REN Safeguarding Policy

Refugee Employment Network acknowledges that all people have the right to live a life free from abuse and exploitation and is committed to uphold these rights by implementing and maintaining a robust system of safeguarding.

Refugee Employment Network is fully committed to the protection of vulnerable persons, young and old and will not tolerate any form of abuse or exploitative acts being perpetrated by our Trustees, employees, volunteers or anyone associated with the delivery of our programmes.

Employees and managers are bound to uphold this policy and to report people or incidents that they believe contravene it.

We recognise our responsibility to take all reasonable steps to promote safe practice and to create a working culture and environment in which children, young people, vulnerable adults and any participants/beneficiaries of our support are protected from abuse. Trustees, staff, vounteers and visitors are encouraged and supported to work together to ensure an ethos that embraces difference and diversity and respects the rights of all vulnerable people.

We acknowledge our duty to respond appropriately to any allegations, reports or suspicions of abuse (neglect, physical, sexual or emotional harm) and that appropriate disciplinary measures are taken
As outlined in our code of conduct, we must demonstrate respect, courtesy and professionalism with all our colleagues. We have a zero tolerance approach to any kind of discriminatory behaviour, harassment, bullying, sexual misconduct or victimisation of any kind.

Refugee Employment Network will not tolerate any form of abuse and believes that every individual who participates in or benefits from our programmes either directly, or through our partners, has a right to protection from abuse, regardless of their age, culture, disability, gender, racial origin, language, religious belief or sexual orientation.

Refugee Employment Network considers it the duty of its Trustees, staff, volunteers and visitors to ensure vulnerable people (children, young people and adults), and any participants/beneficiaries of any project with whom they come into contact are protected from abuse.

Refugee Employment Network also considers it the duty of its member organisations to ensure they have adequate safeguarding arrangements in place including a policy framework and mechanisms to provide assurance on compliance.

Refugee Employment Network, through its work and the behaviour of all Trustees, staff, volunteers and visitors, is committed to ensure that:

1. Everyone has the right to protection from abuse and neglect and should be able to live a life of inclusion and participation, wherever they are, and
2. Everyone has the right to have a dignified, healthy and secure life.

The organisation seeks to prevent the abuse of anyone by the unquestioning recognition of human rights, adhering to the Children’s Act 2004, Working Together 2015 and the Care Act 2014 as well as the UN Universal Declaration of Human Rights with particular reference to Article 5 which states: No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment.

In addition we adhere to the UN Convention on the Rights of the Child and have as our starting point as a definition of abuse, Article 19 which states:

(i) Parties shall take all appropriate legislative, administrative, social and educational measures to protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s) or any other person who has the care of the child.

Such protective measures should, as appropriate, include effective procedures for the establishment of social programmes to provide necessary support for the child and for those who have the care of the child, as well as for other forms of prevention and for identification, reporting, referral, investigation, treatment and follow-up of instances of child maltreatment described heretofore, and, as appropriate, for judicial involvement.

We also seek to prevent harm to any beneficiary/participant of Refugee Employment Network’s support caused by the improper or poor design and implementation of our projects.

For the purpose of this policy:

• a vulnerable person is a child, young person or vulnerable adult;
• a child or young person is defined as anyone under the age of 18;
• a vulnerable adult is defined as a person over the age of 18 with additional care and support needs (The Care Act 2014), who is or may be in need of services 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 is defined as the violation of an individual’s human and civil rights by another person or persons. Abuse may consist of a single act or repeated acts. It may be physical, verbal or psychological, it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which he is she has not consented, or cannot consent. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it. Forms of abuse include physical, sexual, psychological, financial or material, neglect or acts of omission and discrimination

Abuse can take many forms and may be a single or repeated act, which has gone unchallenged for years. The following list indicates some of the many type of abuse that can occur, but is not exhaustive. Any, or all, of these types of abuse may occur as the result of deliberate intent, negligence or ignorance.

Physical: Includes hitting, slapping, pushing, kicking, misuse of medication, restraint or inappropriate sanctions.

Sexual: includes rape and sexual assault or sexual acts to which the vulnerable person has not consented, or could not consent or was pressured into consenting.

Psychological/emotional: includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse and isolation or withdrawal from services or supporting networks.

Financial or material abuse: financial abuse can range from failure to access benefits, through inadvertent mismanagement and opportunistic exploitation to deliberate and targeted abuse, often accompanied by threats and intimidation. It can include theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, overcharging or carrying out unnecessary work, or the misuse or misappropriation of property, possessions or benefits.

Neglect and acts of omission: includes ignoring medical or physical care needs, failure to provide access to appropriate health, social care or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.

Discrimination: includes language, attitudes or actions that discriminate on the basis of age, culture, disability, gender, racial origin, language, religious belief or sexual orientation, and other forms of harassment, slurs or similar treatment.

Professional and/or institutional abuse: Poor working practice and failure to meet the needs of clients can be considered abuse. This may take the form of isolated incidents of poor or unsatisfactory professional practice, pervasive ill-treatment or gross misconduct. Repeated instances of poor working practice may be an indication of more serious problems, and when identified or reported will require investigation.

Criminal Acts: Some types of abuse will constitute a criminal offence, in which case adults who lack capacity are entitled to the protection of the law in the same way as any member of the public. Whenever a criminal offence is suspected, Refugee Employment Network will make a referral to the police, or will report it to our partner organisation and request that they make a referral to the police and other appropriate authority in the location/country where the abuse takes place. It may be necessary to make an urgent referral for the public safety of the vulnerable person and/or to protect or preserve evidence. Criminal investigation by the police takes priority over all other lines of enquiry.

In order to promote safe practice and to create a working culture and environment in which children and vulnerable adults are protected from abuse Refugee Employment Network will:

• ensure Trustees, staff and volunteers are trained to understand the protection of vulnerable persons, what constitutes abuse and how to identify it;
• provide clear internal procedures for identifying and dealing with concerns about possible abuse and ensure Trustees, staff and volunteers are familiar with them;
• ensure that necessary checks are made before finalising the recruitment of staff and adopt enhanced checks for recruiting positions that may be in direct contact with vulnerable persons;
• ensure that all partner organisations adhere to the Safeguarding principles outlined in this policy. We are committed to assist in building the capacity of our partner organisations to meet these stringent requirements.  This includes taking measures so that beneficiaries and participants of our projects are made aware of their ability to report their complaints and concerns.

• Refugee Employment Network adheres to the Red Cross Code of Conduct (1995) and will not portray vulnerable people in a manipulative or sensational manner, neither in words nor images. Everyone has a right to be accurately represented and will only be presented by Refugee Employment Network in a manner that preserves dignity;
• Refugee Employment Network will seek to avoid depicting vulnerable persons as helpless victims but instead as dignified humans;
• Any information that could be used to identify the location of a vulnerable person and cause them to be put at risk shall not be used in any form of communication for general or public purposes

Safer practice in recruitment means thinking about, and including issues to do with, safeguarding and every stage of the process. This may include:

• ensuring any job description makes reference to the responsibility for safeguarding;
• obtaining and scrutinising comprehensive information from applicants, and taking up and satisfactorily resolving any discrepancies or anomalies;
• verifying the successful applicant’s identity;
• verifying that the successful applicant has any academic or vocational qualifications claimed;
• checking his or her previous employment history and experience

UK nationals recruited by Refugee Employment Network to perform work that might bring them into contact with vulnerable persons must agree to undergo a DBS disclosure. The level of disclosure needed will depend on the nature of the position. Those who work directly with vulnerable people will be required to undertake appropriate training. All trustees will undergo DBS checks as well. DBS checks will be repeated every three years for staff / trustees.

Refugee Employment Network is committed to supporting staff to understand this Policy and related documentation, and to providing the opportunity to discuss it with their line manager and colleagues in an open environment. Staff must adhere to our Code of Conduct.

Refugee Employment Network will nominate a Trustee to ensure the Policy is implemented as the Safeguarding Lead. Chair of Trustees, Janice Lopatkin (janice@worldjewishrelief.org)
If any person within Refugee Employment Network has any questions or concerns regarding vulnerable persons protection they should raise them with the Chair of Trustees.

In no circumstance should concerns of abuse and inappropriate behaviour be ignored. The need to ensure the immediate physical and psychological safety of the vulnerable adult or child should always be of paramount importance, and reporting concerns can help to ensure that all appropriate and practical guidance can be sought.

All Refugee Employment Network Trustees, staff, volunteers and visitors are obliged to report any suspicions, allegations or witnessed actions, however uncertain, that might, in any way, breach the Refugee Employment Network Safeguarding Policy, by following the reporting guidelines.

When responding to concerns raised, regarding Safeguarding, the best interests of the vulnerable person will always be paramount. Decisions will be made that attempt to ensure the best outcomes for the vulnerable person.

Supervision and support will be provided for Refugee Employment Network personnel by the Safeguarding Lead, the Chair of Trustees and the National Co-ordinator following an incident or allegation.

Trustees, staff and volunteers will be informed of this policy and where to access it. All Refugee Employment Network personnel must read, understand and adhere to this policy and know where to access it. Failure to comply with this policy will lead to disciplinary action. Also, training on safeguarding is provided for all employees.

Trustees, staff, volunteers and visitors have a responsibility to be aware of and alert to signs that all is not well with a vulnerable person. However, they are not responsible for diagnosing, investigating or providing a therapeutic response to abuse. It is also not the responsibility of the member of staff to whom the allegation is made to ascertain whether or not it is true. It is his/her responsibility to report the concern via the process outlined in this policy.

There are two main ways in which an allegation or suspected incident of abuse may be identified.

• Incidents of suspected abuse may be observed by a Refugee Employment Network trustee, staff, volunteer or visitor;
• Allegations or incidents of abuse may be disclosed by a vulnerable person to a Refugee Employment Network trustee, staff, volunteer or visitor

When a report is received or anxiety is first expressed, the seriousness or extent of abuse is often not clear. In addition, not all concerns relate to abuse, there may well be other explanations. It is therefore important, when considering the appropriate intervention, to deal with reports of incidents or allegations with an open mind. Trustees, staff, volunteers or visitors who are concerned that something is wrong must act immediately and raise the issue with their line manager or the the Chair of Trustees or another Trustee.

When making any assessment of the severity of an incident, the following factors must be considered:

• The vulnerability of the individual;
• The nature and extent of abuse;
• The length of time it has been occurring;
• The impact on the individual and if they are still at risk;
• The risk of repeated or increasingly serious act involving this or other vulnerable adults;
• The mental capacity of the alleged victim and alleged perpetrator

The Safeguarding Lead will then decide, or take advice, on whether or not the matter should be referred to statutory services and if there should be an investigation internally.

Some instances of poor practice, inappropriate action or language or an error in judgement can be considered abuse, but may be corrected by discussing with everyone involved what went wrong and then resolving and documenting the issues and the actions taken. In all other circumstances and/or where the alleged victim wishes to, an alert record sheet must be completed.

It is recognised that clients can be particularly vulnerable to abuse in certain situations and/or environments. Refugee Employment Network personnel who are concerned that clients of members may be in a potentially abusive situation/environment must inform their line manager and the Chair of Trustees, who will then investigate.

It is essential that all Refugee Employment Network personnel are alert to the possibility that a vulnerable person may seek to disclose criminal acts and abuse and where this does occur, consideration should be given to helping the alleged victim to access external advocacy support.

Refugee Employment Network personnel must always explain to the alleged victim that they cannot keep the disclosure secret but can reassure him/her that only those who need to know will be told. Also that such information will generally only move up the organisation’s line management structure and be given to the statutory authorities in line with local or country requirements.

• When responding to concerns raised regarding vulnerable people protection, the best interests of the vulnerable person will always be paramount. Decisions will be made that attempt to ensure the best outcomes for the vulnerable person.

• Any incidents or concerns shall be raised and discussed with the relevant line manager, or the Safeguarding Lead. See Appendix B; Report Form on Suspected Abuse for information on how and what to record.
  If the incident includes their line manager or the Safeguarding Lead then the person reporting the incident should report to the Treasurer.

• Any incident should be reported within 48 hours of concerns being raised or witnessed.

• The appropriate action will be decided upon by the line manager and the Chair of Trustees in consultation with the Treasurer. The Chair of Trustees must always be notified of the incident who will then inform all Trustees of any serious incident.

• All incidents or concerns shall be recorded in a Vulnerable Persons Protection File and signed and dated by the person who raised the concern and the Chair of Trustees.

• The Vulnerable Persons Protection File shall be kept in a secure place. This file will be confidential and can only be accessed by the Chair of Trustees and the Treasurer.

• All incidents must be reported to the relevant authorities. If a formal referral is not made to the police or government social services then a clear rationale for this decision must be recorded in the Vulnerable Person Protection File and signed by the Chair of Trustees. A decision not to report any concerns must include the Trustees.

• Following an incident or allegation, Refugee Employment Network will do everything within its power to ensure that vulnerable people are removed from further harm and that we are survivor centred in any investigations.

• Supervision and support will be provided for Refugee Employment Network personnel by the chair of Trustees and the Treasurer following an incident or allegation.

• In the event of allegations from a vulnerable person, guidelines in the appendix must be followed.

• All Serious Incidents (SIR) incidents will be reported to the Charity Commission by the Chair of Trustees.

• If an allegation of a violation of the Refugee Employment Network Safeguarding Policy is made concerning a named individual from a verifiable source against any Refugee Employment Network Trustee, member of staff, volunteer or visitor, they will be suspended from all activity or association with Refugee Employment Network pending the outcome of an independent investigation upon the advice of the relevant authorities.

• If an independent investigation concludes that anyone associated with Refugee Employment Network has committed an act in relation to vulnerable people – whether within or outside the context of our work – that is criminal, infringes upon rights or contravenes the principles and standards of Refugee Employment Network Safeguarding Policy, Refugee Employment Network will take immediate disciplinary action and any other action that may be appropriate.

• Refugee Employment Network will involve the police or necessary authorities to ensure the protection of vulnerable people and criminal prosecution where this is appropriate this may include the Children’s Board or Local Authority Designated Officer.

• A decision to suspend is not subject to challenge. When investigating and determining any concerns or complaints, the process should always be fair and any adverse determination shall be open to challenge through an appeals process.

• See Refugee Employment Network Whistle Blowing Policy for additional information.

• Whistleblowing policy
• Anti-bribery and corruption policy
• Equal opportunities and discrimination policy
• Personal harassment policy
• Code of Conduct policy
• Disciplinary procedure policy
• Recruitment

Refugee Employment Network will ensure that staff, trustees, volunteers and anyone represented with our projects/programmes are aware of these policies and adhere to the guidance within them.

When a vulnerable person (child, young person or vulnerable adult) informs you that he/she is uncomfortable or concerned with a specific person's (adult or child’s) behaviour towards them or another vulnerable person, the following steps must be taken:

• Reassure them that they were right to report the behaviour;
• Listen carefully and calmly to them and ask questions to clarify the allegation so that you will be able to later report the incident correctly;
• During the conversation, try not to repeat the same questions, as this gives the vulnerable person the impression that they did not give correct information the first time and they are not fully believed;
• Do not promise confidentiality to the vulnerable person. Inform them that you must report the incident of inappropriate behaviour as it is in their best interest;
• Take proper steps to ensure the physical safety and psychological wellbeing of the vulnerable person. This may include referring them for medical treatment or to a psychologist;
• Make certain you distinguish between what the vulnerable person has actually said and the inferences you may have made. Accuracy is paramount in this stage of the procedure;
• Do not permit personal doubt to prevent you from reporting the allegation to the proper supervisor;
• If appropriate, let the vulnerable person know what you are going to do next and that you will let them know what happens

If you have knowledge that a vulnerable person’s safety might be in danger, please complete this form to the best of your knowledge. Please note that vulnerable person protection concerns must be reported directly to your line manager or Chair of Trustees immediately (preferably within the same working day). You may wish to complete this form before contacting this person or you may wish to complete the report after contacting this person. This report is to be used as a tool to develop the most unbiased information-based report possible. For confidentiality reasons, the report should be written and signed solely by you. It should be sent only to the designated contact person. It will be held in a safe and secure place and treated in the strictest confidence.

*This report form will be available to complete directly online from early August, 2022.

The Disclosure and Barring Service (DBS) helps employers to make safer recruitment decisions and prevent unsuitable people from working with vulnerable groups, including children. It replaces the Criminal Records Bureau (CRB) and Independent Safeguarding Authority (ISA).

Contact Details

DBS customer services
PO Box 3961
Royal Wootton Bassett
SN4 4HF

Email: customerservices@dbs.gsi.gov.uk

DBS helpline: 03000 200 190
International:  +44151 676 9390

The DBS is responsible for:

• processing requests for criminal records checks (DBS checks)
• deciding whether it is appropriate for a person to be placed on or removed from a barred list
• placing or removing people from the DBS children’s barred list and adults’ barred list for England, Wales and Northern Ireland

1. In Children and Young People

The following signs could be indicators that abuse has taken place but should be considered in context of the child’s whole life.

Physical

• Injuries not consistent with the explanation given for them
• Injuries that occur in places not normally exposed to falls, rough games, etc
• Injuries that have not received medical attention
• Reluctance to change for, or participate in, games or swimming
• Repeated urinary infections or unexplained tummy pains
• Bruises on babies, bites, burns, fractures etc which do not have an accidental explanation*
• Cuts/scratches/substance abuse*

Sexual

• Any allegations made concerning sexual abuse
• Excessive preoccupation with sexual matters and detailed knowledge of adult sexual behaviour
• Age-inappropriate sexual activity through words, play or drawing
• Child who is sexually provocative or seductive with adults
• Inappropriate bed-sharing arrangements at home
• Severe sleep disturbances with fears, phobias, vivid dreams or nightmares, sometimes with overt or veiled sexual connotations
• Eating disorders - anorexia, bulimia*

Emotional

• Changes or regression in mood or behaviour, particularly where a child withdraws or becomes clinging
• Depression, aggression, extreme anxiety
• Nervousness, frozen watchfulness
• Obsessions or phobias
• Sudden under-achievement or lack of concentration
• Inappropriate relationships with peers and/or adults
• Attention-seeking behaviour
• Persistent tiredness
• Running away/stealing/lying

Neglect

• Under nourishment, failure to grow, constant hunger, stealing or gorging food, Untreated illnesses, Inadequate care, etc
• *These indicate the possibility that a person is self-harming.

2. Signs of Possible Abuse in Adults

Physical abuse

• History of unexplained falls, fractures, bruises, burns, minor injuries
• Signs of under or over use of medication and/or medical problems left unattended
• Any injuries not consistent with the explanation given for them
• Bruising and discolouration - particularly if there is a lot of bruising of different ages and in places not normally exposed to falls, rough games etc.
• Recurring injuries without plausible explanation
• Loss of hair, loss of weight and change of appetite
• Person flinches at physical contact &/or keeps fully covered, even in hot weather
• Person appears frightened or subdued in the presence of a particular person or people

Domestic violence

• Unexplained injuries or ‘excuses’ for marks or scars
• Controlling and/or threatening relationship including psychological, physical, sexual, financial, emotional abuse; so called ‘honour’ based violence and Female Genital Mutilation
• Age range extended to 16 yrs.

Sexual abuse

• Pregnancy in a woman who lacks mental capacity or is unable to consent to sexual intercourse
• Unexplained change in behaviour or sexually explicit behaviour
• Torn, stained or bloody underwear and/or unusual difficulty in walking or sitting
• Infections or sexually transmitted diseases
• Full or partial disclosures or hints of sexual abuse
• Self-harming
• Emotional distress
• Mood changes
• Disturbed sleep patterns

Psychological abuse

• Alteration in psychological state e.g. withdrawn, agitated, anxious, tearful
• Intimidated or subdued in the presence of a carer
• Fearful, flinching or frightened of making choices or expressing wishes
• Unexplained paranoia
• Changes in mood, attitude and behaviour, excessive fear or anxiety
• Changes in sleep pattern or persistent tiredness
• Loss of appetite
• Helplessness or passivity
• Confusion or disorientation
• Implausible stories and attention seeking behaviour
• Low self-esteem

Financial or material abuse

• Disparity between assets and living conditions
• Unexplained withdrawals from accounts or disappearance of financial documents or loss of money
• Sudden inability to pay bills, getting into debt
• Carers or professionals fail to account for expenses incurred on a person’s behalf
• Recent changes of deeds or title to property
• Missing personal belongings
• Inappropriate granting and / or use of Power of Attorney

Modern slavery

• Physical appearance; unkempt, inappropriate clothing, malnourished
• Movement monitored, rarely alone, travel early or late at night to facilitate working hours.
• Few personal possessions or ID documents.
• Fear of seeking help or trusting people.

Discriminatory abuse

• Inappropriate remarks, comments or lack of respect
• Poor quality or avoidance care
• Low self-esteem
• Withdrawn
• Anger
• Person puts themselves down in terms of their gender or sexuality
• Abuse may be observed in conversations or reports by the person of how they perceive themselves

Institutional Abuse

• Low self-esteem
• Withdrawn
• Anger
• Person puts themselves down in terms of their gender or sexuality
• Abuse may be observed in conversations or reports by the person of how they perceive themselves
• No confidence in complaints procedures for staff or service users.
• Neglectful or poor professional practice.

Neglect and acts of omission

• Deteriorating despite apparent care
• Poor home conditions, clothing or care and support.
• Lack of medication or medical intervention

Self-neglect

• Hoarding inside or outside a property
• Neglecting personal hygiene or medical needs
• Person looking unkempt or dirty and has poor personal hygiene
• Person is malnourished, has sudden or continuous weight loss and is dehydrated – constant hunger, stealing or gorging on food
• Person is dressed inappropriately for the weather conditions
• Dirt, urine or faecal smells in a person’s environment
• Home environment does not meet basic needs (for example no heating or lighting)
• Depression

 

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