Protecting childhood.
Building futures.

• Organisation: The David Shelton Foundation
• Location: Kampala, Uganda
• Primary beneficiaries: Vulnerable, orphaned and street-connected children and young people
• Primary focus: Boys aged 7–18
• Policy owner: Board of Directors / Trustees

Contents

• 1. Policy statement
• 2. Purpose of this policy
• 3. Definition of a child
• 4. Our safeguarding principles
• 5. Types of harm
• 6. Identifying children at risk
• 7. Responding to a safeguarding concern
• 8. Reporting responsibilities
• 9. Designated safeguarding person
• 10. Staff and volunteer recruitment
• 11. Code of conduct
• 12. Physical contact
• 13. One-to-one contact
• 14. Transporting children
• 15. Photography and media
• 16. Social media
• 17. Children’s personal information
• 18. Child participation
• 19. Working with street-connected children
• 20. Family reintegration
• 21. Complaints
• 22. Whistleblowing
• 23. Allegations against staff or volunteers
• 24. Allegations against senior management
• 25. Safeguarding training
• 26. Safeguarding risk assessments
• 27. Partner organisations
• 28. Residential services
• 29. Monitoring and review
• 30. Policy breaches

The David Shelton Foundation is committed to protecting children and young people from abuse, neglect, exploitation, violence, discrimination and avoidable harm.

We recognise that children who are orphaned, street-connected, homeless, living in poverty or experiencing family breakdown may face heightened vulnerabilities.

The Foundation therefore places child safety, dignity and wellbeing at the centre of all its activities.

We will take reasonable and appropriate steps to:

• Prevent harm.
• Identify safeguarding concerns.
• Respond appropriately to concerns and allegations.
• Refer matters to relevant authorities and professionals.
• Recruit suitable staff and volunteers.
• Maintain appropriate professional boundaries.
• Protect children’s privacy and dignity.
• Listen to children and take their views seriously.
• Create safe environments for participation.

This policy establishes the Foundation’s minimum standards for safeguarding children.

It applies to:

• Board members.
• Directors and trustees.
• Employees.
• Social workers.
• Outreach workers.
• Volunteers.
• Mentors.
• Consultants.
• Contractors.
• Interns.
• Partner organisations where relevant.
• Visitors working directly with children.
• Anyone representing the Foundation.

No person working with or representing the Foundation is exempt from safeguarding responsibilities.

For the purposes of the Foundation’s programmes, a child is a person under the applicable legal definition of a child in Uganda.

The Foundation will also apply heightened safeguarding measures to young people transitioning from childhood into adulthood where they remain connected to Foundation services.

4.1 Best Interests

The best interests, safety and wellbeing of the child will guide decisions affecting them.

4.2 Do No Harm

Foundation activities must not unnecessarily expose children to additional risk.

4.3 Dignity

Children must be treated with respect regardless of their background or circumstances.

4.4 Listening

Children should be given appropriate opportunities to express their views and concerns.

4.5 Confidentiality

Information concerning children must be handled carefully and shared only where there is a legitimate reason to do so.

4.6 Accountability

Everyone working for the Foundation is responsible for following safeguarding procedures.

4.7 Professional Boundaries

Adults working with children must maintain appropriate and professional relationships.

4.8 Zero Tolerance of Abuse

The Foundation will not tolerate abuse, exploitation or sexual misconduct involving children.

Safeguarding concerns may include:

Physical Abuse

Examples include:

• Hitting.
• Beating.
• Burning.
• Shaking.
• Deliberately causing injury.
• Other forms of physical violence.

Emotional or Psychological Abuse

Examples include:

• Threatening.
• Humiliation.
• Intimidation.
• Persistent verbal abuse.
• Deliberate isolation.
• Severe rejection.
• Manipulation.

Sexual Abuse and Exploitation

This includes any sexual activity involving a child, sexual exploitation, grooming, inappropriate touching, sexual communication or exposure to sexual material.

Neglect

Examples include failure to provide reasonable care, supervision, food, hygiene, medical attention, education or protection from known dangers.

Exploitation

This may include:

• Child labour.
• Forced labour.
• Commercial sexual exploitation.
• Trafficking.
• Criminal exploitation.
• Forced begging.
• Other forms of exploitation.

Online Harm

This may include:

• Online grooming.
• Sexual exploitation.
• Cyberbullying.
• Sharing inappropriate images.
• Manipulation or coercion.
• Unauthorised publication of children’s personal information.

Children may be identified through:

• Street outreach.
• Referrals.
• Schools.
• Families.
• Community leaders.
• Health professionals.
• Social workers.
• Government agencies.
• Partner organisations.
• Self-referral.
• Other legitimate safeguarding channels.

Initial assessments should consider:

• Immediate safety.
• Housing and living arrangements.
• Family circumstances.
• Education.
• Health.
• Nutrition.
• Emotional wellbeing.
• Exposure to abuse.
• Exploitation.
• Substance misuse.
• Criminal exploitation.
• Trafficking concerns.
• Immediate protection needs.

Where a staff member, volunteer or representative becomes concerned that a child may be at risk:

STEP 1 — Listen

Listen calmly if the child chooses to disclose something.

Do not pressure the child for unnecessary details.

STEP 2 — Reassure

Tell the child that their concern has been heard and that they have done the right thing by speaking to a trusted adult.

Do not promise absolute confidentiality.

STEP 3 — Protect

Consider whether the child is in immediate danger.

Where immediate danger exists, seek appropriate emergency or protective assistance.

STEP 4 — Report

Report the concern immediately to the Foundation’s designated safeguarding person.

STEP 5 — Refer

Where required, the concern should be referred to the appropriate statutory or professional authority.

STEP 6 — Record

Make an accurate, factual record as soon as possible.

The record should distinguish between:

• What was observed.
• What the child said.
• What another person reported.
• What action was taken.

The Foundation recognises that organisations and individuals who interface with children have responsibilities to report abuse to appropriate authorities.

Uganda’s Children Act provides mechanisms for reporting matters affecting a child’s wellbeing and provides for protective services, assessment, investigation and appropriate referrals.

The Foundation will therefore maintain clear reporting procedures and cooperate with appropriate authorities.

Emergency concerns

Where there is an immediate threat to a child’s life or safety, staff should prioritise immediate protection and contact the appropriate emergency, police, social-welfare or child-protection authority.

The Foundation shall appoint a:

Designated Safeguarding Lead (DSL)

Name: Janat Namatovu

Position: Safeguarding Lead

The DSL will:

• Receive safeguarding concerns.
• Maintain safeguarding records.
• Coordinate appropriate referrals.
• Advise staff and volunteers.
• Monitor safeguarding risks.
• Support safeguarding training.
• Report serious matters to senior management and/or the Board.
• Liaise with appropriate authorities.

A deputy safeguarding officer should also be appointed.

The Foundation recognises that effective safeguarding begins before a person starts working with children.

Recruitment procedures should include, where appropriate:

• Application forms.
• Identity verification.
• Interviews.
• References.
• Relevant qualification checks.
• Employment history.
• Safeguarding questions.
• Appropriate background or police checks where available and required.
• Declaration of relevant conflicts or safeguarding concerns.

No individual should be given unsupervised access to children until appropriate recruitment and safeguarding procedures have been completed.

Adults working with children must:

• Treat children respectfully.
• Maintain appropriate boundaries.
• Use appropriate language.
• Avoid humiliating or threatening children.
• Never hit or physically punish a child.
• Never engage in sexual behaviour with a child.
• Never exploit a child’s vulnerability.
• Never use Foundation activities for personal gain.
• Never deliberately isolate a child in an unsafe environment.
• Report safeguarding concerns.
• Follow Foundation policies.

Physical contact must always be appropriate to the child’s age, needs and circumstances.

Staff and volunteers should avoid unnecessary physical contact.

Physical intervention may only be used where necessary to prevent immediate harm and must comply with applicable law, professional standards and Foundation procedures.

Any significant incident must be reported and recorded.

Where possible, adults should avoid situations where they are unnecessarily alone with a child.

Where one-to-one work is necessary:

• It should take place in an appropriate environment.
• The interaction should be professional.
• Appropriate records should be maintained.
• Staff should follow supervision requirements.

Anyone transporting children on behalf of the Foundation must:

• Be appropriately authorised.
• Follow applicable driving and safeguarding requirements.
• Use a safe and appropriate vehicle.
• Avoid unnecessary unsupervised stops.
• Maintain professional boundaries.
• Report accidents or safeguarding concerns immediately.

Children must not be photographed, filmed or publicly identified without appropriate consent and safeguarding procedures.

The Foundation will not use images that:

• Humiliate children.
• Sexualise children.
• Portray children in degrading circumstances.
• Reveal unnecessary personal information.
• Put a child at risk.

Images used for fundraising should promote children’s dignity and avoid presenting children solely as objects of pity.

Staff and volunteers must not:

• Privately communicate with children through personal social-media accounts where this creates an inappropriate relationship.
• Share children’s personal information.
• Share inappropriate images.
• Publish identifying information without appropriate consent.
• Post material that could place a child at risk.

Official communication channels should be used wherever practical.

Information about children shall be treated as confidential.

Records should be:

• Accurate.
• Secure.
• Access-controlled.
• Relevant.
• Kept only as long as legitimately required.

Information may be shared where necessary to:

• Protect a child.
• Respond to a safeguarding concern.
• Obtain essential services.
• Comply with legal obligations.
• Facilitate appropriate professional intervention.

The Foundation believes children should be heard.

Children may be invited to contribute to:

• Programme design.
• Feedback.
• Activities.
• Reviews.
• Youth forums.
• Appropriate decision-making.

Participation must always be age-appropriate and voluntary.

A child should never be pressured to disclose personal experiences for publicity or fundraising purposes.

Street-connected children may face complex and overlapping risks.

Outreach workers should consider:

• Immediate physical safety.
• Exploitation.
• Trafficking.
• Violence.
• Substance misuse.
• Criminal exploitation.
• Sexual exploitation.
• Family circumstances.
• Education.
• Health.
• Mental and emotional wellbeing.

Outreach should prioritise building trust and connecting children with appropriate protection and support services.

Staff must not make promises that the Foundation cannot fulfil.

Family reintegration should only be pursued where appropriate and where it is assessed to be in the child’s best interests.

The Foundation should consider:

• Family circumstances.
• Safety.
• Previous abuse or neglect.
• Caregiver capacity.
• Child’s views.
• Availability of support.
• Appropriate professional assessment.
• Follow-up requirements.

A child should not be returned to an environment where there is an unresolved significant risk of harm.

Children should have accessible ways to make complaints.

Complaints may be made to:

• A trusted member of staff.
• The Designated Safeguarding Lead.
• The Executive Director.
• The Board.
• An appropriate external authority.

Children should not be punished for raising genuine concerns.

Staff and volunteers may raise concerns about:

• Abuse.
• Neglect.
• Financial misconduct.
• Safeguarding failures.
• Serious policy breaches.
• Unsafe practices.
• Abuse of organisational power.

No person should be victimised for raising a genuine safeguarding concern in good faith.

Where an allegation is made against a staff member or volunteer:

• The child’s immediate safety must be considered.
• The allegation must be reported to the Designated Safeguarding Lead.
• Appropriate authorities must be contacted where required.
• The Foundation must avoid interfering with any official investigation.
• The person accused may be removed from child-facing duties while the matter is appropriately assessed.
• Confidentiality must be maintained.
• The Foundation will cooperate with legitimate investigations.

Suspension or temporary removal from duties does not itself establish that an allegation is true.

If an allegation concerns the Executive Director, Board member or Designated Safeguarding Lead, it must be reported to an appropriate alternative senior person or directly to the relevant authority where necessary.

No individual should investigate an allegation in which they have a personal conflict of interest.

All staff and volunteers working with children should receive safeguarding induction before beginning child-facing activities.

Training should cover:

• Recognising abuse.
• Responding to disclosures.
• Reporting procedures.
• Professional boundaries.
• Online safety.
• Child participation.
• Confidentiality.
• Safe photography.
• Working with vulnerable children.
• Preventing exploitation.

Refresher training should be provided periodically.

The Foundation should conduct safeguarding risk assessments for:

• Outreach activities.
• Events.
• Transport.
• Accommodation.
• School programmes.
• Sports activities.
• Residential activities.
• International visitors.
• Fundraising activities.
• Photography and media.
• Digital communication.

Risk assessments should identify:

Risk → Likelihood → Potential Impact → Controls → Responsible Person → Review Date

Where the Foundation works with another organisation that has contact with children, reasonable safeguarding standards should be assessed.

Partnership agreements should address, where appropriate:

• Child protection.
• Reporting concerns.
• Staff conduct.
• Information sharing.
• Confidentiality.
• Complaints.
• Safeguarding responsibilities.

If the Foundation establishes residential accommodation for children in the future, it must not do so solely on the basis of this policy.

The Foundation will first ensure that:

• Appropriate legal permissions are obtained.
• Relevant standards are understood.
• Suitable premises are established.
• Staffing arrangements are adequate.
• Safeguarding systems are operational.
• Qualified professionals are available.
• Emergency procedures are established.
• Children receive appropriate care and supervision.

The Board shall monitor implementation of this policy.

The Foundation will review:

• Safeguarding incidents.
• Complaints.
• Training.
• Recruitment.
• Risk assessments.
• Referral procedures.
• Lessons learned.

This policy shall be reviewed at least annually or sooner where there is:

• A significant incident.
• A change in law.
• A change in programme activities.
• A material safeguarding concern.
• A recommendation from an appropriate authority.

Failure to comply with this policy may result in:

• Additional training.
• Supervision.
• Disciplinary action.
• Removal from child-facing activities.
• Termination of a volunteer or employment relationship.
• Referral to relevant authorities.

Serious safeguarding breaches may require immediate action.

Safeguarding concerns are received by the Foundation’s Designated Safeguarding Lead, Janat Namatovu. If a child is in immediate danger, contact the appropriate emergency, police, social-welfare or child-protection authority first.

Our safeguarding commitment ↗