If you’re working through the National Code, Clause 1.4e is probably the requirement giving you a fair bit of work.
It isn’t unclear, but it is ambiguous and hard to determine if you are “doing it right”.
We want to break down what Clause 1.4e actually asks of your organisation, where most teams get stuck, and a practical place to start.
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 the requirement actually involves
Most Institutes of Higher Education reading Clause 1.4e understand the headline requirement.
You need a whole-of-organisation assessment that identifies systemic risks, enablers, and barriers to preventing gender-based violence.
What’s less clear is what carrying out that assessment actually involves.
A whole-of-organisation assessment is not a document. It’s not a policy review or a training audit. It’s an attempt to understand how your organisation functions as a system, and where that system creates risk.
That’s a different kind of work with a lot of moving parts. And it’s why many teams, even those who have already updated policies, delivered training, and mapped out action plans, find themselves uncertain when they reach Clause 1.4e.
The challenge isn’t understanding the requirement of Clause 1.4e in the National Code
This comes down to the confidence in application.
Many teams feel like they have no clear view of where systemic risk sits across the organisation. Prevention efforts are disconnected across teams. There’s limited visibility into what’s working. And there’s real uncertainty about what “good” looks like, especially when audit and reporting time comes around.
That uncertainty makes sense.
Clause 1.4e is asking organisations to do something genuinely different: to demonstrate not just that prevention exists, but that the organisation understands how prevention works, what is working, what is limited, and why.
Where to start
If you’re just beginning your work on Clause 1.4e, the most important thing to know is this: you don’t need to build a whole new way of working.
Your role, at least at the start, is to understand what already exists and how it operates.
Step 1 is to map the key areas of your organisation where prevention sits.
This means identifying the functions that are relevant to gender-based violence prevention. Governance and leadership, student services, HR, accommodation and any other teams or functions that touch the safety and wellbeing of your students and staff.
This sounds straightforward.
In practice, it takes longer than expected (and many tools to bring it all together).
Prevention (and response) doesn’t sit neatly in one team. It’s distributed across the organisation in ways that aren’t always obvious from an org chart.
Some teams have formal responsibilities. Others have informal ones. Some hold critical data. Others own relationships or environments that matter significantly for risk.
Mapping this means asking: which parts of the organisation are involved in prevention, even indirectly? Where do students and staff go when something happens? Who owns the policies? Who delivers the training? Who manages the spaces?
The goal at this stage is not a perfect picture. It’s a working map. Something that gives you visibility across the organisation so you can start to see where risk sits, where gaps exist, and where the work needs to go.
Why taking it back to the “basics” matters with Clause 1.4e
Without it, the rest of the assessment is guesswork.
You can’t identify systemic risks if you don’t know which systems you’re looking at. You can’t find barriers to prevention if you don’t know where prevention is supposed to be happening. You can’t demonstrate a whole-of-organisation understanding if you’re working from a partial view.
Step 1 gives you the foundation everything else builds on.
It also gives you something concrete to show. A clear map of organisational functions, with ownership and relevance to prevention documented, is itself meaningful evidence of the kind of structured, intentional approach Clause 1.4e is looking for.
What comes next
Once you have a working map, the assessment moves into understanding risk across those areas, identifying what’s currently in place, and starting to see where gaps and disconnects exist.
That’s where the work gets more complex, and where having a clear process matters most.
We’ve put together a step-by-step guide to the full Clause 1.4e assessment process, covering all seven steps from initial mapping through to building an organisation-wide view you can report on and act from.
