Safeguarding policy - Investment20/20

Investment20/20 Safeguarding Policy

Investment20/20 has a commitment and responsibility to promote the welfare of all children and young people and keep them safe.

This policy applies to anyone working at/on behalf of the Investment Association and Investment20/20, including employees from member firms who are involved in Investment20/20 or related activities.

This policy:

Provides links to relevant sources of information to ensure that all adults who work with Investment20/20 have a good understanding of safeguarding and child protection.
Outlines good practice guidelines.
Ensures the commitment to safe recruitment for the Investment20/20 team.
Ensures that all adults who work with or alongside Investment20/20 are aware of the structured response procedure for safeguarding concerns.
Expresses the commitment of Investment20/20 to safeguarding and child protection.

This policy complies with the principles in Working Together to Safeguarding Children (2018). This states:

everyone who works with children has a responsibility for keeping them safe
everyone who comes into contact with children and families has a role to play in sharing information and identifying concerns.

More info at https://learning.nspcc.org.uk/child-protection-system/england

1. About Investment20/20

Investment20/20 helps people find out about careers in investment management. We work with schools, colleges, universities and community groups to enable people to find out about careers in investment management and to help them navigate their way to entry level roles.
We work with people in four ways:

a. Delivery of careers workshops in schools, colleges, universities, community venues, employer venues, and other spaces.

b. Through our longer-term programmes where we engage with people on an ongoing basis, in both individual and group work settings. All these people are aged 16 and above and are run via schools, colleges and universities.

c. Delivery of virtual activities such as online sessions and webinars, delivered in partnership with employers and industry volunteers. These are all organised through schools, colleges, universities, charities and other partners.

d. Through our Investment20/20 Trainee Programme, where people over the age of 16 are employed by an Investment20/20 employer partner for a one-year contract.

Any of the people with whom we work may be enrolled at a school, a sixth form, FE College, Sixth Form College, university or other education provider/community provider.

2. Types of abuse

It is important for any adult involved in working with Investment20/20 to have a good understanding of types of abuse. All adults involved in Investment20/20 have a role in identifying signs of abuse. In this policy “child” and “young person” are used interchangeably to mean any person under the age of 18.

The types of child abuse that may occur are extensive. It is the responsibility of each Investment20/20 member of staff to ensure they have completed the NSPCC Introduction to Safeguarding course every three years.

It is signposted to any member of staff from a partner firm that may speak at a group session should also read the NSPCC website: https://www.nspcc.org.uk/what-is-child-abuse/types-of-abuse/.

In addition to types of abuse, we recognise that mental health is particularly important to the ages of the young people that Investment20/20 work with. More can be found here:
https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/mental-health-suicidal-thoughts-children/.

3. Good practice guidelines

All adults working with Investment20/20, in whatever capacity including volunteers (employees who deliver a talk), should demonstrate exemplary behaviour. The following are common sense examples of how to create a positive culture and environment. These examples and guidelines apply to face to face and virtual delivery.

DO:

Always prioritise the welfare of each young person.
Always work in an open environment, avoiding private situations.
Always make sure that you are never by yourself on a virtual session. Always ensure there is a member of education provider staff is present.
Treat all people with respect and dignity
Maintain an appropriate emotional and physical distance from participants.
Ensure the participants are in a space with other people around – never be in a room alone with a participant, and keep doors open and blinds up.
Be an excellent role model e.g. not smoking/drinking in the company of a participant.
Give enthusiastic and constructive feedback rather than negative criticism.
Follow the hosting organisation’s procedure for administering first aid and report in line with the hosting organisation’s/venue’s policy and procedure, and inform Investment20/20.
Check your social media accounts to ensure that no participants from the event have ‘followed’ you. If they have, delete/remove them and check your social media settings and report to Investment20/20 and your HR representative.
Report any incidents (see below).

DO NOT under no circumstances (this applies to face to face and virtual delivery)

Engage in rough physical or sexually provocative games.
Allow or engage in any form of touching (e.g. consoling arm if the student is upset).
Allow participants on Investment20/20 events to use inappropriate language unchallenged.
Say or do anything that might be interpreted as aggressive or hostile.
Do things of a personal nature for participants at an Investment20/20 event that they can do for themselves.
Take a participant in a car or accompany on a journey, e.g., after a careers event.
Make sexually suggestive, discriminatory, offensive or violent comments to participants.
Never meet participants outside of the specific event.
Allow allegations made by participants during Investment20/20 events to go unchallenged, unrecorded or not acted upon.
Attempt to engage with a young person personally outside of the event.
Fail to report to Investment20/20 anything inappropriate that a participant does or says.
Communicate with any participant as a result of an Investment20/20 event (unless it is through the organisation official HR channel)
Connect with participants on any social media platform or accept connection request on social media platforms, including LinkedIn. If you have received a connection request from someone who you believe to be a participant from the event, please delete/decline the request and inform Investment20/20 and your HR representative.

4. Incidents that must be reported to the Designated Safeguarding Officer ([email protected])

If you witness or are a party to any of the following, you should report this immediately to the Investment20/20 Safeguarding Lead and record the incident, and the Safeguarding Lead in the school/college/university/charity. You must report any incidents including the below:

You hurt, or you witness someone else hurting a person, during the event, even if unintentionally.
You witness any inappropriate behaviour from anyone during the event.
You witness/notice/informed that a participant during the event:

seems distressed
mentions they are in danger
mentions they want to harm themselves/others
appears to be physically attracted to you or to another adult
misunderstands or misinterprets something you have done
has not attended or has a lack of engagement which causes concern
makes suggestive or inappropriate comments, either in person, online or using
any other form of communication.

If you are made aware after the event that any of the above is of concern/took place, this must be reported.
If a participant attempts to connect on social media plan, this must be reported.

Where a young person is on an Investment20/20 work shadowing or work placement activity, the employer is expected to notify Investment20/20 and the school/college immediately upon becoming aware of any safeguarding/child protection issues.

5. Face to face events not on the premises of schools, colleges, universities, or other organisations (e.g., workplace visits)

Investment20/20 will only run events when organised in conjunction with the education provider/other organisation. A representative from the education provider/other organisation must accompany participants at all times.

The education provider/other organisation is responsible for informing Investment20/20 what they require to be in place regarding health and safety, dietary requirements and access requirements for young people.

The participants remain in the duty of care of the education provider/other organisation for the entire event. The education provider/other representative must take full responsibility for their participants for the entire duration of the activity and follow their own organisation’s safeguarding policy, in addition to Investment20/20’s safeguarding policy. The education provider/other organisation must take full responsibility for welfare and safeguarding of students at all times. Investment20/20 accepts no responsibility for personal belongings brought by students to events.

Activities that take place outside of the premises of an education provider/other organisation fall under the safeguarding policy of the education provider/other organisation.

6. Investment20/20 attending face to face events on the premises of an education provider/other organisation

Visits to education providers/other organisations are part of the Investment20/20 outreach strategy. These activities often occur in two forms, but are not restricted to just these two:

a. A careers fair/exhibition
This tends to be a large event with many other organisations. Students visit the exhibition stand for information on Investment20/20.

b. Delivering a workshop
This will be in a classroom style setting. The role of Investment20/20 is to deliver a talk about careers in investment management.

Both these types of activities are managed and supervised by the hosting organisation (education provider/other organisation). The hosting organisation is responsible for student welfare and safeguarding as the activities take place on their premises, but the Investment20/20 safeguarding policy also applies to all Investment20/20 staff and employees supporting from Investment20/20 member firms. The hosting organisation must always ensure there is a member of their staff in the room with the Investment20/20 representative.

These sessions fall under the safeguarding policy of the education provider/other organisation. This is made clear to the education provider/other organisation at the point of booking the session. The education provider/other organisation has to completing/or agree to the terms outlined in the Investment20/20 Outreach Activity Provider Agreement.

7. Investment20/20 events: Virtual delivery

Our virtual events are only delivered in conjunction with an education provider/other organisation.

These are always group-based sessions. Investment20/20 and any employer speakers from Investment20/20 member firms join via an online platform and are to never join the session without a representative of the education provider/other organisation being present online.

The education provider/other organisation is responsible for session logistics and student welfare, Investment20/20 and speakers from Investment20/20 member firms have a speaking only role, and it is a group one off intervention. These sessions will not be recorded.

Education providers/other organisation responsibilities:

To send the virtual link to be used.
No student is on webcam.
The education provider/other organisation is responsible for managing the session, safeguarding and welfare of participants.

8. Investment20/20 Alumni and Trainee LinkedIn Group

The Investment20/20 Alumni and Trainee LinkedIn Group is a closed group and by invite only. Individuals need to be accepted into this group by the Investment20/20 team, and it is only for current trainees or alumni. This is not a public group.

All members of this LinkedIn group have a responsibility to contact Investment20/20 should they have concerns for an individual’s safety or welfare based on a comment posted on the LinkedIn group.

If a concern is identified and reported, we will act in accordance with the guidance outlined in this Safeguarding Policy. In addition, we will:

Save the comment but remove from public view.
Contact the HR department of the person who commented to raise our concerns.
Record our concerns in our safeguarding records as outlined in this Safeguarding Policy.

9. Communication

9.1.

Telephone

Any adult representing Investment20/20 must ensure that all communication is transparent and open to scrutiny. Investment20/20 staff must NOT make any phone call from any device to a participant..

9.2

Social media

Any adult representing Investment20/20 individuals (including staff, speakers from Investment20/20 member firms etc.) must not communicate with any participant following an event (unless it is through official HR communication systems) or connect with them on any social media platform, including LinkedIn – see below.

9.2.a LinkedIn – Investment20/20 staff

Investment20/20 staff must not seek nor accept a connection request on any social media platform, including LinkedIn from any participant resulting from an event. Investment20/20 staff contact details on LinkedIn must be hidden. If a connection request is received, it must be reported to the Investment20/20 Designated Safeguarding Officer immediately. The connection request must be ignored/deleted/declined.

9.2.b LinkedIn – speakers from Investment20/20 firms

Speakers from Investment20/20 member firms must not seek contact with a participant connected with an Investment20/20 event nor accept a request to connect on any social media platform, including LinkedIn. If a connection request is received, it must be reported to the Investment20/20 Designated Safeguarding Officer immediately, and to the HR contact at the member firm. The connection request must be ignored/deleted/declined.

9.3

Email communication

9.3.a Investment20/20 staff: There must not be any email communication that takes place on personal email accounts with any participant from any Investment20/20 event. A work email account must always be used. Teams and other messaging platforms must not be used. Participants must only be given the [email protected].

9.3.b Emails – Speakers from Investment20/20 member firms: If an email is received from a participant connected to an Investment20/20 event, the speaker must not respond. Instead, the speaker must forward the email to their HR department and ask them to respond on behalf of your organisation. They should also inform Investment20/20 Designated Safeguarding Officer.

10. Speakers from Investment20/20 member firms that support activities

Speakers from Investment20/20 member firms will not take part in a virtual or face to face session without the supervision of an Investment20/20 member of staff and teacher/other professional from the organisation arranging the session. Speakers from Investment20/20 member firms are not subject to DBS checks as they are always supervised, and they do not have any ongoing contact with young people.

Speakers from Invesmentment20/20 member firms must not actively seek contact with participants after an Investment20/20 session. They must follow all the guidelines in this document including communication guidance on using LinkedIn (see point 9 in full).

Speakers from Invesmentment20/20 member firms must confirm they will adhere to the Speaker Conduct Agreement each time they take part in an Investment20/20 activity. The Speaker Conduct Agreement is shared with the speakers from Investment20/20 member firms in advance of the event. They are asked to sign and return.

11. Photography and film

Investment20/20 will take photos and films of speakers from Investment20/20 member firms at events. We will not take pictures of participants at the events.

Teachers/other representatives from education providers who are attending events with participants are asked to take a group picture and share over email with Investment20/20 if that complies with their own safeguarding policy and conduct.

The teacher/other representative from the education provider must complete the Photo Permission section of the Education Provider Agreement in advance of the event should they plan on sharing photos with Investment20/20.

Photos will be used in line with the ways that are outlined in the Photo Permission section of the Education Provider Agreement. Photos will not identify individual people by name, unless permission given in advance.

12. Investment20/20 Recruitment

All Investment20/20 paid staff are to:

Have a Disclosure and Barring Service (DBS) check to Enhanced level (Guard List checked) in England where they have a frequent role with young people, and Enhanced level (not Guard List checked) for infrequent advice roles.
Have a Basic Disclosure check in England where the role does not include infrequent advice to young people.
Have a Basic Disclosure Scotland check in Scotland
Register with the DBS Update Service in England, or undergo a new DBS Enhanced check every 3 years in England
Undergo a new Basic DBS Check every 3 years in Scotland

All members of Investment20/20 staff will be informed about the Safeguarding Policy and the procedures that are to be followed should any issues arise. They are required to confirm that they have read the Safeguarding Policy, and that they confirm that they will ensure compliance. All adults working with Investment20/20 are expected to follow the good practice guidelines as set out in this policy. In addition, all Investment20/20 staff must complete the NSPCC Introduction to Safeguarding online course. This training must be refreshed every three years. This is logged on a central record.

When a new member of Investment20/20 joins, they are required to complete relevant DBS checks as part of the recruitment process, read and confirm they will ensure compliance with the Safeguarding Policy, and complete the NSPCC Introduction to Safeguarding online course.

13. Reporting a concern or allegation

Concerns can be reported:

Directly from a participant
From someone else about a participant
Something you see or hear about a participant
Something you are told, see or hear about an adult

Allegation would usually apply to concerns about an adult.

If you think a child is in immediate danger, don’t delay – call the police on 999, or call the NSPCC on 0808 800 5000, straight away.

When concerns are reported, all adults working with Investment20/20 should follow the response guidelines set out below.

When a complaint is made about an individual involved in a participant’s work shadowing/ work experience placement, Investment20/20 staff will speak with their key contact from the individual’s organisation to review the evidence. The shadowing/placement must stop until the outcome is determined.

a. What to do if you are informed about a concern.

– For the person receiving the disclosure

Listen carefully.
show you care, help them open up: Give your full attention to the person and keep your body language open and encouraging. Be compassionate, be understanding and reassure them their feelings are important. Phrases such as ‘you’ve shown such courage today’ help.
take your time, slow down: Respect pauses and don’t interrupt the person – let them go at their own pace. Recognise and respond to their body language. And remember that it may take several conversations for them to share what’s happened to them.
show you understand, reflect back: Make it clear you’re interested in what they are telling you. Reflect back what they’ve said to check your understanding – and use their language to show it’s their experience.
Do not ask leading questions
Record the concern in writing, using the exact words the subject has used
Record details such as names, dates, times, and location
Be clear to the person that you cannot guarantee confidentiality
Explain that information will only be shared with people that will help to ensure their safety and well-being
Inform the Investment20/20 Safeguarding Lead immediately

– The Safeguarding Lead at Investment20/20

Should review the information and ALWAYS pass to the education provider/other organisation Designated Safeguarding Officer. It is the responsibility of the education provider/other organisation’s Designated Safeguarding Officer to take the necessary action to ensure the situation is addressed appropriately and escalated to the MASH / Local Area Designated Officer if they feel appropriate.
If the person is not part of a education provider/other organisation, the Local Area Designated Officer must be notified and or MASH by Investment20/20.

– The education provider/other organisation Safeguarding Lead:

Should take the necessary action to ensure the situation is addressed appropriately and escalated to the MASH / Local Area Designated Officer if they feel appropriate
Investment20/20’s role is to follow through on actions allocated. Assistance will be provided to external investigators.

b. Process for reporting

It is the responsibility of the education provider/other organisation’s Area Safeguarding Officer to liaise with the parents/carers/others of the person involved, should it be appropriate. If there has been any physical injury to the person during an event/shadowing day/work placement the parents/carers should be informed immediately.

i. Report disclosure to the Investment20/20 Safeguarding Lead via phone and email: [email protected] / 07851 950207
ii. The disclosure should be reported as soon as possible.
iii. The following information should be reported:
a. the person’s details (name, age, address – if have these)
b. what the person said or did that gave you cause for concern (if the person made a verbal disclosure, write down their exact words)
c. any information the person has given you about the alleged abuser
iv. The Investment20/20 Safeguarding Lead records the disclosure on the Safeguarding Spreadsheet. All correspondence, including notes from phone calls and conversations, are saved in the secure Safeguarding folder on the Investment20/20 shared drive.
v. The Investment20/20 Safeguarding Lead reports the disclosure to:
a. The person’s education provider/other organisation and if necessary, the Safeguarding Lead at the Local Authority in which the person attends an education provider/other organisation.
b. Depending upon the person making the disclosure, it may be necessary to inform one or more of the following people
i. Education Provider’s Safeguarding Officer
ii. Employee’s manager or HR manager
iii. Volunteer’s manager or HR manager
vi. The Safeguarding Lead notes last key action point taken and who is responsible for continuing investigation.

c. Record Keeping

Investment20/20 will keep a clear and comprehensive summary of any allegations made, details of how it was followed up, and details of any action taken and decisions reached. This will be recorded on the Safeguarding spreadsheet, and all correspondence saved in the secured Safeguarding folder on the Investment20/20 shared drive.

We will share safeguarding information with other agencies and will seek consent to do so unless this would jeopardise the safety of the person, in which case information can be shared without consent. In sharing information about the person, the safety and welfare of the person is paramount. Information will be shared following information sharing principles – see https://learning.nspcc.org.uk/child-abuse-and-neglect/recognising-and-responding-to-abuse#information-sharing

d. Outcome of investigation
Investment20/20 would follow the guidance outlined here: https://learning.nspcc.org.uk/safeguarding-child-protection/managing-allegations-of-abuse.

If the allegation is substantiated their participation in Investment20/20 programme activities may be terminated. Further action may be pursued by the relevant authorities. The Investment Association will make any notifications that are required by law. If a criminal offence has been committed the police (and any other relevant body) will be contacted to take the matter further.

If an allegation is determined to be unfounded or malicious, The Investment Association will alert the relevant people or external bodies. In the rare event that an allegation is shown to have been deliberately invented or malicious, the Investment Association will ask the police to consider whether any action might be appropriate against the person responsible.

14. Disciplinary procedures: Investment20/20 staff

Where a disciplinary action is taken against Investment20/20 staff, it should be done so in accordance with the Investment Association’s disciplinary policy.

15. Representatives from Investment20/20 member firms

Where it is an individual who is not an Investment20/20 employee, i.e., a volunteer, it is their employer who will be responsible for taking disciplinary action based upon their own processes and policy.

Contacts

[email protected]

Further information can be gained from the NSPCC Helpline.