I may be wrong, but we all know the legal dept. is probably calling the shots on everything. This document does not sound to me like it was written by lawyers. Examples:
"the matter" I would expect a legal document to read "alleged incident. I also do not believe a lawyer would start off saying the older person involved is the "accused" and the younger is "victim." Certainly they would apply a qualifying word. Until somebody is convicted or confesses a lawyer will consider them "Innocent until proven guilty."