Are Immigrant Women Visible in Australian Domestic Violence Reports that Potentially Influence Policy ?

Through an intersectional lens, this article explores whether immigrant women are represented in a sample of Australian government documents aimed at providing information about family violence in Australia, and discusses implications for policy development. The authors find that while these documents pay lip service to the special vulnerabilities of immigrant and refugee women; arguably, they do not engage with the complexities of the intersection of gender and other social categories. Given that the reports do not focus adequately on how race, ethnicity, culture and immigration status play a role in these women’s experiences of domestic violence, this may limit the effect of policies that address the culturally and linguistically diverse (CALD) victims’ needs and rights to protection. We argue that a more intersectional approach is necessary to address CALD women’s specific needs.


Introduction
Many of the nuances concerning violence against immigrant and refugee women and their vulnerability are neglected in Australian domestic violence (DV) policy despite the presence of growing numbers of culturally and linguistically diverse (CALD) people.The failure to engage with the complexities of the intersection of gender with race, ethnicity and immigration status in these women's experiences of DV contributes to their exclusion and invisibility and damages their right to protection.Therefore, to enhance the quality of domestic and family violence policies, it is important to find out what inequalities are considered besides gender, and how these inequalities are conceptualized and connected to violence (Hearn et al. 2016).To do this, we employ an intersectional approach and examine how multiple inequalities may be made either visible or invisible across a sample of five recent Australian domestic and family violence reports.These reports were drafted or funded by governmental bodies with the intent of guiding policy formulation and implementation.
The first part of the article discusses the relevance of intersectionality in the creation of sound domestic and family violence policy.We see how 'culturalisation' (which describes a process where 'culture becomes the framework used by white society to pre-empt both racism and sexism') (Razack 1998, p. 60;Verloo and Walby 2012) contributes to DV being framed as an inherent part of 'other' cultures.We then turn to the potential vulnerabilities of CALD women.These include how DV is named and defined, the different kinds of CALD-specific abuse such as immigration law-related violence and extended family abuse, specific types and effects of DV and the main barriers to help-seeking.This section is followed by our methodology, findings and discussion concerning whether these specific intersectional issues are being addressed in the sample of reports-in their general text and in their recommendations.We conclude by stressing the need for CALD women's visibility and inclusion in policies with the premise that the application of an intersectional approach in policy-making can improve their quality and their impact (Lombardo and Mieke 2009).

Intersectionality, Domestic and Family Violence and the Quality of Policy
Australia is one of the most multicultural countries in the world with 49% of its population either born overseas or having one or both parents born overseas (Australian Bureau of Statistics 2016).Research has repeatedly reinforced the need for domestic violence policies which are responsive to this diversity (Stubbs and Wangmann 2017) given that the nature and impacts of family abuse may be compounded by different forms of marginalisation for diverse groups of women such as CALD women (Mitra-Kahn et al. 2016).Indeed, battered women's oppression is often multiplied by their location at the intersections of particular race, ethnic, class, gender, sexual orientation, and immigrant systems of oppression and discrimination (Crenshaw 1994;Sokoloff and Dupont 2005;Sokoloff and Pratt 2005).Intersectionality is a way of understanding 'the diversity and multiplicity of the experiences of women of colour in terms of identity, social location, and structural barriers that are based on multiple forms of oppression' (Mehrotra 2010, p. 420).
From an intersectional approach then, no factor alone describes DV but 'intersectional identities are defined in relation to one another' (Shields 2008, p. 303).In other words, to fully understand the experience of abused women, one must consider the total dimensions of their lives including socioeconomic status, age and other identity makers (Sokoloff and Dupont 2005) and that the intersection of gender, race, and ethnicity, as well as the cultural differences experienced by immigrants, compound each other and lead to the social construction of identity and marginalization (Glass et al. 2011).
This perspective is threatened when government reports and/or policy-makers focus instead on culturalisation (Hearn et al. 2016;Montoya and Agustin 2013).By highlighting differences between the majority and minorities, CALD women may be further marginalised as the emphasis on the migrant cultures diminishes attention to other variables and fails to identify the extra-cultural explanations that contribute to their problems.Moreover, seeing the source of the DV as lying within the traditional social system denies the existence of domestic violence among so-called 'assimilated' and native-born members of the host society (Erez et al. 2009).This perception also may diminish the safety options for immigrant women and may preclude consideration of how to work with abused immigrant women to identify helpful sources of support (Erez et al. 2009).
In contrast, an intersectional approach encourages researchers and policymakers to surpass the singular categories (such as class, race and gender) which are common in policy analysis.It allows researchers to consider the complex interactions between the above-mentioned variables and other social locations such as sexuality, immigration status, age, ability and religion (Hankivsky et al. 2012).This enables an analysis of the simultaneous impact of different systems of oppression such as sexism, racism, classism and ableism (Hankivsky and Cormier 2009) mitigating against the creation of policies that privilege one inequality over another (Ferree 2009).
However, despite the development of intersectionality in feminist and gender research (Davis 2008;Hancock 2007;McCall 2005;Yuval-Davis 2006), the intersection of inequalities often continues to be invisible in policies (Nixon and Humphreys 2010).Policy responses to violence against women have not looked through an intersectional lens; instead they tend to focus on the common experiences of abused women (Sokoloff and Dupont 2005).Or, as mentioned above, the focus is on the culture of the victim without the recognition that immigrant women's subordination is not only derived from their cultures of origin, but is also attributable to mainstream structural factors such as racism and gaps in policies as well (Volpp 2011).
In these ways, policies which have the potential to make intersections between inequalities more visible (Strid et al. 2013) may barely address them (Krizsán et al. 2007).In particular, marginalised women remain invisible in most policies (Burmana and Chantler 2005;Crenshaw 1991;Hankivsky and Cormier 2011;Nixon and Humphreys 2010).For a policy to be inclusive, it is essential to take into account the inequalities and specific barriers facing marginalised groups (Lombardo and Rolandsen Augustin 2012).We now go on to examine these.

Specific Issues for CALD Victims of DV and FV (Family Violence)
Quantitative data on the prevalence of domestic and family violence are not readily available for immigrant and refugee women in Australia (Trijbetz 2013).The best available source of information on the prevalence of violence among CALD women is the Personal Safety Survey (PSS).However, both the Multicultural Centre for Women's Health (2014) as well as Cox (2015), who further analysed the data for Australia's National Research Organisation for Women's Safety (ANROWS), believe CALD women to be under-represented in the PSS.Hence, although the PSS (Australian Bureau of Statistics 2012) found that immigrant women experience domestic violence at a lower rate than Australian-born women, some groups of CALD women are likely to be under-represented in the survey.Reasons for under-representation include being members of new, small and emerging communities and a lack of facilitation by the use of interpreters and bilingual interviewers (2012).For example, no professional interpreters were used when conducting interviews for the survey.
A few interviewers with foreign language skills were trained for the Survey.Where a respondent required the assistance of another person to communicate with the interviewer (and an interviewer who spoke their language was not available), interviews were not able to be conducted (VicHealth 2014b, p. 28).
Other Australian research does suggest that the risk of domestic and family violence for CALD women is actually higher than for mainstream women (Ghafournia 2011).This is also supported by figures from domestic violence service providers who note an overrepresentation of women from culturally and linguistically diverse backgrounds (Poljski 2011;VicHealth 2015).Further, if intimate homicide is the tip of the DV iceberg, in a study identifying the ethnicity of both perpetrator and victim in homicides between sexual intimates, CALD women were found to be disproportionately represented, pointing to a higher incidence of antecedent violence (Easteal 1993).Note, however, that this result has not been replicated as more recent data do not differentiate by ethnicity, only by Aboriginality.
In addition to the ambiguity regarding the prevalence of domestic violence among CALD women that may contribute to their invisibility in domestic violence policies, we know that other aspects of their cultural-specific experience may not be visible.Certainly, some CALD survivors experience types and effects of violence that are the unique intersected sum of immigration and/or their ethnicity and identity as an immigrant.experiences with multi-perpetrator family violence, and the impact of violence and abuse [is] exacerbated by immigration policy, visa status and the stressors of the migration experience (Vaughan et al. 2015, p. 2).Indeed, a number of studies have identified that those women who are sponsored to Australia, may be particularly vulnerable to violence by their in-laws in addition to their partner.See for example Easteal (1996b) and Colucci et al. (2014).In-law abuse has also been reported in some international studies focusing on ethnic groups which adhere to extended familism, collectivism and traditional gender roles such as south Asian communities (Chaudhuri et al. 2014;Gill 2004;Raj et al. 2006;Salter 2014).
And as Vaughan et al. (2015) point out, immigration and the settlement processes add to the complexity of family and domestic violence for CALD women (also found by Easteal 2001;Ghafournia 2011;Gray et al. 2014).The social context of immigration consists of a complex set of interacting structural, legal and practical factors which make immigrant women more likely to remain in an abusive relationship (Erez 2000;Raj and Silverman 2002;Sokoloff and Dupont 2005;Vaughan et al. 2015).For instance, abused immigrant women are often economically dependent and frequently do not have the linguistic and occupational skills necessary for employment (Ghafournia 2011).They may fear that reporting domestic violence will negatively impact on their housing and economic security (InTouch: Multicultural Centre Against Family Violence 2010).In particular, while women are waiting for their Australian permanent residency to be approved, they do not have access to public housing and face limited income assistance and sometimes do not even have the right to paid employment (InTouch: Multicultural Centre Against Family Violence 2010; Rees and Pease 2006).
Thus, although immigrant and refugee women face similar obstacles in leaving violent relationships to mainstream women, these issues are exacerbated by other sources of oppression such as social isolation, which may be a part of the immigration experience (Carline and Easteal 2014).Lack of family and friends or a social network is regularly mentioned in the literature and can be used by the abuser to exert more control over a woman, leading to increased social abuse (Easteal 1996a;Flory 2012;InTouch: Multicultural Centre Against Family Violence 2010;Ogunsiji et al. 2011).This further isolation limits any acquisition of knowledge relating to their legal rights and knowledge of available services (Easteal 1996a;Rees and Pease 2007).Accordingly, a report by the Family Law Council (2012) found that a lack of knowledge about the law and a lack of awareness of available services impeded immigrant women's access to the family law system.
In addition, CALD women's experience of racism and discrimination in their contacts with service providers has been found to be an added factor which may deter them from seeking help (Aly and Gaba 2007;Dimopolous 2010;Immigrant Women's Domestic Violence Services 2006;Rees and Pease 2007).Rees and Pease (2007) explain that refugees who come to Australia are aware of the negative view held about them in the broader community, which may discourage them from trying to get help.This appears to be the case particularly for Muslim women.Aly and Gaba (2007), for example, found that negative stereotypes about the Muslim community after 11 September 2001 caused barriers for these women's help-seeking.
Immigration law-related abuse (Easteal 2001;Gray et al. 2014;Vaughan et al. 2015) is another immigrant-specific kind of abuse.It can occur when the abuser who may be the only source of information, misguides his partner (Easteal 1996b) and controls the spouse's legal immigration status (Renzetti and Edleson 2008, p. 194).Abusers of immigrant victims may use threats of deportation to prevent their abused spouses and children from seeking help or reporting the abuse (Abraham 2000;Ammar et al. 2005;Easteal 1996a;Raj andSilverman 2002, 2003).Ironically, it seems that 'Most of the policies on spouse sponsorship are targeted at protecting sponsors rather than the sponsored spouses' (Ghafournia and Easteal 2017, p. 9).Therefore, although the relevant legislation, the Migration Regulations 1994 (Cth) has been amended a number of times, gaps still remain (Gray et al. 2014).

Methodological Approach
The methodology involved an intersectional approach to the examination of government documents for evidence of inequalities, the details of which will be described below.Firstly, five reports were chosen for analysis based on currency and their potential contribution to domestic violence policy and legal reform.The National Plan to Reduce Violence against Women and their Children 2010-2022 (hereafter referred to as The National Plan) (Council of Australian Governments COAG) was published by the Council of Australian Governments (COAG), the peak intergovernmental forum in Australia.The NSW Domestic Violence Death Review (NSW Government 2017); It Stops Here-the NSW Government's Domestic and Family Violence Framework for Reform'(hereafter referred to as It Stops Here) (NSW Government 2014); and the Royal Commission into Family Violence, Summary and Recommendations (hereafter referred to as Royal Commission) (State of Victoria 2016) were selected because NSW and Victoria are the states with the largest population of overseas born residents; therefore, we would expect an emphasis on diversity of women and identification of immigrant communities.Family, Domestic and Sexual Violence in Australia (Australian Institute of Health and Welfare 2018) was analysed because, at the time of writing, it was the most recent, relevant document.
The purpose of and methods used in producing these reports were also an important consideration in our selecting them for analysis.Three of these-the National Plan, the Royal Commission into Family Violence and It Stops Here-were aimed at generating specific policy plans to reduce violence.The purpose of the two NSW reports was to gather data to better inform change.Three of the five reports included public consultation in their methodology: It Stops Here-' . . .worked with representatives from a range of communities and agencies including from CALD and Aboriginal organisations to develop a consultation paper which was released for public consultation in June 2013' (NSW Government 2014, p. 10), and the Victorian Royal Commission held public hearings and received written submissions from people in the community.The National Plan also states in its foreword that experts and the community were consulted.
We used an intersectional approach in our documental research with the aim of ascertaining how CALD women and their particular needs are represented (or not) in these five policy-influencing reports.The narrative data were thematically analysed.Thematic analysis is an effective way to identify patterned responses within qualitative material (Braun and Clarke 2006).We conducted our analytical process in stages.First, we created a Word document where we inserted headings based on themes drawn from the previous literature: naming and defining violence inclusive or not of CALD-specific types and effects; barriers for CALD women in help-seeking; and any CALD-related solutions within the report material.Next we copied and pasted any relevant text from the five reports into our analysis document under the appropriate headings.
In the second stage, sub-headings under each of the headings were generated through systematic reading.Material concerning CALD women was cut and pasted into the relevant sub-heading.For example, under the section 'barriers to obtain help', sub-categories that emerged were: unstable immigration status, lack of knowledge about support services and legal system, lack of providing interpreters, financial dependency and social isolation.And, under the section 'policy solutions/remedies', the sub categories were: providing cultural competency training for service providers, improving data collection on DV among CALD communities, financial support and housing and providing professional interpreters.This process was repeated for each report and recorded in a single table for easy comparison of sections and sub headings across reports.The remaining text was examined for any additional themes, which were then incorporated within the table under a new subheading.
In the final stage of the analysis, one of the authors (in order to preclude questions of inter-coder reliability) examined the substance of the material within each sub-section (by report) and coded for emphasis and/or explanation.Each cell was colour coded to differentiate whether the focus in the text was on the culturalisation of DV, immigration experience or other structural factors, or the intersection of different social categories.

Findings Concerning Intersectionality
We now look at what was found in the context of the intersectional themes in relation to each report.

Naming and Defining Violence Inclusive of CALD-Specific Types and Effects
Australia, like other countries, does not have a nationally agreed definition or a common language for referring to 'domestic violence' (Seymour 2017).Domestic and family violence is named and defined differently in the report.As the findings below demonstrate, these definitions and descriptions may only focus on specific types of partner violence and exclude specific CALD DV manifestations such as abuse by in-laws and immigration law-related control.

The National Plan
The National Plan, which is one of the main policy documents in regard to domestic violence, uses the term 'violence against women and children'.This is reflected in its title and its opening reference to the definition of violence against women (VAW) from the United Nations Declaration on the Elimination of Violence against Women.Throughout the document, the term domestic violence is used repeatedly.DV is defined as 'acts of violence that occur between people who have, or have had, an intimate relationship.'While there is no single definition, 'the central element of domestic violence is an ongoing pattern of behaviour aimed at controlling a partner through fear, for example by using behaviour which is violent and threatening' (Council of Australian Governments COAG, p. 2).
The repeated use of DV in the document 'undermines broader recognition of DV as one of multiple and complex forms of violence against women' (Seymour 2017, p. 6).The National Plan also defines family violence which is 'a broader term that refers to violence between family members, as well as violence between intimate partners.It involves the same sorts of behaviours as described for domestic violence' (Council of Australian Governments COAG, p. 2).The Plan then explains that 'The term, 'family violence' is the most widely used term to identify the experiences of Indigenous people, because it includes the broad range of marital and kinship relationships in which violence may occur' (Council of Australian Governments COAG, p. 2).It does not include the experiences of sponsored brides who may experience abuse by extended family.
In addition, within the label of DV, the plan recognises different kinds of violence including physical, sexual, psychological and emotional abuse.However, there is no reference to economic or financial abuse and social abuse, which we have mentioned as particularly common for CALD victims.Other kinds of violence such as threats of being deported, often perpetrated by extended family, are not mentioned.

'It Stops Here'
Domestic and family violence are defined in this document as: . . .any behaviour, in an intimate or family relationship, which is violent, threatening, coercive or controlling, causing a person to live in fear.It is usually manifested as part of a pattern of controlling or coercive behaviour (NSW Government 2014, p. 7).
The term 'intimate relationship' is defined as including different kinds of relationships such as marriages under cultural and religious traditions and same sex marriages: An intimate relationship refers to people who are (or have been) in an intimate partnership whether or not the relationship involves or has involved a sexual relationship, i.e., married or engaged to be married, separated, divorced, defacto partners (whether of the same or different sex), couples promised to each other under cultural or religious tradition, or who are dating (NSW Government 2014, p. 7).
This report is very explicit in describing various forms of family relationship as susceptible to violence.It extends the definition to any relation based on blood, marriage, adoption, partnership, sibling and extended family.It also contains extended kinship ties in Aboriginal and Torres Strait Islander communities and to relationships in LGBTI communities.
The document identifies different kinds of family violence such as sexual, physical, emotional and economic.It includes stalking and cultural or religious abuse; the latter is mentioned as 'kidnapping or deprivation of liberty, as well as unreasonably preventing the other person from making or keeping connections with her or his family or kin, friends, faith or culture' (NSW Government 2014, p. 7).
Thus, the report places an emphasis on the specific experiences of abuse for CALD women, identifying them as one of the particularly vulnerable groups experiencing domestic and family violence.It attributes the vulnerability of CALD women to barriers such as social isolation, language, financial dependency and migration status (NSW Government 2014, p. 8).Moreover, It Stops Here is the only policy document which acknowledges cultural and religious abuse.

NSW Domestic Violence Death Review 2015-2017
In this other NSW document, DV or intimate partner violence is defined as a term used to 'describe a pattern of behaviour whereby a person intentionally and systematically uses violence and abuse to gain and maintain power over another person with whom they share (or have shared) an intimate relationship' (NSW Government 2017, p. 2).The report uses the term domestic violence to refer to both 'domestic violence' and 'family violence'.It also distinguishes between intimate partner violence and other kinds of family violence.Different kinds of abuse are identified; however, again, there are no references to immigration-related abuse or extended family as perpetrators of violence.

Royal Commission
This Commission was established in the wake of a chain of family violence-related deaths in Victoria-particularly the death of 11-year-old Luke Batty, who was killed by his father on 12 February 2014, after years of abusive behaviour directed at Luke's mother, Ms Rosie Batty.The establishment of the Royal Commission recognised that existing policy responses had proven insufficient to reduce the occurrence of family violence (State of Victoria 2016, p. 1).
The Royal Commission uses the same definition of family violence as Section 5 of the Family Violence Protection Act 2008 (Vic): Family violence is a behaviour by a person towards a family member of that person if that behaviour is physically or sexually abusive; or is emotionally or psychologically abusive; or is economically abusive; or is threatening; or is coercive; or in any other way controls or dominates the family member and causes that family member to feel fear for the safety or wellbeing of that family member or another person; or behaviour by a person that causes a child to hear or witness, or otherwise be exposed to the effects of, behaviour referred to in paragraph (a) (State of Victoria 2016, p. 2).
The Family Violence Protection Act defines 'family member' broadly.'Family violence can occur in any type of familial relationship'.It can include extended family perpetrators (State of Victoria 2016, p. 2).However, there is no inclusion of sexual, social and immigration-law related abuse.

Family, Domestic and Sexual Violence in Australia
The most recent, relevant, Australian government document, Family, Domestic and Sexual Violence in Australia highlights data gaps and areas for data improvement to further strengthen and improve the evidence base to better deal with family, domestic and sexual violence.The report uses the National Plan's definition of domestic, family and sexual violence.The focus is on coercive control of one person over the other.'Intimate partner violence' and 'domestic violence' are used interchangeably.Types of violence identified by the report are physical, sexual, psychological and coercive control.Social and financial violence is not mentioned.People on student and partner visas and newly settled immigrants are identified as an at-risk group (Australian Institute of Health and Welfare 2018).Again, immigration law-related abuse is not identified as a kind of domestic and family violence.In this report, DV is considered as a subset of family violence.The first time CALD communities are mentioned in the report is an indirect quote from ANROWS research (Mitra-Kahn et al. 2016) concerning less reliable data for CALD groups in population surveys.

Summary of Definitions Theme
In sum, the core theme of domestic and family violence is control imposed by perpetrators.The National Plan uses the terms violence against women, domestic violence and family violence but the broader term family violence is applied only to Indigenous communities.Both NSW policies use the words domestic violence and family violence interchangeably.
Considering the similarity of some immigrant communities to Indigenous groups in terms of extended families and tight knit social relationships, it is surprising that the term family violence is not extended to CALD communities.The documents which name an extended family member as a potential perpetrator of family violence are Royal Commission into Family Violence, Summary and Recommendation and It Stops Here.
Differentiating between kinds of domestic violence is common in most of these reports; however, none included an awareness of immigration-law related abuse for CALD women.This is a striking omission because, as noted earlier, the misuse of unstable immigration status by perpetrators has been found in current scholarship to be one of the main kinds of abuse which affects help seeking on the part of the victim.

Identifying Barriers to Accessing Support Services
Among the documents analysed, the National Plan briefly mentions the difficulty experienced by CALD communities in accessing employment or higher education (Council of Australian Governments COAG, p. 15).
It also confirms the individual needs of women based on 'age, English language proficiency, disability, sexuality and prior victimisation' (Council of Australian Governments COAG, p. 23).However, there are no references to the particular needs of CALD women based on their immigration status and specific cultural needs as well as other structural barriers faced by this group of women.
As mentioned above, the two NSW reports which are not policy-driven, more clearly acknowledge various intersected vulnerable groups to domestic violence.In It Stops Here, the vulnerability of CALD women is clearly attributed to barriers such as social isolation, language, financial dependency and migration status (NSW Government 2014, p. 8).Similarly, the NSW Domestic Violence Death Review identifies vulnerable groups such as culturally and linguistically diverse communities, new immigrants and persons with vulnerable visa status who experience discrimination and disadvantage because of language, uncertain visa status, lack of knowledge about available support services, financial dependency on the abuser, social isolation and limited availability of shelter for non-residents (NSW Government 2017, p. 108).The report emphasises the need to apply a holistic approach to address these issues.
The Royal Commission also considers the experiences and needs of people from diverse backgrounds and communities.CALD communities are identified as groups which face specific barriers associated with the experience of migration and resettlement, as well as facing systemic barriers in seeking help for family violence.For example, the Commission mentions that CALD victims who do not have permanent residency may not have access to support services.In addition, men from CALD communities have less opportunity to participate in culturally-specific behaviour change programs which are in their language.Unavailability of professional interpreting services is identified as another obstacle to accessing support services (State of Victoria 2016, p. 34).The Commission clearly acknowledges that 'a comprehensive family violence policy must ensure better services and responses for all people who experience family violence, regardless of their background, identity or membership of a particular community' (State of Victoria 2016, p. 32).
Family, Domestic and Sexual Violence in Australia 2018 is the only document which does not make any references to the specific issues for CALD women including accessing services.Women at risk named in the report are: Aboriginal and Torres Strait Islander women, young women, pregnant women, women with disabilities, women experiencing financial hardships and 'women and men who experienced abuse or witnessed domestic violence as children' (Australian Institute of Health and Welfare 2018, p. xii).CALD women are not considered as a group at risk or as a group with a data gap.The report does mention CALD communities when it explores the findings of the National Community Attitudes towards Violence against Women Survey.It talks about immigrants and uses that survey's term 'people born in countries where English is not the main language'.It emphasises the survey's finding that 'People from non-main English speaking countries are more likely to have violence supportive attitudes' (VicHealth 2014a, p. 14).
Therefore, all but one of the documents in our sample have included a few common obstacles facing CALD women's access of support services.However, none of the reports dug deeper into the specificity of CALD women's experiences of domestic violence, which correlate with special needs.Further, as the next section will reveal, it appears for some (reference which ones) that this omission may be replaced with an emphasis on the ethnic sub-cultures as the source of the violence.

The National Plan
The National Plan acknowledges the diverse needs of women when it refers to the need for flexibility by support services in addressing various needs of clients.One of that document's recommendations is to provide specialist support services for women with individual needs based on 'age, English language proficiency, disability, sexuality and prior victimisation' (Council of Australian Governments COAG, p. 23).We note, however, that although the necessity of specialist domestic violence services for Aboriginal children and young people experiencing domestic violence are listed, there is no suggestion for CALD-specific support services.The plan fails to critically engage with the diverse needs of CALD women such as those derived from their precarious immigration status.The only reference to immigration law, along with family assistance and other related laws (Council of Australian Governments COAG, pp.27, 28) is in the context of the Australian Law Reform Commission's 2010 ALRC inquiry into the impact of Commonwealth laws on those who experience family violence.There is no mention of gaps in 'family violence provision' policy and sponsorship policies, which have been explored recently in the scholarship (Ghafournia 2011;Ghafournia and Easteal 2017;Gray et al. 2014).In addition, the plan considers supporting 'legal literacy among immigrant and refugees on Australian law' to protect CALD women who experience domestic violence (Council of Australian Governments COAG, p. 16), but does not offer solutions for tackling their lack of knowledge about legal and support services.
A strategy for achieving national outcome #5 recommends multi-disciplinary training for professionals to promote more effective and consistent criminal justice and family law responses (Council of Australian Governments COAG, p. 39).However, the plan does not suggest the necessity for cultural competence training for service providers who work with CALD communities.Strategy 1.2 does specifically include CALD women with its aim to 'provide Local Community Action Grants to encourage primary prevention' (Council of Australian Governments COAG, p. 16).Grants will be available to mainstream organisations, but priority 'given to assist women with disabilities, older women, culturally and linguistically diverse communities and gay and lesbian communities' (Council of Australian Governments COAG, p. 16).However, there is no mechanism to monitor what proportion of these grants will be allocated to CALD communities.

It Stops Here
It Stops Here recognises that domestic and family violence is a community issue that requires communities to take the lead and find the solutions (NSW Government 2014, p. 15).It also promotes 'accessible, flexible and person-centred service responses' to DV and FV (NSW Government 2014, p. 24) which should be responsive to specific needs of each community (NSW Government 2014, p. 25).The report emphasises that service providers for CALD communities, along with Aboriginal communities, need to ensure that their 'supports and services are culturally competent' (NSW Government 2014, p. 26).However, there is little discussion concerning how the needs of high-risk groups, in particular CALD communities, should be addressed.

The NSW Domestic Violence Death Review
In contrast, the NSW Domestic Violence Death Review does propose strategies for reaching out to CALD victims of domestic violence.Recommendations 20.1-20.5 propose the need for governments to develop and fund a number of changes including: implementing programs with affordable access to medical services by people with impermanent visa status or without a valid visa; expanding the Family Violence Provisions to other type of visas; incorporating mandatory domestic and family violence professional development for registered Migration Agents in Australia; improving access to shelter accommodation and to permanent housing solutions and providing appropriate financial supports for victims who are non-residents; and updating and distributing to all new immigrants a publication like the booklet, Life in Australia, to provide information on how to seek help (NSW Government 2017, pp. 109-11).

The Royal Commission
Similarly, a number of the Royal Commission recommendations are inclusive and contain some realistic strategies.Suggestions are made to develop 'accessible, inclusive and non-discriminatory service delivery' and to increase the understanding of the complexity of family violence in a variety of communities.In particular, Recommendation 1 requires the Victorian government to review and implement 'the revised Family Violence risk assessment and risk management framework in order to deliver a comprehensive framework' working with different agencies in Victoria (State of Victoria 2016, p. 45).This framework is expected to respond to the specific needs of certain groups, including CALD communities.The report stresses the need for improving practices and policies regarding the use of interpreters in family violence-related cases as well as the need to include forced marriage and dowry-related abuse as examples of family violence in the Family Violence Protection Act (State of Victoria 2016, p. 34).
Another relevant recommendation is #139 which proposes that the Victorian government fund some organisations to provide training for service providers to ensure appropriate services for CALD communities (State of Victoria 2016, p. 83).In addition, Recommendation 204 suggests that the Victorian government work with some agencies to improve state-wide family violence data collection and research in order to fill existing gaps in demographic information on CALD communities (State of Victoria 2016, p. 101).

Family, Domestic and Sexual Violence in Australia 2018
Unfortunately, similar to the National Plan, the other national document, Family, Domestic and Sexual Violence in Australia 2018, does not include CALD women in its discussion of responses to domestic violence.For example, one of the initiatives is to develop a national training package on family violence for general practitioners.
Here, the report fails to recognise the significance of cultural competency training (the ethnic equivalent of culturally appropriate training and strategies for Indigenous women) for GPs or other service providers (Australian Institute of Health and Welfare 2018, p. 110).
The underrepresentation of this group in demographic information collections is confirmed and the report does identify some new developments and emerging issues to improve data capture, fill the gaps and further inform understanding of the extent and nature of domestic violence.5.3.6.Summary of Report Policies/Solutions Focusing on CALD While three of the five reports do offer minimal solutions to overcome barriers for CALD women, for the most part, their needs and experiences are not emphasized in relation to policy development and service provision.More specifically, there is little recognition of how intersectional inequalities potentially impact immigrant women.The documents may acknowledge the position of marginalised groups such as CALD women, but it is with little elaboration of the particular needs of specific high risk sub-groups such as immigrants and refugees.

Findings Concerning Culturalisation
Among the documents analysed, several make reference directly or tacitly to culturalisation.The wording of two papers, The Royal Commission and Family, Domestic and Sexual Violence in Australia, seems to infer that the victims' culture is responsible for the DV while failing to name and consequently explore other intersecting factors.Both reports identify certain practices within some immigrant communities such as FGM, dowry abuse and forced marriage practices.Family, Domestic and Sexual Violence in Australia, also looks at how cultural attitudes and policies towards domestic and family violence 'vary greatly from country to country (where, for example, attitudes may accept dowry abuse, female genital mutilation, forced marriage and 'honour killings')' (Australian Institute of Health and Welfare 2018, p. 29).Further, in the concluding chapter and on the last pages of that document, the issues of FGM and forced marriages are raised again (Australian Institute of Health and Welfare 2018, p. 113).
The National Plan, however, does make some effort not to culturalise but to include intersectionality by recognising the diverse experiences of women and their children, and the need to ensure responses that address their specific circumstances.It acknowledges that policy solutions and strategies are relevant to all Australians regardless 'of their age, sex, sexual orientation, race, culture, disability, religious belief, faith, linguistic background or location' (Council of Australian Governments COAG, p. 11).However, when The National Plan states that it supports 'legal literacy among immigrants and refugees on an Australian law and gender equality principle' (Council of Australian Governments COAG, p. 16), it seems that gender equality is portrayed as a core national value of Australian society which immigrants need to adopt.Implicitly, the policy therefore seems to underline culturalised forms of violence as the problem.
In contrast, It Stops Here avoids any culturalisation of domestic and family violence and identifies vulnerable groups such as Aboriginal people, women with disability, women from CALD background, LGBTIQ people, younger women with children and pregnant women.The vulnerability of CALD women is explained by more external sources such as social isolation, language, financial dependency and migration status (NSW Government 2014, p. 8).Similarly, the NSW Domestic Violence Death Review does not make any sort of reference to types of violence or messages concerning prevention which are indicative of culturalisation of DV.The report collects data regarding country of birth for both abusers and victims.The rationale provided for collecting the data is as a prerequisite for considering 'the availability of appropriate services for perpetrators and victims of violence from culturally and linguistically diverse backgrounds' (NSW Government 2017, p. 10).

Discussion
Our analysis reveals some gaps in recent Australian reports concerning DV and CALD women with invisibility at worst, and a blurring at best, of the intersecting factors that affect naming (and getting away from) the violence.The unique experiences of CALD women and their locations at the multiple systems of inequalities are frequently neglected.In particular, both the gaps in immigration law, which problematise CALD women's access to support services, and the effects of racism on their experiences of getting help (particularly the more visible immigrant women such as those wearing hijab), are not highlighted in any of the five reports, with racism as a relevant construct only mentioned in two: NSW Domestic Violence Death Review and Royal Commission to Family violence.
Further, while most of the reports include references to CALD victims' vulnerability and their specific needs, the documents tend to fall short of addressing the intersecting needs and experiences of CALD women in detail and do not offer holistic proposals that could translate into practical solutions.As we have seen, one of the reports-Family, Domestic and Sexual Violence in Australia-largely ignores CALD women as a vulnerable group with particular needs and tends to culturalise domestic violence in CALD communities without any references to the specific challenges that immigration may contribute to.Culturalisation, by focusing on the immigrant culture's role and mores in perpetuating violence and by ignoring the results of racism and the other consequences of the intersection of different social categories, has the potential to exacerbate the marginalization of CALD women.
Even in those reports that do offer a fairly inclusive intersectional framing of domestic and family violence, intersectionality is largely not treated as central to policy-making.This lack of centrality has been identified in previous research: In many cases, intersectionality is central to policy problem definitions, but it is not part of the policy solutions; intersectionality is important to the diagnosis of a problem, but not to the prognosis (Hearn et al. 2016, p. 559).
Another omission in all the documents we examined is the lack of acknowledgment of the diversity of CALD communities in Australia.There is no reference to the complexity of the experiences of family and domestic violence among refugee women and their unique needs.As Australia is receiving more humanitarian arrivals and the consensus in the literature is that these groups are susceptible to violence (Fisher 2009;Fisher 2013;Ogunsiji et al. 2011;Zannettino 2012), specific attention needs to be given to the vulnerability of these women and their past experience of trauma and abuse.Furthermore, the difficulties for CALD women with insecure immigration status such as asylum seekers, temporary bridging visas, spouse visas and student visas have received minimal attention in the policies.This absence is of particular concern in reference to the two national reports in our sample because immigration laws, regulations and policies fall under the Federal jurisdiction in Australia.

Conclusions
The complex and unique experiences of domestic and family violence among immigrant and refugee women are increasingly identified in academic literature.The inclusion of multiple inequalities and intersectionality could increase the quality of policies aimed to reduce and end domestic and family violence, as well as to address the specific needs of various groups of women.This article has investigated if the needs and issues of CALD women in Australian documents are portrayed adequately in government documents intended to contribute an empirical framework for building domestic and family violence policies.
Unfortunately, it seems that these reports mainly tend to minimize the diverse experiences of domestic violence and position CALD women's experiences of abuse as marginal concerns in relation to policy development.Neither public consultation nor liaison with community organisations seems to have diminished the dominant culturalisation of DV or moved the focus away from mainstream issues to a more inclusive treatment of CALD concerns.If violence against women is analysed only through the lens of gender without recognising other intersecting factors which shape the lived experience of abuse for different group of women, it excludes many of the specific and separate issues for other sub-groups of women.The visibility of CALD women in Australian policy is a doomed enterprise unless the lived experiences of marginalised women are integrated into these reports and ultimately into policy development.
The development of good policy that addresses and considers multiple levels of inequality and marginalization is essential yet challenging and needs to be built with the knowledge and experiential base of CALD women or relevant support services familiar with their CALD women's specificity.We make two suggestions on how to achieve this.One recommendation concerns thematic analysis of penultimate drafts of government reports aimed at exploring violence against women and/or children.These could be analysed, as we have done here, in order to ascertain if the unique policy needs of vulnerable groups are being included.If not, then the absence of intersectionality can be remedied prior to publication.We also suggest that including one or two CALD members with appropriate expertise on government report advisory committees (in addition to ensuring that public consultation includes immigrant women and relevant ethnic welfare agencies) could better ensure that their experiences and needs will be addressed in future rounds of research recommendations designed to inform policy.