Child Safeguarding Policy

Wupwoo Ltd


This policy is relevant to children 9 months – 18 years old  

  1. Policy Statement.
  2. Scope and Eligibility 
  3. Policy Purpose 
  4. Wupwoo Child Safeguarding Principles 
  5. Minimum Standards For Child Safeguarding
  6. Child Safeguarding Responsibilities and Accountabilities 
  7. Breaches of the Child Safeguarding Policy  
  8. Contact With Children 
  9. Child Criminal Exploitation (County Lines)
  10. Reporting 


At Wupwoo, we believe in the inherent rights, freedom, dignity and equality of all people, including children. Children can be extremely vulnerable, especially in situations and deserve higher standards of protection. Furthermore, intersections of various factors such as class, gender, race, sexual orientation, disability, further increase a child’s vulnerability to child abuse and exploitation. 

Whilst Wupwoo is not specifically a child focussed organisation, we come into contact with children in the course of our work. In the delivery of our work, Wupwoo is committed to upholding the rights of children, and safeguarding them against actions (intended or unintended) that place them at risk of all forms of violence and harm, including child abuse and exploitation. 

It is Wupwoo’s policy to create and proactively maintain an organisational culture and operational environments which prevent and deter any actions and omissions, whether deliberate or inadvertent, that place children at the risk of any kind of child abuse. All those who are associated with the delivery of Wupwoo’s work are expected to promote and be part of creating a child safe environment. Additionally, they are explicitly prohibited from engaging in any activity that may result in any kind of child abuse. We will take positive action to prevent child abusers becoming involved with Wupwoo in any way and will not tolerate child abuse in any form. It is the responsibility of all those working on behalf of POSM to raise any concerns they have or concerns which are reported to them according to this policy. 

Wupwoo respects, and will generally work to strengthen communities in which it works. It is Wupwoo’s policy to comply with legislation whenever it is safe to do so. This includes local and child welfare and protection legislation. The requirements of this Child Safeguarding Policy are in addition to any other applicable legal requirements. 

Children may be abused by a wide range of people, including relatives and family members, professional staff, paid care workers, volunteers, other service users, neighbours, friends and associates, people who deliberately exploit vulnerable people, and strangers.

Any violations of this policy will be treated as a serious issue and will result in disciplinary action being taken, including termination and any other available legal remedy. 


This policy applies to all Wupwoo Employees and those associated with the delivery of Wupwoo’s work both during and outside normal working hours. 


This policy will demonstrate Wupwoo’s commitment to protect children from all harm and sexual abuse, including sexual and criminal exploitation and abuse, physical abuse, emotional abuse and neglect. The policy and its accompanying implementation guidelines and toolkit have been developed to provide a practical guide to prevent child abuse and enhance child safeguarding within Wupwoo’s work. They aim to create an open and aware environment where concerns for the safety and wellbeing of a child can be raised and managed in a fair and just manner, giving primacy to the best interests of the child. The responsibility for maintaining child safe environments is a shared responsibility of all those associated with Wupwoo’s work, with the aim to translate the policy into the everyday culture and practice of the Company with regard to: 

The Policy defines the guiding principles, approach and standards to be met in different aspects of our work to ensure Wupwoo is a child safe organisation. 


Wupwoo Child Safeguarding Policy and practices are guided by the following principles:

In all actions concerning children and when dealing with a concern for the safety or wellbeing of a child, the best interests of the child shall be our primary consideration. Wupwoo believes children have the right to be active participants in all matters affecting their lives; that they can make choices and decisions; that they have the right to share the power adults hold and that they have a voice to influence people and events. Decisions made about children and young people will be made as far as possible with their participation and in their best interest giving full consideration to how such decisions will affect them. There may be times when adults have to make decisions for children in order to protect them from harm, but their best interest will be at the heart of those decisions at that time. In the event this policy is breached causing harm, Wupwoo is committed to listening and acting according to the wishes of the child.

Wupwoo has a zero-tolerance approach to child abuse and exploitation. This is enacted via robust prevention and response work, offering support to survivors and holding those responsible for harm and intolerable behaviour to account. Wupwoo will ensure all those associated with the delivery of our work have access to information about how to report concerns or allegations of child exploitation, abuse or other breaches of this policy and will take immediate action upon report of any suspected breach.

Wupwoo believes child safeguarding is a shared responsibility, meaning that successful implementation of child safeguarding measures is reliant on all those associated with the delivery of our work having access to this policy and guidance for its best-practice implementation; knowing and understanding their responsibilities and commitment to upholding child safeguarding principles. Wupwoo will ensure all those who work on behalf of the organisation with children and vulnerable populations will receive training in relation to Child Safeguarding. This training will be carried out on a regular basis. In addition, those with specific responsibilities will receive additional training commensurate with their role. Wupwoo will also ensure that all partner organisations involved in the delivery of our work have appropriate child safeguarding measures to implement the minimum standards outlined in this Policy.

Wupwoo has a duty of care to provide protective environments for children in all operations and activities. Wupwoo will act with intention and foresight to ensure child safeguarding risks are identified, monitored and mitigated against in the assessment of its operations and partner operations – to prevent the risk of a child being abused, exploited or harmed. A risk management approach does not diminish the fact Wupwoo has a zero tolerance approach to breaches of this policy. It is expected that child safeguarding will be considered when planning, as well as during a project.

Wupwoo will continue to strengthen its child safeguarding systems to ensure accountability to children, their families and the communities in which it works. Specific child safeguarding roles and responsibilities will be delegated to staff to effectively embed child-safe organisational practice across all programs, operations and activities. Wupwoo will ensure an organisational child-safe culture which is transparent about safeguarding issues occurring within Posm, in line with privacy regulations and within legal frameworks and where any issues or concerns of child safeguarding or poor practice can be raised and discussed.

Wupwoo is committed to confidentiality in sharing sensitive information in relation to child safeguarding incidents reported to us. Information that identifies individuals will only be shared with due consideration to the safety of the child, witnesses or subject of complaint, or to protect the integrity of an investigation.

Wupwoo commits to creating and maintaining a safe organisational culture where all those whom Wupwoo serves and who work for Wupwoo feel empowered to insist on non-discriminatory and respectful behaviour from each other, where poor behaviour is not accepted, and where power is not abused. The safeguarding of children within Wupwoo’s work is all of our responsibility, and must be considered in every aspect of our work. A commitment to good practice is expected of all Wupwoo’s employees. Wupwoo Safeguarding advisors and teams strive to offer the best service and advice possible and to stay apprised of sectoral and general best practice in Child Safeguarding. Wupwoo is open to feedback, continual learning and improvement in order to ensure that safeguarding children is at the centre of our work. 


Below are the  Child Safeguarding (CS) minimum standards for the implementation of this Child Safeguarding Policy. These minimum standards apply to all Wupwoo operations, programs and projects. 

  1. A) Ensure all those associated with the delivery of our work adhere to the behaviour standards 

outlined in Sec.10 “Contact with Children” when working with or in contact with children. 

  1. B) Ensure child safe recruitment and selection procedures are in place.
  2. C) Ensure all those associated with the delivery of our work are equipped with knowledge, skills and awareness to keep children safe through the provision of appropriate training, including the emerging issues of digital safeguarding, domestic violence, forced marriage, female genital mutilation, unaccompanied minors, child sexual exploitation, criminal explotation and trafficking, race, racism and extremism where relevant. 
  3. D) Ensure clearly documented, contextually appropriate and child-friendly reporting Procedures are in place for managing concerns, suspicions or allegations of child exploitation and abuse, and breaches of the Wupwoo CS Policy and that also consider local laws and referral systems.
  4. E) Ensure the identification and appointment of Wupwoo people with clearly articulated responsibilities to coordinate/lead child safeguarding work (including incident management and reporting).
  5. F) Ensure effective child safeguarding risk management practices which capture and address risks to children as a result of coming into contact with Wupwoo. This will require undertaking a risk assessment to identify any potential risks to children and document steps to mitigate these.
  6. G) Ensure Wupwoo CS minimum standards are clearly communicated and adhered to by partner organisations involved in the delivery of our work through their own policies and procedures. 
  7. H) Ensure that communities and the people we work with are proactively informed about Wupwoo’s child safeguarding minimum standards and the reporting procedures for raising any concerns relating to child safeguarding. 
  8. I) Ensure appropriate procedures, protocols and processes are established and followed for ethical management of personal data relating to children so as to not put children at risk. 
  9. J) Ensure the Wupwoo Digital Safeguarding for the safe use of information and communication technologies, such as the Internet, social networking sites, and digital photography, so as to not put children at risk.



Creating a safe working environment at Wupwoo is everyone’s responsibility and failure to act on concerns or disclosures relating to child abuse and exploitation is not an option. 

Wupwoo Managers and Directors are accountable for this Policy and its implementation. Managers are responsible for promoting awareness of this policy with people they manage. Overall responsibility for identifying individuals who particularly work with children and ensuring that they receive appropriate levels of child safeguarding training commensurate with the risk profile of their role lies with Managers. Managers must prioritise child safeguarding awareness raising for themselves and their teams including, contractors, partners working with them and communities involved in Wupwoo’s programs and provide budget lines for such activities. Affiliate Safeguarding Leads, Safeguarding Teams and senior management teams should offer further support to help implement this Policy. 

Managers at all levels have a particular responsibility to support and develop systems that create and maintain a safe working environment. This means employees and those working on behalf of Wupwoo know how Wupwoo expects them to behave, how they can raise complaints and concerns, and that Wupwoo will take action when they do. Managers at all levels are also responsible for ensuring child safeguarding good practice with regard to risk management assessments of activities and implementation of corresponding mitigations to ensure child safety. 

All those associated with the delivery of Wupwoo’s work are required to report any suspicions or incidences of child abuse or exploitation or any other behaviour in contravention of this policy. This can be done without sharing details of cases if information was given in confidence. Failure to report to a relevant person suspicion of misconduct relating to a child is a breach of Wupwoo’s policy, and could lead to disciplinary action being taken against the employee. 

Staff away from the main office should adapt child safeguarding policies & practices in collaboration with local stakeholders. They should work with managers and Heads to undertake child safe checks . 

If an allegation is made against you, then you must inform your manager immediately. You should create a signed and dated record of the details as you know them. All subjects of complaint will be treated with respect and all allegations will be treated confidentially. You may wish to seek support from your Union or Staff Representative (where applicable) if you are an employee. 


Breaches of the Policy will not be tolerated and may result in disciplinary procedures, including termination. Wupwoo will take action against anyone, whether they are the subject of a complaint or not, who seek or carry out retaliatory action (such as but not limited to harassment, intimidation, unfair disciplinary action or victimisation) against complainants, survivors or other witnesses. Employees who are found to do this will be subject to disciplinary action, up to and including termination of employment. 

If a Wupwoo employee is found to have made an allegation that they knew to be false they will be subject to disciplinary action, up to and including termination of employment. Others who work on behalf of Wupwoo will be subject to action that may result in the termination of their relationship with Wupwoo. 


Those associated with the delivery of Wupwoo’s work must:

 – Conduct themselves in a manner consistent with Wupwoo’s values and the Child Safeguarding Policy. 

– Treat all children with respect regardless of their race, colour, gender (including gender diverse children), language, religion, opinion, nationality, ethnicity, social origin, property, disability, sexual orientation or other status. 

– Immediately disclose all charges, convictions and other outcomes of an offence that they are subject to and relates to child exploitation and abuse, including those under traditional law, which occurred before or occurs during association with Wupwoo.

– Utilise Wupwoo training and awareness sessions to increase their understanding of what constitutes various elements of child abuse.

– Never use language or behaviour towards children that is inappropriate, harassing, abusive, sexually provocative, intended to humiliate or culturally inappropriate.

– Never engage children in any form of sexual intercourse or sexual activity, including paying for sexual services or engaging in other transactional forms of sexual services with any person under 18 years old.

– Never engage in any sort of child abuse whether sexual, physical, emotional, neglect, grooming, harassment or exploitation via digital or other means. 

– Never engage in family violence which can include (but is not limited to) female genital mutilation, child marriage, trafficking and child labour.

– Wherever possible, ensure that another adult is present when working near children.

– In the capacity of my engagement with Wupwoo, not visit a child’s home alone or invite unaccompanied children into your own home or accommodation, unless they are at immediate risk of injury or in physical danger.

– Comply with all relevant legislation, including labour laws in relation to child labour.

– Not use physical or humiliating punishment on children.

– Not to consume alcohol or illicit drugs when working with or in contact with children. 

– Not discriminate against or act in favour of particular children to the exclusion of others. 

– Not seek to make contact or spend time with any child connected with Wupwoo programs or 

activities outside of the designated program or activity time. 

– Not abuse their position to withhold professional assistance, or give preferential treatment, gifts or payment of any kind to a child, or another person in relation to a child in order to solicit any form of advantage or sexual favour from a child. 

– Not engage in physical contact with a child that is: unprofessional, abusive, unnecessary or excessive, that makes a child feel uncomfortable or unsafe, or in a culturally insensitive way (necessary physical contact would include attending to an injured child or removing a child from a dangerous situation). 

– Not engage in child labour, including hiring of children for domestic or other labour: which is inappropriate given their age or developmental stage, which interferes with their time available for education and recreational activities, or which places them at significant risk of injury. 

– Not do things for children involved in Wupwoo programs, activities or events of a personal nature 

that they can do for themselves such as toileting, bathing or changing their clothes. 

– Not use any computers, mobile phones, video cameras, cameras or social media to exploit or 

harass children, or access child sexual exploitation material through any medium. 

– Not condone or participate in behaviour with children which is illegal, unsafe or abusive.

– Immediately report concerns for the safety or wellbeing of a child, or a possible breach of the 

Child Safeguarding Policy in accordance with the Child Safeguarding Reporting Procedures. 

– Speak with Management about any concerns you have of any involvement in any situation where words, actions or behaviour may be interpreted as a breach of this Policy.

– Act professionally towards children with whom you interact, whilst at the same time showing genuine care and compassion.

– To ensure the privacy and safeguarding of children when photographing or filming a child or using children’s images or stories for work-related purposes including promotion, fundraising and development education.


9.1 Criminals are deliberately targeting vulnerable children – those who are homeless, experiencing learning difficulties, going through family breakdowns, struggling at school, living in care homes or trapped in poverty. 

These criminals groom children into trafficking their drugs for them with promises of money, friendship and status. Once they’ve been drawn in, these children are controlled using threats, violence and sexual abuse, leaving them traumatised and living in fear.

However they become trapped in criminal exploitation, the young people involved feel as if they have no choice but to continue doing what the criminals want.

9.2 This link is to the Home Office guidance about criminal exploitation of children and

vulnerable adults: County Lines guidance


10.1 Externally Facing Reporting Information On all Wupwoo websites, information will be provided for the general public, communities and partners on how to raise a concern or complaint. Relevant email and phone contact details should also be provided. 

– Complaints mechanisms should also be visible in the Wupwoo office, in communities where POSM is working and at Wupwoo events and campaign activities. Wupwoo partners should have similar processes of communicating reporting procedures. 

10.2 Child Friendly Reporting Information and Processes Children rarely speak up about abuse or violence against them. If we provide the mechanisms, trusted adults and a safe environment then we increase the likelihood that children will let us know when they are being harmed or feel unsafe. There are many ways in which children can have a voice in creating a child safe and friendly environment and Wupwoo operations and activities should consider these to enhance child safety. 

10.3 How to Raise a Complaint or Concern Anyone can raise a concern or make a complaint to Wupwoo about something they have experienced or witnessed without fear of retribution. You can do this verbally or in writing or emailing safeguarding to the Safeguarding Team. Employees can also choose to raise concerns with their Line Manager. 


10.4 Requirement for Proof Wupwoo does not expect all those associated with the delivery of its work to be child safeguarding experts or to have conclusive facts before making a report. People are required to report any knowledge or concern, founded or otherwise, that they may have of a child safeguarding incident occurring. Those with knowledge or suspicions should not gather evidence, speak to other colleagues or the child involved, or investigate the incident themselves. 

10.5 Confidentiality, Safety and Wellbeing Noting that the wellbeing of the child is of paramount importance at all times, Wupwoo is committed to the confidentiality, safety and wellbeing of all involved in any report of a child safeguarding incident, including the individuals who have reported the incident and the individual against whom the allegation is made. When responding to allegations, Wupwoo will ensure all those involved are treated fairly, and that the rights of each individual are respected during an investigation and any applicable disciplinary process. Confidentiality must be maintained throughout the complaints process by all involved. Employees who breach confidentiality will be subject to disciplinary action up to and including termination of employment.  

11. Sexting

12. Cyberbullying

13. Online Extremism


For the purposes of this Policy and Wupwoo’s approach to Child Safeguarding, these definitions apply: 


Child: Any person under the age of eighteen (18) years as defined by the Convention on the Rights of the Child. 

Child Rights: Children have the “right to life, survival and development” where development 

encompasses physical, emotional, cognitive, social and cultural development. 

Child Safeguarding: The policies, procedures and practices employed to safeguard children who come into contact with Wupwoo and all those associated with the delivery of our work from all forms of harm, abuse or exploitation and the responsibility of all personnel to embed these at the activity level to ensure Wupwoo is a child safe organisation. 

Child Protection: The prevention of and response to significant harm, abuse, neglect, exploitation and violence against children. Child Protection programming is an activity or initiative designed to protect children from all forms of violence. This includes the integration of child protection into all thematic areas of programming to enhance the protective environments for children in the community 

Child Abuse: Child abuse involves the abuse of children’s rights and includes all forms of violence against children: physical, emotional and sexual abuse, neglect, family violence, sexual exploitation, abduction and trafficking, including for sexual purposes, involvement of a child in online child sexual exploitation and child labour as defined below. 

Physical Abuse: When a person purposefully injures, or threatens to injure a child. Physically abusive behaviour includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning. It also includes cultural practices which can alter physicality in ways that cause distress, harm and/or cause lasting health ramifications, such as Female Genital Mutilation. 

Neglect: The persistent failure, where there are means, or the deliberate denial to provide the child with clean water, food, shelter, sanitation or supervision or care to the extent that the child’s health and development is placed at risk. 

Emotional Abuse: A persistent attack on a child’s self-esteem. Examples include, but are not 

limited to name-calling, threatening, ridiculing, shaming, intimidating or isolating the child.

Child Sexual Abuse: When a child is used by another child, adolescent or adult for his or her own sexual stimulation or gratification. Sexual abuse involves contact and non-contact activities which encompasses all forms of sexual activity involving children, including exposing a child to online child sexual exploitation material, or taking sexually exploitative images of children.

Family violence: Includes verbal, physical, sexual or emotional violence within the household or family, which the child witnesses, usually on a regular basis.

Commercial Sexual Exploitation of Children: Comprises sexual abuse by the adult and remuneration in cash or kind to the child or a third person or persons. The child is targeted as a sexual object and as a commercial object. The Commercial Sexual Exploitation of Children constitutes a form of coercion and violence against children and amounts to forced labour and a contemporary form of slavery. 

Modern slavery: Encompasses slavery, human trafficking, forced labour and 

domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment. 

Online Child Sexual Exploitation: Includes all acts of a sexually exploitative nature carried out against a child that have, at some stage, connection to the online environment. It includes any use of Information and Communication Technologies (ICT) that results in sexual exploitation or causes a child to be sexually exploited or results in or causes images or other material documenting such sexual exploitation to be produced, bought, sold, possessed, distributed or transmitted 

Child Marriage: A formal marriage or informal union before age 18, is a reality for both boys and girls, although girls are disproportionately the most affected. Child marriage is widespread and can lead to a lifetime of disadvantage and deprivation. 

Grooming: Generally, refers to behaviour that makes it easier for an offender to procure a child for sexual activity. For example, an offender may build a relationship of trust with the child, and then seek to sexualise that relationship (for example favouring a child, isolating a child, giving excessive attention or gifts, using sexualised language or physical contact, or exposing the child to sexual concepts through online sexual exploitation material). 

Online-Facilitated Child Sexual Abuse: The act of sending an electronic message to a recipient who the sender believes to be under 18 years of age, with the intention of procuring the recipient to engage in or submit to sexual activity with another person, including but not necessarily the sender; or of sending an electronic message with indecent content to a recipient who the sender believes to be under 18 years of age. 

Child Labour: Often defined as work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. It refers to work that is mentally, physically, socially or morally dangerous and harmful to children and interferes with their schooling and recreation. In its most extreme forms, child labour involves children being enslaved, separated from their families and exposed to serious hazards and illnesses. 

Child Trafficking: Relates to any role in the recruitment, transportation or receipt of children for the purpose of exploitation, by means of threat, force or other forms of coercion. This includes abuse of power. 

Military use of Children: Where children are engaged in or exposed to military activity, including as soldiers or human shield. 

Contact with Children: Working on an activity or in a position that involves or may involve direct (including online contact with children) or indirect contact (such as the use of children’s images) with children. This can be either under the position description or as a result of performing the position, such as coming into contact with children when working in communities.

Working with Children: Working with children means being engaged in an activity with a child where the contact would reasonably be expected as a normal part of the activity and the contact is not incidental to the activity. Work includes volunteering or other unpaid work. 

Female genital mutilation (FGM) is a procedure where the female genitals are deliberately cut, injured or changed, but there’s no medical reason for this to be done. It’s also known as female circumcision or cutting, and by other terms, such as sunna, gudniin, halalays, tahur, megrez and khitan, among others. FGM is usually carried out on young girls between infancy and the age of 15, most commonly before puberty starts. It’s illegal in the UK and is child abuse. It’s very painful and can seriously harm the health of women and girls. It can also cause long-term problems with sex, childbirth and mental health.

Legal framework

This policy has been drawn up on the basis of law and guidance that seeks to protect children, namely: 

Safeguarding officer: Peter Martin. 

Deputy: Charles Thompson.

If you should have any child safeguarding issues that you would like to discuss with Wupwoo then please contact us using the following email address. 

Company number: 07865444


Review Date: June 2020