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.
We aim to conduct our work in an ethical and respectful manner that is underpinned by our safeguarding values:
All representatives of Comic Relief must read, understand and comply with the measures outlined in this Framework. This includes:
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.
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:
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:
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:
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:
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 concerns can arise in any part of the organisation. Concerns include, but are not restricted, to:
images (films and photography), events or fundraising activities
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:
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:
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:
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.
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
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.