This document is the Safeguarding Policy which outlines our commitment to safeguarding learners while participating in learning programs with Everything Apprenticeships (EA). The Policy underscores our commitment to collaborate with all parties to uphold the highest standards of safeguarding practices throughout the learning journey. It articulates the proactive measures EA will implement, alongside the expectations placed on all individuals to ensure compliance with safeguarding principles and regulations.

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This Policy brings together the key principles of Safeguarding, the Prevent Duty, Equality, Diversity and Inclusion, and Health and Safety and has been created with reference to ‘Working Together to Safeguard Children (2018) and Keeping Children Safe in Education (2023).

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OBJECTIVES

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EA is committed to ensuring a caring, friendly, and safe environment for all staff and learners so that they can learn and work in a relaxed and secure atmosphere.  We recognise we have a statutory duty to safeguarding and promoting the welfare of children, young people, and adults at risk of harm. 

 

Safeguarding and promoting the welfare of children is defined as: 

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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. 

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Through the implementation of this policy, we aim to: 

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• Teach learners how to keep safe and recognise behaviour that is unacceptable. 

• Identify the expectations of all staff and to promote their understanding and responsibilities relating to safeguarding legislation and statutory guidance. 

• Ensure relevant and effective safeguarding practices are in place and staff are appropriately trained to carry out practices. 

• Promote awareness to staff of the need to safeguard children, vulnerable adults, and all people and to raise awareness of different types of abuse and indicators of safeguarding concerns. 

• Ensure the fundamental rights and needs of apprentices are observed. 

• Ensure staff and apprentices are protected from abuse regardless of sex, race, disability, age, sexual orientation, religion or belief, and gender. 

• Take suspicions and allegations of abuse including risks of radicalisation extremely seriously and to respond to concerns in a timely manager and with consideration. 

• Provide guidelines for staff in handling matters relating to actual or suspected child abuse. 

• Prevent the risk of abuse by ensuring procedures and standards in in place and that staff act professionally. 

• To ensure that the fundamental rights and needs of apprentices, staff and other stakeholders affected by safeguarding issues are observed and that staff are supported when dealing with a safeguarding issue. 

• Deter potential, unsuitable individuals from applying to EA by demonstrating our attentiveness and vigilance in relation to safeguarding through our website, job advertisements, and our Safer Recruitment Process. 

• Reject anyone who applies to work with us or supply us with services where we have doubts about their suitability. 

• Work in partnership and in accordance with external organisations. 

• Have an appropriately trained Designated Safeguarding Lead (DSL) in place at all times to advise on and manage any concerns and referrals. 

• Have an appropriately trained Deputy DSL in place wherever possible. 

• Ensure sensitive personal data is processed in accordance with the requirements of GDPR. ​

 

SCOPE

 

This policy applies to all potential and actual learners, staff, facilitators / coach tutor assessors, employers and suppliers.  The purpose of this policy is to ensure awareness of Safeguarding and provide staff with a clear framework (including the 5 Rs) for ensuring the safety, welfare and protection of all individuals involved in our programs and activities. 

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RESPONSIBILITIES

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The Directors are responsible for ensuring that robust safeguarding policies and procedures are in place, that they are regularly reviewed, and effectively communicated to all learners, staff, facilitators / coach tutor assessors, employers and suppliers.  The Directors must lead by example, demonstrating a commitment to prioritising the safety and welfare of all individuals involved in EA's activities. They are accountable for providing adequate resources and support to enable staff to fulfil their safeguarding responsibilities effectively. Additionally, the Directors must stay informed about relevant safeguarding legislation and best practices, ensuring that EA remains compliant and responsive to emerging safeguarding concerns. 

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Other Stakeholders' Responsibilities:

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• Senior Management is responsible for ensuring the implementation of the Safeguarding Policy, and that processes and procedures are robust, up to date, and implemented. 

• Designated Safeguarding Lead (DSL), which means the DSL or the Deputy DSL where the DSL is not available, is responsible for the management of safeguarding issues including concerns for learner welfare and reports to the Directors on any issues that arise.  The DSL carries out investigations where appropriate and coordinates escalation processes liaising with external bodies such as local multi-agency safeguarding partnerships where cases of suspected abuse or allegations are raised. The DSL is not entitled to give formal legal advice but is able to obtain such advice from experts and maintains links with local multi-agency safeguarding partners, informing, and advising on legislation changes and current safeguarding themes.  The DSL monitors the safeguarding@everythingapprenticeships.com inbox and ensures all concerns are dealt with in a timely and appropriate manner.  The DSL is responsible for making a barring referral and has responsibility for raising awareness across all staff relating to the welfare of children, young people and adults. 

• Facilitators / coach tutor assessors and staff must actively uphold the principles outlined in this Policy and check the safety and welfare of learners during each training session and interaction with them.  They must be aware of safeguarding indicators and follow correct reporting procedures if they suspect a safeguarding concern.  Learner absences must be dealt with in line with the Absence Policy. 

• Learners, employers, and other stakeholders have a responsibility to report any concerns in line with this Policy. 

 

EA is part of Leicestershire County Council and has identified and established contact with the Local Authority Designated Officer (LADO).  In all cases where allegations are made against people who are in contact with EA learners, the DSL will consult with the LADO detailed below.  We also maintain a list of all LADO contact details in each of the Local Authority areas where our learners live and are employed. 

 

Allegations of abuse made against a member of staff, or any other person employed by EA to deliver support or services to any of its learners will be reported immediately to the appropriate authorities including the Leicestershire County Council LADO and Leicestershire Police.  The individual concerned will be suspended / removed from their duties pending further investigation. 

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Designated Safeguarding Lead (DSL) 

Kerry Linley 

kerry@everythingapprenticeships.com 

07846 035748 

 

Deputy DSL 

Tracey Wright 

safeguarding@everythingapprenticeships.com 

07809 701224 

 

LADO Allegations Team 

Leicestershire County Council LADO 

cfs-lado@leics.gov.uk 

0116 305 4141 ​

 

DEFINITIONS

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The following are commonly agreed safeguarding definitions: 

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• Children and young adults is a term used to mean those under the age of 18. 

• Vulnerable adults as defined in section 59 of the Safeguarding Vulnerable Groups Act 2006 and / or those individuals aged 18 and over who by reason of mental or any other disability, age, or illness, are or may be, unable to look after or to protect themselves against harm or exploitation. 

• Adults at risk of harm are defined as people aged 18 years or over who may need or receive community care services by reason of mental health or other disability, age, or illness and who may be unable to take care of themselves or protect themselves against significant harm or exploitation (No Secrets, Department of Health. March 2000). 

• 5 Rs of Safeguarding refer to the steps which should be followed if a safeguarding concern arises – these are Recognise, Respond, Report, Record and Refer.  

 

ABUSE

 

It is important that people are protected from all forms of abuse or potential harm.  Abuse may take many forms including (but not necessarily limited to) the following: 

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• Sexual abuse (either from inappropriate behaviour or relationships) including rape, indecent exposure, sexual harassment, teasing or innuendo or sexual acts to which the adult has not consented or was pressured into consenting to. 

• Physical abuse including assault, hitting, slapping, pushing, restraint, or inappropriate physical sanctions. 

• Emotional abuse including threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation. 

• Neglect including ignoring medical, emotional, or physical care needs. 

• Female Genital Mutilation (FGM). 

• Exploitation including theft, fraud, sexual (include sexploitation), forced marriage, forced labour through modern slavery and / or human trafficking. 

• Grooming (e.g. for a sexual, criminal or radicalisation intent). 

• Domestic violence. 

• Bullying, including cyber bullying. 

• Victimisation. 

• Self-harm such as neglecting to care for personal hygiene, health, or surroundings. 

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Vulnerable adults and are considered vulnerable if they are: 

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• Substantially dependent upon others in performing basic physical functions, or their ability to communicate with other providing services, or to communicate with others, is severely impaired. 

• Living in in sheltered housing or residential accommodation, such as a care home or a residential special school. 

• Receiving any form of health care or domiciliary care in their own home. 

• Detained in a prison, remand centre, young offender institution, secure training centre or attendance centre or under the powers of the Immigration and Asylum Act. 

• In contact with probation services. 

• Receiving a welfare service. 

• Receiving a service or participating in an activity which is specifically targeted at people with age-related needs, disabilities or prescribed physical or mental health conditions. 

• Receiving direct payments from a local authority in lieu of social care services. 

• In need of assistance in the conduct of their own affairs. 

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A person may be deemed at risk of a safeguarding issue due to other factors such as: 

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• Poor numeracy and literacy skills, or a specific learning need. 

• Where English is not a first language. 

• Having an unsupportive employer. 

• Member of an under-represented group. 

• Is acting as a carer for another family member or is a young carer. 

• Has a background of offending or is showing signs of being drawn in to antisocial or criminal behaviour. 

• Has a disability or social need. 

• Has special educational needs (whether or not they have a statutory Education, Health, and Care Plan). 

• Lives ‘In Care’ or has recently transitioned out of Care. 

• Is frequently missing or goes missing from care or from home. 

• Is within a family circumstance presenting challenges. 

 

THE 5 Rs

 

Staff must be vigilant for any signs that a person may be in danger.  The 5 Rs of safeguarding are designed to help people remember and understand how they can do this in the best possible way.  

 

1. RECOGNISE 

2. RESPOND 

3. REPORT 

4. RECORD 

5. REFER 

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You must have a clear understanding of the different signs and symptoms of potential abuse, harm, and neglect.

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If you do have a safeguarding concern, you must respond appropriately, and not ignore the situation. 

 

Safeguarding concerns must be reported without delay, and with full consideration of the need for confidentiality. 

 

Take precise, comprehensive notes that detail the facts about the safeguarding concern. Include who, what, why, when, and where. 

 

The DSL is responsible for passing on concerns of safeguarding to the appropriate authorities. 

 

Full training is provided to all staff and wider stakeholders to help them recognise the signs and symptoms of potential abuse, and respond, report, and record the information in a way that complies with this policy, and ensure EA protects those who engage with its services. 

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REPORTING A SAFEGUARDING CONCERN

 

In all instances, staff must record details of a safeguarding concern raised or witnessed on the Safeguarding Incident Form.  Staff who do not have access to the form must telephone the DSL or, if the DSL and Deputy DSL is not available, send an email to safeguarding@everythingapprenticeships.com with a brief explanation of the safeguarding concern.  The DSL, Deputy DSL, or the Directors (if the DSL / Deputy DSL is not available) will contact the member of staff and record the details of the concern and complete the form on their behalf. 

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The DSL must be informed immediately when a learner does not attend a pre-arranged training session, one-to-one, or review.  The DSL will follow the procedure outlined in the Absence Policy.  Where the absence also gives rise to a safeguarding concern, the DSL will complete a Safeguarding Incident Form.

 

PEER-ON-PEER ABUSE

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Staff must remain vigilant to the signs of peer-on-peer abuse which may include physical and sexual abuse, sexual harassment and violence, emotional harm, on and offline bullying, and relationship abuse.  It can even include grooming for sexual and criminal exploitation.  Where a member of staff believes a learner is being subjected to peer-on-peer abuse, they must take immediate action to ensure the safety and wellbeing of the individuals involved and report the incident to the DSL immediately.  Any instance of abuse by a learner of another learner will be reported to the employer of the learner(s) perpetrating the abuse. 

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Peer-on-peer abuse involving staff will be dealt with via our internal disciplinary and grievance procedures. 

 

IF A LEARNER RAISES A CONCERN OR MAKES AN ALLEGATION 

Staff must record all information on the Safeguarding Incident Form.  Details must be recorded accurately, and staff should not make any judgements or assumptions about the information given by the learner.  Guidance is given on the from about the actions required to secure the immediate safety of the learner.  Staff must request the learner’s consent to refer the concern to the DSL.  If the learner’s safety and / or wellbeing is at risk the matter must be referred to the DSL even if the learner withholds consent.  Staff should advise the learner that they have a duty of care to refer the concern.  The DSL will decide the appropriate course of action and update the Safeguarding Incident Log with details of this.

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IF A THIRD PARTY RAISES A CONCERN OR MAKES AN ALLEGATION 

Staff must record all information on the Safeguarding Incident Form (as above), including contact details of the third party.  Be mindful of confidentiality.  Learners who are aged 16 and above and of employed status are deemed adults.  Do not pass on any follow up information to any third party without the consent of the learner that the concern relates to. 

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IF A CONCERN RELATES TO A MEMBER OF STAFF 

If any individual wishes to raise a concern regarding a member of staff, they must contact the DSL.  If any member of staff becomes aware of a concern regarding another member of staff, they must refer the person raising the concern immediately to the DSL.  The DSL will follow the protocol outlined in the Whistleblowing Policy. 

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OBSERVATION OF A CONCERN IN THE EMPLOYER’S SETTING 

If any member of staff becomes aware of, or observes a concern, whilst on an employer’s premises they should stop the activity they or the learners are currently engaged in and inform the individual involved of the concern and ask them to remove themselves from the area and report the concern to their designated manager.  Staff must take action to secure the safety of themselves and any learners at risk. 

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Staff must be mindful of the differences between poor practices and safeguarding issues and apply any actions appropriately, including recording the safeguarding concern on the Safeguarding Incident Form and referring this to the DSL who will decide the appropriate curse of action and record this on the Safeguarding Incident From. 

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LEARNER REPORT OF A CONCERN IN THE EMPLOYER’S SETTING 

If a learner reports a safeguarding concern that they are aware of in their employer setting, advise the learner to follow the employer’s in-house reporting or whistleblowing procedures, and offer support and intervention if required. 

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REPORTING FGM 

Female Genital Mutilation (FGM) is illegal in England and Wales under the FGM Act 2003 (“the 2003 Act”).  It is a form of child abuse and violence against women.  FGM comprises all procedures involving partial or total removal of the external female genitalia for non-medical reasons.  The FGM mandatory reporting duty is a legal duty provided for in the FGM Act 2003 (as amended by the Serious Crime Act 2015). The legislation requires regulated health and social care professionals and teachers in England and Wales to make a report to the police where, in the course of their professional duties, they are either informed by a girl under 18 that an act of FGM has been carried out on her, or observe physical signs which appear to show that an act of FGM has been carried out on a girl under 18 and they have no reason to believe that the act was necessary for the girl’s physical or mental health or for purposes connected with labour or birth.  

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For the purposes of the duty, the relevant age is the girl’s age at the time of the disclosure/identification of FGM (i.e. it does not apply where a woman aged 18 or over discloses, she had FGM when she was under 18). 

 

Complying with the duty does not breach any confidentiality requirement or other restriction on disclosure which might otherwise apply.  The duty is a personal duty which requires the individual who becomes aware of the case to make a report; the responsibility cannot be transferred. The only exception to this is if you know that another individual from your profession has already made a report; there is no requirement to make a second. 

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Reports under the duty should be made as soon as possible after a case is discovered, and best practice is for reports to be made by the close of the next working day, unless any of the factors described below are present. 

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Staff should act with at least the same urgency as is required by safeguarding processes.  A longer timeframe than the next working day may be appropriate in exceptional cases where, for example, a professional has concerns that a report to the police is likely to result in an immediate safeguarding risk to the child (or another child, e.g. a sibling) and considers that consultation with colleagues or other agencies is necessary prior to the report being made. 

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Staff who think they are dealing with a case of FGM are strongly advised to consult with the DSL as soon as practicable, and to record and maintain clear and factual records which may be used as supporting evidence. 

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INDUCTION AND TRAINING 

 

EA provides training to ensure all staff, facilitators / coach tutor assessors and other associates and partners have the necessary skills, knowledge, and experience to assist them in the exercise of their duties in line with this Policy. 

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Safeguarding training is provided to all staff as part of their induction and periodically as part of their mandatory training, in accordance with our Professional Development Policy, along with access to relevant training resources and ongoing legislative updates.  This training will ensure that staff develop their understanding of the signs and indicators of abuse, neglect, bullying and / or harassment, and that they know how to respond to an individual that discloses any concern covered by this Policy.  All staff will undergo annual refresher training. 

 

TEACHING, LEARNING AND ASSESSMENT 

 

All EA programs will provide a broad and balanced curriculum, delivered by skilled professionals, and will include awareness of safeguarding issues.  EA will provide: 

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• Development opportunities for staff to ensure they can recognise the signs and symptoms of possible abuse in all its forms. 

• Record details about any learner, particularly in relation to potential indicators of abuse or neglect, confidentially and appropriately. 

• Work closely with employers to ensure that they have appropriate and effective safeguarding policies and procedures in place. 

• Integrate safeguarding and wellbeing into our sessions to learners. 

• Provide learners with an opportunity to discuss confidential issues and concerns with an appropriately trained member of staff. 

• Provide regular communications to staff, learners, and their employers about safeguarding and related issues. 

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SUPPORTING STAFF 

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Staff who become involved with a learner or vulnerable person who has suffered harm, or appears to be at risk of harm, may find the situation stressful and upsetting.  EA will support all individuals by providing them with opportunities to discuss their anxieties with a suitable qualified mental health first aider, or a member from the senior management team or directors. 

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Time off will be provided to staff to access external support. 

 

PROTECTING OURSELVES 

Staff should take all reasonable precautions to protect themselves against allegations of abuse.  They must avoid personal and social contact with learners, and steps to minimise the risk of any situation arising in which misunderstandings can occur. 

 

Staff must not: 

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• Engage in flirting, innuendo, suggestive remarks, discriminatory comments or make suggestions. 

• Issue or threaten any form of physical punishment. 

• Engage in any sort of sexual relationship with a learner. 

• Photograph or film learners without prior consent or where the photograph or film does not relate to the evidencing off-the-job learning that is relevant to the apprenticeship or retain photographs or film on personal devices. 

• Send any audio and / or visual material that has inappropriate content to learners. 

• Invite or allow a learner to their home, or any other location where the purpose is one of friendship or an intimate relationship. 

• Do things of a personal nature for learners that they can do for themselves. 

• Dismiss an allegation of any sort relating to a learner's welfare or delay the reporting of an allegation. 

• Withhold any disclosure should they suspect abuse. 

• Spend excessive amounts of time alone with learners away from others. 

• Make unnecessary physical contact with learners.  There may be occasions where physical contact is unavoidable – staff should make every effort to ensure contact only takes place with consent of the individual and should be mindful that some individuals practice non-contact. 

• Meet / arrange to meet a learner outside of working hours unless it is with consent of the senior managers or directors. 

• Befriend or chat to learners/apprentices on private social network sites. 

• Give or receive gifts and / or substances such as drugs, alcohol, cigarettes, e-cigarettes from or to a learner. 

 

Staff must: 

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• Work in rooms and locations with learners where they can be visibly seen by others. 

• Plan in-person activities that involve more than one other person or that are within sight and hearing of others. If it is unavoidable always ensure your line manager knows where you are, with whom and why. 

• All email communication should be sent to learners using the email pseudonyms provided within the Rubitek platform. Comprehensive training has been provided to ensure pseudonyms are used correctly. This process ensures that all emails are securely recorded and easily monitored within the platform. 

• Be aware of the procedures for reporting concerns or incidents and be familiar with the contact details of the DSL. 

• Treat all learners equally and with respect. 

• Ensure allegations or disclosures by a learner are taken seriously and reported. 

• Use professional language when writing, phoning, emailing, or using social media to communicate with learners. 

• Be aware that learners can develop infatuations (crushes) towards those working with them. If you suspect this is happening, tell the DSL who will respond to the situation in a way that maintains the dignity of all concerned. 

• Act as a role model. 

• Set and monitor appropriate boundaries and relationships when working with learners based on openness, honesty, and respect for them. 

• Respect a learner’s right to personal privacy but never agree to keep any information relating to the harm of a learner confidential. 

• Provide support to a learner making a complaint. 

• Report any concerns without delay and record all the facts. 

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Staff who do not comply with this Policy and those who are the subject of a safeguarding allegation may be subject to our internal disciplinary and grievance procedures. 

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RECORDS 

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EA will maintain clear, comprehensive records of any safeguarding concerns. The company will comply with the requirements of the Data Protection Act 1998, which allows for disclosure of personal data where this is necessary to protect the learner.  It is therefore vital that all records include precise and detailed information using the words of the individual making the disclosure or raising the concern.  Information will be accessible only to those who need to access it as part of further investigation or any action necessary. 

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The DSL monitors safeguarding incidents to identify emerging trends or patterns, enabling proactive intervention and the implementation of relevant preventive measures or further training to minimise the likelihood of further recurrence. 

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SAFE RECRUITMENT AND SELECTION

 

EA will comply with best practice in the recruitment and training of its staff, in line with legislative requirements. The EA Recruitment Policy supports this document.  We will ensure safeguarding considerations are incorporated into every stage of the recruitment process.  Applicant identities are checked at interview and all job offers are subject to appropriate references being supplied. Individual’s criminal convictions are checked on appointment, as appropriate to the job role, via Enhanced DBS Disclosure and used in the interim with additional supervision and monitoring in place. 

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Where DBS checks are necessary, we maintain a central DBS register, with 3 yearly renewals in place as follows: 

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• Standard DBS checks where necessary are carried out for administrative non-teaching staff who do not come into direct contact with learners under 18. 

• Enhanced DBS checks are carried out where necessary for all staff who are in direct contact with learners under 18. 

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Through our safeguarding training we ensure learners understand what a DBS check is, and whether it is required for their job role. The employer is ultimately responsible for ensuring anyone they employ has the necessary checks in place.  However, we do support employers to engage with the Disclosure and Barring Service to fully understand their role and responsibility. 

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CONFIDENTIALITY 

 

All matters relating to welfare and safeguarding are highly confidential. EA will only disclose information, both internally and externally, on a ‘need to know’ basis.  Records and referral details will be made and stored on electronic systems accessible by the DSL and Deputy DSL and classified as Confidential. 

 

WHISTLE BLOWING 

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Everyone has the right, and a responsibility, to raise concerns about the behaviour of staff, learners, volunteers, or other stakeholders when such behaviour may be harmful to others in their care and will receive appropriate support from us when doing so.  All stakeholders are encouraged to share any concerns they may have so that problems can be identified, dealt with, and resolved quickly without prejudice to their position. Further information on Whistleblowing can be found in the Whistleblowing Policy. 

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IT USAGE

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Recognising the paramount importance of online safety education, EA is committed to educating both staff and learners on how to remain safe online and the responsible use of technology and the internet. 

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Staff members are responsible for ensuring that learners are well-informed about best practices in online safety and acceptable behaviour and usage of EA equipment.  This is covered during learner inductions at the start of their apprenticeship training and at regular intervals throughout.  We share information with learners about the proactive measures we take to shield learners from cyberbullying, exposure to unsuitable online content (e.g. content that includes references to or depiction of self-harm and / or suicide), and other potential risks.  We also encourage open discussion about the potential of online risks during interactive learning sessions. 

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All EA computing equipment and / or devices which access the internet are protected by a firewall which is configured to filter out inappropriate content or block access to specific websites as detailed in our IT and Software Management Policy, and our Information Security Policy.  However, we recognise that sometimes content can be accessed inadvertently.  To ensure responsible usage and in line with these policies, internet activity may be checked at regular intervals.  This monitoring serves to not only track the frequency of internet usage but also to assess the nature of the accessed content and ensure the suitability of EA firewalls to ensure we are providing the necessary protection for staff and learners. 

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Material, which is deemed inappropriate, whether accessed via the internet or stored on electronic devices, will result in disciplinary action in accordance with the disciplinary and grievance procedures. 

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​APPLICABLE LAWS, REGULATIONS AND OTHER POLICIES

 

This Policy has been written in line with the following legislation and regulations: 

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• Department for Education ‘Keeping Children Safe in Education’ 

• Working Together to Safeguard Children 

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and should be read in conjunction with other EA Policy documents, and the information regarding useful safeguarding links at Appendix I. 

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​PROMOTION AND COMMITMENT

 

​We are committed to ensuring that all staff and wider stakeholders fully understand, comply with, and actively engage with our policies. Directors and senior management are dedicated to fostering a culture of policy adherence and continuous improvement. 

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Our induction process ensures that new staff members are introduced to our policies from the outset, providing them with the necessary information and guidance to adhere to our standards. Additionally, our annual appraisal process includes a thorough review of staff implementation of our policies, recognising and celebrating successes while identifying areas for improvement. 

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EA considers staff and wider stakeholder insights and perspectives when refining and reviewing its policies.  This ensures our policies remain relevant, effective, and responsive to the evolving needs of our organisation and stakeholders.  In addition, we proactively seek out examples of best practices from exemplar training providers, incorporating learnings and insights to further enhance our policies. By continuously benchmarking against industry standards and embracing innovative approaches, we strive to maintain the highest standards of policy governance and effectiveness.  

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​APPROVAL AND REVIEW 

 

The Directors are responsible for ensuring the Company meets its obligations in line with this policy. 

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This policy shall be reviewed by the Directors and updated where necessary before being approved at least annually to ensure that it (and any subsidiary policies and procedures) remains appropriate considering any relevant changes to the law, organisational policies, or contractual obligations. 

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This version 1.3 of the policy is approved by the Directors on 22nd April 2025.