Cultural Competence, Cultural Safety
and Pacific Responsiveness Policy

Policy owner	Director, The Engine Limited
Approved by	Catherine Cooke, Director July 2026
Effective date	1 July 2026
Review cycle	Annual, and earlier if legislation, contracts or delivery needs change
Next review	1 July 2027
Supersedes	Cultural Competence in Strategy and Strategic Planning – effective 1 July 2019, updated annually

1. Purpose

The Engine works with people whose culture, language, identity, family, community, faith, migration history, generation and lived experience can shape how they engage with business support. This policy sets the minimum standard for culturally competent, culturally safe and responsive practice across The Engine’s advisory, coaching, education, consulting, governance, events, digital services and partner/provider activity.

The purpose is not to claim expertise in every culture. It is to create disciplined practice: ask rather than assume; recognise power and bias; adapt delivery; use appropriate cultural expertise; protect dignity and choice; measure the client’s experience; and continuously improve.

2. Scope

This policy applies to directors, employees, advisors, facilitators, contractors, partner providers, volunteers and any person representing The Engine in client or community delivery. Contracted specialists are expected to meet these standards when delivering under The Engine’s name.

3. Definitions

Cultural competence: The knowledge, skills, behaviours and reflective practice needed to work effectively and respectfully across cultures.

Cultural safety: An environment in which the recipient of a service determines whether the interaction feels respectful and safe; it requires attention to power, bias, discrimination and the impact of provider behaviour.

Cultural responsiveness: Adapting communication, relationships, service design and delivery to the client’s cultural context, needs and preferences.

Pacific / Pasifika: An umbrella term covering diverse Pacific peoples and cultures. It must never be treated as one homogeneous identity.

Talanoa: A relational, open form of dialogue used across Pacific contexts. In this policy it means making space for story, context, relationship and shared understanding before rushing to solutions.

V? / relational space: A Pacific concept, expressed differently across cultures, concerning the relationship or space between people and the responsibility to care for that relationship.

4. Policy principles

• Respect and dignity – every client is treated as the expert in their own identity and context.
• Ask, do not assume – ethnicity does not determine language, protocol, family involvement, faith, business ambition or preferred way of working.
• Relationship and trust matter – effective business advice depends on the quality of the relationship as well as technical competence.
• Strengths-based practice – recognise capability, resilience, entrepreneurship, community contribution and existing knowledge, while still providing clear commercial challenge.
• Equity and accessibility – identify barriers and adapt delivery so clients have a fair opportunity to participate and benefit.
• Client choice and consent – clients decide what cultural, family, community or faith context is relevant to their engagement.
• Right expertise – The Engine will not represent a person as culturally or linguistically competent where that capability is not held. Appropriate cultural practitioners, interpreters or partners will be used when needed.
• Accountability – cultural responsiveness is measured through behaviour, feedback, outcomes, complaints and improvement actions, not merely policy statements or training attendance.

5. Pacific responsiveness standard

For Pacific entrepreneurs and organisations, The Engine applies the following additional delivery standard. These practices are informed by Pacific approaches that place relationships, culture, language, identity and community at the centre, including talanoa and relational concepts such as the v?. They are applied with humility because practices differ between and within Pacific cultures.

5.1 Diversity within Pacific peoples

Do not use a single ‘Pacific client’ template. Ask how the client identifies and what, if any, cultural protocols, language preferences, family/community relationships or faith considerations should shape the engagement.

5.2 Relationship before transaction

Allow appropriate time for connection, introductions and trust. Avoid beginning with a rigid checklist when relational engagement is needed. Explain the advisor’s role, confidentiality, scope and expectations clearly.

5.3 Talanoa-informed engagement

Use open questions and listening to understand the entrepreneur’s story, aspirations, obligations, strengths, pressures and definition of success. Summarise back and confirm understanding before prescribing solutions.

5.4 Respecting the v?

Treat relationships as an active responsibility. Communicate respectfully, keep commitments, address misunderstandings early, avoid public embarrassment, and recognise that trust can be affected by how issues are handled as much as by the technical advice itself.

5.5 Family, collective and community context

Where the client wishes, include relevant family/aiga/kainga or trusted supporters in planning and decision-making. Do not assume collective involvement is required. Confirm who has authority to decide and protect the client’s confidentiality.

5.6 Language and communication

Ask the client’s preferred language and communication method. Use plain language, explain technical business terms, and provide Pacific-language support through appropriately skilled people when required and feasible. Do not rely on family members to interpret sensitive or complex matters where professional language support is more appropriate.

5.7 Faith and community

Recognise that church, faith and community can be important sources of identity, trust and obligation for some Pacific clients. They should be acknowledged when the client identifies them as relevant, never presumed.

5.8 Commercial challenge with cultural respect

Cultural responsiveness does not mean avoiding difficult business conversations. Advisors should respectfully address pricing, cashflow, debt, tax, compliance, employment, governance and sustainability, explaining the commercial consequence and working with the client on realistic actions.

5.9 Pacific expertise and co-delivery

Where an engagement would benefit from deeper Pacific cultural, community or language expertise, The Engine will seek an appropriately experienced Pacific advisor/facilitator/partner. Their role and expertise should be substantive and appropriately recognised.

5.10 Accessible delivery

Offer practical options such as in-person/online delivery, reasonable scheduling flexibility, visual or plain-language tools and staged actions where these improve engagement. Accessibility changes must remain consistent with contractual scope and professional obligations.

6. M?ori responsiveness and Te Tiriti awareness

The Engine recognises the distinct status of M?ori as tangata whenua. M?ori cultural responsiveness is not interchangeable with Pacific responsiveness. Engagement with M?ori clients should respect tikanga, whanaungatanga, whakapapa, wh?nau context, te reo M?ori and client preferences, and should be supported by appropriate M?ori expertise where required. The Engine will continue to build its understanding of Te Tiriti o Waitangi and its relevance to organisational relationships and service delivery.

7. Other cultures and intersectionality

The same core disciplines apply across all cultures: curiosity, respect, client-defined identity, accessibility, appropriate expertise and reflective practice. People may hold multiple identities and experiences at once. Advisors should avoid reducing a client’s business needs to ethnicity, and should consider generation, disability/access needs, gender, socioeconomic context, migration experience and other relevant factors only where the client identifies them or they materially affect delivery.

8. Service delivery requirements

Referral / intake: Record preferred name and pronunciation where offered; communication and language preference; accessibility needs; relevant cultural considerations; consent for any family/support-person involvement; and any request for a culturally matched practitioner.

Assessment: Use business capability evidence while allowing relational context. Separate assumptions from facts. Ask what success looks like to the client and what constraints may affect implementation.

Support planning: Agree practical outcomes, responsibilities, timeframes and evidence. Check that the plan is understood and realistic within the client’s context.

Delivery: Use culturally appropriate examples and communication. Explain technical terms. Check understanding without embarrassment. Adapt pace and format where reasonable.

Monitoring: Track actions and business outcomes, but also engagement, barriers and client experience. Where non-engagement occurs, explore barriers respectfully before labelling a client as unwilling.

Closure / transition: Confirm what capability has been transferred, what the client can now do independently, what remains, and whether a culturally appropriate onward referral is needed.

9. Workforce, advisor and provider capability

The Engine will maintain a capability matrix for people delivering services, including technical expertise, cultural experience, languages, communities/regions, training and any limitations. Cultural competence is not inferred solely from ethnicity.

• Induction includes this policy, bias/power awareness, respectful communication, privacy/confidentiality and complaint escalation.
• Pacific-facing delivery includes Pacific-specific learning on diversity of Pacific cultures, relational practice, talanoa, language/access and avoiding pan-Pacific assumptions.
• Learning should include Pacific-led content or facilitators where practicable.
• People are expected to reflect on mistakes, seek advice early and participate in corrective learning where feedback identifies a gap.
• Recruitment and contracting should consider cultural and language capability alongside technical business expertise, without tokenism.

10. Community engagement and co-design

Where The Engine designs programmes for a specific cultural community, it should involve people from that community early enough to influence the design, not simply validate a finished product. Engagement should clarify purpose, decision rights, how feedback will be used, and how contributors will be acknowledged or remunerated where appropriate.

For Pacific-focused programmes, engagement should seek diversity across Pacific cultures, age/generation, gender, region and business stage where relevant, rather than relying on one person to represent all Pacific perspectives.

11. Data, privacy and cultural information

Cultural identity, language and community information should only be collected where there is a legitimate service, reporting or relationship purpose. Explain why it is being collected and how it will be used. Access must be limited and records handled consistently with The Engine’s Privacy Policy, contractual requirements and applicable New Zealand privacy law.

Reporting should avoid deficit framing. Where ethnicity data is used to understand outcomes or access, it should support service improvement and equity, not stereotype individual clients.

12. Complaints, cultural concerns and repair

A client may raise a cultural concern verbally or in writing. The Engine will acknowledge it promptly, listen without defensiveness, record the concern, assess immediate risk, and agree the appropriate response. Where helpful and feasible, the client may have a support person or culturally appropriate person involved.

Resolution may include clarification, apology, change of advisor, corrected communication, service adaptation, further training, partner review or escalation to the Director/funder/contracting agency. The objective is both fair resolution and learning. Serious discrimination, harassment, privacy or safety matters must be escalated under the relevant policy and law.

13. Measurement and evidence

The Engine will evidence cultural responsiveness through more than training records. Measures may include:

Measure	Example evidence	Review
Client experience	Feedback on respect, trust, accessibility, understanding and usefulness	At engagement close and periodic programme review
Access / engagement	Attendance, completion, re-engagement, language/access needs met	Quarterly
Outcomes	Leave-behind results and economic/business outcomes by relevant cohort where appropriate	Quarterly / contract reporting
Workforce capability	Training, reflective practice, language/cultural capability matrix	At least annually
Quality / complaints	Cultural concerns, themes, resolution and corrective action	Quarterly and immediately for serious matters
Community voice	Co-design/consultation records and changes made because of feedback	Per programme / annual policy review

14. Governance and responsibilities

Director: Owns this policy; ensures resourcing, risk oversight, complaints escalation and annual review; approves material changes.

Advisors / facilitators: Apply the policy in practice, seek support where outside competence, document relevant client preferences and respond to feedback.

Contractors / partner providers: Meet The Engine’s standards for work delivered under The Engine arrangements and disclose any capability limitation or conflict.

Programme / contract lead: Ensures culturally responsive design, matching, records, reporting, evidence and corrective actions for the relevant programme.

15. Continuous improvement and review

This policy will be reviewed at least annually. Review inputs will include client feedback, Pacific and M?ori practitioner/community input where relevant, complaints, outcome data, workforce capability, changes in law or contracting expectations and lessons from delivery.

The annual review will produce documented actions, owners and due dates. Material gaps will not wait for the annual cycle.

16. 2026 implementation actions

• Approve and publish this replacement policy.
• Create a cultural capability matrix for advisors and specialist providers, including Pacific cultural/language capability and limitations.
• Introduce intake fields for language, communication, accessibility and culturally relevant support preferences.
• Develop a Pacific engagement checklist and short talanoa-informed first-session guide.
• Identify Pacific advisors/facilitators/interpreters or partner organisations available for substantive co-delivery when required.
• Add cultural responsiveness questions to client feedback and complaints reporting.
• Review website wording to remove encoding errors and outdated 2019 references and to distinguish M?ori and Pacific responsiveness.
• Undertake Pacific-led learning for personnel likely to deliver Pacific-focused contracts.
• Review privacy, H&S, complaints, data quality and business continuity policies so they align with current government/provider due-diligence expectations.

17. Reference framework and sources

This policy has been refreshed with reference to current New Zealand practice and Pacific-led concepts, including Ministry for Pacific Peoples material that centres Pacific voices, values, culture, language and identity, and recognises foundational Pacific wellbeing frameworks such as Fonofale, Ta Vaka Atafaga and Mana Moana. These frameworks inform cultural humility and relational practice; The Engine does not claim to reproduce or own them.

Key public references:

• Ministry for Pacific Peoples – All-of-Government Pacific Wellbeing Strategy and Pacific Wellbeing Talanoa resources.
• Ministry for Pacific Peoples – Pacific Aotearoa Lalanga Fou.
• Ministry of Education – Tapas?: Cultural Competencies Framework for Teachers of Pacific Learners (used as a useful cultural-competency reference, not as a business-service accreditation standard).
• The Engine Privacy Policy, Health & Safety arrangements, complaints procedure and other operational policies [cross-reference current versions].

18. Contact

Catherine Cooke | Director, The Engine Limited
businessadvice@theengine.biz | 09 869 3990 | https://theengine.biz