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Introduction

An introduction to the phases of the independent review

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In late October 2020, following public allegations of discrimination, sexual harassment, bullying and victimisation at Ambulance Victoria, the Victorian Equal Opportunity and Human Rights Commission (the Commission) was engaged by Ambulance Victoria to conduct an Independent Review into Workplace Equality in Ambulance Victoria under section 151 of the Equal Opportunity Act 2010 (Vic).

Workplace discrimination, sexual harassment, victimisation and bullying are unlawful and the Commission has deep experience in conducting large-scale reviews, particularly in relation to these workplace equality issues.


The terms of reference established for the Independent Review directed the Commission to:

  • examine the nature, extent, drivers and impacts of discrimination, sexual harassment, bullying and victimisation

  • consider the adequacy of Ambulance Victoria’s response to such unlawful conduct

  • identify leading practice strategies to ensure a safe, equal and inclusive organisation that promotes positive workplace systems, values and behaviours.

Ambulance Victoria’s Board formally endorsed the terms of reference on 30 November 2020.


The Commission has undertaken this work in 3 phases. This multiphase model has seen the Commission work closely with Ambulance Victoria over the last 4 years: firstly, by providing a deep examination of the state of workplace equality and delivering targeted recommendations for positive change in Phase 1; then walking alongside Ambulance Victoria as a ‘critical friend’ in Phase 2 as it commenced implementing the reforms; and finally delivering an evidence-based and transparent assessment of implementation progress during the Phase 3 Progress Evaluation Audit.

Phase 1 – Examine the state of unlawful and harmful conduct and (in)equality and identify strategies to ensure the workplace is safe, equal and inclusive


During Phase 1 (between December 2020 and March 2022), the Commission spoke to many current and former members of the Ambulance Victoria workforce as well as volunteers, to understand their experiences of discrimination, sexual harassment, victimisation and bullying.

In late 2021, the Commission requested a variation to the terms of reference to deliver the Phase 1 Report in 2 volumes. This was to ensure that the Commission could properly consider all the information provided by the larger than anticipated number of employees and first responders who shared their experiences and views with us.

Volume I

Volume I of the Phase 1 Report was published publicly on the Commission’s website on 30 November 2021 and details our findings and recommendations in relation to safety, respect and trust. This includes the Commission’s findings in relation to:

  • the nature, extent, drivers and impacts of discrimination, sexual harassment, bullying and victimisation at Ambulance Victoria

  • how safe and respected Ambulance Victoria’s employees and first responders feel in the workplace

  • the adequacy of Ambulance Victoria’s response to reports and complaints of unlawful conduct.

Volume II

Volume II of the Phase 1 Report was published publicly on the Commission’s website on 31 March 2022 and details our findings and recommendations in relation to equality, fairness and inclusion within the organisation. This includes the Commission’s findings and recommendations in relation to:

  • equal representation, pay and progression

  • flexibility, accessibility, support for parents and carers, and transition to retirement

  • organisational capability, leadership development and continuous improvement.

Phase 1 of the Review resulted in 43 recommendations across these 2 volumes, highlighting the immediate steps that Ambulance Victoria could take to improve safety, respect, trust, equality, fairness and inclusion.

Ambulance Victoria’s response to Phase 1

Following the release of Volume II of the Phase 1 Report, Ambulance Victoria publicly committed to implementing all 43 of the Commission’s recommendations. Through a public apology, Ambulance Victoria promised to address the substantial discrimination, sexual harassment, bullying and victimisation identified in Phase 1 of the Review and to embrace operational and cultural change.


In July 2022, Ambulance Victoria released Safe, Fair and Inclusive: Your AV Roadmap 2022–2027, which aimed to communicate the organisation’s strategy and commitment to implement the intent of the Commission’s recommendations. This has since been revised to reflect an Outcomes Focussed Model.

Phase 2 – Provide support to implement the Phase 1 recommendations


Following the release of the Phase 1 Report and during the period March 2022 to June 2024, the Commission provided expert advice and guidance to Ambulance Victoria as it began work to implement the recommendations.


Ambulance Victoria and the Commission agreed on guiding principles and parameters for working together during this phase of the Review:

  • ethical – acting with impartiality and integrity

  • transparent – a 'no surprises' approach that applies rules of natural justice

  • evidence-based and intersectional – advice is informed by evidence and the principles of intersectionality

  • independent – maintaining our relationship as a 'critical friend' and not stepping into the shoes of Ambulance Victoria decision-makers.


The Commission met regularly with Ambulance Victoria and provided advice, on request, across a range of recommendations. The Commission also clarified the intent of several Phase 1 recommendations and agreed to variations to some recommendations, where there was a reasonable basis to make adjustments.


This engagement model ensured that the Commission could build on the guidance and recommendations delivered in Phase 1, supporting Ambulance Victoria to understand the intent behind the proposed reforms and explore options for meaningful implementation. It also allowed the Commission to act as a ‘critical friend’ to Ambulance Victoria by delivering honest and expert feedback on proposed approaches and outputs, as requested.


Importantly, Phase 2 was not about providing proscriptive or directive advice to Ambulance Victoria or seeking to step into the shoes of Ambulance Victoria’s decision-makers. The Commission’s approach was to preserve Ambulance Victoria’s organisational discretion and strengthen organisational capability to embed the reforms by offering advice and options for consideration.

Phase 3 – Assess the extent to which the priority recommendations are implemented and identify any areas for improvement


Phase 3 commenced in June 2024 and was completed in November 2024. The purpose of Phase 3 was to determine the extent to which Ambulance Victoria has moved towards compliance with the Equal Opportunity Act 2010 (Vic). This time also marks roughly the midway point of the 5-year strategy that Ambulance Victoria has set itself to fully implement and embed the reforms recommended in Phase 1.


The Commission was originally requested to deliver Phase 3 of the Review by November 2023. However, in January 2023, acknowledging the significant number of Phase 1 recommendations and the early stage of implementation progress, the Commission and Ambulance Victoria agreed to postpone Phase 3 to June 2024, with a public report to be delivered by 30 November 2024.


Prior to Phase 3, the Commission considered which recommendations were a priority for implementation and would therefore be critical to assess during the Phase 3 Progress Evaluation Audit. Accordingly, 25 priority recommendations were selected by agreement with Ambulance Victoria (see Methodology).


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