AEN Response to Draft Labour Hire Licensing Regulations 2018


Earlier today the AEN submitted its response for comment on the Draft Labour Hire Licensing Regulations 2018:

The Apprentice Employment Network (AEN) is the peak industry body representing Group Training Organisations (GTOs) across Victoria. AEN’s purpose is to support members and Government to achieve skilled and sustainable employment and training for the wider community.
Within Victoria, GTOs employ over 6500 apprentices and trainees across all industry sectors. The network supports 10,000+ host employers which are mainly small to medium size businesses.

Currently in Victoria there are 24 nationally registered GTOs that are recognised by the Victorian Regulations and Qualifications Authority (VRQA) and the State and Commonwealth Departments of Education. Victorian GTOs also have access to Department of Education funding and payroll tax exemption through the State Revenue Office.

Whilst AEN agree with, and support the Victorian Governments Labour Hire Licensing Bill, we feel it extremely important that GTOs in Victoria are not mistakenly bundled in and regulated within the labour hire industry. AEN believe, there are significant differences between group training and labour hire activities.

The key areas of difference include:

  • GTOs are already registered with VRQA, and Commonwealth Department of Education and the Victorian State Revenue Office under various agreements and payroll tax exemptions and participate in various audit processes across States and at Commonwealth level.
  • GTOs are registered on the national training register and must adhere to the compliance of the national group training standards by the VRQA.
  • GTOs are mainly incorporated associations and other not-for-profit organisation structures and have boards of management that are comprised of local community and industry leaders to ensure ethical behaviour and governance.
  • All employees’ of GTOs are apprentices and trainees who enter into a contract of training with the GTO and Victorian Department of Education.
  • All apprentices and trainees employed under a GTO naturally have a training contract (on the job and off the job) component attached to their employment and is a requirement for successfully completing the qualification which may occur over multiple host employers to ensure the full scope of training experiences is achieved.
  • GTO field officers ensure that apprentices and trainees placed with host employers have greater support, mentoring that traditional labour hire companies do not have.
    Additional support with workplace health and safety, mentoring, workplace entitlements and conditions.

GTOs core business is to support the individual apprentice or trainee through to completion of their training qualification – it is not set up to provide short-term labour.

By not having an exemption for GTOs under the Labour Hire Licensing Act or through the regulations will create confusion in the wider community and will discredit and damage the reputation of GTOs