AUSTRALIAN CHRISTIAN ARTS LTD (AChA) CHILD SAFE POLICY
(NSW Compliant)
Reviewed and adopted: 13 February 2026
PART A – FOUNDATION
1. PURPOSE AND APPLICATION
1.1 This Policy affirms Australian Christian Arts' commitment to child safety in accordance with the Children's Guardian Act 2019 (NSW) and the NSW Child Safe Standards.
1.2 AChA is committed to creating and maintaining a child-safe organisation in which the safety, welfare, and wellbeing of children and young people are paramount in all decisions and activities.
1.3 This Policy applies to:
  • (a) all AChA activities involving children and young people under 18 years of age;
  • (b) all concerts, rehearsals, workshops, youth programs, events, and online activities;
  • (c) all Board members, staff, volunteers, contractors, members, and teachers; and
  • (d) any guest artist or other person participating in an AChA Activity, unless a separate written agreement applies.
1.4 Child safety responsibilities apply regardless of employment status, remuneration, or tenure.
1.5 This Policy is made under and subject to the AChA Constitution. In the event of any inconsistency between this Policy and the Constitution, the Constitution prevails to the extent of the inconsistency.
1.6 This Policy should be read in conjunction with:
  • (a) the AChA Constitution;
  • (b) the Master Member Code of Conduct;
  • (c) the Talent Release, Performance Consent and Creative Works Policy;
  • (d) the Working With Children Policy / Background Screening Policy;
  • (e) the Privacy Policy; and
  • (f) any other Board-approved policy.
2. LEGISLATIVE FRAMEWORK
2.1 This Policy is developed and implemented in compliance with relevant Australian and New South Wales legislation, including but not limited to:
  • (a) Children's Guardian Act 2019 (NSW);
  • (b) Child Protection (Working with Children) Act 2012 (NSW);
  • (c) Child Protection (Offenders Registration) Act 2000 (NSW);
  • (d) Crimes Act 1900 (NSW) – relevant child abuse offences;
  • (e) National Principles for Child Safe Organisations; and
  • (f) United Nations Convention on the Rights of the Child.
2.2 AChA is committed to continuously reviewing and updating its practices to align with best practices in child safety and any amendments to applicable laws and standards.
2.3 This Policy also aligns with the NSW Child Safe Standards for Community Organisations, ensuring a holistic approach to safeguarding children and young people.
3. DEFINITIONS
3.1 For the purpose of this Policy, the following definitions apply:
  • (a) AChA: Australian Christian Arts Ltd.
  • (b) AChA Activity: Any program, event, service, or activity organised, managed, or sponsored by AChA, including but not limited to concerts, rehearsals, workshops, youth programs, and online engagements.
  • (c) Child/Children or Young Person/People: Any person under the age of 18 years.
  • (d) Child Abuse: Any act or omission that results in serious harm to a child, including physical abuse, sexual abuse, emotional abuse, neglect, and exposure to family violence.
  • (e) Child Safe Organisation: An organisation that actively promotes and implements practices that protect children and young people from abuse and neglect.
  • (f) Staff/Personnel: Includes all paid employees, volunteers, contractors, Board members, members, teachers, and any other person working for or on behalf of AChA.
  • (g) Parent/Guardian: A person who has parental responsibility for a child or young person.
  • (h) Working With Children Check (WWCC): A screening process for people who work or volunteer with children in NSW.
4. CHILD SAFETY PRINCIPLES
AChA is committed to upholding the following principles to ensure the safety and wellbeing of all children and young people involved in its activities:
  • Child-centered approach: Prioritising the best interests of the child in all decision-making processes.
  • Transparency and communication: Maintaining open communication with children, parents, and personnel about child safety policies and procedures.
  • Respect and equality: Treating all children with respect, valuing their diversity, and ensuring equitable access to a safe environment.
  • Empowerment: Educating and empowering children to understand their rights and how to report concerns.
  • Continuous improvement: Regularly reviewing and enhancing child safety practices and policies.
5. NSW CHILD SAFE STANDARDS
AChA fully embraces and is guided by the NSW Child Safe Standards to create a safe environment for children and young people. These standards include:
  • Child safety is embedded in organisational leadership, governance and culture.
  • Children and young people are informed about their rights, participate in decisions affecting them and are taken seriously.
  • Families and communities are informed and involved in promoting child safety and wellbeing.
  • Equity is promoted, and diversity is respected in policy and practice.
  • People working with children and young people are suitable and supported.
  • Processes to respond to complaints and concerns are child focused.
  • Relevant information about child safety and wellbeing is used to improve policies, procedures and practices.
  • Physical and online environments promote safety and wellbeing while minimising the opportunity for children and young people to be harmed.
  • Implementation of the Child Safe Standards is regularly reviewed and improved.
  • Policies and procedures document how the organisation is child safe.
PART B – GOVERNANCE AND ACCOUNTABILITY
6. GOVERNANCE STRUCTURE
6.1 The Board is ultimately responsible for ensuring AChA complies with its child safety obligations and implements this Policy. The Board will:
  • approve this Policy and any significant revisions;
  • designate a Board member to oversee child safety compliance; and
  • ensure adequate resources are allocated to child safety initiatives.
6.2 The Reporting Officer (Roxanne Heng, Programs Director) is responsible for the day-to-day implementation and management of this Policy and will act as the primary contact for child safety concerns and reports.
7. BOARD RESPONSIBILITIES
7.1 The Board will:
  • ensure the Policy is regularly reviewed (at least every two years) and updated in accordance with legislative changes and best practice;
  • promote a child-safe culture throughout the organisation;
  • ensure that all Board members understand and fulfil their child safety responsibilities; and
  • receive regular reports on child safety matters, including incidents and compliance.
8. SCREENING AND RECRUITMENT
8.1 AChA implements a robust screening and recruitment process for all personnel who work with children and young people.
  • All prospective personnel must undergo a Working With Children Check (WWCC) and provide valid clearance.
  • Reference checks will specifically inquire about suitability to work with children.
  • Interviews will include questions assessing a candidate's understanding of and commitment to child safety.
9. TRAINING AND AWARENESS
9.1 All personnel are required to complete mandatory child safety training upon commencement and periodic refresher training.
  • Training will cover child abuse identification, reporting procedures, and the AChA Code of Conduct.
  • Personnel will be made aware of their responsibilities under this Policy and relevant legislation.
10. INDUCTION
10.1 New personnel will receive an comprehensive induction that includes a thorough overview of AChA's child safety policies and procedures.
  • This includes reviewing the Child Safe Standards, Code of Conduct, and reporting mechanisms.
  • New personnel will be provided with contact details for the Reporting Officer and external support services.
11. ONGOING MONITORING AND REVIEW
11.1 AChA is committed to ongoing monitoring and review of personnel conduct and child safety practices.
  • Regular performance reviews will include an assessment of compliance with child safety obligations.
  • Personnel are encouraged to provide feedback on child safety practices and suggest improvements.
PART D – STANDARDS OF CONDUCT
12. CODE OF CONDUCT
12.1 All individuals covered by this Policy must adhere to the Master Member Code of Conduct, which explicitly addresses behaviours that promote child safety and wellbeing, including:
  1. treating children with respect and dignity;
  1. listening to children and valuing their contributions;
  1. maintaining professional boundaries with children;
  1. avoiding any form of physical, emotional, or sexual abuse;
  1. refraining from discriminatory behaviour;
  1. not engaging in rough play or inappropriate physical contact (see section 12.3 for detailed guidelines);
  1. never being alone with a child unless absolutely necessary and in a publicly visible area, or with parental consent for specific activities; and
  1. using appropriate language and communication.
12.2 Any breach of the Code of Conduct, particularly relating to child safety, will be taken seriously and may result in disciplinary action, including termination of engagement with AChA and reporting to external authorities.
12.3 Physical Contact Guidelines
12.3.1 General Principles: Physical contact with children by personnel should always be appropriate, professional, and in the child's best interest, promoting their safety and wellbeing. All contact must be respectful of personal space and cultural differences.
12.3.2 Permitted Contact: Brief, supportive physical contact that is appropriate for the age and developmental stage of the child, such as a hand on the shoulder for reassurance, assisting a child with a task, or a congratulatory high-five, is generally permitted, provided it is initiated by the child or clearly necessary for their support or safety, and is open, transparent, and observable by others.
12.3.3 Non-Permitted Contact: Personnel must avoid any physical contact that could be misinterpreted, is unnecessary, or goes beyond professional boundaries. This includes, but is not limited to, tickling, prolonged hugs, wrestling, or any contact that involves intimate areas.
12.3.4 Inappropriate Contact: Any physical contact that is sexually suggestive, demeaning, intimidating, or abusive is strictly prohibited and will be treated as a serious breach of this Policy.
12.3.5 Emergency/First Aid: In situations requiring emergency first aid or intervention to prevent harm, physical contact may be necessary. In such instances, personnel should use only the minimum contact required and explain their actions to the child (if appropriate) and any witnesses, reporting the incident as soon as safely possible.
12.3.6 Reporting Concerns: Any personnel who feel uncomfortable about physical contact (either their own or that observed between others) must report their concerns to the Reporting Officer immediately.
13. CREATING A SAFE ENVIRONMENT
13.1 AChA is committed to creating and maintaining a physically and emotionally safe environment for all children and young people. This includes:
  • Ensuring physical spaces are regularly inspected for hazards and are child-friendly.
  • Promoting an inclusive and welcoming culture where all children feel safe to participate and express themselves.
  • Encouraging open communication where children feel comfortable raising concerns.
  • Implementing clear procedures for managing child behaviour that prioritises safety and positive interactions.
14. TWO-ADULT RULE
14.1 Whenever possible, and particularly in situations where children may be vulnerable, AChA personnel should avoid being alone with a child. The "Two-Adult Rule" mandates that:
  • At least two screened and authorised adults should be present when working with children, especially in closed-door settings.
  • If a one-on-one situation is unavoidable, it must occur in an open, visible area, with transparency regarding the interaction, or with explicit parental/guardian consent for specific activities.
  • All such instances must be documented as per AChA's procedural guidelines.
15. HIGH-RISK AREAS
15.1 AChA recognises that certain areas or activities may pose a higher risk to child safety and requires enhanced vigilance and specific protocols. These areas may include:
  • Changing rooms, bathrooms, and sleeping areas.
  • Private or secluded spaces away from general view.
  • Transporting children in vehicles.
  • Overnight activities or excursions.
15.2 Specific procedures, including increased supervision ratios, designated personnel, and clear communication with children and parents, will be implemented for all high-risk areas and activities.
16. DIGITAL PLATFORM SAFETY
16.1 AChA is committed to ensuring the safety of children and young people when engaging through digital platforms and online activities. Personnel must adhere to the following guidelines:
  • All online communication with children must be transparent, professional, and conducted through official AChA channels, with parent/guardian awareness.
  • Personnel must not engage in private, one-on-one digital communication with children (e.g., direct messages on social media, private texts) unless explicitly authorised and monitored, with parental consent.
  • Appropriate privacy settings and online safety measures must be utilised for all digital activities involving children.
  • Personnel are prohibited from accessing, downloading, or distributing any inappropriate digital content, especially involving children.
17. DUTY OF CARE
17.1 All personnel, volunteers, and contractors engaged with AChA have a fundamental duty of care to protect children and young people from harm while under AChA's supervision or participating in its programs.
  • This duty includes taking reasonable steps to prevent foreseeable harm, responding appropriately to incidents, and ensuring the physical and psychological safety of children.
  • Personnel must be proactive in identifying and mitigating risks to children's safety and wellbeing.
  • Failure to uphold this duty of care may result in disciplinary action and/or legal consequences.
18. PHOTOGRAPHY
18.1 AChA maintains strict guidelines regarding photography and videography of children:
  • Explicit written consent from parents/guardians must be obtained before taking and using images or videos of children.
  • Images must only be used for the purposes for which consent was given (e.g., promotional materials, program documentation).
  • Personnel must ensure children are appropriately dressed and posed, avoiding any images that could be exploited or misinterpreted.
  • Images of children should never be shared publicly or privately without appropriate consent and adherence to privacy policies.
19. SOCIAL MEDIA
19.1 Personnel must exercise extreme caution and professionalism when using social media, particularly in relation to children involved with AChA:
  • Personnel are prohibited from 'friending' or connecting with children via personal social media accounts.
  • All online interactions with children should be limited to official AChA social media pages, if applicable, and must remain professional.
  • Personnel must not share any information, photos, or videos of children on personal social media without explicit, specific consent from parents/guardians and adherence to AChA policies.
  • Any social media content posted by personnel must reflect AChA's commitment to child safety and not bring the organisation into disrepute.
20. DRUG AND ALCOHOL USE
20.1 AChA has a zero-tolerance policy for personnel consuming or being under the influence of illicit drugs or alcohol while working with children or at any AChA-related activity involving children.
  • Personnel must not possess, supply, or consume alcohol or illicit drugs when in direct contact with children or attending any child-focused programs or events.
  • Any personnel suspected of being under the influence will be immediately removed from their duties and subject to disciplinary action.
  • AChA is committed to providing a safe and sober environment for children.
21. GROOMING
21.1 AChA is committed to preventing grooming and ensures all personnel are aware of what constitutes grooming behaviour and how to respond.
  • Grooming is the process by which a perpetrator builds a relationship of trust and emotional connection with a child, and often their family, with the ultimate aim of sexual abuse.
  • Personnel must be alert to and report any behaviour that could be interpreted as grooming, whether by other personnel, parents, or external individuals.
  • This includes excessive gift-giving, seeking exclusive contact with a child, offering special favours, or attempts to isolate a child from their peers or family.
  • All concerns about potential grooming will be taken seriously and investigated immediately as per AChA's reporting procedures.
PART E – RELATIONSHIPS AND PARTICIPATION
22. PRIOR RELATIONSHIPS AND FAMILIARITY
22.1 Where a Board member, staff, volunteer, or contractor has a pre-existing relationship with a child (e.g., family member), this must be declared to the Reporting Officer.
22.2 Appropriate measures will be put in place to manage potential conflicts of interest or to ensure that professional boundaries are maintained.
23. TRANSPORT
23.1 AChA will provide clear guidelines for the transportation of children, including requirements for driver qualifications, vehicle safety, supervision, and parental consent.
23.2 Private transportation of children by individuals (other than parents/guardians) is generally discouraged unless specific protocols are followed and parental consent is obtained.
24. INAPPROPRIATE FAMILIARITY
24.1 All individuals must avoid any behaviour that could be perceived as developing an inappropriate level of familiarity with children, including:
  1. (a) excessive personal contact;
  1. (b) sharing personal details;
  1. (c) offering special favours or gifts; or
  1. (d) engaging in private conversations without a legitimate reason and visibility.
25. YOUTH-TO-YOUTH RELATIONSHIPS
25.1 AChA promotes positive and respectful relationships among children and young people participating in its programs.
  • Children are encouraged to support each other and develop friendships in a safe and inclusive environment.
  • Any bullying, harassment, or negative interactions between young people will be addressed promptly and effectively according to AChA's anti-bullying policy.
  • Clear guidelines will be provided to children on respectful communication and interaction, both online and offline.
26. CHILD PARTICIPATION AND EMPOWERMENT
26.1 AChA values the voice of children and is committed to empowering them to participate in decisions that affect their safety and wellbeing.
  • Children will be provided with opportunities to express their views, ask questions, and contribute to program development in age-appropriate ways.
  • Mechanisms will be in place for children to report concerns or provide feedback confidentially and without fear of reprisal.
  • AChA will actively listen to children's input and consider their perspectives in decision-making processes, particularly those related to their safety.
27. CULTURAL SAFETY
27.1 AChA is dedicated to creating an environment that is culturally safe and respectful for all children and young people, acknowledging and valuing their diverse backgrounds.
  • Personnel will be trained in cultural awareness and sensitivity to understand and respect different cultural practices, beliefs, and communication styles.
  • Programs and activities will be designed to be inclusive and representative of the cultural diversity of participating children.
  • Specific consideration will be given to the needs of Aboriginal and Torres Strait Islander children and children from culturally and linguistically diverse backgrounds, ensuring their safety and wellbeing are paramount.
28. PARENTAL AND COMMUNITY ENGAGEMENT
28.1 AChA recognises the vital role of parents, guardians, and the wider community in ensuring child safety and wellbeing, and is committed to fostering open and collaborative relationships.
  • Regular communication channels will be maintained with parents/guardians to share information about child safety policies, programs, and any relevant incidents.
  • Parents/guardians will be encouraged to participate in program activities and provide feedback, contributing to a shared responsibility for child safety.
  • AChA will engage with local communities and relevant organisations to draw on their expertise and resources to enhance child safety measures and support networks.
PART F – REPORTING AND COMPLAINTS
29. RECOGNISING DISCLOSURES AND CONCERNS
29.1 All individuals covered by this Policy are responsible for recognising and responding appropriately to disclosures or concerns about child abuse, neglect, or harm.
29.2 This includes taking disclosures seriously, listening without judgment, not making promises of confidentiality, and reporting the concern immediately.
30. INTERNAL REPORTING PATHWAY
30.1 Any child safety concern or allegation, including a disclosure by a child, must be immediately reported to the AChA Reporting Officer (Roxanne Heng, Programs Director).
30.2 If the concern involves the Reporting Officer, the report should be made to a designated alternative Board member (e.g., Board Chair).
30.3 All reports will be handled with sensitivity, respect, and in a confidential manner, to the extent possible while adhering to reporting obligations.
31. REPORTING RISK OF SIGNIFICANT HARM (ROSH)
31.1 Individuals are required to identify and report any situation where there is a perceived Risk of Significant Harm (ROSH) to a child.
31.2 This involves understanding the indicators of ROSH and following specific internal and external protocols for urgent reporting to ensure the child's immediate safety and wellbeing.
32. REPORTABLE CONDUCT
32.1 Any conduct by a Board member, staff, volunteer, or contractor that falls under the definition of 'reportable conduct' as per relevant child safety legislation must be reported without delay.
32.2 Reportable conduct includes allegations of sexual offenses, serious physical assault, or behavior causing serious psychological harm to a child, and will be managed in accordance with legal requirements and organisational policy.
33. EXTERNAL REPORTING TO POLICE
33.1 In instances where there is a reasonable belief that a criminal offense against a child has occurred, including sexual assault, physical abuse, or severe neglect, a direct report will be made to the police or relevant law enforcement agency.
33.2 AChA will cooperate fully with police investigations, providing all necessary information while prioritising the child's safety and welfare.
34. CHILD-FOCUSED COMPLAINTS HANDLING
34.1 AChA is committed to providing a child-friendly and accessible complaints mechanism where children feel safe and empowered to raise concerns.
  • Children will be informed about how to make a complaint, who to complain to, and what will happen next, in an age-appropriate manner.
  • Complaints will be handled sensitively, with respect for the child's perspective, ensuring they are heard and their concerns are addressed promptly and fairly.
  • Support will be offered to children throughout the complaints process, and their feedback will be used to improve child safety practices.
35. WHISTLEBLOWER PROTECTION
35.1 AChA is committed to protecting individuals who report child safety concerns or reportable conduct in good faith.
35.2 The organisation will ensure that no person is subjected to detrimental action for making a report, and will provide support and maintain confidentiality as appropriate.
36. RESPONSE TIME FRAMES
36.1 All reports and complaints related to child safety will be acknowledged within a specified time frame, typically within 24 hours of receipt.
36.2 Initial assessments and responses will commence immediately, with detailed investigations and actions to follow promptly, ensuring all statutory requirements and internal policies are met.
36.3 Complainants and relevant parties will be kept informed of the progress and outcomes of reports and investigations, while respecting privacy and confidentiality obligations.
PART G – INVESTIGATION AND RESPONSE
37. INTERIM MEASURES
37.1 Upon receiving an allegation of child abuse or reportable conduct, AChA will immediately implement interim measures to ensure the safety of the child(ren) involved and other children.
37.2 These measures may include temporarily removing the accused individual from child-related work.
38. INVESTIGATION
38.1 All allegations will be thoroughly and impartially investigated in accordance with AChA's procedures and relevant legislative requirements.
38.2 Investigations will be conducted by suitably qualified and impartial individuals.
39. EXTERNAL INVESTIGATION
39.1 In cases of serious allegations or reportable conduct, external agencies (e.g., Police, Office of the Children's Guardian, child protection services) will be involved as required by law.
39.2 AChA will fully cooperate with any external investigation.
40. CONFLICTS OF INTEREST
40.1 Any individual with a conflict of interest relating to a child safety concern or investigation (e.g., personal relationship with parties involved) must declare it and recuse themselves from the process.
41. DISCIPLINARY OUTCOMES
41.1 If an allegation is substantiated, appropriate disciplinary action will be taken, which may include:
  • mandatory training;
  • changes to duties;
  • suspension;
  • termination of employment or engagement; and/or
  • referral to professional bodies or law enforcement.
41.2 The focus of disciplinary action will always be the safety and well-being of children.
42. STAFF WELLBEING AND SUPPORT
42.1 AChA recognises that responding to child safety concerns can be distressing for individuals and will provide appropriate support to Board members, staff, and volunteers involved in such processes.
PART H – ADMINISTRATION
43. PROGRAM-SPECIFIC REQUIREMENTS
43.1 Specific child safety requirements and protocols may be developed for individual AChA programs or activities, in addition to this overarching Policy.
43.2 These program-specific requirements will be consistent with this Policy.
44. PRIVACY, DATA PROTECTION AND RECORD KEEPING
44.1 Health and Safety Information Collection
44.1.1 AChA collects and maintains information about children's health, safety, and special requirements to ensure appropriate care and support. This includes:
  1. allergies and anaphylaxis information (including EpiPen requirements and emergency response procedures);
  1. medical conditions that may affect participation or require specific accommodations;
  1. disabilities or additional support needs;
  1. dietary requirements; and
  1. emergency contact information.
44.1.2 All health and safety information is collected with parental/guardian consent and is held securely in accordance with AChA's Privacy Policy.
44.1.3 This information is accessible only to authorised AChA personnel on a need-to-know basis for child safety and care purposes.
44.2 Personal Information of Children, Parents/Guardians, Staff, and Volunteers
44.2.1 AChA collects and holds personal information of children, parents/guardians, staff, and volunteers for purposes related to program participation, employment, volunteering, and child safety compliance.
44.2.2 This information includes names, contact details, relevant medical history, and consent forms.
44.2.3 All personal information is handled in strict accordance with AChA's Privacy Policy and relevant privacy legislation.
44.3 Record Keeping
44.3.1 Comprehensive records of all child safety incidents, concerns, investigations, and training will be maintained.
44.3.2 Records will be stored securely and confidentially, with access restricted to authorised personnel.
44.3.3 Records will be retained for the period required by law or best practice guidelines.
44.4 Data Breach Protocol
44.4.1 In the event of a data breach involving child safety information, AChA will follow its established Data Breach Response Plan, which includes notification to affected individuals and relevant authorities as required by law.
45. INSURANCE COVERAGE
45.1 AChA maintains appropriate insurance coverage, including public liability and professional indemnity insurance, to protect against risks associated with its operations and the provision of child-related activities.
46. RISK MANAGEMENT
46.1 AChA is committed to proactive risk management to identify, assess, and mitigate risks to child safety across all its programs and activities.
46.2 Regular risk assessments will be conducted, and mitigation strategies implemented, reviewed, and updated.
47. CONTINUOUS IMPROVEMENT
47.1 AChA is committed to continuous improvement in its child safety practices.
47.2 This Policy and related procedures will be regularly reviewed, at least every two years, or sooner if legislative changes or significant incidents occur.
47.3 Feedback from children, families, staff, and volunteers will be sought and considered during reviews.
48. GENERAL PROVISIONS
48.1 This Policy is intended to provide a framework for child safety within AChA. It should be read in conjunction with all other relevant AChA policies and procedures.
49. VARIATION OF POLICIES
49.1 AChA reserves the right to amend, update, or revoke this Policy and any related procedures at its sole discretion, provided that any changes are consistent with its commitment to child safety.
50. POLICY EVOLUTION CLAUSE
50.1 This Policy is a living document that will evolve to reflect best practice in child safety, legislative changes, and the changing needs of AChA's programs and community.
51. ACKNOWLEDGMENT AND COMPLIANCE, COMMENCEMENT, AND CONTACT AND SUPPORT RESOURCES
51.1 Acknowledgment and Compliance
51.1.1 All Board members, staff, and volunteers are required to read, understand, and comply with this Policy and associated procedures.
51.1.2 Compliance with this Policy is a condition of engagement or employment with AChA.
51.2 Commencement
51.2.1 This Policy comes into effect on [Date].
51.3 Contact and Support Resources
51.3.1 For questions regarding this Policy or to report a child safety concern, please contact:
  • [Designated Child Safety Officer/Contact Person]
  • [Email Address]
  • [Phone Number]
51.3.2 Additional external support resources for child safety concerns:
  • [Relevant External Agency 1]
  • [Relevant External Agency 2]