Investment20/20 Safeguarding Policy
This policy applies to anyone working on behalf of the Investment Association and Invesment20/20. 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 Investment20/20 are aware of the structured response procedure for safeguarding concerns
• Expresses the commitment of Investment20/20 to safeguarding and child protection
Investment20/20 has a responsibility to promote the welfare of all children and young people and keep them safe.
Investment20/20 is a national careers service for the investment management sector.We work with schools, colleges, universities and community groups to enable young people to find out about careers in investment management and to help them navigate their way to entry level roles.
We work with young people in three ways:
1. Delivery of careers workshops to groups of young people aged from 11 years upwards in schools, colleges, universities, community venues, employer venues, and other spaces.
2. Through our longer term programmes such as Think Investments and Work Experience, spanning from one week to over 6 months, where we engage with young people on an ongoing basis, in both individual and group work settings.
3. Through our Investment20/20 Trainee Programme, where young people over the age of 16 are employed by an Investment20/20 employer partner for a one year contract.
Young people who participate in Investment20/20 activities 2&3 above are aged over 16. We engage with young people under the age of 16 through activity 1, above.Any of the young people with whom we work may be enrolled at a school sixth form, FE College, Sixth Form College or other education provider.
Types of abuse
It is important for any adult involved in working with Invesment20/20 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 read the briefing on the types of child abuse on 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:
Good practice guidelines
All adults working with Investment20/20, in whatever capacity, should demonstrate exemplary behaviour. The following are common sense examples of how to create a positive culture and environment.
• Always work in an open environment, avoiding private situations
• Treat all young people with respect and dignity
• Always prioritise the welfare of each young person
• Maintain an appropriate emotional and physical distance from the young person
• Ensure the young person is in a space with other people around - never be in a room alone with a young person, and keep doors open and blinds up
• Be an excellent role model e.g. not smoking/drinking in the company of a young person
• Give enthusiastic and constructive feedback rather than negative criticism
• Administer first aid/other medical treatment when necessary, and report in line with the hosting organisation’s/venue’s policy and procedure, and inform Investment20/20
• Never take a young person in a car or accompany on a journey, e.g., after a careers event
• Do not say or do anything that might be interpreted as aggressive or hostile
• Do not do things of a personal nature for young person at a Investment20/20 event or programme student that they can do for themselves
• Report any incidents (see below)
Under no circumstances should any adult working with Investment20/20:
• 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 young people on Investment20/20 events/programmes to use inappropriate language unchallenged
• Make sexually suggestive comments to young people on Investment20/20 events/programmes
• Meet with young people on Investment20/20 events/programmes in an inappropriate place, e.g., a nightclub, bar, restaurant
• Allow allegations made by young people on Investment20/20 events/programmes to go unchallenged, unrecorded or not acted upon
• Fail to report to Investment20/20 anything inappropriate that a young person does or says
Incidents that must be reported
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.You must report any incidents including the below:
• You hurt a young person on Investment20/20 events/programmes, even if unintentionally
• You witness any inappropriate behaviour, whether from another adult or from a young person on Investment20/20 events/programmes
• A young person on Investment20/20 events/programmes
- seems distressed
- mentions they are in danger at home or school
- 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
- makes suggestive or inappropriate comments, either in person, online or using any other form of communication.
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.
Investment20/20 has a duty of care towards young people who are participating in our organised events. This duty of care covers the duration of the event from the designated meeting point until the event finishes. Investment20/20 is responsible for obtaining from the venue, a risk assessment for the visit.
When a teacher or other school/college/university/community group representative is attending with young people, the young people remain in the duty of care of the school/college/university/ community group.Investment20/20 will provide a risk assessment of the venue but it is expected that the school/college representative takes full responsibility for their students for the entire duration of the visit.
When students attend an event independently of the school/college/university/community group, Investment20/20 expects students to travel to the event by themselves and manage the planning and funding of their journey independently of Investment20/20.
Investment20/20 will endeavour to gain emergency contact details for each young person that attends and event, and will call a parent/carer should a young person become unwell or if there is a concern regarding their welfare.Investment20/20 accepts no responsibility for personal belongings brought by students to events.
Investment20/20 follows a guideline of one member of staff for every 20 students.These members of staff may include adults from the hosting organisation who support the event.
Any adult representing Investment20/20 must ensure that all communication is transparent and open to scrutiny. Investment20/20 staff must use their Investment20/20 mobile or office phone to contact young people, and NOT their personal phone number.If their Investment20/20 phone is damaged, not working or lost, and staff must call a young person, then they may use their personal phone but ensure their number is blocked and do not share their personal number with the young person. Staff may only communicate with young people on social media via the official Investment20/20 social media outlets or their own LinkedIn account (no other social media platforms) but their contact details must be hidden.Any email communication must take place on the Investment20/20 email account and NOT personal email accounts.
Photography and film
Investment20/20 will take photos and films at our events, which could be either Investment20/20 organised events or a partner organisation event.Young people will be asked to agree to their image/footage being used as part of the registration process for the event where it is Investment20/20 organised.Where it is a partner organised event, Investment20/20 will ask sign young people to sign a photography/film permission form.
All Investment20/20 staff, including consultants, are to:
• Have a Disclosure and Barring Service (DBS) check to Enhanced level in England
• 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 and volunteers 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.
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.
Reporting a concern or allegation
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 young person’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
• Listen carefully
• 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 young person that you cannot guarantee confidentiality
• Explain that information will only be shared with people that will help to ensure the young person's safety and well-being
• Inform the Investment20/20 Safeguarding Lead immediately
• The Safeguarding Lead should review the information and ALWAYS pass to the school/college/university/community group Safeguarding Officer.It is the responsibility of the school/college/university/community group Safeguarding Officer to take the necessary action to ensure the situation is addressed appropriately
• If the young person is not part of a school/college/university/community group, the Local Authority Safeguarding Officer must be notified
• Investment20/20’s responsibility is to follow through on actions allocated. Assistance will be provided to external investigators.
b. Process for reporting
It is the responsibility of the school/college/university/community group/Local Authority Safeguarding Office to liaise with the parents/carers of the young person involved, should it be appropriate.If there has been any physical injury to the young person during an event/shadowing day/work placement the parents/carers should be informed immediately.
1. Report disclosure to the Investment20/20 Safeguarding Lead via phone and email: firstname.lastname@example.org / 07851 950207
2. 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.
3.The Investment20/20 Safeguarding Lead reports the disclosure to:
a. The young person’s school, college, university or community group and if necessary, the Safeguarding Lead at the Local Authority in which the young person attends school/college/university/community group
b. Depending upon the person making the disclosure, it may be necessary to inform one or more of the following people
i. School or college Safeguarding Officer
ii. Employee’s manager or HR manager
iii. Volunteer’s manager or HR manager
4. The Safeguarding Lead notes last key action point taken and who is responsible for continuing investigation.
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.
c. Outcome of investigation
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.
d. 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.
e. Investment20/20 volunteers
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.
Initial queries should be directed to Jenny Barber, Safeguarding Lead, on 07851 950207or email@example.com.Further information can be gained from the NSPCC Helpline: 0808 800 5000