PALM Approved Employer Gap Analysis
Staff Labour Hire Personnel Co Pty Ltd
PALM Approved Employer Deed (June 2023) & Guidelines v2.1 (March 2026)
58%
Overall weighted maturity
Managed — but vulnerable
Maturity band: 2.5–3.4 average score
A. Mitchell — Operations Manager (Ch 2, 3, 4)
P. Sharma — Payroll Manager (Ch 5)
T. Chen — HR Director (Ch 6, 7, 8, 11, 12, 13)
J. Okafor — Welfare Lead (Ch 9, 10)
Executive Summary
Overall assessment findings
58%
Overall weighted maturity
44%
Average evidence readiness
14pp
Current state vs evidence gap
8
High-priority clauses (score 0–2)
Staff Labour Hire Personnel Co achieved an overall weighted maturity score of 58% across all 12 chapters. This places the organisation in the Managed — but vulnerable band: obligations are generally being met, but controls rely on manual processes and experienced individuals rather than documented, auditable systems.
A 14-percentage-point gap exists between the average current state score (58%) and average evidence readiness (44%). This means the organisation would face significant difficulty demonstrating compliance during a DEWR assurance review — the most material risk identified. Chapters 4, 9 and 13 require immediate attention.
Chapter Overview
Current state vs evidence readiness
Root Cause Analysis
Why gaps exist — aggregated across all respondents
7
Lack of documented process
5
Evidence retention issues
3
Manual process, no monitoring
2
Reliance on key individuals
1
Poor visibility or reporting
1
Requirement not understood
Key insight: The dominant theme across this assessment is a lack of documented process (7 occurrences), compounded by evidence retention issues (5 occurrences). Activities are largely occurring but are not being converted into repeatable, auditable workflows. The priority remediation theme is process documentation and evidence capture — not rebuilding controls from scratch.
Priority Actions
Clauses requiring immediate attention (score 0–2)
| Score | Clause | Chapter | Respondent | Recommended action |
|---|
0 | 4.1.1 No changes without DEWR approval | Ch 4 | A. Mitchell | Establish written DEWR approval checklist before any placement change is actioned |
1 | 4.1.3 Worker written agreement | Ch 4 | A. Mitchell | Create standard consent form; make mandatory in placement change workflow |
1 | 9.1.1 24/7 emergency number | Ch 9 | J. Okafor | Verify line is answered 24/7; document staffing roster and evidence distribution to workers |
1 | 9.12.4 Grievance register | Ch 9 | J. Okafor | Establish formal register with DEWR required fields; assign owner; set monthly review |
1 | 13.1.1 Notify within required timeframes | Ch 13 | T. Chen | Document incident type trigger matrix; assign notification owner; set up PALMIS workflow |
2 | 7.1.1 Organise and pay for travel | Ch 7 | T. Chen | Document PALM airfare matrix process; assign responsibility for per-worker cost tracking |
2 | 8.2.1 Bank, TFN, super, SIM, MyGov | Ch 8 | T. Chen | Create arrival checklist with sign-off for each task; retain completed forms centrally |
2 | 13.4.1 Non-critical reporting by next day | Ch 13 | T. Chen | Define non-critical incident triggers; establish daily review and exception reporting |
Chapter Detail
Selected chapter findings
Assessed by: A. Mitchell — Operations Manager
DEWR prior written approval not consistently obtained before placement changes are implemented — highest risk finding in this assessment
Worker written agreement not documented; consent obtained verbally or informally
PALMIS change submissions completed but without a documented workflow or exception monitoring
Root causes:Lack of documented processPoor visibility or reporting
Assessed by: J. Okafor — Welfare & Wellbeing Lead
Fortnightly welfare meeting records incomplete — meetings occurring but content and follow-up actions not documented
Grievance register not maintained in a format that meets DEWR required data fields
Welfare refresher briefings not delivered at required 3-month, 6-month and annual intervals
Root causes:Evidence retention issuesManual process, no monitoringLack of documented process
Assessed by: T. Chen — HR Director
No documented trigger matrix for the three incident types — staff unclear on Critical, Other and Non-critical thresholds
Evidence of timely PALMIS reporting not centrally retained or monitored
Root causes:Lack of documented processEvidence retention issues
Important notice: This is a sample report for demonstration purposes only. All company names, respondent names, scores and findings are entirely fictional. A real Compliance Console gap analysis report is generated from your organisation's actual assessment responses and reviewed before delivery. It does not constitute legal advice.