海角社区

1. Reference

This Policy is the overarching policy that sits above the following policies, which must be read in conjunction with it:

• PSEAH (Prevention of Sexual Exploitation, Abuse and Harassment) Policy;

• Child Safeguarding Policy;

• Prevention of Modern Slavery and Trafficking in Persons Policy; and

• Anti-Bullying and Harassment Policy.

Relevant to the above suite of safeguarding policies are the following policies:

• Anti-Bribery and Corruption Policy; and

• Whistleblowing Policy.

2. Introduction

As a humanitarian organisation, The 海角社区 Trust (海角社区) is committed to providing a safe, respectful, and trusted environment for all individuals who come into contact with our work. This includes communities impacted by our programmes, particularly children and adults who may be more vulnerable to abuses of power鈥攁s well as staff, volunteers, and partners.

海角社区 maintains zero tolerance to Safeguarding misconduct and will investigate all allegations following due process and with a survivor centred approach.

The Trustees hold ultimate accountability for ensuring that 海角社区鈥檚 activities do not cause harm and that all individuals are treated safely, appropriately, and with dignity and respect.

3. Scope

This Policy applies globally to any 海角社区 employees, partners, and other representatives, both during and outside of working hours. This includes the Trustees, senior managers, officers, other employees, consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with 海角社区, wherever they are located.

This Policy applies across all 海角社区 operations, except where local legislation imposes more stringent requirements. In all other circumstances, 海角社区鈥檚 standards take precedence.

4. Summary of Key Safeguarding Commitments

海角社区 is committed to:

Providing a safe and trusted environment for all individuals connected to the organisation;

Promoting an organisational culture which prioritises safeguarding and where concerns can be raised safely, confidentially, and without fear of retaliation;

Maintaining effective safeguarding policies and procedures to prevent harm.

Ensuring clarity on internal and external reporting requirements, including obligations to donors and regulatory authorities.

海角社区 fosters a culture in which safeguarding reporting is encouraged and expected, and reporters are protected from retaliation.

All safeguarding concerns must be reported immediately and will be handled confidentially by trained personnel. Disclosure of identities will only occur when necessary for safety and will be done in consultation with the reporter. Failure to disclose a safeguarding concern may result in disciplinary measures - reports can be made anonymously.

海角社区 has a zero-tolerance approach to safeguarding misconduct and will ensure that all reports are responded to appropriately.

5. 海角社区's Values

海角社区鈥檚 Values, as set out In the Code of Conduct, define the behaviours expected from Trustees, senior managers, officers, other employees, consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with 海角社区, wherever they are located.

Adherence to these values is essential to maintaining safe and respectful working environments. Strict adherence to our Values is at the core of effective safeguarding and everyone coming in contact with 海角社区 should expect to be treated in accordance with them.

6. Roles and Responsibilities

6.1. Trustees

Trustees recognise the importance of safeguarding as a governance priority and are accountable for overseeing the adherence to this Policy, and other related Safeguarding Polices, across the organisation.

6.2. Senior Managers and Leadership

Hold accountability for this Policy, its implementation at programme level and staff adherence to it

Accountable for ensuring that staff have received training in PSEAH and Child Safeguarding.

Accountable for identifying those staff whose roles put them in direct contact with children and ensuring that they receive appropriate child safeguarding training and background checks.

6.3. Managers

Ensure the development and maintenance of a safe working environment.

Socialise the 海角社区 Code of Conduct and Safeguarding Policies to all staff and communities impacted by 海角社区鈥檚 work.

Ensure appropriate safeguarding risk assessments in their areas of activity.

6.4. All Staff

Required to report any suspected or actual safeguarding misconduct. Failure to report a safeguarding concern may result in disciplinary action.

Ensure that they know how to report safeguarding concerns using the 海角社区 reporting mechanisms.

Required to keep confidentiality of information relating to any safeguarding case they may be involved with. Breaches of confidentiality may result in disciplinary action.

Report any allegations made against you immediately to your line manager or other senior manager, in line with investigation procedures.

6.5. Programme safeguarding leads

Delivery of safeguarding training to all staff, appropriate to their roles.

Socialise the Safeguarding Policies to all stakeholders.

Delivery of safeguarding training to all staff.

Progression of the safeguarding action plan.

6.6. Global Safeguarding Lead

Ensure that all programmes have a safeguarding self-review and action plan in place.

Collate all safeguarding and child safeguarding reports across the organisation and extrapolate lessons to be learned and best practice from safeguarding cases.

Work with the General Counsel to submit Serious Incident Reports to the Charity Commission, as required, and for liaising with the Senior Partnership Manager for donor reporting.

Overall oversight of all safeguarding and child safeguarding concerns raised and how these are responded to.

6.7. Local HR staff

Develop context specific policy implementation guidance.

Ensure that this Policy, and other related policies are disseminated at the programme level.

Provide expert advice on local labour law for safeguarding investigations.

7. The Survivor Centred Approach

The survivor centred approach places the survivor鈥檚 needs, rights, wishes, and safety at the core of all actions. It aims to empower survivors by focusing on their dignity, fostering recovery, and ensuring they have control over their identity in decision-making processes.

海角社区 is committed to responding to safeguarding concerns using a survivor centred approach. This includes:

• Safety: Prioritising the safety and wellbeing of the survivor;

• Confidentiality: Sharing information only with informed consent and on a need-to-know basis;

• Respect: Ensuring all decisions reflect the survivor鈥檚 wishes, rights, and dignity;

• Non-discrimination: Providing equitable support, regardless of personal characteristics;

• Information: ensuring that the survivor has the information to be able to make informed decisions about engagement with a safeguarding investigation; and

• Impartiality: Ensuring allegations are handled independently, without conflicts of interest.

8.Risk Management

Risk鈥恗anagement is key to all safeguarding. Safeguarding risk management involves assessing operations to identify safeguarding risks and to implement mitigation measures. Risk assessment is integral both to programme design and to the management of safeguarding concerns.

9.Safe Recruitment

海角社区 is committed to preventing individuals who pose safeguarding risks from joining or re-entering the organisation or being re-deployed. All staff undergo criminal record checks (DS, DBS, or national equivalents) in line with 海角社区 recruitment procedures. Programmes must conduct appropriate due diligence, within national constraints, to assess candidate suitability.

海角社区 is signed up to the Misconduct Disclosure Scheme. This scheme facilitates the sharing of Sexual exploitation and sexual abuse misconduct data between employers.

10.Partner Organisations

All partner organisations are required to comply with this Policy and 海角社区鈥檚 Values and Standards. Contractual agreements and due diligence processes ensure safeguarding obligations are met.

Where required, 海角社区 will support partners to strengthen their safeguarding capacity.

11. Reporting of Suspected or Actual Safeguarding Misconduct

海角社区 is committed to ensuring that 海角社区 staff and related personnel, as well as communities impacted by our work, have multiple, accessible channels to report safeguarding misconduct, developed in consultation with affected stakeholders.

海角社区 is committed to ensuring that staff, related personnel and communities impacted by our work are informed of what constitutes safeguarding misconduct and what reporting channels are available.

All staff have a duty to report any suspected or actual safeguarding misconduct. Failure to report misconduct may result in disciplinary action.

All staff making reports in good faith will be protected in accordance with the Whistleblowing Policy.

Any breaches in confidentiality may result in disciplinary action and, if upheld, could result in dismissal.

When reporting a suspected or actual safeguarding concern, do not copy in multiple people. The person receiving the report has a duty to escalate up to the Global Safeguarding Lead.

12. Reporting Channels

• Line Manager or other Senior Manager

• Global Safeguarding Lead: Xara Church (WhatsApp +44 744359818; Teams; safeguarding@halotrust.org)

• SafeCall (independent, anonymous): safecall.co.uk/report | +44 191 516 7749

• Local reporting mechanisms (e.g. hotline).

• Whistleblowing channel 鈥� whistleblowing@halotrust.org

13. Responding to Safeguarding Incidents

海角社区 will:

• Provide accessible, confidential, and culturally appropriate reporting mechanisms;

• Ensure all staff and related personnel receive safeguarding training and understand their reporting obligations;

• Respond promptly and appropriately to all concerns, engaging professional advice and informing relevant authorities when required;

• Ensure investigations follow due process and are conducted by trained, neutral specialists, with oversight by the Global Safeguarding Lead; and

• Uphold obligations to report safeguarding related serious incidents to the Charity Commission when criteria are met.

14. Implementation

This Policy and associated policies and procedures are provided to all staff, volunteers; and Trustees during induction. Annual safeguarding training is mandatory.

Awareness raising with communities impacted by our work is also required to ensure they understand their rights and reporting pathways.

Where national laws differ from this Policy, programmes should identify and provide guidance to ensure that this Policy is contextualised to ensure appropriate adherence to national laws. This Policy takes precedence unless local laws exceed its standards.

Failure to comply with this Policy constitutes gross misconduct and may result in dismissal.

15. Mainstreaming of Safeguarding

海角社区 is committed to ensuring that all programmes meet international safeguarding standards, with a Safeguarding Action Plan in place to achieve this.

The Programme Manager has responsibility to ensure that a member of the programme is allocated to progress the Safeguarding Action Plan.

16. Monitoring and Review

The Global Safeguarding Lead will review this Policy annually, or more frequently if needed. The Board of Trustees must approve all material updates.

Staff are encouraged to provide feedback to support continuous improvement.

17. Definitions, in Line with UN Definitions

Bullying: rude, abusive, or threatening behaviour or misuse of power that intends to make a person feel humiliated, fearful or ashamed.

Commercial Sexual Exploitation of Children: Comprises sexual abuse by the adult and remuneration in cash or kind to the child or a third person or persons. The child is targeted as a sexual object and as a commercial object.

The Commercial Sexual Exploitation of Children constitutes a form of coercion and violence against children and amounts to forced labour and a contemporary form of slavery.

Duty of care: a common law concept that refers to the responsibility of the organisation to provide children with an adequate level of protection against harm. It is the duty of the organisation to protect children from all reasonably foreseeable risk or injury.

Harassment: any improper, or unwelcome conduct that might cause offence, or the humiliation of another person. Harassment could be in the form of words, gestures or actions which annoy, alarm, abuse, demean, intimidate, belittle, humiliate, or embarrass another, or which create an intimidating, hostile, unstable/inconsistent, or offensive work environment. Harassment is when bullying is because of a person鈥檚 identity, or who they are such as their age, gender, race, ethnicity, disability, religion, sexual identity etc. Often harassment is covered by law.

Perpetrator: a person (or group of persons) who commits an act of sexual exploitation or abuse. For the purposes of this guideline, a perpetrator means 海角社区 staff or related personnel.

Sexual Abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. This would include forced marriage and sexual slavery and includes sexual activity with a child.

Sexual Exploitation: 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.

Sexual Harassment: Any unwelcome sexual advance, request for sexual favour, verbal or physical conduct or gesture of a sexual nature, or any other behaviour of a sexual nature that might reasonably be expected or be perceived to cause offence or humiliation to another. Such conduct will also be considered sexual harassment when it interferes with work, is made a condition of employment, or creates an intimidating, hostile or offensive work environment. While typically involving a pattern of behaviour, it can take the form of a single incident. Sexual harassment may occur between persons of the opposite or same sex. Both males and females can be either the victims or the offenders.

Subject of Complaint (SoC): a person who has had an allegation of misconduct made against them.

Victim/Survivor: a person who is or has been sexually exploited or abused.

Victim/Survivor: centred approach places the rights, wishes, needs, safety, dignity and well颅being of the victim/survivor at the centre of all prevention and response measures concerning sexual exploitation and abuse (SEA) and sexual harassment (SH).

Last updated: 11 August 2026