This policy summarises current working practices in relation to safeguarding children and young people of any age, who may be at risk of abuse in the context of Bright World Education and Guardianships. The document details the policy aims, safeguarding measures, Safer Recruitment, response to individual concerns, use of IT and the internet, Information Sharing and Confidentiality. The policy is linked to the Child Protection Policy and supports requirements of AEGIS (Association for the Education and Guardianship of International Students) accreditation and Travel Safe guidance.
This policy is linked to Bright World Guardianships’ Child Protection Policy and describes the policy aims, safeguarding measures, Safer Recruitment, response to individual concerns, use of IT and the internet, information sharing and confidentiality. The policy is linked to the Child Protection Policy and supports requirements of AEGIS accreditation and Travel Safe guidance. Travel Safe were a child protection charity set up by Avon and Somerset Police to lead safeguarding of children and young people away from home, particularly in the global youth travel sector. The charity has since closed. Bright World are working in partnership with a replacement accreditation body called SAFE (Safeguarding Associates for Excellence).
This policy focuses on the measures in place for students of any age who are under the care of Bright World Guardianships Ltd, with the best interests of the student being at the centre of our work.
In line with our mission statement, this policy supports Bright World Guardianships’ duty and commitment to safeguard and promote the welfare of students and our aim to create a culture of vigilance.
The mission statement is made with reference to Statutory Guidance for Schools and Colleges on Safeguarding Children and Safer Recruitment in Education, Department for Education, July 2015; Keeping Children Safe in Education, September 2022; Working Together to Safeguard Children, 2018; National Guidance for Child Protection in Scotland, 2014; Social Services and Well-being (Wales) Act 2014; and ‘What to do if you are worried that a child is being abused’ March 2015. Bright World Guardianships’ policies and processes are in line with the requirements of the Association of Education and Guardianship of International Students (AEGIS), National Minimum Boarding Standards and sector specific accredited training experts.
Bright World Guardianships refers to various expert sources advice on child abuse and safeguarding, for example National Society for the Prevention of Cruelty to Children (NSPCC) website, Barnardo’s and the Local Safeguarding Partnerships (LSP) when developing policies and managing incidents.
Local Agency Contacts
The company is aware of how to access local agency contacts; this includes Local Safeguarding Partnerships across the country and how to access locally agreed inter-agency procedures and guidance. In addition, the company is aware of the non-emergency reporting procedures via the Local Authority’s Children’s Services relevant to the area or Multi-Agency Safeguarding Hub (MASH), or by telephoning the non-emergency Police number 101. For emergency situations, the company is aware of the need to contact the relevant police force for the area by dialling 999, this includes in Wales and Police Scotland.
A link to the list of Local Safeguarding Partnerships can be found here.
The specific LADO’s for the West Sussex area where our Head Office is based, are:
Contact: LADO should be contacted either by email: LADO@westsussex.gov.uk or by phone, LADO Consultation Contact No. 0330 222 6450 (9.00am – 5.00pm)
The company is aware that in Scotland, for a non-emergency referral or concern they can contact the local children’s social work team. Their contact details can be found on the website for the local authority the child lives in. Alternatively they can contact the local office of Scottish Children’s Reporter Administration: https://www.scra.gov.uk/contact-us/
The company is aware that in Wales for a non-emergency referral or concern they can contact the local child protection services. Their contact details can be found on the website for the local authority the child lives in.
Bright World Guardianships Contacts
Bright World recognises that safeguarding children is the responsibility of everybody and the owners and directors of the company have appropriate safeguarding training and oversight of company practices.
The Designated Safeguarding Leads for the Company are:
Lana Foster, Managing Director who can be contacted on 01273 835745 or email@example.com (also Prevent Lead)
James Foster, Commercial Director who can be contacted on 01273 835745 or firstname.lastname@example.org
Robbie Piper, Senior Guardianship & Safeguarding Manager who can be contacted on 01273 835745 or email@example.com
Concerns in relation to the Managing Directors should be addressed to the Guardianship & Safeguarding Manager, Robbie Piper. Concerns in relation to the Senior Guardianship & Safeguarding Manager, Robbie Piper, should be addressed to Lana or James Foster. Concerns about any of the above can be directed to Crimestoppers which will remain confidential.
1. Application of this policy
This policy applies to all full-time, part-time, contracted, agency and volunteer staff including those who do not have cause to come into direct or regular contact with students in order to carry out their daily duties. This policy also applies to those who provide homestay accommodation for our students and third party contractors.
2. Aims of the policy
2.1 This policy aims to:– ensure that Bright World Guardianships students have a safe and child-centred environment which promotes and prioritises their safety and well-being, accepting that children with special educational needs and disabilities can face additional safeguarding challenges - support children’s development by protecting them from specific safeguarding issues and all forms of child abuse - create a culture of safe recruitment, adopt procedures that help deter, reject or identify people who might abuse children and create an environment where staff remain vigilant - ensure that all Bright World Guardianships staff have a valid enhanced DBS check, understand their role and responsibility in respect of identifying safeguarding opportunities and reporting child protection concerns, are provided with regular training opportunities for staff to help them develop their knowledge, understanding and professionalism (refer to Professional Code of Conduct – Bright World Staff Handbook) - ensure that appropriate action is taken in the event of incidents or concerns of abuse being reported to Bright World staff and that support is provided to individuals who raise or disclose the concern - ensure that confidential, detailed and accurate records of all safeguarding concerns are maintained and securely stored
2.2 The policy will be reviewed every year after development or sooner if in response to changes in legislation/government guidance, as required by the LSP and as a result of any other significant change or event.
3. Safeguarding Policy and Key Principles
3.1 Bright World Guardianships’ understands ‘Safeguarding’ to be a recognised multi-agency pro-active process for protecting children at risk of harm or potential abuse. Effective safeguarding will reduce the need for action to protect children from harm.
3.2 Bright World Guardianships is aware of the national threat of child sexual abuse cases (recent and historical) as per the Strategic Policing Requirement March 2015, that protecting children is a matter of national importance and working together with schools and partners is critical in our work.
3.3 Child abuse is a form of maltreatment of a child by inflicting harm or by failing to act to prevent harm.
Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults or by another child or children.
Bright World aims to protect children from the four main types of abuse:
Physical abuse – may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child or failing to protect a child from that harm. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces illness in a child.
The NSPCC says that some signs and indicators of physical abuse are:
commonly on the head but also on the ear or neck or soft areas – the abdomen, back and buttocks
defensive wounds commonly on the forearm, upper arm, back of the leg, hands or feet
clusters of bruises on the upper arm, outside of the thigh or on the body
bruises with dots of blood under the skin
a bruised scalp and swollen eyes from hair being pulled violently
bruises in the shape of a hand or object.
Burns or scalds:
can be from hot liquids, hot objects, flames, chemicals or electricity
on the hands, back, shoulders or buttocks; scalds may be on lower limbs, both arms and/or both legs
a clear edge to the burn or scald
sometimes in the shape or an implement for example, a circular cigarette burn
multiple burns or scalds
usually oval or circular in shape
visible wounds, indentations or bruising from individual teeth.
Fractures or broken bones:
fractures to the ribs or the leg bones in babies
multiple fractures or breaks at different stages of healing
Other injuries and health problems:
effects of poisoning such as vomiting, drowsiness or seizures
respiratory problems from drowning, suffocation or poisoning
Sexual abuse – involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, or encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for sexual abuse. This form of abuse can happen online and technology can be used to facilitate abuse offline. Sexual abuse is not solely perpertrated by adult males. Women can also commit acts of sexual abuse, as can other children.
The NSPCC says some signs and indicators of sexual abuse are as follows:
Children who are sexually abused may:
Stay away from certain people
they might avoid being alone with people, such as family members or friends
they could seem frightened of a person or reluctant to socialise with them.
Show sexual behaviour that’s inappropriate for their age:
a child might become sexually active at a young age
they might be promiscuous
they could use sexual language or know information that you wouldn’t expect them to.
Have physical symptoms:
anal or vaginal soreness
an unusual discharge
sexually transmitted infection (STI)
Emotional abuse – is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. Emotional abuse may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. This form of abuse may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to 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, though it may occur alone.
The NSPCC says some signs and indicators of emotional abuse may be that:
Babies and pre-school children who are being emotionally abused or neglected may:
be overly-affectionate towards strangers or people they haven’t known for very long
lack confidence or become wary or anxious
not appear to have a close relationship with their parent, e.g. when being taken to or collected from nursery etc.
be aggressive or nasty towards other children and animals.
Older children may:
use language, act in a way or know about things that you wouldn’t expect them to know for their age
struggle to control strong emotions or have extreme outbursts
seem isolated from their parents
lack social skills or have few, if any, friends.
Neglect – Neglect is the ongoing failure to meet and child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development and is the most common form of child abuse. Neglect may occur during pregnancy, for example, as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision
(including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
The NSPCC says some signs of neglect are as follows:
*Neglected children may: *
be smelly or dirty
have unwashed clothes
have inadequate clothing, e.g. not having a winter coat
seem hungry or turn up to school without having breakfast or any lunch money
have frequent and untreated nappy rash in infants.
They may have:
untreated injuries, medical and dental issues
repeated accidental injuries caused by lack of supervision
recurring illnesses or infections
not been given appropriate medicines
missed medical appointments such as vaccinations
poor muscle tone or prominent joints
skin sores, rashes, flea bites, scabies or ringworm
thin or swollen tummy
faltering weight or growth and not reaching developmental milestones (known as failure to thrive)
poor language, communication or social skills.
They may be:
living in an unsuitable home environment for example dog mess being left or not having any heating
left alone for a long time
taking on the role of carer for other family members.
3.4 In addition, this policy aims to protect children and young people from other forms of child abuse by ensuring staff are aware of signs and symptoms of the four main types of abuse which could indicate:
Radicalisation and extremism
Child trafficking including Child Sexual Exploitation
‘Honour Based’ Violence – Female Genital Mutilation, Breast Ironing and Forced Marriage
Cyber-bullying and bullying Grooming
Harmful sexual behaviour and Child on Child abuse
County Lines (As set out in the Serious Violence Strategy, published by the Home Office, a term used to describe gangs and organised criminal networks
involved in exporting illegal drugs into one or more importing areas within the UK, using dedicated mobile phone lines or other form of ‘deal line’. They are likely to exploit children and vulnerable adults to move and store the drugs and money, and they will often use coercion, intimidation, violence (including sexual violence) and weapons)
The vulnerability of children who take drugs, abuse alcohol, truant and send sexually explicit photographs or messages via mobile phone (sexting) is recognised as putting children in additional danger, and considered during the management of incidents and the annual student safeguarding review. Bright World also aims to be alert to the potential need for early help for children who have special educational needs or disabilities.
3.5 Bright World Guardianships has individual policies for the following types of child abuse:
Radicalisation and extremism
‘Honour Based’ Violence – Female Genital Mutilation (FGM), Breast Ironing and Forced Marriage
Some signs and indicators of FGM are:
-A family arranging a long break abroad during the summer holidays.
-Unexpected, repeated or prolonged absence from school.
-Academic work suffering.
-A child may ask a teacher or another adult for help if she suspects FGM is going to happen or she may run away from home or miss school.
A girl or woman who’s had female genital mutilation (FGM) may:
-have difficulty walking, standing or sitting
-spend longer in the bathroom or toilet
-appear withdrawn, anxious or depressed
-have unusual behaviour after an absence from school or college
-be particularly reluctant to undergo normal medical examinations
-ask for help, but may not be explicit about the problem due to embarrassment or fear.
Sexting – youth produced imagery
Child Sexual Exploitation
(NB: The statutory definition of Child Sexual Exploitation from Department for Education – Child Sexual Exploitation – Definition and a guide for practitioners, local leaders and decision makers’ (February 2017) is: Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.
Potential indicators of child sexual exploitation are:
going missing for periods of time or regularly coming home late
regularly missing school or education or not taking part in education
appearing with unexplained gifts or new possessions for example mobile phones, drugs, alcohol, cigarettes;
excessive receipt of texts/phone calls;
spending time at places of concern or of known sex work, such as hotels or known brothels;
get involved in gangs, gang fights, gang membership and/or isolation from peers/social networks;
concerning use of internet or other social media;
not know where they are because they have been moved around the country;
associating with other young people involved in exploitation;
having older boyfriends or girlfriends;
suffering from sexually transmitted infections;
mood swings. self-harm or changes in emotional wellbeing;
drug and alcohol misuse; and
displaying inappropriate sexualised behaviour;
increasing secretiveness around behaviours;
relationships with controlling or significantly older individuals or groups;
evidence of/suspicions of physical or sexual assault.
Part One of ‘Keeping Children Safe in Education’ (2022) and ‘What to do if you’re worried a child is being abused’ (2015) outlines the signs and symptoms of the different forms of child abuse. The documents contain examples of relevant signs which staff may notice in information from the students, schools, Local Coordinators or other staff member for example.
3.6 This policy should be used read in conjunction with ‘Working Together to Safeguard Children 2018’, ‘Keeping Children Safe in Education 2022’ and the LSP guidance in the area. The policy is in line with requirements of AEGIS accreditation and Travel Safe guidance (Avon and Somerset Police).
3.7 Bright World understands ‘Child Protection’ to be a part of safeguarding and promoting welfare. The term refers to the activity undertaken to protect specific children who are suffering or at risk of suffering significant harm. Refer to Bright World Child Protection Policy – Operations Manual.
3.8 The mission statement of the company is “Bright World is committed to safeguarding and promoting the welfare of children and young people and expects all staff and volunteers to share this commitment”.
‘Safeguarding and promoting the welfare of children is defined as: “protecting children from maltreatment, preventing impairment of children’s health or development; ensuring that children are growing up in circumstances consistent with the provision of safe and effective care”, and “undertaking that role so as to enable those children to have optimum life chances and to enter adulthood successfully (Sussex LCSB, September 2015)
3.9 Bright World works to ensure that all members of staff are aware that the responsibility for specific safeguarding issues and child protection from all forms of abuse belongs to everyone, and that families, communities and professionals must work together to promote their welfare.
3.10. Bright World Guardianships Designated Safeguarding Leads (DSL) are Lana Foster (firstname.lastname@example.org), James Foster (email@example.com) & Robbie Piper (firstname.lastname@example.org).
Concerns about any member of staff must be reported to the DSL or directly to a statutory authority including Crimestoppers or the NSPCC Whistleblowing Hotline.
3.11 The DSL has lead responsibility for safeguarding and child protection and is expected to:
- refer cases of suspected abuse to the local authority children’s social care as required;
- support staff who make referrals to local authority children’s social care;
- refer cases to the Channel programme where there is a radicalisation concern as required;
- support staff who make referrals to the Channel programme;
- refer cases where a person is dismissed or left due to risk/harm to a child to the Disclosure and Barring Service as required;
- refer cases where a crime may have been committed to the Police as required.
- liaise with the head teacher or principal to inform him or her of issues especially ongoing enquiries under section 47 of the Children Act 1989 and police investigations;
- as required, liaise with the “case manager” and the designated office and
- liaise with staff on matters of safety and safeguarding and when deciding whether to make a referral by liaising with relevant agencies; and
- act as a source of support, advice and expertise for staff.
3.12 Bright World Head Office Staff are trained by Safe.co to Level 3 and Local Coordinators are trained to Level 1 (with renewal training being at least every 2 years). The Accommodation and Travel Department, the Guardianship & Safeguarding Manager and the Managing Directors are Safer Recruitment trained and this is due for renewal every 3 years. Annual safeguarding refresher training is made available to staff at the yearly conference. Level 1 training (Awareness of Safeguarding) has also been made available to all host families and taxi companies online with a request for completion.
3.13 Bright World is committed to providing all employees with a healthy and safe work environment which allows complaints to be dealt with and resolved within Bright World, without limiting a person to pursue the resolution of their complaint with the relevant statutory authority. Refer to ‘Understanding bullying, discrimination and harassment’ policy and procedure; Whistle Blowing Policy; Welfare, Health and Safety Policy – Bright World Staff Handbook.
All staff, Local Coordinators and Host Families are encouraged to read Keeping Children Safe in Education (Part 1 and Annexe A):
4. Safeguarding measures, training and development
4.1 Bright World Guardianships students are provided with a safeguarding handbook and membership card which details the 24 hours 7 days a week emergency number should they wish to speak a Guardianship Care Manager from Head Office.
4.2 Students are provided with the telephone number and email address of their Local Coordinator (‘Bright World Buddy’) as an alternative means of contacting a member of staff with any concerns or issues.
4.3 Students are provided with information on what to do if they need help of advice while in the UK. The leaflet is a safeguarding measure and outlines to students where they can go to obtain help and support if they are troubled. The leaflet includes contact details for (amongst other organisations) the NSPCC, Samaritans and Police.
4.4 We aim to ensure that the students in our care experience at all times a caring and secure environment in which they feel safe, respected and valued. In pursuit of this aim, Bright World Guardianships undertakes the following:
1. To train Head Office staff to a minimum of Level 3 Child Protection training with Local Co-ordinators being trained to a minimum of Level 1. Head Office staff maintain the responsibility of responding to CP concerns raised by students, other guardianship personnel, host families and transfer companies.
2. To ensure Head Office staff record any allegations/concerns in an incident in IBOS and refer them to the Senior Guardianship & Safeguarding Manager Robbie, or DSL, Lana. Where appropriate concerns will be reported to the relevant Children’s Services Duty team or Multi Agency Safeguarding Hub (MASH) in the local area.
3. To ensure that a Bright World On Duty Manager is available for advice and guidance if staff are not sure whether a referral to Children’s Services is required. The On Duty Manager is able to contact Lana Foster and James Foster for advice in relation to referrals.
4. To ensure that all guardianship personnel and partners, (for example travel companies and host families where possible) receive CP Awareness Training and to make them and the students in our care aware of the need to report allegations and suspicions of child abuse to Head Office. In cases where the strategic leads are unavailable, staff must make direct contact where appropriate with the local Children’s Services (Scotland/Wales) or MASH On Duty Team, as delay could put a child/Young Person at further risk of harm. Contact with the local Children’s Services (Scotland/Wales) or MASH is made via the telephone numbers available on the Local Authority website.
5. To promote an environment of trust, openness and clear communication between students, school and Bright World Guardianship staff and our Host Families, so that student welfare, safety and pastoral care is recognised as the top priority
6. To respond to any reported allegation or suspicion of child abuse in accordance with the Bright World guidelines and those set out in the Child Protection Procedures of the Association for the Education and Guardianship of International Students (AEGIS) and to take children’s wishes and feelings into consideration when determining what action to take and services to provide.
7. To ensure that all guardianship personnel and personnel offering outsourced services who come into direct contact with students in our care, are recruited using safe recruitment practices and are formally screened through the completion of an Enhanced DBS check
8. To maintain links with the appropriate Agencies who have a statutory responsibility to deal with child welfare and child protection concerns. If you have any reason to believe that a child in your care is suffering from any form of abuse or neglect then please report it immediately in confidence to Robbie Piper or Lana Foster by telephone at the office or out of hours via the emergency telephone.
9. To circulate regular safeguarding and child protection updates to all staff and partners (where possible) to ensure that the most current and comprehensive information is made available to them.
5. Safer Recruitment
5.1 Safer recruitment of staff members (including Local Co-ordinators and Host Family Inspectors) and partners (host families and travel companies), is aligned to the Department for Children, Schools and Families ‘Safeguarding children and safer recruitment in education’ (2010).
5.2 The document sets out the highest standards of safeguarding and promoting the welfare of children and recruitment best practice (some areas underpinned by legislation) for schools, local authorities and further education sectors. The guidance contained within this document is relevant for Bright World Guardianships who are responsible for children (under 18’s) and who work in partnership with schools, colleges and universities.
5.3 Bright World Guardianships has individual policy and process documents for staff, travel companies and host families which are designed to maximise the safeguarding and welfare of our students according to the role being performed:
5.3.1 Safer Recruitment for Staff Members
18.104.22.168 Bright World Guardianships has a Safer Recruitment Policy and Process document for staff which includes Head Office Staff, Local Coordinators and Host Family Inspectors.
22.214.171.124 The recruitment of staff in accordance with the principles of Safer Recruitment ensures that employees are recruited in an effective and secure way, and is designed to deter candidates who would be unsuitable to work with children.
5.3.2 Safer Recruitment of Transfer Companies and the Safeguarding Travel Policy
126.96.36.199 Bright World Guardianships has a specific safeguarding policy for the recruitment of transfer companies and taxi drivers. The policy outlines the requirements for accrediting a new transfer company and for the on-going monitoring of the company.
188.8.131.52 Bright World Guardianships has a Travel Operations Policy and Process which ensures that our internal processes afford the highest levels of safeguarding to our students. The policy outlines the processes for booking transfers, sending taxi requests and confirmations to guarantee that students are safely transported to and from their destinations.
184.108.40.206 There is a safeguarding policy for students during a transfer (including shared journeys and ad-hocs), including safeguarding a student at the airport (escort to terminal, unaccompanied minors, and Airport Angels). The policy is called ‘Student Transfers including airports’ Policy and Procedure.
5.3.3 Safer Recruitment for Bright World Host Families
220.127.116.11 Bright World Guardianships has a specific safeguarding policy for the recruitment of Host Families who care for students for periods of less than 28 days, for example during half terms, exeat weekends, periods of sickness or other occasions when the school is closed. Bright World Guardianships does not, in general, provide private fostering for students (i.e. for periods over 28 days) though is aware of the mandatory duty to inform the local authority of children where such arrangements exist.
18.104.22.168 The Safer Recruitment Policy outlines the processes which ensure the highest level of safeguarding is afforded to our students while staying with a host family.
22.214.171.124 Safer Recruitment influences the process from planning and point of advertising to post induction of a new host family, including on-going monitoring through the initial, revisit and spot check process.
6. Responding to individual safeguarding concerns
6.1 Bright World ‘Child Protection Policy and Procedure’ (Policy Manual) outlines the procedures for dealing with reports or information of a child protection nature. The same reporting procedure is used for responding to safeguarding incidents.
6.2 Staff must respond promptly to any safeguarding concerns including allegations against staff members, host families or local coordinators or allegations of Child-on-Child abuse and submit their concerns in writing as per Section 4 of the Child Protection Policy – Indicators of child abuse and response to individual concerns and Section 5 – Receipt of a suspected report of child abuse by the Designated Safeguarding Lead.
6.3 Incidents of students being reported as absent or missing from Bright World Guardianship (for example half terms or exeat weekends), must be dealt with as per the Bright World Absent or Missing Student Policy. Students who are reported as absent or missing from school premises during term time are accommodated by the relevant school’s missing student policy.
6.4 As general guidance, schools have the lead on any incidents which happen during the term time with Bright World have the lead on any incidents which happen during an event (for example exeat weekend, half term or during a period of expulsion/suspension where the student is with a Bright World Host Family).
6.5 All reports to Bright World from Local Coordinators, schools, Guardianship Care Managers and students are initially regarded as children in need. The Deputy or Designated Safeguarding Lead is notified. The Bright World database system (IBOS) record is created on the Guardianship Student Record in order for the incident to be effectively managed, the safety of the student to be maximised and any risk to be minimised. Any report pertaining to Child Protection will be automatically classified as a RED incident.
6.6 The IBOS incident is investigated through (where appropriate) discussions with the school, parents, LC’s, existing records and other agencies as appropriate. Parental consent for referral will be sought unless the child may be at risk of significant harm or there may be the risk of a loss of evidential material. All verbal conversations should be recorded in writing.
6.7 The information is evaluated on the day of receipt and a decision made and recorded regarding the next course of action and/or outcome. This could include no further action (with the provision of information and advice or signposting to another agency), Bright World Emergency Meeting to decide on future actions, or emergency action to protect a child through the statutory authorities (e.g. Police or Social Services) where there is a risk to the life of a child or the possibility of serious immediate harm. (Refer to Bright World Absent or Missing Student Policy).
6.8 A member of the Senior Management Team must review, approve the outcomes of the incident and ensure the record has been updated. Members of the Senior Management Team are Lana Foster, James Foster, Su Warren and Charlotte Hamson.
6.9 Where a crime may have been committed the police must be informed at the earliest opportunity, and they will decide whether to commence a criminal investigation. The reporting of the matter to the police must be recorded in the IBOS record.
6.10 There is a Major Incident Contingency Plan (Emergency Procedures) Policy, also contained within this manual for large-scale emergency incidents.
7. Bright World Guardianships Professional Code of Conduct for Staff
7.1 Bright World Guardianships Staff Handbook outlines the Professional Code of Conduct for staff members which includes acceptable practice and behaviour to avoid:
7.2 Bright World Guardianships recognises that the vast majority of adults who work with our students act professionally and in the best interests of the child. There may be occasions when there are interactions with students which can lead to tensions and misunderstandings with students. This section aims to reduce the risk of these occasions in the interest of the student and the member of staff, and adheres to the guidance detailed in the Safer Recruitment Consortium’s ‘Guidance for safer working practice for those working with children and young people in education settings’ (October 2015).
7.3 This guidance outlines what is expected in terms of professional behaviour, provides clear advice about what constitutes unacceptable behaviour and what might be considered as misconduct. The information provided details safe practice and the behaviours which should be avoided. If a member of staff does not follow this code of conduct this may lead to disciplinary or legal procedures.
7.4 Bright World Guardianships staff should be aware of their own conduct and ensure that their professional practice is clear and unambiguous. Staff should ensure that they work in an open and transparent way, not showing favouritism and by treating students respectfully and fairly irrespective of culture, disability, gender, language, racial origin, religious belief and sexual orientation.
7.5 The purpose of this guidance is to provide help to staff to establish the safest and most supportive environment for our students to secure the well-being and very best outcomes for the students under our guardianship.
7.6 This Code of Conduct should be read in conjunction with:
- Bright World Guardianships Child Protection Policy and Whistle Blowing Policy
- Department for Education “Keeping Children Safe in Education Part 1 and Annex A” (September 2022)
- Department for Education “Guidance for Safer Working Practices” (2015)
7.7 Bright World Guardianships recognises that this guidance may not cover every eventuality. There may be times when staff use their professional judgement to deal with situations not outlined in this section. In such circumstances staff should always advise their senior colleagues of the justification for any action taken or proposed.
7.8 Bright World staff should not give gifts to students on a regular basis and should not give gifts of any significant value. Similarly, such gifts should not be given to the families of students as this could be interpreted as a gesture to groom or bribe a student. Where a reward is given to a pupil this should be in accordance with agreed practice, consistent with the behaviour policy and not based on favouritism.
7.9 Where staff members become aware that a student may be trying to form an inappropriate relationship with a Bright World representative, the staff member should report any indications and/or incidents to a senior manager. Staff members should always maintain professional boundaries. Senior managers should implement an action plan to manage the concern(s) raised. The plan should respond sensitively to the child and staff member and maintain the dignity of all, while being regularly monitored and reviewed.
7.10 The Bright World Guardianships Social Media Policy states that staff members should not give their personal contact details to students for example email address, home or mobile telephone numbers or details of web based identities. If students locate these by any other means and attempt to contact or correspond with the staff member, they (staff member) should not respond and must report the matter to their line manager. Students and staff should communicate for professional reasons using the company email addresses and telephone numbers.
7.11 A host family can never take the place of a parent in providing physical comfort and should be cautious of any demonstration of affection. Host family members are advised to avoid physical contact with students as even when well intentioned, this contact may be misconstrued by the student, an observer or any person to whom this action is described. There may also be cultural, gender sensitive or religious reasons about touching which the host family member is not aware of. Host family members must be aware that any physical contact with a student may need to be explained and would be open to scrutiny. Where a student is upset or distressed (for example due to homesickness) remember that sympathy and help can be given using kind words. Also, sitting with the student and listening to them until they feel better can also be of great comfort. Host families should, therefore, use their professional judgement at all times and in cases where this may be unavoidable (for example a young child who has fallen over, makes physical contact with the primary carer first or is crying with homesickness), we would recommend asking a child if physical comfort is wanted before giving it. However in the majority of cases it would not be appropriate and we do not recommend physical contact, and would encourage comforting the child as detailed above.
7.12 Any (contact or non-contact activity) sexual behaviour (including grooming of a child so sexual abuse can take place), by a member of staff with or towards a pupil is unacceptable and could be a matter for criminal and/or disciplinary proceedings. Pupils are protected by the same laws as adults in relation to non-consensual sexual behaviour, and by additional legal provisions depending on their age and understanding.
7.13 Staff should ensure that only photography, videos or images of students are taken with their and their parent’s consent and that these are published where such consent has been obtained (please note our terms and conditions ask parents to let us know if they do NOT give their consent so unless you hear otherwise, a Bright World Guardianships student’s parents have consented). Images should be securely stored and used only by those authorised to do so. This means staff members (for example Local Coordinators and Head Office Staff) who are present on school premises for the purpose of a student visit or parents evening, the parent/student has not objected to images being taken and the images are taken in relation to the purpose of the visit. Under no circumstances should staff take images of students without consent or without the students knowing that the images are being taken. Staff should always be able to justify images of pupils in their possession and avoid making images in one to one situations.
7.14 Bright World Guardianships staff members should take extreme care to ensure that children and young people are not exposed, through any medium to inappropriate or indecent images. If such images are found on school or work premises, an immediate referral should be made to the Designated Safeguarding Lead.
7.15 Staff members working in one to one situations with pupils should ensure that the meetings are on school premises or a recognised workplace. Wherever possible staff should ensure there is visual access and/or an open door. Where a meeting with a pupil is required away from school or work premises (for example for an urgent situation), the necessity for this should be clear and approval should be obtained from a senior member of staff, pupil and their parent/carers.
7.16 Where an unplanned situation presents which involves a staff member providing support to pupils with medical conditions or administering medicines, advice should be sought from the Designated Safeguarding Lead in the first instance. In an emergency situation, the staff member should immediately call 999 and request urgent medical assistance.
7.17 The Bright World Guardianships Whistle Blowing Policy provides guidance to staff on how to deal with malpractice in the workplace where there is concern for the safety of children. Bright World Guardianships Safeguarding and Child Protection policies outline to staff the correct procedures for reporting and recording concerns and incidents.
8. Use of IT and the Internet
8.1 Bright World Education Ltd and Bright World Guardianships Ltd believe information and communications technology includes all forms of computing, the internet, telecommunications, digital media and mobile phones. This policy is linked to the Bright World Guardianship Social Media Policy which outlines the guidelines for staff using social media for business and personal use, and to the Bright World Guardianships Information and Communications Technology policy which outlines the professional responsibility which staff members have when using any form of ICT.
8.2 Any member of the company personnel that uses illegal software or access inappropriate websites when on company premises faces dismissal.
8.3 Staff members must be aware of the principles of the Computer Misuse & Copyright Acts 1998, and GDPR and the Data Protection Act 2018.
8.4 The use of the internet, web based or mobile communications and social media by staff members must be appropriate to the staff member’s role, lawful, proportionate and ethical.
8.5 Staff members must access Bright World internal information for a legitimate and authorised purpose only, must not disclose internal information to unauthorised recipients and must maintain confidentiality of internal information.
8.6 The following list of offences will be considered as misconduct and will lead to a disciplinary review:
- abuse, misuse or neglect of IT systems within the company
- misuse of the internet and/or email to access or distribute material of a pornographic, offensive, obscene or inappropriate nature
- excessive use of the internet for personal purposes during working time
- accessing information on Bright World internal systems for unauthorised purposes or persons
- accessing and disclosing information obtained from Bright world internal systems for unauthorised purposes or persons
- disclosure of confidential information for unauthorised purposes or persons
8.7 Staff members have a positive obligation to report any of their own behaviour which has fallen below the standards of professional behaviour in this policy
8.8 Staff members have a positive obligation to report, challenge or take actions against the conduct of colleagues which has fallen below the standards of professional behaviour in this policy.
9. Whistle Blowing Policy – Definition
9.1 Bright World believes whistle blowing to be the reporting of suspected wrongdoing in the workplace involving systemic or procedural failures which leave children or staff at risk, in addition to concerns about individuals. This is in support of Bright World’s commitment to safeguarding and promoting the welfare of children and young people. Bright World expects all staff (including self-employed consultants), partners and volunteers to share the commitment to the company’s overall aim. Bright World actively encourage all personnel, partners and volunteers to report any serious concerns they may have about any aspect of the company including such as:
▪ health and safety concerns
▪ damage to the work environment
▪ a criminal offence that has taken place or is about to take place
▪ disobeying the law
▪ the covering up of a wrong doing
▪ the conduct of its personnel or others acting on behalf of the company at work or representing the Company at external functions for work or pleasure
▪ illegal or neglectful practice at work including inadequate child welfare
▪ discipline, grievance, harassment and bullying
▪ recruitment and selection of host families and taxi drivers
9.2 The aim of this policy is to:
▪ To encourage all Bright World staff to report any serious concerns about any aspect of the company or the conduct staff or others acting on behalf of the company
▪ To work with partners and schools and the relevant Local Authority to share good practice in order to improve this policy
9.3 Those wishing to make a disclosure may do so to any member of the team, a manager or supervisor, to the Senior Member Team or to an accredited body for example AEGIS or to the Local Authority. We believe that where the concern relates to an individual’s own employment Bright World’s Grievance Policy must be used. However, if the concern relates to something which is against the company’s policies, falls below standards of practice or amounts to improper conduct then the procedures in this policy must be used. We are committed to the highest possible standards of openness, integrity and accountability. We have a commitment to promote equality. Therefore, an equality impact assessment has been undertaken and we believe this policy is in line with the Equality Act 2010.
9.4 When a concern has been raised, the Managing Directors:
▪ Have a responsibility to ensure all staff are aware of and comply with this policy;
▪ will provide support for a member of staff who has raised a concern;
▪ will provide support for a member of staff against whom allegations have been made;
▪ must keep both parties informed of all progress during any investigation;
▪ will take no action against a member of staff if, after investigation, their concern has not been confirmed;
▪ will take disciplinary action if a concern is raised frivolously, maliciously or for personal gain;
▪ has responsibility for ensuring that the school complies with all equalities legislation;
▪ has responsibility for ensuring funding is in place to support this policy;
▪ has responsibility for ensuring this policy and all policies are maintained and updated regularly;
▪ has responsibility for ensuring all policies are made available to parents, schools and partners;
▪ has responsibility for the effective implementation, monitoring and evaluation of this policy
When a concern has been raised, members of the Senior Management Team will:
▪ ensure all staff and volunteers are aware of and comply with this policy;
▪ encourage all staff and volunteers to raise any concerns they have regarding actual or potential breaches of duty or a failure by the company;
▪ provide support for a member of staff who has raised a concern;
▪ provide support for a member of staff against whom allegations have been made;
▪ keep both parties informed of all progress during any investigation;
▪ work closely with the Managing Directors;
▪ provide leadership and vision in respect of equality;
▪ provide guidance, support and training to all staff;
▪ monitor the effectiveness of this policy;
▪ annually report to the Managing Directors on the success and development of this policy.
Bright World staff have a duty to speak out against and report any:
▪ criminal offence that has been committed, is being committed or is about to be committed;
▪ person who has failed, is failing or is about to fail compliance with any legal obligation that they are subject to;
▪ miscarriage of justice that has occurred, is occurring or is likely to occur;
▪ health and safety issue that has endangered, is endangering or is likely to endanger any person;
▪ damage to the work environment that has been committed, is being committed or is about to be committed
Bright World has a Low Level Concerns Policy located within this manual, with further information and guidance for staff on how to ensure that the company maintains a culture of openness, transparency and safeguarding.
9.5 Any Bright World member of staff, who speak out against and report any of the above, will receive support from the Managing Directors. Bright World will not tolerate any harassment or victimisation of member of staff who speaks out against and reports any of the above. Such behaviour will be treated as a serious disciplinary offence, which will be dealt with under the Disciplinary Rules and Procedure.
The Senior Management Team will give support to any member of staff against whom allegations have been made.
9.6 If the concern is about senior personnel in Bright World, an external contact (such as below) may be required to help you proceed. Expolink:http://expolink.co.uk/whistleblowing/whistleblowing-hotlineservice/
9.7 All raised concerns are investigated and every effort is made to ensure confidentiality for all parties:
▪ All concerns should be made in person or in writing.
▪ The person raising the concern may wish to receive help from another member of the team or Senior Management Team, or external support including a Local Authority prescribed body (OFSTED, NSPCC, Children’s Commissioner)
▪ At any future meeting the employee may be accompanied by a colleague or an external supporter if the selection of the external support is considered appropriate by the Managing Directors. If not, the staff member will be asked to select an alternative representative
▪ Within 10 working days the person with whom the concern has been registered acknowledges receipt in writing.
▪ The letter will state the following:
➢ How the concern will be dealt with;
➢ How long it will take to provide a final response;
➢ Information on employee support services.
▪ After initial enquiries have been conducted, a decision will be made if an investigation should take place under the Bright World Disciplinary Rules and Procedure.
▪ After initial enquiries have been conducted, any false allegations will be considered for investigation under the Bright World Disciplinary Rules and Procedure
▪ The investigation will be either: ➢ an internal investigation;
➢ a referral to the police;
➢ a referral to AEGIS;
➢ an external independent enquiry.
▪ The employee will be informed in writing of the outcome of the investigation by the Managing Directors.
▪ The employee has the right to take their concern to an independent body if they feel it has not been addressed adequately.
9.8 The NSPCC Whistleblowing Helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call 0800 028 0285 – line is available from 8:00 AM to 8:00 PM, Monday to Friday and email: email@example.com
9.9 Awareness of this policy is raised through company handbooks and other publications, the company website, the Staff Manuals and newsletters and briefings
10. Information Sharing
10.1 Bright World recognises that keeping children safe from harm requires the early, effective sharing of information and is a vital element of safeguarding and child protection, as per ‘Information Sharing’ March 2015 and ‘Working Together To Safeguard Children’ 2018: “Effective sharing of information between professionals and local agencies is essential for effective identification, assessment and service provision”
10.2 Bright World recognises the need for confidentiality of their student, school, Host Family, staff and transfer company records and works in adherence to GDPR and the Data Protection Act 2018. (Refer to Confidentiality and General Data Protection Regulation Policy)
10.3 In cases were a child is believed to have been put at risk or is likely to be put at risk of harm, staff will use their professional judgement when making decisions on what information to share and when. As per HM Government Information Sharing Advice for Safeguarding Practitioners 2018, GDPR, “The Data Protection Act 2018 and human rights law are not barriers to justified information sharing, but a framework to ensure that personal information about living individuals is shared appropriately”.
Information Sharing Advice for Safeguarding Practitioners 2018 can be seen via this link.
10.5 Bright World will be open and honest with the individual (and/or family where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.
10.6 Bright World will share with informed consent where appropriate and, where possible, respect the wishes of those who do not consent to share confidential information. Bright World understands that information can still be shared without consent if, in our judgement (based on facts), there is good reason to do so, such as where safety may be at risk. When sharing or requesting personal information from someone, Bright World staff will be aware of the basis upon which they are doing so. Where Bright World have consent to share information, staff are mindful that an individual might not expect information to be shared.
10.7 Bright World considers safety and well-being of the individual and others who may be affected, when forming information sharing decisions.
10.8 Bright World will only share information which is necessary for the purpose for which the information is being shared, will share information only with those individuals who need to have the information, will ensure the information is accurate, current and is shared in a secure and timely fashion.
11.1 Bright World Guardianships staff have access to personal confidential information about students, their families, and staff members. This information is stored and processed in accordance with GDPR and the Data Protection Act 2018. The principles of this Act are considered when sharing confidential information when legally permissible and when in the interests of the child. Bright World adhere to the principles of GDPR and the Data Protection Act 2018 which are to ensure that the information is:
- used fairly and lawfully
- used for limited, specifically stated purposes
- used in a way that is adequate, relevant and not excessive
- accurate – kept for no longer than is absolutely necessary
- handled according to people’s rights
- kept safe and secure
- not transferred outside the European Economic Area without adequate protection
11.2 Bright World Guardianships will only share records with those who have a legitimate professional need to see them. Staff should never use confidential or personal information about a pupil or her/his family for their own, or others advantage (including that of partners, friends, relatives or other organisations). Information must never be used to intimidate, humiliate, or embarrass the child.
11.3 Confidential information should never be used casually in conversation or shared with any person other than on a need-to-know basis.
11.4 In circumstances where the pupil’s identity does not need to be disclosed the information should be used anonymously. There are some circumstances in which a member of staff may be expected to share information about a pupil, for example when abuse is alleged or suspected. In such cases, individuals have a responsibility to pass information on without delay, but only to those with designated safeguarding responsibilities.
11.5 If a child – or their parent / carer – makes a disclosure regarding abuse or neglect, the member of staff should follow the setting’s procedures. This means that staff:
➢ need to know the name of their Designated Safeguarding Lead and be familiar with LSP child protection procedures and guidance:
➢ are expected to treat information they receive about pupils and families in a discreet and confidential manner
➢ should seek advice from a senior member of staff (designated safeguarding lead) if they are in any doubt about sharing information they hold or which has been requested of them
➢ need to be clear about when information can/ must be shared and in what circumstances
➢ need to know the procedures for responding to allegations against staff and to whom any concerns or allegations should be reported
➢ need to ensure that where personal information is recorded using modern technologies that systems and devices are kept secure
➢ should not promise confidentiality to a child or parent, but should give reassurance that the information will be treated sensitively.
11.6 If a member of staff is in any doubt about whether to share information or keep it confidential he or she should seek guidance from the Designated Safeguarding Lead. Any media or legal enquiries should be passed to senior management
11.7 Enquiries or complaints in relation to misuse of data should be directed to James Foster, Commercial Director. If further advice needs to be sought, contact can be made with Information Commissioner’s Office (ICO) – ICO Helpline Telephone 0303 123 1113. The ICO can investigate claims and take action against anyone who’s misused personal data (https://ico.org.uk/concerns/)
12. Bright World Staff and Enhanced Disclosure and Barring Service (DBS) Checks
12.1 Bright World conducts an enhanced DBS checks for their head office staff, Local Coordinators and host families (who are classed as volunteers). This DBS check along with registration to the Disclosure and Barring Service Update Service is a fundamental requirement of becoming and remaining one of these staff members for Bright World.
12.2 There are three types of checks: standard, enhanced and enhanced for people working in regulated activity with children for example teachers and social workers. The enhanced DBS check includes a check of the Police National Computer Records (PNC) plus other information held by the police that is considered relevant by the police force.
12.3 Bright World does not conduct its own checks for our suppliers though does require sight of an original and valid enhanced DBS certificate before we utilise their service. Details of these checks are recorded securely on IBOS. The database is only accessible by accredited Head Office staff members with a username and password and information is protected by Bright World Guardianships compliance with the Act (1998).
12.4 Bright World collects the following information about staff members (i.e. Head Office staff, Local Coordinators, host families) in the following ways:
Staff members are asked to submit an application form for an enhanced DBS certificate. For host families this includes every member of your household who is aged 16 years and over. This application will be made to the DBS (Disclosure and Barring Service) via an online disclosure system. The DBS helps employers make ‘Safer Recruitment’ decisions and prevents unsuitable people from working with vulnerable groups including children. The DBS replaces the Criminal Records bureau (CRB) and Independent Safeguarding Authority (ISA).
- On receipt of an application, UCheck will require the applicant to provide personal details. UCheck provide a range of vetting and screening services for employers and employees including the administrative process for DBS checks.
- For host family applications to UCheck, a Bright World representative will inspect their original documents to confirm identity. Once the Bright World representative has sighted and verified the documents, the details of these identification sources will be logged onto UCheck. In some circumstances when this is not possible they will be asked to fill out a paper form to collect these details.
- Bright World will ask applicants whether they have already subscribed to the DBS Update Service and if the answer is yes, then Bright World will request they provide their Update Service ID. The Disclosure and Barring Service Update Service allows applicants and employers to conduct future checks to be carried out to confirm that no new information has been added to the certificate since the date of issue. This allows for portability of a certificate across employers.
12.5 Bright World needs this information so that they can conduct an enhanced criminal record for their prospective staff members and suppliers. Bright World use UCheck to facilitate this process as they provide a quick and reliable service that is an alternative to the standard paper forms therefore allowing us to complete an application at any location with internet access. This check is relevant as the applicant is seeking a role in the child workforce and will assist Bright World in making safer recruitment decisions.
Once an applicant’s DBS certificate has been received we will register them online for the DBS update service on a yearly subscription basis, allowing us to regularly re-check their certificate status online. If an applicant has already subscribed to UCheck, we will use their current update number to continue to manage their subscription.
12.6 UCheck are a certified umbrella body of the DBS who provide their own statement of fair processing. When an applicant supplies personal information to their site, they have legal obligations in the way they deal with your data. (https://www.UCheck.co.uk/)
Bright World Guardianships has a legal obligation to abide by the Act 2018 and as part of this, they must provide a policy for secure storage, handling, use, retention and disposal of Disclosures and Disclosure information which is outlined below:
12.7 Bright World policy for handling of DBS certificate information
• Once the email with the UCheck result has been sent to the Host Family Recruitment Manager (HFRM) and only if the result is clear, the HFRM logs on to the government update service website and signs that person up for the automatic Update Service. If the DBS check is returned with a conviction marker
• the HFRM forwards this to the Designated Safeguarding Lead (DSL) to make an informed decision as to whether the Host Family will be used. The DSL can obtain a copy of the certificate from the named person to further assess the applicant’s suitability for hosting. • Only authorised members of staff have access to our UCheck disclosure account where there are applications that are processing or completed. UCheck will automatically archive certificates 6 months after their issue date according to DBS guidelines.
12.7 The appointed lead for questions, concerns or complaints about the way in which Bright World conduct their criminal record checks is the Managing Director, Lana Foster, on firstname.lastname@example.org (Refer to Complaints Policy – Operations Manual)
13. Welfare, Health and Safety
13.1 The Workplace (Health, Safety and Welfare) Regulations 1992 cover a wide range of basic health, safety and welfare issues and apply to Bright World Guardianships as a workplace.
13.2 Bright World Guardianships takes their duty under the Health and Safety at Work Act 1974 seriously to ensure, so far as reasonably practicable, the health, safety and welfare of their employees at work.
13.3 The lead for health, safety and welfare is James Foster, Commercial Director.
13.4 Bright World Guardianships has a Health and Safety Policy which outlines the roles, risks and emergency procedures to follow. The policy is included in the Bright World Guardianships Staff Handbook.
13.5 The policy is reviewed annually by James Foster.
14.1 Bright World Guardianships has a ‘Complaints Policy and Procedure’ as we recognise that there may be legitimate concerns from students, parents, agents host families or transfer companies about the service we provide. As a company we encourage these concerns being made known to Bright World staff so that they can be addressed in partnership with us, and we can continuously improve our service.
14.2 Bright World Guardianships has an internal complaints policy and procedure for staff who have complaints and these are detailed in the Staff Handbook.
14.3 If complainants are not satisfied with the outcome as decided by Bright World, they can contact AEGIS to report their concerns if they wish to do so (as detailed in the Complaints Policy). The relevant contact details are set out below:
Association for the Education and Guardianship of International Students (AEGIS)
Bond’s Mill Estate,
+44 (0) 1453 821293 www.aegisuk.net
Policy published: May 2016
Policy reviewed: August 2022