star* scheme is committed to safeguarding and promoting the welfare of all children registered to the scheme. All children are entitled to feel safe and protected from any form of abuse and neglect, and have the right to take part in sport in a safe, positive and enjoyable environment. star* scheme recognises that this is the responsibility of everyone involved, in whatever capacity, within the organisation. 

Safeguarding and promoting the welfare of children is defined within statutory guidance “Working Together to Safeguard Children” as protecting children from maltreatment; preventing impairment of children’s health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes. 

This policy sets out a clear and consistent framework for delivering our commitment, in line with safeguarding legislation and statutory guidance. It will be achieved by;

• Ensuring that all trustees, core staff, advisers, freelancers, facilitators, and volunteers understand their responsibilities under safeguarding legislation and statutory guidance, are alert to the signs of child abuse, and know to refer concerns to the DSO. 

• Having clear guidelines so that the children and young people know how to keep safe and recognise behaviour that is unacceptable. 

• Creating a culture of safer recruitment by adopting procedures that help deter, reject or identify people who might pose a risk to children. 

• Providing a safe and welcoming environment where children are respected and valued; where the voice of the child is listened to and is paramount. 

Policy Statement

This policy statement is based on the following key principles:

• The welfare of the child is paramount

• All participants regardless of age, gender, sexual identity, ability or disability, racial origin, language, colour, nationality, ethnic or national origin, religious beliefs and/or size have the right to protection from harm.

• All allegations, suspicions of harm and concerns will be taken seriously and responded to swiftly, fairly and appropriately. Everybody who works or volunteers at star* has a duty of care to prevent abuse and to report any abuse discovered or suspected through the appropriate channels highlighted within this document.

• star* will work appropriately with local agencies to promote the welfare, health and development of children and to ensure that any concerns are reported and acted upon appropriately. 

• Children have a right to expect support, and personal and social development delivered by adults who are appropriately recruited, vetted and managed in relation to their participation in rugby union, whether they are playing, volunteering or officiating in the community or professional areas of the sport.

• Parents/guardians will be supported to engage with star*, and clear communication channels will be developed to facilitate this. 

• Core staff, facilitators, freelancers, trustees and volunteers will provide good role models of behaviour, in line with the principles of best practice when working with children, young people and adults.

Roles and responsibilities

star* scheme employees and volunteers

All adults who have contact with children and young people at star* scheme should: 

• Maintain an attitude of ‘it could happen here’ where safeguarding is concerned 

• Be proactive to provide a safe and secure environment

• Be prepared to identify children or families who may benefit from early help

• Be aware of the charity’s individual procedures that support safeguarding, including all policies, internal reporting procedures, information and engage with training provided 

• Be aware of the role and identity of the DSO and DDSO and seek them for advice if required 

• Undertake safeguarding training, including online safety training, during induction and subsequently on a regular basis 

• Be aware of, and understand, the process for making referrals to Children's Social Care, understanding that anyone can make a referral

 • Understand how to make a referral to CSC and/or the police immediately, if at any point there is a risk of immediate serious harm to a child 

• Be aware of and understand the procedure to follow in the event that a child confides they are being abused, exploited or neglected, in a timely manner 

• Maintain appropriate levels of confidentiality when dealing with individual cases 

• Reassure children and young people that they are being taken seriously, that they will be supported, and that they will be kept safe 

• Be aware of safeguarding issues that can put children at risk of harm 

• Be aware of behaviours linked to safeguarding issues such as drug-taking, alcohol misuse, deliberately missing education, sharing indecent images, extremist behaviours and other signs that children may be at risk of harm 

• Be fully aware of the importance of mental health in relation to safeguarding and that all staff should also be aware that mental health problems can, in some cases, be an indicator that a child has suffered or is at risk of suffering abuse, neglect or exploitation 

• Avoid victim-blaming attitudes and challenge it in a professional way if it occurs

• Understand the process for reporting concerns over staff or adult conduct or behaviours 

• Be aware of the indicators of abuse, neglect and exploitation. 

The role of the Designated Safeguarding Officer (DSO) and the Deputy Designated Safeguarding Officer (DDSO)

star* scheme has a DSO (Tom Kenny – 07528 483 800) and a DDSO (Sian Morgan – 07976 794 867). 

The DSO has overall responsibility for the safeguarding of children, young people and vulnerable adults who engage in activities provided by the organisation. The DDSO supports the decision making and management of safeguarding deputising for the DSO in their absence. The DSO and DDSO jointly take responsibility for safeguarding and child protection whilst creating a culture of safeguarding throughout the organisation, continually raising the profile of safeguarding by;

• Providing advice, support and expertise on child welfare, safeguarding and child protection matters

• Ensuring that all who work and volunteer at star* receive appropriate safeguarding training at induction. This is updated regularly, at least annually.

• Refer cases: - Where it is believed that a child is at risk of or is suffering significant harm, the charity will follow the procedures set out by the local Safeguarding Children Partnership arrangements 

• Liaise with staff and volunteers when deciding whether to make a referral by liaising with relevant agencies so that children’s needs are considered holistically

• Promote supportive engagement with parents in safeguarding and promoting the welfare of children, including where families may be facing challenging circumstances 

• Ensure effective communication and information sharing 

• Work with the trustees to ensure the Child Protection and Safeguarding Policy is reviewed annually, and the procedures are updated and reviewed regularly 

• Undergo DSO initial training and update this training with refresher training at least every two years to remain compliant  

Role of the Safeguarding Trustee

• Support the work of the DSO and DDSO team and provide advice and help when needed 

• Ensure effective communication and information sharing 

• Work with the trustees to ensure the Child Protection and Safeguarding Policy is reviewed annually, and the procedures are updated and reviewed regularly 

• Ensure that the strategic plans reflect safeguarding legislation, regulations specific to your activities, statutory guidance, and the safeguarding expectations of the Charities Commission

• Work with the senior leadership team and DSO regularly to review whether the things the organisation has put in place are creating a safer culture and keeping people safe.

• Check the organisation’s risk register reflects safeguarding risks properly and plans sensible measures to take. 

• Undergo charity trustee safeguarding training via the NSPCC website via  https://learning.nspcc.org.uk/training/safeguarding-charity-trustees and update this training with refresher training at least every two years to remain compliant

• Decide with the trustees if a safeguarding incident needs to be reported to the Charity Commission, this would be serious incidents that have resulted in or risk significant harm to beneficiaries and other people who encounter the charity through its work

 • Oversee safeguarding allegations against staff or volunteers, together with the senior leadership team and DSO.

• Be a point of contact if someone wishes to complain about a lack of action in relation to safeguarding concerns.

Role of coaches and volunteers (non-star* scheme staff) working at grassroots partner clubs involved with star* 

star* scheme will ensure that all clubs involved in star* have a safeguarding policy in place, which is written to the guidelines given by the Rugby Football Union (RFU) as stated on their website (https://www.englandrugby.com/governance/safeguarding), before engaging with them. 

All coaches working with the star* scheme at Grassroots level must have received Safeguarding training from the RFU, through the Play It Safe online or face to face course.

Coaches and volunteers who are delivering star* scheme at grassroots partner club level will be members of the clubs existing coaching workforce and will therefore be subject to the club’s safeguarding policy and procedures. 

In addition, star* scheme will communicate to all coaches and volunteers at grassroots clubs involved in star* scheme that they are expected to adhere to the Best Practice Guidance as issued by the RFU. In summary of that RFU guidance, the following are NOT acceptable and may result in disciplinary action being taken by, the CB or the RFU:

• Working alone with a child

• Consuming alcohol whilst responsible for children

• Providing alcohol to children or allowing its supply

• Smoking in the presence of children

• Humiliating children, including sarcasm

• Inappropriate or unnecessary physical contact with a child

• Participating in, or allowing, contact or physical games with children, in line with RFU regulation 15

• Having an intimate or sexual relationship with any child developed as a result of being in a ‘position of trust’

• Making sexually explicit comments or sharing sexually explicit material

Safeguarding Training 

star* scheme recognises the importance of ongoing training and development so that everyone is aware of emerging issues and keeping the ethos of safeguarding high. 

star* scheme employees (and staff volunteers who are not affiliated to a grassroots partner club) will undertake annual safeguarding training from the NSPCC website.

The DSO and DDSO will complete the following training annually https://learning.nspcc.org.uk/training/designated-safeguarding-officer-dso

All other eligible employees and volunteers will undertake the following training annually https://learning.nspcc.org.uk/training/introduction-safeguarding-child-protection 

Trustees with responsibility for safeguarding will undertake the following training annually https://learning.nspcc.org.uk/training/safeguarding-charity-trustees 

The induction training for staff and volunteers will cover: 

• The Safeguarding and Child Protection Policy

• The Code of Conduct 

• Appropriate child protection and safeguarding training 

• Information about the role and identity of the DSO and DDSO

• How to record concerns 

The Charity Manager will keep secure records of all inductions. 

Safer Recruitment of star* staff and volunteers

As part of the recruitment and selection process, offers of contract employment, voluntary work opportunities or placements to positions which involve working with children, young people, or vulnerable adults, are subject to satisfactory standard DBS disclosure and appropriate references. Adults will not be allowed to work unsupervised with children, young people and vulnerable adults until their DBS certificate has been received. 

Individuals are expected to take up the option to subscribe to the DBS Update Service themselves once the DBS check is complete, and claim this as an expense from star*. Once their DBS check expires with star* scheme, we provide individuals with another DBS check if they are not a member of the update service, and they are to work with us again. 

Health and Safety 

The star* scheme Health Safety & Wellbeing Policy gives guidance to those whose role involves working with children, young people, and vulnerable adults. Risk assessments must consider situations where there is the potential for safeguarding to be compromised in any way. In accordance with our Health and Safety Policy, all star* volunteers and coaches have a level of personal responsibility for their own safety. 

Reporting procedures

If any member of staff believes that a child or young person is in imminent danger then you must call the police on 999. 

It is important to report any concern you may have about a child, no matter how low level this may seem. 

In the first instance, staff must report any concerns to the DSO and DDSO by calling them on their mobile telephone numbers (Tom Kenny – 07528 483 800 / Sian Morgan – 07976 794 867) as soon as possible. 

In the second instance, staff must log their concern using the star* scheme safeguarding incident form which should be emailed to the DSO (tom@starscheme.co.uk) and the DDSO (sian@starscheme.co.uk). 

Dealing with a disclosure 

Do:

• Always treat any disclosures extremely seriously and act as if you believe what the child, young person or vulnerable adult is saying. 

• Tell the child or young person that they are right to disclose. (e.g.Thank you for telling me. You have done the right thing.)

• Reassure them that they are not to blame. (e.g. This is not your fault)

• Be honest about your own position – and about who you must tell and why you must report disclosures. 

• Where possible, tell the child what you are doing and when and keep them informed of what is happening. 

• Write down everything said and what was done. Keep a record of this and subsequent conversations, making sure any recorded information is factual and accurate. (e.g. I am going to write down what you say so that I don’t forget)

• Seek medical attention if necessary. 

• Inform parents or carers, unless there are grounds to believe they are involved in the abuse. 

• Remain calm and remember this is likely to be a stressful situation for the child, young person, or vulnerable adult. 

Don’t: 

• Make promises that you cannot keep, including a promise to keep secret.  

• Interrogate the child. It is not your job to carry out an investigation. This will be up to the police or social services. (e.g. ask the child ‘is there anything else you want to tell me?’ rather than specific direct questions)

• Cast doubt on what the person has told you. Don’t interrupt or change the subject.  

• Say anything that makes the child, young person or vulnerable adult feel responsible for the abuse. 

• Include your own opinion or interpretation in any written reports. It is important to make sure that what is written is an accurate reflection of what the child or young person has been telling you. 

• Avoid showing emotions, such as distrust, anger, or disbelief, as this may stop an individual from talking or make them feel your negative feelings being directed at them.

DSOs will make a referral to Children’s Social Care where there are concerns about a child's safety and well-being, especially if the child is believed to be suffering or likely to suffer significant harm. This includes situations where a child has been harmed, may have been harmed, or is at risk of harm. Immediate reporting is necessary if a child is believed to be in immediate danger, and the police or social care should be contacted immediately. 

Where a member of staff suspects radicalization, they will call the police on 101. The police are likely to ask the DSO to make a referral to the Prevent program. This referral is not an accusation of wrongdoing but a step to connect the individual with support to prevent them from being drawn into terrorism. The DSO should also assess the level of risk and consider whether other agencies need to be involved.  

Where a member of staff suspects female genital mutilation (FGM) may have occurred or is about to occur, they will inform the DSO and DDSO who is obliged to inform the police.

Concerns raised at a grassroots rugby club

If a disclosure or concern is raised about a child at a Grassroots Partner club, the concern will be shared with the club’s designated safeguarding lead, to be handled in line with the club’s safeguarding policy. This concern must still be reported to the DSO and DDSO at star* scheme.

If the designated safeguarding lead is unavailable, concerns will be reported to the relevant responsible child’s team within the local authority (DOLA/LADO), or the constituent body safeguarding team e.g. Somerset RFU, or straight to RFU Safeguarding team.

Any concerns which present an immediate and realistic threat to the wellbeing or safety of the child will be reported immediately to the Police. 

If a member of the star* team has a concern regarding a coach or club, or is dissatisfied with the process followed by a club, they will report it to the relevant responsible child’s team within the local authority (DOLA/LADO). 

Concerns raised at a school

If a disclosure or concern is raised about a child at a school, the concern will be shared with the school’s designated safeguarding lead or if unavailable to the Headteacher, to be handled in line with the school’s safeguarding policy. This concern must still be reported to the DSO and DDSO at star* scheme.

Concerns about the conduct of a member of staff at star* scheme

If a member of the star* team has a safeguarding concern regarding a star* employee or volunteer, it must be reported to the DSO and DDSO who will also share with the safeguarding lead of the relevant grassroots partner club. 

If a member of the star* team has a safeguarding concern regarding the DSO, it must be reported to the star* trustee responsible for safeguarding Siobahn Collingwood, siobahn@starscheme.co.uk / 07702074035.

Recording Procedures

star* scheme staff will use the following procedure when recording Safeguarding concerns and incidents.

• star* scheme staff must record all safeguarding incidents using the star* scheme incident log.

• Incident logs must be written factually with accuracy and objectivity avoiding opinions and feelings.

• Incident logs must be written with clarity and in chronological order.

  • Use phrases like, First x happened; Then y; After that, z.

• Incident logs must be written with specificity, and include dates, times, locations and full names.

• Incident logs will be stored securely and safely in the ‘Safeguarding’ shared drive accessible to the DSO and the DDSO.

Whistleblowing

Whistleblowing, which is the act of reporting malpractice or wrongdoing, is an essential component of a robust safeguarding framework, especially in organizations that work with vulnerable individuals. It allows individuals to raise concerns about potential harm or abuse without fear of reprisal, ensuring that issues are addressed promptly and appropriately. Sharing information or talking through a concern can be the first step to helping an organisation identify problems and improve their practices.

In the first instance, any concerns regarding a child should be raised with the DSO and DDSO. This may depend however, on the seriousness and sensitivity of the issues involved and who is suspected of malpractice of failing. 

All concerns will be treated in confidence and every effort will be made not to reveal the informant’s identity. It is important to be aware however, that any subsequent investigation of the concern(s), could lead to the person(s) against whom the concern was raised facing disciplinary proceedings or even Court proceedings. Under these circumstances, individuals may be required to come forward as a witness.

In every circumstance, star* scheme will ensure that the individual suffers no detriment or disadvantage for raising their concern. 

While the person with the concern is not expected to prove beyond reasonable doubt the truth of the allegation, they should be able to demonstrate to the person contacted, that there are reasonable grounds for concern. 

Where there are considered reasonable grounds for the concern, star* scheme will: 

• Conduct a management investigation; and

• Where appropriate refer the matter to the police or Local Authority; and

• Notify the placing Local Authority and RFU as required

Within five working days of a concern being raised, the individual raising the matter will receive a written acknowledgement. This will also indicate how the matter will be dealt with, given an estimate of how long it will take for a final response and seek their views on whether they feel the need for independent support during this process. 

The individual raising the concern will be notified in writing of the outcome of any investigation, as far as possible, within the company’s need to maintain the confidentiality of individuals. 

If a person considers that they have been victimised or discriminated against as a result of raising a concern, they may complain using the star* scheme’s complaints procedure or by contacting the Rugby Football Union (RFU) at safeguarding@rfu.com  

Similarly, if the person remains concerned and feels that the matter has not been properly investigated, they should contact the RFU at safeguarding@rfu.com 

Public Interest Disclosure Act 1998 (amended 2013) 

This Act is designed to protect individuals who make certain disclosures of information in the public interest. These disclosures are often referred to as ‘whistleblowing’ but the Act only covers employees, and therefore foster carers, Panel Members, and independent social workers are not included in the provisions of this Act. 

However, many of the organisations set up to provide support and advice for ‘whistle-blowers’ under the Public Interest Disclosure Act, will also provide valuable support and advice to those who are not employees but have similar concerns. 

Useful contacts and sources of information therefore include:

The charity Public Concern at Work have a whistleblowing advice line – 020 7404 6609 or by email whistle@pcaw.org.uk and their website can be found at http://www.pcaw.co.uk/ 

The NSPCC has a whistleblowing advice line – 0800 028 0285 or email help@nspc.org.uk 

Mental health and wellbeing 

Mental health problems and suicidal thoughts can affect anyone, of any age and of any background. Mental health problems are common among children and young people, but they can be difficult to identify. It is important that everyone working with children know the signs and symptoms of mental health problems. These will differ from child to child, but some common signs include:

• becoming withdrawn from friends and family

• persistent low mood and unhappiness 

• tearfulness and irritability

• sudden outbursts of anger 

• loss of interest in activities they once enjoyed

• problems eating or sleeping 

Children who are suffering from mental health problems may also be more vulnerable to harm. For example, exploitation, grooming and radicalisation. Mental health problems may also be indicators of abuse and neglect and child-on-child abuse.

If there is a suggestion that a child has been harmed or is at risk of harm, this must be raised immediately with the DSO and DDSO

Self-harm and suicidal thoughts

If the child or young person is felt to be acutely suicidal and you don't feel you can keep them safe, ring 999.

If you are concerned that they pose a serious risk to themselves then contact parents/guardians (unless it will pose a greater risk) so that they can be taken to A&E. 

Always contact the DSO and the DDSO team as soon as possible for help and advice or contact Children's Social Care if no one is available. 

Any child or young person who self-harms or expresses thoughts about this or about suicide must be taken seriously and appropriate help and intervention should be offered at the earliest point. A supportive response demonstrating respect and understanding of the child or young person, along with a non-judgmental stance, are of prime importance. It is essential to talk to the child or young person and establish: If they have taken any substances or injured themselves, if so, the severity of this and whether medical treatment is needed. If medical treatment (beyond basic First Aid) is required, then arrangements must be made to take the child or young person to A&E and parents should be contacted unless it is felt that this exposes the child or young person to greater harm.

Children with special educational needs and disabilities (SEND) 

star* scheme recognises the requirements of the Equality Act 2010 to ensure that no child is discriminated against on the grounds of disability (including in relation to admission to the scheme). Reasonable adjustments will be made to ensure that a child is not placed at a disadvantage compared to non-disabled children in the ways we organize and deliver our provision. 

We also recognise that children with Special Educational Needs or Disability (SEND) or Additional Educational Needs (AEN) can face additional safeguarding difficulties. There are additional risks and barriers which can exist. These can include: 

• assumptions that signs of possible abuse such as behaviour, mood and injury relate to the child’s disability, without further exploration

• being more prone to peer group isolation than other children

• the potential for these children to be disproportionately affected by behaviours such as bullying, without showing any outward signs 

• communication, challenges, barriers and difficulties in managing or reporting these challenges

• difficulty in being unable to understand the difference between fact and fiction in online content

• repeating content or behaviours without understanding the consequences of doing so.

Recognising and Responding to Abuse 

Abuse and neglect Abuse is defined as a form of maltreatment of a child which involves inflicting harm or failing to act to prevent harm.

Harm can include ill treatment that is not physical as well as the impact of witnessing the ill treatment of others – this can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse. Children may be abused in a family, institutional or community setting by those known to them or by others, e.g. via the internet.

Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by one or multiple adults or other children. 

Physical abuse is defined as a form of abuse which may involve actions such as hitting, shaking, throwing, biting, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical abuse can also be caused when a parent fabricates the symptoms of, or deliberately induces, illness in a child. Staff are aware of Female Genital Mutilation, a form of Physical abuse. 

Emotional abuse is defined as the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. 

This may involve conveying to a child that they are worthless, unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child the opportunities to express their views, deliberately silencing them, ‘making fun’ of what they say or how they communicate. 

It may feature age or developmentally inappropriate expectations being imposed on children, such as interactions that are beyond their developmental capability, overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction. 

It may involve seeing or hearing the ill treatment of another. It may involve serious bullying, including cyberbullying, causing the child to frequently feel frightened or in danger, or the exploitation or corruption of children. 

Some level of emotional abuse is involved in all types of maltreatment of a child, but it may also occur alone. 

Sexual abuse is defined as abuse that involves forcing or enticing a child to take part in sexual activities, not necessarily involving violence, and regardless of whether the child is aware of what is happening.

This may involve physical contact, including assault by penetration, or non penetrative acts, such as masturbation, kissing, rubbing, and touching outside of clothing. It may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can be perpetrated by people of any gender and age.

Sexual abuse can take place online, and technology can be used to facilitate offline abuse. 

Two thirds of sexual abuse cases are within the family. 

Neglect is defined as the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in serious impairment of a child’s health or development.

This may involve a parent or carer failing to provide a child with adequate food, clothing or shelter (including exclusion from home or abandonment); failing to protect a child from physical or emotional harm or danger; failing to ensure adequate supervision (including through the use of inappropriate caregivers); or failing to ensure access to appropriate medical care or treatment.

It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs. All staff and volunteers will be aware of the indicators of abuse and neglect and be vigilant and always raise concerns with the DSL. In addition, staff and volunteers understand that there are specific and emerging ways in which children can be abused and are aware of these specific issues, reporting any concerns, in the appropriate manner to the DSL.

Specific issues include (but are not limited to): 

Child on child abuse can take many forms. This can include (but is not limited to) bullying (including cyberbullying, prejudice-based and discriminatory bullying); sexual violence and sexual harassment; physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm; upskirting; initiating/hazing type violence and rituals; abuse in intimate personal relationships between children; consensual or non-consensual sharing of nudes or semi-nude images or videos, or causing someone to engage in sexual activity without consent.

Domestic abuse definitions in this policy are in line with the Domestic Abuse Act 2021, and is defined as abusive behaviour of a person towards another person where both are aged 16 or over and are personally connected. Abusive behaviour includes physical or sexual abuse, violent or threatening behaviour, controlling or coercive behaviour, economic abuse, psychological or emotional abuse, or another form of abuse. Domestic abuse can have serious, long lasting emotional impact on children, as victims in their own right, if they see, hear or experience the effects of domestic abuse. 

Child Criminal Exploitation (CCE) is defined as a form of abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into taking part in criminal activity, for any of the following reasons: 

• In exchange for something the victim needs or wants 

• For the financial advantage or other advantage of the perpetrator or facilitator 

• Through violence or the threat of violence (this could be online or through technology)

Specific forms of CCE can include: 

• Being forced or manipulated into transporting drugs or money through county lines.

• Working in cannabis factories.

• Shoplifting or pickpocketing. 

• Committing vehicle crime. 

• Committing, or threatening to commit, serious violence to others. 

Criminal exploitation of children can include County Lines. This is a geographically widespread form of harm that is a typical feature of county lines criminal activity: drug networks or criminal networks / gangs groom and exploit children and young people to carry drugs and money into one or more areas. Key to identifying potential involvement in county lines are missing episodes, when the victim may have been trafficked or the purpose of transporting drugs and a referral to the National Referral Mechanism should be considered in addition to normal safeguarding procedures. 

Child Sexual Exploitation (CSE) is defined as a form of sexual abuse where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child into sexual activity, for any of the following reasons: 

• In exchange for something the victim needs or wants 

• For the financial advantage, increased status or other advantage of the perpetrator or facilitator

• Through violence or the threat of violence, this could be online or through technology. 

Key indicators that a child is the victim of CSE may include 

• Appearing with unexplained gifts, money or new possessions. 

• Associating with other children involved in exploitation. 

• Suffering from changes in emotional wellbeing

• Misusing drugs or alcohol. 

• Going missing for periods of time or regularly coming home late.

• Having older boyfriends or girlfriends. 

• Suffering from sexually transmitted infections.

• Displaying sexual behaviours beyond expected sexual development.

• Becoming pregnant. 

Where CSE, or the risk of it, is suspected, staff will discuss the case with the DSO. If after discussion a concern remains, local safeguarding procedures will be triggered. 

Extremism & Radicalisation, for the purposes of this policy are defined as:

“extremism” is the promotion or advancement of an ideology based on violence, hatred or intolerance, that aims to: 

1. negate or destroy the fundamental rights and freedoms of others; or 

2. undermine, overturn or replace the UK’s system of liberal parliamentary democracy and democratic rights; or

3. intentionally create a permissive environment for others to achieve the results in (1) or (2) 

“radicalisation” refers to the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups. 

Concealed and Denied Pregnancy is when a woman knows she is pregnant but does not tell anyone; or when she tells a professional but conceals the fact that she is not accessing antenatal care; or when she tells another person or persons and together they conceal the fact from all agencies.

A denied pregnancy is when an expectant mother is unaware of or unable to accept the existence of her pregnancy. Physical changes to the body may not be present or be misconstrued; they may be intellectually aware of the pregnancy but continue to think, feel and behave as though they were not pregnant. 

There may be a number of reasons why a pregnancy is concealed or denied, including, but not limited to; fear of stigma or shame, in cases of rape, sexual or domestic abuse, forced or sham marriage, in cases of rape, sexual or domestic abuse, forced or sham marriage, fear of a child being removed or asylum seekers and illegal immigrants who may be reluctant to come to the attention of authorities. 

Modern slavery encompasses human trafficking and slavery, servitude, and forced or compulsory labour. This can include CCE, CSE, and other forms of exploitation. The DSL will also be aware of the support available to victims of modern slavery and how to refer them to the National Referral Mechanism (NRM) from The Modern Slavery Act 2015, Section 52). The public authority bears this obligation where it has ‘reasonable grounds to believe that a person may be a victim of slavery or human trafficking’: would liaise with a 'First responder Organisation' as detailed in part 4 of the guidance, to support and request a referral to the NRM. 

Female Genital Mutilation (FGM) is defined as all procedures involving the partial or total removal of the external female genitalia or other injury to the female genital organs. FGM is illegal in the UK and a form of child abuse with long-lasting harmful consequences. All staff will be alert to the possibility of a child or young person being at risk of FGM, or already having suffered FGM. If staff are worried about someone who is at risk of FGM or who has been a victim of FGM, they must inform the DSO who is required to share this information with CSC and/or the police. 

Forced marriage is defined as a marriage that is entered into without the full and free consent of one or both parties, and where violence, threats or any other form of coercion is used to cause a person to enter into the marriage. Threats can be physical, emotional, or psychological. A lack of full and free consent can be where a person does not consent or where they cannot consent, e.g. due to some forms of SEND. 

Forced Marriage is a crime in the UK and a form of honour based abuse (HBA). Staff who have any concerns regarding a child who may have undergone, is currently undergoing, or is at risk of forced marriage will speak to the DSL and local safeguarding procedures will be followed – this could include referral to CSC, the police or the Forced Marriage Unit. 

It will be made clear to staff members that they should not approach the pupil’s family or those with influence in the community, without the express consent of the child or young person , as this will alert them to the concerns and may place them in further danger.

Sextortion has seen a large increase in reports of children and young people being forced into paying money or meeting another financial demand after an offender has threatened to release nudes or semi-nudes of them. This is financially motivated sexual extortion, a type of online blackmail often referred to as ‘sextortion’. It is a form of child sexual abuse. 

At star*, we deeply value feedback and view complaints as an opportunity to learn and improve for the future, as well as a chance to put things right for the person, or organisation, that has made the complaint. Our commitment is to handle all concerns with fairness and care, reinforcing the trust placed in our community.

Our policy is:

• To provide a fair, accessible, and clear complaints procedure, designed to be straightforward for anyone wishing to raise a concern.

• To actively publicise the existence of our complaints procedure, ensuring our community knows how to connect with us.

• To empower everyone at star* to know precisely what to do if a complaint is received, including how to sensitively identify and appropriately escalate safeguarding concerns.

• To ensure all complaints are investigated with integrity, impartiality, and in a timely manner.

• To make sure that complaints are, wherever possible, resolved effectively, and that relationships are not only repaired but strengthened.

• To diligently gather insights from every complaint, helping us to continuously enhance our services and prevent recurrence, fostering a culture of ongoing learning.

What is a Complaint?

A complaint is any expression of dissatisfaction about any aspect of star* work, encompassing our fundraising and delivery efforts in the United Kingdom and beyond. We believe that every piece of feedback, whether big or small, helps us grow and evolve.

Where Complaints Come From

Complaints may come from any individual, volunteer or organisation who has a legitimate interest in star*, including the general public if something is perceived to be improper. A complaint can be received verbally, by phone, by email or in writing.

This policy does not cover complaints from staff, who should refer to the star* grievance policy.

Should a complaint received through this channel raise a safeguarding concern (e.g., relating to the safety or welfare of children or adults at risk), it will be immediately escalated and managed with utmost priority, according to the robust procedures outlined in the star* Safeguarding Policy.

Confidentiality

All complaint information will be handled sensitively, telling only those who need to know and following any relevant data protection requirements. This includes adherence to our Data Management Policy and Safeguarding Policy where applicable. We are committed to maintaining the trust of those who share their concerns with us.

Responsibilities

Trustees

Overall responsibility for this policy and its implementation lies with the Board of Trustees, ensuring that our commitment to transparent and effective complaint handling is upheld at the highest level.

Directors

The Directors of star* together with the Charity Manager are responsible for ensuring complaints are received, handled, and resolved with diligence, empathy, and in a timely manner.

 star* People

Every individual connected with star* has a responsibility to follow this policy when receiving and handling complaints about star*, contributing to a consistent and supportive experience for all.

Complaints Procedure

Publicised Contact Details for Complaints:

Written complaints may be sent to star* at:

1300 Aztec West,

Almondsbury,

Bristol

BS32 4RX

or by e-mail at info@starscheme.co.uk

Verbal complaints may be made in person to any star* representative at the appropriate grassroots club or star* event.

To streamline the process and ensure all necessary information is captured consistently, a dedicated complaints form is also readily available on our website.

How we will resolve complaints

Stage One

In many cases, a complaint is best resolved by the person responsible for the issue being complained about. If the complaint has been received by that person, they may be able to resolve it swiftly and should do so if possible and appropriate. Whether or not the complaint has been resolved, the complaint information should be passed to a Director or the Charity Manager within 5 business days.

On receiving the complaint, the Director or Charity Manager will record it in the complaints log. If it has not already been resolved, they delegate an appropriate person to investigate it and to take appropriate action. If the complaint relates to a specific person, they should be informed and given a fair opportunity to respond.

Complaints should be acknowledged by the person handling the complaint within five business days. The acknowledgement should say who is dealing with the complaint and when the person complaining can expect a reply. A copy of this complaints procedure should be attached. We aim for complainants to receive a definitive reply within one month. If this is not possible because, for example, an investigation has not been fully completed, a progress report should be sent with an indication of when a full reply will be given.

The reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint. Our goal is to provide a clear explanation and demonstrate our commitment to learning and improvement.

Stage Two

If the complainant feels that the problem has not been satisfactorily resolved at Stage One, they can request that the complaint is reviewed at Board level.

At this stage, the complaint will be passed by the Director or Charity Manager to the appropriate member of the Board of Trustees. The request for Board level review should be acknowledged within five working days of receiving it. The acknowledgement should say who will deal with the case and when the complainant can expect a reply.

The Board of Trustees may investigate the facts of the case themselves or delegate a suitably senior person to do so. This may involve reviewing the paperwork of the case and speaking with the person who dealt with the complaint at Stage One. The person who dealt with the original complaint at Stage One should be kept informed of what is happening.

Ideally, complainants should receive a definitive reply within a month. If this is not possible because, for example, an investigation has not been fully completed, a progress report should be sent with an indication of when a full reply will be given. Whether the complaint is upheld or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint. The decision taken at this stage is final, unless the Board decides it is appropriate to seek external assistance with resolution.

External Stage

As star* is registered with the Charities Commission of England and Wales, the complainant can complain to the Charities Commission at any stage. Information about complaints against charities can be found here:

https://www.gov.uk/complain-about-charity

Furthermore, if the complaint specifically relates to fundraising and the complainant remains dissatisfied after exhausting our internal procedures, they may also refer their complaint to the Fundraising Regulator. 

Comprehensive information on this process is available on the Fundraising Regulator's website: www.fundraisingregulator.org.uk.

Variation of the Complaints Procedure

The Board may vary the procedure for good reason. This may be necessary to avoid a conflict of interest, for example, a complaint about a Chair or trustee should not also have the Chair and/or trustee involved as a person leading a Stage Two review. Any such variation will be made with utmost transparency and communicated clearly to the complainant, always upholding the principles of fairness and impartiality.

Monitoring and Learning from Complaints

Complaints are reviewed annually to identify any trends which may indicate a need to take further action. This vital review process is formally documented, and key findings and actions taken are diligently reported to the Board of Trustees, driving continuous improvement across star* operations.