Purpose of Policy

The purpose of this policy is to protect people, particularly children, at risk adults and clients, from any harm caused by coming into contact with Reprieve. This policy lays out the commitments made by Reprieve and informs Reprieve personnel of their responsibilities in relation to safeguarding.

We work for people whose experiences have made them extremely vulnerable, as it is in their cases that human rights are most swiftly jettisoned and the rule of law is cast aside. We promote and protect the rights of those facing the death penalty and those who are the victims of extreme human rights abuses.

In so doing, we have a responsibility to:

• ensure that we do no harm to our clients;
• safeguard children and adults at risk whom we come into contact with in the course of our work; and
• safeguard all other people that we come into contact with in the course of our work (including our employees, fellows, consultants, secondees and volunteers).

Definitions

• child: as anyone under the age of 18 years old.

• adult at risk: as defined in the Care Act 2014 is an individual aged 18 or over, who:
  • has needs for care and support; and
  • is experiencing, or at risk of, abuse or neglect; and
  • as a result of those care and support needs is unable to protect themselves from either the risk of or the experience of abuse or neglect.

·       Harm: psychological or physical abuse including but not limited to:

• sexual harassment, abuse and exploitation
  • criminal exploitation
  • cyber abuse
  • modern day slavery
  • negligent treatment
  • self-neglect
  • physical or emotional abuse
  • bullying or harassment
  • health and safety
  • commercial exploitation
  • forced marriage
  • human trafficking
  • female genital mutilation.

Reprieve personnel: anyone employed or engaged directly or indirectly by Reprieve and includes Trustees, staff, volunteers, work placement students, trainers and consultants.

• Safeguarding: means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially adults at risk, clients and children, from that harm; and to respond appropriately when harm does occur. Safeguarding puts clients and affected persons at the centre of all we do.

While this policy focuses on the workplace responsibilities of staff, responsibilities to safeguard and promote the welfare of children and adults at risk extends to an individual’s personal and domestic life.

Safeguarding Procedures

We commit to addressing safeguarding throughout our work, through the three pillars of prevention, response and reporting.

Prevention

1. Ensuring that Reprieve practises safe recruitment and employment.

• Ensuring safe environments for provision of services and the implementation of sufficient safeguards in those environments.

• Building a culture of safeguarding that values and respects all children and adults and modelling appropriate conduct in line with our values.

• Setting out clear roles and responsibilities for safeguarding.

Reporting

• Raising awareness of child and adult protection situations, and our procedures for identifying and reporting concerns or suspected cases.

• Reporting any breaches of this policy, allegations or incidents to Social Services, Charity Commission and law enforcement where appropriate.

Response

• Investigating fully any allegations or incidents connected to this policy.

PREVENTION

1.        Safe recruitment and employment

Prior to an individual’s appointment being confirmed at Reprieve, the individual will be subjected to the following vetting checks:

• A check in which they are asked to disclose previous spent convictions and disciplinary or capability procedures – this is saved by Reprieve’s Operations Officer.
• Provision for sighting of an identity document that includes a photo.
• Provision of right to work documentation and certification that the documentation is theirs and is valid.
• Provision of two references including at least one professional reference from their previous employer.
• Provision of qualification certificates if required for the role.
• Completion of a Disclosure and Barring Service (DBS) Check if eligible or an equivalent overseas check – see guidance here.

Reprieve ensures all new Reprieve personnel complete an induction. As part of the induction process, the new starter will be provided with a copy of this safeguarding policy and will be asked for confirmation that they have read it. All new starters must complete a Safeguarding training which will be facilitated by the Operations team at least every six months.

2.        Safe environments

The workplace

Reprieve is a small organisation staffed with committed individuals who work closely together, sometimes travelling together, and supporting one another when working on difficult cases

When we enter the Reprieve workplace (either in person or remotely), we act as professionals and need to be mindful of others’ religious and cultural beliefs and values, as well as the personal history that each of us holds close. This means that Reprieve personnel should exercise great discretion and sensitivity in the way that we interact with each other, bearing in mind that some of us may be adults at risk for particular reasons. We should refrain from making physical contact with each other if it might reasonably be deemed unprofessional, offensive or inappropriate to others.

Those under the age of 18 years’ old may not enter the Reprieve office unless they are supervised by an adult at all times, preferably a parent or guardian. The Head of Operations must be notified in writing in advance of a child entering the office, so that any necessary safeguarding measures can be put in place. For instance, it may be necessary for Reprieve personnel to remove casework related media or documents from sight in the event that these contain disturbing content.

Provision of counselling support in connection with work

Reprieve recognises that the work it carries out can exact a heavy psychological toll on staff. The impact of such work on individual staff needs to be carefully assessed at all points throughout the working relationship. Unfortunately, advocating on behalf of the victims of extreme human rights abuses necessarily means that staff will, at times, experience secondary trauma from their work. Reprieve will make available counselling services to assist all staff to effectively manage any trauma they experience as a result of their work. Staff are strongly encouraged to notify their line manager or the Head of Operations / a member of the Senior Management Team in the event of any safeguarding incident, mental health issues, or trauma, to enable Reprieve to take steps to support individuals in their work.

Work-related travel

All travel inherently carries risk of harm. Reprieve has separate comprehensive trip planning guidance which covers risk assessments, personal protection plans and security measures. You must ensure that you follow Reprieve’s trip planning procedure and the travel safety and security procedure on work related trips.

3.        Culture of Safeguarding

Reprieve is a human rights charitable organisation and therefore respect for the human rights of others is of paramount concern to us. Our culture places great value on diversity, differing opinions, transparency, and the worth of each individual irrespective of their place in the organisation.

There is an organisational hierarchy at Reprieve, which confers certain responsibilities on staff. Staff must be mindful that there may be concerns, some confidential, that have bearing on these plans and certain organisational decisions, and one of those concerns is safeguarding. For example, it might be that a staff member is not sent on a particular work trip on account of mental health issues, but that the reason for this decision is not provided to their team because their mental health is sensitive personal information.

1. Contact with children

Reprieve personnel, in the course of their work, often come into contact with children and young people in a variety of fora, including prisons, visits to clients’ families, trips to communities affected by drone strikes, career fairs, and university speaking engagements. Reprieve personnel should take measures, to the extent that this is possible, to ensure that they are not alone with a child, and that the child has their parent or guardian present. Staff may sometimes observe directly, infer from statements made or hear information that raises concerns about a child’s welfare. In such a case, staff should raise these concerns at the earliest opportunity in line with the reporting section set out below.

• Contact with adults at risk and clients

Reprieve staff should be mindful of the power dynamics and experiences of the clients with whom they are interacting. Our clients may have become vulnerable and/or be at risk due to their genetics, biology, nature, nurture and the context in which they find themselves. While not all Reprieve clients will fall within the legal definition of an ‘adult at risk’ in England and Wales, it is highly likely that a number of them will and that all of our clients are particularly vulnerable due to their circumstances.

Reprieve is supported in its work by a clinical psychologist who is available to assist with carrying out safeguarding risk assessments in connection with specific cases. Due to the nature of our work, clients are highly likely to be at risk of harm due to circumstances outside of Reprieve’s control. However, we still have a responsibility to ensure that we create safe culture in how we work with our clients and their family members. We should also ensure that we know how and when to raise concerns about ongoing safeguarding concerns.

Staff will be provided with regular training and guidance on safeguarding generally and in relation to working with people who have become vulnerable because of their circumstances.

Client interaction – best practice

In working with clients, Reprieve caseworkers and staff seek in all circumstances to:

• Ensure that communication with clients and family members is professional, transparent and open;
• Put in place, and keep to, clear boundaries in communications with clients and family members;
• Set clear and realistic expectations of the level of support that can be provided;

• Take steps to ensure that in-person contact with an adult at risk or child is not in a one-to-one environment;
• Keep written records of all interactions with clients and family members;
• Support clients in establishing and maintaining other supportive relationships with family and friends;
• Ensure clear handover and intentional communication if a client or family member point of contact is changing to a new staff member; and
• Raise safeguarding concerns internally at an early stage.

• The media

Images of children and adults at risk in the public domain can put these individuals at risk of further harm. Therefore, Reprieve will obtain informed consent in writing for the use of an image of a child or of an adult at risk where they are identifiable. All attributable quotations or case studies will also require authorisation in writing in advance. In the event that a person does not have the capacity to give informed consent, or where direct contact with the individual is not possible; an individual with authority to act (i.e. parent, next of kin, individual with power of attorney) should provide this.

• Online safeguarding

We recognise that operating online carries specific safeguarding risks and we need to take steps to protect people from abuse and protect sensitive information.

Reprieve has a public facing website as well as official X, Facebook, LinkedIn and Instagram accounts which are used to further our casework and raise funds. All content posted goes through a stringent approval process and we ensure that we consider any safeguarding and data protection considerations during this process. Trigger warnings on sensitive content are considered as part of the sign off process and included where appropriate. We may contact professionals (i.e. journalists) via direct messaging but we do not engage with clients or supporters via direct messages and will ensure guidance is in place if we do intend to use this functionality in the future.

Our social media policy sets out clear expectations for all individuals connected with Reprieve on their personal social media use.

4.        Clear Roles and Responsibilities

Safeguarding is everyone’s responsibility. All Reprieve personnel who, during the course of their employment or engagement with Reprieve have direct or indirect contact with children or adults at risk, or who have access to information about them, have a responsibility to safeguard and promote their welfare.

Trustee Responsibilities

1. Trustees are responsible for ensuring that those who come into contact with Reprieve are not harmed in any way through contact with it.

• The Trustees will ensure that:
  • All Reprieve personnel have access to, are familiar with and know their responsibilities as set out in this policy;
  • Safeguarding procedures are implemented when recruiting and contracting Reprieve personnel;
  • Staff receive regular training on safeguarding;
  • Reports of safeguarding concerns are followed up promptly and in accordance with best practice;
  • An annual audit of safeguarding concerns raised takes place;
  • A lead trustee for safeguarding is designated; and

• This policy is reviewed annually as per Charity Commission guidance.

Senior Leadership Responsibilities

• The Deputy Director, Legal & Governance is accountable to Trustees for safeguarding within the organisation and will ensure a clear framework for the management of and accountability for safeguarding is in operation.

• The Deputy Director, Legal & Governance will stay abreast of developments on safeguarding best practice, advise on changes to policy and practice and coordinate Safeguarding reporting.

• The Deputy Director, Legal and Governance, shall ensure that timely, accurate external reports are made as set out in this policy.

• A Joint Executive Director must communicate any breaches of safeguarding directly to the Trustees.

Reprieve Personnel Responsibilities

• Reprieve personnel must not, under any circumstances:

• Engage in sexual activity with a child, client of Reprieve or adult at risk;
• Sexually abuse or exploit a child, client or Reprieve or adult at risk;
• Subject a child, client of Reprieve or adult at risk to physical, emotional or psychological abuse or neglect;
• Exchange money, employment, goods or services for sexual activity.

• Reprieve personnel must:
• Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of this policy;
• Report any concerns or suspicions regarding safeguarding.

Reprieve Partners, Fellows and Consultants

Reprieve’s Partners have a duty, under the terms of our Partnership Agreement, to notify Reprieve of any safeguarding incident or allegation. It is therefore important to ensure that we do have a Partnership Agreement in place with all Partners who we work closely with and that we ensure they have an appropriate safeguarding policy in place.

Reprieve works closely with a number of fellows and consultants to whom this policy applies when working with Reprieve,

Reprieve will work in partnership with its partners, fellows and consultants to ensure the principles and objectives of this policy are respected in their work with Reprieve, and that safeguarding concerns are communicated and acted on appropriately.

Reporting

• Raising awareness of child and adult protection situations

If anyone become aware that any individual is at imminent risk of serious harm, they should contact the Police to report this where this is appropriate. Please refer to the Charity Commission guidance on this available here. Where the risk of harm is not imminent, we would expect you to raise these concerns internally so that we can advise on the most appropriate cause of action.

If anyone becomes aware that a Reprieve client who is a British national abroad, is at imminent risk of serious harm, this should be reported to the FCDO Global Response Centre on: +44 (0)207 008 1500 which has an urgent out of hours service. Where possible, the relevant manager should notify the Joint Executive Directors, the Director of Casework and the Deputy Director for Legal & Governance prior to notifying the Global Response Centre.If anyone becomes aware that there is a risk of harm to a Reprieve client or family member but not directly connected to our work, this should still be reported in accordance with this policy.Reprieve may take advice on a case-by-case basis to carry out a risk assessment and agree any specific guidance for the casework team. Reprieve may also take advice from any local safeguarding experts on any external reporting requirements.

If anyone becomes aware that there is an allegation or incident of harm to a client or family member connected with our work this must be reported as a breach of this safeguarding policy as soon as reasonably practicable (within 24 hours of becoming aware of the allegation or incident).

Where there is an allegation or incident of harm connected with any Reprieve personnel or any other breach of this policy this must be reported as soon as reasonably practicable (within 24 hours of becoming aware of the allegation or incident).

In the first instance, reports should be raised with any one of the following:

• The individual’s line manager or point of contact;
• The Deputy Director of Legal and Governance; or
• The Joint Executive Directors.

While we would always encourage individuals to speak with their line manager in the first instance the most important thing is that safeguarding concerns are reported without delay and any of the individuals above can be notified.

Where a line manager or point of contact has been notified of a safeguarding incident they should discuss the appropriate response with the Deputy Director of Legal and Governance prior to taking action.

If an allegation or incident relates to a member of the Senior Management Team it may be raised through the whistleblowing channels to the nominated Trustee point of contact (Dame Elish Angiolini, Reprieve’s chairperson).

For the avoidance of any doubt, no Reprieve personnel will suffer any negative treatment for raising a safeguarding concern.

6.        External reporting to the Charity Commission, Local Authorities and law enforcement where appropriate

The Deputy Director of Legal and Governance shall ensure that:

• Any safeguarding allegation or incident connected with Reprieve’s work is reported to the Charity Commission as a serious incident, where applicable, in line with Charity Commission guidance.

• Where an allegation or incident amounts to a criminal offence the default position is that it is reported to the necessary law enforcement, unless there is a legitimate reason not to report such as where it is clear that to do so would put the individual at further risk of harm.

• Referrals are made to the relevant local authority/social services body where there is concern that a child or adult at risk within the UK is suffering significant harm or is likely to do so.

• Legal advice is taken in the countries in which we are working, to ensure appropriate external referrals are made.

• Safeguarding incidents connected with external donors are notified to the donors in line with the terms of our agreement with them.

Response

• Investigating Fully

1. Any allegation of a breach of this Safeguarding Policy shall be taken extremely seriously and will be investigated fully in line with best practice guidance.

• Where appropriate, Reprieve shall appoint independent experts to carry out an investigation into a safeguarding allegation connected with Reprieve.

Raising concerns with Reprieve

• External concerns

If any third party (including clients of Reprieve or those connected with our clients) has any concerns about safeguarding issues relating to Reprieve, they should:

• In an emergency, contact the relevant emergency services first; and

• Share it with their immediate contact at Reprieve or by emailing us on [email protected].

Any allegation of a breach of this Safeguarding Policy will be taken extremely seriously.