appropriate perpetrators. penalties for  Consider eliminating the general use of banishment for cases of family violence unless clearly justified. INQUIRY FINDING 40: The Churches in Samoa are generally not offering protection to victims of family violence and often counsel them into returning to abusive relationships, placing them at risk of further harm. RECOMMENDATION ACTION OUTCOME RECOMMENDATION 32: Increase  the capacity of the church to protect against family violence and prevent placing victims at risk of further harm.   Consult and establish a national guideline for church ministers dealing with victims and perpetrators of family violence, covering: a) The nature, causes and impacts of family violence in Samoa; b) Dealing with victims and perpetrators of family violence; c) Laws and services; d) Counseling of couples showing early signs or risks of family violence e) Prohibition of counseling to return to abusive relationships. Consult with relevant partners and develop plans for emergency shelter system for victims of family violence. Establish a complaint and reporting mechanism (and associated disciplinary process) for perpetrators of violence within the church. IMPLEMENTATION/ RESPONSIBLE AGENCY  NCC  All Church Leaders TIMEFRAME  Immediate attention INQUIRY FINDING 41: Non-government organisations play a substantial and admirable role in meeting the need not currently being met by Government. However, greater accountability, coordination, training and data collection is required for increased effectiveness and to ensure victims of family violence receive the relevant care to a required standard.