If your whole-of-organisation view lives in a spreadsheet, Clause 1.4e of the National Code is going to be difficult to manage.
It’s what we’re seeing across institutes of higher education right now.
Most aren’t starting from scratch. They’re using a mix of tools that already exist across the organisation. Spreadsheets, shared documents, email threads, internal systems. Tools that are familiar, accessible, and already embedded in how teams work.
Individually, they work. Together, they make the big picture nearly impossible to see.
And the big picture is exactly what Clause 1.4e is asking for. So how institutes are higher education actually documenting Clause 1.4e of the National Code?
What is Clause 1.4e?
Clause 1.4e is part of the National Higher Education Code to Prevent and Respond to Gender-based Violence. It requires Institutes of Higher Education to conduct a whole-of-organisation assessment that identifies systemic risks, enablers, and barriers to preventing gender-based violence across the full organisation.
The Code commenced for Australian universities in January 2026 and will commence for Institutes of Higher Education registered under TEQSA in January 2027.
We’ve written more about what the National Code means for higher education here.
Here is the Clause directly from the Act
What Clause 1.4e actually requires
Clause 1.4e requires institutes of higher education to conduct a whole-of-organisation assessment that identifies systemic risks, enablers and barriers to preventing gender-based violence across the full organisation.
That’s not a policy document, a checklist or a training record.
It’s an attempt to understand how the organisation actually operates as a system, and where that system creates risk.
To do that well, you need visibility across the whole organisation. And that’s where the tools most teams are relying on start to create problems.
The tools teams are using and where each one falls short
How institutes of higher education are documenting Clause 1.4e of the National Code.
Spreadsheets
Spreadsheets are the most common starting point. They’re easy to set up, flexible, and good for tracking progress in the early stages.
The difficulty is that they don’t scale well. As more information gets added and more teams get involved, spreadsheets become hard to maintain. Connections between areas of the organisation get lost. Version control becomes a problem. And it becomes increasingly difficult to see how everything fits together.
Documents
Documents are useful for structuring information, easy to share, and good for formal outputs. Many teams use them to write up policies, map processes, and record decisions. Which works.
The problem is that documents are static and when you are managing different parts of the code, it is hard to track anything. They reflect what was true when they were written, not what is happening now. In a fast-moving compliance environment, they go out of date quickly and stop reflecting what is actually happening in practice.
Email and conversations
Email captures real discussions. It enables collaboration, clarifies responsibilities, and creates a record of decisions being made in real time.
But that record is buried. Decisions made over email don’t have a consistent structure. They’re hard to find, hard to reference, and invisible to anyone who wasn’t part of the original thread.
When staff change, that institutional knowledge often disappears with them.
Internal systems
Internal systems contain real data. They reflect actual activity, track interactions, and can be useful for identifying trends over time.
The challenge is that they sit in isolation. Student management systems don’t talk to HR systems. Incident reporting tools don’t connect to training records. Hard to see patterns across the organisation as a whole when the data is spread across systems that were never designed to work together.
What this means for Clause 1.4e
The challenge isn’t whether the work is being done. It’s that the work sits across multiple tools, teams and systems. Which makes it difficult to see how everything connects, where the gaps are, and whether you have a clear, organisation-wide view to demonstrate.
We understand this work is time consuming. It often starts in spreadsheets, shared documents, and long email threads trying to piece together what exists and who owns what. What starts as a practical way to get visibility can quickly become difficult to manage. Multiple versions, unclear ownership, and gaps that are hard to see unless you already know where to look.
And even when everything is pulled together, it is still difficult to answer the core question.
What does this actually tell us about how prevention is working across the organisation?
Where to go from here
The tools you’re using aren’t the problem. The gap is having something that brings them together into a view you can understand, act on, and demonstrate.
That’s what we built CapyBenchmark for. To give organisations a clear, structured view of how prevention operates across the organisation, so you can get on with the work that matters and advocate for what you need, backed by a clear chain of evidence.
What tools are you using to navigate the National Code? We’d love to hear what’s working and where things are getting difficult.
