PURPOSE
The safety and well-being of everyone connected with our work is of paramount importance. Comic Relief holds a power position as a funder and an internationally recognised brand. We have a responsibility to ensure this does not result in harm, abuse or exploitation of any kind. The Safeguarding Framework (‘Framework’) sets out the measures that must be taken to ensure:
Prevention: All reasonable steps are taken to prevent harm, abuse and exploitation across our operations;
Protection: All safeguarding concerns are taken seriously and receive a robust response which prioritises the safety and well-being of those at risk;
Personify: Representatives of Comic Relief maintain the highest standards of behaviour and fulfil their responsibilities to keep people safe; and
Partnership: Listening to the organisations we fund, individuals with lived experience and others in the sector to continually learn and improve.
SCOPE
All representatives of Comic Relief must read and comply with the measures outlined in this Framework. This includes:
All Staff, whether employed permanently or as a consultant or contractor
Trustees and Committee Members
Volunteers and Interns
Agencies or organisations employed to deliver services on our behalf
Organisations who receive funding from Comic Relief, our Funded Partners, are not expected to comply with Comic Relief’s Safeguarding Framework but must have their own adequate safeguarding policies and procedures in place.
Owner & Version
Approved by: Board of Trustees
Date: April 2022
Review interval: 2 years
Next review due: April 2024
Employee lead: Head of Legal & Assurance
Executive Director sponsor: Chief Operating Officer
OBJECTIVES
This Framework is divided into five Standards which reflect the different aspects of Comic Relief’s work:
Standard 1: Accountability
Standard 2: Safe People
Standard 3: Safe Investments
Standard 4: Safe Story Telling
Standard 5: Safe Fundraising & Partnerships
Each Standard contains the measures which must be followed to ensure the safety of everyone connected with our work. Safeguarding is everyone’s responsibility and we are all accountable for ensuring that the standards set out in this Framework are maintained throughout our work.
The safeguards contained in this Framework apply equally to all individuals irrespective of age, gender, race, ethnicity, religion, political opinions, sexual orientation or disability. Additional safeguards are included to ensure adequate protection of children, adults with additional care and support needs, and adults living in vulnerable circumstances (See Appendix A: Definitions).
STANDARD 1: ACCOUNTABILITY
1.1 The Board of Trustees and Senior Management Team are responsible for promoting a positive safeguarding culture across Comic Relief
Comic Relief’s Board of Trustees has ultimate responsibility for safeguarding. They have a duty to ensure all reasonable steps are taken to prevent harm and ensure all safeguarding concerns are managed effectively. To enable our Board of Trustees to fulfil this function must guarantee that
Safeguarding is a standing agenda item at every Board meeting,
A Safeguarding Update is produced for every Audit & Risk Committee, and subsequent Board meeting, which provides an overview of safeguarding cases and a summary of proactive measures to implement and strengthen safeguarding across the organisation,
Safeguarding is included in the Organisational Risk Register,
All serious incidents which require reporting to the Charity Commission are shared with a sub-group of Trustees who ensure appropriate action is taken, and
The Board of Trustees and Audit & Risk Committee are informed of all serious incident reports although access to sensitive information will still be restricted to preserve the confidentiality of individuals involved.
The Executive Leadership Team (ELT)is responsible for actively promoting safeguarding within day-to-day operations and role modelling best practices. Led by the CEO, the ELT will:
Promote awareness of safeguarding within their own areas of operation,
Ensure all staff have received the appropriate training and are aware of safeguarding guidance, and
Maintain an overview of safeguarding within Comic Relief through the updates provided at the monthly ELT meetings which include a summary of safeguarding cases, serious incident reports and key risk areas.
In addition, Comic Relief has a Designated Trustee and a Designated Executive Director for responsible for safeguarding. Their role is to:
Champion the importance of safeguarding within the Board of Trustees, ELTand across the organisation,
Attend regular meetings with the Safeguarding Business Partner to maintain an overview of safeguarding cases and measures to implement and strengthen safeguarding across the organisation,
Support the Safeguarding Business Partner in the management of high-risk cases and ensure that risks are managed appropriately, and
Approve any decisions to suspend or terminate funding due to safeguarding concerns.
1.2 The Safeguarding Business Partner with support from the Head of Legal & Assurance ensure staff can access technical expertise and ensure the effective management of any safeguarding issues that arise
It is important that all staff have access to specialist expertise and advice to ensure the highest standards of safeguarding are maintained across all our operations. The Safeguarding Business Partner is responsible for:
Providing advice and support to staff and where resources permit, to Funded Partners;
Developing guidance and building capacity across the organisation;
Managing all safeguarding concerns reported to Comic Relief and ensuring a robust and timely response; and
Maintaining awareness of best practices across the sector to inform Comic Relief’s approach.
The Head of Legal & Assurance maintains oversight of all safeguarding matters:
Meets with the Safeguarding Business Partner regularly to monitor active cases and proactive measures to embed safeguarding policies, processes and culture,
Is informed of any new safeguarding issues, contributes to decision making and ensures appropriate follow-up, including advising on serious incident reports, and ensures the Safeguarding Business Partner has adequate resources and support to fulfil their responsibilities.
1.3 SafeguardingChampions are in place from teams across Comic Relief to build awareness and mainstream safeguarding across the organization
Comic Relief is a unique and diverse organisation and each team manages very different types of safeguarding risk. To ensure safeguarding measures respond to the different organisational needs, Safeguarding Champions:
Meet with the Safeguarding Business Partner on a quarterly basis to share the specific safeguarding issues and support required by their teams/departments,
Promote safeguarding within their teams/departments and support the implementation of safeguarding policies and procedures,
Provide advice to their teams/departments, including signposting to safeguarding resources,
Ensure that safeguarding concerns are escalated in line with safeguarding procedures, and
Support the Safeguarding Business Partner to develop and deliver training and other resources to meet the needs of their teams.
1.4 Clearprocedures exist for reporting and escalating safeguarding concerns, and these are widely understood across the organisation
A safeguarding concern is any allegation or suspicion that someone associated with our work has caused or may be at risk of harm or abuse (See Appendix B: Types of Harm).
Comic Relief operates a low-level concern approach which means that even minor concerns or suspicions of harm must be reported. Failure to report safeguarding concerns will be considered a serious breach of Comic Relief’s safeguarding procedures and may result in disciplinary action
All safeguarding concerns must be reported to the Safeguarding Business Partner or Head of Legal & Assurance. This can be done in person or via e-mail (safeguarding@comicrelief.com(opens in new window)). The Safeguarding Business Partner will discuss the concern with you and decide what further action is required. All records are held confidentially, and access limited to those with safeguarding responsibilities.
If you are unable or unwilling to discuss the concern with the Safeguarding Business Partner:
Speak to your line manager
Speak to a Safeguarding Champion
Report the concern to: designatedcontact@comicrelief.com(opens in new window)
Contact Safe Call - 0800 915 1571
1.5 Safeguarding measures are regularly reviewed to ensure compliance and promote a culture of learning and improvement
Comic Relief is committed to continually learning and improving our safeguarding practice. To achieve this:
This Safeguarding Framework is updated every two years,
Safeguarding is regularly reviewed by the Internal Auditors, and
An external safeguarding review is commissioned every three years to ensure external scrutiny of our work.
Related Policies and Guidance
Procedure for Reporting Safeguarding Concerns
Reporting Concerns (Whistleblowing) Policy
STANDARD 2: SAFE PEOPLE
2.1 Comic Relief adopts safe recruitment practices
Safeguarding measures are incorporated into our recruitment practices to ensure all representatives of Comic Relief are suitable for the role and do not represent a risk to others. The People team will ensure that:
Hiring managers receive training which includes safe recruitment practices;•Our commitment to safeguarding is included in all job adverts;
Questions on safeguarding are included in interviews;
Two references are obtained for all posts;
DBS checks are completed for all staff and trustees. Checks will be initiated once an offer letter has been issued; and
All short-term consultants/contractors will be subject to appropriate background checks if their work includes contact with the projects we fund, members of the public or access to personal data.
2.2 All staff, Trustees and representatives of Comic Relief must comply with the Safeguarding Behavioural Code
The Safeguarding Behavioural Code sets out our expectations regarding safe, respectful behaviour within the organisation and when visiting the projects we fund.
The People Team will ensure that:
All staff, Trustees, consultants and others representing Comic Relief must read and sign the Safeguarding Behavioural Code on joining the organisation;
Compliance with the Safeguarding Behavioural Code is included in employment contracts; and
The expectations set out in the Safeguarding Behavioural Code are explained during Safeguarding Inductions.
2.3 All staff, Trustees and representatives of Comic Relief are supported to understand and fulfil their safeguarding responsibilities
To ensure an effective safeguarding culture, staff and representatives of Comic Relief must be supported to understand their obligations and compliance with these expectations should be monitored throughout the employment cycle.
All new staff receive a Safeguarding Induction within 3monthsof joining the organisation so that they are aware of their responsibilities and how safeguarding relates to their role;
Staff, such as Portfolio Managers and Production staff, who come into direct contact with partners will receive a Safeguarding Induction within one month of joining;
All Trustees are provided with a Safeguarding Induction upon joining the organisation;
Line Managers must ensure their team members have attended safeguarding training and are aware of safeguarding guidance relevant to their role; and
There are opportunities to discuss safeguarding within team meetings, 1-to-1s, appraisals and other forums across the organisation.
2.4 Staff with designated responsibilities for safeguarding are provided with additional training and support in order to fulfil their responsibilities
It is important that the Safeguarding Business Partner, and other support staff including other Assurance Business Partners, have access to additional training and support and are up to date on best practices and learning from across the sector.
All staff with designated safeguarding responsibilities and Assurance Business Partnersattend appropriate safeguarding training at least every 3 years;
The Safeguarding Business Partner will be supported to attend conferences, webinars and other learning forums; and
Additional training needs will be determined through line management supervision, and appraisal.
2.5 ComicRelief promotes a safe working environment and procedures exist to prevent bullying, harassment and exploitation within the workplace
In order that staff are able to work effectively, Comic Relief must provide a safe and supportive environment where staff are protected against all forms of bullying, harassment and exploitation. The People team will ensure that:
The right to a safe working environment and how to report concerns is explained as part of on-boarding new staff and in the Safeguarding Induction,
All staff complete mandatory online reporting concerns/ whistleblowing training to ensure they are aware of their rights and how to raise concerns;
Staff can raise concerns through a diverse range of channels. They can:-Speak to their line manager or any member of ELT-Speak to a member of the People Team-Report concerns to the Safeguarding Business Partner-Report to Designated Contacts (designatedcontact@comicrelief.com(opens in new window)) -Report externally via Safecall
Comic Relief’s Designated Contacts (Head of Legal & Assurance and Head ofPeopleandFacilities) have authority to make independent representations to Trustees where serious concerns about the organisation are reported, and
Any allegations or suspicion of bullying, harassment and exploitation are referred to the PeopleandFacilitiesTeam who will investigate any concerns.
In addition, Comic Relief is committed to supporting the well-being and mental health of their staff.
Line Managers receive training on supporting mental health at work,
Staff have access to counselling and support via the Comic Relief Employee Assistance Programme, and
A team of Mental Health First Aiders are available across the organisation.
Related Policies and Guidance
Recruitment Policy
Safeguarding Behavioural Code
Bullying and Harassment Policy
Grievance Policy
Disciplinary and Dismissal Policy
STANDARD 3: SAFE INVESTMENTS
3.1. Safeguarding is integrated into the assessment of organisations who apply for funding from Comic Relief
Comic Relief invests in a diverse range of organisations and we expect all the organisations we fund to have measures in place to prevent harm and to respond to safeguarding concerns. We assess this by:
Asking questions about safeguarding in the application form;
Reviewing the safeguarding policies of organisations shortlisted for funding;
Exploring safeguarding in more detail during the assessment meeting;
Rating the organisational safeguarding within the assessment report; and
Providing assessors with specialist training.
We recognise that organisations will be at different stages in terms of their safeguarding. All organisations must have basic measures in place but where weaknesses are identified, we will ensure that gaps are addressed by:
Placing additional conditions on the funding;
Allowing budget to be allocated towards strengthening safeguarding;
Providing additional funding so that partners can organise external capacity building support; and
Where resources permit, the Safeguarding Business Partner will provide additional advice and share resources, where necessary.
3.2. Comic Relief establishes clear expectations regarding safeguarding that are monitored throughout the duration of the funding
Comic Relief expects all Funded Partners to fully implement and monitor the safeguarding measures set out in their policies and procedures. This expectation is reinforced by:
Including specific requirements in the Conditions of Funding;
Explaining our expectations during the start-up phase;
Including a specific question on safeguarding in the monitoring reports; and
Exploring safeguarding practice during monitoring visits.
3.3. Funded Partners are required to report serious safeguarding incidents to Comic Relief and we take action to ensure adequate safeguards are in place
In order to ensure that our Funded Partners respond appropriately to safeguarding concerns, Comic Relief requires partners to notify us of any allegations of harm, abuse or exploitation in relation to their staff, volunteers or operations. We make partners aware of this expectation through:
Including the notification requirement in the Conditions of Funding;
Sharing our ‘Guidance on Making Safeguarding Notifications to Comic Relief’ to clarify what should be reported and how this will be managed;
Explaining notification requirements during the start-up phase; and
Including a question about safeguarding incidents in monitoring reports.
When Comic Relief is notified of a safeguarding incident:
The Safeguarding Business Partner is informed and assesses what action is required;
The Safeguarding Business Partner will normally speak to the Funded Partner to gain a better understanding of the issue and the response by the Funded Partner;
We may review relevant policies and procedures to check that appropriate safeguards are in place;
Where we are concerned that the Funded Partner is not able to deliver their work safely, Comic Relief may suspend funding;
In exceptional circumstances, Comic Relief may decide to withdraw funding if the Funded Partner is unable or unwilling to address safeguarding concerns. The decision to terminate funding is never taken lightly and we will always try and support our partners to address concerns rather than terminate funding; and
Any decision to suspend or terminate funding must be agreed with the Head of Legal & Assurance and approved by the Designated Executive Director responsible for safeguarding and the Designated Trustee for responsible for safeguarding.
Where Comic Relief provides funding in conjunction with other donors, we will notify them of safeguarding incidents in our monitoring reports to them. We will provide details of the incident and the actions taken to address the concerns, although sensitive information about the case will be kept confidential to Comic Relief. Any decision to suspend or terminate funding will be taken in collaboration with the co-funding agency.
3.4. Support is provided to Funded Partners to ensure they understand their responsibilities and implement best practice in terms of safeguarding
Comic Relief aims to support our partners to maintain and improve their safeguarding practice. We achieve this by:
Allowing all organisations to include a budget line for safeguarding in their application for funding;
Being flexible in our requirements and allowing budget to be re-allocated for safeguarding if gaps are identified;
Signposting to capacity building support via external specialists and where appropriate, providing additional funds to cover this additional support; and
Where resources permit, the Safeguarding Business Partner will provide guidance including on policies and procedures.
3.5. Where funding is distributed through another organisation acting as an intermediary grant maker, Comic Relief will ensure safeguarding is included in their assessment, monitoring and support to grantees
Some Comic Relief funding is dispersed via intermediary organisations as this allows us to extend our impact. Where funding is granted to intermediaries we expect safeguarding to be fully considered in their grant making cycle. To achieve this:
Intermediary organisations are assessed to ensure they have adequate safeguarding policies and procedures in place;
All intermediaries will sign a partnership agreement that sets out our safeguarding requirements, including the requirement to notify us of safeguarding incidents within their organisation or their grant recipients; and
Support is offered to intermediaries through sharing tools, resources and offering advice from the Safeguarding Business Partner.
Related Policies and Guidance
Guidance on Assessing Safeguarding Policies and Procedures
Guidance on Making Safeguarding Notifications to Comic Relief
Safeguarding Agreement: Intermediary Partners
Co-Funding Partnerships: Protocol for Reporting Safeguarding Incidents
STANDARD 4: SAFE STORY TELLING
4.1. Comic Relief’s Safe Story Telling Guidelines are followed at all times when gathering stories for use on TV, social media or other channels
Telling compelling stories about the impact our funding is a critical part of Comic Relief’s work. Our Safe Story Telling Guidelines help ensure that the safety, dignity and welfare of contributors is always at the heart of this work.
All staff and representatives of Comic Relief involved in gathering stories must comply with the Safe Story Telling Guidelines;
Safe Story Telling Training is mandatory for the content, digital, media and talent teams;
Independent Production Companies and freelancers contracted by Comic Relief are also be required to attend safe story telling briefing and compliance with the Safe Story Telling Guidelines is included in their contracts;
Safeguarding measures are included in the Rules of Engagement agreed with the BBC prior to each campaign and will set out how to resolve differences in our approach; and
A summary of the Safe Story Telling Guidelines is shared with projects prior to story gathering so they are aware of the safeguards staff must follow
4.2. Do No Harm: Measures are in place to protect the safety and well-being of everyone involved in our story telling
The safety and well-being of contributors, staff and audiences must always be our paramount consideration. We will never prioritise story telling over safety.
The Safeguarding Business Partner meets regularly with staff responsible for story gathering to ensure that safeguarding is considered throughout,
There is a designated safeguarding lead on all story gathering visits who is sufficiently experienced and ensures safeguarding measures are adhered to,
A risk assessment is completed prior to story gathering and safety risks are discussed with contributors and documented on the consent form,
For high risk stories, a full Contributor Safeguarding Assessment is completed,
For high risk stories, the Safeguarding Business Partner will review content prior to use on air to ensure that safety concerns have been appropriately mitigated,
The Safeguarding Business Partner must be informed within 24 hours if there is any concern that our story gathering has placed contributors or others at risk, and
Community management guidelines are in place to manage risks associated with sharing content online.
4.3. Dignity & Respect: Measures are in place to ensure that our story telling is respectful and does not degrade, victimise or shame contributors
We will treat all contributors with dignity and respect. We will avoid telling stories that are based on stereotypical assumptions or could in anyway degrade, victimise or shame contributors.
Story gathering is planned in ways that minimise disruption and respects the work, education, family, religious and cultural practices of contributors;
Where our content includes stories of human suffering, we will treat this sensitively and avoid portraying contributors as victims;
We will respect the voice of our contributors and Funded Partners by allowing them, wherever possible, to tell their own story in their own words; and
We will, wherever possible, use our story telling to amplify the work of our partners. This may include naming partners in our films, on our Comic Relief website or on our social media channels.
4.4. Privacy: Measures are in place to ensure that personal information is handled sensitively and complies with data protection and privacy legislation
We will respect a contributor’s right to privacy and will take all reasonable measures to protect personal information shared with us.
We comply with UK data protection and privacy legislation, regardless of where we are working in the world;
The collection, storage and sharing of personal information complies with GDPR legislation and Comic Relief’s Data Protection Policy and Data Retention Policy;
Stories should not include identifiers which could be used to locate contributors (e.g. logos on school uniforms, street names or other signage);
In cases where it is essential to the story to share details of the specific location (e.g. a story about fundraising within a particular school), we will limit the personal information shared about individual contributors;
We will only use contributors' first names in our stories. Exceptions may be made for professionals but there should be a clear justification and consent before using full names;
Additional privacy restrictions (e.g. changing the name, not showing the individual’s face) may be required for ‘high risk’ stories; and
The Data Protection Officer must be immediately informed of any potential/ actual data breaches.
4.5. Accuracy: Measures are in place to ensure our story telling is accurate and does not mislead our audiences
We will be honest and transparent in our story telling and provide an accurate depiction of our work. We will avoid telling stories that could be misleading and will never manipulate, distort or sensationalise the stories we tell.
We will be honest and transparent in our story telling and provide an accurate depiction of the work that we fund;
Where Comic Relief only funds certain aspects of an organisation’s work, we will verify proposed content with the Funded Partner to ensure we are not misrepresenting the impact of our funding;
We will not use production techniques that could mislead the audience; and
We will share content with our Funded Partner and/or contributors to ensure accuracy and that we have not misrepresented the story in any way.
4.6. Informed Consent: Consent will be obtained for all content used by Comic Relief
We will provide our Funded Partners and Contributors with clear and honest information so that they can make an informed decision about participating in our story telling. We will acknowledge inherent power dynamics and take steps to ensure that participation is voluntary, and consent is freely given.
Informed consent must be obtained from all contributors in line with data protection legislation;
For children under the age of 16, consent must be provided by the parent or guardian who has legal responsibility for the child;
For adults with care and support needs consent must be obtained from a family member but, wherever possible, the adult contributor should give their assent to participate and sign the consent form;
It is essential that we obtain demonstrable consent. If we are unable to locate proof of consent, we cannot use the footage;
We will only re-use material for three years after which re-consent must be obtained; and
If we wish to use images in a different way not covered at the time of consent, we must re-confirm consent.
Related Policies and Guidance
Safe Story Telling Guidelines and Safe Story Telling Checklist
People on the Move (Story Gathering) Guidelines
Contributor Care Guidelines and Contributor Safeguarding Assessment
Guidelines for Obtaining Consent
Data Protection Policy and Data Retention Policy
Community Management Guidelines
STANDARD 5: SAFE FUNDRAISING & PARTNERSHIPS
5.1. There are clear agreements in place for safeguarding when engaging schools and colleges in our work
Comic Relief regularly works with schools and colleges across the UK as part of our public fundraising. Although schools and colleges have their own safeguarding policies and procedures in place, it is important to clarify our respective roles and responsibilities. We achieve this by:
The measures set out in the ‘Safeguarding Checklist for Engagement with Schools and Colleges’ are followed at all times;
Prior to any visit, Comic Relief will write to the school to clarify roles and responsibilities in relation to safeguarding;
Where individuals are visiting schools on behalf of Comic Relief but without a member of our staff present (e.g. athletes visiting as part of Sport Relief), they will be asked to sign a Safeguarding Memorandum of Understanding prior to the visit and must be accompanied by school staff at all times; and
Comic Relief will ensure that informed consent is obtained for any filming or photography and this must contain specific consent for use by Comic Relief.
5.2. Safeguarding is integrated into arrangements with Comic Relief’s Corporate Partners
Comic Relief’s work is supported by a wide variety of Corporate Partners who help promote our work and actively support our fundraising. Comic Relief aims to engage with ethical, responsible organisations and ensure that they adhere to safeguarding measures when engaging with the work that Comic Relief funds. We achieve this by:
Including safeguarding in our due diligence checks before approving new partnerships;
Including safeguarding clauses in contracts with Corporate Partners;
Where Corporate Partners directly engage with children and/or adults with additional care and support needs as part of their core business, we request copies of their safeguarding policies; and
During visits to Comic Relief funded work, the measures set in Standards 5.3 are in place.
5.3. Safeguarding is carefully managed during visits from Corporate Partners, talent, high net-worth individuals and others who support our work
Comic Relief engages with a diverse range of individuals who are interested in supporting our work and may wish to visit the organisations we fund. Comic Relief must ensure that visitors clearly understand the importance of safeguarding and our expectations when visiting the work that we fund. We achieve this by:
Visitors are always accompanied by Comic Relief staff;
The measures set out in the ‘Safeguarding Checklist for Visitors’ must be adhered to at all times;
Information on safeguarding in is provided in Visit Briefing Packs and then re-iterated during verbal briefing at the start of each visit;
All visitors must read and sign a Visitor’s Agreement;
Children under the age of 18 are not permitted to attend visits;
Comic Relief will ensure there is consent for any photography or filming obtained during the visit and will approve all images before use; and
Additional guidance on working with talent is included in the Talent Engagement Guidelines.
5.4. There are protocols and processes in place to safeguard children and adults with care and support needs when communicating with the public or engaging them in fundraising activities
Comic Relief receives a range of inquiries from the public on a daily basis. Although these rarely raise any safeguarding concerns, it is important that measures are in place to ensure appropriate response to individuals who may be vulnerable or at risk.
Staff engaging with the public have access to guidance on ‘Responding to Safeguarding Issues in Inbound Enquiries’;
Any inquiries which indicate that an individual is at risk of harm, abuse or exploitation are escalated to the Safeguarding Business Partner. Where they are at immediate risk, they will be supported to contact emergency services;
Where a member of the public is not at risk but is seeking advice or support, they are signposted to a trusted service contained in the Inbound Inquiry database;
Any inquiry from a child under the age of 18, or where the language indicates the person may be a child, is immediately routed to a designated team who are authorised to respond to children; and
Children are informed that all contact must be directed via an appropriate adult.
Additional protocols and processes are in place to ensure that our fundraising activities protect children and adults with care and support needs:
All public fundraising activities must comply with Comic Relief’s policies on fundraising and data protection;
‘Safety Tips for Fundraising’ are published on the Comic Relief and campaign websites;
Comic Relief only engages children in fundraising via a responsible adult;
All Comic Relief fundraising information clearly states that no-one under the age of 18 should be involved in fundraising without adult supervision; and
Where there are specific safety or other risks associated with public fundraising, a Fundraising Agreement is completed and a Risk Assessment submitted to the Business Assurance Partner – Risk & Compliance.
5.5. Arrangements with global licensees include clear guidance and contractual requirements in relation to safeguarding
Building on success in the UK, organisations in other countries can obtain a license agreement to stage their own fundraising campaigns using the Comic Relief brand. These campaigns must maintain the integrity of the Comic Relief brand and licensees are expected to have safeguarding measures in place. To achieve this:
License Agreement requires Licensees to have adequate safeguarding measures in place;
The safeguarding measures must be documented and approved by Comic Relief;
Guidance on safeguarding is included within the Brand Manual; and
We share safeguarding materials developed in the UK so that these can be adapted for use in other contexts.
Related Policies and Guidance
Checklist for Engagement with Schools and Colleges
Responding to Safeguarding Issues in Inbound Enquiries and Database of Signposting Support Services
Visitor’s Agreement
Fundraising Agreements
Talent Engagement Guidelines
Data Protection Policy
Fundraising Policy
APPENDIX A: DEFINITIONS
Comic Relief operates in many different countries around the world, each with their own regulations and legal frameworks. The information provided here, therefore, does not refer to any specific legislation but represents the agreed definitions that Comic Relief staff and representatives must apply to their work, irrespective of location.
Child: Anyone under the age of 18.
Adult with care and support needs: Any person aged 18 or over, who may be at increased risk of harm or abuse or less able to protect themselves due to age, disability, special educational needs, illness, mental or physical frailty or impairment of, or disturbance in, the functioning of the mind or brain.
Adult living in vulnerable circumstances: Any person aged 18 or over, who may be at increased risk of harm or abuse or less able to protect themselves due to isolation, socio-economic factors and environmental living conditions.
APPENDIX B: WHAT IS A SAFEGUARDING CONCERN AND TYPES OF HARM
A safeguarding concern is any allegation or suspicion that any individual associated with our work may be at risk of harm. Concerns may relate, but are not restricted, to:
Beneficiaries of Comic Relief grants;
Participants in Comic Relief events or fundraising activities;
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 work place; and
Concerns about conduct outside the workplace that may indicate some kind of abusive or exploitative behaviour.
Harm can take many different forms – it may be physical, emotional or sexual in nature. It may also include some form of exploitation for financial or other gain. This procedure does not to include specific definitions of abuse for a number of reasons:
Our commitment to safeguarding means that we aim address a broad spectrum of concerns relating to the safety and well-being of others, even if these do not reach the threshold of abuse;
Abuse can be difficult to assess and applying this threshold may prevent individuals from reporting; and
Comic Relief operates in many different countries and legal jurisdictions and the definition of harm and abuse will vary in each.
This Framework does not to include definitions of abuse for a number of reasons:
Comic Relief operates in many different countries and legal jurisdictions and the definition of abuse will vary in each;
We aim to address a broad spectrum of concerns relating to the safety and well-being of others, even if these do not reach the threshold of abuse; and
Abuse can be difficult to assess and applying this threshold may prevent individuals from reporting.
In order to assist our teams in identifying safeguarding concerns, however, we do provide a broad overview of the types of harms our staff and representatives should be alert to.
Physical: Any physical contact that results in discomfort, pain or injury
Sexual: Coercion or force to take part in sexual acts of any kind
Emotional/Psychological: Action or inaction that causes mental distress
Exploitation: Misuse of power or control over another person for financial, social, sexual or other benefit
Bullying & Harassment: Unwanted behaviour which causes offense, intimidates or humiliates others
Sexual Harassment: Unwanted verbal, non-verbal or physical conduct of a sexual nature
Institutional: Systems or culture within an organisation that can result in any kind of harm or failure to prevent harm through acts of omission
This list is not exhaustive and any concerns about the safety or welfare of anyone connected with our work, no matter how minor, should be reported to the Safeguarding Business Partner or Head of Legal & Assurance.