1. Introduction

1.1 This policy relates to in particular Code Your Future’s commitments to safeguarding (as defined by the Charity Commission) and protecting its beneficiaries.

1 Where any suspected wrongdoing is in relation to staff, the procedure set out in Code Your Future’s Whistleblowing Policy or Complaints Policy should be followed, as appropriate. A link to these policies can be found under the section entitled ‘Other relevant policies’.

1.2 Over recent years there has been increasing recognition of the way in which vulnerable people can be at risk of harm from organisations and institutions that are supposed to help them, either as a result of abuse and exploitation by individuals in positions of trust, or via programme activities in general.

1.3 As a consequence, there has been a significant increase in the efforts made by agencies to ensure that no harm comes to beneficiaries or target communities from contact with their staff and associates or as a result of any of the organisation’s activities.

1.4 This duty of care extends beyond statutory safeguarding requirements. Code Your Future does not engage in any activity with children or vulnerable adults that is regulated by domestic safeguarding legislation but it does take seriously its obligations to operate in a way that ensures, so far as is possible, that its work does no harm to anyone with whom it engages.

1.5 In particular, Code Your Future is conscious that its activities mean that it may work directly with beneficiaries who are defined by the Charity Commission as adults at risk. The phrase adult at risk refers to a person aged 18 or over:

  • who has needs for care and support, for example, by reason of disability, age or illness, the context they are in, or as a result of social and other inequalities; and
  • who is experiencing or is at risk of abuse or neglect; and
  • who as a result of those needs or circumstances, is unable to protect themselves from either the risk of, or the experience of abuse or neglect.

1.6 Code Your Future has therefore developed this policy to promote protection for all those people it comes into contact with, as well as staff and volunteers within Code Your Future itself. Whenever it comes into contact with adults at risk or children, Code Your Future takes responsibility to ensure it is doing all it can to protect such groups from all forms of harm, including abuse, neglect and exploitation and to ensure appropriate action is taken if such harm occurs.

2. Understanding Risks

2.1 It is clear that vulnerable persons can be harmed, or put at risk of harm, by organisations and institutions, and that abuse of vulnerable groups (including children) can happen in all types of organisations. Such harm may result from unintentional acts or deliberate actions.

2.2 Unintentional acts may lead to harm due to a lack of ‘due diligence’ or competence or through organisational negligence, such as inadequate care and supervision, lack of policies, procedures and guidance to inform programming and practice, or lack of staff compliance with legal requirements. Also, deliberate actions may be taken by people with intent to abuse vulnerable people.

2.3 Code Your Future will maintain a risk register, which will be regularly reviewed, which identifies risks to the charity and how they will be managed and mitigated.

3. Scope of this policy

3.1 For Code Your Future’s staff and contractors

3.1.1 Compliance with this policy is mandatory for all Code Your Future staff. For the purposes of this policy ‘staff’ is defined as anyone who works for, or is engaged by Code Your Future,

either in a paid or unpaid, full time or part time capacity. This includes directly employed staff, contractors, agency staff, consultants, volunteers, interns and equivalents.

3.2 For trustees

3.2.1 Trustees must act at all times in the best interests of Code Your Future and its beneficiaries, and therefore they are also expected to comply with this policy. This expectation is made clear to trustees throughout the trustee recruitment process.

3.3 For partnership organisations

3.3.1 This policy also applies to other organisations with whom Code Your Future works. Code Your Future expects that the principles and approaches already shared with partnership organisations mean that they will fully support the values and commitments set out in this

policy. Code Your Future recognises that some will already have safeguarding policies and associated measures in place. Where this is the case they should have no difficulty in also complying with the standards set out in this policy.

3.3.2 Code Your Future will ensure that each partner has appointed a member of staff who will be responsible for promptly reporting to the Code Your Future Designated Safeguarding Officer (or, in the event that they are unavailable the Deputy Designated Safeguarding Officer or other appropriate person) any safeguarding concerns that arise in, or are relevant to the context of the partnership.

4. Statement of Commitments

4.1 Code Your Future commits to taking all reasonable measures to ensure adults at risk (or, if applicable. children) impacted by projects and programmes delivered and/or supported by Code Your Future are protected as far as possible from harm, including exploitation, neglect and abuse of all kinds.

5. Code Your Future commits to:

  1. Developing a zero tolerance ‘safety culture’ within Code Your Future that creates and maintains protective environments.
  2. Placing safeguarding at the heart of recruitment practices by carrying out the highest level of DBS or other criminal record checks to which we are entitled, requesting two written references, considering gaps in work history, checking qualifications and certifications and, where appropriate, confirming a person’s right to work in the UK.
  3. Ensuring Code Your Future’s staff and board members are fully cognisant of safeguarding best practice;
  4. Increasing understanding and raising the awareness of staff and trustees of risks relating to safeguarding within the organisation and in connection with its activities.
  5. Taking appropriate and proportionate action if the policy is not complied with.
  6. Developing criteria so that staff understand what constitutes non-compliance.
  7. Maintaining adequate insurance in relation to the charity’s activities and the people involved, to the extent that it is reasonably available.
  8. Carrying out appropriate due diligence on partners, which may include ensuring they have appropriate controls and safeguarding measures in place; meet any applicable international standards in carrying out their activities; and integrating safeguarding and onward reporting requirements in Code Your Future’s partnership or funding-related agreements, taking account of the Charity Commission’s relevant guidance.
  9. Making sure people protection considerations are integrated into all aspects of the organisation.
  10. Ensuring all staff and trustees are aware of their responsibilities to report concerns and of steps to take/who to go to in order to report such concerns.
  11. Ensuring that safeguarding concerns are addressed promptly and through the appropriate channels.
  12. Reporting safeguarding incidents, allegations or concerns to external authorities and regulators, as appropriate, and in accordance with best practice. Code Your Future will fully risk assess such reporting to ensure that making a report is not likely to cause further harm to the individual(s) to whom harm has (actually, allegedly or potentially) already been caused.
  13. Ensuring that its privacy notice remains suitably updated so that it is clear that, in keeping with Code Your Future’s zero tolerance policy, it will report wrongdoing on the part of its trustees, staff and partners to appropriate authorities; will share such information as may be necessary to protect individuals from harm; and will provide fair and accurate references, which appropriately reflect Code Your Future’s experience and interaction with trustees, staff and partners.

6. Embedding organisational commitment

6.1 In order to make its policy commitments a practical reality, Code Your Future will instigate or strengthen a range of measures that focus on making sure this policy and associated procedures are in place, that people are supported to understand and work within the provisions of the policy, that it is fully and effectively integrated into all of our activities, and that it is subject to monitoring and review.

6.2 Code Your Future staff and trustees will receive regular training/briefing on their responsibilities and obligations under this policy and it will form part of the induction for new staff and trustees.

6.3 Staff (and trustees) will be expected to acknowledge and accept their responsibilities under this policy. Breaches of this policy by staff will be treated seriously and will be treated as a potential cause for disciplinary action or termination of the relationship by other means.

Breaches by trustees may result in the termination of their trusteeship.

7. Reporting & responding to concerns

7.1 Recognising signs of abuse

7.1.1 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.

7.1.2 It can take a number of forms, including the following:

  1. Physical abuse
  2. Sexual abuse
  3. Emotional abuse
  4. Neglect
  5. Financial abuse 

7.1.3 Schedule 1 sets out further details of the different categories of abuse and how to recognise signs of abuse.

7.2 Reporting safeguarding concerns

7.3 Where any safeguarding concern arises, whether as a result of an occurrence during an activity or arising from a complaint or otherwise, the concern will be treated seriously and dealt with in accordance with this policy and procedures.

7.4 When dealing with a complaint, accusation or whistle-blowing, whether it is from a child, an adult at risk or a concerned adult, the approach is the same:

  1. Stay calm and listen carefully to what is said.
  2. Reassure the person that to tell is the right thing to do.
  3. Find an appropriate and early opportunity to explain that it is very likely that the information will be shared with others. Do not promise to keep secrets even if the person threatens “only to tell” if it is a secret.
  4. Allow the person to dictate the pace.
  5. Ask questions only to seek clarification and make sure they are not leading questions.
  6. Explain what will happen next, who will be told.
  7. As soon as possible record in writing what was said using the person’s own words whenever possible. Include any dates, times, names, name of person making record and make sure it is dated and signed.
  8. Also record the name of the person or persons with whom the information will be shared.
  9. Report to the Designated Safeguarding Officer as soon as possible.

7.5 It is not the responsibility of anyone in Code Your Future to decide whether or not an individual has been abused. It is however everyone's responsibility to report concerns and comply with this policy.

7.6 The person making the report should otherwise keep the matter strictly confidential and not seek to investigate the incident or suspicion.

7.7 The Safeguarding Lead Trustee, who sits on Code Your Future’s board of trustees, will have oversight of safeguarding and welfare arrangements and will receive reports of any safeguarding and welfare incidents that arise. The Safeguarding Lead Trustee will have a regular slot at meetings of the board of trustees to ensure that trustees are appropriately apprised of matters that arise.

7.8 The names of the Designated Safeguarding Officer and Safeguarding Lead Trustee can be found in the ‘Contact Information’ section at the end of this policy.

7.9 We are committed to reporting all relevant incidents to the Charity Commission for England and Wales via a serious incident report.3 We will also report incidents to other regulatory bodies and government departments or funding bodies, where appropriate. Where there is evidence that criminal activity may have taken place, or concerns have been raised in relation to a child or adult at risk, we will report to the relevant police and/or safeguarding authorities as appropriate (for example to the relevant Local Authority Designated Officer (LADO) or Adult Safeguarding Board), taking appropriate account of the Charity Commission’s guidance in this respect4.

7.10 Decisions to report to external authorities will be fully risk assessed and anonymisation/pseudonimisation considered when necessary. 

Reporting will not be avoided on the basis that it may harm Code Your Future’s reputation or give rise to litigation and any concerns in relation to data protection will not act as a barrier to reporting, although they will be carefully considered to ensure that the disclosure is made within the legal framework for so doing.

7.11 Code Your Future will develop strategies and tools to ensure effective implementation of this policy and to enable the Designated Safeguarding Officer, trustees and others to monitor its performance.

7.12 Existing systems for risk management, due diligence, monitoring and evaluation, audit and review, and other organisational performance mechanisms will be adapted to include indicators and processes by which implementation of the Safeguarding Policy can be measured and these processes will be periodically reviewed to ensure that they remain effective and up-to-date in respect of best practice.

7.13 Code Your Future will implement and keep updated a Whistleblowing and a Complaints Policy aimed at encouraging a culture of openness and accountability wherein staff and members of the public are, respectively, confident that they can raise any matter of genuine concern without fear of reprisal in the knowledge that they will be taken seriously and that matters will be investigated appropriately and managed on a need-to-know basis, with appropriate remedial action taken.

8. Policy Review

8.1 We are committed to reviewing our policy and good practice regularly. This policy will be reviewed by the board of trustees at least annually, when there is a change in UK law and/or best practice or when an incident occurs that highlights a need for change – whichever occurs first.

9. Other relevant policies

9.1 The following Code Your Future policies relate to contexts in which safeguarding and welfare incidents may arise:

  1. Whistleblowing Policy
  2. Complaints Policy
  3. Disciplinary policy/procedures
  4. Code of conduct
  5. Health and Safety Policy
  6. Data Protection Policy.

10. Contact information

10.1 Code Your Future’s Designated Safeguarding Officer is Alec McCrindle. The Deputy Designated Safeguarding Officer is Claire Bickley.

10.2 Code Your Future’s Safeguarding Lead Trustee is Ieva Kajokaite.

10.3 These individuals have access to the email inbox for reporting safeguarding concerns, which is

10.4 If you are not comfortable with submitting your report via email to that address, you can phone the Designated Safeguarding Officer on plus four four, zero seven nine one eight six nine three eight seven three.

11. Publishing this policy

11.1 Code Your Future will ensure that this policy is Code Your Future will ensure that this policy is at all times publicly accessible on its website.

It can often be difficult to recognise abuse. It is nevertheless important to know what could indicate that abuse is taking place and to be alert to the need to consult further. Someone can abuse an adult at risk by actively inflicting harm or by failing to act to prevent harm. Abuse can take place within a family, in an institutional or community setting, by telephone or on the Internet. Abuse can be carried out by someone known to the person or by a complete stranger. If you are worried about a child or adult at risk it is important that you keep a written record of any physical or behavioural signs and symptoms. In this way you can monitor whether or not a pattern emerges and provide evidence to any investigation if required.

Signs of abuse of a child

Physical Abuse Physical abuse is the deliberate infliction of pain, physical harm or injury and includes withholding or misuse of medication. Indicators include:
• Any injuries not consistent with the explanation given for them
• Injuries which occur to the body in places which are not normally exposed to falls, bumps, etc.
• Injuries which have not received medical attention
• Reluctance to change for, or participate in, games or swimming
• Finger marks or multiple bruising
• Bruises, bites, cuts, scratches, burns, fractures, etc. which do not have an accidental explanation
• Flinching or evidence of pain/discomfort during normal activity
Emotional abuse Emotional abuse is the emotional ill treatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to children that they are worthless, unloved or inadequate or causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. It may feature age or developmentally inappropriate expectations. Some level of emotional abuse is involved in all types of ill treatment of a child, though it may occur alone.
Indicators include:
• Changes or regression in mood or behaviour, particularly where a
child withdraws or becomes clingy
• Nervousness, frozen watchfulness
• Obsessions or phobias
• Sudden under-achievement or lack of concentration
• Inappropriate relationships with peers and/or adults
• Attention seeking behaviour
• Running away/stealing/lying
Sexual Abuse Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, whether or not they are aware what is happening. This may involve physical contact, including penetrative or non-penetrative acts or non-contact activities, such as involving children in looking at, or the production of, pornographic material or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.
Indicators include:
• Any allegations made by the child concerning sexual abuse
• Child with excessive preoccupation with sexual matters and detailed knowledge of adult sexual behaviour, or who regularly engages in age-inappropriate sexual play
• Sexual activity through words, play or drawing
• Child who is sexually provocative or seductive with adults
• Inappropriate bed sharing arrangements at home
• Unexplained bruising around or bleeding from the genital area
• Stained or bloody underclothing
• Unexplained difficulties in walking
Neglect Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. It may involve a parent or carer failing to provide adequate food, shelter or clothing, failure to protect a child from physical harm or danger, or failure to ensure access to appropriate medical care or treatment.
Indicators include:
• Persistent hunger
• Weight loss
• Poor hygiene
• Dress inappropriate to weather or activities
• Physical problems and medical needs that are not attended
Neglect and acts of omission Neglect may be deliberate or by default where the abuser is not able to provide the care and support needed or may not recognise the need for the care and support to be given. The abuser may also be neglecting themselves.
Indicators include:
• Persistent hunger and / or weight loss
• Poor hygiene
• Dress inappropriate to weather or activities
• Denial of religious or cultural needs
• Physical problems and medical needs that are not attended to
Organised abuse Organised or multiple abuse may be defined as abuse involving one or more abuser and a number of related or non-related abused children and young people. The abusers concerned may be acting in concert to abuse children, sometimes acting in isolation, or may be using an institutional framework or position of authority to recruit children for abuse.
Indicators include:
• Series of complaints from different parents about the same staff/situations/issues
• Records regularly being mislaid/poor record keeping
• Controlling relationships
• Children/activities being visited regularly by “associates” of staff

Signs of abuse of an adult

Physical Abuse Physical abuse is the deliberate infliction of pain, physical harm or injury and includes withholding or misuse of medication.
Indicators include:
• Injuries not consistent with falls or offered explanations
• Unexplained loss of hair in clumps
• Cuts that are not likely to be explained by self-injury
• Finger-marks
• Flinching or evidence of pain/ discomfort during normal activity
Psychological abuse Psychological abuse is any pattern of behaviour by another that results in harm and may include insults, humiliation, ridicule, bullying, threats, enforced isolation, interference in relationships and contact between consenting adults, coercion, lack of privacy or choice, denial of dignity.
Indicators include:
• Signs of strain within a relationship and/ or tension when a
particular person is present
• Indicators that an individual acts differently when a third person is
present than at other times
• Suggestions of refusal to allow a choice e.g. to eat or not eat more
or less of particular foods, to dress according to preference
• Signs of withdrawal or fear or other changes to emotional state
• Signs of unexplained sleep or weight loss
Sexual Abuse Sexual abuse is any sexual activity involving but carried out without the informed consent of an adult at risk. Sexual abuse may include sexual intercourse, inappropriate touching, offensive or suggestive language,‘voyeuristic’ behaviour and exposure to the suggestive or sexually explicit activities of others, including films, photographs, images etc.

Indicators include:
• Unexplained bruising around or bleeding from the genital area
• Stained or bloody underclothing
• Unexplained difficulties in walking
• Reluctance of the person to be alone with an individual known to
• Unusual and inappropriate sexualised language
Financial or material abuse Financial abuse is the misappropriation of funds (savings or income) or property of an adult at risk. This may include exploitation, theft or fraudulent use of money, misuse of property or possessions and incurring financial liabilities on behalf of an adult at risk without their informed consent.
Indicators include:
• Unexplained shortage of money despite a seemingly adequate
disposable income
• Unexplained withdrawals from savings accounts
• Unexplained disappearance of financial documents for example
bank statements, receipts for non-routine expenditure
• Loss of personal possessions
Neglect and acts of omission Neglect may be deliberate or by default where the abuser is not able to provide the care and support needed or may not recognise the need for the care and support to be given. The abuser may also be neglecting themselves.
Indicators include:
• Persistent hunger and / or weight loss
• Poor hygiene
• Dress inappropriate to weather or activities
• Denial of religious or cultural needs
• Physical problems and medical needs that are not attended to
Discriminatory abuse When the adult at risk is harassed or discriminated against because of their age, race, gender, sexuality, religion, disability, culture etc.
Indicators include:
• Signs of strain within a relationship and/ or tension when a
particular person is present
• Signs of withdrawal or fear or other changes to emotional state
• Unexplained outbursts
• Out of character discriminatory language, behaviour
Organisational abuse Where neglect and poor professional practice in an institutional setting such as a residential care home or medical facility, impacts on the care of adults at risk.
It can occur when poor communication, systems, practice and norms mean the care received is below that what should be expected.
Indicators include:
• Medication errors
• Poor record keeping
• Complaints from service users and their family
• Loss of personal possessions / clothing
• Controlling relationships between staff and service users
Self Neglect Where the adult at risk is neglecting to care for their own personal hygiene, health or surroundings
Indicators include:
• Hoarding
• Poor personal hygiene
• Unexplained weight loss
• Wearing the same clothes for a number of days
• Physical problems and medical needs that are not attended to
Modern Slavery Includes forced labour, debt bondage, sexual exploitation, criminal
exploitation and domestic servitude
Indicators include:
• Not being allowed to travel alone or make decisions
• Lack of personal possessions
• Reluctance to seek help
• Poor levels of nourishment, dress and energy
Domestic violence Includes controlling, coercive or threatening behaviour and / or violence between people who are or have been intimate partners or family members
Indicators include:
• “Honour” based violence
• Female genital mutilation (FGM)
• Forced marriage
• Signs of strain within a relationship and/ or tension when a particular person is present
• Signs of withdrawal or fear or other changes to emotional state

This is not an exhaustive list of abuse and its indicators. There could be other forms of abuse we have not discussed in this policy. We ask all our partner organisations to familiarise themselves with this policy and to train their staff who have contact with adults or children at risk in safeguarding, and on the signs of recognising abuse.

Whistleblowing Notice

Should Students, Customers, Suppliers or anyone else linked to Code your Future business wish to raise a concern relating to suspicions about any wrongdoing, unethical practice or criminal acts they believe to have taken place within Code your Future they can of course use the Complaints Policy or Safeguarding Policy in the first instance to raise these concerns. All concerns will be handled efficiently and confidentially.

If an individual feels this is not possible or not appropriate and the disclosure relates to the ‘public interest’ they may seek advice from Protect who are an independent whistleblowing charity. Their contact details are:

Protect Advice Line: 020 3117 2520

Protect Email Advice: