellbeing of the AHN community, including for the safety of the person identified.

Internal Reporting and Continuous Improvement

The AHN Chief Executive Officer must advise the MSI executive when a sexual assault has occurred or when any incidents that occurred in hosted accommodation are reported to the Police.

The AHN Chief Executive Officer must advise the MSI executive if there has been a termination of employment because of staff misconduct.

Access to this information will be managed in accordance with AHN’s Privacy Policy. The reports to the MSI executive are used to:

1. identify trends and systemic issues
2. contribute to evaluation of prevention programs, and
3. identify opportunities for improvements and preventative actions.

AHN may provide information to a third party for investigation purposes. Where a requirement to make a report to a third party exists, such as the Commission for Children and Young People, and this information is not able to be provided in a de-identified format, the individual will be consulted prior to the report being made and every effort taken to respect privacy and minimise trauma.

External Reporting

AHN provides de-identified data to external agencies or bodies, where required, to ensure compliance with legislated reporting requirements. Access to this information will be managed in accordance with AHN’s Privacy Policy.

If disclosed or reported incidents indicate material breaches in safety or preventative controls, including recurring incidents of gender-based harm, AHN will notify the relevant Education Provider immediately to determine if it is appropriate to notify the Tertiary Education and Quality Standards Agency (TEQSA). If deemed appropriate, AHN will provide the required disclosure to the Education Provider.

Definitions

Term	Definition
Child	A person who is under the age of 18 years.
Concern	An expression of dissatisfaction with the behaviour of a guest, host, third-party, AHN staff member or MSI staff member, where a response is not expected.
Disclosure	Where a person first makes known an incident of sexual harm to AHN. This may or may not lead to a report being made via the AHN Complaint Management Policy or another reporting avenue.
Gender-based violence	Any form of physical or non-physical violence, harassment, abuse or threats based on gender that results in or is likely to result in harm, coercion, control, fear or deprivation of liberty and autonomy. Harm can be physical, sexual, emotional, psychological, social, cultural, spiritual, financial and technology-facilitated abuse (including image-based abuse), and stalking.
Intersectionality	The ways in which different aspects of a person’s identity can expose them to overlapping forms of discrimination and marginalisation. Intersectionality addresses and acknowledges gender, sexual orientation, Indigeneity, race, economic status, ability, or other factors can compound the impact of gender-based violence, resulting in certain groups of people being more vulnerable and/or disproportionally impacted than other groups to the effects of gender-based violence, harm, discrimination or harassment.
MSI Group	MyStay International Pty Ltd and its subsidiaries, contracted partners and its controlled entities
Sexual assault	Is when:  i. a person (A) intentionally touches another person (B) and the touching is sexual  ii. person (B) who was touched did not agree or consent to the touching, and  iii. person (A) did not reasonably believe that person (B) consented.  If person (A) knew that (B) was not consenting, this will be sexual assault; and if person (A) did not believe on reasonable grounds that B was consenting, this will also be sexual assault.  For the purposes of this policy, AHN also includes the following acts: (i) rape, (ii) rape by compelling sexual penetration, (iii) sexual assault by compelling sexual touching, (iv) assault (being the non-consensual application of force) with intent to commit a sexual act, and (v) threat to commit a sexual assault or rape. For succinctness, the specific elements of each are not set out separately in this policy.
Sexual exploitation and abuse	Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially, or politically from sexual exploitation of another. The abuse may be actual or threatened intrusion of a sexual nature, whether by force or under unequal or coercive conditions, and includes but is not limited to sexual assault, sexual harm and sexual harassment.  Technology-facilitated sexual exploitation and abuse is the use of technology and new media to facilitate sex-based abuse and harassment. Behaviours can include nonconsensual pornography (“revenge porn”), recorded sexual assaults, deepfakes, sextortion, cyber harassment, cyber dating violence, and cyberstalking.
Sexual harm	Non-consensual behaviour of a sexual nature that causes a person to feel uncomfortable, frightened, distressed, intimidated, or harmed, either physically or psychologically. Sexual harm includes behaviour that also constitutes sexual harassment, sexual assault and rape.
Sexual harassment	When a person:  (a) makes an unwelcome sexual advance, or an unwelcome request for sexual favours, or  (b) engages in other unwelcome conduct of a sexual nature in relation to a person, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated or intimidated.
Third Parties	Any person or entity external or separate to AHN, including franchisees, licensees, contractors, consultants, volunteers, and visitors as well as members of the public.
Trauma informed	A strengths-based framework that applies the core principles of safety, trustworthiness, choice, collaboration for shared decision-making, empowerment and respect for diversity. Trauma-informed services recognise the physiological, emotional, psychological and neurological effects of trauma; minimise the risk of re-traumatisation and promote healing; emphasise physical and emotional safety; and focus on the whole context in which a service is provided – not just on what is provided.

 (7) MODIFICATION OF THIS POLICY

AHN reserves the right to modify and revise this Policy from time to time. 

 (8) COMPLIANCE AND ENFORCEMENT

Every entity identified in the ‘Scope’ section of this Policy must comply with all the provisions of this Policy, as non-compliance may attract disciplinary measures.

 (9) HOW TO MAKE A COMPLAINT OR SEEK ASSISTANCE

For further information about this policy or to discuss any matters related to it, contact info@homestaynetwork.org.