Safeguarding Policy
1. Introduction
1.1 The Trust is an educational charity which selects and financially supports international graduate students for 1-year master’s level courses at the University and runs a leadership training programme
1.2 The Trust does not currently carry out activities which are specifically aimed at children or vulnerable adults but there may be times when it encounters children or vulnerable adults while holding events which are open to the friends and family of our students and supporters and members of the public. Students attending residential courses at the Trust may not bring their own children with them whilst they are staying at residential premises
1.3 The Trust is committed to proactively safeguarding and promoting the welfare of its beneficiaries, staff, trustees, and volunteers, and to taking reasonable steps to ensure those who encounter the Trust do not, as a result, come to any harm.
1.4 Safeguarding is everyone’s responsibility. The Trust believes that everyone it encounters, regardless of age, gender identity, disability, sexual orientation, or ethnic origin has the right to be protected from all forms of harm, abuse, neglect, and exploitation. The Trust will not tolerate abuse and exploitation by its Staff, Trustees and Advisory Board, students or Partners.
1.5 The Trust has developed this policy to promote protection for all those people it encounters, as well as staff, Trustees, Advisory Board and any other volunteers within the Trust itself and the students and Partners with which it has relationships. This policy relates to the Trust’s commitments to safeguarding (as defined by the Charity Commission) and protecting children and vulnerable adults.1
2. What is safeguarding?
Safeguarding is about embedding practices throughout the organisation to ensure the protection of children and vulnerable adults wherever possible and dealing sensitively and appropriately with the situation should any incident arise which places a child or vulnerable adult at risk or in which a child or vulnerable adult has suffered abuse.
2.1 Vulnerable persons can be harmed, or put at risk of harm, by organisations and institutions, and abuse of vulnerable groups 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.
3. What is abuse?
3.1 Abuse 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.
3.2 Abuse can take a variety of forms, for example:
Physical abuse
Sexual abuse
Emotional abuse
Psychological abuse
Neglect
Radicalisation
Financial abuse
A non-exhaustive list of potential indicators of abuse is set out at Appendix 1 of this Policy.
4. Scope of this policy
4.1. For the Trust’s staff and contractors
4.1.1. Compliance with this policy is mandatory for all the Trust’s Staff. For the purposes of this policy ‘Staff’ is defined as anyone who works for, or is engaged by the Trust, either in a paid or unpaid, full time or part time capacity. This includes directly employed staff, Advisory Board members, contractors, agency staff, consultants, visitors, researchers, volunteers, interns, and equivalents.
4.2 For trustees
4.2.1 As trustees must always act in the best interests of the Trust and its ultimate beneficiaries, they are also expected to comply with this policy.
4.3 For Partners
4.3.1. “Partner” means any organisation which receives funding from the Trust, which collaborates with the Trust to deliver any of its programmes or activities, or which is otherwise associated with the Trust’s name and brand. This policy is intended to work alongside the equivalent policies of the Trust’s partners, where appropriate. The Trust expects that the principles and approaches already shared with Partners mean that they will fully support the values and commitments set out in this policy.
4.3.2. The Trust will ensure that each Partner has appointed a member of staff who will be responsible for promptly reporting to the Trust’s Safeguarding Officer (or, if they are unavailable the Deputy Safeguarding Officer or other appropriate person) any safeguarding concerns that arise in, or relevant the context of the partnership.
Consequences of breaches of this policy
4.4 Breaches of this policy by Staff will be treated seriously and will be treated as a potential cause for disciplinary action (in the case of employees of the Trust) or termination of the relationship by other means. Breaches by trustees may result in the termination of their trusteeship. Breaches by Partners may result in the termination of the relationship in accordance with the relevant partnership agreement.
5. Roles and Responsibilities
5.1 The trustees of the Trust have ultimate responsibility for ensuring that the Trust protects from harm all those who come into with it. The Trustees have oversight of the Trust’s safeguarding and linked policies and oversee the Trust’s handling of safeguarding reports. The Trustees also have responsibility for deciding whether any serious incident reports need to be made to the Charity Commission in relation to safeguarding incidents.
5.2 The trustees may appoint one of their number to act as Safeguarding Trustee. The role of the Safeguarding Trustee will be to act as the first point of contact on the board for the Safeguarding Officer, but the appointment of a Safeguarding Trustee will not detract from the fact that all the trustees share collective responsibility for safeguarding within the Trust.
5.3 The Trust’s Safeguarding Officer will:
5.3.1. respond to all child and vulnerable adult safeguarding concerns and enquiries, as set out in paragraph 10;
5.3.2. make any necessary reports to statutory agencies and will keep records of any action taken in response to safeguarding concerns;
5.3.3. ensure the Trust’s policy reflects changes to legislation and is kept up to date in relation to best practice when the policy is reviewed;
5.4. ensure that trustees, members of staff and volunteers have appropriate training in the application of the policy on an annual basis and will review the position annually; and
5.5. monitor the overall trend of any safeguarding concerns and report annually (or more frequently, as appropriate) to the trustees. While all the trustees have a collective responsibility for safeguarding, the Safeguarding Trustee will usually be the first point of contact on the board for the Safeguarding Officer.
5.6 All Staff working with children and vulnerable adults within or connected with the Trust’s activities/events should be familiar with this policy. In addition, they should conduct themselves in accordance with the Trust Code of Conduct (which is set out at Appendix 2). This provides guidance on acceptable and desirable conduct to protect both children and vulnerable adults who come onto Trust premises to study and to visit, and those working with them.
5.7 Every individual who becomes aware of any suspicions or allegations regarding harm to children or vulnerable adults is required to report this immediately to the Safeguarding Officer.
6. Definitions
6.1 A child is anyone under the age of 18.
6.2 A vulnerable adult is any person who is aged 18 years or over who, because of their needs for care and support is unable to protect themselves from either the risk of or the experience of abuse or neglect. Whether an individual is a vulnerable adult or not is something which can change with their circumstances and is not fixed. A vulnerable adult may have a mental illness, a learning disability, a physical disability, be frail or be otherwise in need of additional assistance to protect themselves from harm or exploitation, for example, due to social factors such as poverty, displacement or lack of services or support.
7 Examples of the Trust’s activities where it may encounter children and vulnerable adults
7.1 The current nature of the Trust’s work means that the Trust will not routinely be engaged in activities that are specifically aimed at children or vulnerable adults. However, the Trust recognises that children or vulnerable adults may attend the Trust’s premises or its events.
8 Statement of Commitments
8.1 The Trust commits to taking all reasonable measures to ensure vulnerable adults impacted by projects and programmes delivered and/or supported by the Trust are protected as far as possible from harm, including exploitation, neglect, and abuse of all kinds.
8.2 The Trust commits to:
(a) Developing a zero tolerance ‘safety culture’ within the Trust that creates and maintains protective environments.
(b) Placing safeguarding at the heart of recruitment practices by:
(i) assessing whether a role is eligible for a standard, enhanced or enhanced (with a check of the barred list) DBS check and, if so, carrying out the highest level of those checks for which the role is eligible2;
(ii) where a role is not eligible for a standard, enhanced or enhanced (with a check of the barred list) DBS check, carrying out a risk assessment to identify relevant risk factors, including, (1) whether the post-holder may have any contact with children or vulnerable adults and (2) the nature, length and frequency of the contact and whether the contact would be supervised or unsupervised, in order to determine whether it would be appropriate to require a basic DBS check for the role;
(iii) requesting at least one written reference;
(iv) considering gaps in work history; and
(v) checking qualifications and certifications, and, where appropriate confirming a person’s right to work in the UK,
(c) Ensuring the Trust’s Staff and trustees are fully cognisant of protection issues and adhere to the Trust’s Code of Conduct (as set out in Appendix 2).
(d) Increasing understanding and raising the awareness of Staff and trustees of risks relating to safeguarding within the organisation and in connection with its activities.
(e) Taking appropriate and proportionate action if the policy is not complied with.
(f) Maintaining adequate insurance in relation to the Trust’s activities and the people involved, to the extent that it is reasonably available.
(g) Carrying out appropriate due diligence on any 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 the Trust’s partnership agreements, taking account of the Charity Commission’s relevant guidance3.
(h) Making sure people protection considerations are integrated into all aspects of the organisation.
(i) Ensuring all Staff and trustees are aware of their responsibilities to report concerns and of steps to take/who to go to report such concerns.
(j) Ensuring that safeguarding concerns are addressed promptly and through the appropriate channels.
(k) Reporting safeguarding incidents, allegations or concerns to external authorities and regulators, as appropriate, and in accordance with best practice. The Trust 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.
(l) Ensuring that its privacy policy remains suitably updated so that it is clear that, in keeping with the Trust’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 the Trust’s experience and interaction with trustees, Staff and Partners.
9. Embedding organisational commitment
9.1 To make its policy commitments a practical reality, the Trust will instigate a range of measures that focus on making sure this policy and associated procedures are in place, that Staff are supported to understand and work within the provisions of the policy, that it is fully and effectively integrated into all our activities, and that it is subject to monitoring and review.
9.2 The Trust’s 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.
9.3 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.
10. Reporting and responding to concerns
10.1 Where any safeguarding concern arises, whether because 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.
10.2 When dealing with a complaint, accusation, or whistleblowing, whether it is from a child, vulnerable adult or a concerned adult, the approach is the same:
(a) Stay calm and listen carefully to what is said.
(b) Reassure the person that to tell is the right thing to do.
(c) 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.
(d) Allow the person to dictate the pace.
(e) Ask questions only to seek clarification and make sure they are not leading questions.
(f) Explain what will happen next, who will be told.
(g) 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.
(h) Also record the name of the person or persons with whom the information will be shared.
(i) Report to the Safeguarding Officer as soon as possible.
10.3 It is not the responsibility of anyone in the Trust to decide whether a child or vulnerable adult has been abused. It is however everyone's responsibility to report concerns and comply with this policy.
10.4 The concern must be reported to the Safeguarding Officer who will consider the circumstances and decide whether further investigation is needed or what other action to take. The Safeguarding Officer will ensure that all concerns are properly recorded, and records kept securely and confidentially. The Safeguarding Officer will liaise with statutory safeguarding bodies as required.
10.5 If there is a serious or immediate safeguarding concern which places a child or vulnerable person at risk anyone can make a referral to social services or to the police to prevent harm.
11. Next steps to be taken by the Safeguarding Officer
11.1 On notification of a safeguarding concern, the Safeguarding Officer shall consider the circumstances and decide whether further information gathering is required or what other action to take. The Safeguarding Officer will ensure that all concerns are properly recorded, and records kept securely and confidentially in accordance with the Trust's Data Protection Policy. The Safeguarding Officer shall liaise with statutory safeguarding bodies as required.
11.2 The Safeguarding Officer shall take steps to ensure that the individual who made the disclosure has access to appropriate ongoing support. They should also offer support to the Trust representative who heard the initial disclosure.
Reporting serious incidents to the Charity Commission and other external bodies
11.3 The Trust is committed to reporting all relevant incidents to the Charity Commission for England and Wales via a serious incident report.4 The Trust 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 vulnerable adult, the Trust will report to the relevant police and/or safeguarding authorities as appropriate (for example to the relevant Local Authority Adult Safeguarding Board), taking appropriate account of the Charity Commission’s guidance in this respect.5
11.4 Decisions to report to external authorities will be fully risk assessed and anonymisation/pseudonymisation considered when necessary. Reporting will not be avoided on the basis that it may harm the Trust’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.
12. Data protection
12.1 The Trust complies with the principles of GDPR and the Data Protection Act 2018 in the way it collects, holds, and disposes of personal information. Please see the Data Protection Policy for more details.
13 Linked policies
13.1 The Trust will implement and keep updated a Whistleblowing 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.
13.2 This Safeguarding Policy should be read alongside the following linked policies, once these have been adopted:
(a) Bullying & Harassment Policy
(b) Whistleblowing Policy
(c) Grievance Policy
(d) Employee Disciplinary Policy
(e) Code of Conduct
(f) Data Protection Policy
(g) Equal Opportunities Policy
14. Contacts
The Safeguarding Officer is:
Name: Hilary Boulding
Direct:
Mobile: 01865 411514
Email: hilary.boulding@whtrust.org
If the Safeguarding Officer is unavailable for any reason, or the concern relates to the Safeguarding Officer, it must be reported to the Deputy Safeguarding Officer.
The Deputy Safeguarding Officer is:
Name: Jane Baldwin
Direct:
Mobile: 01865 411514
Email: info@whtrust.org
15. Publishing this policy
15.1 The Trust will ensure that this policy is always publicly accessible on its website.
16 Review
16.1 The Trust is committed to reviewing this policy and good practice regularly. This policy will be reviewed by the trustees at least annually or when an incident occurs that highlights a need for change – whichever occurs first.
Date of policy: reviewed February 2026
This policy will be next reviewed no later than: February 2027