About this policy

 KPSC has a zero-tolerance approach to bullying, harassment, and discrimination at the club.

 This policy sets out the guidelines and process used by KPSC in the management and resolution of complaints and grievances, in particular inappropriate behaviour displayed by members of the club, including coaches, players, and spectators, with the appropriate guidance and support to resolve such matters in a fair and reasonable manner.

• Football Australia and all football entities, (including Keilor Park Soccer Club ‘KPSC’) have a zero-tolerance policy for bullying, harassment and discrimination and KPSC will treat all such allegations very seriously.

If you have an Operational Complaint*, we encourage you to talk to your Team Manager in the first instance.

Definitions

 Operational Complaints This includes complaints that don’t fall into the below categories. This may include general complaints, equal game time, on field positions, team selection, communication challenges and the like.

Bullying, discrimination and harassment Serious allegations include discrimination, bullying and harassment. There is often common misunderstandings about what each of these terms mean. Helpful information is available on the Play by the Rules Website.

Criminal Allegations All allegations of child abuse should be referred to a member of the KPSC Committee or the Member Protection Information Officer (MPIO).  Allegations of Child Abuse will be dealt with separately to the process described in this information sheet and are managed under the Football Australia Safeguarding Policy.

Determine the Seriousness of the Complaint

Before moving into the complaints process, work out the nature of your complaint. If the complaint is at the most serious level – involving allegations of child abuse, external management of the allegation is necessary. Ordinarily, if your complaint involves child abuse, you will exit the KPSC complaint process. All allegations of child abuse must be referred to a member of the KPSC Committee or directly to the KPSC Member Protection Officer (MPIO).

If your complaint is about discrimination, bullying, harassment or abuse and if it is safe, reasonable and appropriate to do so, you should attempt to resolve the complaint directly with the other person in the first instance. You may also wish to seek some further information about your rights or support from the KPSC MPIO.

Information and Support is available

Sometimes you may need reassurance, information and support before taking further steps. In this case, you may benefit from seeking support from a range of sources, such as the Coach, a KPSC Committee Member, the State Body Member (Football Victoria), an external agency (such as the Human Rights Commission or the Victorian Department of Sport and Recreation), the Play by the Rules website, or the MPIO at KPSC.

An MPIO or “Member Protection Information Officer” is a qualified person who provides information about the complaints process including your rights, responsibilities and options. They can also support you through the complaints process. The MPIO is not an investigator, adviser, advocate or decision maker and are trained to remain impartial at all times.

How to raise an informal complaint

An informal complaint should be discussed with your Team Manager or the KPSC MPIO at first instance. Alternatively, you may wish to talk about your complaint with any member of the KPSC Committee. If you are not satisfied with the solutions being offered by the Team Manager or Committee Member, you can have your complaint escalated to the KPSC Technical Director. If you are not satisfied with the solution being offered by the Technical Director, you have the option of formalising your complaint.

Often, many of the informal complaint resolution strategies can be used to resolve the complaint. They are explained in the next column and include Observation, Education and Counselling.

How to raise a formal complaint

You may make your complaint in writing (such as by email), in person or over the phone by calling the local MPIO. When you do so, please state clearly that you wish to make a formal complaint.

Clearly set out what happened, when it happened, where it happened and who was involved (including any witnesses that may be able to assist). Any relevant background or context to a complaint may help. Have in mind an outcome that you are seeking. You may like to use the KPSC Complaints form to lodge your complaint – HERE Where you lodge your complaint will depend upon where the incident occurred.

State Body Member matter: incidents that occur at state level, or that involve people operating at state level, should be reported to and handled by Football Victoria at first instance.

How KPSC will manage your formal complaint

 The complaint will usually be managed by the Club MPIO or a member of the KPSC Committee. The MPIO will record all of the details of your complaint and explain your options for resolution. Even though you have made the complaint ‘formal’, a range of informal resolution strategies are still available. The MPIO will explain informal complaint resolution strategies to you.

• Observation

Example: A coach at a senior women’s grassroots team constantly uses derogatory terms when referring to the players. The club secretary attends training and hears the coach using this language during the session. The secretary is able to call the coach over and tell them that this behaviour is unacceptable.

• Education

Example: The President of the club sits down with the coach and explains that in line with the club’s code of conduct, verbal abuse and intimidation of members is not appropriate under any circumstances. The coach explains that they are going through a stressful period at home. The President explains that the club is willing to offer support to help the coach manage the situation. The President and the coach book in another conversation in a week’s time.

• Counselling

Example: The club secretary and the coach have a discussion about inappropriate language. The secretary explains that certain words they have been using are offensive, inappropriate and are upsetting for the players. The coach now appreciates that their behaviour is unacceptable and that external pressures have got the better of them. They undertake to do training and to refrain from using the language again.

When Informal strategies don’t work

 Sometimes, informal strategies don’t work or for whatever reason, are not appropriate to the situation. In most instances, it is your choice whether the proceed through to formal complaint resolution. Sometimes, if the behaviour being complained about is very serious, the KPSC Committee will refer the complaint directly to formal resolution.

Formal procedures are usually appropriate in the following circumstances:

• informal attempts have failed;
• the complaint involves serious allegations;
• allegations are denied;
• the complaint is against someone holding a senior position in the relevant organisation;
• the Complainant has been victimised; and/or
• the Complainant wants to make it formal.

Three Steps to a Formal Complaint Resolution

Investigate

If an investigation needs to be conducted to gather more information about a complaint, an impartial person will undertake the investigation. This may be a person from within KPSC who is not otherwise connected to you, such the Complaints Handler, Complaints Officer or another appropriate staff member such as a legal professional or person with experience in conducting investigations (such as a background in law enforcement). Or, if appropriate in the circumstances, an independent external investigator may be appointed.

 Report

The investigator may deliver a report to the Committee as to whether in their view the complaint is:

• substantiated (there is sufficient evidence to support the complaint);
• inconclusive (there is insufficient evidence either way);
• unsubstantiated (there is sufficient evidence to show that the complaint is unfounded); and/or
•  mischievous, vexatious or knowingly untrue; and
• if requested, recommend whether action should be taken in accordance with the Football Australia National Code of Conduct and Ethics or any other relevant rules, regulations or codes.

The investigator may make recommendations in their report. However, any decision about a breach must be referred to the relevant Football Entity to consider and determine in accordance with their rules and, where applicable, the Football Australia National Code of Conduct and Ethics.

Mediation

At this point, the complaint may be able to be resolved through mediation. Complaints may be resolved by agreement between the people involved with no need for formal disciplinary action. Mediation allows those involved to be heard and to come up with mutually agreed solutions. Mediation is a process during which people in conflict are helped to communicate with each other to identify the areas of dispute and to make decisions about resolving it.

Formal Disciplinary Action

If the Report by the investigator supports a finding that the complaint is substantiated and the matter is not (or is not appropriate to be) resolved through mediation, the KPSC Committee can decide to convene a disciplinary sub-committee to consider whether the matter should be referred for formal disciplinary action. Formal disciplinary action will only be taken by KPSC consistent with the Football Australia National Code of Conduct and Ethics.

Resources

Member Protection Framework – https://www.footballaustralia.com.au/member-protection-framework

Football Victoria Child Safety Standards  – https://www.footballvictoria.com.au/resources/clubs/child-safety

Sport Recreation Victoria Safeguarding Children Regulations and Standards –https://sport.vic.gov.au/publications-and-resources/integrity-sport/safeguarding-children