CEI is a small charity based in Glasgow and since its inception has been run entirely by volunteers who undertake work in both Scotland and Bangladesh with partner organisations. CEI’s Safeguarding Policy applies to all board members, volunteers and employees in every aspect of their involvement whether at home or abroad. The Policy covers expected standards of behaviour in relation to the safety and welfare of those we work with. and also seeks to protect those who work for us and act on our behalf. CEI adopts the Scottish International Development Agency’s definition of Safeguarding: “Safeguarding promotes the safety and welfare of people involved in the delivery or receipt of humanitarian aid and development assistance, protecting them from harm, including all forms of exploitation, abuse and harassment.”
2. Purpose and aim of the safeguarding policy
The purpose of the policy is to ensure that those who work for, (whether paid or unpaid), or represent CEI act responsibly and with integrity to ensure that all our beneficiaries are safe and protected from harm or abuse and free from sexual exploitation. Further, this policy aims to protect all our trustees, workers and volunteers to ensure not just that they act appropriately but also that they can confidently report any issues of concern and recognise their responsibility to report such concerns. The policy is founded upon the principles of non-discrimination and confidentiality. CEI’s vision is a world where human beings are educated, healthy and free from poverty. Our mission is to create a replicable model of development that has empowerment at its core. Our aim is to help people achieve their potential. CEI’s central values are integrity and transparency. CEI recognises that all children and vulnerable adults have an equal right to protection from harm regardless of their gender, culture, ethnicity, age, religion, sexual orientation, or ability. CEI recognises that it is at the start of formalising its safeguarding culture which has up until this point been implied rather than stated. To create and embed a strong safeguarding culture, CEI is committed to: > taking continuous action to embed it throughout the organisation and with its international partners > a programme of orientation for the trustees, workers and volunteers > establishing clear reporting procedures > training appropriate to roles and and responsibilities > learning from other organisations to share good practice > developing and on reviewing complementary policies such as Whistleblowing, AntiBullying & Harassment and formalising its Code of Conduct. > reviewing the need for safeguarding checks in the context of the type of volunteer work being undertaken. When a concern has been notified, CEI undertakes to act in a timely manner and to treat the concern confidentially and will only share without consent where the duty to protect from harm supersedes the individual’s right to privacy. CEI, November 2018 SCIO No SCO027183 !1 of!5
3. Legal and policy basis of the policy
This policy is governed by the laws and regulations of Scotland. In Scotland the following policies, legislation and guidance apply:
• UN Convention on the Rights of the Child
• Children Act (Scotland) 1995
• Protecting Children and Young People: The Charter
• Children and Young People Act (Scotland) 2014
• Getting it Right for Every Child (GIRFEC)
• Protection of Vulnerable Groups (Scotland) Act 2007
• Part V of the Police Act 1997
• OSCR strategy and guidance
• Scottish Governance Code - DRAFT (pdf)
• NCVO Code of Ethics - draft code, in consultation
• SCVO Safeguarding Guidance
• Safer recruitment guidance for social care providers
4. Definitions: (definition of a child, vulnerable adult, beneficiaries and who it applies to)
CEI adopts OSCR’s definitions of a child and a vulnerable adult:
• A child is anyone under 18 years of age.
• A vulnerable adult is anyone over 16 years of age who is unable to safeguard themselves, their property and their rights. Harm: CEI aims to protect all its beneficiaries from harm which can include: physical harm, psychological harm, financial harm, sexual harm, neglect. Abuse: CEI aims to protect all its beneficiaries from abuse which we define as action by another person, adult or child, that causes or is likely to cause significant harm. It can be physical, sexual or emotional. or neglect. CEI’s direct international work is in Bangladesh where definitions are not so clear cut. In the context of our direct international work, our beneficiaries are students aged 17 plus and the teaching staff of a rural northern college; those who attend the Health Centre for medical care and children classified as orphans (i.e. no father or both parents deceased). CEI does not work directly with vulnerable adults as defined in Scotland. CEI’s orphan’s support project is limited to providing small stipends to keep children in school and there is strict criteria for allocating these.
5. What is your responsibility?
Trustees As Trustees we are responsible for safeguarding and we will make public our clear commitment to safeguarding by publishing our safeguarding policy we assert that failure to follow it will be dealt with as a very serious matter. It is our job to safeguard and where appropriate, promote the well-being and welfare of CEI’s beneficiaries. We will take reasonable steps to protect CEI’s beneficiaries, staff, volunteers and those connected with the activities of the charity from harm. Safeguarding Responsibility Anyone who works with children or vulnerable adults is obliged legally and morally to ensure that they are protected from harm, and therefore must:
• Behave in a way that does not place children, or, vulnerable adults at risk of harm or exploitation.
• Report all safeguarding concerns about specific children or adults at risk to the Safeguarding Lead and ensure these concerns are addressed. CEI, November 2018 SCIO No SCO027183 !2 of!5 Workers Workers must follow their contractual obligations and the Code of Conduct and be responsible for their own behaviour and for reporting safeguarding concerns. When working in the field workers must be mindful of the local conditions and customs and must not breach expected standards of behaviour. Particularly, workers should observe protocols and should avoid putting themselves in a position where they put themselves or beneficiaries at risk. At all times workers should avoid making sexually suggestive comments to young people - even in fun. and flirting should be avoided even with staff. Volunteers Volunteers must adhere to the Code of Conduct and be responsible for their own behaviour and for reporting safeguarding concerns. When working in the field volunteers must be mindful of the local conditions and customs and must not breach expected standards of behaviour. Particularly volunteers should observe protocols and should avoid putting themselves in a position where they put themselves or beneficiaries at risk. At all times volunteers should avoid making sexually suggestive comments to young people - even in fun. and flirting should be avoided even with staff. Applicable to all Bullying and/or harassment should be avoided at all costs as this can contribute to an environment where it is difficult to raise safeguarding concerns. Harassment is a discriminatory act and is also a criminal offence. It is very difficult to define as it can take many forms, but in the main it takes the form of unwanted, uninvited and unreciprocated behaviour by one worker (or volunteer) towards another, for example:
• Patronising or belittling comments.
• Comments about appearance/body/clothes.
• Leering or staring at a person’s body.
• Unwelcome sexual invitations or pressure.
• Promises or threats, concerning employment or conditions, in exchange for sexual favours.
• Displaying offensive or sexually explicit material.
• Touching, caressing, hugging or indecent assault. Bullying behaviour could include the following; is also difficult to define:
• Threats of or actual physical violence.
• Unpleasant or over repeated jokes about a person.
• Unfair or impractical work loading.
6. Mitigation and Implementation
Mitigation As already outlined, CEI expects high standards of behaviour which, if followed, will prevent harm and abuse and if it does occur, will ensure it is reported on. To foster and inculcate a culture of safeguarding, CEI trustees will ensure that regular reports are given at its meetings and that a regular review of all policies will take place and appropriate training will be undertaken. CEI, November 2018 SCIO No SCO027183 !3 of!5 Implementation When recruiting, due diligence will apply and PVG disclosure will be conducted if appropriate and everyone recruited from Scotland will take part an induction process and staff and volunteers will require to read and sign all relevant policies. We will undertake risk assessments at every level both in-country and in Scotland. CEI will designate a Board member from its Trustees to be the focal point for Safeguarding. In-country we will work with appropriate leads, raise awareness of safeguarding and to ensure there is a process in place to deal with safeguarding concerns. Most people in the village of Kakina where CEI works, do not speak English and this presents challenges. CEI will identify a male and female Safeguarding Lead within the college who speaks and understands English at a sufficient level and who has a level of seniority in the college that would give due weight.
7. Recognising concerns
CEI’s main field of work is in-country (Bangladesh) and the area we work in is the remote rural north where levels of poverty are high. Corporal punishment in schools is legal and frequently used and many children are barefoot and often hungry, reflecting in-country norms. What CEI workers and volunteers need to look out for is anything out of the ordinary that would raise a safeguarding concern.
8. Reporting procedures and process
Reporting in Scotland CEI does not generally work directly with children or vulnerable adults in Scotland however we adopt standard policy in this regard. If you believe there is a safeguarding incident or concern you must follow the reporting procedure:
• take emergency action if needed (police/medical/social services),
• record what you have witnessed or been told with key facts (date, times, incident/concern),
• refer the incident/concern to the designated Safeguarding Lead. In the event that the incident relates to the Safeguarding Lead, then this should be taken immediately to the chairman of the Board. If the Safeguarding Lead does not act on concerns raised, then this should also be taken to the Chairman of the Board,
• do NOT investigate the incident or concern yourself. If you have concerns about a child or vulnerable adult, ascertain whether urgent police or medical attention is needed. In this instance, police/medical/social services should be contacted immediately. When working overseas there may be instances when the police or local services are not the safest place for a child or vulnerable adult to be. Liaise with our designated safeguarding leads in the partner organisation. In a non-emergency situation, where you are concerned that there is a safeguarding issue you must report your concerns to the Safeguarding Lead. The incident or concern must be documented immediately. CEI, November 2018 SCIO No SCO027183 !4 of!5 If a child or vulnerable adult discloses a safeguarding concern to you, you must pay careful attention to their disclosure and be clear that this is taken seriously. Listen attentively, offer support and reassurance and be clear that you need to tell someone so that the incident/concern can be dealt with. Document the details using the form provided, or an appropriate form that is signposted in the policy. Without delay but as soon as is reasonable, report this to the Safeguarding Lead for action. If you bring a report of a safeguarding incident or concern you will not be victimised for having brought the complaint, even if it is found that the concern or incident is not upheld. However, in the event that following a full and fair investigation, the organisation has grounds to believe that the complaint was brought with malicious intent, you will be subject to disciplinary action under the disciplinary procedure. Investigating procedures
• If a member of staff is subject to safeguarding allegation they will be relieved of their duties while an investigation takes place. In compliance with labour law they are entitled to full pay while the investigation takes place.
• If a volunteer, contractor, or trustee is the subject of a safeguarding allegation they will be required to stop any work they are doing until an investigation has been completed.
• Importantly, while an investigation takes place all those involved in the investigation will be supported, including the person whom the concern has been raised about.
• Disclosure of abuse in regards to a member of staff, volunteer, contractor, trustee will be reported to the police and relevant authorities.
• Disclosure of a suspicion may not always be reported to the police, but a risk assessment and appropriate action will be undertaken, and may result in police involvement.
• IMPORTANT - any safeguarding concern that has been raised by a Scottish based organisation must be reported to OSCR through their notifiable events email: firstname.lastname@example.org.
• If CEI is a grant holder of the Scottish Government’s International Development Fund or other fund, we will inform the relevant grant manager.
• A reporting flowchart and reporting form accompany this document.
9. Monitoring, review and complementary polices
The Safeguarding Lead will be responsible for monitoring the implementation of our safeguarding policy. At each meeting of the Trustees, Safeguarding will be standing item on the agenda and policies will be reviewed regularly. CEI’s Safeguarding Policy should be read alongside the Code of Conduct, the Protection from Bullying and Harassment Policy, the Whistleblowing Policy, Grievance Procedure and our Equal Opportunities Policy. Should CEI become an employer, we will develop other relevant policies. Policy adopted on 1st November 2018 Safeguarding Lead: Irene Graham, 07807621411 / 0141 552 5382 email@example.com CEI, November 2018 SCIO No SCO027183 !5 of 5