Sexual harassment prevention plan

The current version of this document lives at diverseroutes.com.au — printed or downloaded copies are uncontrolled.

Purpose and legal basis

From 1 March 2025 Queensland requires every person conducting a business or undertaking to have a written prevention plan wherever a risk of sexual harassment, or sex- or gender-based harassment, is identified (Work Health and Safety Regulation 2011 (Qld), as amended by the Work Health and Safety (Sexual Harassment) Amendment Regulation 2024). This is that plan. It is written in plain language, identifies the specific risks in Diverse Routes' work, sets the controls, explains how to report and what happens next, and records how it was consulted on and when it is reviewed.

Our position

Sexual harassment and sex- or gender-based harassment are not tolerated in any Diverse Routes setting — a training room, a client site, a vehicle, a campsite or an online channel — whether directed at our personnel, by our personnel, or between the people in our care. In plain words: unwelcome sexual advances, requests for sexual favours, or conduct of a sexual nature that a reasonable person would expect to offend, humiliate or intimidate; and demeaning or hostile conduct directed at someone because of their sex or gender. Trainers and trip leaders hold a position of authority, which raises the standard we hold ourselves to, not lowers it.

Who this plan covers

• Diverse Routes personnel — currently the Managing Director as sole worker, and any person facilitating under the brand.
• Learners in our courses, participants on our tours and workshops, and host-site personnel, as the people our workers interact with — and as people entitled to the same protection while in our care.

Risks identified

Setting	Specific risk	Factors
Training rooms and practical yards	Harassment of the trainer by learners, or between learners, during delivery	Cohorts drawn from male-dominated industries; sole trainer with no colleague present; authority dynamic between assessor and learner
Client and host sites	Exposure to host-workforce conduct outside our control	Remote sites and camps; extended stays; reliance on the host's culture and reporting systems
Multi-day tag-along tours and skills weekends	Harassment within mixed participant groups, or of the trip leader, in camping settings	Multi-day proximity; evening alcohol among participants; shared facilities; remoteness from external help; family groups including young people
Communication channels	Inappropriate contact via email, phone, messaging or social media around bookings and courses	Personal mobile number published for business purposes; direct contact with participants before and after trips

Control measures

• Standards set up front. Behavioural expectations, including zero tolerance of harassment, are stated at every course start and every tour briefing, alongside the exclusion criteria already in manual s.4. Tour booking terms include participant conduct conditions that participants accept before travelling.
• Authority to act on the spot. The trainer or trip leader may pause or stop delivery, separate people, or exclude a participant for harassing conduct — the same stop-work authority that applies to physical hazards (manual s.6.4). On tours, exclusion arrangements (transport to the nearest town, refund position) are set out in the booking terms so the decision is never constrained by logistics.
• Tour design. Alcohol expectations are set in the pre-trip briefing; camp layout gives every participant privacy; group briefings on day one address conduct; where family groups include young people, supervision responsibility is confirmed with the responsible adult.
• Client sites. Host reporting arrangements are identified at induction (manual s.5); harassment by host personnel is reported to the host and to Diverse Routes' own record, and repeated or unaddressed conduct is grounds to withdraw from the engagement.
• Our own conduct. Personnel maintain professional boundaries with learners and participants, including in communications outside delivery hours; personal social-media contact with learners is not initiated.
• Communication channels. Business contact details are used for business purposes; inappropriate contact is documented, not engaged with, and blocked where necessary.

How to report

Anyone — worker, learner, participant or host personnel — can report harassment in a Diverse Routes setting:

• To the Managing Director directly, in person, by phone (0421 709 395) or by email (scameron@diverseroutes.com.au). Reports are acknowledged within one business day.
• Where the Managing Director is the subject of the concern, or the person prefers not to report to him: to the client or RTO contact for the engagement, who may raise it with Diverse Routes; or to any of the external bodies below, which may be approached at any time and do not require an internal report first.
• Anonymous reports are accepted and acted on to the extent the information allows.
• An allegation against Diverse Routes personnel is handled under the response protocol in DR-WHS-POL-04 (allegations against our personnel): independent handling through the client or RTO's complaints process, preservation of records, insurer notification, and a fair hearing for the person complained of.

External avenues: Workplace Health and Safety Queensland (1300 362 128); the Queensland Human Rights Commission; the Australian Human Rights Commission; the Fair Work Commission (for workers); and, for conduct that may be criminal, Queensland Police (000 in an emergency).

What happens next

• Every report is recorded on the incident report form (DR-WHS-FRM-02) and managed under the incident process in manual s.13 — the same rigour as a physical injury.
• Immediate safety first: separation of the people involved and, on tours, the exclusion arrangements above if needed.
• Investigation proportionate to the matter: the person reporting is heard first; the person complained of is given the substance of the concern and a chance to respond; findings are made on the balance of what is known; outcomes may include warnings, exclusion from the course or tour, withdrawal from an engagement, referral to the client or RTO, or referral to police.
• Confidentiality is maintained as far as the investigation and safety allow. Victimisation of anyone for making or supporting a report is itself a breach of this plan.
• The person who reported is told the outcome. Learnings feed the risk register and this plan.

Consultation

At the date of issue the business has one worker, who prepared this plan from the code of practice and the regulation. Consultation is therefore outward: learners and participants are invited to comment on conduct standards in post-course and post-trip feedback, and any person who is to facilitate under the brand will be consulted on this plan before their first engagement. Growth trigger as per manual s.2: this plan is re-consulted before any worker or regular subcontractor is engaged.

Review

Reviewed at least every three years as the regulation requires, and sooner after any report or incident, when a request for review is received, and before activities change — specifically before the first commercial tour departs. Carried in the standing risk register (DR-WHS-REG-02) and cross-referenced from the psychosocial hazard policy (DR-WHS-POL-04).

Version	Date	Approved by	Amendments
1.0	3 September 2026	Straun Cameron, Managing Director	Initial issue