Anti-Bullying, Anti-Cyberbullying and Social Media Use Policy

Karabena Consulting and Weyarn Pty Ltd

1. Purpose

Karabena Consulting and Weyarn Pty Ltd are committed to providing a safe, respectful, and inclusive workplace for all employees, contractors, and stakeholders. This policy outlines our stance against bullying, cyberbullying, and improper use of social media in compliance with Federal and Victorian legislation.

2. Definitions

For the purposes of this policy, Karabena Consulting and Weyarn Pty Ltd use the following definitions:

2.1 Bullying

Repeated unreasonable behaviour directed towards an employee, or group of employees, that creates a risk to health and safety.

2.2 Cyberbullying

The use of technology, particularly social media, to bully, harass, or harm someone.

2.3 Social media use

The creation and sharing of information, ideas, and other forms of expression via platforms such as Facebook, LinkedIn, X (formerly Twitter), Instagram, and other internet-based platforms.

3. Scope

This policy applies to all employees, contractors, consultants, and any third parties working with Karabena Consulting and Weyarn Pty Ltd. It covers conduct within and outside of the workplace where interactions between employees, contractors, consultants, and any third parties working with Karabena and Weyarn Pty Ltd occur, including online interactions and the use of social media platforms.

A third party refers to any person or persons conducting services on behalf of or for Karabena Consulting and Weyarn Pty Ltd.

4. Legislative framework

4.1 Victorian legislation

Occupational Health and Safety Act 2004 (Vic). Places a duty on employers to provide and maintain, so far as is reasonably practicable, a working environment that is safe and without risks to health, including psychological health.

Occupational Health and Safety (Psychological Health) Regulations 2025 (Vic). Commenced 1 December 2025. These regulations create a specific duty to identify psychosocial hazards, to eliminate or reduce the associated risks so far as is reasonably practicable, and to review control measures. Bullying is named as a psychosocial hazard, alongside sexual harassment, aggression or violence, high job demands, and exposure to traumatic content or events. WorkSafe Victoria's compliance code on psychological health provides practical guidance.

Crimes Act 1958 (Vic), as amended by the Crimes Amendment (Bullying) Act 2011 (Vic), known as Brodie's Law. Recognises serious bullying, including cyberbullying, as a criminal offence.

4.2 Commonwealth legislation

Fair Work Act 2009 (Cth). A worker who reasonably believes they have been bullied at work may apply to the Fair Work Commission for an order to stop the bullying. The Act separately provides general protections against adverse action.

Sex Discrimination Act 1984 (Cth). Since December 2022, employers have a positive duty to take proactive and meaningful action to prevent workplace sexual harassment, sex discrimination, sex-based harassment, hostile workplace environments on the ground of sex, and related victimisation. The Australian Human Rights Commission has held compliance and enforcement powers in relation to the positive duty since December 2023.

4.3 A note on jurisdiction

Victoria has not adopted the model Work Health and Safety laws. The Occupational Health and Safety Act 2004 (Vic) is the operative safety legislation for Karabena Consulting and Weyarn Pty Ltd. Where we deliver work in another State or Territory, we observe the work health and safety law of that jurisdiction. Cyberbullying may also constitute a criminal offence under the law of the jurisdiction in which it occurs.

5. Anti-bullying

Karabena Consulting and Weyarn Pty Ltd have zero tolerance for workplace bullying. Any form of harassment, intimidation, or repeated unreasonable behaviour is unacceptable.

5.1 Reporting

Any employee, contractor, consultant, or third party conducting services on behalf of Karabena Consulting and Weyarn Pty Ltd who perceives they are the target of any form of bullying, as defined by relevant legislation, should report the incident in writing immediately to their supervisor or the Human Resources Department. This written report should include as much detail as possible, including the date, time, and overview of the incident. A supervisor or Human Resources Department representative will provide assistance to develop a written report if requested. All reports will be treated confidentially and investigated.

5.2 Investigations

An impartial investigation will be conducted by a Human Resources Representative to ascertain the facts. Where bullying is confirmed, disciplinary action will follow, which may include termination of employment. The disciplinary action applied will be determined by Karabena Consulting and Weyarn Pty Ltd's Executive depending on the severity of the incident or incidents.

6. Anti-cyberbullying

Cyberbullying is equally as serious as physical, verbal, or psychological bullying. Employees are expected to behave online in the same respectful and professional manner as they would in face-to-face interactions.

6.1 Reporting and investigations

Cyberbullying reports will be investigated similarly to workplace bullying, as outlined above, and any confirmed cases will lead to disciplinary action.

6.2 Legal consequences

Cyberbullying may also be reported to authorities where it breaches criminal law in the jurisdiction in which it occurs.

7. Social media use

Employees are expected to maintain professionalism in their use of social media, whether on personal or company accounts.

7.1 Personal social media accounts

Employees must not post defamatory, harmful, or inappropriate content about the company, colleagues, or clients. Social media use should not infringe upon the rights, safety, or reputations of others.

7.2 Workplace responsibilities

Social media should not be used during work hours unless it is part of an employee's role. Social media use during scheduled work breaks is permitted, as long as the employee adheres to all other responsibilities outlined in this policy.

7.3 Privacy and confidentiality

Employees must not disclose confidential company information, client details, or personal data on social media without explicit authorisation.

8. Consequences of policy breaches

Failure to adhere to this policy will result in disciplinary action, which may include:

• Counselling or feedback
• Written warning
• Performance management plan
• Suspension or termination of employment
• Legal action, including civil or criminal proceedings, where applicable

9. Implementation and workplace response

Karabena Consulting and Weyarn Pty Ltd are committed to proactively addressing bullying and cyberbullying through:

9.1 Education and training

Providing regular training to staff about recognising and responding to bullying and cyberbullying, including appropriate social media use.

9.2 Support mechanisms

Employees affected by bullying or cyberbullying will have access to support services, including counselling and mediation.

9.3 Monitoring and review

This policy will be reviewed annually by Karabena Consulting and Weyarn Pty Ltd's Executive to ensure it remains effective and relevant. Anonymous feedback from employees will also be used to inform the policy's review.

9.4 Implementation timeline

The implementation steps set out when this policy was introduced were as follows.

10. Conclusion

Karabena Consulting and Weyarn Pty Ltd are dedicated to providing a positive, respectful, and safe working environment. Employees and stakeholders are expected to uphold these values both in person and online, ensuring our workplace is free from bullying and cyberbullying.