Training
In Safety and Productivity

STUDENT Information  

Rural Training Australia

 

Table of contents

  1. Welcome
  2. About us     (scope etc.)
  3. Products and services
  4. Delivery method. Training and assessment
  5. Commitment to you
  6. Contacts
  7. Pre enrolment
  1. Enrolment process
  1. Obligations
  2. Student conduct
  3. Awarding of qualifications and/or Statements of attainment
  4. Re-issue of certificates
  5. Student feedback

 

    Welcome

    At Rural Training Australia we provide quality training in the Agriculture, Horticulture and Thoroughbred Race Horse Industries.

    We do not try to be all things to all people but concentrate on what we do best. We believe our quality training will provide you with the outcomes you desire, be it a better job, an increased income, being a better food producer or gaining professional recognition.

    Agriculture - Horticulture - Food Production

    The major part of our business is Food Production because it is what we know best and it is our passion. We are just as passionate about you our students; we want you to succeed. Work with us to increase your knowledge and skills. We subscribe to best practice assessment standards ensuring you to be at the leading edge of your field. You will be equipped with the skill and knowledge gained from an industry-leading training course that will fast track your Food Production career. Our industry is poised for an exciting future and we look forward to supporting our valued students and clients on this journey.

    The avenues to pursue in our industry are numerous such as, Farmer, Cattle Station Manager, Head Stockman, Stock Agent, Grower, Ag Consultant. It all starts here.

     

    About us

    Rural Training Australia is the trading name for Coastal & Rural Training Pty Ltd which was started in 2001 by people from a rural and remote background in the Western Australian wheatbelt and has grown to encompass WA, Northern Territory and Queensland. 

    Our Trainer/assessors are Cattle and Stock horse experts or Grain and Sheep experts or Fruit and Vegetable growers.

    All still work in their chosen area to keep their knowledge and skills current to provide you with the latest and best possible industry information and practices.

    Some are relief Station Managers or Head Stockmen, others are Stock horse trainers or Plantation workers or Animal Husbandry/cropping and Farm Maintenance contractors.

    Our office staff have all worked in livestock yards and paddocks, driven tractors and fixed fences.

    It is our commitment to you for us to have the most up to date knowledge and skills to assist your development.

     

    Qualifications (click on course link below for further information)  

    AHC20116 - Certificate II in Agriculture

    AHC30116 - Certificate III in Agriculture

    AHC40116 - Certificate IV in Agriculture

    AHC33316 - Certificate III in Feedlot Operations

    AHC20416 - Certificate II in Horticulture

    AHC30716 - Certificate III in Horticulture

    RGR30518 - Certificate III in Racing (Trackwork Rider)

    RGR40208 - Certificate IV in Racing (Jockey)

    Products and services  

    Our range of products and services include Funded workplace traineeships in Western Australia, Northern Territory and Queensland for the Qualifications that we offer.

    We also provide an RPL service for the Qualifications that we offer.

    We are currently considering utilising our Trainer/assessors skills and expertise to offer short courses in the future depending on industry demand.

     

    Delivery Method

    RTA specialises in providing professional education and training services to you in Western Australia, Northern Territory or Queensland.

    Our friendly and experienced team will provide support and assessment feedback as you progress through your studies.

    WORKPLACE TRAINING

    The majority of your training is ‘workplace based’. This allows us to deliver hands on training that specifically targets the requirements of your job role whilst contributing towards productivity.

    It is our aim that you meet and exceed industry requirements.

    Example; if one of your chosen competencies is AHCMOM202 Operate Tractors.

    “There are many makes, models, weight, capacity and variations of tractor. Some are for small acreages slashing grass whilst others are huge being articulated and towing 20 metre air seeder units.

    We will endeavour to equip you with the knowledge and skills to operate as many as practical.”

     

    The overall objective of Training by ‘Rural Training Australia’ is to enhance the work capability of all students by assisting them to improve job related skills & underpinning knowledge in workplace related tasks.

    Assisting you to develop and work through training.

    Assisting you to gain job pathways.

    Therefore, our preferred method of training delivery is face to face, IE, Discussion, demonstration and structured practice. This is supplemented with workplace documentation and varying learning resources. You may also be required to complete a project or build a portfolio. 

    WORKPLACE ASSESSMENT

    As per the training delivery, your assessment sessions will be based on the same format. IE, you will be assessed as you perform the unit of competency during the normal course of your employment. If the assessor is unable to witness your work performance, then a simulated exercise will be requested. The theory component will be by either written exam or verbal discussion for a more in-depth knowledge assessment. Your performance will also be supported by an employer representative or a workplace referee. The assessor may request reassessment or that you perform a portion of the unit at a later date.

     

    RURAL TRAINING AUSTRALIA’S ONGOING COMMITMENT TO YOU

    Building on the strong relationships we develop with learners completing our courses, our industry experts are available by arrangement to provide ongoing mentoring to you. Students can also benefit from access to current industry information through our client network. 

    In Australia, only Registered Training Organisations can issue nationally recognised qualifications. Our RTO provider code is 50898.

    Our courses are delivered by appropriately qualified and experienced Facilitators, and through a variety of methods.

    We will also notify you immediately if a change occurs that may affect the services that we provide.

    This includes a change of ownership, and/or any changes to, or new 3rd party arrangements.

    Simply put, we guarantee to protect and support your endeavours to gain a qualification.

     

    Contacting us

    Feel free to contact us with any query you may have regarding your learning experience with Rural Training Australia.

    Main contact for all queries

    Office Manager Kylie

    PO Box 159 Northampton WA 6535

    Mobile 0428 951616

    Email     kylie@rtau.com.au 

    Or via our website www.ruraltrainingaustralia.com.au

    Direct contact for complaints and appeals or just a chat

    Dave Rock CEO

    Mobile 0427 341 430

    Email    ceo@rtau.com.au

    Pre-enrolment information

    • For Course information including pre-requisite requirements, entry requirements, duration and other information.

     

                             

     

    Please click on the qualification below 

     

    AHC20116 - Certificate II in Agriculture                                  

    AHC30116 - Certificate III in Agriculture                                 

    AHC40116 - Certificate IV in Agriculture                                

    AHC33316 - Certificate III in Feedlot Operations                

    AHC20416 - Certificate II in Horticulture                                

    AHC30716 - Certificate III in Horticulture                                               

    RGR30518 - Certificate III in Racing (Trackwork Rider)     

    RGR40208 - Certificate IV in Racing (Jockey)                                    

     

     

    • RPL and credit transfers

    All prospective students will be offered RPL and credit transfers during the unit selection stage of their enrolment.

    RTA recognises AQF qualifications and statements of attainment issued by any Registered Training Organisation in Australia.

     

    Tips & hints to help you show your skills for recognition.

     

    There are many forms of assessment available to gain Recognition of Prior Learning (RPL).

     

    In order to have skills formally recognised in a national system, assessors must make sure you have the skills and knowledge to the industry standard. This means you must be involved in a careful & comprehensive process that really covers the content of all of the units or qualifications you are applying for recognition. Your skills & experience from the past 2 years are the most important in the assessment because this shows you are current in the industry. Assessment can happen in a variety of ways. Being prepared can save you lots of time & hassle. Here are some tips & hints to prepare for a recognition process.

    1. Browse through the descriptions of units that relate to your work. This will help you to get an idea about where your skills could fit with national training units. You can get full details of any unit from your training provider.
    2. Plan & perform with the RPL Assessor which units would be better assessed by doing workplace observation or 'walk-through' which can be a fast & comfortable way for you to demonstrate your skills & knowledge.
    3. Be prepared to talk about your job roles & your work history. Bring a resume or jot down a few points about where you have worked, either paid or unpaid, & what you did. 
    4. Think about who can confirm your skill level. Think about current or recent employers/supervisors who have seen you work in the past 2 years & will be able to confirm your skills. We will need to contact them. You may also have work colleagues or even clients themselves who can vouch for your skill level.
    5. Collect any certificates from in-house training or formal training you have done in the past. E.g.; forklift ticket, shoeing school, low stress stock handling course, first aid etc. A copy of these is required.
    6. You can speak with the training organisation about other ways you can show your skills. These could be letters from employers, records of your professional development sessions, acknowledgements, workplace forms (as long as they don't show confidential work place information) or other relevant documents 

     

    • LLN (Literacy, Language and Numeracy) test, requirements and support

    It is Rural Training Australia’s requirement that all prospective students complete an LLN test to assist in determining the level of adjustment, assistance or support required, if any.

    • Welfare and guidance services

    Rural Training Australia staff are able to provide referral to appropriate organisations for your support.

    Rural Training Australia offers referral to welfare, guidance, & external support services to all students. The nature of the information required can either be one of training/assessment nature, external support aspect, or that of a private matter.

    Students with physical or mental impairments may require adjustments to the workplace Assessment of workplace facilities, equipment. The following processes will be applied for students considered to be at risk.

    RTA is at all times concerned with the welfare of our students. Staff will counsel students as appropriate and/or refer them to qualified counsellors. Staff are required to respond to and attempt to alleviate any signs of distress, discomfort or risky behaviour by students, and to actively render appropriate support and assistance.

    • If students require extra support or counselling, they are encouraged to make contact with a member of our team who will be eager to assist and refer them to the appropriate support services, such as: Lifeline – 13 11 14 or lifeline.org.au
    • Relationships Australia - 1300 364 277 http://www.relationships.org.au
    • MensLine Australia – (For men of any age) 1300 78 99 78
    • Kids Helpline (For young people aged 5-25) – 1800 551 800
    • Beyondblue.org.au
    • Complaints and appeals 

    It is Rural Training Australia’s desire to provide a positive experience to all clients.

    We take complaints seriously.

    Should the occasion arise that you have a complaint regarding our staff or practices it is recommended that you communicate with your trainer/assessor. If this does not result in a positive resolution, please contact Rural Training Australia’s CEO 0427 341 430 ceo@rtau.com.au .

     

    • Complaints and appeals Policy

    RTA’s Management shall ensure that all complaints and appeals are dealt in accordance with the principles of natural justice and procedural fairness and remains publicly available. All complaints and appeals shall be subject to notification within RTA’s management meeting and require the implementation of RTA’s complaints and appeals process.

    Scope of Complaints and Appeals Policy

    RTA will manage and respond to allegations involving the conduct of:

    1. a) RTA, its trainers, assessors or other staff;

      b) a third-party providing services on RTA’s behalf, its trainers, assessors or other staff; or

      c) a learner of RTA.

    Complaints and Appeals Procedures
    Learners may choose to submit a complaint to RTA staff via the Informal Process or Formal Process.
    (Please note ‘RTA staff’ will be considered to include third parties or partnering organisation staff)

    Informal process
    • Learners may submit a complaint (verbally or in writing) directly to RTA’s staff with the purpose to resolve a complaint through discussion and through mutual agreement. All complaints received will be acknowledged in writing by RTAs Management.
    • RTA staff are required to explain to the Learner the Informal, Formal and complaints and appeals processes available to them.
    • Learners may be accompanied by a third party of their choice to support them in the informal process discussion.
    • All informal complaints when finalised shall be reported to RTA’s Management by RTA’s staff (via a STUDENT COMPLAINT form available on request) for further review and consideration for potential continuous improvement actions, regardless of whether the complaint was resolved or not.
    • All informal complaints that are not resolved with Learners by mutual agreement with RTA’s staff will require the completion of the formal complaints process.

    Formal Process
    • When a Learner wishes to submit a formal complaint or is dissatisfied with the attempt to resolve a complaint informally (directly with staff) the Learner may submit a formal complaint to RTA’s management utilising the 'Student Complaint Form' available on request.
    • RTA’s Management will respond in writing to all formal Learner complaints within 5 days of receipt of a 'Student Complaint Form'.
    • When a Complaint is recognised as requiring more than 60 calendar days to resolve RTA’s management must inform the complainant in writing, including reasons why more than 60 calendar days are required; and regularly update the complainant on the progress of the matter.
    • RTA’s Management shall respond to formal complaints from Learners in writing proposing a resolution to the complaint.
    • RTA Management responses to the complainant shall include information and procedures concerning the complainant’s right to appeal the proposed solution and request for an independent adjudicator.
    • All formal complaints when finalised shall be reported to RTA’s Management by RTA’s staff (via a 'Student Complaint Form') for further review and consideration for potential continuous improvement actions, regardless of whether the complaint was resolved or not.

    Appeals Process

    In the event of a Learner advising that they are dissatisfied with the proposed solution for a formal complaint to RTA’s management, the CEO shall provide an additional opportunity to provide a solution and shall apply the External Appeal process.

    External Appeals
    • The CEO shall advise the Learner that an Independent Third party shall be sought to consider the nature of the complaint and a possible further resolution at no cost to the Learner.
    • The selection of the Independent Third party shall be communicated with the Learner and the selection must be with the mutual agreement of the Learner.
    • RTA’s management shall make contact with the Independent Third party and provide all documentation related to the formal complaint and Learner contact details.
    • Independent adjudication responses must be within 7 days from the date that all formal complaint documentation is provided to the Independent Adjudicator.
    • When an Appeal process is recognised as requiring more than 60 calendar days to resolve RTA’s management must inform the appellant in writing, including reasons why more than 60 calendar days are required; and regularly update the appellant on the progress of the matter.
    • On receipt of the formal complaint documentation the Independent Third party shall make contact with RTA’s Management staff and the Learner and arrange a suitable time for further discussion pertaining to the formal complaint.
    • All Independent Third Party proposed solutions shall be final and be reported to RTA’s management and the Learner in writing and will require immediate implementation by both parties.

    Assessment result appeals

    All appeals from Learners relating to assessment results must be received in a period no longer than 3 months following the competency decision.

    Assessment Appeals Procedure

    Staff delivering training and assessment services on behalf of RTA will be required to:

    • Provide timely guidance to all course participants regarding the assessment appeals procedure.

      • Clarify any aspects of the assessment results that a student does not understand.

      • Provide each student that requests an assessment appeal with the required 'Assessment Appeal form' available on request.

      • Communicate directly via email as soon as possible with RTA’s management on any advice (verbal or written) provided by a student that they are seeking to appeal an assessment decision.

      • Schedule a meeting with the student and RTA’s management when a completed assessment appeal form is received from a student.

      • Communicate any outcome decision by RTA’s management to uphold or overturn an assessment appeal to the student’s by completing the assessment appeal form clearly identifying the reason for the outcome.

      • All assessment appeals will be processed by RTA’s staff and management within 10 days of receipt of an appeal. All assessment appeals must be maintained on the students file.

      • Student records will be adjusted to comply with RTA’s management appeal outcome decisions.

    Complaints and appeals records

    RTA’s management shall maintain records of all complaints and appeals and their outcomes and reference complaints and appeals in RTA’s Complaints Register and Management meeting minutes identifying potential causes of complaints and appeals and takes appropriate corrective actions to eliminate or mitigate the likelihood of reoccurrence.
    Records of all Informal, Formal complaints and appeals will be recorded in RTA’s Review meeting minutes and all written student complaints records will be retrievable through the Student Complaints PCFs.

    • Fees and charges

    Rural Training Australia is unable to receive any payment above $1500.00 before Course commencement, or during the course, for learning that is yet to be received by its enrolled students. 

    For our fees and charges please click on the link below

    Resource fees must be published by RTA prior to the commencement of enrolments. RTA does not charge resource fees.

     

    RTA provides Training Record Books to trainees and apprentices, we must do so free of charge.

     

    Fees and charges

     

    • Refunds

    The following refund will apply to training cancellations: 

    • WA User Choice funded trainees: Where a student withdraws prior to the census/withdrawal date for each unit a FULL refund for those unit's fees will be applied.
    • QLD User Choice/Higher Level Skills funded trainees: Where a student withdraws, a FULL refund of fees for units NOT YET STARTED (no training has taken place) will be applied.

     

    • Privacy of Personal Information

    Privacy Notice

    Under the Data Provision Requirements 2012, Rural Training Australia is required to collect personal information about you and to disclose that personal information to the National Centre for Vocational Education Research Ltd (NCVER).

    Your personal information (including the personal information contained on the enrolment form), may be used or disclosed by Rural Training Australia for statistical, administrative, regulatory and research purposes. Rural Training Australia may disclose your personal information for these purposes to:

    • Commonwealth and State or Territory government departments and authorised agencies; and
    • NCVER.

    Personal information that has been disclosed to NCVER may be used or disclosed by NCVER for the following purposes:

    • populating authenticated VET transcripts;
    • facilitating statistics and research relating to education, including surveys and data linkage;
    • pre-populating RTO student enrolment forms;
    • understanding how the VET market operates, for policy, workforce planning and consumer information; and
    • administering VET, including program administration, regulation, monitoring and evaluation.

    You may receive a student survey which may be administered by a government department or NCVER employee, agent or third-party contractor or other authorised agencies. Please note you may opt out of the survey at the time of being contacted.

    NCVER will collect, hold, use and disclose your personal information in accordance with the Privacy Act 1988 (Cth), the National VET Data Policy and all NCVER policies and protocols (including those published on NCVER's website at www.ncver.edu.au).

     

    According to the Department of Industry and the Student Identifiers Bill 2014:

    Using the USI, the personal information would only be linked to the educational information when a student asks to see his or her own records or when a student authorises someone else to do so (such as a training organisation) or as otherwise authorised by Commonwealth legislation. 

     

    Rural Training Australia as a Registered Training Organisation (RTO) has an obligation to report student data on an annual basis to the VET regulators; the USI will form part of this reporting. 

     

    Rural Training Australia is also required to provide traineeship student data on a monthly basis to the appropriate State Training Authority.

    • Image and testimonial usage permission

    Rural Training Australia will seek your written permission to use your images or testimonials for the purpose of promoting our services.

    Enrolment process

    • USI (Unique Student Identifier)

    A USI is required by all Australians undertaking nationally recognised training. It allows students to link to a secure online record of all qualifications gained regardless of the provider. This system was implemented by the Australian Government in 2015, so it will show student achievements from 1 January 2015 onwards. As an RTO, Rural Training Australia cannot issue Certificates or Statements of Attainment without a USI. Therefore, it is mandatory that all students supply their USI upon enrolment.

     

    Applying for a USI

    The USI system accepts any one of the following valid forms of Australian ID:

    • Driver's Licence
    • Medicare Card
    • Australian Passport
    • Visa
    • Birth Certificate (Australia)
    • Certificate of Registration by Descent 
    • Citizenship Certificate
    • Names entered into the USI system must match the ID presented.

     

    Without one of these documents a USI cannot be issued and enrolment may not be possible. In this situation it is recommended to contact Rural Training Australia and they can discuss with the USI Registrar.
    Note that there is no charge to apply for a USI.   
    More information on applying for a USI: https://www.usi.gov.au/

     

    • Identification

    It is a requirement that ID is provided by all intending Traineeship students. 

    Please provide either Drivers licence or passport to the AASN (Australian Apprenticeship Support Network) representative when requested.

    • Unit selection    

    Prior to completing the enrolment/training plan you, the employer representative and the trainer/assessor must choose the competencies that will make up your qualification. This is a negotiation process and only units that we offer can be chosen. The training plan will outline who, how, when and where your training and assessment takes place.

    • Enrolment/Training plan     

    The training plan will outline who, how, when and where your training and assessment takes place. Completed and signed by you, the employer representative and the RTA trainer/assessor.

    If you are under 18 years of age a parent or guardian will be required to sign. 

    • Work books and course materials    

    Rural Training Australia will provide a student record book within 4 weeks of enrolment. Additional resources are available via our Student management System for which you are provided with a log in.

    Hard copies of resources are provided on request as you may be at a location where internet is minimal or not available. Please also utilise your trainer as much as possible.

    There is no charge for any of the above.   

    • What you need to provide

    You will need to have available all appropriate PPE (Personal Protection Equipment) that is required in your workplace.

    Example; helmet, boots, gloves, eye protection, hearing protection etc.

     

     

    Obligations

     

    RTO Obligations

    • Ensure the workplace is safe and in line with Workplace Health & Safety Guidelines
    • Ensure that the Training Plan is completed. This will be negotiated by the RTO, Employer and Trainee.
      Deliver or arrange delivery of the structured training, which may be the RTO, workplace or a combination of both.
      Provide workplace support to the employer & student, including assisting with scheduling structured training & planning of the Assessment process.
    • Negotiate assessment arrangements with the employer & apprentice/trainee & validate final assessment;
    • Issuance of Certificate or Statement of Attainment in compliance with Australian Qualifications Framework guidelines
    • Once the student has commenced study in their chosen course Rural Training Australia will guarantee to complete the training and/or assessment within the course duration and will further negotiate the timing for completion of the course if a student is unable to complete the course due to illness or extenuating circumstances.
    • Rural Training Australia does not guarantee that a learner will successfully complete a training course.

    Employer & Trainee obligations

    The Employers traineeship obligations are to

     

    • Employ & train the trainee as agreed in our Training Plan & ensure the trainee understands the choices that he/she has regarding the training
    • Provide the appropriate facilities & experienced people to facilitate the training & supervise the trainee while at work, in accordance with the Training Plan

    • Make sure the trainee receives on-the-job training & assessment in accordance with our Training Plan

    • Provide work that is relevant & appropriate to the vocation & also to the achievement of the qualification in the Contract
    • Release the trainee from work & pay the appropriate wages to attend any training & assessment specified in our Training Plan
    • Meet all legal requirements regarding the trainee, including Workplace Health & Safety requirements & payment of wages & conditions under the relevant employment arrangements
    • Work with RTA & the trainee to make sure we follow our Training Plan, assist in keeping training records up-to-date, & monitor & support the trainee's progress; &
    • Let the relevant State/Territory Training Authority & RTA know within five working days (or when the local State/Territory legislation requires, if this is different) if the Training Contract has become jeopardised.

                   

    The Students obligations:

    • Attend work, do their job, & follow the employer's instructions, as long as they are lawful.
    • Work towards achieving the qualification stated in our training plan
    • Undertake any training & assessment in our training plan.
    • Abide by all regulation IE: animal welfare, WHS, Antidiscrimination, etc.
    • Provide USI to RTA at enrolment, if not give permission to RTA to obtain the USI on their behalf.

     

    Student conduct

    Students are expected to adhere to the following:

    • Respect and courtesy are to be upheld at all times
    • Personal possessions are the responsibility of the student and interference with another student’s or RTA will not be tolerated
    • Consideration without disruption or impediment to others learning must be adhered to at all times
    • Inappropriate physical contact or verbal abuse will not be tolerated
    • Clothing and footwear should be appropriate to attending a training facility and not cause offence to other students and staff
    • Mobile phones are to be switched off during session times
    • Eating and drinking is to be confined to designated areas whilst in training
    • Smoking and alcohol are not permitted in training facilities
    • Drinking alcohol during allocated break times is strictly not permitted
    • Drug usage is strictly prohibited unless you are required to take legally prescribed drugs
    • Respect start and finish times of all face to face sessions
    • Follow all emergency procedures as directed by RTA staff
    • Inform RTA of any personal or contact details change
    • Complete all required work including assessment tasks, assignments or learning tasks within timeframes allocated by the trainer/assessor
    • Maintain regular contact with their trainer/assessor and advise them if there are any issues or they require additional assistance.
    • Consequences for misconduct will depend on the severity and frequency of the breach, and include, but are not limited to:
    • Formal reprimand (warning) 
    • Suspension from the course
    • Student to reimburse the costs incurred by any damage caused
    • Cancellation of the course without refund and/or credit
    • Matter referred to the police.
    • Students found guilty of misconduct have a right to lodge an appeal by following our ‘Complaints and Appeals’ process which will be made available upon request.

    Awarding of qualifications and/or Statements of attainment 

    Rural Training Australia will issue all certification and Statement of Attainment in line with the requirements of Schedule 5 of the Australian Qualifications Framework and the endorsed Training Packages as per the scope of registration the RTO is approved to deliver. Certificate and Statement of Attainment to the learner with 30 days of being assessed as meeting the requirement of the Training.  

    For qualification security we utilise a watermark system and unique QR barcode.

     

    Re-issue of certificates

    A fee of $20.00 will be charged for electronic copy of Certificates.

    A fee of $30.00 will be charged for printed copy of Certificates.

     

    Student feedback

    We would appreciate your feedback to assist us continually improve our services.

    Feedback is sought from internal and external stakeholders as well as students, employers and industry (i.e. administration staff, trainers/facilitators, assessors, contractors, instructional designers and specialist course writers). As an RTA student, you will be asked from time to time to participate in our stakeholder feedback through the completion of a survey re your experience as a student in our learning program. Your cooperation would be appreciated as all results are analysed to enable us to improve our learning programs and maintain our high standard. Our assessors participate in moderation and validation of assessment activities on a regular basis to maintain the quality of the learning and assessment strategy. Our Quality Indicator feedback returns, in conjunction with internally generated surveys are analysed for opportunities to implement continuous improvement initiatives to our learning and assessment strategies, identify areas for staff continuing professional development and/or improvement or adjustment to our internal policies, processes and systems.

     

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