CHILD SAFETY & PROTECTION POLICY

Issued by MTB Detour Pty Ltd (ACN 693 200 289)

Version 1.0 — Effective 1 January 2026

1. Purpose

1.1 This Child Safety & Protection Policy (“Policy”) establishes mandatory standards, responsibilities, reporting obligations, and behavioural expectations that ensure the safety, wellbeing, and protection of all individuals under 18 years of age (“Minors”) participating in tours, coaching sessions, events, races, or associated activities (“Activities”) delivered by MTB Detour Pty Ltd (“the Operator”).

1.2 This Policy supports compliance with:

(a) Child Protection Act 1999 (Qld);

(b) Working with Children (Risk Management and Screening) Act 2000 (Qld);

(c) Working with Children (Risk Management and Screening) Regulation 2020 (Qld);

(d) Human Rights Act 2019 (Qld);

(e) Criminal Code Act 1899 (Qld) (mandatory reporting and criminal offence provisions);

(f) adventure-sector child safety frameworks, including relevant Adventure Activity Standards (AAS).

1.3 This Policy forms part of the Operator’s legally required Child Risk Management Strategy.

2. Scope

2.1 This Policy applies to:

(a) all Minors participating in Activities;

(b) all Guardians providing consent;

(c) all Operator staff, Guides, coaches, contractors, and volunteers;

(d) all locations where Activities occur, including Queensland, interstate, or international sites.

3. Definitions

3.1 “Minor” means a person under 18 years of age.

3.2 “Guardian” means the lawful parent or legal guardian.

3.3 “Harm” includes physical, emotional, sexual, psychological, or neglect-related harm.

3.4 “Mandatory Reporter” means any individual legally required to report suspected harm (including certain staff under Queensland law).

3.5 “Child Safety Concern” means any suspicion, allegation, disclosure, behaviour, or circumstance that may indicate harm or risk to a Minor.

4. Child Safety Principles

4.1 The Operator is committed to:

(a) protecting Minors from all forms of harm;

(b) creating an environment that is welcoming, inclusive, and safe;

(c) ensuring all staff and contractors comply with legislation;

(d) responding promptly to concerns or allegations;

(e) supporting Minors and their Guardians transparently and respectfully.

4.2 Child safety is prioritised above operational or commercial considerations.

5. Staff & Guide Requirements

5.1 All staff working with Minors must hold:

(a) a valid Working With Children Blue Card;

(b) a National Police Criminal History Check;

(c) current First Aid and CPR qualifications;

(d) relevant coaching or guiding certification.

5.2 Staff must complete:

(a) child safety and protection training;

(b) mandatory reporting training;

(c) training in professional boundaries;

(d) code-of-conduct training.

6. Professional Boundaries

6.1 Staff must maintain appropriate and professional boundaries at all times.

6.2 Prohibited conduct includes:

(a) being alone with a Minor without line-of-sight supervision;

(b) texting, private messaging, or direct social media contact with Minors;

(c) giving gifts or favours;

(d) physical contact that is inappropriate or not safety-related;

(e) behaving in a manner that could be misinterpreted as grooming.

6.3 Permitted physical contact includes:

(a) first aid;

(b) safety management;

(c) urgent risk mitigation;

(d) instructional corrections with verbal consent where appropriate.

7. Supervision Expectations

7.1 Minors must be supervised continuously during Activities.

7.2 Supervision includes:

(a) visual monitoring;

(b) Group management;

(c) maintaining safe spacing;

(d) ensuring Minors do not become isolated on trails.

7.3 Staff must actively monitor:

(a) fatigue;

(b) heat stress;

(c) peer interactions;

(d) risk-taking behaviour.

8. Recognising Harm and Abuse

8.1 Harm may include:

(a) physical abuse;

(b) emotional abuse;

(c) sexual abuse or exploitation;

(d) neglect;

(e) exposure to family or domestic violence;

(f) bullying or harassment.

8.2 Signs of harm may be:

(a) behavioural changes;

(b) unexplained injuries;

(c) anxiety or withdrawal;

(d) distress around particular individuals;

(e) disclosures from the Minor or peers.

9. Mandatory Reporting Obligations

9.1 Where a staff member suspects a Minor has been harmed, is being harmed, or is at risk of harm:

(a) they must notify the Managing Director immediately;

(b) the Managing Director must determine whether mandatory reporting applies;

(c) reports may be made to Queensland Police, Child Safety Services, or relevant local authorities.

9.2 Allegations involving staff must be reported regardless of perceived credibility.

9.3 All disclosures or suspicions must be documented accurately, including:

(a) date and time;

(b) account of concern;

(c) observations;

(d) names of witnesses;

(e) actions taken.

10. Procedures for Handling Child Safety Concerns

10.1 Steps include:

(a) ensure immediate safety of the Minor;

(b) notify relevant staff;

(c) document the concern;

(d) escalate to Managing Director;

(e) contact authorities if required;

(f) maintain confidentiality except where disclosure is mandated;

(g) provide support for the Minor and Guardian.

10.2 Minors must be taken seriously and treated with respect when making disclosures.

11. Photography, Video & Digital Content

11.1 Photography of Minors requires Guardian consent.

11.2 Photography must:

(a) avoid identifying details;

(b) avoid sensitive contexts (toilets, changing rooms, injury scenes);

(c) avoid one-on-one photography without supervision.

11.3 Use of images must comply with:

(a) the Photography, Media & Digital Content Policy;

(b) child protection laws;

(c) Guardian restrictions.

12. Transportation of Minors

12.1 Transportation must follow:

(a) two-adult supervision where practicable;

(b) avoidance of one-on-one travel unless unavoidable for safety;

(c) written Guardian consent for all transport.

12.2 Seatbelts and vehicle safety laws must be strictly applied.

13. Behaviour Management

13.1 Staff may intervene to:

(a) prevent harm;

(b) manage behaviour;

(c) enforce safety rules;

(d) protect other Minors.

13.2 Prohibited management strategies include:

(a) corporal punishment;

(b) humiliation;

(c) intimidation.

13.3 Minors may be removed from Activities if behaviour presents a risk.

14. Risk Management & Planning

14.1 Child safety risks must be assessed as part of:

(a) Activity planning;

(b) route selection;

(c) supervision ratios;

(d) heat and weather risk assessment;

(e) emergency planning.

14.2 Risk assessments must include considerations specific to Minors.

15. Confidentiality

15.1 Information relating to child safety concerns is confidential.

15.2 Disclosure is permitted only:

(a) to emergency or child protection authorities;

(b) to the Managing Director;

(c) where legally required.

15.3 Records must be stored securely and retained according to the Data Retention & Records Management Policy.

16. Allegations Involving Staff

16.1 Allegations against staff require:

(a) immediate suspension from child-related duties;

(b) internal investigation;

(c) mandatory reporting to authorities;

(d) full cooperation with external investigations;

(e) written documentation of all actions taken.

17. Jurisdiction

17.1 This Policy is governed by the laws of Queensland.

17.2 Local child protection laws apply where Activities occur outside Queensland.

18. Acceptance Statement

“By permitting a Minor to participate in activities delivered by MTB Detour Pty Ltd (ACN 693 200 289), I acknowledge the Operator’s commitment to child safety and understand the Child Safety & Protection Policy and associated protections.”