Domestic, Family and Sexual Violence Policy

1. Purpose and Scope

Neptune Internet Pty Ltd (the Company) is a carriage service provider supplying fixed broadband services to residential and small business consumers. This Policy outlines the Company's commitment to supporting consumers who are or may be experiencing domestic, family or sexual violence.

This Domestic, Family and Sexual Violence Policy (Policy) reflects the requirements of the Telecommunications (Domestic, Family and Sexual Violence Consumer Protections) Industry Standard 2025 (the Standard). The Policy should be read in conjunction with the Company's Domestic, Family and Sexual Violence Procedures.

It applies to:

• All staff of the Company, including any contractors or agents who interact with consumers, as defined under the Standard, or consumer accounts
• All telecommunications services supplied by the Company to consumers
• All consumer interactions, account management activities, billing, and service operations

The Company recognises that domestic, family and sexual violence causes profound harm across Australian society, impacting individuals' safety and wellbeing. As a telecommunications service, we play a critical role in safeguarding victim survivors' rights to privacy, safety and continued access to communication services at all times.

Domestic and family violence can occur in any personal relationship including between intimate partners, parents and children, immediate and extended family groups, communal and extended kinship connections and in carer and guardianship arrangements.

We recognise that our services can be misused by perpetrators to monitor, isolate and control victim survivors, and understand the importance of ensuring that, through our services to a victim survivor, we do not exacerbate the risk of harm caused by domestic, family and sexual violence.

We acknowledge that many people affected by domestic, family and sexual violence operate as sole traders or run small businesses and perpetrators can misuse telecommunications services related to the business to control and cause harm. Irrespective of who holds the account, including if this is a business or organisation, we have a responsibility to recognise the risk and provide appropriate support and protections as required by the Standard.

We are committed to ensuring that people affected by domestic, family and sexual violence stay connected to communications services through safe, respectful and trauma-informed support.

2. Definitions

3. Principles

3.1 Safety First

The safety of the affected person is the paramount consideration in every interaction. We will always safeguard the safety, privacy and continued access to services of the affected person.

3.2 Trauma-Informed Practice

We recognise that consumers experiencing domestic, family and sexual violence may be in distress, fearful, or in danger. We will respond with empathy, patience and without judgment.

3.3 Privacy and Confidentiality

We will take all reasonable steps to protect the privacy of affected persons and only access or share personal and sensitive information to the extent needed to support them.

3.4 No Barriers to Assistance

We will not create unnecessary barriers to affected persons seeking support.

3.5 Inclusivity

We recognise that domestic, family and sexual violence affects people across all backgrounds, genders, ages, abilities, cultures, and communities. We will adopt an inclusive, intersectional approach and offer multiple options for seeking support, ensuring that no one is excluded or disadvantaged in doing so. Our approach will be accessible and inclusive, acknowledging the heightened and compounding risks and barriers to accessing services faced by First Nations peoples, people with disability, people from culturally and linguistically diverse backgrounds, LGBTQIA+ individuals, and people in regional and remote areas.

4. How We Will Engage

We will provide a safe, non-judgmental, and trauma-informed experience to every consumer who discloses they are or may be experiencing domestic, family and sexual violence.

We will accept a consumer's statement that they are or may be experiencing domestic, family or sexual violence and will not require them to disclose the details of their circumstances or provide any evidence or supporting material to demonstrate they are an affected person, unless this is necessary to protect them or we are required by law to do so.

We will offer and provide warm transfers when assisting an affected person.

We will never require a person affected by domestic, family or sexual violence to contact or engage with the perpetrator, alleged perpetrator or their authorised representative.

5. Ensuring Safety and Providing Support

5.1 Ensure Safety

Where we identify (either directly or indirectly) that a consumer is or may be a person affected by domestic, family or sexual violence, we will immediately ask the affected person to confirm that it is safe for them to communicate with us.

5.2 Advise of Available Supports

If an affected person confirms that it is safe for us to communicate with them, we will:

• Advise them that:
  • The Company is able to assist them in accordance with our Domestic, Family and Sexual Violence Policy
  • We have a team member who provides tailored assistance to people who are or may be experiencing domestic and family violence
  • They can request a warm transfer to that team member
  • There are specialist support organisations listed in our Domestic and Family Violence Statement on our website that can assist them, and advise them exactly where they can find the Statement
• Ask them if they would like to access further information and support from us

5.3 Establish Agreed Communication Method

If the affected person indicates they would like to access more information and support, we will:

• Advise them what communication methods are offered by the Company
• Ask them what their preferred communication method is and whether they have a preferred time of day for being contacted via that communication method

We will only communicate with the affected person via their agreed communication method on matters relating to domestic and family violence, unless:

• They request a different communication method or time for communication, which will become the new agreed communication method
• They initiate contact with us via a different communication method and confirm that we can use that different method for the purpose of that communication
• We are required by law to communicate with them via a different communication method, in which case we will provide two options for communication

5.4 Discuss and Provide Support Options

Clarifying account ownership and access

Before discussing support options, we will identify if the affected person is the customer (contract holder) or end user of our products or services.

If the affected person is the customer, we will advise them:

• If there is an authorised person on the account, what the authorised person can access on their account, and that they can keep, change or remove the authorised representative
• How they can make changes to their account and update personal information

Responding to safety concerns

We will ask the affected person if they have any concerns about their account (if applicable) or their privacy, safety and security in relation to our products or services.

If the affected person has such concerns, we will discuss available options to protect their privacy, safety and security and seek their instructions as to which options they would like to adopt. We will act promptly in accordance with those instructions until the affected person provides any updated instructions.

As a minimum, we will offer the following options and implement them, should the affected person wish to do so:

• Setting up a new account that is not linked to the perpetrator
• Adding privacy, safety and security protections to the affected person's account, such as a PIN, password or sending of a verification code to a safe number or email address provided by the affected person or within a mobile application

Providing information and support

Where an affected person has sought our assistance, we will keep them informed about the matter via the agreed communication channel, if any.

Where an affected person has expressed concerns about their safety, to the extent allowed by law, we will:

• Prioritise taking action to assist them with any needs they may have in relation to our products or services
• Not restrict, suspend or disconnect their service for 30 days (or any agreed longer period) unless they ask us to do so
• Urgently reverse any restriction, suspension or disconnection that has already been implemented or, if this is not practical, offer them an equivalent product or service

5.5 Delaying Credit Management Action

Where an affected person has sought our assistance in the previous 60 days, we will not take any credit management action against them before:

• Considering the potential impact on them of such action
• Considering whether any other person may have contributed to the debt on their account
• Reviewing their records to ensure we have undertaken any agreed actions on their account

Our Payment Assistance Policy provides further details on credit management action.

5.6 Inclusive Design and Intersectional Approach

We will apply inclusive, safety-by-design principles when developing our systems, products and communication channels to ensure they are accessible and safe for all consumers, regardless of ability, language, culture or circumstance. We will do this by testing our systems and consumer interfaces, providing plain-language communications, multiple contact channels, and accessibility features including screen-reader compatibility.

When we develop or update our systems, products and services, we will assess whether a design element would increase the risk of technology-facilitated abuse or unauthorised access and take steps to mitigate those risks. To the extent practicable, we will incorporate design improvements based on any feedback received from affected persons that would strengthen safety, privacy and secure connection to telecommunications services.

Our domestic and family violence support framework recognises that experiences of violence may vary based on gender, age, disability, cultural background, sexual orientation, or socio-economic factors. We will adopt an intersectional approach in service design and staff training to address these different needs.

6. Privacy and Record Keeping

We will only access personal and sensitive information for legitimate account management purposes.

We will protect the privacy and safety of affected persons by suppressing sensitive information from bills, statements and account records where possible, and comply with requests by an affected person as to how their bills are received.

We will not disclose information identifying an affected person without their consent or unless legally required to do so. This includes an affected person's contact details (such as phone number, email or address) and financial details (such as billing or account history).

We will only store information and records necessary to provide support to the affected person and where we are legally required to do so. We will securely store this information to protect it from misuse, interference and loss, unauthorised access, modification or disclosure.

If the affected person's personal information is accessed or shared without permission, we will notify the affected person, using the agreed communication method, as soon as practicable and take steps to reduce the risk until the notification can occur. This includes circumstances caused by human error, malicious intent or cyber-attacks. We will explain the information that has been breached, advise the support available and offer referral to a national or state-based support service for safety planning. We will take any necessary additional steps to change account settings, suppress information or take protective action. We will notify ACMA within two days of becoming aware of the breach.

We will retain records for the period required by the Standard, or law, and ensure information is safely disposed of and destroyed when it is no longer needed.

We will manage consumer complaints in accordance with our Complaints Handling Process. All complaints where the affected person indicates a threat to their safety or their children's safety require an urgent response and must be resolved within two working days.

7. Support of Our Personnel

We take the safety and wellbeing of our staff seriously. We recognise the sensitive nature of supporting people who are or may be experiencing domestic, family or sexual violence.

All staff will receive training on domestic and family violence upon joining the Company and prior to interacting with consumers so they feel confident and empowered to assist affected persons. Our consumer-facing staff will receive specialised training on recognising, responding to and referring affected persons. Refresher training will be offered annually.

We will establish clear escalation pathways for when an affected person has more complex circumstances, to ensure staff do not feel alone and solely responsible for supporting an affected person.

We provide the following support to staff:

• Managerial supervision and direct support
• Internal wellbeing and debriefing support after sensitive interactions
• Peer support

8. Monitoring and Review

We monitor implementation and compliance with this Policy and its related Procedures, and seek opportunities for improvement to best uphold the safety, privacy and access of affected persons to telecommunications services.

We will review this Policy at least annually, or sooner if:

• There are changes to the Standard or other relevant legislation or regulation
• A significant domestic, family and sexual violence related incident occurs that highlights a deficiency in this Policy
• Feedback or a complaint is received from an affected person, consumers, staff or a domestic, family and sexual violence support service raising safety concerns or systemic issues suggesting the Policy requires updating
• An internal audit identifies deficiencies or unintended harms
• Compliance action by the ACMA or other regulators, especially where there is evidence of impact on a person affected by domestic, family and sexual violence or broader consumer groups

We will consult with DFSV support organisations during the review process, consistent with the approach taken for policy development.

9. Responsibilities

10. Consultation

Before this Policy was finalised, the Company consulted with Gladstone Women's Health and Good Shepherd Australia New Zealand, via representatives of the Internet Association of Australia and WISPAU who engaged Gladstone Women's Health and Good Shepherd on behalf of their members. The outcomes of that consultation have been incorporated into this Policy and supporting Procedures.

11. Related Documents

• Domestic, Family and Sexual Violence Website Statement
• Domestic, Family and Sexual Violence Procedures
• Privacy Policy
• Complaints Handling Process
• Payment Assistance Policy