Peninsula Strikers Football Club
Harassment, Bullying and Complaints Policy
Policy status: Draft for Committee approval
Policy owner: Club Committee
Last reviewed: September 2026
Review cycle: At least annually, and after any significant incident or change to applicable law or governing-body requirements
1. Purpose
Peninsula Strikers Football Club, including its junior and senior programs (the Club), is committed to providing a safe, respectful, inclusive and welcoming environment for everyone involved in the Club.
Harassment, bullying, discrimination, vilification, victimisation, abuse and threatening behaviour are not accepted. This policy explains how concerns can be raised, how the Club will respond and when a matter may be referred to Football Victoria, Football Australia or an external authority.
The safety and wellbeing of children and young people are paramount. Complaints involving a person under 18 will also be managed under the Club's Child Safety and Wellbeing Policy and applicable child-safety reporting procedures.
2. Who and what this policy covers
This policy applies to all people involved with or attending Club activities, including:
junior and senior players;
coaches, assistant coaches, team managers and other team officials;
committee members, employees, contractors and volunteers;
referees and other match officials engaged by the Club;
parents, carers, guardians, family members and spectators;
members, life members, guests, sponsors and visitors; and
any other person representing or participating in the Club.
It applies to behaviour:
at training, matches, trials, tournaments, meetings, functions and other Club activities;
at Club grounds, away venues, change rooms and during Club-related travel;
through email, telephone, messaging services, team applications, social media or other online platforms; and
outside a formal Club activity where the behaviour has a material connection with the Club, affects a person's participation or safety, or may bring the Club or football into disrepute.
This policy may apply whether the behaviour is directed at an individual or a group and whether it occurs in person or online.
3. Unacceptable behaviour
3.1 Harassment
Harassment is unwelcome conduct that a reasonable person would expect might offend, humiliate or intimidate another person. It may be a single incident or repeated behaviour and may be verbal, physical, written, visual, sexual or online.
Examples include insults, slurs, sexual comments or advances, intrusive questions, offensive jokes or images, deliberate exclusion, intimidation, hostile messages, repeated unwanted contact, or conduct targeting a person's personal attribute.
3.2 Bullying
Bullying is repeated unreasonable behaviour directed at a person or group that creates a risk to health, safety or wellbeing. It can include verbal abuse, threats, humiliation, spreading rumours, deliberately isolating someone, unreasonable criticism, misuse of authority or repeated online abuse.
Reasonable coaching feedback, team selection, performance management, disciplinary action or Committee decisions carried out lawfully, fairly and respectfully are not bullying merely because a person disagrees with them or finds them disappointing.
3.3 Other prohibited conduct
The Club also prohibits:
discrimination or vilification based on a protected personal attribute;
sexual harassment, sexual misconduct, grooming, child abuse or harm;
physical violence, threats, stalking, hazing or coercion;
retaliation or victimisation against a person who raises, supports or participates in a complaint;
knowingly false or deliberately misleading allegations; and
attempts to pressure a person not to report a concern or to withdraw a complaint.
A complaint that is not substantiated is not, by itself, a false or malicious complaint.
4. Guiding principles
The Club will:
prioritise immediate safety and the best interests of children and young people;
take concerns seriously and respond promptly, impartially and sensitively;
provide procedural fairness to the complainant and respondent;
manage actual, potential and perceived conflicts of interest;
use a response proportionate to the seriousness, circumstances and available evidence;
protect privacy as far as reasonably possible while recognising that confidentiality cannot be guaranteed where information must be shared to investigate, manage risk or comply with the law;
provide reasonable accessibility assistance, including an interpreter or support person where practicable;
keep appropriate and secure records; and
prohibit retaliation against anyone who raises a genuine concern or assists with a complaint.
No person is required to confront the person complained about or attempt informal resolution before making a complaint.
5. Getting immediate help
Immediate danger or urgent medical assistance: call 000.
Possible criminal conduct: contact Victoria Police. The Club may also report the matter where required or appropriate.
Concern that a child is being abused, harmed or neglected: follow the Club's Child Safety and Wellbeing Policy and report to Victoria Police, Child Protection and/or the Social Services Regulator where required.
Making a report to the Club does not prevent any person from contacting police, a regulator, a governing body, a legal adviser, a union, a health and safety authority or another support service at any time.
6. How to raise a concern or complaint
A concern may be raised verbally or in writing with any of the following:
the relevant team manager, coach or age-group coordinator;
the Club's Member Protection Information Officer (MPIO), Complaint Officer or Child Safety Officer, where appointed;
the Club Secretary, President or another Committee member; or
any trusted Club official, who must promptly pass the concern to an appropriate Complaint Officer.
An MPIO can explain a person's rights, responsibilities and complaint options and provide process support. The MPIO is not the investigator, advocate or decision-maker. A different, suitably independent person will handle or investigate the complaint.
Current contact details and the Club's online contact form are available on the Club website.
A complaint about the President should be directed to the Secretary or another non-conflicted Committee member. A complaint about the Secretary should be directed to the President. If the whole Committee may be conflicted, or the complaint concerns the Club's handling of a matter, the person may contact Football Victoria directly.
Children and young people may raise a concern themselves, with a parent or carer, or through any trusted adult. They will be listened to and taken seriously. A parent or carer will ordinarily be involved when appropriate, unless doing so may create a safety risk, is contrary to the child's best interests, or an authority directs otherwise.
Anonymous complaints will be accepted. However, anonymity may limit the Club's ability to investigate or take disciplinary action. The Club may still act on anonymous information where it identifies a safety risk or can be independently verified.
Information that is helpful
Where possible, a complaint should include:
the complainant's name and contact details, unless they wish to remain anonymous;
what happened, including the date, time and location;
who was involved and any witnesses;
any relevant messages, screenshots, photographs, video or other documents;
whether the behaviour is continuing and whether anyone is at immediate risk; and
what assistance or outcome the complainant is seeking.
Lack of complete information will not prevent the Club from receiving or assessing a complaint.
7. Initial response and risk assessment
The Club will aim to acknowledge a complaint within two business days and appoint an appropriate Complaint Officer. The Complaint Officer will not be a person directly involved in the matter and must disclose any conflict of interest.
The Club will conduct an initial assessment to:
identify and manage immediate safety, child-safety and wellbeing risks;
determine whether mandatory or external reporting is required;
identify the policies, rules or laws that may apply;
decide whether the matter should be managed by the Club, referred elsewhere or both; and
explain the next steps to the complainant, as far as reasonably possible.
The Club may put interim measures in place while a matter is considered. These are precautionary and do not mean that a finding has been made. Measures may include changing supervision or contact arrangements, directing a person not to communicate with another person, changing duties or team arrangements, restricting attendance, or temporarily standing a person aside where authorised and reasonably necessary.
8. Options for resolving or investigating a complaint
Depending on the nature and seriousness of the matter, the Club may use one or more of the following options.
8.1 Early or informal resolution
Where it is safe and appropriate, the Club may offer facilitated discussion, mediation, an agreed behaviour plan, education, an apology or another practical resolution. Participation is voluntary.
Informal resolution will not normally be used for suspected child abuse, serious sexual harassment, violence, threats, significant power imbalances, repeated serious behaviour or where an external authority should first consider the matter.
8.2 Formal investigation
The Club may appoint a suitably independent person to investigate. The process may include:
confirming the allegations and relevant policy provisions;
giving the respondent sufficient details and a reasonable opportunity to respond;
speaking separately with relevant people and considering available evidence;
allowing each person to have an appropriate support person present;
making findings on the balance of probabilities, taking account of the seriousness of the allegation and the quality of the evidence; and
providing the parties with an outcome summary, subject to privacy, child-safety, employment and legal obligations.
Children will be spoken with in a safe, age-appropriate and child-focused manner by a suitable person. The Club will avoid repeated questioning and will not conduct an internal interview that could compromise a police, Child Protection, regulator or governing-body investigation.
8.3 Referral
The Club may refer or report a matter to Football Victoria, Football Australia, a competition administrator, Victoria Police, Child Protection, the Social Services Regulator, eSafety Commissioner or another appropriate authority. The Club may pause or modify its process while an external process is underway.
Match-day misconduct and incidents involving another club, opposition participants or match officials may also be reported under the applicable Football Victoria or competition rules and reporting procedures.
9. Timeframes and communication
The Club will aim to complete its initial assessment within 10 business days and resolve a formal complaint within 30 days, where reasonably practicable.
Some matters may take longer because of their complexity, the availability of witnesses, natural justice requirements or an external investigation. If there is a delay, the Club will provide reasonable progress updates, generally at least every 10 business days, unless doing so would be unlawful, unsafe or compromise an investigation.
10. Outcomes and consequences
Possible outcomes include:
no further action where the available information does not justify it;
informal resolution, education, counselling, mentoring or a written agreement;
a direction to stop or change behaviour;
an apology or restorative action, where freely agreed and appropriate;
increased supervision or conditions on participation;
a warning, removal from a role, restriction from Club activities, suspension or termination of membership, engagement or registration, subject to the Club's constitution, rules and applicable law;
referral to Football Victoria, Football Australia or an external authority; or
changes to Club practices, training, supervision or risk controls.
Consequences will be determined case by case. The Club does not require repeated complaints or apply an automatic three-strikes rule before acting. A single serious incident may justify immediate protective or disciplinary action.
The complainant will be told whether the complaint was substantiated, partly substantiated, not substantiated or otherwise resolved, together with appropriate reasons. Detailed disciplinary, personal or employment information about another person may be withheld where privacy or legal obligations require it.
11. Review and escalation
A complainant or respondent may request an internal review within 14 days of receiving the outcome where they believe:
the process was materially unfair or this policy was not followed;
significant new evidence has become available that could not reasonably have been provided earlier;
there was a material conflict of interest; or
the outcome or consequence was not reasonably open on the information available.
The request must identify the review ground and supporting information. Where practicable, the review will be conducted by a person or panel not previously involved. An internal review is not a complete rehearing merely because a party disagrees with the outcome.
Member-protection complaints may be escalated through Football Victoria and, where permitted, Football Australia in accordance with the current Football Australia National Complaints Procedure. Governing-body escalation generally concerns whether the required complaints process was followed; it is not automatically an appeal against the Club's discretionary outcome.
Nothing in this policy limits any right a person may have under the Club's constitution, Football Victoria or Football Australia rules, or applicable law.
12. Child-safety complaints and external reporting
Where a complaint concerns suspected abuse or harm of a child, grooming, sexual misconduct or an adult who may pose a risk to children, the Club will prioritise the child's safety and follow its Child Safety and Wellbeing Policy.
Club personnel must not investigate whether alleged child abuse is true before making a report required by law or Club policy. The Club will comply with applicable obligations concerning mandatory reporting, failure to disclose, failure to protect, information sharing and the Victorian Reportable Conduct Scheme where it applies. As at the date of this review, the Social Services Regulator administers Victoria's Child Safe Standards and Reportable Conduct Scheme.
13. Confidentiality, privacy and records
Information will be shared only with people who reasonably need it to manage the complaint, provide procedural fairness, protect a person, obtain advice or comply with legal and reporting obligations.
The complainant, respondent, witnesses and support people are expected to respect the privacy of everyone involved. This does not prevent a person from seeking confidential support, obtaining legal advice, reporting to an authority or exercising a lawful right.
The Club will securely record the complaint, risk assessment, communications, evidence, actions, findings and outcome. Records involving children or serious misconduct will be retained in accordance with applicable legal and child-safety requirements.
14. Protection from victimisation
No person may threaten, disadvantage, exclude, intimidate or retaliate against someone because they made or may make a complaint, supported another person, provided evidence or participated in a process. Alleged victimisation will be treated as a separate and potentially serious breach.
15. Responsibilities
Everyone covered by this policy must behave respectfully, act on safety concerns, cooperate honestly with complaint processes and comply with reasonable directions.
Coaches, managers, volunteers and officials who receive a complaint must:
listen without dismissing or blaming;
respond calmly and prioritise safety;
avoid promising absolute confidentiality;
make an accurate written record as soon as practicable;
promptly refer the matter to the appropriate Club officer; and
follow child-safety and external reporting procedures where applicable.
The Committee is responsible for ensuring that complaints are allocated appropriately, conflicts are managed, records are secured, governing bodies and authorities are notified where required, and complaint trends are reviewed to improve Club practices.
16. Related policies and external frameworks
This policy should be read with the current versions of:
the Club's Constitution, Codes of Conduct, Child Safety and Wellbeing Policy, Member Protection Policy, Social Media Policy and disciplinary procedures;
Football Australia's Member Protection Framework, National Complaints Procedure, National Code of Conduct and Ethics, and Safeguarding Policy;
Football Victoria's Member Protection information, Grievance and Discipline Regulations, Grievance and Tribunal By-Law, Child Safety requirements and applicable competition rules;
the Victorian Child Safe Standards and Reportable Conduct Scheme; and
applicable Victorian and Commonwealth anti-discrimination, workplace safety, privacy and criminal laws.
If this policy is inconsistent with a binding law or governing-body rule, that law or rule prevails to the extent of the inconsistency.
17. Club contact details
General complaints: Club Secretary, President, MPIO or Complaint Officer via the contact details published on the Club website
Child-safety concerns: Club Child Safety Officer via the contact details published on the Club website
Football Victoria member protection: footballvictoria.com.au/about/member-protection
Football Australia integrity and member protection: footballaustralia.com.au/governance/integrity-framework
Victorian child-safety concerns and Reportable Conduct Scheme: vic.gov.au/report-your-concerns-under-child-safe-standards
Online abuse: esafety.gov.au/report
Emergency assistance: 000
Plain-language guide for children and young people
If someone at football makes you feel unsafe, scared, embarrassed, threatened or repeatedly picked on:
Move somewhere safe if you can.
Tell an adult you trust, such as a parent, carer, coach, team manager, Child Safety Officer or Committee member.
You can bring someone you trust when you talk to us.
You will be listened to. You will not be in trouble for speaking up.
If the first person does not help, tell another trusted adult or contact the Club's Child Safety Officer.
Call 000 if you or someone else is in immediate danger.
You do not have to confront the person or prove what happened before asking for help.