Terms and Conditions

1. Workplace Behaviour Policy

Why do we have this policy?

A safe working environment, where Social Marketers respect each other and are free from risks to their mental and physical health and safety, helps us to collaborate and achieve our aim. This policy aims to ensure that every (HLThee) Social Marketer (SM) is able to work in an environment that is free from discrimination, bullying and harassment.

Working environment refers to; A location where a task is completed. When pertaining to a place of employment, the work environment involves the physical geographical location as well as the immediate surroundings of the workplace, such as a construction site or office building, or home office. Including a virtual workplace which refers to; A workplace that has multiple locations, but not necessarily the same location all the time, as business is also done over email, mail, internet and video. SM’s within HLThee communicate with each other through such technology, as well as communication with their mentees.

Policy Requirements
What must a Social Marketer do/not do?

SM’s must not in the course of their membership, subject anyone (which includes other SM’s and non SM’s, such as contractors or representatives of suppliers and clients) to inappropriate behaviours such as discrimination, harassment, bullying, victimisation and vilification (referred to generally in this policy as “discrimination, bullying and harassment”).

Clothing/Branding on clothing- SM’s are not to wear any personal HLThee company, group or affiliated branding clothing trademarked to any registered Modere events. This policy applies to all conduct and behaviour in the course of a SM’s membership and includes conduct or behaviour occurring outside of the physical work environment/office provided there is some connection with HLThee. For example,this policy applies to conduct and behaviour at out of hours work functions (such as work HLTHee Events and SRC), and at all times whilst travelling on business. It also applies to interactions between SM’s outside work that may impact on relationships at work or work performance, or the reputation of HLThee.

Policy Principles
How do we achieve the aim of this policy?

HLThee is committed to providing a safe and healthy workplace where SM’s are free from harm and respected for their diversity and life choices. HLThee aims to promote a culture that is free from discrimination, bullying and harassment, and encourages fairness and equality based on performance and merit. This is achieved by adherence with our policy principles, which are:


LThee expects SM’s to interact with each other in a respectful and professional manner and treat everyone in a fair and equitable manner. SM’s are encouraged to report any inappropriate behaviour in the working environment, including discrimination, bullying and harassment to their immediate upline.

Natural Justice

HLThee aims to treat any person against whom a complaint is made in a fair manner. Generally, this means they will have the complaint or grievance put to them and be provided with an opportunity to reply.

Confidentiality And Sensitivity

Generally, only the people directly involved in a complaint or grievance (or the resolution of a complaint or grievance) in relation to an alleged breach of this policy will have access to information about a complaint or grievance. All parties to a complaint or grievance must maintain confidentiality at all times and not discuss the matter with anyone other than the persons involved in resolving the complaint.

No Unfair Repercussions

HLThee aims to treat all SM’s raising a complaint or grievance, in respect of this policy, fairly and aims to avoid them being victimised as a result of raising their complaint or grievance. However, SM’s must use this policy appropriately and not make a complaint or raise a grievance unnecessarily or inaccurately. Before making a complaint or raising a grievance please consider the serious consequences and potential damage to reputation that such a complaint or grievance could have upon the person; the subject of the complaint.


HLThee aims to deal with complaints and grievances arising under this policy as quickly as possible in the circumstances.


HLThee is committed to training all new and existing SM’s in relation to discrimination, bullying and harassment and other workplace behaviours. Where possible this training will be completed in the SM’s first month of membership. This training will cover what constitutes discrimination, bullying and harassment, how to identify discrimination, bullying and harassment and the HLThee grievance procedures which exist to support potential claims. 

HLThee is dedicated to providing ongoing workplace behaviour training to existing SM’s, and to providing training to new and existing SM’s who may be required to deal with grievances or complaints. 

Training delivery methods include but are not limited to:

  • HLThee Mentor Groups
  • Live videos
  • SM Handbooks
  • FAQ’s
  • Modere Lives
  • Modere Zoom’s
  • SRC
Consequences for Breach of This Policy
What will happen if a Social Marketer does not comply?

HLThee treats its obligations in relation to providing a working environment that is free from discrimination, bullying and harassment very seriously and takes a “zero tolerance” approach. In the event that an SM is found to have breached this policy they may be subject to disciplinary action which, depending on the circumstances and the seriousness of the breach, may include termination of membership.

What type of behaviour does this policy apply to?
What Is Discrimination?

Discrimination occurs when someone is treated poorly or unfairly compared to others based on a particular attribute/s. In accordance with legislation, it is unacceptable and unlawful for anyone to be discriminated against, either directly or indirectly, because of any of the following reasons/attributes:

  • Age
  • Race
  • Colour
  • National or ethnic origin
  • Sex or gender identity
  • Mental or physical disability
  • Sexual preference
  • Political belief or activity
  • Trade union activity
  • Religion
  • Marital status or family responsibilities
  • Pregnancy or breastfeeding
  • Criminal record
  • Physical features
  • Or any other characteristic specified under anti-discrimination or human rights legislation

Direct discrimination may occur if an individual treat, or proposes to treat, an SM with one of the above attributes less favourably than another/others without the attribute, under the same or similar circumstances.

For example, an employer denies a female candidate a position simply because she is female. In these circumstances, the female is treated less favourably than male candidates for the position solely based on her sex and the fact that she is a female.

Indirect discrimination may occur when a rule, practice or policy appears to be neutral, but in fact has a discriminatory effect on a group of people.

For example, an employer has a policy of not allowing any staff to work part-time. This may disadvantage those individuals with children/family/other responsibilities which hinder them from working full time.

In certain limited circumstances (such as in satisfying the inherent requirements of a job) direct or indirect discrimination may be justified and is therefore not unlawful. These exceptions are however very rare.

Discriminating behaviour can include, but is not limited to:

  • Office jokes/ in presence of, on line forms of communication, written, or verbalised
  • Making derogatory comments or taunts about someone in relation to one of the above grounds
  • Asking intrusive questions about someone’s personal life
  • Excluding or disadvantaging a person (or a group of people) based on one of the above grounds
What Is Vilification?

Vilification is the use of acts or words in public which provoke hatred, ridicule or contempt for a person or a group of people. Vilification is unlawful if it is on the grounds of race, religion, homosexuality, transgender status, sexuality, gender identity or HIV/AIDS status and is therefore unacceptable in the workplace. Examples of vilification include displaying or communicating offensive material, calling people names and making offensive comments.

What Is Harassment?

In general, harassment is any form of behaviour that is unwelcome and that a reasonable person would have anticipated would:

  • Humiliate someone
  • Offend someone
  • Intimidate someone

Workplace harassment usually consists of a pattern of unwelcome behaviour. However, it can consist of just one act. There is no requirement that the harasser intend to offend or harm in order for it to be unlawful. All that is required under the law is that a reasonable person would consider that the person being harassed would be offended, humiliated or intimidated by the behaviour in question.

Workplace harassment based on any of the attributes or reasons outlined above as being discriminatory (such as race, disability, age, pregnancy, marital status, homosexuality, transgender or HIV/AIDS status etc) is unlawful.

What Is Sexual Harassment?

The most common form of workplace harassment is sexual harassment. Sexual harassment is behaviour of a sexual nature which is unwelcome and has the effect of offending, intimidating or humiliating the person being harassed. There is no requirement that the harasser intend to offend, humiliate or intimidate another person.

A person’s intention is irrelevant.

Sexual harassment can include, but is not limited to:

  • Staring, leering or unwelcome touching
  • Suggestive comments, jokes or discussions
  • Sending sexually explicit emails or text messages
  • Repeated unwanted requests to go out on dates
  • Intrusive questions about a person’s private life
  • Requests for sex or other sexual acts
  • Displaying posters, magazines or screen savers of a sexual nature
What Is Not Sexual Harassment?

Developing friendships or personal relationships with people at work based on mutual consent.

What Is Bullying?

Bullying is also a form of harassment. Bullying is persistent or repeated inappropriate or unreasonable behaviour towards a person or group of people over a period of time that is offensive, humiliating or degrading that insults or ridicules the person at work (any location, in presence or on line).

Some examples of bullying include:

  • Verbal or physical abuse
  • Excluding or isolating staff members
  • Psychological harassment
  • Deliberately undermining work performance, for example, by refusing to give sufficient instructions, imposing unnecessary deadlines or impossible assignments
  • Belittling a staff member’s contribution or opinion
  • The misuse of a performance management system, or a return to work process
  • Publicly criticising a staff member or members
What Is Not Bullying?

Legitimate comments and advice from SM’s uplines, including constructive feedback on performance, or work-related behaviour of an individual or group, is not bullying. The process of providing feedback to staff during a formal performance appraisal, or counselling staff regarding their work performance, will not always be free of stress. Managers should manage these processes with sensitivity; however, they should not avoid their responsibility to provide full and frank feedback to staff.

What Is Victimisation?

Victimisation is any conduct which disadvantages a person because he or she has complained, or intends to complain about, being harassed, sexually harassed, discriminated against, bullied or vilified. Victimisation also includes any conduct which disadvantages a person who is assisting or supporting a person who has been subjected to inappropriate behaviour. Victimisation can take any form including intimidation, exclusion from work activities, withholding opportunities, dismissing a staff member or refusing a promotion, threatening a person or limiting their access to benefits. If a staff member lodges a complaint pursuant to State or Federal legislation, it is unlawful to victimise that SM or any person assisting with the complaint. There are penalties for individuals and corporations, which include fines and imprisonment.

Roles and Responsibilities
What are your responsibilities?
Management Team
  • Encourage fairness and equality within HLThee by promoting a workplace that is free from discrimination, bullying and harassment
  • Take all reasonable steps to implement, monitor and maintain a safe working environment including:
    • The development and implementation of policies and procedures in relation to workplace behaviour
    • Providing training in relation to appropriate behaviour in the workplace
    • Responding promptly and confidentially to all allegations of inappropriate behaviour in the workplace.
Director 1 and Above
  • Ensure SM’s are aware of HLThee’s policies and expected behaviours in the workplace
  • Promote a workplace that is free from discrimination, bullying and harassment
  • Seek to eliminate behaviour that constitutes discrimination, bullying and harassment regardless of whether a complaint is received about the behaviour
  • Investigate allegations and complaints of discrimination, bullying and harassment promptly and with confidentiality in accordance with HLThee’s grievance procedures
  • Seek to facilitate a fair and mutual resolution between the parties concerned
Social Marketers
  • Comply with this policy and ensure that they engage in appropriate workplace behaviour at all times
  • Treat others in a professional, fair and respectful manner
  • Report any behaviour that might amount to discrimination, bullying or harassment to their immediate upline or in accordance with HLThee’s grievance procedure
  • Cooperate with any investigation in relation to a breach of this policy

2.1 Therapeutic Goods Act Policy

Why do we have this policy?

and maintenance of a national system of controls relating to the quality, safety, timely availability and, where necessary, efficacy, of therapeutic goods that are:

  • used in Australia, whether produced in Australia or elsewhere; or
  • exported from Australia; and
  • to provide a framework for the States and Territories to adopt a uniform approach to control the availability and accessibility, and ensure the safe handling, of poisons in Australia.

The Therapeutic Goods Act 1989, and Regulations and Orders set out the requirements for inclusion of therapeutic goods in the Australian Register of Therapeutic Goods, including advertising, labelling and product appearance. The legislation also sets out the rights of individuals to have a decision that affects them, reviewed.

Decisions regarding the classification of drugs and poisons are set out in the Schedules of the Poisons Standard, these are then included in the relevant legislation of the States and Territories.

The Poisons Standard also includes model provisions about containers and labels, a list of products recommended to be exempt from these provisions, and recommendations about other controls on drugs and poisons.

Due to requirements of the Therapeutic Goods Act (TGA) 1989 and Regulations, the Competition and Consumer Act 2010 and other relevant laws we as Social Marketers are unable to comment on any medical or health related diagnosis or treatment options.

Policy Requirements
What must you as a Social Marketer for HLThee do/not do?

Refer to The Therapeutic Goods Procedure.

For SMs that reside/market in other countries, please ensure you are aware of relevant country laws and requirements to be considered in addition to Therapeutic Goods Act 1989.

Policy Principles
How do we achieve the aim of this policy?

Every HLThee Social Marketer (SM) is to indicate that they have read and understood the Therapeutic Goods Act (TGA).

  • The TGA section of the Registration process is to be read, understood, and completed as part of the registration process.

2.2 Therapeutic Goods Act Procedure

Why do we have this procedure?

Due to requirements of the Therapeutic Goods Act (TGA) 1989 and Regulations, the Competition and Consumer Act 2010 and other relevant laws we are unable to comment on any medical or health related diagnosis or treatment options.

What type of behaviour does this procedure apply to?

This procedure is in place to ensure the same, correct information is provided to every potential mentee, ensuring continuity of information is consistent.

What must you as a Social Marketer for HLThee do/not do?

The purpose of these requirements is to protect us as Social Marketers, your business, the overall business and the health of our customers. It is a requirement of the TGA that we must not:

  • Make any therapeutic claims relating to the healing of disease. (e.g. healing, curing, restorative etc.)
  • Comment on any disease, condition, surgery or the treatment of disease. (e.g. Cancer Diabetes etc.)
  • Use any medical terminology to make any claim, statement or implication that it is effective in all cases of any medical condition. (e.g. we cannot use the medical term “obesity” but we can use the term “weight loss”)
  • Be likely to lead to consumers self-diagnosing or inappropriately treating potentially serious diseases. (e.g. “I have stopped my depression medication because I feel so happy”)
  • Contain any claim, statement or implication that it is infallible, unfailing, magical, miraculous, or that it is a certain, guaranteed or sure cure. (e.g. “You WILL lose 10kg” is better said as “Lose up to 10kg’)
  • Be directed at children (must be 18 years or over)
  • Contain any claim, statement or implication that it is effective in all cases.