Child Protection Policy

1.0. Purpose

Australian Chamber of Commerce Mongolia (AustCham Mongolia) has a strong commitment to the safety, wellbeing and protection of children. Al children have the right to be safe from physical, sexual and emotional abuse and exploitation.
AustCham Mongolia's commitment to child rights is reflected in its procedures and expected
behaviours for al AustCham Mongolia's staff, volunteers, contractors and associates. These measures reflect AustCham Mongolia's zero tolerance approach to child exploitation or abuse,
empower people to be alert to risks, and to seek guidance and support to respond appropriately.
AustCham Mongolia encourages a culture of open discussion regarding the protection and
rights of children. AustCham Mongolia commits to doing everything in its power to prevent child abuse and exploitation.

2.0. Scope

Al personnel and associates must comply with this policy in the course of their work and when representing AustCham Mongolia:

  • AustCham Mongolia's personnel
  • Associates, Board and Committee members
  • Contractors and service providers (who are not directly supervised by AustCham Mongolia's staff)
  • International and National volunteers

AustCham Mongolia's personnel (as defined for the purposes of this policy) are: employees, consultants, contractors, Board members and Committee members.

3.0. Definitions

AustCham Mongolia's definitions of abuse include:

  • Physical abuse - the use of physical force against a child that results in harm to the child. Physically abusive behaviour includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning.
  • Neglect - the failure by a parent or caregiver to provide a child (where they are in a position to do so) with the conditions that are culturally accepted as being essential for their physical and emotional development and wellbeing.
  • Emotional abuse - refers to a parent or caregiver's inappropriate verbal or symbolic acts toward a child, or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Such acts have a high probability of damaging a child's self-esteem or social competence.Sexual abuse - the use of a child for sexual gratification by an adult or significantly older child or adolescent. Sexually abusive behaviours can include but not limited to fondling genitals; masturbation; act of sex; vaginal or anal penetration by a penis, finger or any other object; fondling breasts; and exposing the child to, or involving the child in, pornography.
  • Ill-treatment - disciplining or correcting a child in an unreasonable and seriously inappropriate or improper manner; making excessive and/or degrading demands of a child; hostile use of force towards a child; and/or a pattern of hostile or unreasonable and seriously inappropriate degrading comments or behaviour towards a child.
  • Grooming - grooming concerns predatory conduct undertaken to prepare a child for sexual activity at a later time. Grooming behaviour is where an adult communicates, by words or conduct, with a child or with a person who has care, supervision or authority for the child with the intention of facilitating the child's involvement in sexual conduct, either with the groomer or another adult.
  • Online grooming - sending electronic messages to children, with the intention of procuring children to engage in or submit to sexual activity with another person, including but not necessarily the sender; or of sending an electronic message with indecent content to a recipient who the sender believes is a child.
  • Child Exploitation - includes forcing or coercing another person to commit an act or acts of abuse against a child, possessing, controlling, producing, obtaining or transmitting child exploitation material, forcing or coercing another person to commit an act or acts of grooming or online grooming, or using a child for profit, labour, sexual gratification, or other personal or financial advantage. Child exploitation also includes modern slavery and the trafficking or recruitment of children into armed conflict.

4.0. Responsibilities and Procedures

4.1. Child safe recruitment and screening

AustCham Mongolia will take all reasonable steps to ensure all personnel, and associates have passed screening procedures and do not pose a risk to children. Where AustCham Mongolia is directly responsible for recruitment, AustCham Mongolia will consistently apply recruitment procedures for all personnel, program participants and associates.
AustCham Mongolia's child safeguarding recruitment procedures include:
a) AustCham Mongolia will require a National Criminal record checks as a condition for employment:
  • Criminal record checks must be obtained prior to engagement for all AustCham Mongolia's personnel and associates, irrespective of position or length of engagement.
  • AustCham Mongolia will not employ or engage a person fi their criminal record check includes convictions or sentences for: sexual offences against a child or adult; violent offences against a child or adult; any child exploitation or abuse offence; stalking of a child; serious drug offences; family and domestic violence offences.
  • AustCham Mongolia will take all fair and reasonable steps as part of any investigation following an adverse finding including whether the nature of the finding is in conflict with or affects the AustCham Mongolia's worker's position - or other persons also covered by the scope of this policy from being able to carry out their duties and responsibilities. AustCham Mongolia will abide by relevant Mongolian laws such as the 1996 Law on the Protection of Children's Rights and the 1999 Law on Family and the AustCham Code of Conduct, regarding ensuring any investigations following disclosure are undertaken in line with privacy, confidentiality, and anti-discriminatory legislation.

b) Behavioral based interview questions: questions pertaining to the worker's interactions with children will be utilized in employment interviews to determine attitudes, motivations, and values, regarding children and AustCham Mongolia's commitment to child rights.

c) Sign and comply with this policy and 'Child Protection Code of Conduct: as a condition of engagement with AustCham Mongolia. A written record of agreement will be retained on file.

d) All employment contractscontain provisions for potential disciplinary action: including termination of employment following breach of the Child Protection Policy and Code of Conduct.

4.2. Education, training, and communication

AustCham Mongolia's personnel and associates will undertake child protection policy training as part of orientation and ongoing engagement. Training is delivered through a range of mediums including face to face and through online modules.

AustCham Mongolia's Child Protection Policy and Code of Conduct will be available on the AustCham Mongolia's official website.

4.3. Child Protection Code of Conduct

  • treat children with respect regardless of race, colour, gender, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status
  • not use language or behaviour towards children that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate
  • not engage children under the age of 18 in any form of sexual intercourse or sexual activity, including paying for sexual services or acts
  • wherever possible, ensure that another adult is present when working in the proximity of children
  • not invite unaccompanied children into my home, unless they are at immediate risk of injury or in physical danger
  • not sleep close to unsupervised children unless absolutely necessary, in which case I must obtain my supervisor's permission, and ensure that another adult is present if possible
  • use any computers, mobile phones, video cameras, cameras or social media appropriately, and never to exploit or harass children or access child exploitation material through any medium
  • not use physical punishment on children
  • not hire children for domestic or other labour which is inappropriate given their age ordevelopmental stage, which interferes with their time available for education and recreational activities, or which places them at significant risk of injury
  • comply with all relevant legislation, including labour laws in relation to child labour
  • immediately report concerns or allegations of child exploitation and abuse in accordance with appropriate procedures
  • immediately disclose all charges, convictions and other outcomes of an offence, which occurred before or occurs during my association with AustCham Mongolia that relate to child exploitation and abuse.

4.4. When photographing or filming a child or using children's images for work- related purposes:

  • assess and endeavour to comply with local traditions or restrictions for reproducing personal images before photographing or filming a child
  • obtain informed consent from the child and parent or guardian of the child before photographing or filming a child. As part of this I must explain how the photograph or film will be used
  • ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive
  • ensure images are honest representations of the context and the facts
  • ensure file labels, meta data or text descriptions do not reveal identifying information about a child when sending images electronically or publishing images in any form.

5.0. Risk Assessment

AustCham Mongolia is committed to protecting children in all of its programs and activities. Accordingly, AustCham Mongolia will endeavor to identify any risks to children in its programs and activities, and will seek to reduce and remove identified risks, before commencing with a program or activity. Identified risks and management strategies will be documented in AustCham Mongolia's Risk AssessmentLog.

5.1. Identification of Risks:

  • Conduct a thorough review of our organization's activities, events, facilities, and personnel to identify potential risks and hazards.
  • Consider physical, psychological, and social risks that may affect children.
  • Engage relevant stakeholders, including staff, volunteers, parents, and child protection experts, in the identification process to ensure comprehensive coverage.

5.2. Risk Assessment: 

  • Evaluate the severity and likelihood of identified risks.
  • Assess the potential harm each risk could cause to children.
  • Consider the vulnerability of children involved and any protective factors in place.

5.3. Risk Assessment Log: 

  • Any or all potential harm to children will be identified, accessed and evaluated as per the Risk Assessment Log below and control measures will be taken to address such risks:
Risk assessment log
Identified riskControlsDelegation

6.0. Incident Reporting and Response Procedures

AustCham Mongolia's personnel or associates must immediately report any concerns, suspicions, or behaviour that is suspected of being child abuse or exploitation, or a suspected breach of the Child Protection Policy and Code of Conduct.

Children and members of the community may also report:

  • An observation or disclosure b y an adult or child) of abuse or exploitation
  • An observation or disclosure of potential risk of harm or child abuse
  • A breach of the AustCham Mongolia's Child Protection Policy or 'Child Protection Code of Conduct'
  • A situation or environment which is working in opposition to, or poses a threat to children's rights
  • An observation or disclosure of behaviour which could be considered grooming
  • Child exploitation materials that are received on AustCham Mongolia's electronic
    equipment (this can include, but is not limited to, SPAM, popups, text messages, emails, or social media communications.

A report must be made when:

  • Suspected harm is due to the actions or inactions of an AustCham Mongolia's Board member, staff member or other associate, or due to the actions of a person representing an AustCham Mongolia or contractor.
  • An alleged criminal offence has been committed against a child and the matter will be reported to the relevant authorities in Mongolia.

When to report:

The report must be made immediately, or within 24 hours, of becoming aware of the incident, suspicion or risk.

Who to report to:

Reports must be made to one or more of the following:

  • Chairperson or Executive Committee Members or to the Board Members

What happens after a report:

Al incident reports wil be documented, investigated and responded to. An incident response case plan will be developed and will include:

a) An assessment of the incident report information,

b) An outline of the specific actions to be taken, a time frame, and those persons
responsible for taking the action required. Actions required may include:

  • Reporting to local and/or National authorities in accordance with 1996 Law on the Protection of Children's Rights and the 1999 Law on Family
  • Action to be taken by the Board of Directors and Executive Committee of AustCham Mongolia

Following a formal investigation, a confirmed breach of the Child Protection Policy or Code of Conduct may lead to the instigation of performance and disciplinary procedures, which may involve termination of employment for staff.

No action will be taken against any person who informs AustCham Mongolia in good faith of incidents and risks. However, those who willfully inform AustCham Mongolia using false information will be subject to investigation and possible consequences as per disciplinary procedures. AustCham Mongolia is committed to ensuring privacy, and psychological and physical safety for individuals who report.

7.0. Confidentiality and Safety

AustCham Mongolia will ensure that all incidents and reports are handled according to the principles of confidentiality, safety, impartiality, procedural fairness, timeliness and accuracy.

All incidents and reports and the names of people involved, wil be handled in the strictest of confidence. Details will only be disclosed on a 'need to know' basis, where required by relevant local or Mongolia law, or when a notification to police or appropriate authorities must be made.

8.0. Policy review

This policy will be reviewed and, where appropriate, updated, at least once every two years.

9.0. Related policies and documents

  • L1-POL-002 Code of Ethics
  • L2-AUS-003 Employee Relations Procedure
  • AustCham Child Protection Code Conduct

10.0. Revision history

DateSectionOutline changesAuthorization
2022.02.09First issueFirst issueErlan Khuatkhan
2022.07.18Second issueSecond issueErlan Khuatkhan and Oyun-Erdene Gandemberel
AustCham Mongolia’s April Sundowner Networking Event
April 17 @ 6:30 pm - 9:00 pm

AustCham Mongolia Professional Speakers Series with PwC Legal
April 12 @ 8:30 am - 10:30 am

AustCham Mongolia Annual Report 2023
April 1, 2024

AustCham Mongolia Board Nominees 2024
April 1, 2024

ALS Group Mongolia becomes a new ‘Company’ member of AustCham Mongolia
July 26, 2023

Minpac Logistics (Australia) Pty Ltd becomes a new ‘Corporate’ member of AustCham Mongolia
July 6, 2023

Techenomics Mongolia renewed their ‘Company’ membership with AustCham Mongolia for 2023!
July 5, 2023


Julien Lawrence
AustCham Mongolia