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Safeguarding policy

1. Purpose of this policy
The purpose of this policy is to protect people from any harm that may be caused due to their coming into contact with representatives of Debt Justice.

2. Policy Development
This policy is based on advice from Bond and Bates Wells Braithwaite and content adapted from the safeguarding policy of our partner Christian Aid.

3. Scope
This is an internal policy that applies to the work of Debt Justice as it directly impacts the lives of our beneficiaries, staff, trustees, supporters, and consultants.

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

5. 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.

We are committed to:
* Providing a safe and trusted environment for everyone who comes into direct 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
* 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 incidents of sexual harassment and abuse to the Charity Commission in the UK.
* 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

6. Roles & Responsibilities

* All staff, trustees and volunteers

It is the responsibility of all staff, trustees and volunteers to prevent and report any potential or suspected incidents of physical, sexual, emotional abuse or neglect of anyone resulting from their 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.

What to do when you suspect alleged abuse:
Actual, potential or suspected incidents of abuse must be reported immediately. Where appropriate you should make a report to your Line Manager who will inform the Director, who will ensure that the matter is appropriately investigated. Alternative reporting mechanisms are also noted below.

The need to report arises in the following instances:
• Abuse is observed or suspected
• An allegation of abuse is made
• Someone discloses abuse

No representative of Debt Justice will prejudice their own position or standing with Debt Justice by responsibly reporting potential or suspected abuse.

* Safeguarding Manager: Head of Finance and Operations

The Safeguarding Manager is 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 of information with appropriate people
* Producing a written report as soon as possible after the concern was raised (within 24 hours if possible)
* Keeping any written records securely in a locked place or in a confidential electronic folder

* Safeguarding Trustee

If an individual raising a safeguarding concern believes there are outstanding/unresolved issues or that there has been unreasonable delay in handling or addressing the concern, or wishes to raise a concern about the Safeguarding Manager or other senior members of staff, they can contact Debt Justice’s principle Safeguarding Trustee, who will conduct an appropriate investigation.

The Safeguarding Trustee is chosen by the board.
See Annex 2 for the responsibilities of the Safeguarding Trustee.
Your information will be treated in confidence. 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.

* Board Oversight

The Management Committee of the board provides oversight of the Safeguarding Policy on behalf of the board.  It receives confidential reports on incidents and also approves separate reporting, where applicable, to the Charity Commission under the Serious Incident Reporting Policy.

7. 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.

8. 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 applying have completed an application form including a self-declaration disclosure in relation to safeguarding
* 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

9. 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. In shared accommodation, all staff will always have their own bedroom.

Debt Justice representatives may accept offers to share the accommodation from supporters, volunteers and allies if such offers are received, provided they meet the responsibilities below. But they should never proactively approach supporters, volunteers and allies with requests for accommodation.

10. Responsibilities in relation to Children & 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 CRB 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. 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.  

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

3. 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.  

4. 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.
* 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 


5. 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  


6. Shared accommodation
* Shared accommodation means a shared house or flat with no locks on bedroom doors 


Annex 2 

Key Responsibilities of a Safeguarding Trustee:
* 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.  


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