Safeguarding Policy

Scope of this Policy

Safeguarding is term with a broad definition. We adopt the following definition: our objective is to protect the rights of all people who FBDS interacts with to live in safety, free from abuse and neglect. This applies equally to all people, regardless of gender, sexuality, religion, disability, ethnic origin or age.

FBDS has a suite of policies and internal documents that exist to ensure that we safeguard those who we come in to contact with, including FBDS Ethical Policy, Health and Safety, Anti-Fraud and Corruption Policy, the FBDS Terms of Employment, Code of Conduct, Grievance Procedure and Whistle-blowing Procedure.

This policy is therefore focused primarily on our approach to keeping people safe from bullying, harassment, sexual exploitation and abuse. It should be read alongside the broader suite of policies listed above.

Commitments

At FBDS we will not tolerate any representative of FBDS, whether our employee, consultant, contractor or partner carrying out any form of bullying, harassment, sexual exploitation and abuse.

In particular, we commit to:

• Create a safe and trusted working environment which safeguards anyone FBDS has contact with, including beneficiaries and staff
• Ensure our culture is one where all those who we work with, and all those who work for us feel empowered to insist on non-discriminatory and respectful behaviour from each other
• Ensure that there are safe and trusted channels through which people can raise any issues of concern
• Ensure all concerns and allegations are responded to in a timely and appropriate manner
• Ensure all staff and managers are familiar with organisational policies relating to safeguarding, and understand their responsibilities via the induction and training
• Take robust action if problems arise in the observation of this policy and relevant employment and criminal laws
• Ensure our consultant, contractor and partner are aware of safeguarding standards that FBDS expect on them
• Be transparent with our partners about any issues we face

Policy Guidance

All FBDS staff and representatives should:

• Act in accordance with the requirements of the FBDS Code of Conduct and take responsibility for their own actions.
• Treat all those they come in to contact with on behalf of FBDS with dignity and respect, and to refrain from any behaviour that falls within the definitions of bullying, harassment, sexual exploitation and abuse, both in and out of the workplace, such as on business trips, events or work related social functions.
• Consider whether their words or conduct could be offensive. Even unintentional harassment or bullying is unacceptable.
• Not have any sexual contact with children under the age of 18 (or older if local law specifies), or engage in sexual relationships with staff, partners or any beneficiaries of FBDS projects or programmes of FBDS through an abuse of a position of power (including line management relationships, and funding relationships).
• Report in line with this policy any instances or suspicions of inappropriate behaviour they experience or witness by FBDS employees, contractors, clients or partners, unless disclosed to them confidentially by a victim who does not wish them to disclose.
• Disclose any instances or suspicions of inappropriate behaviour that involve a child (under 18 years unless older in any applicable jurisdiction) or a vulnerable adult.

Managers should be made aware of any consensual relationships they may develop with other FBDS colleagues over whom staff hold a position of power (e.g. direct reports or within chain of line management) and ensure that no abuse of power or conflict of interest is allowed to occur.

Safe Programming

Where projects or programmes will work directly with communities or individuals we will ensure FBDS staff and representatives observe the requirements of Code of Conduct to minimize the risk of unintended harm, and we will ensure that mechanisms exist and are publicized to enable those we work with to raise and concerns and provide any feedback they wish to. If a specific project or programme is undertaken that will involve direct work with vulnerable adults or children specific measures for that project or programme will be designed to ensure that risk is appropriately managed.

Procedure to raise and handle complaints and concerns

• Anyone can raise a concern or make a complaint to FBDS about something they have experienced or witnessed. It is possible to make a complaint verbally or in writing.
• People external to FBDS can raise an issue by writing into any management level FBDS personnel.
• Internally, issues can be raised through the usual line management chain, directly at a mmore senior level if appropriate. The current process is set out in Grievance Procedure.
• FBDS is committed to responding to all concerns raised, and to ensuring that those raising complaints have confidence in and control over how complaints are investigated and handled. The only exception to this is where a concern is raised about a vulnerable adult or child’s treatment, where an investigation will always be undertaken, and confidentiality of those raising a concern cannot be guaranteed.
• FBDS is committed to ensuring that no employee who raises a genuine issue under this policy will be subject to victimization or be disadvantaged in any way.
• All the complaints will be dealt with sensitively and with due respect for the privacy of any individuals involved. Any employee who is found to have contravened FBDS’s expectations about their conduct will be subject to disciplinary action that may result in dismissal. Contractors may have their relationship with FBDS terminated. Partners will be expected to take appropriate action against their own staff, and any ongoing relationship with the partner cannot involve any individuals found to have breached expectations.
• Any instances of criminal misconduct (dependent on the laws of that specific jurisdiction) will be reported to the relevant authorities, subject to the consent of the victim. The only exception to this is where an incident involves a vulnerable adult or a child, where incidents or suspicions must always be reported to relevant authorities.
• FBDS is committed to meeting its legal, statutory and contractual obligations of reporting safeguarding issues. When safeguarding issues occur relevant donors and regulators will be informed of the outcome of investigations in line with their requirements.

Responsibilities

Board of Directors has ultimate responsibility for safeguarding and should always act in the best interests of the beneficiaries and staff, including:

• developing and reviewing safeguarding policies and procedures; reviewing management of safeguarding issues and risks through a standing agenda item in regular meetings and the risk register update.
• carrying out thorough and prompt investigation if allegation occurs; taking disciplinary action against staff where there are breaches of code of conduct.
• reporting safeguarding issues to the relevant donors and regulators in line with the requirements.

Executive Director is responsible for ensuring the application of this procedure is implemented fairly and consistently. He will also focus on recruitment of the qualified people and provide induction and refresher training to staff and management on safeguarding.

Management teams are responsible for ensuring the policy and procedures are operating effectively within their areas of responsibility.

Every member of staff and representative is responsible for implementing the policy and procedures.