Partnering with the Code Administrator: Why Collaboration Matters

The Code Manager plays an important complementary role to the Code Administrator by supporting member clubs to understand their obligations under the Code, promoting education and guidance and assisting with the consistent and effective operation of the Code framework.

The Code is designed to support member clubs in managing complaints in a fair, transparent and effective manner.

An important element of this framework is effective engagement between member clubs and the Code Administrator, whose functions include receiving complaints, facilitating information gathering and supporting the consistent administration of the Code.

This engagement is supported by the Code Manager, who provides education, guidance and support to member clubs to assist with understanding and meeting their obligations under the Code.

Recent action items from the Code Authority have again highlighted the value of early, open and cooperative engagement with the Code Administrator as part of good governance practice.

How effective engagement supports good governance

Clear, timely and complete communication with the Code Administrator is an important factor in the effective operation of the Code.

Effective engagement with the Code Administrator can assist member clubs to:

• progress complaints efficiently and within appropriate timeframes
• reduce the risk of complaints escalating due to delay or incomplete information
• ensure decisions are based on accurate and sufficient material
• avoid procedural complications arising from late, partial or absent responses
• enable a complete and balanced understanding of the relevant facts and context
• support procedural fairness by ensuring all relevant material is available for consideration
• reduce the risk of misunderstandings arising from incomplete or one-sided‑ information
• assist the Code Authority to make determinations based on a full evidentiary record
• reduce the need for repeated information requests and follow-up‑ correspondence
• support proportionate handling of complaints, consistent with the nature and seriousness of the issues raised
• assist in resolving matters without unnecessary escalation or review
• support the efficient use of Code Authority and member club resources
• support the preparation of accurate, de‑identified reporting obligations under the Code

In practice, delays in responding, failure to respond, or the provision of incomplete information can significantly affect the timely and fair handling of complaints. These issues may limit the Code Administrator’s ability to properly assess matters, increase the risk of escalation, and place pressure on procedural timeframes contemplated by the Code.

Where relevant information is not provided, or is provided late or in incomplete form, determinations may need to be made on the basis of the material available, which may not fully reflect the club’s position.

Effective engagement supports the Code’s objectives by promoting consistency, transparency and procedural fairness in the handling of complaints.

Practical ways member clubs can engage effectively

Member clubs can support effective outcomes under the Code by:

• engaging with the Code Manager for guidance and education on Code obligations and governance practices, where appropriate
• responding within reasonable timeframes to requests for information from the Code Administrator and engaging with the Code Manager for guidance where appropriate
• advising the Code Administrator or Code Manager where additional time is genuinely required to respond
• ensuring information and documents provided are accurate, complete and relevant to enable proper assessment
• clearly outlining the internal steps taken to address a matter before it is referred under the Code
• seeking early guidance from ClubsNSW where a matter appears complex or at risk of escalation

These steps assist the Code Administrator to understand the context of a complaint and to progress matters efficiently and fairly.

Engagement as a governance principle

Engagement with the Code Administrator is not merely a procedural obligation. It reflects a member club’s broader commitment to accountable, transparent and well-governed decision-making.

When member clubs and the Code Administrator engage effectively:

• recurring or systemic issues can be identified at an earlier stage
• emerging patterns may inform broader education and guidance
• the expectations of club members can be better understood
• confidence in the integrity and credibility of the Code process is supported
• systemic or recurring governance issues across the industry can be identified
• consistent governance standards across member clubs are promoted
• the likelihood of matters being revisited through review or external escalation is reduced
• governance practices across the industry can be applied more consistently

Strong working relationships help ensure the Code continues to operate as a constructive, educational and supportive framework for all ClubsNSW member clubs.