Direct Relief Policy

1. Purpose and constitutional basis

Constitution clause 4(a)(iii) authorises the Company to "where necessary and consistent with the Company's Direct Relief Policy adopted from time to time by the Board, discharge or reduce specific debts of beneficiaries where such discharge is, in the Board's judgement, the most effective form of benevolent relief available in the circumstances".

This Policy is the Direct Relief Policy contemplated by that clause. It sets out how the Board authorises the CEO and delegated staff to deploy Company funds to relieve the financial hardship of beneficiaries.

2. Beneficiary class

Relief under this Policy is available only to beneficiaries who fall within the constitutional beneficiary class defined in clause 4(a) — namely:

persons in Australia who are living with a terminal, life-limiting, chronic or serious illness or health condition, and the immediate families and primary carers of such persons.

Consistent with Standing Order #4 (Sprint 28 · full clause 4(a) launch scope), the Company serves the complete constitutional beneficiary class from Y1 onwards, subject to operational capacity.

3. Relief mechanisms — the mechanism mix

The Company delivers relief through the five mechanisms authorised by clause 4(a)(i)–(v). This Policy governs the balance between them (the "mechanism mix"), noting that debt mediation is expected to be the primary mechanism at most beneficiary interactions.

Rationale. Debt-mediation is expected to achieve the largest impact per program dollar because mediated waiver or reduction by creditors leverages our advocacy without requiring cash outlay for the debt itself. Direct discharge is retained as an available mechanism where mediation fails and the beneficiary's circumstances make immediate discharge the most effective relief.

4. Eligibility criteria

A beneficiary is eligible for relief under this Policy where all of the following apply:

1. the person falls within the constitutional beneficiary class in clause 4(a);
2. the person's financial position is such that essential living costs and/or consumer-debt obligations cannot reasonably be met from the person's own resources or from publicly funded sources (a "financial-hardship threshold" documented in the case file);
3. the relief sought is directed to relieving hardship connected to, or exacerbated by, the beneficiary's illness or health condition — not to unrelated commercial or investment liabilities;
4. the case has been documented on the Company's case-management system with the beneficiary's informed consent to record and process their information; and
5. where debt discharge under clause 4(a)(iii) is proposed, the CEO or delegate is satisfied that discharge is the most effective form of relief available in the circumstances.

5. Engaged professionals — clause 4(a)(v)

The Company may train, engage or fund suitably qualified professionals to deliver services under this Policy, including financial counsellors, community lawyers, debt-mediation specialists, social workers, and clinical liaison staff. All engaged professionals must:

1. hold current professional registrations or accreditations relevant to their role;
2. agree to the Company's Confidentiality & Privacy Policy, Conflict of Interest Policy, and Safeguarding Policy;
3. work under a written engagement letter that references this Policy; and
4. be remunerated at rates the CEO is satisfied are at or below market for the service delivered.

6. Delegated authorities — living-cost relief (clause 4(a)(ii))

The Board delegates to the CEO the authority to approve direct financial relief for essential living costs under clause 4(a)(ii), subject to the following caps per beneficiary case:

7. Delegated authorities — specific debt discharge (clause 4(a)(iii))

The Board delegates to the CEO the authority to approve specific debt discharge or reduction, subject to the following caps per beneficiary case:

8. Case documentation and audit trail

Every relief authorisation under this Policy must be documented on the Company's case-management system with, at a minimum:

1. beneficiary identifier and clause-4(a) eligibility statement;
2. documentation of financial-hardship threshold (income, essential expenses, debt schedule);
3. evidence of illness or health-condition status (clinician letter, referral, or equivalent — held with beneficiary's consent);
4. the mechanism(s) applied and the amount authorised;
5. the approver's name and date; and
6. where debt discharge is applied, evidence that discharge is the most effective form of relief in the circumstances.

Case documentation is retained for the period required by ACNC record-keeping rules and the Privacy Act 1988.

9. Reporting to the Board

The CEO reports on relief activity under this Policy at every Board meeting, including:

1. number of beneficiaries assisted, by mechanism;
2. total spend by mechanism, against the Y1 mechanism-mix targets in s.3;
3. any relief authorisation that exceeded the delegated caps in s.6 or s.7 (with Board approval evidence);
4. trends and observations that may inform future policy revisions.

10. Policy review

This Policy is reviewed by the Board at least annually and after any of the following triggers:

1. a material change in the Company's financial position;
2. a material change in the ATO's or ACNC's guidance on PBI direct-relief expenditure;
3. any relief authorisation that generated a compliance, media or reputational issue;
4. a request from the Board Chair or CFO Advisor;
5. Y1 mechanism-mix targets in s.3 requiring revision in light of operating experience.

11. Adoption and amendment

This Policy is adopted by resolution of the Board. Any amendment requires a further resolution of the Board and must be recorded in the Company's policy register and communicated to all staff and engaged professionals within 14 days.

This DRAFT v1.0 was authored by the Board-Appointed CFO Advisor (Carla Oliver) at Sprint 28 for Board adoption at the next Directors' Meeting.

Version history

• v1.0 · DRAFT · Sprint 28 (Carla Oliver, CFO Advisor · HA1 draft) — Initial draft under Standing Order #3 (project-build mode · launch voice) and Standing Order #4 (full clause 4(a) launch scope). Prepared to accompany Kit-04 Room A consideration copy, which references this Policy as the source-of-truth for LWD's mechanism mix.

Entity, registrations and complaints

Life Without Debt Ltd (in formation) — an Australian public company limited by guarantee, to be endorsed by the ACNC as a registered charity of subtype Public Benevolent Institution, and by the ATO as a Deductible Gift Recipient (Item 1 · s.30-45 Income Tax Assessment Act 1997).

• ABN: pending — see /registrations.json
• ACN: pending — see /registrations.json
• ACNC charity number: pending
• DGR endorsement: pending (Item 4.1.1 · PBI)

Registration numbers on this page are held as placeholders under Standing Order #3 (project-build mode · launch voice) pending issue by ASIC, the ACNC and the ATO. On flip-day the single file /registrations.json is updated with the issued numbers and this footer is regenerated at build time.

Complaints. Beneficiaries, donors, professionals and members of the public may raise a complaint about any relief authorisation, delegated decision or conduct arising under this Policy by writing to the Company Secretary at the registered office of Life Without Debt Ltd. Complaints are handled under the Company's Complaints Handling Policy (Attachment G to the ACNC Registration Application) and, where unresolved, may be escalated to the ACNC (acnc.gov.au/raise-concern).