COORDINATED COMPLAINTS TRIGGER DEFAMATION PROTOCOL

If multiple parties act in concert to publish or amplify allegations:

• Our Defamation Pre-Action Protocol activates immediately
• Formal Concerns Notices may be issued
• Retraction and removal may be demanded
• Injunctive relief may be sought

We resolve disputes privately and lawfully.

We do not engage in reputational warfare.

We enforce our rights.

1. COORDINATED DEFAMATION = IMMEDIATE PROTOCOL TRIGGER

Where Growth Works forms a reasonable belief that:

• Multiple parties are acting in concert
• Statements are being repeated across platforms
• Messaging appears templated or synchronised
• Complaint escalation is publicly amplified prior to formal notice

The matter will be treated as:

Coordinated Defamatory Conduct

This automatically activates the:

DEFAMATION PRE-ACTION PROTOCOL NOTICE

Under Australian law, including the Defamation Act 2005, Growth Works may:

• Issue a Concerns Notice
• Demand particulars
• Seek retraction
• Require removal of publications
• Pursue aggravated damages

Where coordination is evident, the matter may be escalated without further informal engagement.

2. MANDATORY SEQUENCE BEFORE ANY PUBLIC ESCALATION

Before:

• Publishing allegations
• Encouraging others to complain
• Posting reviews
• Contacting regulators collectively
• Contacting media

The party must:

  1. Submit a formal written Notice of Dispute
  2. Allow the contractual response period
  3. Participate in structured mediation (if required)

Failure to follow this sequence may be relied upon in any subsequent proceedings as evidence of bad faith.

3. NO PUBLIC COMMENTARY DURING ACTIVE DISPUTE

During any unresolved dispute:

• Public allegations are prohibited
• Coordinated review campaigns are prohibited
• Group complaint mobilisation is prohibited

Public commentary during this period may:

• Void goodwill settlement discussions
• Trigger injunctive proceedings
• Trigger indemnity cost claims

This clause operates alongside the Defamation Pre-Action Protocol.

4. AMPLIFICATION LIABILITY

Where an individual:

• Shares
• Reposts
• Endorses
• Republishes
• Encourages others to publish

Potentially defamatory material relating to Growth Works, they may assume liability as a publisher under Australian law.

This applies even if the individual did not originate the statement.

4. AMPLIFICATION LIABILITY

Where an individual:

• Shares
• Reposts
• Endorses
• Republishes
• Encourages others to publish

Potentially defamatory material relating to Growth Works, they may assume liability as a publisher under Australian law.

This applies even if the individual did not originate the statement.

5. INDEMNITY LINKAGE

If coordinated complaint conduct results in:

• Legal expenditure
• PR remediation costs
• Insurance notifications
• Loss of commercial opportunity

Growth Works reserves the right to rely on:

• Contractual indemnity provisions
• Liquidated damages clauses
• Reputation restoration multipliers

This applies whether conduct occurs domestically or internationally.

6. REGULATORY COMPLAINT SAFEGUARD

Nothing in this Policy prevents lawful regulatory reporting made:

• Individually
• In good faith
• With genuine evidence
• Without coordinated amplification

However, orchestrated mass-complaint campaigns designed to exert commercial pressure may be treated as:

• Abuse of process
• Bad faith conduct
• Tortious interference

7. ESCALATION THRESHOLD

1. Immediate Retraction Obligation Upon Defamatory Publication

Where Growth Works forms a reasonable belief that:

• A false statement of fact has been published
• Allegations are misleading or deceptive
• Harm to commercial reputation has occurred
• Statements have been coordinated or amplified

Growth Works may issue a Formal Retraction Demand pursuant to the:

Defamation Act 2005

This operates in conjunction with our Defamation Pre-Action Protocol Notice.

2. Required Retraction Standards

If a publication is found to be false, misleading, or defamatory, the publishing party must:

  1. Remove the content immediately from all platforms.
  2. Publish a clear retraction in the same location and format.
  3. Publish the retraction with equal or greater visibility than the original statement.
  4. Confirm removal in writing within the specified compliance period.

The retraction must:

• Be unambiguous
• Identify the original statement
• Acknowledge the inaccuracy
• Withdraw the allegation in full

Qualified or partial retractions may be rejected.

3. Timeframe for Compliance

Unless otherwise specified in a Concerns Notice:

• 48 hours for digital removal
• 5 business days for formal published retraction

Failure to comply within the stated timeframe may result in:

• Application for injunctive relief
• Proceedings seeking damages
• Claim for aggravated damages
• Indemnity cost recovery

4. Amplification Retraction Requirement

Where defamatory material has been:

• Shared
• Reposted
• Quoted
• Endorsed
• Reproduced

Each publisher may be required to issue an independent retraction.

Liability may attach to secondary publishers under Australian law.

5. Reputation Restoration Cost Recovery

Where public allegations require:

• PR engagement
• Legal response
• Media management
• Digital suppression efforts

Growth Works reserves the right to pursue recovery of:

• Reputation remediation costs
• Legal costs
• Loss of commercial opportunity
• Future revenue impairment

Where applicable, liquidated damages provisions in engagement contracts may apply.

6. Coordinated Complaint Escalation

If defamatory publications form part of:

• A coordinated complaint campaign
• Group-based amplification strategy
• Reputational pressure tactic

The matter may be escalated immediately without further informal resolution attempts.

7. Good Faith Carve-Out

This clause does not prevent:

• Lawful regulatory reporting
• Honest opinion properly based on fact
• Fair comment compliant with statutory defences

However, false factual allegations or reckless publication may remove the protection of statutory defences.