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Policies

Safeguarding and Prevent Policy

1. Policy Statement

VI makes a positive contribution to a strong and safe community and recognises the right of every individual to stay safe. We are committed to safeguarding all individuals in its programs, ensuring protection from abuse regardless of age, race, religion, ability, gender, language, background, or sexual identity. 

We are also committed to preventing radicalization and extremism within our online internship programs. We acknowledge our responsibility to protect our community, fostering a culture of respect, inclusivity, and understanding.

All VI staff are expected to understand and adhere to this policy. VI provides regular training to participant-facing staff to help them identify and respond to signs of abuse or concerns. 

This Safeguarding and Prevent Policy (“Policy“) outlines our approach to meeting the Prevent Duty and promoting British values, in line with the Counter-Terrorism and Security Act 2015.

2. Legal Framework

The principal pieces of legislation governing this policy are:

  • The Care Act 2016; 
  • The Working together to Safeguard Children Act 2015; 
  • the Protection of Freedoms Act 2012; 
  • the Safeguarding Vulnerable Groups Act 2006; 
  • the Children Act 2004; 
  • the Adoption and Children Act 2002: 
  • the Care Standards Act 2000; 
  • the Human Rights Act 1998;
  • the Public Interest Disclosure Act 1998; 
  • the Police Act – CRB 1997; 
  • the Children Act 1989; 
  • the Mental Health Act 1983; 
  • the NHS and Community Care Act 1990; 
  • the Rehabilitation of Offenders Act 1974; 
  • Counter-Terrorism and Security Act 2015; 
  • the Prevent Duty Guidance (2015); and 
  • the Equality Act 2010. 

3. Related Policies

The scope of this Policy is broad ranging and in practice, it will be implemented via a range of policies and procedures within VI. These include our:

  • Whistleblowing policy;
  • Equality & Diversity policy;
  • Child Protection policy;
  • Digital Harassment policy;
  • Anti-Modern Slavery policy;
  • PSEAH policy;
  • Privacy policy;
  • Staff induction and training procedures. 

4. Scope of Application & Responsibilities

This policy applies to all persons working for VI or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. 

VI expects all staff (paid or unpaid) to promote good practice by being an excellent role model, contribute to discussions about safeguarding and to positively involve people in developing safe practices.

The Board of Directors of VI is responsible for: 

  • Ensuring that the policy is in place and appropriate; and 
  • Allocating sufficient resources (time and money) to ensure that this policy can be effectively implemented.

The CEO of VI will be responsible for ensuring that:

  • Ensuring that the policy is accessible and implemented; and
  • Liaising with and monitoring the Designated Safeguarding Lead’s (DSL) work.

The DSL is VI’s General Counsel. The DSL is responsible for:

  • Ensuring that the policy is monitored and reviewed;
  • Promoting the welfare of children and vulnerable adults; 
  • Ensuring staff  (paid and unpaid) have access to appropriate training/information; 
  • Receiving staff concerns about safeguarding and respond to all seriously, swiftly and appropriately; 
  • Keeping up to date with local arrangements for safeguarding and DBS;
  • Developing and maintaining effective links with relevant agencies; and
  • Taking forward concerns about responses 

5. Definitions

Abuse: Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. This can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture. Abuse can take a number of forms, including the following:

  • Physical abuse
  • Sexual abuse
  • Psychological or Emotional abuse
  • Neglect or Omission to act
  • Financial or material abuse
  • Child Sexual Exploitation
  • Modern Slavery 
  • Self Neglect
  • Domestic Abuse
  • Institutional Abuse
  • Discriminatory Abuse
  • Harassment
  • Radicalisation

Child: A child is under the age of 18 (as defined in the United Nations convention on the Rights of a Child).

Extremism refers to the vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty, and mutual respect for different faiths and beliefs

Radicalization refers to the process by which individuals come to support extremism and terrorism.

Prevent Duty refers to the responsibility to prevent individuals from being drawn into terrorism.

Vulnerable adult: A vulnerable adult is a person aged 18 years or over who may be unable to take care of themselves or protect themselves from harm or from being exploited.This may include a person who: is elderly and frail; has a mental illness including dementia; has a physical or sensory disability; has a learning disability; has a severe physical illness; is a substance misuser; is homeless.

6. Safeguarding

Safeguarding is about embedding practices throughout our organisation to ensure the protection of children and / or vulnerable adults wherever possible. In contrast, child and adult protection is about responding to circumstances that arise. For matters related to child protection, please refer to our Child Protection Policy. 

Safe recruitment

VI aims to recruit and retain individuals who are committed to the safeguard of children and vulnerable adults. To ensure a safe recruitment process, VI will ensure a robust screening and interview process for any position which may involve contact or working with children and vulnerable adults. This may include the following actions:

  • Providing the following safeguarding statement in recruitment adverts or application details – ‘recruitment is done in line with safe recruitment practices.’
  • Job or role descriptions for all roles involving contact with children and / or vulnerable adults will contain reference to safeguarding responsibilities.
  • There are person specifications for roles which contain a statement on core competency with regard to child/ vulnerable adult protection/ safeguarding
  • For staff assigned to, or individuals applying for, a role involving work with children or vulnerable adults, require the provision of (i) a criminal record check from the country where they permanently reside and (ii) verbal referee checks; 

8. Criminal Record Check (CRC) Gap Management

In order to avoid CRC gaps, the organisation will (insert methods) 

  • Maintain a list of roles across its organisation which involve contact with children or vulnerable adults; 
  • Commit resources to providing DBS records check on staff (paid or unpaid) whose roles involve contact with children and /or vulnerable adults. 
  • Recheck the CRC records in place for holders of identified roles every 3 years.

In addition to checks on recruitment for roles involving contact with children or vulnerable adults, VI will require existing staff (paid or unpaid) who transfer from a role which does not require a CRC check to one which involves contact with children / vulnerable adults to be subject to a CRC. 

Program contracting

For any VI program involving children or vulnerable adults:

  • There will be systematic checking of safeguarding arrangements of partner organisations
  • Safeguarding will be a fixed agenda item on any partnership reporting meetings
  • Contracts and memorandums of understanding for partnerships will include clear minimum requirements, arrangements for safeguarding and non compliance procedures.

10. Preventing Extremism

To actively prevent extremism, VI will: 

  • Raise awareness among all participants about the threats of violent extremism and the role of VI in minimizing these threats.
  • Empower participants to create resilient communities through positive contributions.
  • Promote British values through all aspects of the program.
  • Challenge segregation and promote social cohesion among participants.
  • Implement an anti-bullying approach that creates a safe environment for all.
  • Provide ongoing support and referral options for individuals at risk of radicalization.
  • Conduct periodic risk assessments to identify and address vulnerabilities.
  • Ensure a shared understanding of risks through ongoing training and information sharing.

11. Training 

For VI’s staff: 

        1. All VI’s staff with student facing roles will complete training focused on the Prevent Duty. This includes recognizing signs of radicalization, understanding extremist ideologies, and knowing how to respond appropriately to concerns.
        2. Additional staff members, as identified by the DSL, may also be required to undertake training. This may include those working with externally contracted service providers.
        3. Staff will receive periodic updates and refresher training to stay informed about evolving risks and strategies related to extremism. This ensures that all team members maintain a proactive stance in safeguarding the well-being of participants.
        4. Attendance and completion of training will be documented to ensure compliance with this policy. Staff who do not complete the required training will be subject to follow-up actions as part of our commitment to safeguarding. 

For Participants:

VI will make participants enrolled in its programs aware of this Policy, and other relevant VI policies, through the following means:

  1. Communicating all applicable VI policies to participants who are enrolled in our programs.
  2. Ensuring participants understand they may reach out to their Intern Experience Manager for all matters related to VI policies.
  3. Publishing VI policies on our website.

11.3. For Host Company

VI will ensure that Host Companies participating in its programs will comply with this Policy, and other relevant VI policies. Host Companies are further expected to put in place appropriate risk-based measures to ensure they comply with this policy. Non-compliance with requirements may lead to VI suspending or terminating an agreement with a host company.

12. Reporting 

    1. When alleged incidents are reported, VI will work with the individual to track incident management. VI expects two kinds of incident reporting:
      1. Mandatory and immediate (within 24 hours of becoming aware of an alleged incident) reporting by all staff and VI partners of any alleged incident of discrimination.
      2. Mandatory reporting (within two working days) by all staff and VI partners of any alleged non-compliance with this Policy.
    2. All VI staff, participants and partners must report any alleged or suspected safeguarding/prevent concerns or non compliance with this policy committed by anyone in connection with VI’s business and programs. Reporting must be made in accordance with the following procedure:

For Participants:

  1. VI can take corrective action only when it becomes aware of problems. Therefore, VI encourages any VI participant who has any preventative concern to come forward promptly with their inquiries, reports, or complaints and to seek assistance within VI. At any time during the Participant’s program, the Participant has safeguarding/prevent concerns, then the Participant should follow the following procedure.
  2. All safeguarding/prevent concerns will be dealt with seriously and promptly. Participants who have any safeguarding/preventative concern must not hesitate in using this procedure nor fear victimization.
  3. VI staff will provide, in confidence, advice and assistance to participants who communicate, safeguarding/prevent concerns and assist in the resolution of any problems. If Participant is in any doubt as to whether an incident or series of incidents which have occurred raise safeguarding/prevent concerns, then in the first instance Participant should approach Participant’s Intern Experience Manager on an informal confidential basis. They will be able to advise Participant as to whether the complaint necessitates further action, in which case the matter will be dealt with formally/informally as appropriate.
  4. Participants should report all safeguarding/prevent concerns to the Participant’s Intern Experience Manager, who will take appropriate action to resolve the issue. The means of resolving the issue will differ depending on the circumstances, but VI will consult the Participant during each step of the process to ensure the Participant is aware of the actions we are taking. These may include:
    1. Seeking medical or psychological attention for the vulnerable person if required;
    2. Discussing with the parents of the child or with the vulnerable adult;
    3. Obtaining permission to referrals if safe and appropriate;
    4. Contacting the help desk of local authorities and reporting the safeguarding incidents in accordance with procedures in place;
    5. Ensuring that feedback from local authorities is received, recorded and implemented.
  5. If Participant’s Intern Experience Manager is involved in any way with the instances or events which gave rise to the safeguarding/prevent concerns, and it would be inappropriate to report to them, Participant should report the issue to any other VI staff member with whom Participant have contact or to VI’s General Counsell ([email protected]).

For VI Staff:

  1.  If any VI staff member believes he/she may have witnessed a safeguarding/prevent incident in the context of a VI program, or receive a report from a program participant in accordance with this Policy, VI staff should resolve the issue appropriately, taking particular note of confidentiality concerns. VI staff should follow internal company policies and, within 24 hours of the occurrence of any such event, inform his/her line superior or the company’s in-house legal counsel ([email protected] )

For Host companies: 

  1. If the Host Company suspects or witnesses a safeguarding/prevent  incident related to a VI program, they should report the matter to their primary contact at VI. This contact will collaborate with the Host Company to address the issue appropriately.

13. Non-Compliance

      1. Non-compliance with this Policy is a serious matter and can result in disciplinary action, including but not limited to:
        1. For VI Staff Members: Failure to adhere to training requirements or reporting procedures may lead to disciplinary measures up to and including termination of employment.
        2. Participants: Any behavior that undermines the principles of this Policy may result in disciplinary action, which could include immediate termination of the participant’s program without a refund. Participants will receive written notice of any such action..
        3. Host Companies: Non-compliance with the Prevent Duty or failure to uphold safeguarding standards may result in termination of agreement and expulsion from the VI program.
      2. All incidents of non-compliance will be investigated promptly and fairly. Appropriate measures will be taken to address any breaches and safeguarding/prevent recurrence.
      3. All relevant details related to instances of non-compliance will be recorded and retained in accordance with the requirements of this Policy and the relevant laws.

14. Monitoring, Compliance and Review

VI will monitor compliance with this Policy through a range of approaches including performance assessments, reviews and due diligence. This policy will be reviewed once a year by VI’s DSL to ensure that it remains up to date and reflects VI’s needs and practices. The policy may also be reviewed if legislation changes or if monitoring information suggests that policy or practices should be altered.

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