Safeguarding Policy

The purpose of this policy and associated procedures is to provide clarity to all staff on how they should engage with children, young people and vulnerable adults when working for, on behalf of, or in partnership with SmartDaddy LLP of Noorayinganakath, 25/9 8, Firdous Manzilpunnathiruthi, Thrikkavu, Ponnani Malappuram, Kerala, India -679577.

As a Parental Control platform that permits minors to use the services, it is also to help us make sure that employees, and other representatives are protected. And, intended to help us to have a common understanding of safeguarding issues, develop good practice across the diverse and complex areas in which we operate and thereby increase accountability in this crucial aspect of our work.

Any breach of this policy will be treated as a disciplinary matter, which may result in immediate termination of employment or contract, withdrawal of volunteer status, and reporting to the police, relevant regulatory authority or other body.

Abuse – a violation of an individual’s human and civil rights by any other person or persons. It can take the form of physical, psychological, financial or sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the health, survival, development or dignity of a child, young person or vulnerable adult. Abuse can be a single act or repeated acts and can be unintentional or deliberate. Abuse often involves criminal acts.

Discriminatory abuse – abuse motivated by a vulnerable person’s age, race, nationality, sex, sexual orientation, disability, or other personal characteristic.

Financial or material abuse – including theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.

Neglect – the persistent failure to meet a vulnerable person’s basic physical and/or psychological needs, likely to result in the serious impairment of his/her health or development. Examples include failure to provide adequate food, clothing and shelter, failure to protect them from physical or psychological harm or danger; failure to ensure adequate supervision; or failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a vulnerable person’s basic emotional needs.

Physical abuse – includes hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm, misuse of medication, restraint, or inappropriate sanctions.

Psychological abuse – includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks. Examples include not giving a vulnerable person opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on a vulnerable person, which may include interactions that are beyond a vulnerable person’s developmental capability. It may involve serious bullying (including cyber bullying), or the exploitation or corruption of a vulnerable person.

Sexual abuse – involves forcing, enticing or coercing someone to take part in sexual activities, whether or not the vulnerable person is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may also include non-contact activities, such as involving a vulnerable person in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse can be carried out by adults or other children.

Vulnerable adult – a person, 18 years and above, who by reason of disability, age, gender, social and economic status, or illness, the context they are in, may be unable to take care of or to protect him or herself against abuse, harm, or exploitation. Youth or young people – individuals aged 15 to 25 (15 to 35 in some countries) – SmartDaddy recognises that this group spans the categories of ‘children and ‘adults’ but regards young people as having particular safeguarding needs and requiring distinct consideration aside from younger children and older adults.

This policy is mandatory for all SmartDaddy employees. For the purposes of this policy, ‘employee’ is defined as anyone who works for or on behalf of SmartDaddy, either in a paid or unpaid capacity. This therefore includes directly employed staff, contractors, employees of sub-contractors, agency workers, consultants, interns and all visitors.

It also covers implementing partners whom we fund, and who we expect to work under the policy as a condition of their involvement with SmartDaddy.

This policy demonstrates how SmartDaddy will meet its legal obligations and reassure, employees, partners and members of the public:

• On what they can expect SmartDaddy to do to protect and safeguard vulnerable people.
• That they are able to safely voice any concerns through an established procedure.
• That all reports of abuse or potential abuse are dealt with in a serious and effective manner.
• That there is an efficient recording and monitoring system in place.
• That employee, subcontracted agencies and partners receive appropriate induction on safeguarding.
• That a robust ‘safe’ recruitment procedure is in place.
• There are additional procedures in place that apply to those that work or have contact with, either directly or indirectly, children, young people, or vulnerable adults or who live in communities alongside them.

SmartDaddy has zero tolerance against abuse and exploitation of vulnerable people. SmartDaddy also recognises that safeguarding is everyone’s responsibility and that it has an obligation to put in place reasonable measures to ensure, as far as possible, the safety and wellbeing of vulnerable people with whom we work and those in the communities in which we live. SmartDaddy works to the following key principles to protect vulnerable people:

• Everyone has an equal right to protection from abuse and exploitation regardless of age, race, sex, sexual orientation, marriage and civil partnership, pregnancy or having a child, gender reassignment, language, religion, political or other opinion, national, ethnic, or social origin, property, disability, birth or other status.
• The best interests of the vulnerable person are paramount and shall be the primary consideration in our decision making.
• SmartDaddy will take responsibility to meet our obligations regarding our duty of care towards vulnerable people, and take action where we believe that a child, young person or vulnerable adult is at risk or is actually harmed.
• SmartDaddy will ensure that employees are inducted in our Safeguarding Standards and procedures as a key part of the recruitment and on boarding process.
• SmartDaddy will ensure that all partners are informed and in compliance with our Safeguarding Standards.
• When working with or through partners or subcontractors, SmartDaddy will ensure that their safeguarding procedures are consistent and in line with the principles and approaches set out in this policy.
• SmartDaddy recognises that an element of risk exists, and while we may never be able to totally remove this, we need to do all we can to reduce it or limit its impact.
• SmartDaddy respects confidentiality and has a responsibility to protect sensitive personal data. Information should only be shared and handled on a need-to-know basis, that is, access to the information must be necessary for the conduct of one’s official duties. Only individuals who have legitimate reasons to access the information are allowed to receive it.

SmartDaddy seeks always to work in ways which are culturally sensitive and that respect the diverse nature of the people we work with. We recognise that there are many different ways of thinking and taking care of vulnerable people and making sure they are protected. It is acknowledged that protecting these groups of individuals and being culturally sensitive can be a difficult balancing act, especially given the situation in many of the countries where we work. As an international organisation, we endorse the United Nations Convention on the Rights of the Child general principle, that all the rights guaranteed by it must be available to all children without discrimination; and article 19 which accords equal rights to protection for children from abuse. Every child matters everywhere in the world.

All employees, consultants, agency staff, sub-contractors, partner organisations and visitors are obliged to follow this policy and maintain an environment that prevents exploitation and abuse, and which encourages reporting of breaches of this policy using the appropriate procedures.

All people working with SmartDaddy will:

• Read, understand, and adhere to this Policy
• Strive to promote a zero-tolerance approach to discrimination, sexual harassment and abuse in all working environments
• Strive to develop relationships with all stakeholders which are based on equality, trust, respect, and honesty
• Place the safety and welfare of children and vulnerable people above all other considerations
• Report any concerns they may have about the welfare of a child or vulnerable person
• Report any concerns they may have about the behaviour of a SmartDaddy representative in relation to safeguarding.
• In a one-to-one situation with a child or young person, where privacy and confidentiality are important, try to make sure that another adult knows the contact is taking place and why. If possible, ensure another adult is in sight and that the child or young person knows another adult is around.

All people working with SmartDaddy will not:

• Sexually harass, assault, or abuse another person
• Physically harass, assault, or abuse another person
• Emotionally abuse another person, such as engaging in behaviour intended to shame, humiliate,
• belittle or degrade
• Condone, or participate in behaviour, which is abusive, discriminatory, illegal, or unsafe
• Develop, encourage, or fail to take action of relationships with children or other vulnerable people which
• could in any way be deemed sexual, exploitative, or abusive
• Act in ways that may be violent, inappropriate, or sexually provocative
• Agree with a child to keep a secret which has implications for their safety or the safety of other young people.

Managers at all levels are responsible for ensuring employees, consultants, and partner organisations are aware of the policy and are supported to implement and work in accordance with it, as well as creating a management culture that encourages a focus on safeguarding. They must ensure that they are responsive, acting immediately if they become aware of any safeguarding concerns, and supportive towards employees who complain about breaches in this policy.

Advice, support, and training on safeguarding will be provided to all employees on:

• What they should do in the event of a disclosure
• What to do if they have concerns about the welfare of a child
• How to recognise signs of abuse
• What to do if they have concerns about a SmartDaddy employee, volunteer, or employee of a partner organisation
• Where to go for advice and support within the organisation

SmartDaddy Designated safeguarding officers are responsible for handling reports or concerns, about the protection of vulnerable people, appropriately and in accordance with the procedures that underpin this policy.

The SmartDaddy Executive Board is responsible for ensuring the effective implementation of this policy and associated procedures and ensuring that everyone linked with SmartDaddy is equipped and supported to meet their responsibilities.

Safe recruitment and vetting processes are followed for all, employees, consultants, and partners. Where an employee, volunteer or partner is engaged in ‘regulated activity’ (direct work with vulnerable individuals), a criminal background check will be undertaken as part of the recruitment process. All SmartDaddy employees must sign and abide by this safeguarding policy and the Code of Conduct.

Ensure that clear processes for reporting and dealing with safeguarding concerns and incidents are widely communicated, regularly reviewed, and consistently applied. Where allegations are made about an employee, careful consideration must take place about the appropriateness of the person continuing to work with SmartDaddy.

SmartDaddy places a mandatory obligation on all employees, contractors, and partners to report concerns, suspicions, allegations and incidents which indicate actual or potential abuse or exploitation vulnerable people, or which suggests this policy may have in any other way been breached. It is not the responsibility of the employees to decide whether or not abuse has taken place, however, concerns should be raised with an individual’s line manager, functional lead or a designated safeguarding officer who will initiate the procedure for dealing with suspected or actual incidents of abuse.

Designated Safeguarding Officers are responsible for ensuring that the reporting procedure is followed so that suspected or actual cases of abuse are responded to appropriately and consistently and referred to the relevant statutory authority. To ensure that all such situations are handled appropriately and effectively:

• Reports must be made, and decisions and actions taken.
• SmartDaddy is not an investigative authority. It is essential that referrals are made to the relevant law enforcement agency to ensure that appropriate protection and support is given to the vulnerable individual, and that any evidence is collected in accordance with the law.
• All sensitive and personal data must be kept confidential (including the names of anyone who makes a report of abuse) and be shared on a strictly ‘need to know basis’, that is, access must be necessary for the conduct of one’s official duties.
• Where a SmartDaddy employee is the subject of an investigation, the lead designated safeguarding officer will lead the case.

SmartDaddy takes recruiting the right people very serious and we make sure our staff are suitable to work with children and young people. For us it is a vital part of creating a safe and positive environment and we are commitment to keep children safe from harm. We also ensure that all appropriate checks are carried out on all staff who work with us and monitor accordingly.

Should you have any further questions about this Child Protection and Safeguarding Policy, please speak to a member of our Team.

The Company Secretary will SmartDaddy the effectiveness and review the implementation of this policy, considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to audit reviews to provide assurance that they are effective.

All workers are responsible for the success of this policy and should ensure they use it and the Whistleblowing Policy to disclose any suspected wrongdoing.

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries should be addressed to the Company Secretary or any Senior Manager.

This policy does not form part of any employee’s contract of employment, and it may be amended at any time.