PURPOSE

The purpose of this policy is to protect people — particularly children, vulnerable adults and service users — from any harm that may be caused due to their coming into contact with BDE. This includes potential harm arising from: 

• The conduct of staff or personnel associated with BDE,

• The design and implementation of BDE’s programmes and activities.

 

The policy lays out the commitments made by BDE, and informs staff and associated personnel of their responsibilities in relation to safeguarding. 

This policy does not cover: 

• Safeguarding concerns in the wider community not perpetrated by BDE or associated personnel.

 

WHAT IS SAFEGUARDING?

In Malta, safeguarding means protecting peoples' health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect. In our sector, we understand it to mean protecting people — children, vulnerable adults and service users — from potential harm that arises from coming into contact with our staff or programmes.

 

SCOPE 

• All staff contracted by BDE.

• Associated personnel whilst engaged with work or visits related to BDE, including but not limited to the following: consultants, volunteers, interns, partner NGOs, researchers, contractors, programme visitors including journalists, celebrities and politicians.

 

POLICY STATEMENT

BDE believes that everyone we come into contact with, 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.  BDE will not tolerate abuse and exploitation by staff or associated personnel.

This policy will address the following areas of safeguarding: child safeguarding, adult safeguarding, and protection from emotional, sexual and cultural exploitation and abuse. These key areas of safeguarding may have different policies and procedures associated with them (see Code of Conduct).

BDE commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.

 

PREVENTION

BDE responsibilities:

BDE will:

• Ensure all staff have access to, are familiar with, and know their responsibilities within this policy.

• Design and undertake all its programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with BDE. This includes the way in which information about individuals in our programmes is gathered and communicated.

• Implement safeguarding procedures when recruiting, managing and deploying staff and associated personnel.

• Ensure staff receive training on safeguarding at a level commensurate with their role in the organisation.

• Follow up on reports of safeguarding concerns promptly and according to due process.

 

Staff and associated personnel responsibilities:

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Child safeguarding

BDE staff and associated personnel must not:

• Engage in sexual activity with anyone under the age of 18. 

• Sexually abuse or exploit children.

• Subject a child to physical, emotional or psychological abuse, or neglect.

• Engage in any commercially exploitative activities with children including child labour or trafficking.

 

Adult safeguarding

BDE staff and associated personnel must not:

• Sexually abuse or exploit at risk adults.

• Subject a vulnerable adult to physical, emotional, cultural or psychological abuse, or neglect.

• Engage in any commercially exploitative activities with vulnerable adults including slave labour or trafficking.

 

Protection from sexual exploitation and abuse

BDE staff and associated personnel must not:

• Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to service users.

• Engage in any sexual relationships with service users, since they are based on inherently unequal power dynamics.

 

Additionally, BDE staff and associated personnel are obliged to:

• Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy.

• Report any concerns or suspicions regarding safeguarding violations by an BDE staff member or associated personnel to the appropriate staff member. 

 

REPORTING

BDE will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities they work with. 

BDE will also accept complaints from external sources such as members of the public, partners and official bodies.  

How to report a safeguarding concern

A complaint or concern relating to safeguarding should be reported immediately in written form to the Operations Officer, the Deputy Operations Manager, or any member of the BDE Board by sending an email to info@bluedooredu.org or a WhatsApp to 00356 7904 2040. If the person reporting does not feel comfortable with these channels of reporting (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may submit an anonymous report in written form (e.g. typed and printed, dated but not signed, in an envelope addressed to BDE and deposited in the postbox outside).

 

RESPONSE

BDE will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations.

BDE will apply appropriate disciplinary measures to persons found in breach of policy.

BDE will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation).  Decisions regarding support will be led by the survivor.

 

CONFIDENTIALITY

Confidentiality will be maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management will be shared on a need to know basis only, and will be kept secure at all times. 

 

GLOSSARY OF TERMS

• Service users: Someone who directly receives goods or services from BDE’s programme.  Note that misuse of power can also apply to the wider community that the NGO serves, and also can include exploitation by giving the perception of being in a position of power.

• Child: A person below the age of 18.

• Harm: Psychological, physical and any other infringement of an individual’s rights.

• Psychological harm: Emotional, psychological and cultural abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation.

• Protection from Sexual Exploitation and Abuse (PSEA): The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel.  The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)

• Safeguarding: In the UK, safeguarding means protecting peoples' health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect. In our sector, we understand it to mean protecting people, including children and vulnerable adults, from harm that arises from coming into contact with our staff or programmes.  One donor definition is as follows: Safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur. This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes. Safeguarding applies consistently and without exception across our programmes, partners and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty. Safeguarding puts beneficiaries and affected persons at the centre of all we do. 

• Sexual abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. 

• Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. This definition includes human trafficking and modern slavery.

• Survivor: The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.

• Vulnerable adult: Sometimes also referred to as at-risk adult. A person who is or may be in need of care 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.