Aligned to ISO 45003WHS positive duty

Psychosocial risk is a
legal obligation.
Not a wellness initiative.

Every Australian employer has a positive duty to identify and manage psychosocial hazards at work. Officers, including directors, board members, and principals, carry personal liability under s.27 of the WHS Act.

Most organisations in frontline human services cannot evidence compliance. Not because they do not care, but because they do not have the systems to surface what is actually happening.

The positive duty

WHS law requires employers to proactively identify and manage psychosocial hazards, not just respond to complaints. The duty is to prevent harm, not react to it.

Personal liability

Officers can be prosecuted individually, separately from the organisation, for failing to exercise due diligence. This duty is non-delegable. Volunteer board members are not exempt.

The evidence gap

Annual engagement surveys do not satisfy your obligations. You need ongoing hazard identification, consultation evidence, control measures, and verification at the manager level, not in aggregate.

What HR already has

Your engagement survey works for engagement.
The regulator needs something different.

Most HR teams running a wellbeing programme today are stacking three things: an annual engagement survey, an outsourced WHS assessment every eighteen to twenty-four months, and an EAP. Each has its place. None were built to satisfy positive duty.

Annual engagement survey

Culture Amp · Glint · Gallup Q12 · Officevibe

Strong at: Built for engagement, culture and eNPS — useful for HR insight.

Gap for positive duty: Annual cadence. Not mapped to ISO 45003. No hazard register the regulator can audit.

Evidence for the regulator? Insufficient

WHS consultant snapshot

External assessment every 12–24 months

Strong at: Point-in-time psychosocial risk assessment from a credentialed consultant.

Gap for positive duty: Ages immediately. No worker voice between visits. Recommendations rarely operationalised.

Evidence for the regulator? Insufficient

EAP + wellbeing programs

Counselling, mindfulness apps, wellbeing initiatives

Strong at: Direct support for workers experiencing distress. Important downstream provision.

Gap for positive duty: Reactive only. No preventive function. No data on what hazards are driving the distress.

Evidence for the regulator? Insufficient

Just Engage

One platform — replaces two to three of the above

  • All 14 ISO 45003 hazard categories
  • Quarterly cycles, not annual snapshots
  • Live, exportable hazard register
  • Manager-level resolution by default
  • Intervention tracking on the controls hierarchy
  • Evidence framework regulators look for
Evidence for the regulator? Yes — auditable trail

Positive duty rests with the PCBU. Just Engage provides the system of work, the hazard register, and the evidence trail an investigator would ask for. The organisation remains responsible for resourcing interventions and acting on the findings.

For HR teams, Just Engage replaces the annual survey, removes the need for a separate consultant snapshot, and delivers what an EAP cannot: identification of the conditions causing distress before workers reach for crisis support. One subscription replaces two to three line items in your wellbeing and compliance budget — at less than most teams pay today — and produces the evidence both your board and the regulator need.

SafeWork NSW issued over 1,200 psychosocial non-compliance notices in 2025. Engagement data alone is no longer treated as evidence of hazard management.

Your sector

See what this means for your world.

Just Engage is built for sectors where workforce psychological safety directly impacts the people you serve.