What is grooming and why are organisations grappling with this problem?  

Grooming is a deliberate and patterned process of behaviour in which an adult builds trust and emotional connection with a child, and often their family or community, for the purpose of facilitating sexual abuse. It typically occurs gradually over time and may involve a series of seemingly appropriate or positive interactions that, when viewed in isolation, appear non-threatening. Grooming can occur both in-person and online. 

A key challenge for organisations is that many grooming behaviours overlap with legitimate, supportive, and developmentally appropriate professional practice. Staff working with children are expected to build trust, provide care, and develop relational safety, precisely the same domains targeted by perpetrators. 

This creates a significant safeguarding tension: the same relational skills required for good practice can also be exploited for harmful purposes. 

To reconcile this tension, organisations need clear guidance on ways to identify grooming behaviours so that child-friendly programs can run effectively and staff feel safe and supported to work with one another. Such guidance cannot be so high level or independent of work context to render it of little practical use, nor can it be so prescriptive or punitive that staff are given no discretion to build safe and supportive relationships with children.  

Information about the risks of child sexual abuse occurring 

All children are vulnerable to child sexual abuse based on their developmental dependence  and power imbalance that occurs between them and adults.i However, vulnerability is not evenly distributed and certain children experience heightened risk of child abuse, including children who identify as Aboriginal and Torres Strait Islander, culturally and linguistically diverse, with a disability, LGBTQI+ and/or live in out of home care.ii This is an extension of the power dynamic that exists between children and adults.  

Contemporary safeguarding research suggests that the likelihood of child sexual abuse is increased through the interaction of multiple risk domains rather than a single causal factor. The Royal Commission into Institutional Responses to Child Sexual Abuse identified four key domains of risk: 

• Vulnerability risk – the characteristics of the child. 

• Situational risk – opportunities for adults to be alone with children or form close relationships). 

• Propensity risk – disproportionate clustering of adults with a propensity to abuse child  

• Institutional risk – characteristics of the institution that may make abuse more likely to occur and less likely to be identified and responded to effectively. iii 

Rather than being viewed as fixed “conditions,” these domains are best understood as interacting factors that elevate or reduce risk within organisational settings. 

The role of a Child Safeguarding Code of Conduct 

A Child Safeguarding Code of Conduct is a critical operational tool that translates safeguarding principles into clear, observable behavioural expectations for staff. 

Importantly, Codes of Conduct do not attempt to determine intent. Instead, they define acceptable and unacceptable behaviours and provide a structured framework for identifying, responding to, and escalating concerns based on observable practice. 

This helps resolve a key tension in child-facing organisations: staff must be able to build trusting, relational environments while also maintaining clear professional boundaries that reduce risk. 

Where breaches occur, Codes of Conduct support: 

• early intervention and supervision  

• behaviour correction and guidance  

• escalation to formal review processes where necessary  

• identification of behavioural patterns over time  

An effective Child Safeguarding Code of Conduct helps overcome this tension and provides guidance to personnel about expected standards of behaviour when working with or around children. It does not ask organisations to determine personnel’s intentions, but identifies and publicises a set of clear behaviours that all personnel must adhere to.iv Personnel who do not meet these behavioural expectations are then guided to improve their behaviour and/or depending on the number and severity of breaches may receive disciplinary action including dismissal. Moreover, reporting of such behaviours means that the organisation can identify patterns or an overview of behaviours by individuals that need to be addressed.  

Child Safeguarding Codes of Conducts go beyond providing high level advice and provide clear criteria that staff can meet. For example, they identify clear behaviours that may demonstrating grooming behaviours and actively mitigate against these, including personnel should not: 

• spend one-on-one time with children where there is no professional duty to do so. 

• transport children in their private vehicle. 

• ignore or disregard any concerns, suspicions or disclosures of child abuse or harm. 

• photograph children without their consent and where there is no professional duty to do so. 

• have unauthorised contact with children on social media or by phone.  

• engage in non-work activities such as babysitting or tutoring without management’s consent. 

• provide any gifts to children. 

• use sexual language or gestures toward children. 

• initiate unnecessary physical contact with children or do things of a personal nature that children can do for themselves such as changing clothes. 

• develop ‘special’ relationships with specific children or show favouritism through the provision of gifts or unnecessary or unsuitable attention. 

This list is neither exhaustive, nor universally applicable to all organisations based on their unique context. They are, however, a clear set of behaviours that staff can identify as appropriate, which provides them with clear guidance to report concerns.  

The best Child Safeguarding Codes of Conduct may begin with a clear set of behaviours taken from model guidance provided by various regulatory bodiesv and provide further guidance and/or case studies on how staff can navigate areas where there are inconsistencies or ambiguity in interpreting criteria. For example, school teachers may know not to spend one-on-one time with children but are also unable to leave them unsupervised due to their duty of care. This can pose a challenge during weekend or evening sports if a teacher is left with a child because their parents or carers have not collected them. In such circumstances, staff need guidance about how to navigate these situations, so they feel confident that they meet behavioural expectations and fulfill their duty to support children. Such guidance can be developed within organisations by teams with knowledge of the activities that are of higher risk, and could include protocols that are escalated.  

Based on differences between the type of organisation and other characteristics of the same type of organisation (e.g. location, funding, resources, staff experience, physical site, etc), behaviour expectations can also be implemented with staff collaboratively. While there may be a need for a clear set of general behavioural expectations such as those identified above, this list can be extended and/or reduced based on consultation with staff who know the environment and children well. In addition, there may be an important role for consultation to help staff understand the intent and rationale of the Code and its effective implementation. This can help empower staff to implement these behaviours to support children.  

Conclusion 

Grooming is a complex and often subtle process that can be difficult to identify in real time. Perpetrators frequently rely on ambiguity, gradual boundary testing, and the appearance of positive or supportive behaviour to avoid detection. 

This complexity means that safeguarding cannot rely on intuition or isolated incident reporting alone. Instead, effective protection of children requires a combination of: 

• clear behavioural expectations  

• structured Codes of Conduct  

• strong supervision and reflective practice  

• organisational awareness of risk domains  

The National Principles for Child Safe Organisations provide a foundational framework for safeguarding at a systems level. However, operational effectiveness depends on how these principles are translated into clear behavioural guidance and everyday decision-making tools for staff. 

Child Safeguarding Codes of Conduct therefore play a critical role in bridging the gap between high-level safeguarding principles and frontline practice, enabling staff to both build safe, supportive relationships and recognise early indicators of grooming-related behaviour patterns. 

References and further reading 

• Australian Childhood Foundation – Child Safeguarding Resources 
• Australian Institute of Family Studies – Child Abuse and Neglect Statistics 
• Australian Human Rights Commission – Children’s Rights 
• Child Family Community Australia (CFCA) – Information Exchange on Child Abuse Prevention 
• Commission for Children and Young People (Victoria) – Child Safe Standards 
• National Office for Child Safety – National Principles for Child Safe Organisations 
• Office of the Public Guardian (NSW) – Child Safe Organisations 
• Royal Commission into Institutional Responses to Child Sexual Abuse – Final Report 
• UNICEF – Child Safeguarding Toolkit for Business 
• United Nations Committee on the Rights of the Child – Guidelines on Violence against Children