Comic Relief’s Safeguarding Framework

Introduction

The safety and well-being of everyone connected with our work is of paramount importance to us. As a funder and internationally recognised brand, we must always be aware of the power imbalance that this can create and the potential for this to result in abuse and exploitation. This framework is divided into in five standards and sets out the measures that we consider essential to ensuring a safe environment for all those engaged in Comic Relief’s work.

Safeguarding Values

We aim to conduct our work in an ethical and respectful manner that is underpinned by our safeguarding values:

  • Prevent: we aim to prevent harm through professional, responsible conduct. We take a robust approach to dealing with any breaches.
  • Protect: we take a zero-tolerance approach to harm, abuse or exploitation of any kind. All of our decisions and actions prioritise the safety and well-being of those connected with our work.
  • Personify: we assume individual and organisational responsibility for safeguarding and provide staff with training and guidance to fulfil their obligations. 
  • Partner: we maintain best practice through open, transparent dialogue with others, including the communities we serve. By listening to others, we ensure our conduct is appropriate to each context and the unique needs of those we are working with.

Scope

All representatives of Comic Relief must read, understand and comply with the measures outlined in this Framework. This includes:

  • All staff employed by Comic Relief, whether permanently or on a freelance contract
  • All trustees and committee members
  • All volunteers and interns
  • All visitors to Comic Relief projects and operations
  • All agencies or organisations employed to deliver services on behalf of Comic Relief 

Grantee Partners are not expected to comply with Comic Relief’s Safeguarding Framework but must have their own safeguarding policies and procedures in place which reflect the unique nature of their organisation and the work they are undertaking.

The safeguards contained in this document apply equally to all individuals engaged with Comic Relief, irrespective of age, gender, race, ethnicity, religion, political opinions, sexual orientation or disability. Additional safeguards are included to ensure adequate protection for particularly vulnerable groups such as children and adults at risk.

Approval and Review

The Safeguarding Framework was approved by Comic Relief’s Board of Trustees in September 2018. The framework will be reviewed annually, and any revisions submitted to the Board of Trustees for approval. 

The supplementary guidance referenced in the Framework will be updated more regularly to reflect any changes in our work and to incorporate learning from lived practice. The supplementary guidance will be reviewed and approved by the Head of Assurance on an on-going basis.

Standard 1: Accountability

1.1 Trustees are provided with regular reports on safeguarding, including reporting of serious safeguarding incidents

Safeguarding is integral to the leadership and governance of Comic Relief. Our Board of Trustees have a duty to ensure Comic Relief takes all reasonable steps to prevent and protect beneficiaries, employees and others from harm. They must also be satisfied that our grantee partners have adequate measures in place to safeguard children and adults in the communities they serve. If something goes wrong, the Trustees are accountable for ensuring that all possible action is taken to put things right.

To enable our Board of Trustees to fulfil this function, a Safeguarding Dashboard will be produced on a monthly basis and this will be included in Trustee papers for discussion at their bi-monthly meetings. The Dashboard will contain an overview of all safeguarding cases, key areas of risk as well as an update of implementation of the safeguarding action plan.

In addition, Comic Relief will identify a Designated Trustee for Safeguarding who will: 

  • Meet with the Head of Safeguarding bi-monthly to maintain an overview of all safeguarding measures across Comic Relief 
  • Be informed of and contribute to decisions on high risk cases and maintain oversight of any follow up to help ensure that all risks are appropriately managed
  • In conjunction with the Chief Executive Officer (CEO) and Designated Executive Director for Safeguarding, ensure that Trustees are fully informed of safeguarding issues across the organisations and contribute to maintaining safe practice across all our operations

1.2 Senior leadership actively contribute to a positive safeguarding culture, including ensuring specific designated responsibilities for safeguarding at Executive Director level 

The leadership of any organisation is essential to ensuring that there is a positive culture of safeguarding within day-to-day operations. Led by the CEO, the Senior Leadership team will actively promote an awareness and commitment to safeguarding and role model best practice within their own areas of operation.

In addition, Comic Relief will identify a Designated Executive Director for Safeguarding who will have more direct oversight of safeguarding issues and the implementation of the Safeguarding Action Plan. The Designated Executive Director for Safeguarding will: 

  • Meet with the Head of Safeguarding monthly to maintain an overview of the active cases as well as measures to embed safeguarding across all Comic Relief operations
  • Be informed immediately of any high-risk cases and contribute to decisions making and ensure appropriate follow up to manage and reduce risk 
  • nsure that safeguarding is considered by the Executive Team and that they are fully informed of safeguarding issues across the organisations

1.3 Comic Relief will ensure that all those working on our behalf have access to technical expertise and advice from a dedicated Safeguarding Team

Comic Relief will employ a dedicated safeguarding team to help ensure that safeguarding issues are managed effectively and that proactive measures are in place to prevent harm across all areas of operation. The Safeguarding Team will:

  • Provide advice and support on safeguarding issues to staff and others connected with our work
  • Develop guidance and deliver training to increase the level of understanding and expertise on safeguarding across all teams
  • Manage any safeguarding concerns that arise and ensure that learning from safeguarding issue informs organisational practice
  • Proactively engage with other agencies and external experts to ensure that Comic Relief’s approach is informed by and contributes to best practice within the sector

1.4 Safeguarding Champions are in place across the organisation to support the awareness and mainstreaming of safeguarding across all operations

Comic Relief is a unique and diverse organisation. Each area of operation will manage very specific safeguarding risks. To ensure that our safeguarding measures respond to the specific needs of each team, Safeguarding Champions will be identified across the organisation to:

  • Act as advocates for safeguarding and increase awareness of safeguarding measures within their specific areas of operation 
  • Help disseminate guidance, procedures and signpost teams to relevant resources 
  • Advocate for the needs of their teams to ensure that relevant guidance and support is provided by the Safeguarding Team
  • Help ensure that safeguarding issues are escalated to Safeguarding team in a timely manner
  • Develop and co-deliver trainings to meet the safeguarding needs of their teams
  • Act as a point of advice and support on safeguarding issues within their teams
  • Contribute to safeguarding self-assessments and workplans

The Safeguarding Champions will meet with the Safeguarding Team individually on a monthly basis as well as attending the Champions Working Group meetings on a quarterly basis where safeguarding priorities at an organisational level will be reviewed.

1.5 Clear procedures exist for reporting and escalating safeguarding concerns and these are widely understood across the organisation

safeguarding process

 

Safeguarding concerns can arise in any part of the organisation. Concerns include, but are not restricted, to:

  • Concerns about the safety and welfare of beneficiaries of Comic Relief grants
  • Concerns about the safety and welfare of participants in Comic Relief 

images (films and photography), events or fundraising activities

  • Concerns about the safety and welfare of community members who we meet during project visits or other activities 
  • General concerns that our work may be exposing others to risk of harm
  • Concerns about conduct in the workplace 
  • Concerns about conduct outside the workplace that may indicate some kind of abusive or exploitative behaviour

It is important that concerns are escalated to the Safeguarding Team as quickly as possible – this can be done face-to-face, via e-mail or over the telephone. No forms need to be completed as the safeguarding team will then ensure that all discussions and actions are documented on a Safeguarding Concern Form. 

If you are unable or unwilling to discuss the concern with the Safeguarding Team, you can:

  • Speak to your line manager 
  • Speak to one of Comic Relief’s Safeguarding Champions
  • Make a report via the Designated Contact e-mail: designatedcontact@comicrelief.com
  • Contact Safe Call - 0800 915 1571 - who provide an independent reporting line for staff to raise concerns.  

Failure to report safeguarding concerns will be considered a serious breach of Comic Relief’s safeguarding procedures and may result in disciplinary action

1.6 The implementation of safeguarding measures will be assessed through an annual self-assessment which will inform an annual review of Comic Relief’s safeguarding framework. An external review will be commissioned every 3 years

It is important that our safeguarding measures are constantly reviewed and updated so that they respond to changes within our work and reflect learning from lived practice. 

The guidance and procedures referred to in this policy will be updated regularly to ensure that any gaps and weaknesses are addressed without delay. 

The over-arching Safeguarding Framework will be reviewed annually and will be informed by an annual Self-Assessment. The self-assessment will be participatory, allowing staff from across the organisation to contribute their ideas and experiences so that we can build on areas where we are performing well and proactively address any gaps or weaknesses in lived practice.  The results of the self-assessment, the safeguarding action plan and the revised policy will be shared with the Board of Trustees for their approval. 

Every 3 years, Comic Relief will commission an external review of our safeguarding measures to ensure external scrutiny of our work and ensure that we benefit from expertise and insights from outside the organisation.

Standard 2: Safe People

2.1 Information on safeguarding is integrated throughout the recruitment cycle

Building a culture of safeguarding depends on our ability to instil a commitment to safeguarding amongst all those who join the organisation. This process begins at recruitment.

We will demonstrate our commitment to safeguarding by:

  • Ensuring all Recruiting Managers have received training on safer recruitment
  • Including a statement about our commitment to safeguarding in all job adverts
  • Including specific safeguarding questions in interviews for roles which have direct contact with children and adults in communities
  • Completing appropriate background checks on all staff and consultants
  • Ensuring all new starters read and sign their commitment to the Safeguarding Framework and Code of Conduct on their day of arrival
  • Incorporating compliance with safeguarding and the Code of Conduct in all employment contracts

2.2 Background checks, including references and DBS checks are conducted on all staff, trustees and others employed by Comic Relief

It is important to ensure the suitability of all staff and consultants and ensure that they do not represent a risk to the children and adults in communities we work with. Two references will be obtained before confirming any offer of employment and these will include specific questions about suitability to work with children and adults in communities where this is relevant to the role.

A DBS check will be completed for all staff and consultants. The level of check required will be determined by the People and Culture team based on an assessment of the level of risk associated with the post. 

2.3 All staff, trustees & other representatives of the organisation must comply with Comic Relief’s Code of Conduct

The Comic Relief Code of Conduct forms critical part of our overall approach to safeguarding. It sets out our expectations of the way we treat each other as well as the way we treat the children and adults in communities we may come in to contact with.

On joining the organisations, all staff and representatives must read and sign that they comply with the Code of Conduct. Signed copies of the Code of Conduct are retained on personnel files.

The importance of the Code of Conduct is further underlined through:

  • Explaining the Code of Conduct within Safeguarding Inductions
  • Inclusion of guidance on conduct in Briefing Packs issued prior to project visits
  • Inclusion of guidance on conduct in verbal briefings prior to interactions with children and adults in communities
  • Including compliance with the Code of Conduct in employment contracts
  • Obtaining signed copies of Visitor’s Agreements from Talent and Corporate Partners which include adapted versions of the staff Code of Conduct 

2.4 Safeguarding is a compulsory part of the induction process for new starters

It is important that all new starters receive an induction to safeguarding within a month of joining the organisation. It is the responsibility of the recruiting manager to ensure new starters attend this training, but attendance will also be monitored by the People and Culture Team.

The Safeguarding Induction is only meant as an introduction to safeguarding. It provides an overview of our different standards to ensure that people are aware their responsibilities and how safeguarding relates to their role. The induction will also direct people to more detail guidance and provide advice on how to access support from the Safeguarding Team.

To ensure robust safeguarding, the induction will be complemented by role specific training that is developed and delivered with Safeguarding Champions on an on-going basis.

2.5 All staff to receive safeguarding training tailored to their individual roles and responsibilities, with specialist training provided to staff with designated responsibilities for safeguarding

The safeguarding needs of each team will be varied and unique. To accommodate these different needs, there will be a rolling programme of training that is developed and delivered by the Safeguarding Team in conjunction with the Safeguarding Champions. The active involvement of Safeguarding Champions is critical as enables them to build their knowledge and skills through working closely with the Safeguarding Team.

The specialist training needs of the Safeguarding Team will be determined on an individual basis through line management supervision and appraisal. As a minimum, all staff with designated safeguarding responsibility (including Trustee and Executive Director level) will attend safeguarding training provided by the local Safeguarding Board within Lambeth. A budget for additional training will be incorporated into the annual safeguarding budget.

2.6 Comprehensive procedures exist to prevent sexual exploitation and abuse, including harassment in the workplace

Although Comic Relief does not directly deliver interventions to children and adults in communities around the world, we must always be alert to the risk of from sexual exploitation and abuse, including the risk of exploitation and abuse within the workplace. Comic Relief will develop and enforce comprehensive measures to prevent sexual exploitation and abuse and to ensure that any concerns receive a robust response.

These include:

  • Comprehensive policies which include our Code of Conduct, Reporting Concerns Policy, Harassment & Bullying Policy and Safer Recruitment Policy. 
  • Ensuring all staff are aware of and feel confident to use the Reporting Concerns mechanisms and can access external support through Safe Call
  • Ensuring the public can notify us of concerns through use the Reporting Concerns mechanism advertised on our website
  • Assigning responsibility for responding to and investigating concerns to Designated Contacts (Head of Assurance, Head of People and Culture, Legal Counsel) who have authority to make independent representations to Trustees as appropriate  
  • Ensure that all concerns are investigated promptly, and appropriate action taken, with oversight from the Board of Trustees

Standard 3: Safe Investments

3.1 Safeguarding is integrated throughout the grant assessment process and assessors are trained to assess safeguarding.

Comic Relief is committed to investing in ‘safe organisations’. This means that we take all appropriate steps to ensure that organisations we fund have adequate measures in place to prevent harm and to respond effectively if safeguarding issues do arise.

We will ensure this by:

  • Providing assessors with training on assessing safeguarding within the application process
  • Asking specific questions relating to safeguarding and risk management at application stage
  • Reviewing safeguarding policies for all shortlisted applications
  • Exploring safeguarding in more detail during assessment interviews
  • Placing conditions on grants where we feel that improvements are required
  • Allowing applicants to include a budget line for safeguarding within their applications

3.2 Safeguarding practice is actively monitored through the grant life cycle

Once a grant has been approved, all organisations must sign Comic Relief’s Conditions of Grant which includes specific requirements in relation to safeguarding. Comic Relief will monitor compliance through: 

  • Including a specific question on safeguarding in 6 monthly and annual reports
  • Including safeguarding within Monitoring visits
  • Ensuring all safeguarding issues are escalated immediately to the Safeguarding Team
  • Where specific safeguarding concerns have arisen, the Investment Partner may request that a member of the Safeguarding Team accompany them on a monitoring visit
  • Where specific safeguarding concerns have arisen, the Safeguarding Team can provide on-going support and guidance to the Grant Partner

3.3 Grantees are required to report serious safeguarding incidents and Comic Relief takes appropriate action to ensure all projects have adequate safeguards in place

As part of their Conditions of Grant, our Grant Partners are required to notify Comic Relief of any safeguarding incident. This includes reporting:

  • Allegations of harm, abuse or misconduct which have resulted in an internal investigation and/or referral to a relevant authority such as social services, the police or regulatory body 
  • Any serious breach or failure in safeguarding procedures or policies which may have put beneficiaries at risk and/or have resulted in a referral to any regulatory body or relevant authority such as social services or the police
  • For Grantees working through implementing partners, the above applies to incidents relating to your partners, their staff and representatives and includes referrals to authorities in the country of operation as well as in the UK
  • Historic cases should normally have been disclosed at the time of application. However, if historic information comes to light after the grant has started and has not been disclosed to Comic Relief, this should also be reported 

Following a notification, the Safeguarding Team will normally request to speak to the Grant Partner to better understand the issues and their response. We may also ask for copies of relevant policies and procedures to gain re-assurance that appropriate safeguards are in place. If the relevant policies and procedures are not in place or we identify weaknesses, we will support Grant Partners to address any gaps.

We recognise that suspending or withdrawing funding can have a negative impact on beneficiaries but, where there is an on-going risk of harm we may suspend funding while this is addressed. If the Grant Partner is unable or unwilling to sufficiently address concerns, funding may be terminated. This decision will always be taken in conjunction with both the Designated Executive Director and Designated Trustee for Safeguarding.

3.4 Support is provided to grantees to ensure they understand their responsibilities and implement best practice in terms of safeguarding

Comic Relief works with a wide variety of Grant Partners who vary in size, focus and their level of expertise in relation to safeguarding. We recognise that effective safeguarding requires constant commitment, learning and resources. 

We will support our Grant Partners to implement effective safeguarding measures by:

  • Allowing them to include a budget line for safeguarding
  • Where we recognise there are gaps to be addressed, putting a condition on the grant and monitoring compliance with this condition
  • Providing access to the Safeguarding Team who will provide advice, review policies and, where appropriate, provide workshops to help strengthen safeguarding within organisations
  • Linking grantee organisations to other organisations with expertise of the local area context who can provide peer-to peer support

3.5 Additional processes are in place to ensure that devolved grant-makers have the correct safeguarding requirements of sub-grantees.

Within some initiatives, Comic Relief may issue a grant to an intermediary organisation who will be responsible for assessing, issuing and monitoring the grant. This approach is important as it allows us to extend our impact in wider geographical and thematic areas. 

In devolving our Grant Making authority, Comic Relief will:

  • Ensure the intermediary organisation has a robust safeguarding policy in place and that this is supported by adequate resources and expertise within their organisation 
  • Ensure that the intermediary’s approach to assessing and monitoring both risks and safeguarding in their Grant Partners is robust and in line with Comic Relief expectations
  • Ensure that clear safeguarding expectations are set out in the partnership agreement / contract with the intermediary organisation
  • Require the intermediary organisation to notify us any safeguarding concerns in their organisation or grant partner so that the response has oversight from Comic Relief’s Safeguarding Team
  • Adopt a partnership approach so that we support intermediary organisations by sharing our own safeguarding approach, any tools that we develop and also allowing them to access relevant training offered within Comic Relief. 

3.6 Clear procedures are in place for reporting safeguarding issues between co-funders

Comic Relief provides some grants in conjunction with other funding bodies. Where this happens, we will develop specific protocols to ensure that co-funders are aware of safeguarding issues that may arise and are kept informed of the response. Any decision to suspend or terminate funding will be taken in collaboration with the co-funding agency. 

Standard 4: Safe Story Telling

4.1 Comic Relief have clear filming and media guidelines that are strictly adhered to & this includes a rigorous approvals process of all assets before use

Comic Relief aims to take an ethical approach to the collections and use of all our images which follow the principles of: 

  • Safeguarding – the safety and well-being of contributors must always be a primary concern and images will not be used which place contributors at risk of harm, abuse or exploitation
  • Dignity – The collection and use of images must uphold the dignity of our contributors and Comic Relief will avoid using images that could degrade, victimise or shame the individual 
  • Accuracy – Images should provide a balanced and accurate depiction of our work and must not be manipulated, including taken out of the original context, or sensationalised in any way 
  • Privacy - Information shared alongside images should respect the contributor’s right to privacy and information will only be shared with the contributor’s informed consent 
  • Equality & Diversity - images should, as far as possible, show the diversity of Comic Relief’s work, featuring contributors of different ethnicities, gender, ages, abilities and backgrounds  

All images must be approved prior to use. This includes images taken by Comic Relief staff as well as those taken by Corporate Partners, Talent or others who are sharing images in collaboration with Comic Relief.

When approving images, Comic Relief will adhere to the following guidelines:

  • Contributors should not be shown in a state of undress. Limited exceptions may be made where the image is directly relevant to story-telling (e.g. coverage of swimming event, story about breast feeding
  • Images should not feature violent behaviour, use of weapons, drug use, gambling, smoking, drinking or other harmful behaviours
  • Images must not reinforce prejudicial perspectives or depict groups in stereotypical ways
  • Images must not sexualise children or young adults and we will not use images of children that could in any way be deemed sexually provocative 
  • Images should not include any identifiers which could be used to locate contributors (e.g. logos on school uniforms, street names or other signage, significant landmarks)

4.2 Safeguarding is integrated into the risk assessment, approval and planning of project visits (UK & overseas) where media assets are to be obtained

We believe that sharing people’s stories and experiences can drive positive change but this must not place contributors at risk of harm.

To help ensure contributors are not exposed to additional risk, we will: 

  • Ensure all staff have received safeguarding training as well as understood and signed a copy of Comic Relief’s Safeguarding Framework and Code of Conduct
  • Only film contributors from projects which have at least 12 months funding in place to ensure that on-going support is in place after filming 
  • Identify and review potential risks at different intervals in the process – when selecting the project, when casting contributors, prior to filming and prior to broadcast. We will draw on the expertise and local knowledge of project staff to inform our risk-based decision making
  • Fully explain the implications of filming for both the grant partner and individual contributors.to ensure genuinely informed and meaningful consent 
  • Keep project staff informed of our plans and explicitly ask the project to confirm whether there are any additional safeguarding measures they want us to follow

4.3 There is a designated lead for Safeguarding on every project visit who is trained & competent to address safeguarding issues

On every project visit, there will be a designated Safeguarding Lead whose name and contact details will be clearly indicated on the risk assessment and itinerary. The Safeguarding Lead may also be the Trip Leader, although on larger projects the two roles may be separated.

The safeguarding lead will be responsible for:

  • Contributing to the risk assessment to ensure that risks to contributors are identified and mitigated 
  • Ensure that all members of the team have read and understood the risk assessment and have signed Comic Relief’s Code of Conduct
  • Providing a briefing to the team so that everyone understands their roles and responsibilities in relation to safeguarding and know what to do if any concerns arise
  • Ensuring that project staff accompany the crew whenever they are engaging with contributors
  • Ensure that consent is adequately explained to contributors, including discussing any risks and explaining the right to withdraw 

4.4 Consent is obtained for all assets & meets GDPR requirements (informed consent, withdrawal of consent, secure storage & destruction)

Consent is not simply ensuring a form is signed. It is a process through which we provide clear information to contributors and confirm informed and voluntary consent at different points in the process. 

Consent must be obtained from all contributors prior to the collection of images. In addition, written consent must be provided by the parent or guardian for children under the age of 18. Where an adult has lacks the capacity to provide informed consent (e.g. due to age, illness or disability) consent must be obtained from a family member or, where one is unavailable, from a senior member of project staff who has responsibility for the contributor’s well-being. 

For consent to be informed consent we must explain:

  • Who we are and why we are collecting the images 
  • Who will benefit from use of the images 
  • How the images will be shared and who is likely to see them 
  • How we will protect the contributor’s privacy
  • Any potential risks (both current and future) arising from the use of images 
  • How long we will use the images (Comic Relief will only use images for 4 years before the materials are archived)
  • How to withdraw consent, ensuring that withdrawing consent is as easy as giving consent. 

This information must be presented in a way that is clear, intelligible and adapted for the intended audience. We must be able to demonstrate consent through obtaining a signed consent forms which must be stored with the images that have been collected.

If necessary and where possible, consent forms will be translated into local languages. If consent forms are interpreted verbally, attention must be paid to ensure accuracy and full understanding.

4.5 Clear Community Management Guidelines are in place for social media and digital channels, including the proactive moderation of content

Social media is a powerful mechanism for sharing our work and driving social change but online engagement does represent additional risks for contributors and must be carefully managed.  Comic Relief’s Community Managers are responsible for posting content and for monitoring the comments, photos, videos and links that are shared by our audience 

Comic Relief will:

  • Ensure Community Managers are suitable for the role, including completing enhanced DBS checks for individuals who are moderating online engagement aimed at children
  • Ensure that Community Managers have received training on online safeguarding and are clear on the procedures for responding to our audience and escalating concerns 
  • Ensure that Community Management guidelines are in place and include clear protocols so that community managers can access support and advice whenever issues arise

Any comments or posts which raise safety and serious well-being concerns must be escalated immediately to Safeguarding Team who will craft a response which includes signposting to appropriate support agencies.  This includes:

  • Any posts which suggests an individual is at risk of physical attack or a situation that is likely to result in physical injury
  • Any posts which suggest an individual is at risk of rape, sexual assault, sexual harassment or sexual exploitation
  • Any posts which indicate that the individual is a risk to themselves or others e.g. suicide
  • Any direct requests for help in relation to safety, well-being or in relation to physical, sexual or emotional abuse 

4.6 The relationship between Comic Relief and other creative agencies, including the BBC, clearly delineate responsibility for safeguarding on joint ventures

Comic Relief regularly collaborates with others to strengthen our story telling and safeguarding forms an integral part of the success of these collaborations.

The relationship with the BBC is central to the success of our campaigns and there must be clarity in regard to our joint safeguarding responsibilities. Comic Relief’s safeguarding procedures have been developed with explicit reference to the BBC guidelines to ensure that our approaches are cohesive and complimentary. 

When undertaking joint ventures with the BBC or other creative agencies, we will:

  • Agree who will assume the Designated Lead for Safeguarding 
  • Ensure the Designated Lead for Safeguarding understands Comic Relief procedures and is able to fulfil the responsibilities set out in standard 4.3
  • Ensure that the creative team has received a briefing from Comic Relief’s Safeguarding Team and is able to access the team for advice and support
  • Clarify responsibilities with any project they may be visiting to ensure that they are clear that Comic Relief safeguarding procedures and code of conduct apply

Standard 5: Safe Fundraising & Partnerships

5.1 Guidelines for engagement with schools & colleges are in place with clear agreements regarding safeguarding

Comic Relief regularly works with schools and colleges across the UK as part of our fundraising strategy. Although schools and colleges are required to have comprehensive safeguarding measures in place, Comic Relief must still take a robust approach to safeguarding which takes in to account the specific vulnerabilities and risks associated with working with children and young people.

Our safeguarding in relation to schools and colleges will include:

  • Ensuring that all fundraising plans are directed through an appropriate adult at the school and arranged directly with the children and young people
  • Completing the Safeguarding Checklist for Engagement with Schools and Colleges
  • Prior to any visit, sending a letter sent to school to clarify roles and responsibilities and ensuring a risk assessment is completed
  • Ensuring the school has obtained appropriate consent for all activities, including the collection of images
  • Where appropriate, completing a Fundraising Agreements with the school which incorporates the management of safeguarding concerns and consent

5.2 Safeguarding is integrated into corporate partnerships & included in all contracts

Comic Relief’s work is generously supported by a wide variety of Corporate Partners who help raise awareness of our work and actively support our fundraising. The diversity of businesses who support Comic Relief means that we must tailor our approach to the specific needs of our corporate partners but without compromising our commitment to safeguarding.

To ensure that safeguarding is a primary consideration in all our corporate partnerships, Comic Relief will:

  • Ensure that safeguarding is included as criteria to be explored in our due diligence and background checks before approving a new corporate partnership 
  • Discussing the importance of safeguarding at the outset of the relationship and ensuring that safeguarding clauses are incorporated in contracts with Corporate Partners
  • Where corporate partners directly engage with children and/or vulnerable adults as part of their core business, requesting and reviewing their safeguarding policies
  • Where corporate partners do not directly engage with children and/or vulnerable adults, they may not have specific safeguarding policies in place. In these circumstances, we will meet with the Corporate Partner to develop a bespoke Safeguarding Agreements which sets out expectations for working together
  • Whenever Corporate Partners are visiting Comic Relief funded projects, they must be accompanied by Comic Relief staff and all visitors must sign Comic Relief’s Visitor’s Agreement
  • Where Corporate Partners want to use images of Comic Relief’s work, these must be approved by Comic Relief and appropriate, specific consent must be in place

5.3 Guidelines are in place for fundraising and marketing to children and other vulnerable groups

At present Comic Relief does not directly market or fundraise to children under the age of 18 - fundraising is always directed at responsible adults (e.g. teachers, parents) and the materials tailored accordingly. However, we recognise that children do become engaged in our work in different ways and want to ensure that safety is a prominent consideration. We must also be proactive in identifying and supporting vulnerable adults who may also wish to become involved in our fundraising activities.

To achieve this, Comic Relief will:

  • Publish ‘Safety Tips for Fundraising’ on the Comic Relief and campaign websites
  • Include Safeguarding clauses within Fundraising Agreements 
  • Provide clear guidance to the Fundraising Team through ‘Inbound Enquiries Guidance’ and Guidelines for Marketing to Children and Vulnerable Adults 
  • Ensure that safeguarding training and support is provided to the fundraising team on a regular basis

5.4 Arrangements with Global licensees include clear guidance and contractual requirements in relation to safeguarding

Having created a hugely successful brand in the UK, Comic Relief now supports organizations in other territories in the world to stage their own fundraising campaigns under license from Comic Relief UK.  This allows the Comic Relief brand to have an impact globally and multiplies the investment in amazing projects across the world. 

Any licensed organizations and campaigns must maintain the integrity of the Comic Relief brand and licensees are legally required to work within a set of parameters. We work closely with our licensees to ensure safeguarding is integrated in all their work by:

  • Including safeguarding clauses in License Agreement
  • Including guidance on safeguarding within Global Licensee Manual 
  • Sharing safeguarding materials developed in the UK so that they can be adapted and used by Global Licensees in their own context
  • Ensuring that any media assets developed or produced in the UK are subject to standard media assets approvals and comply with safeguarding standards

5.5 Agreements are in place with investors (corporates, funding partners, high net-worth individuals etc.) to govern conduct on visits to projects

Comic Relief works with a variety of individuals who are interested in engaging with and supporting our work. These individuals come from diverse backgrounds and may not have a good understanding of safeguarding. It is our responsibility to support our investors and visitors to ensure they have a good understanding of the work and the importance of safeguarding the children and adults in communities we engaged with.

This will be achieved by:

  • Including information on safeguarding in Briefing Packs and in the verbal briefing provided prior to Project Visits
  • Ensuring all visitors read and sign the Visitor’s Agreements before engaging with children and adults in communities
  • Providing a debrief after every visit to allow a discussion about our work, to address any concerns the individual may have and to ensure that they are clear about the processes that have to be followed if they are going to share information about the visit on social media or other platforms
  • Where individuals want to use images of Comic Relief’s work, these must be approved by Comic Relief and appropriate, specific consent must be in place

5.6 Comic Relief actively engages with networks and policy forums & engages other funders on safeguarding

We believe by championing and convening alongside others, we can contribute to accelerating changes in attitudes, policies and practices on the issues we care about. Comic Relief will proactively engage with other funders, INGOs, creative agencies and others to ensure that we are aware of and contribute to best practice in safeguarding across the sector.

If you have any questions or queries about our safeguarding approach, please contact safeguarding@comicrelief.com