POL-04 — Incident, Near Miss & Emergency Management Policy

CONVI has a zero tolerance approach to preventable harm and a clear obligation to respond to and report incidents in accordance with the NDIS framework and Victorian law.

Document reference	POL-04
Version	v1.1 (supersedes v1.0)
Status	Current — Authoritative
Changes in v1.1	Clarified reportable incident scope (connection to service delivery required); unexplained absence threshold; safeguarding obligation for pre-existing injuries
Review cycle	Annual — next review May 2027

1. Definitions

Term	Definition
Incident	Any event or circumstance that has caused or could cause harm to a participant, worker, or third party in connection with CONVI's service delivery.
Near Miss	An event that did not cause harm but had the potential to do so. Logged internally for continuous improvement.
Reportable Incident	A specific category of incident under the NDIS (Incident Management and Reportable Incidents) Rules 2018 that must be notified to the NDIS Commission within 24 hours.
Mandatory Report	A report to Child Protection or Police required under Victorian law when a worker forms a reasonable belief that a child is at risk of or has experienced abuse or neglect. This is separate from the NDIS reportable incident framework.

2. What Is a Reportable Incident

Critical principle: A reportable incident must be connected to CONVI's provision of supports or services. Events that occur independently of CONVI's involvement follow safeguarding obligations, not the reportable incident pathway.

The following are reportable incidents where they occur in connection with CONVI's service delivery:

Type	Clarification
Death of a participant	Death that occurs during or is directly related to a CONVI-delivered session or the actions of a CONVI worker.
Serious injury of a participant	A significant injury — fracture, hospitalisation, burns, serious head injury — that occurs DURING a CONVI session or as a direct result of support delivery.
Abuse or neglect by a CONVI worker	Any physical, sexual, psychological, or financial abuse, or neglect, involving a CONVI worker or occurring during a CONVI session.
Unlawful sexual contact or inappropriate sexual conduct	Any such conduct involving a participant and a CONVI worker or another person during service delivery.
Use of unauthorised restrictive practice	Any restraint, seclusion, or restriction used by a CONVI worker that is not authorised through the full NDIS/Victorian framework.
Unexplained absence — genuine safety concern	See Section 4 for the critical distinction between a reportable unexplained absence and a routine no-show.

3. Pre-Existing Injuries

Scenario: Worker Arrives and Discovers a Participant Has an Injury

Where a worker arrives and observes an injury that did not occur during CONVI's service delivery:

This is NOT a reportable incident under the NDIS Rules — the event did not occur in connection with CONVI's service delivery.
However — assess whether the injury raises a safeguarding concern. Ask: Is this injury unexplained? Is the participant's account inconsistent? Are there other signs of harm or neglect?
If YES — triggers safeguarding obligations under POL-07. Contact the Director immediately.
If NO reasonable safeguarding concern — document the observation factually in the session note and notify the Director at the end of the session.

When in doubt about whether an observed injury raises a safeguarding concern — call the Director before proceeding. It is always better to over-escalate than to leave a concern undocumented.

4. Unexplained Absence — When Is It Reportable?

Not a Reportable Incident (Routine No-Show)

A routine no-show where the participant is simply not home, contact with family or emergency contacts confirms their whereabouts, or there is a reasonable explanation — is not a reportable incident. Apply cancellation billing rules. No Commission notification required.

Reportable Incident — Genuine Safety Concern

An unexplained absence becomes a reportable incident when ALL of the following apply:

The participant is known to have been at or near the residence and cannot be located
Attempts to contact the participant and their emergency contacts have failed
There is genuine, reasonable concern for the participant's immediate safety based on their known history, presentation, or circumstances

Response steps: Search the immediate vicinity. Contact all emergency contacts from the participant's Emergency Management Plan. If not located within 10 minutes — call 000 and report as a missing person. Notify Director immediately. Notify the NDIS Commission within 24 hours.

5. Mandatory Reporting — Child Participants

Mandatory reporting is a personal legal obligation under the Children, Youth and Families Act 2005 (Vic). Where a worker forms a reasonable belief that a child participant has been, or is at risk of being, abused or neglected:

Call Child Protection immediately: 131 278 (business hours) | 13 12 78 (after hours)
You do not need Director authorisation before calling. The obligation is personal and immediate.
Notify the Director on the same day — after the report has been made, not instead of making it
Document the report in the session note: date, time, officer's name, reference number

6. NDIS Commission Notification

Reportable incidents must be notified to the NDIS Commission within 24 hours of CONVI becoming aware. The 24-hour clock starts from when the Director or any CONVI representative became aware — not from when the incident occurred. A written report must be submitted within 5 business days of initial notification.

Portal: provider.ndiscommission.gov.au

7. Worker Support After an Incident

Director offers a debrief within 24 hours of any significant incident
Workers are never penalised for reporting an incident in good faith
Concealing an incident, providing a false account, or tampering with records is grounds for termination and possible Commission referral

Over-reporting is always safer than under-reporting. When in doubt about whether something is a reportable incident — treat it as one and notify the NDIS Commission.

POL-04 | v1.1 | May 2026 | Convi Pty Ltd (ACN 677 127 703) as Trustee for Attard Family Australia Trust | ABN 60 342 025 267

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