Child & Vulnerable People Safeguarding Policy
1. Introduction
Our Ocean School Ltd (OOS) is committed to conducting its activities in a manner that prevents its funds, programs, assets, reputation, or status as a charity from being used, directly or indirectly, to support money laundering or terrorism financing, in accordance with Australian laws (including anti-terrorism financing and anti-money laundering laws) and with its governance obligations under the OOS Constitution.
This policy sets out OOS’s commitment to take all reasonable and proportionate steps toprevent any misuse of its resources for illicit purposes and to protect the organisation, its beneficiaries, partners, donors and reputation.
2. Purpose
The purpose of this policy is to:
Clearly articulate OOS’s commitment to avoid involvement in, or support for, terrorism or terrorism financing or money laundering activities.
Establish OOS’s organisational position on counter-terrorism and anti-money laundering compliance.
Define responsibilities, controls, due diligence and reporting obligations to identify, mitigate, monitor, review and respond to risk.
3. Scope
This policy applies to:
- OOS Board directors and officers;
- Employees, volunteers, interns and representatives;
- Contractors, consultants, suppliers or agents engaged by OOS;
- All partner organisations, program partners and affiliates that receive funds, support, or direction from OOS.
4. Definitions
For the purposes of this policy:
- Counter-Terrorism Financing — Any act of providing or collecting funds, directly or indirectly, with the intention or knowledge that these funds will be used to facilitate or commit terrorist acts or support terrorist organisations.
- Money Laundering — The process of making the proceeds of crime appear legitimate through concealment or conversion so that they appear to come from legal sources.
- Terrorist Act — An act or threat that is designed to coerce, intimidate or influence a civilian population or government for political, ideological or religious ends.
- Assets — Includes funds, property, goods or resources of any kind, whether tangible or intangible.
5. Policy Principles
OOS will:
- Comply with all relevant Australian counter-terrorism, AML and sanctions laws,including restrictions on dealing with individuals or entities on recognised lists of prohibited persons; and ensure funds are not directed to support terrorism or laundering activities.
- Exercise due diligence when engaging partners, suppliers, contractors or disbursing funds, and ensure that such parties do not pose a terrorism risk.
- Integrate screening and verification checks into partner and third party selection where appropriate to identify potential links to terrorism or money laundering (e.g., checking against lists of proscribed entities maintained under Australian law).
- Ensure robust financial controls and transparent record-keeping to demonstrate lawful use of funds and compliance with reporting requirements.
- Provide awareness and training to personnel on AML/CTF risk and reporting obligations.
6. Risk Management
OOS recognises that charities operating overseas or transferring funds internationally have heightened risk under Australian terrorism financing guidance. OOS will embed AML/CTF risk into its enterprise risk management framework, consistent with the OOS Constitution’s governance and risk oversight provisions.
The Board will:
- Periodically assess the organisation’s exposure to AML/CTF risk;
- Ensure that risk mitigation actions are documented and monitored;
- Review this policy regularly and adjust as required.
7. Due Diligence & Screening
OOS will:
- Conduct due diligence on potential partners, especially those receiving funds or entrusted with programs in higher-risk environments;
- Where feasible, check partners and key individuals against internationally recognized sanctions and terrorist listings; and
- Seek assurances from partner organisations that they maintain adequate controls to prevent misuse of OOS funds.
8. Reporting and Response
All personnel must:
- Report any suspicious activity or credible concerns about money laundering or terrorism financing to the CEO or Board immediately; and
- Escalate concerns in line with OOS whistleblower procedures.
Where required by law or best practice, OOS will report incidents to relevant authorities, including law enforcement, AUSTRAC, and the Australian Federal Police.
9. Training & Awareness
OOS will:
- Ensure all relevant staff, volunteers and managers receive training to recognise and respond to AML/CTF risks;
- Provide ongoing awareness about legal obligations and this policy’s requirements; and
- Incorporate AML/CTF responsibilities into induction processes.
10. Responsibilities
- Board of Directors: Oversight, approval of policy, periodic review, risk governance.
- CEO/Executive Management: Implementation, monitoring and reporting.
- All Personnel: Compliance with policy, due diligence, and reporting obligations.
11. Record Keeping
In accordance with the OOS Constitution and Australian law:
- OOS will maintain financial and program records that demonstrate lawful and transparent use of funds; and
- Retain documentation relating to due diligence and AML/CTF checks in secure systems for audit and compliance verification.
12. Policy Review
This policy will be reviewed at least every two years or sooner if:
- There are changes in AML/CTF legislation or regulatory guidance;
- OOS’s risk profile changes significantly;
- New operational or partnership structures are introduced.
13. Approval
This policy is adopted and approved by the Board of Directors of Our Ocean School Ltd on
01.03.2026
