Safeguarding Policy

Status: Approved by the Management Committee of the board (3 March 2021), last reviewed October 2025

Owner: Head of Finance and Operations

Scheduled review date: October 2026 or following any serious incident.

Review process:  Any changes in light of national policy developments, feedback from safeguarding incidents and training during the year to be discussed by Safeguarding Manager and Safeguarding Trustee, proposed to Management Committee/Union for approval and supplied to Board / staff for information.

  1. Purpose of this policy

There are two purposes of this policy:

  • To protect people who come into contact with Debt Justice from harm.
  • To provide staff, trustees, consultants, supporters and beneficiaries of Debt Justice with the overarching principles which guide our approach to safeguarding and protection from harm.
  • Policy Development

This policy is based on content adapted from the safeguarding policy of our partner Christian Aid and from the following resources:

  • Scope

This policy applies to

  • All Debt Justice staff
  • Anyone working on behalf of Debt Justice, including trustees, volunteers and consultants
  • Third party organisations in a joint initiative where it has been decided that Debt Justice’s Safeguarding Policy and associated procedures will be followed
  • Supporters and anyone else when they engage in our activities.

This policy has been developed in accordance with requirements of legislation in England and Wales, and the Safeguarding Manager will ensure that when work is undertaken in other countries, relevant requirements are met, and local procedures are understood and followed.

  • Definitions

See Annex 1 for definitions of key terms used in this document.

  • Our approach and commitments

Debt Justice has a zero-tolerance approach to serious misconduct and will not tolerate our staff, trustees, volunteers, consultants, partners or any representatives associated with our work carrying out any form of violence, abuse, harassment or exploitation. All our community without exception have the right to protection from abuse.  

Our approach is informed by our core organisational values of solidarity, courage and kindness.  In this context solidarity means listening to the experiences of others, supporting their struggles and ensuring inclusion and participation in our work. Courage means speaking out where there is a problem that needs to be challenged, and placing our mission and beneficiaries above our personal pride and ego. Kindness means showing empathy with people, holding their underlying dignity when conflict occurs and ensuring our work centres the voices of people who are most marginalised.

We are committed to:

  • Providing a safe and trusted environment for everyone who comes into contact with our work
  • Safeguarding the wellbeing of beneficiaries, staff, volunteers, and all those directly connected with the activities of Debt Justice, and ensuring they have equal rights to protection from harm
  • Ensuring concerns or allegations are taken seriously, investigated and acted on as appropriate
  • Ensuring all our staff, trustees, volunteers, and consultants are familiar with this policy and know their responsibilities within it
  • Ensuring that all staff and trustees receive safeguarding training and maintaining a record of this training
  • Ensuring all actions on protecting people are taken in the best interests of the person at risk
  • Ensuring that survivors of abuse are supported, and alleged perpetrators are held to account
  • Ensuring our recruitment practices are robust enough to ensure we never recruit anyone who poses a known risk
  • Ensuring that alleged perpetrators of abuse are treated fairly and in accordance with the law
  • Reporting criminal acts to the relevant statutory agency
  • Reporting all serious incidents of abuse to the Charity Commission in the UK, in line with Charity Commission guidance[1].
  • Reporting incidents to relevant donors
  • Ensuring our beneficiaries and supporters are fully aware of the expected behaviour of our staff, volunteers, trustees, consultants and partners
  • Risk assessment

The Board holds an organisational risk register which is reviewed annually and contains a specific section on safeguarding. A written risk assessment is to be completed for every event run by Debt Justice that involves members of the public, or which involves a higher than usual risk to employees. The lead event organiser is responsible for completing the risk assessment, which must be reviewed and approved by two members of the SLT (normally the Department Head responsible for oversight of the relevant area of work, and the Safeguarding Manager).

  • Roles & Responsibilities
  1. All staff, trustees, consultants, and volunteers

It is the responsibility of all staff, consultants, trustees and volunteers to prevent and report any potential or suspected incidents of physical, sexual, emotional abuse or neglect of anyone in contact with our work as an organisation.

As a member of the Debt Justice community, you have the responsibility to raise any concerns you may have or those which are reported to you according to this policy.

It is not your responsibility to decide if an incident of violence, abuse, harassment or exploitation has taken place or whether an incident constitutes a safeguarding breach. This is the responsibility of the Safeguarding Manager and the Safeguarding Trustee, with support from the Chair of the Board and the Chair of the Management Committee of the Board.

Dealing with safeguarding issues can be difficult and traumatic. You are encouraged to talk things through with your line manager, the Safeguarding Manager, or the Safeguarding Trustee where appropriate, for advice on how to deal with any potential safeguarding issues, or if you have any support needs.

What to do when you have a safeguarding concern:

Actual, potential or suspected incidents of abuse must be reported immediately.

The need to report arises in the following instances:

  • Abuse is observed or suspected
  • An allegation of abuse is made
  • Someone discloses abuse
  • the safeguarding policy is not being followed. 

Remember that it is not your responsibility to decide if an incident constitutes a safeguarding breach – your responsibility is only to report the incident. No representative of Debt Justice will prejudice their own position or standing with Debt Justice by responsibly reporting potential or suspected abuse.

How to report a safeguarding concern:

Providing the concern does not involve your line manager, in the first instance you should report the concern to your line manager who is responsible for informing the Safeguarding Manager, who will ensure that the matter is appropriately referred or investigated.

If you are not a Debt Justice employee, the concern involves your line manager or there is another reason why reporting the concern to them does not feel appropriate, you should go directly to the Safeguarding Manager, who will ensure the matter is appropriately referred or investigated.

In the following instances, you should contact the Safeguarding Trustee on the Board directly:

  • If the concern involves the Safeguarding Manager or another senior member of staff
  • If you have reported a concern according to the instructions above, but believe that there are outstanding/unresolved issues or that there has been unreasonable delay in handling or addressing the concern.

In the above instances, the Safeguarding Trustee will take responsibility for conducting an appropriate investigation.

Contact details for the Safeguarding Manager and Safeguarding Trustee can be found on page 1 of this document.

Please be assured that the information you provide will be treated in confidence, and not shared any further than necessary for the investigation. You do not have to provide personal details; however, such information will assist us in taking forward your concerns and enable us to provide you with a response on the outcome. If you ask us not to disclose your identity we will not do so without your consent, unless required by law. This may apply if a criminal offence is suspected, or if the safety of a child or vulnerable adult is at risk.

  • Safeguarding Manager: Head of Finance and Operations

The Head of Finance and Operations is the organisation’s designated Safeguarding Manager responsible for:

  • Ensuring that they themselves are fully abreast of best practise in safeguarding
  • Notifying the Chair of the Board, the Chair of the Management Committee, and the Safeguarding Trustee that a report has been made
  • Investigating any reports of abuse, taking care with regard to confidentiality and only sharing information with appropriate people
  • Producing a written report as soon as possible after the concern was raised (within 24 hours if possible)
  • Making referrals to police or other statutory services as required
  • Keeping any written records securely in a locked place or in a confidential electronic folder
  • Ensuring that the safeguarding policy is regularly reviewed and updated in line with the law and organisational best practice.

Further guidance for the Safeguarding Manager in undertaking their role is provided here: https://knowhow.ncvo.org.uk/safeguarding/checklists-training-and-other-support/specialist-guides/a-designated-safeguarding-leads-handbook

  • Safeguarding Trustee

The Safeguarding Trustee is chosen by the board and is responsible for:

  • Meeting regularly with the Safeguarding Manager, receiving reports and discussing activity
  • Acting as an independent resource that can offer advice, on request, to management that are dealing with and reporting safeguarding incidents
  • Challenging the organisation to ensure that it is doing all it can to safeguard those it comes into contact with
  • Ensuring appropriate time is devoted to safeguarding at Board meetings
  • Being a key resource for the whole Board, as someone with specialised training and knowledge
  • Operating as a person independent from management to whom safeguarding issues can be directly referred, if it is felt that management is not dealing with an issue appropriately or if it involves management. 

Further guidance for the Safeguarding Trustee in undertaking their role is provided here: https://knowhow.ncvo.org.uk/safeguarding/checklists-training-and-other-support/specialist-guides/a-designated-safeguarding-leads-handbook

  • Executive Director

The Executive Director is responsible for oversight of Debt Justice’s safeguarding approach via line management of the Safeguarding Manager, and may be consulted (where appropriate) on the management of safeguarding incidents.

  • Management Committee of the Board

The Management Committee of the Board is responsible for:

  • Scrutinising updates to the safeguarding policy on behalf of the Board to ensure the policy is in line with the law and best practise
  • Receiving confidential reports on incidents and also approving separate reporting, where applicable, to the Charity Commission under the Serious Incident Reporting Policy.
  • Risk Committee of the Board

The Risk Committee of the Board is responsible for undertaking, with the Safeguarding Trustee, an annual review of operations, identifying any areas of work which present new safeguarding risks, and defining appropriate mitigation actions.

  • Board Chair & Chair of the Management Committee:

The Chair of the Board and Chair of the Management Committee are responsible for supporting the Safeguarding Manager and Safeguarding Trustee to ensure reports of incidents or suspected incidents of abuse are investigated and dealt with appropriately.

  • Debt Justice Board

The Board has ultimate and collective responsibility[2] for ensuring that Debt Justice:

  • Has appropriate policies and procedures in place, which are followed by all Trustees, volunteers and beneficiaries
  • Checks that people are suitable to act in their roles
  • Knows how to spot and handle concerns in a full and open manner
  • Has a clear system of referring or reporting to relevant organisations as soon as concerns are suspected or identified
  • Sets out risks and how they will be managed in a risk register which is regularly reviewed
  • Follows statutory guidance, good practice guidance and legislation relevant to their charity: this guidance links to the main sources of information
  • Is quick to respond to concerns and carry out appropriate investigations
  • Does not ignore harm or downplay failures
  • Has a balanced Trustee board and does not let one trustee dominate its work – trustees should work together
  • Makes sure protecting people from harm is central to its culture
  • Has enough resources, including trained staff/volunteers/trustees for safeguarding and protecting people
  • Dealing with Safeguarding Issues

Debt Justice will take any disciplinary action necessary against staff or trustees if they are found to have breached our Code of Conduct and Safeguarding Policy. If such an incident occurs, Debt Justice’s Disciplinary Policy will be invoked.

There will be times when the behaviour of employees may constitute a breach of the Code of Conduct, but not be considered criminal conduct under UK or local legislation. In this instance Debt Justice may consider providing other support to these staff, for example, training, counselling, increased supervision or transfer to other duties.

This will be cognisant of any ongoing risk to beneficiary communities, staff and volunteers and we will always err on the side of caution.

There may be cases where Debt Justice feels it is appropriate to dismiss an employee even if the behaviour is not criminal, for example a gross violation of the Safeguarding Policy or Code of Conduct.

Identifying information about safeguarding should be shared on a ‘need to know’ basis only. Any staff members who raise concerns of serious malpractice should be protected as far as possible from victimisation or any other detrimental treatment if they come forward with concerns, provided that concerns are raised in good faith.

Deliberate false allegations are a serious disciplinary offence and will be investigated by Debt Justice.

The Safeguarding Manager will ensure that reports are made to the Charity Commission, relevant donors and where applicable to relevant statutory authorities.

We aim to seek feedback regularly from those we work alongside, and we seek to always learn from any mistakes.  Each safeguarding concern that is reported is also an opportunity to learn, adapt and improve our practice and processes.

  1. Recruitment

 It is our policy that no-one shall work within Debt Justice who:

  • Has been convicted of or has received a formal police caution concerning an offence against children; or
  • Has been convicted of or has received a formal police caution concerning sexual offences against adults; or
  • Is notified to us as having a red flag in relation to safeguarding by a former employer

Debt Justice will ensure all workers will be appointed, trained, supported and supervised in accordance with government guidance on safe recruitment. This includes ensuring that:

  • There is a written job description / person specification for the post
  • Those short listed have been interviewed
  • Safeguarding has been discussed at interview where the applicant will be working with children, adults at risk or beneficiary communities
  • Two references have been obtained including one from the most recent employer
  • A Disclosure and Barring Service (DBS) check or local equivalent is completed, where available and appropriate for the role
  • Qualifications where relevant have been verified
  • A suitable training programme is provided for the successful applicant
  • The applicant has completed a probationary period
  • The applicant has been given a copy of the organisation’s safeguarding policy and knows how to report concerns
  • The successful application signs Debt Justice’s Code of Conduct
  1. Digital safety

Debt Justice does not tolerate online abuse (see definition in appendix 1). Any instances of online abuse by a representative of Debt Justice or using Debt Justice equipment will be dealt with through the disciplinary policy. Online abuse of a Debt Justice representative by an external party should be reported to senior management, either as a safeguarding concern or through the normal line management structure.

Online spaces where Debt Justice supporters and other members of the public interact with each other and Debt Justice representatives (for example the chat function of online webinars) will be moderated by Debt Justice staff for inappropriate content. Online meetings will not be recorded without the express permission of all participants and personal information of supporters, partners and allies will never be shared without their consent, in accordance with the Debt Justice data protection policy.

  1. Accommodation

Debt Justice staff will always have the option of individual accommodation when staying away from home for work. While staff may share apartments or Air B&Bs, all staff will be asked to positively consent to this, and no-one will be pressured to share. Accommodation booked online must have at least five positive reviews. Apartments or Air B&Bs must be booked for exclusive hire only, and only shared with colleagues or people known to staff. In shared accommodation, all staff will always have their own bedroom.

Debt Justice representatives may not offer their personal accommodation to, nor accept offers to share personal accommodation from, supporters, volunteers and allies, unless a personal relationship exists outside the work context.

  1. Responsibilities in relation to children and adults at risk

Representatives of Debt Justice must not:

  • Hit or otherwise physically assault or physically abuse children or adults at risk
  • Develop physical/sexual relationships with children or adults at risk
  • Develop relationships with children or adults at risk, which could in any way be deemed exploitative or abusive
  • Place themselves in a position where they could be accused of sexually abusing a child, young person or adult at risk, i.e. holding or hugging a child, young person or adult at risk, or physically touching children, young persons or adults at risk in a way that could be considered abusive in ways described in this document
  • Spend time alone with children or adults at risk as part of their work with Debt Justice. Plan activities so that more than one person is present or, at least, other people are within sight and hearing. Wherever possible ensure that another adult is present to supervise the activity
  • Take children/adults at risk alone in a car, even on short journeys, as part of their work with Debt Justice
  • Act in ways that may be abusive or may place a child or adult at risk of abuse
  • Use language, make suggestions or offer advice, which is inappropriate, offensive or abusive
  • Use the position of power conferred by their role with Debt Justice to exert pressure in order to gain economically, professionally or sexually, or extract or accept favours, bribes, gifts or other forms of personal enrichment.
  • Show favouritism to any individual for sexual favours in return
  • Act in ways intended to shame, humiliate, belittle or degrade children or adults at risk, or otherwise perpetrate any form of emotional abuse

All representatives must:

  • Treat everyone with dignity and respect, recognising their right to personal privacy
  • Be aware of situations that may present risks and manage these
  • Plan and organise events and activities so that risks are minimised
  • Avoid being drawn into inappropriate attention-seeking behaviour, such as tantrums or crushes
  • Never sleep in the same room or bed as a child or adult at risk with whom they are working
  • Avoid shared accommodation with children or vulnerable adults UNLESS:
    • The care-giver is also staying in the same accommodation and has given explicit consent for the staff person to stay there AND
    • The staff member is DBS checked
  • Never ask for accommodation from a supporter, or put any pressure on supporters or allies to accommodate them.
  • If a residential event is being planned, the person organising the event must ensure that adults at risk and/or children never share accommodation with an adult who is not their care-giver unless explicit consent has been given by the care-giver
  • Remember that someone else may misinterpret your actions, no matter how well intentioned
  • Adults should avoid being placed in a compromising or vulnerable position. The adult (not at-risk) is always considered responsible.

ANNEX 1: Definitions

  1. Safeguarding

Safeguarding is defined by the Care Act 2014 as protecting a person’s right to live in safety, free from abuse and neglect.

  • Vulnerability

As defined by the Core Humanitarian Standard people may be vulnerable because of individual factors such as age (particularly the very young and the very old), disability or illness or because they are caring for others who are vulnerable. Social and contextual factors also contribute to people’s vulnerability. These include discrimination and marginalisation (e.g. in some contexts, the low status and power of women and girls), social isolation (including the lack of access to information), environmental degradation (e.g. soil erosion or deforestation), climate variability, poverty, lack of land tenure, poor governance, ethnicity, class, caste, and religious or political affiliations.

  • Child

A child is defined as anyone under 18 years old, irrespective of local definition.

  • Adult at risk

Sometimes also referred to as vulnerable adult. A person who is or may be in need of care by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.

  • Abuse

Abuse may include, but is not exclusive to:

  • Physical abuse or physical injury, such as evidence of hitting, kicking or shaking, where there is definite knowledge or reasonable suspicion, that the injury was inflicted or knowingly not prevented.
  • Domestic violence or abuse, which includes any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been, intimate partners or family members.
  • Psychological or emotional abuse where harm is done by persistent or severe emotional ill treatment or rejection, such as degrading punishments, threats and withholding due care, resulting in adverse effects on behaviour and emotional developments of a person.
  • Sexual abuse where exploitation of a person occurs. This includes rape, incest and all forms of sexual activities including pornography. Exchanging of benefits, for example goods, food and money in exchange for sexual favours.
  • Neglect, where basic needs such as food, warmth and medical care are not met, or when there is a failure to protect a person from exposure to any kind of danger, resulting in serious impairment of a person’s health or development.
  • Sexual Harassment is unwanted behaviour of a sexual nature which: violates your dignity, makes you feel intimidated, degraded or humiliated or creates a hostile or offensive environment.

NB. You don’t need to have previously objected to someone’s behaviour for it to be considered unwanted. Sexual harassment can include:

  • Sexual comments or jokes
  • Physical behaviour, including unwelcome sexual advances, touching and various forms of sexual assault
  • Displaying pictures, photos or drawings of a sexual nature
  • Sending texts or emails with a sexual content
  • Financial or material abuse, which can include theft, fraud, preventing a person from accessing their own money or benefits, and putting undue pressure on them in connection with financial transactions.
  • Modern slavery, which includes human trafficking, forced labour, domestic servitude, sexual exploitation and debt bondage
  • Discriminatory abuse, which can be unequal treatment, verbal abuse or harassment based on protected characteristics under the Equality Act 2010, but also substandard service provision or denying access to basic rights to healthcare, education and employment on grounds of a protected characteristic.
  • Organisational or institutional abuse, which is the mistreatment of people brought about by poor or inadequate care or support, or systematic poor practice, in an institution or organisation.
  • Online abuse, which can include cyber bullying, harassment and stalking, the creation and sharing of sexually explicit materials, grooming or being persuaded to perform sexual acts online or being exposed to sexual content.
  • Individual accommodation
  • Individual accommodation means a hotel room, a self-contained bedroom and bathroom with a door that locks, or a sole-occupied whole apartment / house.
  • Shared accommodation
  • Shared accommodation means a shared house or flat with no locks on bedroom doors.

[1] See Charity Commission guidance on what constitutes a serious incident and should be reported: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/752170/RSI_guidance_what_to_do_if_something_goes_wrong_Examples_table_deciding_what_to_report.pdf

[2] Please see: https://www.gov.uk/guidance/safeguarding-duties-for-charity-trustees

Share This