Norwich City of Sanctuary Safeguarding Policies

Norwich City of Sanctuary (NCoS) seeks to promote the inclusion and welfare of asylum seekers and refugees; to encourage and support statutory and non-statutory organisations and businesses to support and work with asylum seekers and refugees; to publicise and celebrate the contribution asylum seekers and refugees make to society and community.

NCoS believes that it is unacceptable for any child or adult to face hostility, discrimination or abuse of any kind and will endeavour to ensure that adults and children within its sphere of influence and practice are safeguarded to the best of our ability.

Within its Steering Group, NCoS has a safeguarding officer (SO) whose role is to ensure that NCoS undertakes its responsibilities regarding safeguarding seriously and effectively. The current officer is Alice Ndiaye who can be contacted on [email protected] 01603 774725

This policy is in two parts: safeguarding of children and safeguarding of vulnerable adults.

This policy is unable to cover every eventuality but anyone with concerns about a safeguarding issue is expected to alert a relevant body and/or our safeguarding officer. Proformas are available for use in such instances.

The policy has been guided by the following which also provide further information as required:

Care Act 2014 (amended 2020/2021)

Children Act 1989/2004 (updated 2019)

Children and Social Work Act 2017

The Data Protection Act 2018

Human Rights Act 1998

Mental Capacity Act 2005

Mental Health Resource Pack City of Sanctuary 2017

Protection of Freedoms Act 2012 (part 5)

Sexual Offences Act 2003

Rehabilitation of Offenders Act 1974 (updated 2023)

Safeguarding Vulnerable Groups Act 2006

UN Convention on the Rights of the Child 1989

Working Together to Safeguard Children 2023

Keeping Children Safe in Education 2024

Part 1: Safeguarding Children (Child Protection)

Principles

NCoS does not ordinarily provide direct services to children but is committed to safeguarding all children and young people who come into contact with its work.
All employees and volunteers working on behalf of NCoS accept personal and individual responsibility for the welfare of children they come into contact with
All employees and volunteers will raise any concerns they might have by following NCoS guidelines and reporting those concerns to a responsible person or body, including the NCoS Safeguarding Officer (SO)
All employees and volunteers should familiarise themselves with the NCoS safeguarding policy and develop an awareness of the signs of stress relating to safeguarding issues
A culture of mutual respect between children and those connected with NCoS will be encouraged and adults will be expected to model good practice
No representative of NCoS should work in isolation with a lone child
For the purpose of this policy, ‘child’ refers to anyone less than 18 years of age.
NCoS recognises that people seeking sanctuary can face additional safeguarding challenges that hinder the recognition of abuse and neglect in children from this group. Children from minority ethnic groups and those whose first language is not English, including the children of asylum seekers and refugees, face specific barriers, especially around communication, which may impact disclosure.

Guidelines

1 Issues causing harm to children:

Neglect: the persistent failure to meet a child’s basic physical, psychological or social needs. Short-term neglect may be due to poor adult supervision leading to harm
Sexual Abuse: the sexual exploitation of a child takes place where they are under the legal age of consent and/or they do not comprehend what they are being required to do. Adults may misuse their power over children for their own sexual needs. Matters may become worse where children are trafficked or groomed by adults
Physical abuse: actual or likely physical injury to a child, e.g. hitting, burning, shaking etc which also links with neglect where lack of supervision is involved
Emotional abuse: persistent emotional ill-treatment or rejection which includes a child being frightened, made to feel worthless, subject to constant/regular criticism, bullying or undue pressure to perform to high expectations.

Signs of physical abuse: this list is not exhaustive and can sometimes be misinterpreted.

Unexplained injuries/burns
Improbable excuses for injuries
Refusal to discuss injuries
Untreated injuries
Withdrawal from physical contact
Arms and legs covered (other than for cultural reasons) e.g.in hot weather
Fear of receiving medical help
Low self-esteem/neurotic behaviour
Compulsive behaviour e.g. stealing
Lack of social relationships

Signs of emotional abuse: again, not an exhaustive list

Lack of trust in adults/fear of an individual
Over-familiarity or provocative behaviour
Withdrawal and introversion/problems with peer relationships
Running away/sudden behaviour changes
Low self-esteem
Stealing/substance misuse/over-sexed behaviour
Sleeplessness/nightmares/fear of the dark
Depression/eating disorders
Recurring urinary tract problems/pregnancy

Specific Issues:

Child sexual exploitation- where children receive something (money/gifts/drugs etc or simply affection) in return for engaging in sexual activities. There is nearly always a control element involved and children may be groomed or bullied (including cyberbullying) over a substantial time period
Female genital mutilation may cause significant harm both physically and emotionally to children
Radicalisation refers to the process by which a young person may come to support terrorism. Multi-agency interventions seek to intervene to prevent this

These issues are complex and may not be revealed. Where NCoS staff, trustees or volunteers come across incidences, they should refer to the police and to the NCoS SO.

How concerns may arise

Self-observation e.g. The conduct of an individual, a child ‘disclosing’ abuse, evidence of physical hurt, inadequate support arrangements, from a third party

Should a child reveal they are being abused:

Reassure the child
Do not make promises you cannot keep, e.g.do not tell them that you will keep the information to yourself
Stay calm and ensure that the child is safe
Tell the child that you are going to inform someone
Do not approach the alleged abuser; where possible keep the child away from the alleged abuser
If you are working with a partner agency, report it to their lead person or some other reliable person
Contact the BCoS SO and agree one person to contact police and/or Social Care if required. If the SO is not available, take the relevant action
Complete the BCoS proforma and inform the SO – or Chair, should any complaint involve the SO

Role of the SO

Know which safeguarding/child protection agency to contact in the event of a concern
Liaise with the appropriate person where the complaint involves a partner organisation
Provide information about safeguarding/child protection to NCoS staff, trustees and volunteers
Appraise the Steering Group about any concerns and the actions stemming from them
Ensure that, where appropriate, staff and volunteers have a Disclosure and Barring Service (DBS) check
Initiate any internal investigation into concerns raised about NCoS staff or volunteers; ensure that there is no further contact between alleged victim and abuser
Ensure that appropriate records are kept following NCoS’ policy
Advise the Steering Group about any training needs
Ensure that this policy is regularly reviewed and updated

Useful Contacts

Local Authority Designated Officer (LADO) [email protected]
Norfolk County Council’s Children’s Advice and Duty Service direct line: 0344 800 8021.
NSPCC Child Protection Helpline- free 24-hour service offering counselling, and advice. 0808 800 5000
NSPCC Whistleblowing Advice Line- for professionals concerned about their organisation regarding safeguarding. 0800 028 0285 [email protected]

Part 2: Safeguarding Vulnerable Adults

Principles

All adults have the right to be safe from harm and should be able to live free from fear of abuse, neglect and exploitation (Protection)
For the purpose of this document, ‘adult’ means a person aged 18 years or over
NCoS has a Safeguarding Officer (SO) who is Alice Ndiaye who can be contacted on [email protected] 01603 774725 and whose role can be found in Part 1 of this policy (Safeguarding Children – para. 7).
All employees and volunteers working on behalf of NCoS have a duty to promote the welfare and safety of vulnerable adults and to familiarise themselves with this policy (Prevention)
Being a vulnerable adult may be a temporary condition, e.g. as a result of an accident, or may be more long-term and complex
Being an asylum-seeker or refugee does not necessarily mean that an adult is automatically vulnerable, but NCoS recognises that adults who are from minority ethnic groups, who may not speak English or who may be asylum-seekers or refugees may be at an increased risk of abuse and exploitation.

Whilst legislation does not provide any definition of vulnerability, para 66 of https://www.legislation.gov.uk/ukpga/2012/9/part/5/enacted makes it clear that vulnerability is determined (only) by the need for care and support due to clearly defined factors, primarily relating to age and disability.

NCoS will work in partnership with service providers and carers to safeguard anyone who we believe to be definable as vulnerable adults (Partnership)
NCoS will, wherever possible, involve vulnerable adults in decisions about making a safeguarding referral (Empowerment)

Guidelines

1 The Nature of Abuse

Abuse is a violation of an individual’s human and civil rights by any other person or persons. It may consist of a single act or repeated acts. It may be an act of neglect or an omission to act. It may happen when a vulnerable person is persuaded or coerced into a financial or sexual transaction to which s/he has not consented or is unable to consent. People can be abused in several ways:

Physical including hitting, slapping, pushing, kicking, misuse of medication, restraint or inappropriate sanctions
Sexual including rape and sexual assault or sexual acts to which the vulnerable adult could not consent or was pressurised into consenting
Psychological including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, control, withdrawal of supportive networks
Financial or material including theft, fraud, exploitation, pressure regarding wills, property or financial transactions or the misuse and/or misappropriation of personal finances/goods etc.
Neglect and acts of omission including ignoring medical or physical needs failure to provide appropriate health, education or social care services, withdrawal of medicines, food, heating etc.
Discriminatory including racist, sexist discrimination or that based on disability, age, sexuality etc
Institutional including rigid and insensitive routines, lack of privacy or comfort.
Modern slavery includes human trafficking, forced labour and domestic servitude. It may take the form of organisational abuse or domestic abuse. Any of the above forms of abuse might present themselves under this abuse.
Self-neglect includes lack of care for personal hygiene, hoarding, not taking medication, poor nutrition etc.

2 Signs and Symptoms of Abuse

Physical- history of unexplained falls or minor injuries; bruising in protected areas; finger marks; burns; bruising in the shape of an object; injuries in various stages of healing; history of GP or agency hopping; differing accounts; weight loss; ulcers or bed sores; drowsiness
Sexual- disclosure or partial disclosure; medical problems such as genital infections or pregnancy; disturbed behaviour e.g. depression, withdrawal, sleeplessness or nightmares, self-harm, inappropriate sexual behaviour; circumstantial- e.g. 2 people found in a quiet location, one in a distressed state
Psychological/emotional- isolation; unkempt or unwashed; over-meticulous; inappropriately dressed; withdrawn or agitated; change in appetite; insomnia or excessive sleep; tearfulness; low self-esteem; confusion
Neglect- poor physical condition; poor clothing; inadequate diet; untreated injuries/medical problems; poor personal hygiene
Financial/Material- unexplained or sudden inability to pay bills; unexplained or sudden withdrawal/closure of accounts; disparity between assets and satisfactory living conditions; excessive interest in their accounts by others

Institutional, Modern Slavery and Self-neglect may feature any of the signs or symptoms of the other forms of abuse.

3 Disclosure

Where a disclosure is made or observations lead to the possibility that there has been abuse, make sure that both yourself and the victim are safe. If there are immediate concerns, ring 999. If the alleged abuser is present, do not confront them.
Where possible, discuss the nature of the abuse with the victim. Reassure them. Do not investigate. Explain that you need to refer the situation in order to get help. Unless there is a clear lack of capacity, obtain the victim’s agreement for referral. Where interpreters are in use, ensure that they have understood that the information gathered is confidential
Make sure that you take notes of all the key points and check details for accuracy. If there is evidence of criminal activity, preserve the evidence.
As soon as possible, contact the SO who will make any onward referral should that be necessary. Complete the NCoS proforma as soon as possible and within 24 hours.

4 Role of the SO

Once a referral is made, progress that referral to an appropriate agency (police, adult social services, local mental health team)
Consider capacity and consent. Consent for referral must be obtained unless the vulnerable adult lacks the mental capacity to make a decision, where others might be at risk, or where a crime has been committed.
The SO should collate all relevant material/evidence etc including liaising with others involved e.g. witnesses
Where a member of staff, trustee or volunteer is suspected of perpetrating abuse, then the SO should liaise with the Chair of NCoS to consider whether that person needs to be suspended from NCoS activity pending a full investigation. The SO would normally lead such an investigation.
Identify and inform trustees of any new training requirements regarding vulnerable adults
Ensure that records are secured and kept in line with NCoS policy.
Ensure that this policy is regularly reviewed and updated

Complaints Policy & Procedure

Norwich City of Sanctuary is committed to creating a positive and inclusive environment for refugees, people seeking sanctuary, volunteers, staff, and the local community.

We value feedback and take all complaints seriously. This policy outlines how complaints will be handled, ensuring that they are addressed in a fair, transparent, and timely manner.

We commit to reviewing this policy every year and will publish on our website for ease of access.

Scope

This Complaints Policy applies to all Norwich City of Sanctuary activities, including but not limited to:

● Activities and events organised by Norwich City of Sanctuary.

● The behaviour of Norwich City of Sanctuary volunteers, staff, and partners.

How to Make a Complaint?

Informal Complaints:

○ We encourage individuals to address concerns informally, where possible. If someone is dissatisfied with an aspect of our service, we recommend they speak directly with our chair or volunteer involved.

○ Many issues can be resolved through a respectful conversation, and we encourage a solution-oriented approach.

Formal Complaints:

○ If a concern cannot be resolved informally, individuals should submit a formal complaint in writing to our coordinator. Complaints can be submitted via:

■ Email: [email protected]

What to Include:

○ The nature of the complaint (what happened).

○ Details of the individual(s) involved.

○ Any steps already taken to resolve the issue (if applicable).

○ Any supporting evidence (e.g., emails, photos, records of communication).

○ Preferred outcome or resolution (if applicable).

Complaints Procedure

Acknowledgment:

○ Once a complaint is received, it will be acknowledged as soon as possible.

Investigation:

○ The complaint will be investigated by an appointed member of the Steering Group who will gather facts, review evidence, and interview relevant parties.

○ We will aim to complete the investigation as soon as possible.

Resolution:

○ After completing the investigation, we will inform the complainant of the outcome and any actions taken. This may include:

■ An apology or explanation.

■ A change in practice.

■ Referral to external bodies if necessary (e.g., local authorities, regulatory bodies).

Outcome Review:

○ If the complainant is dissatisfied with the outcome, they can request a review of the decision. This review will be conducted by different member of the group who was not involved in the original investigation.

○ The review process will be completed as soon as possible.

Anonymous Complaints

● Norwich City of Sanctuary will accept anonymous complaints, though it may be more difficult to investigate these effectively without specific details.

● Whenever possible, we will respond to anonymous complaints and take appropriate action.

Unreasonable Complaints

We are committed to addressing all complaints fairly and thoroughly. However, we recognize that some complaints may be unreasonable due to their nature or frequency. Unreasonable complaints may include those that are excessively repetitive, malicious, or unrealistic, or those where no clear or actionable issue is raised. In such cases, we reserve the right to limit our response or refuse to engage further.

We aim to resolve all complaints in a constructive manner, but we also strive to maintain a balanced approach, ensuring resources are focused on addressing legitimate concerns.

Complaints about Norwich City of Sanctuary

In the first instance you must contact Norwich City of Sanctuary directly to raise your complaint.

If after the group’s complaints procedure has been exhausted and the complainant is not satisfied they can raise the complaint with City of Sanctuary UK. However, the complaint will only be investigated by City of Sanctuary UK if the complainant has sufficient evidence that:-

● A group has acted contrary to the values of City of Sanctuary;

● What a group has done, or not done, is of such a serious nature that it has brought the City of Sanctuary name and reputation into disrepute.

Complaints should be sent to the Chief Officer. If following an investigation, the Chief Officer finds sufficient evidence to justify the complaint they will refer the matter to the trustees to decide whether the group will be removed from the network.

City of Sanctuary UK complaints policy

Complaints about an awarded mainstream institution/organisation

Initial complaints will need to go to the organisation concerned. You may wish to check with Norwich City of Sanctuary whether the organisation concerned is an awarded institution/organisation and whether this was processed by Norwich City of Sanctuary or City of Sanctuary UK.

If the organisation was awarded by City of Sanctuary UK, Norwich City of Sanctuary will notify the relevant member of staff at City of Sanctuary UK. The complaint will therefore be handled by City of Sanctuary UK using their complaints procedure.

If the organisation was awarded by Norwich City of Sanctuary the following process will be followed.

Norwich City of Sanctuary will only investigate a complaint if the relevant award criteria are no longer being met.

In the first instance the person should raise the complaint directly with our chair without going into the formal complaint’s procedure. Complaints will be handled informally by the chair, in the first instance.

During the investigation the person handling the complaint will consider the following key questions:-

1. Has the organisation acted contrary to City of Sanctuary values?

2. Is what the organisation has done/not done of such a serious nature that it has brought the City of Sanctuary name and reputation into disrepute?

If following an investigation, the person handling the complaint has sufficient evidence to be able to answer these questions in the affirmative it will decide whether to revoke the organisation of its award. In this instance, City of Sanctuary UK will be notified.

Confidentiality

● Complaints will be treated in confidence, and only those who need to know will be informed.

● However, in certain circumstances, information may need to be shared with external authorities (e.g., if the complaint relates to safeguarding concerns, criminal behavior, or illegal activities).

Monitoring and Review

● The Complaints Policy will be reviewed annually to ensure it is effective and continues to meet the needs of the organization and those we serve.

● Data on complaints will be monitored to identify any trends or areas where improvements can be made.

Contact Information

● Complaints Officer: Norwich City of Sanctuary Coordinator, [email protected]

● Safeguarding Officer: Alice Ndiaye [email protected]

Norwich City of Sanctuary

Policies