Safeguarding policy

Investment20/20 Safeguarding Policy

Investment20/20 has a commitment and responsibility to promote the welfare of all children and young people and keep them safe.

This policy applies to anyone working on behalf of the Investment Association and Investment20/20, including volunteers (employees from firms who speak at Investment20/20 events or events which Investment20/20 has been asked to speak at). This policy:

  • Provides links to relevant sources of information to ensure that all adults who work with Investment20/20 have a good understanding of safeguarding and child protection
  • Outlines good practice guidelines
  • Ensures the commitment to safe recruitment for the Investment20/20 team
  • Ensures that all adults who work with Investment20/20 are aware of the structured response procedure for safeguarding concerns
  • Expresses the commitment of Investment20/20 to safeguarding and child protection

 

More info at https://learning.nspcc.org.uk/child-protection-system/england

 

1. About Investment20/20

Investment20/20 helps people find out about careers in investment management.  We work with schools, colleges, universities and community groups to enable young people to find out about careers in investment management and to help them navigate their way to entry level roles.

We work with young people in four ways:

a. Delivery of careers workshops to young people in schools, colleges, universities, community venues, employer venues, and other spaces.

b. Through our longer-term programmes, such as Think Investments, where we engage with young people on an ongoing basis, in both individual and group work settings. All these young people are aged 16 and above and are run via schools, colleges and universities.

c. Delivery of virtual activities such as online sessions, webinars, and video calls to young people, delivered in partnership with employers and industry volunteers. These are all organised through schools, colleges, universities, charities and other partners.

d. Through our Investment20/20 Trainee Programme, where young people over the age of 16 are employed by an Investment20/20 employer partner for a one-year contract.

Any of the young people with whom we work may be enrolled at a school sixth form, FE College, Sixth Form College, university or other education provider.

2. Types of abuse

It is important for any adult involved in working with Investment20/20 to have a good understanding of types of abuse. All adults involved in Investment20/20 have a role in identifying signs of abuse.  In this policy “child” and “young person” are used interchangeably to mean any person under the age of 18.   

 

The types of child abuse that may occur are extensive.  It is the responsibility of each Investment20/20 member of staff to ensure they have completed the NSPCC Introduction to Safeguarding course every three years. 

 

It is signposted to any member of staff from a partner firm that may speak at a group session should also read the NSPCC website: https://www.nspcc.org.uk/what-is-child-abuse/types-of-abuse/.

 

In addition to types of abuse, we recognise that mental health is particularly important to the ages of the young people that Investment20/20 work with.   More can be found here:

https://www.nspcc.org.uk/preventing-abuse/keeping-children-safe/mental-health-suicidal-thoughts-children/.

3. Good practice guidelines

All adults working with Investment20/20, in whatever capacity including volunteers (employees who deliver a talk), should demonstrate exemplary behaviour. The following are common sense examples of how to create a positive culture and environment.   These examples and guidelines apply to face to face and virtual delivery. 

DO:

  • Always prioritise the welfare of each young person
  • Always work in an open environment, avoiding private situations
  • Always make sure that you are never by yourself on a video call or virtual. Always ensure there is a member of the Investment20/20 team already signed in and a teacher is present.
  • Treat all young people with respect and dignity
  • Maintain an appropriate emotional and physical distance from the young person
  • Ensure the young person is in a space with other people around – never be in a room alone with a young person, and keep doors open and blinds up
  • Be an excellent role model e.g. not smoking/drinking in the company of a young person
  • Give enthusiastic and constructive feedback rather than negative criticism
  • Administer first aid/other medical treatment when necessary, and report in line with the hosting organisation’s/venue’s policy and procedure, and inform Investment20/20
  • Report any incidents (see below)

 

DO NOT under no circumstances (this applies to face to face and virtual delivery)

  • Engage in rough physical or sexually provocative games
  • Allow or engage in any form of touching (e.g. consoling arm if the student is upset)
  • Allow young people on Investment20/20 events/programmes to use inappropriate language unchallenged
  • Say or do anything that might be interpreted as aggressive or hostile
  • Do things of a personal nature for young person at an Investment20/20 event or programme student that they can do for themselves
  • Take a young person in a car or accompany on a journey, e.g., after a careers event
  • Make sexually suggestive, discriminatory, offensive or violent comments to young people on Investment20/20 events/programmes
  • Meet with young people on Investment20/20 events/programmes in an inappropriate place, e.g., café, a nightclub, bar, restaurant, park etc. Never meet outside of the specific event or delivery of programme.
  • Allow allegations made by young people on Investment20/20 events/programmes to go unchallenged, unrecorded or not acted upon
  • Attempt to engage with a young person personally outside of the Investment20/20 led (face to face or virtual delivery) event EXCEPT from phone calls with the young person as a follow up, e.g., enquiry about a job vacancy, CV improvement discussion etc.
  • Fail to report to Investment20/20 anything inappropriate that a young person does or says.
  • Any adult representing Investment20/20 (staff, Investment Ambassadors, volunteers etc.) must not communicate with any young person as a result of an Investment20/20 event (unless as a result of a request from a young person in relation to the event, job vacancy or other relevant subject, i.e., CV advice) or connect with them on any social media platform.

4. Incidents that must be reported to the Designated Safeguarding Officer ([email protected])

If you witness or are a party to any of the following, you should report this immediately to the Investment20/20 Safeguarding Lead and record the incident.  You must report any incidents including the below:

  • You hurt a young person on Investment20/20 events/programmes, even if unintentionally
  • You witness any inappropriate behaviour, whether from another adult or from a young person on Investment20/20 events/programmes
  • A young person on Investment20/20 events/programmes
    • seems distressed
    • mentions they are in danger at home or school
    • mentions they want to harm themselves/others
    • appears to be physically attracted to you or to another adult
    • misunderstands or misinterprets something you have done
    • has not attended or has a lack of engagement which causes concern
    • makes suggestive or inappropriate comments, either in person, online or using
    • any other form of communication.

 

Where a young person is on an Investment20/20 work shadowing or work placement activity, the employer is expected to notify Investment20/20 and the school/college immediately upon becoming aware of any safeguarding/child protection issues.

5. Face to face events not in the premises of schools, colleges, universities or other partner organisations

Investment20/20 will only run events when organised in conjunction with the school, college, university or other organisation and a representative from the school/college/university/other organisation must accompany the young people. 

The school/college/university/community organisation is responsible for informing Investment20/20 what they require to be in place regarding health and safety, dietary requirements and access requirements for young people.

The young people remain in the duty of care of the school/college/university/ community for the entire event.  It is expected that the school/college representative takes full responsibility for their students for the entire duration of the visit including obtaining parental consents in line with their own safeguarding policy.  The school/college/university/other organization must take full responsibility for welfare and safeguarding of students at these events. Investment20/20 accepts no responsibility for personal belongings brought by students to events. 

These sessions fall under the safeguarding policy of the school, college or university.

6. Investment20/20 attending face to face in an education or community/other setting

Visits to schools, colleges, universities and community settings are part of the Investment20/20 outreach strategy.  These activities often occur in two forms, but are not restricted to just these two:

a. A careers fair/exhibition: This tends to be a large event with many other organisations. Students visit the exhibition stand for information on Investment20/20. 

b. Delivering a workshop: This will be in a classroom style setting.  The role of Investment20/20 is to deliver a talk about careers in investment management.

Both these types of activities are managed and supervised by the hosting organization (school/college/university/other organization).  The hosting organisation is responsible for student welfare and safeguarding as the activities take place on their premises, but the Investment20/20 safeguarding best practice still applies to all Investment20/20 staff and volunteer conduct.  The hosting organisation must always ensure there is a member of their staff in the room with the Investment20/20 representative (this includes volunteers – employees from an investment manager firm).  

These sessions fall under the safeguarding policy of the school, college or university.  This is made clear to the school/college/university/other organisation at the point of booking the session through:

  • Investment20/20 sharing the Code of Conduct on email with the individual that booked the session from the school/college/university/other organisation
  • Investment20/20 including the Code of Conduct on the meeting planner with the individual that booked the session from the school/college/university/other organisation, with clear guidance that by accepting the meeting planner, the school/college/university/other organisation are agreeing to the Code of Conduct.

7. Investment20/20 events: Virtual delivery

Our virtual events are only delivered in conjunction with a school, college, university or other organisation.

These are always group based sessions.  Investment20/20 and any employer speakers are projected onto the whiteboard.  Employer speakers are never to attend by themselves. This is very similar to Investment20/20 visiting an education establishment and being in the classroom:  the teacher is responsible for session logistics and student welfare, Investment20/20 and the Investment Ambassadors have a speaking only role, and it is a group one off intervention. These sessions will not be recorded.  

School/college/university/other organisation responsibilities

  • The teacher/other professional to send the virtual link to be used
  • No student is on webcam unless the teacher has enabled it/allowed it.
  • The teacher/other professional is responsible for managing the session, safeguarding and welfare of the students

 

These sessions fall under the safeguarding policy of the school, college or university.  This is made clear to the school/college/university/other organisation at the point of booking the session through:

  • Investment20/20 sharing the Code of Conduct on email with the individual that booked the session from the school/college/university/other organisation
  • Investment20/20 including the Code of Conduct on the meeting planner with the individual that booked the session from the school/college/university/other organisation, with clear guidance that by accepting the meeting planner, the school/college/university/other organisation are agreeing to the Code of Conduct.

8. Communication

8.1.

Telephone

Any adult representing Investment20/20 must ensure that all communication is transparent and open to scrutiny.   Investment20/20 staff must use their Investment20/20 mobile or office phone to contact young people in relation to an enquiry about an event, job vacancy or other relevant subject, and NOT their personal phone number.

 

8.2

Social media

Any adult representing Investment20/20 individuals (including staff, Investment Ambassadors, volunteers etc.) must not communicate with any young person as a result of an Investment20/20 event (unless as a result of a request from a young person in relation to the event, job vacancy or other relevant subject, i.e., CV advice) or connect with them on any social media platform.

 

8.2.a LinkedIn – Investment20/20 staff

Investment20/20 staff must not accept a connection on LinkedIn from a young people known through any Investment20/20 programme or event.  Only the official LinkedIn account for Investment20/20 can accept connection requests from LinkedIn.  Investment20/20 staff contact details on LinkedIn must be hidden.

 

8.2.b LinkedIn – Investment20/20 volunteers and speakers from firms

Investment Ambassadors, employee speakers from firms and volunteers MUST NOT seek contact with a young person connected with an Investment20/20 event nor accept a request to connect on any social media platform, including LinkedIn.  Investment Ambassadors and other volunteers MUST have their work email address, or no email address, and not personal email address on their LinkedIn account.

 

8.3

Emails

Investment20/20 staff:  any email communication must take place on the Investment20/20 email account and NOT personal email accounts.

 

Investment Ambassadors and volunteers:  If an email is received from a young person connected to an Investment20/20 event do not respond and instead please forward the email to your HR department and ask them to respond on behalf of your organization.

9. Investment Ambassadors, speaker volunteers and other non Investment20/20 individuals that support Investment20/20 activities

Investment Ambassadors and volunteers are people who support the delivery of Investment20/20 careers sessions (face to face, virtually, online or video calls). 

Investment Ambassadors, speaker volunteers and other non Investment20/20 individuals will NOT take part in a virtual or face to face session (see point 7) without the supervision of an Investment20/20 member of staff or teacher/other professional from the organising arranging the session.  Investment Ambassadors, speaker volunteers and other non Investment20/20 individuals are not subject to DBS checks as they are always supervised and they do not have any ongoing contact with young people.

Investment Ambassadors, speaker volunteers and other non Invesmentment20/20 individuals must not actively seek contact with young people after their session.  Investment Ambassadors, speaker volunteers and other non Invesmentment20/20 individuals must follow all the guidelines in this document including communication guidance on using LinkedIn (see point 8 in full).   

An Investment Ambassadors, speaker volunteers and other non Invesmentment20/20 individuals must confirm they will adhere to the Volunteer Code of Conduct each time they take part in an Investment20/20 activity.  This is managed in the following ways:

  • The Volunteer Code of Conduct is shared with the Investment Ambassadors, speaker volunteers and other non Invesmentment20/20 individuals once they have confirmed their participation. They are asked to sign and return.  In addition;
  • The Volunteer Code of Conduct is included on the ‘meeting planner’ for each event request. By accepting the meeting request, Investment Ambassadors, speaker volunteers and other non Invesmentment20/20 individuals are agreeing to adhere by the Volunteer Code of Conduct.

10. Photography and film

Investment20/20 will take photos and films at our events, which could be either Investment20/20 organised events or a partner organisation event.  Young people will be asked to agree to their image/footage being used as part of the registration process for the event where it is Investment20/20 organised – this includes our face to face, and online, virtual and video call events and programmes.   Where it is a partner organised event, it is the partner organisations responsibility to obtain consent for photography and film.

11. Investment20/20 Recruitment

All Investment20/20 paid staff are to:

  • Have a Disclosure and Barring Service (DBS) check to Enhanced level (Guard List checked) in England where they have a frequent advice role with young people, and Enhanced level (not Guard List checked) for infrequent advice roles.
  • Have a Basic Disclosure check in England where the role does not include infrequent advice to young people.
  • Have a Basic Disclosure Scotland check in Scotland
  • Register with the DBS Update Service in England, or undergo a new DBS Enhanced check every 3 years in England
  • Undergo a new Basic DBS Check every 3 years in Scotland

 

All members of Investment20/20 staff will be informed about the Safeguarding Policy and the procedures that are to be followed should any issues arise. They are required to confirm that they have read the Safeguarding Policy, and that they confirm that they will ensure compliance.  All adults working with Investment20/20 are expected to follow the good practice guidelines as set out in this policy. In addition, all Investment20/20 staff must complete the NSPCC Introduction to Safeguarding online course.  This training must be refreshed every three years. This is logged on a central record.

 

When a new member of Investment20/20 joins, they are required to complete relevant DBS checks as part of the recruitment process, read and confirm they will ensure compliance with the Safeguarding Policy, and complete the NSPCC Introduction to Safeguarding online course.

12. Reporting a concern or allegation

Concerns can be reported:

  • Directly from a YP
  • From someone else about a YP
  • Something you see or hear about a YP
  • Something you are told, see or hear about an adult

 

Allegation would usually apply to concerns about an adult.

If you think a child is in immediate danger, don’t delay – call the police on 999, or call the NSPCC on 0808 800 5000, straight away.

When concerns are reported, all adults working with Investment20/20 should follow the response guidelines set out below.

When a complaint is made about an individual involved in a young person’s work shadowing/ work experience placement, Investment20/20 staff will speak with their key contact from the individual’s organisation to review the evidence. The shadowing/placement must stop until the outcome is determined.

a. What to do if you are informed about a concern.

  • For the person receiving the disclosure
    • Listen carefully.
      • show you care, help them open up: Give your full attention to the child or young person and keep your body language open and encouraging. Be compassionate, be understanding and reassure them their feelings are important. Phrases such as ‘you’ve shown such courage today’ help.
      • take your time, slow down: Respect pauses and don’t interrupt the child – let them go at their own pace. Recognise and respond to their body language. And remember that it may take several conversations for them to share what’s happened to them.
      • show you understand, reflect back: Make it clear you’re interested in what the child is telling you. Reflect back what they’ve said to check your understanding – and use their language to show it’s their experience.
    • Do not ask leading questions
    • Record the concern in writing, using the exact words the subject has used
    • Record details such as names, dates, times, and location
    • Be clear to the young person that you cannot guarantee confidentiality
    • Explain that information will only be shared with people that will help to ensure the young person’s safety and well-being
    • Inform the Investment20/20 Safeguarding Lead immediately
  • The Safeguarding Lead at Investment20/20
    • Should review the information and ALWAYS pass to the school/college/university/community group Designated Safeguarding Officer. It is the responsibility of the school/college/university/community group Designated Safeguarding Officer to take the necessary action to ensure the situation is addressed appropriately and escalated to the MASH / Local Area Designated Officer if they feel appropriate. 
    • If the young person is not part of a school/college/university/community group, the Local Area Designated Officer must be notified and or MASH by Investment20/20.
  • The school/college/university Safeguarding Lead
    • Should take the necessary action to ensure the situation is addressed appropriately and escalated to the MASH / Local Area Designated Officer if they feel appropriate
    • Investment20/20’s role is to follow through on actions allocated. Assistance will be provided to external investigators.

 

b. Process for reporting

It is the responsibility of the school/college/university/community group/Local Area Safeguarding Office to liaise with the parents/carers of the young person involved, should it be appropriate.  If there has been any physical injury to the young person during an event/shadowing day/work placement the parents/carers should be informed immediately.

i. Report disclosure to the Investment20/20 Safeguarding Lead via phone and email: [email protected] / 07851 950207

ii. The disclosure should be reported as soon as possible.

iii. The following information should be reported:

  • the child’s details (name, age, address – if your have these)
  • what the child said or did that gave you cause for concern (if the child made any verbal disclosure, write down their exact words)
  • any information the child has given you about the alleged abuser

iv. The Investment20/20 Safeguarding Lead records the disclosure on the Safeguarding Spreadsheet. All correspondence, including notes from phone calls and conversations, are saved in the secure Safeguarding folder on the Investment20/20 shared drive.

v. The Investment20/20 Safeguarding Lead reports the disclosure to:

  1. The young person’s school, college, university or community group and if necessary, the Safeguarding Lead at the Local Authority in which the young person attends school/college/university/community group
  2. Depending upon the person making the disclosure, it may be necessary to inform one or more of the following people
    • School or college Safeguarding Officer
    • Employee’s manager or HR manager
    • Volunteer’s manager or HR manager

 

vi. The Safeguarding Lead notes last key action point taken and who is responsible for continuing investigation.

c. Record Keeping

Investment20/20 will keep a clear and comprehensive summary of any allegations made, details of how it was followed up, and details of any action taken and decisions reached.  This will be recorded on the Safeguarding spreadsheet, and all correspondence saved in the secured Safeguarding folder on the Investment20/20 shared drive. 

We will share safeguarding information with other agencies and will seek consent to do so unless this would jeopardise the safety of a young person, in which case information can be shared without consent. In sharing information about the young person, the safety and welfare of the young person is paramount. Information will be shared following information sharing principles – see https://learning.nspcc.org.uk/child-abuse-and-neglect/recognising-and-responding-to-abuse#information-sharing

d. Outcome of investigation

Investment20/20 would follow the guidance outlined here: https://learning.nspcc.org.uk/safeguarding-child-protection/managing-allegations-of-abuse.

 If the allegation is substantiated their participation in Investment20/20 programme activities may be terminated.  Further action may be pursued by the relevant authorities.  The Investment Association will make any notifications that are required by law.  If a criminal offence has been committed the police (and any other relevant body) will be contacted to take the matter further.

If an allegation is determined to be unfounded or malicious, The Investment Association will alert the relevant people or external bodies.  In the rare event that an allegation is shown to have been deliberately invented or malicious, the Investment Association will ask the police to consider whether any action might be appropriate against the person responsible. 

13. Disciplinary procedures: Investment20/20 staff

Where a disciplinary action is taken against Investment20/20 staff, it should be done so in accordance with the Investment Association’s disciplinary policy. 

14. Investment20/20 volunteers

Where it is an individual who is not an Investment20/20 employee, i.e., a volunteer, it is their employer who will be responsible for taking disciplinary action based upon their own processes and policy.

Contacts

[email protected]

 

Further information can be gained from the NSPCC Helpline: 0808 800 5000