EM Normandie UK Limited ((hereafter ‘EMN’ or ‘the school’) recognises its duty of care to safeguard
Children as detailed under the Children Acts’ 1989 and 2004 and Working Together to Safeguard Children 2018.
EM Normandie UK Limited operates a business school for post A-level degree courses. The normal age of students ranges from 18 to 25 but exceptions can be made for applications who are 17-year old where appropriate. No residential accommodation is available to students in Oxford, and we have grave concerns regarding the safety of students under the age of 17 living on their own in a foreign country. The school is unable to provide the supervision and assistance necessary for students under the age of 17 and/or for students who, because of their particular personal circumstances, may be considered more vulnerable than their peers. As we are not in a positions to meet the needs of these students outside of the school environment, we have made it a mandatory requirement for all students under the age of 17 to be placed under the supervision of and to live with an accredited UK guardian who assumes full responsibility ‘in loco parentis’ for the student. A guardianship agreement will also be recommended to all parents of 17-year old students.
For the purpose of this policy, the term ‘young people’ is used for 16 and 17-year olds.
We are fully committed to safeguarding and protecting the welfare of all children, and taking all reasonable steps to promote safe practice and protect children, from harm, abuse and neglect.
EMN acknowledges its duty to act appropriately with regards to any allegations towards any member of staff, contractor, student or visitor or towards any disclosures or suspicion of abuse.
We believe that the welfare of all children and young people is paramount. All children, regardless of age, ability, gender, racial heritage, religious or spiritual beliefs, sexual orientation and /or identity, have the right to equal protection from harm or abuse.
Some children and young people are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues.
Working in partnership with children and young people, their parents, guardians and other agencies is essential in promoting young people’s welfare.
We will provide all our members of staff with the training, guidance, leadership and support which will enable them to fulfil their roles under this policy.
This policy has been developed for EM Normandie UK Limited in accordance with the principles established by the following legislation and guidance:
The purpose of this policy is to
To keep young people safe, EMN will:
This policy applies to all staff, including senior managers, committee members, contractors, volunteers, agency staff, students and/or anyone in a position of trust.
A child is defined as a person under the age of 18 (The Children’s Act 1989).
This policy should be read alongside the following organisational policies and guidance, all of which are available on the company’s website at www.em-normandie.co.uk
Every member of staff, contractor, volunteer and visitor at the school must therefore commit to
Please see Appendix A for guidance on procedures
Please see Appendix B for a summary of the different types of abuse and possible indicators
Please see Appendix C for all important contact details
The Board of Directors is ultimately accountable for ensuring settings provided by EMN are safe, including the implementation of effective safeguarding procedures.
This policy is available to all and can be accessed at www.em-normandie.co.uk
Safe recruitment is central to the safeguarding of children and young people. All organisations which employ people to work with children in a position of trust have a duty to safeguard and promote their welfare. This includes ensuring that the organisation adopts safe recruitment and selection procedures which prevent unsuitable persons from gaining access to children.
Please see the school’s Safe Recruitment Policy which can be access at www.em-normandie.co.uk
The policy will be reviewed annually. All individuals in a position of trust should have access to this policy and sign to the effect that they have read and understood its contents.
EMN will complete an annual self-assessment to appraise their safeguarding practice against OSCB standards.
All professionals have a responsibility to report concerns to Children’s social care under section 11 of the Children Act 2004, if they believe or suspect that the child
If/when a child reports they are suffering or have suffered significant harm through abuse or neglect, or have caused or are causing physical or sexual harm to others, the initial response from all professionals should be to listen carefully to what the child says and to observe the child’s behaviour and circumstances to
The child must not be pressed for information, led or cross-examined or given false assurances of absolute confidentiality, as this could prejudice police investigations, especially in cases of sexual abuse.
If the child can understand the significance and consequences of making a referral to children’s social care, they should be asked for their views.
It should be explained to the child that whilst their view will be considered, the professional has a responsibility to take whatever action is required to ensure the child’s safety and the safety of other children.
Children have a right to confidentiality under Article 8 of the European Convention on Human Rights. It’s important to respect the wishes of a child or any person who doesn’t consent to share confidential information.
If you’re not given consent to share information, you may still lawfully go ahead if the child is experiencing, or is at risk of, significant harm.
Child protection concerns, disclosures from children or safeguarding allegations made against a person in a position of trust must not be discussed across the workforce as a whole. This information should be shared solely with Designated Safeguarding Leads, Children’s Social Care and/or the Local Area Designated Officer (LADO) as appropriate (please see Appendix C for details).
Personal information which is shared by the child or young person on a 1:1 level, such as sexual orientation or gender identification, should not be disclosed to the workforce as a whole.
If members of staff wish to discuss situations with colleagues to gain a wider perspective, this should be done on an anonymous basis with names and other identifying information relating to the child and their family remaining strictly confidential.
1. Remember that the Data Protection Act 2018 and human rights law are not barriers to justified information sharing, but provide a framework to ensure that personal information about living individuals is shared appropriate.
2. Be open and honest with the individual (and/or their 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.
3. Seek advice from other practitioners if you are in any doubt about sharing the information concerned, without disclosing the identity of the individual where possible.
4. Share with informed consent where appropriate and, where possible, respect the wishes of those who do not consent to share confidential information. You may still share information without consent if, in your judgement, there is good reason to do so, such as where safety may be at risk. You will need to base your judgement on the facts of the case. When you are sharing or requesting personal information from someone, be certain of the basis upon which you are doing so. Where you have consent, be mindful that an individual might not expect information to be shared.
5. Consider safety and well-being: base your information sharing decisions on considerations of the safety and well-being of the individual and others who may be affected by their actions.
6. Necessary, proportionate, relevant, adequate, accurate, timely and secure: ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those individuals who need to have it, is accurate and up-to-date, is shared in a timely fashion, and is shared securely.
7. Keep a record of your decision and the reasons for it – whether it is to share information or not. If you decide to share, then record what you have shared, with whom and for what purpose.
We recognise the importance of sharing information and reporting concerns to ensure children are protected The following procedures apply to all staff working with child students. Their aim to provide a robust framework which enables staff to take appropriate action if they are concerned that a child is being harmed or is at risk of being harmed. The prime concern must be the interests and safety of the child. The welfare of the child is always paramount.
When a child makes a disclosure, the member of staff should
Following the receipt of concerns, the DSL must
Keep in mind that schools do not investigate where there are child protection concerns
Record keeping during and after a referral
Where a safeguarding issue is noted, all concerns, discussions, decisions and reasons for these, have to be recorded in writing , including names of those involved in the decision taking and other action and details for how matters were followed up.
All matters relating to Safeguarding are confidential
All allegations of abuse by those who work with children must be taken seriously, whether they are in a paid or unpaid capacity. This procedure should be used if it is alleged that a member of staff, a contractor, volunteer or visitor, has
If a child student or their representative makes a complaint of abuse against a member of staff, the person receiving the complaint must
To report an allegation or concern about a person in a position of trust, please contact the LADO and Safeguarding Team on 01865 810603 or email: LADO.email@example.com
We recognise that children cannot be expected to raise concerns in an environment where those in a position of trust fail to do so. All those in a position of trust should be aware of their duty to raise concerns about dangerous or illegal activity, or any wrongdoing within their organisation.
Whistleblowing is a term used when staff want to report a concern within their organisation that involves their manager or a person senior to them. This may prevent them from feeling able to follow the normal report procedures.
There are a limited number of areas that can be called ‘Whistleblowing’ and it is important that staff be protected from sanctions for raising concerns.
The Principal is responsible for all EMN staff. If anyone has concerns that any member of staff is not following safeguarding processes or behaving in a way that is placing children at risk, they should, in the first place, make the Principal aware of this.
If the concern is about the Principal, they should raise this with the DSL, deputy DSL or one of the company directors:
We would prefer for members of staff to raise concerns internally in the first instance. However, there may be instances where a member of staff might prefer to raise their concerns outside of the organisation. In that case, they can contact
Our complete Whistleblowing Policy is available at www.em-normandie.co.uk
The table below outlines the main categories of abuse as defined by the Department of Health ‘Working Together to Safeguard Children’ document 2018. (Full definitions can be found in this document). All staff should be aware that the possible indicators are not definitive and that some children may present these behaviours for reasons other than abuse.
Type of Abuse
The persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy 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.
Signs that may indicate a child is living in a neglectful situation:
• excessive hunger
• poor personal hygiene
• frequent tiredness
• inadequate clothing
• frequent lateness or non-attendance at school
• untreated medical problems
• not brought
• poor relationships with peers
• compulsive stealing and scavenging
• rocking, hair twisting and thumb sucking
• running away
• loss of weight or being constantly underweight (the same applies to weight gain, or being excessively overweight
• low self esteem
• poor dental hygiene
May involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces illness in a child.
Signs that may indicate physical abuse:
• physical signs that do not tally with the given account of occurrence
• conflicting or unrealistic explanations of causer
• repeated injuries
• delay in reporting or seeking medical advice
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, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet).
Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.
Signs that may indicate sexual abuse –
• changes in behaviour
• changes in language
• changes in social interaction
• changes to physical wellbeing
Most importantly: there may be no signs at all
The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development.
It 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
It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), 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.
Signs that may indicate emotional abuse:
• lack of self-confidence/esteem
• sudden speech disorders
• self-harming (including eating disorders)
• drug, alcohol, solvent abuse
• lack of empathy (including cruelty to animals)
• concerning interactions between parent/carer and the child (e.g. excessive criticism of the child or a lack of boundaries)
Child Sexual Exploitation (CSE)
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.
Signs that may indicate CSE:
• Going missing from school/home/care placement
• Associating with older people/adults
• Isolation from family/friends/peer group
• Physical symptoms including bruising/STI’s
• Substance misuse
• Mental health
• Unexplained possessions, goods and/or money
The indicators can be spotted when speaking to the young person themselves or family/friends
If a child or young person has made a disclosure regarding sexual exploitation, or if you think a child may be at risk of being sexually exploited please contact the Kingfisher Team on 01865 309196. Out of hours calls will divert to Thames Valley Police Referral Centre.
Child exploitation describes how gangs from large urban areas supply drugs to suburban and rural locations, using vulnerable children and young people to courier drugs and money.
Typically, gangs use mobile phone lines to facilitate drug orders and supply to users. They also use local property as a base; these often belong to a vulnerable adult and are obtained through force or coercion (this exploitation is sometimes referred to as ‘cuckooing’).
It also finds that the age of those involved is getting younger, with children as young as 12 being targeted. Gangs ‘recruit’ through deception, intimidation, violence, debt bondage and/or grooming into drug use and/or child sexual exploitation.
While there has been an increased awareness of the use of children and young people in county line markets, more needs to be done as it cuts across a number of issues such as drug dealing, violence, gangs, child sexual exploitation, safeguarding, modern slavery and missing persons.
Signs that may indicate drug/criminal exploitation are similar to CSE, as follows
Defined as, “any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality. This can encompass but is not limited to the following types of abuse: psychological, physical, sexual, financial or emotional”.
A forced marriage (FM) is a marriage conducted without the valid consent of one or both parties and where duress is a factor. Forced marriage is now a specific offence under Section 121 of the Anti-Social Behaviour, Crime and Policing Act 2014.
FM is very different to an arranged marriage where both parties give consent.
Modern slavery can take many forms including the trafficking or people, forced labour, servitude and slavery. Victims can include adults and children and come from all walks of life and backgrounds. A quarter of all victims are children.
The Modern Slavery Act 2015 places a duty on specified public authorities to report details of suspected cases of modern slavery to the National Crime Agency.
Indicators of Modern Slavery can include
Female genital mutilation (FGM), sometimes referred to as female circumcision, refers to procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons. The practice is illegal in the UK.
There are no health benefits to FGM, it is carried out for cultural and social reasons within families and communities. The procedure is traditionally carried out by an older woman with no medical training. Anaesthetics and antiseptic treatment are not generally used, and the practice is usually carried out using basic tools such as knives, scissors, scalpels, pieces of glass and razor blades.
The Oxford Rose Clinic is a specialised clinic run at the John Radcliffe Hospital to address the health and safeguarding issues associated with FGM. Women should be referred to this clinic by emailing firstname.lastname@example.org or calling 01865 222969.
Healthcare professionals have a duty to safeguard any children who may be at risk of FGM. Information about how to identify children at risk of FGM, including a screening tool and pathways are available on the Oxfordshire Safeguarding Children Board website.
Deliberate self-harm is intentional self-poisoning or injury, irrespective of the apparent purpose of the act, (www.nice.org.uk). Self-harm is an expression of personal distress, not an illness.
Self-harm can involve
Indicators of self-harm may include
Bullying is not always easy to recognise as it can take a number of forms. A child may encounter bullying attacks that are
Persistent bullying can result in depression, low self-esteem, shyness, poor academic achievement, isolation, threatened or attempted suicide
Indicators a child is being bullied can be
Peer-on-peer abuse is any form of physical, sexual, emotional and financial abuse, and coercive control, exercised between children and within children’s relationships (both intimate and non-intimate).
Peer-on-peer abuse can take various forms, including serious bullying (including cyber-bullying), relationship abuse, domestic violence, child sexual exploitation, youth and serious youth violence, harmful sexual behaviour, and/or gender-based violence.
The Counter-Terrorism and Security Act 2015 places a safeguarding duty on settings to have “due regard to the need to prevent people from being drawn into terrorism”.
Settings subject to the Prevent Duty will be expected to demonstrate activity in the following areas
Indicators may include
To report concerns about child radicalisation
Make safe – If emergency services are required – call 999. Take reasonable steps to ensure that there is no immediate danger.
To refer concern identified by member of the public or professional, call MASH on 0345 050 7666
EM Normandie UK Safeguarding Lead : Dr. Miriam Schmidkonz, Tel 01865 681 408
EM Normandie Deputy Safeguarding Leads : Birgit Muller, Tel 01865 681 412
Emma Pruszewicz, Tel 01865 681 410
You should call the Multi-Agency Safeguarding Hub (MASH) immediately Tel: 0345 050 7666 or out of office hours 0800 833 408
Please call the Locality and Community Support Service (LCSS) Central : 0345 241 2705
To report an allegation a person in a position of trust
Please refer to and follow EMN internal processes in the first instance. If this is not possible or not appropriate,
please contact the Oxfordshire Local Authority Designated Officer (LADO) on 01865 810603 or email: LADO.email@example.com
The LADO should be made aware of all cases in which it is alleged that a person who works with children has:
Oxford City Assessment Team – Tel: 01865 323048
Emergency Out of Hours – Tel: 0800 833408 (After 5pm Mon-Thurs and 4pm Friday)
Please contact the Kingfisher Team on 01865 309196
Out of hours calls will divert to Thames Valley Police Referral Centre.
Call 999 if there is any immediate danger – make safe if possible
In non-emergency situations, please contact MASH on 0345 050 7666