Incidents and Complaints Policy for Customers 

and Support Workers

Issued by	Ethical Hire ABN 77 679 399 001
Version	1.0
Last updated	06/03/2026
Applies to	Ethical Hire public website, platform, workers, clients, participants, providers, coordinators and authorised representatives, as applicable

1. Definitions

In this Incidents and Complaints Policy, the following words and expressions have the meanings set out below unless the context requires otherwise:

• Complaint: This is when a User expresses dissatisfaction to or about Ethical Hire concerning our Platform, services, staff, or how a previous complaint was handled, and expects a response or resolution. This can cover anything from service quality to communication, operational delays, or financial matters like billing. Ethical Hire does not actively monitor or seek out complaints made on third-party media or public channels.
• Incident: Any act, omission, event, or circumstance that causes, or could potentially cause, harm during a Service or Shift arranged through the Ethical Hire Platform or directly connected to our marketplace operations. This includes, but is not limited to, workplace health and safety (WHS) concerns, injuries, property damage, near-misses, or potential breaches of our Code of Conduct and Terms.
• Dispute: An unresolved complaint or billing issue that has been escalated, either within Ethical Hire’s internal resolution frameworks or to an external regulatory or statutory body.
• Vulnerability: A state in which an individual may be more susceptible to detriment, harm, or exploitation due to personal or social circumstances, including but not limited to disability, age, literacy levels, language barriers, trauma, and acute stress.
• Regulated Restrictive Practice: Regulated Restrictive Practice means any restrictive practice as defined under applicable NDIS legislation, including seclusion, chemical restraint, mechanical restraint, physical restraint, and environmental restraint. Ethical Hire does not support the use of unauthorised restrictive practices. Where restrictive practices are utilised in connection with services arranged through the Platform, they must comply with all applicable legal requirements, including NDIS authorisation requirements, Behaviour Support Plans, and reporting obligations.
• Platform: The Ethical Hire digital marketplace, including its website, mobile application, and all associated tools, features, and billing services.
• User: Any individual or entity registered on the Platform, including Clients, Providers, Participants, and Support Workers.
• Worker / Support Worker: A support worker, disability support worker, aged care worker, nurse, or allied health professional who registers on the Platform to find work opportunities or be matched with Shifts.
• Client / Provider / Participant: Individuals, families, authorised nominees, or healthcare organisations seeking care, support, companionship, nursing, or allied health services through the Platform.

2. Introduction and Purpose

Ethical Hire is committed to providing a safe, respectful, inclusive, and accessible platform for people seeking disability, aged care, nursing, allied health, and community support services.

This Policy establishes Ethical Hire’s framework for receiving, managing, investigating, resolving, and learning from incidents and complaints raised by Participants, Clients, Support Workers, authorised representatives, family members, carers, advocates, and other users of the Platform.

Ethical Hire recognises every person’s right to raise concerns, provide feedback, make complaints, and report incidents without fear of disadvantage, retaliation, or interruption to their access to supports or services.

This Policy supports Ethical Hire’s commitment to:

• Upholding the rights, dignity, independence, and safety of people with disability;
  • Promoting person-centred and trauma-informed practices;
  • Supporting continuous improvement and quality service outcomes;
  • Meeting obligations under applicable Australian laws and regulatory frameworks;
  • Supporting compliance with the NDIS Practice Standards, NDIS Code of Conduct, and relevant safeguarding requirements.

Ethical Hire operates as a digital marketplace that connects independent support workers and customers. While Ethical Hire is not generally the direct provider of supports arranged through the Platform, it is committed to maintaining appropriate systems for safeguarding, incident management, complaints handling, risk management, and regulatory cooperation.

3. Guiding Principles

Ethical Hire’s approach to managing incidents and complaints is built on core principles aligned with Australian best practices in complaints handling, WHS standards, and federal care regulations:

• People-Focused and Proactive: We firmly believe everyone has the right to raise a concern. Ethical Hire takes a proactive approach to listening to your feedback. We are deeply committed to addressing your concerns promptly, treating you with the respect you deserve, and involving you actively in the resolution process.
• Accessibility: Our system is designed to be accessible to everyone, including those who might need extra support due to vulnerability. We ensure information on how and where to complain, and what support is available, is widely shared and easy to find. Accessible formats (including Easy English resources) are supported, and you will never be charged a fee to lodge a complaint or report an incident.
• Responsiveness: When you submit a complaint, we commit to acknowledging it within three (3) working days. For incidents, we act even faster based on severity:
  • Level 5 (Major) Incidents: Acknowledged within 4 business hours (during business days).
  • Level 4 (High) Incidents: Acknowledged within 8 business hours (during business days).
  • Levels 1–3 (Minor to Moderate) Incidents: Acknowledged within 48 business hours. We will keep you informed every step of the way, explaining our process, expected timeframes, your role, and potential outcomes.
• Impartiality and Fairness: Every incident and complaint is handled impartially and fairly. We guarantee that internal conflicts of interest will not influence the outcome. Furthermore, Users will always have the option for an independent review by an internal team member different from the initial decision-maker.
• Equity: We address all matters fairly and consistently with our policy frameworks. We also maintain a clear framework to manage conduct that may be deemed unreasonable or abusive, ensuring safety and fairness for everyone involved.
• Privacy and Disclosure: Personally identifiable and sensitive information—including medical records, disability diagnoses, or incident details—is handled with the utmost care, strictly adhering to the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and our Privacy Policy. Unauthorised use or disclosure of sensitive information is treated as a severe breach of our Terms.
• Accountability, Learning, and Prevention: We hold ourselves accountable for our complaint and incident system. Ethical Hire is dedicated to systematically collecting, classifying, and analysing data from every incident and complaint to continuously improve our marketplace features, manage operational risks, identify systemic issues, and prevent future disputes.
• Safeguarding and Zero Tolerance: We maintain an absolute zero-tolerance position against all forms of abuse, neglect, exploitation, violence, financial abuse, sexual misconduct, and discrimination towards people with disabilities, older persons, or any other person on our Platform. Any allegation or incident of this nature is acted upon immediately.

4. Incident Management System

To ensure a swift, proportional, and appropriate response, Ethical Hire categorises incidents into five impact levels (1 to 5) based on complexity, impact, and safety implications. Levels 4 and 5 are classified as High or Major, triggering immediate additional containment steps and direct escalation to our internal Trust & Safety Committee.

A. Receiving & Recording

You can easily report an incident to Ethical Hire through multiple communication channels:

• Online Webforms & App: Submit details directly through our designated in-app reporting tools or timesheet feedback fields.
• Phone Support: (1300 731 289 ) — Monday to Friday, 9am to 6pm AEST/AEDT 
• National Relay Service: If you are deaf, hard of hearing, or have a speech impairment, you can contact us via the National Relay Service (NRS) at nrschat.nrscall.gov.au/nrs/internetrelay.

Every report is carefully logged in our central database, assigned a unique case identifier, and includes details such as your contact information, the exact issues raised, your desired outcomes, and any immediate support or adjustments needed.

B. Acknowledgement & Assessment

We will acknowledge your incident report within the strict timeframes outlined in our Guiding Principles. Each case is assessed based on its medical urgency, severity, health and safety implications, systemic complexity, and platform risk to determine the most appropriate operational path.

C. Referral & Mandatory Reporting

Because Ethical Hire operates as a digital marketplace, primary legislative compliance often resides with the independent Workers, Clients, or registered organisations involved. However, we enforce clear safety reporting loops:

• Notifying Registered Providers: Where an incident involves clients linked to a third-party NDIS Registered Provider or Home Care Package (HCP) Provider, Ethical Hire will promptly notify that organisation to assist them in fulfilling their regulatory reporting obligations.
• Ethical Hire’s Indirect Reporting Obligation: For serious or reportable incidents, if we cannot confirm that the primary parties (the independent Support Worker, Client, or Registered Provider) have reported the matter to the appropriate regulator, or if they are unwilling or unable to do so, Ethical Hire will step in and report directly to the NDIS Quality & Safeguards Commission, the Aged Care Quality and Safety Commission, or other relevant oversight bodies.
• Police and Child Protection Notification: Suspected criminal activity (including fraud, assault, or financial exploitation) will be immediately reported to state, territory, or federal police. Suspected child abuse or neglect will be reported to state child protection services. For Priority 1 Aged Care incidents or serious NDIS reportable incidents where reasonable grounds exist, police will be notified within 24 hours, whether the incident is directly alleged or reasonably suspected.

D. Investigation and Actions

Based on the incident’s nature and impact level, the Trust & Safety Team develops a clear action plan to decide if Ethical Hire needs to investigate platform suitability or refer the matter to external authorities. Our investigations always prioritise user safety and well-being.

When an account is restricted to preserve safety, Ethical Hire will issue a formal Notice to the account holder explaining the reason for the Platform Safety Measure and its immediate effects. Opportunities and timeframes to respond are explicitly outlined within the Notice.

Where an adverse finding is confirmed, or where Ethical Hire judges there is an unacceptable ongoing risk to the community, outcomes range from formal warnings to permanent removal from the platform. We are committed to offering support to affected parties during this transition, such as providing support documentation, guiding users on how to access counseling resources, or assisting clients in navigating the platform database to find new independent workers. All details, steps, evidence, and final decisions are thoroughly documented and archived.

 

E. Resolution and Closure

We ensure you are clearly informed in writing about the actions taken, the outcomes, and the reasons behind our decisions. A case in our incident management system is only officially closed once all necessary remediation, regulatory reporting, and internal actions are complete.

1. NDIS Reportable Incidents

Where applicable, Ethical Hire will support the identification, documentation, escalation, and reporting of incidents that may constitute NDIS Reportable Incidents, including:

• The death of a person with disability;
  • Serious injury;
  • Abuse or neglect;
  • Unlawful sexual or physical contact;
  • Sexual misconduct;
  • Unauthorised use of restrictive practices.

Where Ethical Hire becomes aware of a potentially reportable incident and reasonably believes that the responsible party has not met their reporting obligations, Ethical Hire may notify the relevant regulatory authority or assist affected parties to do so.

5. Complaints Management System

A. Receiving & Recording

Complaints regarding platform operations, user conduct, billing errors, or service quality can be submitted via:

• Online Portal: Our dedicated digital complaint submission form.
• Phone Support: (1300 731 289 ) — Monday to Friday, 9am to 6pm AEST/AEDT 
• National Relay Service: Accessible at nrschat.nrscall.gov.au/nrs/internetrelay for deaf or hard-of-hearing Users.

Every complaint is assigned a unique tracking identifier in our system, capturing key details, your desired resolution, and your preferred contact method.

B. Acknowledgement

We will acknowledge receipt of your complaint within three (3) working days.

C. Referral & Mandatory Reporting

Mirroring our incident protocols, Ethical Hire will notify relevant NDIS/HCP Registered Providers of complaints concerning clients under their care. If a complaint reveals a underlying serious incident or reportable breach, and the primary parties fail to notify the authorities, Ethical Hire will directly report the matter to the Police, NDIS Quality & Safeguards Commission, or the Aged Care Quality and Safety Commission.

D. Investigation & Actions

Every complaint prompts a tailored investigation, whether it is to educate a user on community standards, resolve an administrative misunderstanding, or investigate a serious behavioral breach. Our investigations consistently prioritize user safety and evaluate the continued suitability of users to hold active accounts. We follow specific operational protocols based on the complaint category (e.g., Behaviour/Conduct, Financial/Billing Dispute, Platform Operations), ensuring fair and balanced contact with all involved parties.

E. Resolution & Closure

Outcomes vary based on findings and may include platform access limitations, formal written warnings, financial/billing adjustments within our secure payment system, or mandatory referrals to internal mediation or external bodies. We will communicate the final outcome clearly to the parties involved. Once all actions are completed, verified, and recorded, the complaint will be formally closed.

1. Ethical Hire recognises and supports the rights of Participants and all Platform Users to:

• Make a complaint or report an incident at any time;
  • Be treated with dignity, respect, and fairness;
  • Be supported throughout the complaints process;
  • Access advocacy, interpretation, translation, communication, and support services;
  • Nominate a representative, guardian, family member, friend, or advocate to assist them;
  • Receive information in accessible formats where reasonably required;
  • Receive regular updates regarding complaint and incident investigations;
  • Request review of decisions affecting them;
  • Escalate concerns to external regulators and oversight bodies.

No person will be disadvantaged, discriminated against, intimidated, or victimised for raising a concern, making a complaint, reporting an incident, or participating in an investigation conducted in good faith.

6. Escalation and Appeals

If you are directly impacted by an initial decision or outcome from Ethical Hire regarding an incident or complaint, you have the right to access our internal appeals framework.

• Submission: To lodge an appeal, contact 1300 731 289. You must clearly state your reasons for the appeal, present any new supporting evidence, and quote your original incident or complaint case reference number.
• Time Limit: Appeals must be lodged within 3 months from the date the original decision or outcome notice was issued.
• Review Process: Your case will be escalated to and thoroughly reviewed by senior members of the Ethical Hire Trust & Safety Committee who were not involved in the initial determination. We aim to decide on all appeals within 21 days of submission, holding special committee sessions when required to guarantee a fair, comprehensive, and timely resolution.
• Outcome Communication: The appeal’s final outcome and the comprehensive reasons behind it will be provided to you in writing.
• External Referral: If you remain unsatisfied after exhausting Ethical Hire’s internal appeals process, you have the right to refer the matter to an external statutory body. Ethical Hire will actively provide you with details to contact relevant oversight bodies, including:
  • NDIS Quality and Safeguards Commission: Ph: 1800 035 544 | Web: www.ndiscommission.gov.au
  • Aged Care Quality and Safety Commission: Ph: 1800 951 822 | Web: www.agedcarequality.gov.au
  • Australian Health Practitioner Regulation Agency (AHPRA): (For registered nurses or allied health professionals)
  • Health and Community Services Complaints Commissioner (HCSCC): Relevant to your specific State or Territory (e.g., the Victorian Disability Worker Commission or Health Complaints Commissioner for operations within Victoria).

7. Platform Safety Measures

To protect our marketplace community and uphold Ethical Hire’s strict ethical standards, we may implement Platform Safety Measures on user accounts. These measures include Permanent Account Closure, Temporary Account Suspension, or Limited Platform Access, and are applied based on conduct, specifically in cases of:

• Serious Misconduct: Conduct that has caused, or poses an imminent threat to cause, serious harm, including but not limited to fraud, financial exploitation, physical or verbal violence, sexual harassment or assault, or severe safety breaches. It also applies automatically if a Support Worker’s NDIS Worker Screening Check, Working with Children Check (WWCC), or AHPRA registration is suspended, revoked, or cancelled. Decisions regarding permanent marketplace removal require a rigorous investigation and formal sign-off from the Ethical Hire Permanent Closure Committee.
• External Investigations: If a User is currently under active investigation by law enforcement, a child protection authority, or a regulatory body (such as the NDIS Commission or AHPRA) for conduct that threatens the safety or welfare of platform users, temporary account suspensions will be applied protectively pending the investigation outcome.
• Pattern of Behaviour: Platform Safety Measures may be implemented if a User demonstrates a consistent pattern of minor or moderate misconduct, typically defined as three (3) or more repeated violations of our Code of Conduct or Terms after formal warnings have been issued.
• Other Misconduct: This covers less severe or first-time breaches of Ethical Hire’s Code of Conduct, Community Standards, or Terms of Use (such as minor billing discrepancies or platform circumvention attempts).

Should a Support Worker be temporarily suspended or permanently removed due to safety measures, Ethical Hire is dedicated to supporting affected Clients and Participants by allowing them to access platform tools to identify and connect with alternative independent workers.

8. Roles and Responsibilities

An effective incident and complaint management system depends on clear, shared accountability across the entire Ethical Hire team:

• Senior Leadership: Our executive leadership team actively champions complaint management, ensures the allocation of necessary compliance resources, promotes community awareness, and holds ultimate organizational accountability for the system’s effectiveness.
• Chief Executive Officer (CEO): Oversees the operational implementation of this policy, formally approves or appoints our designated Incident/Complaint Manager, ensures significant or high-risk matters are immediately reported to executive management, and ensures that trust, safety, and systemic data trends remain a core focus of the Board of Directors.
• Complaint / Incident Manager: This key role monitors the overall performance of our reporting systems, coordinates staff training, identifies and reports on systemic issues, manages internal compliance resources, and ensures our documentation and operational procedures remain robust and compliant with Australian law.
• Staff Handling Complaints/Incidents: Frontline Trust & Safety officers are specialized in incident response procedures and trauma-informed communication to support vulnerable individuals. They treat all reporters with dignity and respect, strictly adhere to regulatory timelines, and are empowered to share continuous improvement feedback based on case data.
• Board Sub-Committees: Dedicated sub-committees (including the Risk, Trust & Safety Committee) hold direct oversight of this policy. They conduct regular reviews of anonymized incident data, track systemic operational trends, and play a crucial role in auditing significant safety determinations, such as permanent platform closures.

9. Policy Review and Continuous Improvement

We are deeply committed to constantly improving our incident and complaint management system. Senior management reviews this policy framework annually to ensure it remains suitable, legally accurate, and highly effective at protecting our users. This includes continuous monitoring of our teams, data accuracy, and response performance, alongside regular independent audits to verify that we are adhering strictly to our stated procedures.

Complaint and incident data are systematically collected, securely classified, and analyzed. This data is utilized to eliminate systemic friction points, optimize platform safety features, foster a culture of active learning, and prevent ongoing marketplace disputes.

Governing Law: This policy is governed by and construed in accordance with the laws of the State of Victoria, Australia.