Policy Statement:
The Eligo Group of Companies believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect, and exploitation. We will not tolerate abuse and exploitation by staff or associated personnel.
This policy will address the following areas of safeguarding [as appropriate]: child safeguarding, adult safeguarding, and protection from sexual exploitation and abuse. These key areas of safeguarding may have different policies and procedures associated with them.
The Eligo Group of Companies commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting, and response.
The Eligo Group of Companies abides by its duty of care to safeguard and promote the welfare of adults at risk, children, and young people and is committed to safeguarding practice that reflects statutory responsibilities, and government guidance and complies with best practice requirements.
- We recognise the welfare of adults at risk, children and young people is paramount in all the work we do and in all the decisions we take
- All adults at risk, children and young people, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse
- Some adults at risk, children and young people are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues
- Working in partnership with adults at risk, children and young people, their parents, carers and other agencies is essential in promoting their welfare.
Purpose:
The purpose of this policy is to protect people, particularly adults at risk, children and young people from any harm that may be caused due to their coming into contact with the Eligo Group of Companies. This includes harm arising from:
- The conduct of staff, candidates placed by or personnel associated with the Eligo Group of Companies
- The design and implementation of The Eligo Group of Companies programmes and activities
The policy lays out the commitments made by The Eligo Group of Companies, and informs staff, associated personnel, and candidates placed in situations where they are in contact with adults at risk, children and young people of their responsibilities in relation to safeguarding.
This policy applies to anyone working on behalf of the Eligo Group of Companies, including senior managers and the board of directors, paid staff, volunteers, sessional workers, candidates, agency staff and students. Failure to comply with the policy and related procedures will be addressed without delay and may ultimately result in dismissal/exclusion from the organisation.
This policy does not cover:
- Sexual harassment in the workplace – this is dealt with under the Eligo Group of Companies Bullying and Harassment Policy
- Safeguarding concerns in the wider community not perpetrated by Eligo Group of Companies employees or associated personnel
Definitions:
Adult at Risk:
- An adult who has needs for care and support (whether or not the authority is meeting any of those needs),
- is experiencing, or is at risk of, abuse or neglect, and
- as a result of those needs is unable to protect themselves against abuse or neglect or the risk of it.
Beneficiary of Assistance
Someone who directly receives goods or services from an employee, candidate or agent of the Eligo Group of Companies. Note that misuse of power can also apply to the wider community that we serve, and also can include exploitation by giving the perception of being in a position of power.
Child: The definition of a child in The Children Act 1989 is anyone who has not yet reached their 18th birthday, even if they are living independently, are a member of the armed forces or is in hospital.
Child and Adult Abuse: Children and adults may be vulnerable to neglect and abuse or exploitation from within their family and from individuals they come across in their daily lives. There are 4 main categories of abuse, which are: sexual, physical, emotional abuse, and neglect. It is important to be aware of more specific types of abuse that fall within these categories, they are:
- Bullying and cyberbullying
- Child sexual exploitation
- Child Criminal exploitation
- Child trafficking
- Domestic abuse
- Female genital mutilation
- Grooming
- Historical abuse
- Online abuse
Harm: Psychological, physical and any other infringement of an individual’s rights
Psychological harm: Emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation
Protection from Sexual Exploitation and Abuse (PSEA): The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel. The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)
Safeguarding: In the UK, safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur. In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff, candidates or agents.
This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.
Safeguarding applies consistently and without exception across our business, directors, candidates, agents and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty.
Safeguarding puts beneficiaries and affected persons at the centre of all we do.
Safeguarding children: Safeguarding children is defined in Working Together to Safeguard Children 2018 as:
- protecting children from maltreatment.
- preventing impairment of children’s health or development.
- ensuring that children are growing up in circumstances consistent with the provision of safe and effective care.
- taking action to enable all children to have the best outcomes.
Sexual abuse: The term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.
Sexual exploitation: The term ‘sexual exploitation’ means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. This definition includes human trafficking and modern slavery.
Survivor: The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however, it is the individual’s choice how they wish to identify themselves.
Legal Framework:
This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in England. A summary of the key legislation is available from nspcc.org.uk/learning.
The Eligo Group of Companies should have in place arrangements that reflect the importance of safeguarding and promoting the welfare of children and young people as well as vulnerable adults.
Prevention:
The Eligo Group of Companies responsibilities
We will:
- Ensure all staff have access to, are familiar with, and know their responsibilities within this policy
- Design and undertake all our programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with us. This includes the way in which information about individuals is gathered and communicated
- Implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel
- Ensure staff receive training on safeguarding at a level commensurate with their role in the organisation
- Follow up on reports of safeguarding concerns promptly and according to due process
Staff responsibilities
Child safeguarding
Our staff and associated personnel must not:
- Engage in sexual activity with anyone under the age of 18
- Sexually abuse or exploit children
- Subject a child to physical, emotional or psychological abuse, or neglect
- Engage in any commercially exploitative activities with children including child labour or trafficking
Adult safeguarding
Our staff and associated personnel must not:
- Sexually abuse or exploit at risk adults
- Subject an at risk adult to physical, emotional or psychological abuse, or neglect
Protection from sexual exploitation and abuse
Our staff and associated personnel must not:
- Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance
- Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics
Additionally, our staff and associated personnel are obliged to:
- Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy
- Report any concerns or suspicions regarding safeguarding violations by an Eligo Group staff member or associated personnel to the appropriate staff member
The Prevent duty
Some organisations in England, Scotland and Wales have a duty, as a specified authority under section 26 of the Counterterrorism and Security Act 2015, to identify vulnerable children and young people and prevent them from being drawn into terrorism. This is known as the Prevent duty. These organisations include:
- Schools
- Registered childcare providers
- Local authorities
- Police
- Prisons and probation services
- NHS trusts and foundations.
- Other organisations may also have Prevent duties if they perform delegated local authority functions.
Children can be exposed to different views and receive information from various sources. Some of these views may be considered radical or extreme.
Radicalisation is the process through which a person comes to support or be involved in extremist ideologies. It can result in a person becoming drawn into terrorism and is in itself a form of harm.
Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.
Reporting:
We will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities we work with.
Any staff reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by the Eligo Group of Companies Whistleblowing Policy.
We will also accept complaints from external sources such as members of the public, partners and official bodies.
How to report a safeguarding concern
Staff members who have a complaint or concern relating to safeguarding should report it immediately to Aleks Dimitrova or line manager. If the staff member does not feel comfortable reporting to Aleks Dimitrova or line manager (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to Victoria Bodhani, General Manager.
Response:
We will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations.
We will apply appropriate disciplinary measures to staff found in breach of policy.
We will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation). Decisions regarding support will be led by the survivor.
Training and Awareness:
We will ensure an appropriate level of safeguarding training is available to our Directors, Employees, Candidates, Volunteers and any relevant persons linked to the organisation who require it (e.g. contractors).
For all employees who are working or volunteering with adults at risk, children and young people, this requires them as a minimum to have awareness training that enables them to:
- Understand what safeguarding is and their role in safeguarding adults at risk, children and young people.
- Recognise a child potentially in need of safeguarding and take action.
- Understand how to report a safeguarding Alert.
- Understand dignity and respect when working with adults at risk, children and young people.
- Have knowledge of our Safeguarding Policy.
Confidentiality and Information Sharing:
We expect all employees, candidates, volunteers and other personnel to maintain confidentiality. Information will only be shared in line with the General Data Protection Regulations (GDPR) and Data Protection Act 2018.
However, information should be shared with any relevant Local Authority if an adult at risk, child or young person is deemed to be at risk of harm or contact the police if they are in immediate danger, or a crime has been committed.
Recording and Record Keeping:
A written record must be kept about any concern regarding an adult with safeguarding needs. This must include details of the person involved, the nature of the concern and the actions taken, decision made and why they were made.
All records must be signed and dated. All records must be securely and confidentially stored in line with General Data Protection Regulations (GDPR) and the Data Protection Act 2018. (see the Eligo Group of Companies Privacy Policy)
Safe Recruitment & Selection:
We are committed to safe employment and safe recruitment practices, which reduce the risk of harm to adults at risk, children and young people from people unsuitable to work with them or have contact with them.
We have policies and procedures that cover the recruitment of all directors, employees, candidates and volunteers. (see the Eligo Group of Companies Recruitment Policy).
Social Media:
All employees, candidates and volunteers should be aware of our social media policy and procedures (see the Eligo Group of Companies Employee Handbook) and the code of conduct for behaviour towards any adults at risk, children and young people we support.
Use of Mobile Phones and other Digital Technology:
All employees, candidates and volunteers should be aware of our policy and procedures regarding the use of mobile phones and any digital technology and understand that it is unlawful to photograph adults at risk, children and young people without the explicit consent of the person with guardianship and/or parental responsibilities. (see the Eligo Group of Companies Employee Handbook)
Whistleblowing:
It is important that people within the Eligo Group of Companies have the confidence to come forward to speak or act if they are unhappy with anything. Whistleblowing occurs when a person raises a concern about dangerous or illegal activity, or any wrong- doing within their organisation. This includes concerns about another employee, candidate or volunteer. There is also a requirement by the Eligo Group of Companies to protect whistleblowers. This is more specifically dealt with in the Eligo Group of Companies Whistleblowing Policy.
Important Contacts:
Primary Contact for Safeguarding
Name: Aleks Dimitrova (Operations and Finance Manager)
Email address: aleksd@eligo.co.uk
Telephone number: 020 8944 4116
Police
Emergency – 999
Non-emergency – 101
NSPCC Helpline
0808 800 5000