This policy applies to the whole of Armirate Education Limited’s workforce. This policy is available for parents online.

Armirate Education Limited's commitment to Safeguarding
1. Armirate Education Limited recognises its responsibility for safeguarding and promoting the welfare of children under the age of 18 and vulnerable adults. We seek to establish a safe and nurturing environment for all participants of our courses. Because of the day-to-day contact with children, our staff have a responsibility to be vigilant to the outward signs of abuse, and act if they know or suspect that a child is being abused. Safeguarding is the responsibility of everyone within Armirate Education Limited that may come into contact with children on the course. We will apply this policy equally to any child regardless of age, gender, ethnicity, disability, sexuality, faith or belief.

2. Armirate Education Limited will:
• uphold a culture of ongoing vigilance towards safeguarding;
• treat safeguarding as everyone's responsibility;
• maintain openness around discussing concerns in the belief that 'it could happen here';
• ensure participants know they can approach any staff member of Armirate Education Limited
and they will receive a consistent, supportive response;
• provide clear procedures and support for reporting concerns and setting acceptable standards
of behaviour.

3. This means that all staff are contractually required to report any safeguarding concerns to a designated safeguarding lead and undertake safeguarding training, as deemed appropriate by Armirate Education Limited. We will keep accurate written records of concerns on participants even where referral is not appropriate immediately and ensure that all child protection records are kept securely, remain confidential, and separate from the main files.

4. This also means that Armirate Education Limited will undertake to follow the specific local authority's safeguarding procedures for all locations in which we deliver our courses.

5. We will review our policy and procedures annually with all changes communicated to staff and we will ensure that we have a designated member of staff for safeguarding who has received appropriate training and support for this role. We will also maintain a designated safeguarding lead (“DSL"), currently listed as Lawrence Coupland (lawrie.coupland@armirate.com).

6. All staff will have access to requisite training for their role, and we shall ensure that staff who work with children are to be trained in Armirate Education Limited's safeguarding procedures. This includes ensuring that:
• all newly appointed staff will have induction training which includes child protection;
• prior to staff working on courses in foreign jurisdictions, such staff will undertake the requisite online training modules so that they are able to operate effectively in the foreign jurisdiction and
at the premises in which the course is to take place.
• all staff are aware that any inappropriate relationship between staff and a participant of any age on the course will result in instant dismissal. In cases where the law is broken, the appropriate authorities shall be involved;
• all staff understand their responsibilities in being alert to, and acting appropriately in, cases of abuse or suspected abuse;
• all staff understand that all allegations made against staff or participants shall be dealt with by the DSL.

Safer Recruitment
7. All our staff will be recruited in accordance with our safer recruitment policy, which includes:
• obtaining an enhanced DBS check and barred list check, or (if international) a certificate of good conduct from their local police (translated);
• before employment begins, obtaining validated reference checks which specifically indicate the candidate’s suitability to work with vulnerable adults and children under the age of 18;
• reporting to the Disclosure and Barring Service any person (whether employed, contracted or a volunteer) whose services are no longer used because he or she is considered unsuitable to work with children. This will be done within one month of the individual leaving Armirate Education Limited; and
• in cases where a member of residential staff is suspended pending investigation of a child protection nature, we will undertake to resolve the investigation as quickly as reasonably possible to enable the member of staff to return to their accommodation. Armirate Education Limited may, at our discretion based on the nature of the investigation, provide alternative accommodation.

Prevention and Support

8. We recognise that high self-esteem, confidence, supportive friends and good lines of communication with a trusted adult helps to safeguard participants on the course. Armirate Education Limited will therefore:
• establish and maintain an ethos where children are encouraged to talk and are listened to; and
• ensure children know that there are staff whom they can approach if they are worried or in difficulty.

At Armirate Education Limited, we respect the participants of the course. The atmosphere is one that encourages all participants in the course to obtain the most they can from the course. We provide opportunities that enable the participants to experience a new culture in a safe and protected environment.

Participant and Staff Ratios

9. In the interests of participant and staff welfare, courses will be staffed to support a ratio of one staff member to ten participants. However, whilst on off-campus excursions, such excursions will be staffed to support a ratio of one staff member to 15 participants and all coaches / busses transporting participants will have at least 2 staff members on board. Additionally, there will never be less than one qualified first-aider as resident with every participant group and on every external day trip.

Recognising Abuse

10. There are four categories of abuse to recognise in safeguarding:
• Physical abuse - any abuse that causes physical harm.
• Emotional Abuse - any abuse causing negative effects on emotional development.
• Sexual Abuse - forcing a child under the age of 18 and vulnerable adults to engage in sexual activities, behave in sexually inappropriate ways or by exposing them to sexual activities.
• Neglect - persistent failure to meet a child’s (under the age of 18) and vulnerable adult’s basic physical and/or psychological needs. This failure can then impair their development and/or health. We must also be aware that abuse can be both active and passive, that is to say someone can actively harm a child under the age of 18 and / or vulnerable adult or they can fail to act to prevent harm to a child under the age of 18 and / or vulnerable adult.

11. Other forms of abuse include female genital mutilation, trafficking and modern slavery, sexual exploitation, drug exploitation, forced marriage, radicalisation and extremism, bullying/ cyberbullying, fabricated or induced illness.

Adult-Child Interaction

12. Positions of Trust. Adults who work with children should avoid any conduct which would lead any reasonable person to question their motivation and intentions. Adults working with under 18s are in a position of trust; the Sexual Offences Act (2003) states that any person in a position of trust engaged in a sexual activity of any sort with participants under the age of 18 is breaking the law even though the UK legal age of consent is 16.
13. Physical Contact. There are occasions when it is entirely appropriate for staff to have some physical contact with children but this should always be consistent with their professional role and responsibilities. These situations may include:
when a child is in distress – staff should comfort or reassure a child in an age-appropriate way whilst maintaining clear professional boundaries;
• for restraint and physical intervention - if staff have failed to diffuse situations any other way, physical intervention may be used to manage a child’s or young person’s behaviour if it is necessary to prevent personal injury to the child, other children or an adult, to prevent serious damage to property or in what would reasonably be regarded as exceptional circumstances. When physical intervention is used it should be undertaken in such a way that maintains the safety and dignity of all concerned;
• First Aid – staff should ensure another member of staff is aware of the action being taken, explain to the participant what is happening and record it. Physical contact should take place only when it is necessary in relation to a particular activity. It should take place in a safe and open environment, i.e. one easily observed by others, and be for the minimum time necessary.

Staff should not:

• use physical force as a means of punishment and discipline. The use of unwarranted force may constitute a criminal offence;
• touch a participant in any way that could be considered inappropriate;
• indulge in horse-play.

14. Behaviour Management. Staff should not use any form of degrading treatment to punish participants. Sarcasm and demeaning or insensitive comments are not acceptable. The use of corporal punishment is not acceptable. Any sanctions or rewards should be in line with Armirate Education Limited’s terms & conditions and rules & regulations.
15. Fairness. Staff should exercise care when selecting participants for specific activities or privileges to avoid perceptions of favouritism or unfairness. Methods and criteria for selection should always be transparent and subject to scrutiny.
16. Use of appropriate language. Staff should not:
• shout at participants (except in situations of danger);
• swear in the vicinity of or at participants;
• ridicule or bully participants;
• make suggestive remarks or gestures towards participants (or towards colleagues while participants are present).

17. Infatuations and Sexual Contact. Occasionally, a participant may develop an infatuation with an adult who works with them. Staff should deal with these situations sensitively and appropriately to maintain the dignity and safety of all concerned. They should remain aware, however, that such infatuations carry a high risk of words or actions being misinterpreted and should therefore make every effort to ensure that their own behaviour is above reproach. An adult, who becomes aware that a child or young person is developing an infatuation, should discuss this at the earliest opportunity with the DSL so appropriate action can be taken to avoid any hurt, distress or embarrassment. All staff should clearly understand the need to maintain appropriate boundaries in their contacts with children. Intimate or sexual relationships between participants and staff will be regarded as a grave breach of trust. Allowing or encouraging a relationship to develop in a way which might lead to a sexual relationship is also unacceptable. Any sexual activity may be regarded as a criminal offence and will always be a matter for disciplinary action. Children are protected by specific legal provisions regardless of whether they consent or not. The sexual activity referred to does not just involve physical contact including penetrative and non-penetrative acts. It may also include non-contact activities, such as causing children to engage in or watch sexual activity.
Staff should not:
• have any form of communication with a child which could be interpreted as sexually suggestive or provocative i.e. verbal comments, letters, notes, electronic mail, phone calls, texts, physical contact;
• make sexual remarks to, or about, a child; and
• discuss their own sexual relationships with or in the presence of children.

18. Appropriate appearance. Staff should dress in ways that are appropriate to their role. Clothing should take account of weather conditions, not be revealing, sexually provocative or give rise to misunderstanding or political/cultural offence. Should the course leader decide that a staff member’s clothing or appearance is inappropriate for their role, the course leader shall have the right to request the staff member change clothing and / or suspend them from course activities.

19. Alcohol, drugs & smoking.
• Staff must not have consumed alcohol prior to supervising participants or return to accommodation under the influence of alcohol which causes their behaviour to be disruptive or makes them a risk to participants.
• All campuses used by Armirate Education Limited are non-smoking environments. Staff are not permitted to smoke anywhere on any campuses including the accommodation. Participants must be informed of the smoking ban and that disciplinary action will be enforced if the ban is ignored.
• Smoking inside a building is a serious matter due to the fire risk and tainting of interior decoration, so this would prompt a formal warning as per the disciplinary procedures in place from time to time.
• Proven drug taking/buying will result in the staff member being removed immediately from their position. Participants proved to have bought/taken drugs will be immediately removed from the course and will either be sent home at the earliest opportunity or reported to the local authority, as Armirate Education Limited deems appropriate. Substances that would constitute a drug for the purposes of this provision are those that are illegal in the UK, China or any jurisdiction in which the course shall take place.

20. Communication with participants. Communication between participants and staff, by whatever method, should take place within clear and explicit professional boundaries. This includes the wider use of technology such as mobile phones, text messaging, e mails, digital cameras, videos, webcams, websites and blogs. Staff should not share any personal information with a participant.

They should not request, or respond to, any personal information from the participant (during and after the course) and should ensure that all communications are transparent and open to scrutiny. Therefore staff should:
• only make contact with participants for professional reasons;
• recognise that messaging is rarely an appropriate response to a participant in a crisis situation or at risk of harm. It should only be used as a last resort when other forms of communication are not possible – direct calling should be the first resort when a participant is in a crisis situation or at risk of harm;
• not use internet or web-based communication channels to send personal messages to a participant – always have at least a second staff member included in all communications.

21. Accommodation. All staff should note that among the higher-risk times in accommodation settings
are the following:

• early morning when participants are getting up;
• at bedtime/lights out;
• during showering, when participants are getting changed for sports activities or external trips.

In order to minimise risks, staff must adhere to the following, except where doing so may prejudiceparticipant safety:

no member of staff can go to accommodation areas of the opposite sex after timetabled bedtime, without being accompanied by a same sex staff member;

• no member of staff may enter a participant’s bedroom unless the door is kept wide open or unless accompanied by another member of staff;
• a member of staff must never enter a changing room of the opposite sex;
• male/female showers are clearly signposted and must be respected. A member of staff should not go into a showering facility of the opposite sex.

Reporting a Concern

22. Participants are with Armirate Education Limited for usually two weeks. This limits time for abuse to occur, to be noticed, or to be expressed. We recognise that participants who are abused may find it difficult to disclose this to staff whom they have only known for a short while. Therefore, we will do all we can to foster a culture of openness and trust, as well as equipping staff with the knowledge needed to recognise abuse should it occur.

23. It is also possible that participants may feel that their time away from home is their opportunity to disclose abuse in their lives. In both instances a concern for the participant may arise and it is the responsibility of any staff member concerned about a participant to voice their concern.

Whistleblowing

24. All staff should be aware of their duty to raise concerns, where they exist, about the attitude or actions of their colleagues. We recognise that participants cannot be expected to raise concerns in an environment where staff fail to do so.

25. As part of their induction training all new members of staff at Armirate Education Limited are given an explanation of the steps that the company will take when concerns are raised by a staff member or a participant.

Equal Opportunities and Safeguarding

26. Some participants may be vulnerable to an increased risk of abuse. It is important to understand that this increase is always due to societal attitudes and child protection procedures that fail to acknowledge participants’ diverse circumstances, rather than the individual participant’s personality, impairment or circumstances. Many factors can contribute to an increase in risk, including prejudice and discrimination, isolation, social exclusion, communication issues, learning disabilities and reluctance on the part of some adults to accept that abuse can occur.

27. To ensure that all of participants receive equal protection, we will give special consideration to participants who are:

• disabled or have special educational needs;
• living in a domestic abuse situation;
• vulnerable to being bullied, or engaging in bullying;
• living in chaotic and unsupportive home situations;
• vulnerable to discrimination and maltreatment on the grounds of race, ethnicity, religion or sexuality;
• not fluent users of English.

Handling a Disclosure

Suspecting a participant may be at risk of harm

28. There will be occasions when you suspect that a participant may be at risk, but you have noquantifiable evidence. In these circumstances, you should try to give the participant the opportunityto talk or communicate in their preferred method. The signs you have noticed may be due to avariety of factors, for example, a parent has moved out, a pet has died, a grandparent is very ill. Itis fine to ask the participant if they are ‘okay’ or if you can help in any way.

If a participant discloses to you

29. If a participant communicates to you any risks around their safety or wellbeing you must let them know that you must pass the information on. The point at which you do this is a matter for professional judgement. Never promise confidentiality as we must act with the participant's best interests in mind. During your conversation:

• allow them to speak freely;
• remain calm with composed reactions;
• give reassuring nods or words of comfort;
• do not be afraid of silences;
• under no circumstances ask investigative questions;
• at an appropriate time tell the child/young person that in order to help them you must pass the information on; and
• do not automatically offer any physical touch as comfort.

30. If the participant is in immediate harm you must notify the DSL immediately and failing that contact the local authority. Irrespective of immediate harm, always report the conversation to the DSL. Write up the situation and series of events as soon as possible and seek support if you feel distressed.

Supporting staff

31. We recognise that staff who have become involved with a participant who has suffered, or is
suffering, harm, may find the situation stressful and upsetting. We will support staff by providing an
opportunity to talk through their anxieties with the DSL and we will seek further support whenever
needed.