Gender-based Violence Prevention and Response Policy & Procedure  

1. Purpose  

This document establishes the commitment of Yugo Australia Pty Ltd (‘Yugo Australia’) to provide safe, respectful and inclusive environments for its residents, employees, contractors, volunteers, and guests.  

2. Scope  

This policy applies to residents, employees, contractors and volunteers of Yugo Australia at all times, and considers relevant laws Federal and State as they may apply such as but not limited to Employment Laws, Privacy Law, Residential Tenancy Laws.

3. Principles

• Gender-based violence is unacceptable.  
   
• The safety and wellbeing of those who experience gender-based violence (‘victim-survivors’) will be the priority of Yugo Australia in responding to any incidents.  
   
• Yugo Australia will follow the principle that all responses follow principals of procedural fairness and natural justice for all parties involved understanding gender-based violence.
   
• Gender-based violence means any form of physical or non‑physical violence, harassment, abuse or threats, based on gender, that results in, or is likely to result in, harm, coercion, control, fear or deprivation of liberty or autonomy. Gender-based violence can occur in person or online.
   
• Gender-based violence includes, but is not limited to:
  • sexual harassment (a form of sexual violence)
  • sexual assault (a form of sexual violence)
  • technology-facilitated abuse or technology-facilitated gendered violence, including image-based abuse
  • emotional/psychological abuse
  • economic and financial abuse
  • stalking and harassment
  • systems abuse  
  • spiritual or religious abuse  
  • femicide or homicide
  • modern slavery, human trafficking and forced marriage
  • harmful practices that put sexual and reproductive health and rights at risk (such as stealthing).  
     
• Coercive control is the underlying dynamic of most instances of gender-based violence. Coercive control involves perpetrators using patterns of abusive behaviours over time in a way that creates fear and denies liberty and autonomy.  
   
• There are groups in the community that are disproportionately affected by gender-based violence. This includes women, young women, First Nations people, people from racially and culturally marginalised groups, people of diverse sexual orientation and gender identity, and people with disability. Evidence shows that the majority of perpetrators of gender-based violence are men.  

4. Preventing gender-based violence  

• Yugo Australia will deliver education, training and initiatives across the organisation to prevent gender-based violence. These activities will challenge factors that drive and contribute to gender-based violence, including:
  • condoning of violence against women  
  • men’s control of decision-making and limits to women’s independence in public and private life
  • rigid gender stereotypes  
  • male peer behaviours that promote aggression and disrespect towards women
  • condoning of violence in general
  • experiences and exposure to violence
  • weakening of pro-social behaviour
  • resistance and backlash against gender equality, diversity and inclusion.
     
• These activities will also challenge other forms of discrimination – including but not limited to racism, homophobia, transphobia and ableism – that intersect to shape people’s experiences of gender-based violence. Yugo Australia’s policies relating to discrimination and harassment can be found here.
   
  • Anti-Harassment Global Policy
  • Psychological Safety Policy Australia
  • Employee Wellbeing Global Policy
  • Anti Human Trafficking Policy
     
• To reflect Yugo Australia’s large international student population, prevention activities will specifically address racism as well as any cultural norms that are not underpinned by principles of gender equality, diversity and inclusion.  

5. Responding to gender-based violence

• Yugo Australia recognises that making a disclosure or formal report of gender-based violence can be traumatic, and the response a victim-survivor receives plays a key role in their recovery and healing.
   
• In responding to gender-based violence, Yugo will take a person-centred and trauma-informed approach. This means the needs and preferences of the victim-survivor will be genuinely considered as part of decision-making while ensuring their safety. It also means that risks of re-traumatisation will be minimised to the greatest extent possible.  

6. Disclosures and formal reports

• A disclosure is when someone provides information to Yugo Australia about an experience of gender-based violence. Disclosures can be made by the victim-survivor or a third party, such as a bystander or witness. The person disclosing may be seeking support or advice and may or may not want to make a complaint.
   
• A formal report means when a victim-survivor makes a complaint to Yugo Australia and would like further action to be taken.  
   
• A person can choose whether they want to remain anonymous or identify themselves when they make a disclosure or formal report.  

7. Ways to make a disclosure or formal report

• Residents, volunteers, and guests can make an anonymous disclosure or formal report to Yugo Australia via the website
   
• Residents, volunteers, and guests can make an identified (non-anonymous) disclosure or formal report to Yugo Australia via the website, emailing the property residence manager directly and submitting an enquiry via the student app.
   
• Employees and contractors can make a disclosure or formal report to their direct line manager, People and Culture manager, Senior Vice President of APAC and via the website.
   
• Information on support services can be found here and at Appendix A.  
  Getting Help & Support at Yugo

8. Immediate safety responses  

a. Identified disclosures and formal reports

• Upon receiving an identified disclosure or formal report of gender-based violence, Yugo Australia will:
  • Make contact with the victim-survivor on the same day. Yugo Australia will discuss available support services and other reporting options (for example, to police) and will provide urgent support and assistance to access these services and options
     
• Immediately assess risk and take all measures necessary to protect the safety of victim-survivor, other residents and employees. Where the identified respondent is a resident or employee, measures may include temporarily relocating the respondent if they are a resident, or adjusting work arrangements.
  • Explain confidentiality and information-sharing. Yugo Australia recognises that when making a disclosure, a victim-survivor may request that no-one else is told about their experience. However, there are circumstances in which Yugo Australia is obligated to share key information with others (such as particular Yugo Australia employees, the victim-survivor’s university, or police) to protect the victim-survivor’s safety and the safety of others. In all circumstances and prior to any information being shared, Yugo Australia will explain to a victim-survivor why, what and with whom information about the disclosure may need to be shared, and will collaborate with the victim-survivor on how this information-sharing occurs. Yugo Australia will maximise victim-survivors’ agency and autonomy within this context to the greatest extent possible.
     
• Any sharing of personal information will comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Information will only be shared where required or authorised by law, necessary to prevent a serious threat to the life, health or safety of any person, or with consent.  
   

b. Anonymous disclosures and formal reports

• Upon receiving an anonymous disclosure or formal report of gender-based violence, Yugo Australia will take all steps reasonable within its control to address the behaviour and prevent further violence occurring based on information received.  
   
• Any sharing of personal information will comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principals. Information will only be shared where required or authorised by law, necessary to prevent a serious threat to the life, health or safety of any person, or with consent
   
• Yugo Australia may be limited in the steps it can take in response to anonymous disclosures and formal reports.  

9. Steps following an immediate safety response  

a. Resident victim-survivor choice in who leads next steps

• Following the implementation of any immediate safety measures, Yugo Australia will ask a resident victim-survivor whether they would like Yugo Australia or their University to lead next steps.  
   

b. Where Yugo Australia leads next steps

• Where a resident victim-survivor requests that Yugo Australia leads next steps, Yugo Australia will:
   
  • conduct a risk assessment within 48 hours of original receipt of the disclosure or formal report. The purpose of this assessment is, among other things, to determine the level of risk to the victim-survivor’s safety, the likelihood of further violence occurring and risks to the safety of other people. The person conducting the risk assessment will have specific knowledge, expertise and experience in gender-based violence risk assessment.  
     
  • develop and implement a support plan within 48 hours in collaboration with the victim-survivor. This plan will include additional/amended safety measures, referrals to services, adjustments to work or participation in resident activities, and wellbeing checks.  
     
• Based on findings of the risk assessment, Yugo Australia may decide to take further action in response to a disclosure – such as an investigation – against the wishes of the victim-survivor because there is a serious threat to safety.  
   
• Yugo Australia will notify the victim-survivor of any further action in writing and discuss processes with them. Throughout the process Yugo Australia will promote the victim-survivor’s agency and autonomy as much as possible and provide or facilitate access to ongoing support.  
   
• Where further action is taken involving a respondent, Yugo Australia will notify a respondent of further action on the same day as the victim-survivor, with the victim-survivor notified first. Yugo Australia will develop and implement a support plan within 48 hours in collaboration with the respondent and provide or facilitate access to ongoing support.

10. Investigations

• Investigations will be conducted by a person with specific knowledge, experience and expertise in gender-based violence, record keeping and complaints handling.  
   
• To minimise the number of times a victim-survivor has to share details about their experience, Yugo Australia will provide the investigator with all necessary information and collaborate with the victim-survivor on how this information-sharing occurs.  
   
• The investigator will ask to interview the victim-survivor and resident/employee respondent (if identified). All parties are entitled to have a support person with them throughout the process.  
   
• Neither the victim-survivor nor respondent are required to participate in the investigation process. At all times, Yugo Australia will take a victim-survivor centred, safety-first approach.  
   
• If a respondent chooses not to participate, the investigation will proceed without them.  
   
• The investigator will prepare and provide a report with a recommendation to the Senior Vice-President Operations Australia for decision.  
   
• A decision on whether gender-based violence occurred will be based on the balance of probabilities; this means that it is more likely than not to have occurred.  
   
• Where gender-based violence is found to have occurred, Yugo Australia will consider actions that are legally at its disposal for residents and employees that are focused on the outcomes of any risk assessment and recommendations to ensure the safety and security of the parties involved be they residents or employees and the safety and security of the entire building.
   
• Actions available may be;  
  • to contact the police where Yugo Australia considers there is a serious or imminent threat to safety & wellbeing.
  • terminate employment
  • discuss the details with the relevant University.
  • Consider options for removing the responder from the accommodation.
  • Offering options to the Discloser to move from the accommodation.
     
• The Senior Vice-President Operations Australia will notify the victim-survivor and respondent on the decision, reasons for the decision and any actions that Yugo has determined must be taken for the safety and security of the parties and other students living in the residence. Both parties will be notified in writing on the same day, with the victim-survivor notified first.  
   
• Yugo Australia employees who have experienced gender-based violence may apply for domestic and family violence leave. Information on applying for this leave can be found here Family and domestic violence leave - Fair Work Ombudsman. 

11. Compliance and reporting

• All records or information obtained by Yugo Australia in managing a disclosure or formal report will be managed and retained in accordance with Yugo Australia’s Privacy Policy and will be kept confidential to the greatest extent possible.
   
• Under the Universities Accord (National Higher Education Code to Prevent and Respond to Gender-based Violence) Act 2025 (Cth) Yugo Australia is required to share de-identified and aggregated information on disclosures and formal reports of gender-based violence to relevant universities on an annual basis. All information provided to universities will comply with Yugo Australia’s obligations under the Privacy Act 1988 (Cth).
   

• Definitions 

  Coercive control	Coercive control is often a significant part of a person’s experience of family and domestic violence and describes someone’s use of abusive behaviours against another person over time, with the effect of establishing and maintaining power and dominance over them.
  Economic abuse	Economic abuse involves a pattern of control, exploitation or sabotage of money and finances and economic resources, which affects a person’s ability to obtain, use or maintain economic resources, threatening their economic security and potential for self-sufficiency and independence.
  Emotional/psychological abuse	An ongoing pattern of behaviour intended to cause harm to a person's mental health and emotional wellbeing. It includes behaviours such as insults, belittling, and gaslighting.
  Financial abuse	Financial abuse is a common form of domestic and family violence. It is perpetrated by intimate partners or family members, and also occurs in the context of elder and carer abuse. It manifests in different ways but generally it is a type of controlling behaviour where the perpetrator controls finances and assets to gain power and control in a relationship.
  Forced marriage	A modern slavery crime where someone is married without freely and fully consenting to the marriage because of threats, deception or coercion, or the individual is incapable of understanding the nature and effect of the marriage ceremony, or the individual is under the age of 16 years.
  Image-based abuse	When an intimate image or video is shared, or threatened to be shared, without the consent of the person shown. This includes images or videos that have been digitally altered.
  Modern slavery	Describes all human trafficking, slavery and slavery-like practices in Divisions 270 and 271 of the Criminal Code Act 1995 (Cth). These offences include trafficking in persons, slavery, servitude, forced labour, deceptive recruitment for labour or services, debt bondage, and forced marriage. The term modern slavery is also used to describe the worst forms of child labour
  Sexual assault	Sexual assault is an act of a sexual nature carried out against a person’s will through the use of physical force, intimidation or coercion, including any attempts to do this. This includes rape, attempted rape, aggravated sexual assault (assault with a weapon), indecent assault, penetration by objects, forced sexual activity that did not end in penetration and attempts to force a person into sexual activity. Note sexual assault occurs when a person is forced, coerced or tricked into sexual acts against their will or without their consent, including when they have withdrawn their consent.
  Sexual harassment	An unwelcome sexual advance, unwelcome request for sexual favours or other unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated, where a reasonable person would anticipate that reaction in the circumstances.
  Sexual violence	Sexual violence refers to sexual activity that happens where consent is not freely given or obtained, is withdrawn or the person is unable to consent due to their age or other factors. It includes sexual harassment and sexual assault. It occurs any time a person is forced, coerced or manipulated into any sexual activity. Such activity can be sexualised touching, sexual abuse, sexual assault, rape, sexual harassment and intimidation and forced or coerced watching or engaging in pornography. Sexual violence can be non-physical and include unwanted sexualised comments, intrusive sexualised questions or harassment of a sexual nature. Forms of modern slavery, such as forced marriage, servitude or trafficking in persons may involve sexual violence.
  Spiritual or religious abuse	When a person uses spiritual or religious beliefs to hurt, scare or control someone. It includes ridiculing or making fun of someone’s religious or spiritual beliefs to undermine their identity and sense of self or self-confidence, isolating the person from communal worship, limiting religious activities, or forcing someone to covert to a religion.
  Stalking	Stalking is a pattern of unwanted behaviours aimed at causing fear or distress and reducing the victim’s autonomy and sense of security. It is considered a form of emotional or psychological abuse.
  Systems abuse	The manipulation of legal and other systems by perpetrators to exert control over, threaten and harass a victim-survivor. It includes filing false or retaliatory complaints, weaponising legal or disciplinary systems, manipulating confidentiality and privacy protections to restrict legitimate information sharing to protect disclosers, threatening to leak private information to silence the discloser, and claiming procedural unfairness.
  Technology-facilitated abuse	A wide-ranging term that encompasses many subtypes of interpersonal violence and abuse using mobile, online and other digital technologies. These include harassing behaviours, sexual violence and image-based sexual abuse, monitoring and controlling behaviours, and emotional abuse and threats.
  Victim-survivor	Someone that has experienced gender-based violence.