Club Governance Code of Practice

The Club Governance Code of Practice sets out common standards of conduct for all Member Clubs, with a specific focus on corporate governance.

About the code

The Club Governance Code of Practice (the Code) outlines Member Clubs’ key governance obligations in their dealings with their Members, visitors and the community. A Member Club means a registered club that is a member of ClubsNSW. For the purposes of the Code process:

• A Member means an individual member of a Member Club
• A complainant is a Member who lodges a complaint under the Code.

All Member Clubs operate under their own constitution (or equivalent) and must also comply with a wide range of state and federal laws including the Registered Clubs Regulation 2025 (NSW) (the Regulation). Member Clubs are also expected to meet evolving expectations of Members and the club community.

It is a plain‑English document designed to assist Member Club boards, management and staff to meet these responsibilities. Compliance with the Code is a condition of membership of ClubsNSW. While the Code is administered with administrative support from ClubsNSW, it is overseen and determined by an independent Code Authority.

The Code was first introduced in July 2005 and is subject to regular review to ensure it remains aligned with current laws and evolving community expectations. The current version of the Code was published in February 2023.

The Regulation commenced on 1 September 2025. ClubsNSW is currently engaging with Liquor & Gaming NSW to update the Code to reflect changes arising from the Regulation, together with other minor amendments.

Where there is any conflict or inconsistency between the Code and any state or federal legislation or regulation, the legislation or regulation will prevail to the extent of the conflict or inconsistency.

Further details about the application of the Code can be found in Part A of the Code, which can be accessed via the “View the Code” button located at the top of this page.

View FAQs

How does the code help?

Who oversees the code?

The Code Authority is an independent panel established under the Code. Its highly experienced members bring decades of collective experience across law, policy, governance and the club industry.

The Code Authority’s role is to independently oversee, determine and enforce the Code. In doing so, it supports high standards of governance across Member Clubs and helps maintain confidence both within the club industry and the broader community.

ClubsNSW provides administrative support only. This supports the Code Authority’s independence and objectivity. The Code Authority acts as a neutral decision-maker for complaints within the Scope of the Code and provides guidance to Member Clubs and their Members.

How are complaints assessed?

The Code Administrator applies a robust and proportionate approach to assessing the validity of complaints and determining which complaints warrant further action in all of the circumstances.

The Code Administrator seeks to ensure complaints are handled efficiently and that resources are applied proportionately to matters that raise serious or substantiated concerns. Efforts are directed towards achieving practical outcomes, including meaningful change where appropriate.

In doing so, the Code Administrator is guided by the following principles:

• Complaints are most effectively addressed when assessed in a timely manner
• Complaints can only be properly assessed where sufficient information is provided and required processes have been followed
• Some complaints may identify broader or systemic issues that are more appropriately addressed through guidance, engagement or systemic review rather than individual escalation
• Where a complaint relates to a matter already under assessment or subject to another process or proceeding, consideration of the complaint may be deferred
• Some complaints, including those that may technically establish a breach, may not warrant further action in all the circumstances, particularly where they are low impact or do not justify the proportionate use of resources

Not all complaints will proceed beyond assessment. In exercising its discretion, the Code Administrator will have regard to the objectives of the Code.

What a complainant needs to do before lodging a complaint

Before lodging a complaint with the Code Administrator:

• The Member should first raise the matter with the relevant Member Club and allow a reasonable opportunity, generally 30 days, for response and resolution
• Genuine attempts by both parties to resolve the issue are expected
• The Member should ensure they have read the Code and FAQs before lodging the complaint

If the complaint cannot be resolved through these steps, it may be submitted to the Code Administrator for assessment. The Code Administrator has the discretion to uphold, not uphold, dismiss or refer a complaint to the Code Authority based on all of the material submitted by all parties.

What you need to provide when lodging a complaint

To enable timely assessment, in the online Code Breach Allegation Form Members will need to provide us with all of the necessary information from the outset:

• The Member’s name
• The Member’s contact details
• The Member’s current Club Membership number for the Member Club detailed in the complaint,
• The identity of the Member Club the complaint is about
• Details of the specific and relevant section(s) of the Code alleged to have been breached by the Member Club
• A clear description of the alleged breach including details of the conduct, date of the incident, impact of the incident
• Details of any complaint made to the Member Club and any response received and genuine attempts made with the Member Club to resolve the issue
• Copies of supporting material including documents or correspondence
• Details of how the supporting material is relied upon the outcome sought
• Details of whether the complaint about the Member Club has been made to another organisation or a government agency or if legal action is pending

What you need to be aware of when lodging a complaint

The Code Administrator has discretion to determine whether to proceed with, continue or discontinue the assessment of a complaint, having regard to all of the circumstances.

This may involve:

• Seeking further information from the complainant or Member Club
• Resolving the matter through early engagement
• Determining that no further action will be taken, including providing reasons

A clear‑eyed look at constraints and outcomes

It is important for Members to understand the potential outcomes of the assessment process:

• Where a Member Club has already offered a reasonable resolution, the complaint is unlikely to proceed further
• Where a Member Club has previously addressed the issue sufficiently to the Member, the complaint will not progress
• Not all complaints will result in further action or sanctions
• Complaints may be paused or deferred where they relate to matters already under assessment or subject to other processes
• Delays may arise where complaints intersect with broader or systemic issues under consideration
• Complaints that do not contain sufficient information not progress or may be assessed on the limited material submitted

The Code Administrator adopts this approach to support the effective operation of the Code and ensure resources are directed towards matters of significance.

Code authority meeting timing

The Code Authority meets approximately quarterly. Having regard to this schedule and the time required for Member Clubs to respond, the complaint process may take longer and, in some instances, exceed six (6) months depending on the complexity. Member Clubs and complainants are not required to, and do not have a right to, appear before the Code Authority.

What complaints are dealt with under the code?

The Code covers a wide range of complaints relating to Member Club governance, including board elections, complaints handling, the conduct of disciplinary proceedings, financial reporting, executive remuneration, procurement of goods and services, major capital works, overseas travel and board operations.

Where a Member considers that an issue may involve a potential breach of the Code by the Member Club, information about the Code process (including how to raise a complaint) is available on this website and in the ‘Frequently Asked Questions’ (FAQs) document that is linked at the top of this page.

Please note:

• Complaints are progressed in the order in which they are received, subject to all information and documents being provided by all parties
• Complaints are not expedited on request
• Mandatory Code requirements apply and will not be waived
• Complaints that incorrectly identify Code sections will not progress
• Complaints that are not properly supported will not progress, unless determined otherwise by the Code Administrator or Code Authority based on the material available
• As the Code process is based on written submissions, a complaint will not progress until the required material has been provided to, and received by the Code Administrator, unless determined otherwise by the Code Administrator or Code Authority based on the material available.
• Anonymous complaints, complaints by non-members, or requests by a Member for their identity not to be disclosed to the Member Club will not be accepted.

Lodging a code breach allegation

All Code Breach Allegations must be submitted using the secure online form, which can be accessed via the ‘Code Breach Allegation Form’ link below.

What issues are not dealt with under the code?

The Code does not deal with issues that fall outside the governance framework of registered clubs or that are otherwise governed by applicable legislation or regulation. This includes, for example, personal disputes between Members and a Member Club where no governance issue arises, employment‑related matters, operational matters, commercial disputes with third parties and complaints that are more appropriately dealt with through a legal or regulatory process or are currently under investigation by another organisation, government agency or regulator.

Complaints that are incomplete and lack supporting material from either the complainant or the Member Club will not progress through the Code assessment process or may be determined based on the material available. It is therefore important that parties cooperate with the Code process at all times to enable resolution.

The Code does not replace a Member Club’s internal grievance or disciplinary processes, nor does it override a Member Club’s constitution, bylaws or rules, or decisions made by Member Club boards in disciplinary proceedings.

What the code does not do

The Code does not conduct financial or forensic investigations of Member Clubs, as this falls outside the scope of the Code. The Code Administrator and the Code Authority do not have any powers to compel the production of documents or CCTV footage, conduct audits, site visits, interviews or independently verify the accuracy or completeness of club accounts or financial records.

The Code does not provide legal advice, determine civil liability or award compensation. The Code Administrator and the Code Authority do not act as an advocate for any party and do not assess issues that fall outside the scope of the Code. Where an issue falls outside the Code’s remit.

The Code Authority determines complaints based on an assessment, relying on information and supporting material provided by the complainant and the Member Club. Complainants must clearly identify the alleged breach of the Code and provide relevant supporting evidence with each allegation made.

Complainants must first raise the issue with the Member Club and provide evidence demonstrating reasonable attempts to resolve the issue directly before lodging a complaint under the Code.

Complaints that incorrectly reference the Code, misapply Code provisions, or do not relate to issues within the scope of the Code will not progress. The Code Administrator has observed an increase in complaints generated using artificial intelligence tools that contain incorrect or unreliable references to the Code. Complaints of this nature will not progress where they do not accurately identify a potential breach of the Code and are not properly supported by evidence.

Engagement with the code process

All correspondence with the Code Manager, Code Administrator and the Code Authority is expected to be polite, professional and constructive. Communication that is dismissive of, or seeks to undermine, the Code process may limit the ability of the Code Administrator or the Code Authority to assess a complaint effectively. The use of offensive or abusive language of any kind in any discussions or in any correspondence will not be tolerated, will not receive a response and may result in the termination of the complaint.

Code breach allegation form

Complainants must hold a current Club Membership for the Club detailed in this complaint. Any complaints received from non-members or anonymously (or any request by a complainant for his/her name not to be shared with the Club) are unfortunately unable to be considered.

Before you begin, please ensure you have all relevant information and supporting documents available. The form cannot be saved and returned to later.

Complete form

Further information

Access information about the Code, FAQs and details on how to raise an alleged breach of the Code using the buttons above on this page.