Policies

The International College of Celebrancy has policies on the following topics:

• Anti-Discrimination : Relationships with Others
• Refund Policy
• Grievance Policy and Procedure
• Promotion and Privacy
• Statement on Incomplete Payments and Course Materials
• RPL: Recognition of Prior Learning – Payments and Procedure
• Australian Consumer Law (2011) (subsuming the Trade Practices Act 1974)
  Top

1. Policy on Anti-Discrimination : Relationships with Others.

International College of Celebrancy actively supports the principle of equal employment opportunity regardless of race, religion, national origin, sex, age marital status, etc and expects it employees and students to practice and support this principle. International College of Celebrancy policy is to avoid discriminatory practices of any kind and to make staffing and student selection decisions on the basis of individual ability, performance, experience and company requirements.

International College of Celebrancy believes that every individual has the right to dignity and respect. Therefore any personal/sexual harassment is regarded by as totally unacceptable, regardless of the perpetrator. International College of Celebrancy is a Distance Education Course but is committed to maintaining the health and safety of its employees and students when they are at seminars and conferences.

Compliance with Occupational health and Safety laws and company policies is expected by all staff and students at all time. International College of Celebrancy and its Students Customer service is paramount at International College of Celebrancy. If the company is to retain and attract students, we must offer quality products and services that our students perceive are priced fairly to provide value and our staff and trainers must be seen to be competent and honest. In this regard, International College of Celebrancy requires all its staff to be likewise committed to the company’s Code of Conduct and policies.

2. Refund Policy From March 1, 2003. Revised September 2005.

If the International College of Celebrancy cancels or postpones a Distance Education course for any reason we will refund all monies paid for that course unless we can make alternative course arrangements acceptable to the student.

Once a student pays the Registration fee and the fee for one or more modules, and has received the Distance Education course materials they are deemed to have started the course and so no refund is payable. If a student pays the course registration and fees for more than one module and then wishes to cease the study within the ten weeks allowed for each module, the College will not refund the fees for the first module but will refund the amount for all other accredited modules paid for less $100 per module administration fees.

Unless the course materials are returned in good order and condition an additional $80 per unit will be withheld. Temporary suspensions of study may be given on application to the Dean of Studies which will preserve the right to a refund. Conditions on any special offer will be considered as an overriding policy for that offer only.

A student may opt not to receive the materials for modules other than the Module 1 until they have finished the preceding module. In this case a refund for the modules for which training materials have not yet been received (less $100 administration) will be given on notice of cessation of the course.

The time allowed for each Module is 10 weeks. No refund will be given if a student withdraws after the 10 weeks allowed for the Module has commenced unless they have taken advantage of the two exceptions stated above. After 6 months no refund will be given, no continuance is available. The student will be deemed to have retired from the course. To continue the student must pay for the Module and start again. Having said this the College states clearly that it wants students to start and finsih every Module they pay for and the College is committed to giving them every assistance.

The refund will be given to the student within 4 weeks of the notification by the student.

There is no refund for $100 module holding fee on pre-March 2003 prices.

Cheque Payments – Allow 3 working days for clearance of any cheque. Should a cheque be dishonoured there will be a charge of $20 + any bank fees payable.

3. Grievance Policy and Procedure (Complaints)

All prospective students are hereby provided with a copy of the Grievance Policy and Procedure document .

All disputes or grievances will be handled professionally and confidentially in order to achieve a resolution. All parties will have a clear understanding of the steps involved in the grievance procedure. Students will be provided with details of external authorities they may approach, if required.

All grievances will be managed fairly and equitably and as efficiently as possible. International College of Celebrancy will resolve any grievances fairly and equitably within five (5) working days. Students may raise any matters of concern relating to training delivery and assessment, the quality of the teaching, student amenities, discrimination, sexual harassment and other issues which may arise.

The policy provides an avenue for most grievances. In some cases alternative measures may be needed. The International College of Celebrancy will encourage the parties to approach a grievance with an open view and to attempt to resolve problems through discussion and conciliation. Where a grievance cannot be resolved through discussion and conciliation, we acknowledge the need for an appropriate external and independent agent to mediate between the parties. Any substantial complaint will be acted on expeditiously.

Grievance Procedure: The grievance procedures relating to the delivery of training and/or the assessment involves the student initiating the following:
Discussion with relevant consultant /teacher/trainer about the grievance. If it is unable to be resolved, the grievance can be taken before the Principal.
If the grievance is still unresolved, it may be referred in writing to the Grievance Committee made up of three of the Board of Advisors of The International College of Celebrancy.
If the grievance cannot be resolved internally, the College will advise the student of the appropriate body where he/she can seek further assistance.

4. Promotion and Privacy

The International College of Celebrancy is wholly owned by Dally Messenger III who also owns the Celebrants Centre based in Victoria, Australia. One of the objects of the College and of the Centre is to publicise their students and clients as broadly as possible. We make normal contact details available to anyone who wants them as a means of promotion. Obviously private details such as Credit Card numbers are kept on a password protected Database, controlled by select staff, and are passed on to no one under any circumstances without the client’s permission. We only hold that information which clients and students have provided us on application forms. That information can be recalled or changed on request.

5. Statement on Incomplete Payment and Course Materials.

1. In cases where ICC course materials have been sent on the basis of a deposit, College staff are not expected to provide further services relating to a module until the payment for that module has been completed.

2. In no circumstances will any documents such as Diplomas or Statements of Attainment be issued until all fees have been paid.

3. If the cost of the Module has increased between the issue of the Module and completion of payment, the student has a three-month period of grace before the additional cost is added to what is owed. Having made that extra payment, they would be entitled to whatever upgraded materials have been added in the meantime.

4. Where a major updates of materials occur, students can expect a free upgrade electronically if they enrolled within the previous 6 months. If they return to the course later than this they will be expected to pay for updated materials at the discretion of the Registrar.

6. RPL – Recognition of Prior Learning – Payments and Procedure

It is presumed, unless agreed otherwise in writing, that the cost of Recognition of Prior Learning is the same as the cost of the course, or section of the course. The procedures and bureacratic requirements of the VET and similar educational systems usually require more work and exactness for the educationist than if the student had simply completed the work required without claiming RPL. We often recommend this as excellent revision. Care is demanded by the system because applicants for RPL frequently exaggerate and embellish their prior learning.

---

7. Australian Consumer Law 2011 – Trade Practices Act 1974
COMPLIANCE PROGRAM – TRADE PRACTICES ACT 1974 (now subsumed by subsequent legisltation but the general provisions are the same)

1.. PURPOSE OF THIS PROGRAM:

This policy document is intended to comply with an order made in the Federal Court to establish an effective education, training and trade practices compliance program [the Program] for employees or other persons involved in the International College of Celebrancy -registered business name [the College]. It includes training and educating persons who wish to become civil celebrants, including but not limited to funeral celebrants.

This program is designed:-

To instill an awareness of the prohibitions contained the Code contained in Part IV of The Trade Practices Act 1974, including Sections 45 and 45A, in relation to contravening conduct in proceedings against the company or any similar or related conduct, and
Subject to the Compliance Program being tailored to the company’s circumstances, to be consistent with the Australian Standard on Compliance Program AS3806.

2. OUR COMMITMENT

The Company will conduct its business ethically and so that it complies with the letter and spirit of its obligations under law and in particular part IV of the Trade Practices Act 1974.

The company will create and maintain a workplace and service culture that is ethical; that celebrates diversity and is free from unacceptable and unlawful behaviours, and which maximises its performance through all of its decisions and practices, and those of its office holders, employees and insofar as it is able to do so, those who are trained by the College and who are associated with the company through with the practice of civil celebrancy.

This program and these values and functions were endorsed by the company’s officeholders on the 9th November 2007.

3. COMPLIANCE POLICY

The company requires its employees, contractors and customers to comply with laws that prohibit restrictive trade practices.

The responsibility for preventing and eliminating such unlawful behaviour lies with every member of the company, its officeholders, employees, graduates and trainees and those associated with the company.

Price fixing in particular is unlawful and is prohibited. Price fixing is an arrangement between people in competition with each other which has the purpose or effect of controlling, fixing or maintaining the price of goods or services bought or sold by them. The company has always objected to such practices in the funeral industry in particular.

Any agreement between a business and one or more competitors to fix prices is illegal under the Trade Practices Act, no matter how or whether it is recorded, provided that its effect is that competitors work out their prices collectively rather than individually, whether or not it actually has any effect on competition in a market.

For that reason the company, the centre and its associates will not be a party to or encourage any fixed price arrangement for celebrancy services other than is required or permitted by law.

In particular the company requires and encourages its graduates, students, associates and supporters and all civil celebrants to negotiate their own price for their services with each and every client, based on a reasonable hourly rate for the services tailored to the particular client and freely agreed to by the parties, having regard to the actual time required.

The principles set out in this policy and procedures are intended to apply to any work-related context including conferences, work functions and business activities in and on facilities owned and managed by third parties.

The company will through its compliance advisor assess the risk and take preventive steps to eradicate potential factors increasing any likelihood of breach of this policy.

Action taken to remedy any complaint of breach of this policy if substantiated may include apology, counselling, and any other form of action deemed appropriate and consistent with the company’s values and code of conduct.

Adequate resources will be made available to ensure that this policy is put into full effect.

4. RESPONSIBILITY

It is the responsibility of the Director of the company to ensure that the company complies with applicable laws, regulations, codes and organisational standards, and that its workplace is committed to the rights and entitlements of all employees and associates to work and perform their functions without fear of unacceptable or unlawful behaviour.

It is employees’ and associates’ responsibility to ensure that they understand and are committed to respect the rights and responsibilities of all employees and associates to perform their functions without fear of unacceptable or unlawful behaviour in any form; they provide an environment which discourages such behaviour, and immediately report any offensive action.

5. IMPLEMENTATION

This policy needs to be understood and acted on by those who work for the company, whether internally or externally.

The company intends to develop a culture in which behaviours that create and support compliance with this policy flourish.

All reasonable steps to eliminate behaviours prohibited by the Policy will be taken and all employees will be regularly made aware of their obligations in the following respects:

PUBLICATION: This policy will be published to all employees and made available to those engaged in business with the company, as set out below.

WEBSITE: The company’s website will refer to this policy, and to the fact that
TRAINING: The company has established a trade practices training program (as set out below) for its employees and any civil celebrant
MONITORING: The company will monitor the activities of its employees and graduates insofar as possible to ensure the Act is not breached
VETTING: The company will ensure that its legal documentation and promotional materials are not misleading or deceptive and that its contracts are vetted by an appropriately qualified person with trade practices expertise to ensure that they are not capable of amounting to anti competitive conduct or a restricted trade practice
BREACH: The Company will take immediate and appropriate corrective action if the company becomes aware of any breach of this policy.
6. TRAINING PROGRAM

The Company will provide to all employees and students on at least an annual basis a short training course based on the ACCC’s Best and Fairest Training Package, which will enable each participant to identify practices that are prohibited under the Trade Practices Act; identify examples of such conduct, and the obligations and responsibilities of persons who are engaged in such activities or become aware of them, as follows:

Office holders: forthwith (9th November 2007)

Employees: prior to 28 February 2008

and thereafter from year to year, in each year, by way of a refresher. The course will also be made available to students of the College and civil celebrants upon demand.

7. ACCOUNTABILITY/ MONITORING AND MEASURING/ CONTINUAL IMPROVEMENT

The company has appointed an independent organisation, Moira Rayner & Associates, as its compliance advisor, to monitor the development and implementation and continuing improvement of this compliance program, reporting directly to the Managing Director and principal officeholder of the company.

Adequate written records will be kept of the company’s compliance with this policy to ensure that compliance endeavours can be substantiated in the event of a breach by the company or its officers or employees.

At least once a year the compliance advisor will review the company’s records and interview staff and peruse the college’s training program to critically evaluate the values and culture of the organisation with respect to compliance with this policy, and shall report to the Managing Director.

The Managing Director will receive the compliance adviser’s annual report on the implementation of this program, and meet the company’s reporting obligations to the ACCC, on or before the 10th November in each of 2008, 2009 and 2010. The receipt and adoption of this Policy on the 9th November 2007 shall be deemed to be the first report of the compliant adviser.

The company will set benchmarks and continually improve its effectiveness and the operation of this policy having regard to the Principles and Activities of the Australian Business Excellence Framework.

8. SUSPECTED/REPORTED BREACH/COMPLAINT

In the event that a breach or potential breach of this policy should be suspected, the person identifying this issue should take firm, positive and prompt action.

The first action should be to notify the Managing Director of the suspected breach. The Managing Director may refer the matter for investigation to the compliance adviser.

In the event that a notification to the Managing Director is not ap

The compliance adviser will ascertain the facts and make a recommendation to the company on the appropriate response.

9. RECORD-KEEPING

Records are to be kept and filed in a confidential and secure place and retained for a period of five years.

The compliance advisor will incorporate in the annual report to the Managing Director on the complaints and concerns under this part of the policy, including any matters which the organization is required to notify to any regulatory authority, and make recommendations for corrective or ameliorative or improving

The compliance advisor will assist the managing director of the company to report annually to the company on its compliance program and meeting its legal obligations under the order of the Federal Court of Australia and pursuant to the Trade Practices Act

REVIEW

This Policy and program will be reviewed by the company at least once in each year and may be modified to meet changes in the obligations of the company under the Trade Practices Act and any other legislation affecting its responsibilities under the law, at any time.

Adopted by and signed on behalf of the company

Dally M Publishing and Research

2024: changes As the former company referred to in this document now belongs to a sole proprietor the policies refer to only his decision as an individual business – mutatis mutandis

Policies

The International College of Celebrancy has policies on the following topics:

• Anti-Discrimination : Relationships with Others
• Refund Policy
• Grievance Policy and Procedure
• Promotion and Privacy
• Statement on Incomplete Payments and Course Materials
• RPL – Recognition of Prior Learning – Payments and Procedure
• Australian Consumer Law (2011) (subsuming the Trade Practices Act 1974)
  Top

1. Policy on Anti-Discrimination : Relationships with Others.

International College of Celebrancy actively supports the principle of equal employment opportunity regardless of race, religion, national origin, sex, age marital status, etc and expects it employees and students to practice and support this principle. International College of Celebrancy policy is to avoid discriminatory practices of any kind and to make staffing and student selection decisions on the basis of individual ability, performance, experience and company requirements.

International College of Celebrancy believes that every individual has the right to dignity and respect. Therefore any personal/sexual harassment is regarded by as totally unacceptable, regardless of the perpetrator. International College of Celebrancy is a Distance Education Course but is committed to maintaining the health and safety of its employees and students when they are at seminars and conferences.

Compliance with Occupational health and Safety laws and company policies is expected by all staff and students at all time. International College of Celebrancy and its Students Customer service is paramount at International College of Celebrancy. If the company is to retain and attract students, we must offer quality products and services that our students perceive are priced fairly to provide value and our staff and trainers must be seen to be competent and honest. In this regard, International College of Celebrancy requires all its staff to be likewise committed to the company’s Code of Conduct and policies.

2. Refund Policy From March 1, 2003. Revised September 2005.

If the International College of Celebrancy cancels or postpones a Distance Education course for any reason we will refund all monies paid for that course unless we can make alternative course arrangements acceptable to the student.

Once a student pays the Registration fee and the fee for one or more modules, and has received the Distance Education course materials they are deemed to have started the course and so no refund is payable. If a student pays the course registration and fees for more than one module and then wishes to cease the study within the ten weeks allowed for each module, the College will not refund the fees for the first module but will refund the amount for all other accredited modules paid for less $100 per module administration fees.

Unless the course materials are returned in good order and condition an additional $80 per unit will be withheld. Temporary suspensions of study may be given on application to the Dean of Studies which will preserve the right to a refund. Conditions on any special offer will be considered as an overriding policy for that offer only.

A student may opt not to receive the materials for modules other than the Module 1 until they have finished the preceding module. In this case a refund for the modules for which training materials have not yet been received (less $100 administration) will be given on notice of cessation of the course.

The time allowed for each Module is 10 weeks. No refund will be given if a student withdraws after the 10 weeks allowed for the Module has commenced unless they have taken advantage of the two exceptions stated above. After 6 months no refund will be given, no continuance is available. The student will be deemed to have retired from the course. To continue the student must pay for the Module and start again. Having said this the College states clearly that it wants students to start and finsih every Module they pay for and the College is committed to giving them every assistance.

The refund will be given to the student within 4 weeks of the notification by the student.

There is no refund for $100 module holding fee on pre-March 2003 prices.

Cheque Payments – Allow 3 working days for clearance of any cheque. Should a cheque be dishonoured there will be a charge of $20 + any bank fees payable.

3. Grievance Policy and Procedure (Complaints)

All prospective students are hereby provided with a copy of the Grievance Policy and Procedure document .

All disputes or grievances will be handled professionally and confidentially in order to achieve a resolution. All parties will have a clear understanding of the steps involved in the grievance procedure. Students will be provided with details of external authorities they may approach, if required.

All grievances will be managed fairly and equitably and as efficiently as possible. International College of Celebrancy will resolve any grievances fairly and equitably within five (5) working days. Students may raise any matters of concern relating to training delivery and assessment, the quality of the teaching, student amenities, discrimination, sexual harassment and other issues which may arise.

The policy provides an avenue for most grievances. In some cases alternative measures may be needed. The International College of Celebrancy will encourage the parties to approach a grievance with an open view and to attempt to resolve problems through discussion and conciliation. Where a grievance cannot be resolved through discussion and conciliation, we acknowledge the need for an appropriate external and independent agent to mediate between the parties. Any substantial complaint will be acted on expeditiously.

Grievance Procedure: The grievance procedures relating to the delivery of training and/or the assessment involves the student initiating the following:
Discussion with relevant consultant /teacher/trainer about the grievance. If it is unable to be resolved, the grievance can be taken before the Principal.
If the grievance is still unresolved, it may be referred in writing to the Grievance Committee made up of three of the Board of Advisors of The International College of Celebrancy.
If the grievance cannot be resolved internally, the College will advise the student of the appropriate body where he/she can seek further assistance.

4. Promotion and Privacy

The International College of Celebrancy is wholly owned by Dally Messenger III who also owns the Celebrants Centre based in Victoria, Australia. One of the objects of the College and of the Centre is to publicise their students and clients as broadly as possible. We make normal contact details available to anyone who wants them as a means of promotion. Obviously private details such as Credit Card numbers are kept on a password protected Database, controlled by select staff, and are passed on to no one under any circumstances without the client’s permission. We only hold that information which clients and students have provided us on application forms. That information can be recalled or changed on request.

5. Statement on Incomplete Payment and Course Materials.

1. In cases where ICC course materials have been sent on the basis of a deposit, College staff are not expected to provide further services relating to a module until the payment for that module has been completed.

2. In no circumstances will any documents such as Diplomas or Statements of Attainment be issued until all fees have been paid.

3. If the cost of the Module has increased between the issue of the Module and completion of payment, the student has a three-month period of grace before the additional cost is added to what is owed. Having made that extra payment, they would be entitled to whatever upgraded materials have been added in the meantime.

4. Where a major updates of materials occur, students can expect a free upgrade electronically if they enrolled within the previous 6 months. If they return to the course later than this they will be expected to pay for updated materials at the discretion of the Registrar.

6. RPL – Recognition of Prior Learning – Payments and Procedure

It is presumed, unless agreed otherwise in writing, that the cost of Recognition of Prior Learning is the same as the cost of the course, or section of the course. The procedures and bureacratic requirements of the VET and similar educational systems usually require more work and exactness for the educationist than if the student had simply completed the work required without claiming RPL. We often recommend this as excellent revision. Care is demanded by the system because applicants for RPL frequently exaggerate and embellish their prior learning.

---

7. Australian Consumer Law 2011 – Trade Practices Act 1974
COMPLIANCE PROGRAM – TRADE PRACTICES ACT 1974 (now subsumed by subsequent legislation but the general provisions are the same)

1.. PURPOSE OF THIS PROGRAM:

This policy document is intended to comply with an order made in the Federal Court to establish an effective education, training and trade practices compliance program [the Program] for employees or other persons involved in the International College of Celebrancy -registered business name [the College]. It includes training and educating persons who wish to become civil celebrants, including but not limited to funeral celebrants.

This program is designed:-

To instill an awareness of the prohibitions contained the Code contained in Part IV of The Trade Practices Act 1974, including Sections 45 and 45A, in relation to contravening conduct in proceedings against the company or any similar or related conduct, and
Subject to the Compliance Program being tailored to the company’s circumstances, to be consistent with the Australian Standard on Compliance Program AS3806.

2. OUR COMMITMENT

The Company will conduct its business ethically and so that it complies with the letter and spirit of its obligations under law and in particular part IV of the Trade Practices Act 1974.

The company will create and maintain a workplace and service culture that is ethical; that celebrates diversity and is free from unacceptable and unlawful behaviours, and which maximises its performance through all of its decisions and practices, and those of its office holders, employees and insofar as it is able to do so, those who are trained by the College and who are associated with the company through with the practice of civil celebrancy.

This program and these values and functions were endorsed by the company’s officeholders on the 9th November 2007.

3. COMPLIANCE POLICY

The company requires its employees, contractors and customers to comply with laws that prohibit restrictive trade practices.

The responsibility for preventing and eliminating such unlawful behaviour lies with every member of the company, its officeholders, employees, graduates and trainees and those associated with the company.

Price fixing in particular is unlawful and is prohibited. Price fixing is an arrangement between people in competition with each other which has the purpose or effect of controlling, fixing or maintaining the price of goods or services bought or sold by them. The company has always objected to such practices in the funeral industry in particular.

Any agreement between a business and one or more competitors to fix prices is illegal under the Trade Practices Act, no matter how or whether it is recorded, provided that its effect is that competitors work out their prices collectively rather than individually, whether or not it actually has any effect on competition in a market.

For that reason the company, the centre and its associates will not be a party to or encourage any fixed price arrangement for celebrancy services other than is required or permitted by law.

In particular the company requires and encourages its graduates, students, associates and supporters and all civil celebrants to negotiate their own price for their services with each and every client, based on a reasonable hourly rate for the services tailored to the particular client and freely agreed to by the parties, having regard to the actual time required.

The principles set out in this policy and procedures are intended to apply to any work-related context including conferences, work functions and business activities in and on facilities owned and managed by third parties.

The company will through its compliance advisor assess the risk and take preventive steps to eradicate potential factors increasing any likelihood of breach of this policy.

Action taken to remedy any complaint of breach of this policy if substantiated may include apology, counselling, and any other form of action deemed appropriate and consistent with the company’s values and code of conduct.

Adequate resources will be made available to ensure that this policy is put into full effect.

4. RESPONSIBILITY

It is the responsibility of the Director of the company to ensure that the company complies with applicable laws, regulations, codes and organisational standards, and that its workplace is committed to the rights and entitlements of all employees and associates to work and perform their functions without fear of unacceptable or unlawful behaviour.

It is employees’ and associates’ responsibility to ensure that they understand and are committed to respect the rights and responsibilities of all employees and associates to perform their functions without fear of unacceptable or unlawful behaviour in any form; they provide an environment which discourages such behaviour, and immediately report any offensive action.

5. IMPLEMENTATION

This policy needs to be understood and acted on by those who work for the company, whether internally or externally.

The company intends to develop a culture in which behaviours that create and support compliance with this policy flourish.

All reasonable steps to eliminate behaviours prohibited by the Policy will be taken and all employees will be regularly made aware of their obligations in the following respects:

PUBLICATION: This policy will be published to all employees and made available to those engaged in business with the company, as set out below.

WEBSITE: The company’s website will refer to this policy, and to the fact that
TRAINING: The company has established a trade practices training program (as set out below) for its employees and any civil celebrant
MONITORING: The company will monitor the activities of its employees and graduates insofar as possible to ensure the Act is not breached
VETTING: The company will ensure that its legal documentation and promotional materials are not misleading or deceptive and that its contracts are vetted by an appropriately qualified person with trade practices expertise to ensure that they are not capable of amounting to anti competitive conduct or a restricted trade practice
BREACH: The Company will take immediate and appropriate corrective action if the company becomes aware of any breach of this policy.
6. TRAINING PROGRAM

The Company will provide to all employees and students on at least an annual basis a short training course based on the ACCC’s Best and Fairest Training Package, which will enable each participant to identify practices that are prohibited under the Trade Practices Act; identify examples of such conduct, and the obligations and responsibilities of persons who are engaged in such activities or become aware of them, as follows:

Office holders: forthwith (9th November 2007)

Employees: prior to 28 February 2008

and thereafter from year to year, in each year, by way of a refresher. The course will also be made available to students of the College and civil celebrants upon demand.

7. ACCOUNTABILITY/ MONITORING AND MEASURING/ CONTINUAL IMPROVEMENT

The company has appointed an independent organisation, Moira Rayner & Associates, as its compliance advisor, to monitor the development and implementation and continuing improvement of this compliance program, reporting directly to the Managing Director and principal officeholder of the company.

Adequate written records will be kept of the company’s compliance with this policy to ensure that compliance endeavours can be substantiated in the event of a breach by the company or its officers or employees.

At least once a year the compliance advisor will review the company’s records and interview staff and peruse the college’s training program to critically evaluate the values and culture of the organisation with respect to compliance with this policy, and shall report to the Managing Director.

The Managing Director will receive the compliance adviser’s annual report on the implementation of this program, and meet the company’s reporting obligations to the ACCC, on or before the 10th November in each of 2008, 2009 and 2010. The receipt and adoption of this Policy on the 9th November 2007 shall be deemed to be the first report of the compliant adviser.

The company will set benchmarks and continually improve its effectiveness and the operation of this policy having regard to the Principles and Activities of the Australian Business Excellence Framework.

8. SUSPECTED/REPORTED BREACH/COMPLAINT

In the event that a breach or potential breach of this policy should be suspected, the person identifying this issue should take firm, positive and prompt action.

The first action should be to notify the Managing Director of the suspected breach. The Managing Director may refer the matter for investigation to the compliance adviser.

In the event that a notification to the Managing Director is not ap

The compliance adviser will ascertain the facts and make a recommendation to the company on the appropriate response.

9. RECORD-KEEPING

Records are to be kept and filed in a confidential and secure place and retained for a period of five years.

The compliance advisor will incorporate in the annual report to the Managing Director on the complaints and concerns under this part of the policy, including any matters which the organization is required to notify to any regulatory authority, and make recommendations for corrective or ameliorative or improving

The compliance advisor will assist the managing director of the company to report annually to the company on its compliance program and meeting its legal obligations under the order of the Federal Court of Australia and pursuant to the Trade Practices Act

REVIEW

This Policy and program will be reviewed by the company at least once in each year and may be modified to meet changes in the obligations of the company under the Trade Practices Act and any other legislation affecting its responsibilities under the law, at any time.

Adopted by and signed on behalf of the proprietor

Dally M Publishing and Research

Trade Practices Act 1974