Safeguarding Policy

Introduction

This Policy applies to every employee of The ESG Institute Limited ("the Company") as well as to contractors, consultants, agency workers, volunteers, interns and any other person who carries out work in our name. It sets out our commitment to protecting children, young people and adults at risk of harm with whom our trainers, consultants and support staff may come into contact in the course of delivering programmes. The Policy is issued pursuant to the Safeguarding Act 2018 (Isle of Man), the Children and Young Persons Act 2001 (Isle of Man), the Vulnerable Adults (Safeguarding) Act 2011 (where applicable in the Channel Islands or the United Kingdom), the Criminal Justice Act 1990 (Isle of Man) Part I sexual offences provisions, the Employment Act 2006 (Isle of Man), and the Data Protection Act 2018 (Isle of Man). Nothing in this Policy limits or replaces the statutory obligations contained in those enactments.

Policy Statement

The Company believes that the welfare and dignity of every child and adult at risk are paramount. We recognise our duty of care and accept our responsibility to safeguard and promote the welfare of children and vulnerable people by protecting them from abuse, neglect or exploitation. The Company will take all reasonable practicable steps to create and maintain a safe environment, to identify when there is cause for concern, and to respond appropriately to disclosures, allegations or suspicions of harm. Safeguarding is a shared responsibility: all personnel are expected to be alert to the signs of abuse and to act swiftly in accordance with this Policy.

Scope

Safeguarding applies wherever Company activities involve, or may involve, contact with children or adults at risk. This includes face‑to‑face training sessions, online or hybrid delivery, consultancy engagements, site visits, social events linked to work, and any travel or accommodation arranged by the Company. It also extends to digital communications, social media interaction, the creation or handling of images and case‑study material, and the storage of personal data.

Legal Framework and Guidance

Our approach is underpinned by the Safeguarding Act 2018, which establishes the Isle of Man Safeguarding Board and places duties on relevant organisations to safeguard and promote welfare. We follow the Isle of Man Safeguarding Board Inter‑Agency Child Protection and Adult Safeguarding Procedures 2023, the UK Working Together to Safeguard Children 2023 where it provides best practice, and guidance issued by the Disclosure and Barring Service (DBS) regarding regulated activity. In cases of overseas work we observe local child‑protection law as a minimum and default to Isle of Man standards where these are higher.

Roles and Responsibilities

The Board of The ESG Institute holds ultimate accountability for safeguarding. The Board appoints a Designated Safeguarding Lead (DSL) at senior‑management level, supported by at least one deputy. The DSL develops and maintains the Policy, provides advice, ensures staff training, liaises with external agencies and reports annually to the Board. Managers must promote safe practice within their teams, verify that personnel are appropriately vetted and supervise activities that involve children or adults at risk. Every worker must familiarise themselves with this Policy, complete mandatory safeguarding training, follow the Code of Conduct and immediate‑report procedures, and cooperate fully with any investigation.

Safer Recruitment and Vetting

All roles that involve unsupervised or substantial contact with children or adults at risk are classed as regulated activity. Candidates for such roles will be subject to enhanced DBS checks with barred‑list information, verification of identity and right to work, review of employment history and references, and, where appropriate, overseas police checks. Recruitment adverts and documentation will state the Company’s safeguarding commitment and the requirement for checks. Offers of employment or engagement are conditional on satisfactory vetting results and completion of safeguarding induction.

Code of Conduct

Personnel must act professionally, respectfully and in a manner that always places the welfare of children and adults at risk first. They must avoid lone working wherever practicable; ensure, where lone contact is unavoidable, that it is time‑limited, openly recorded and, wherever possible, observable by others; maintain appropriate boundaries; obtain written informed consent before collecting images or personal stories; use Company devices and channels for communications; and immediately report any breach of this Code to the DSL.

Recognising Abuse and Neglect

Abuse may be physical, emotional, sexual or neglectful. Indicators can include unexplained injuries, fearfulness, sudden behavioural change, sexualised behaviour inappropriate to age, poor physical care or withdrawal. Adults at risk may also be subject to financial or institutional abuse, discriminatory abuse or self‑neglect. Personnel do not need to be certain that abuse has occurred; any suspicion, allegation, disclosure or unexplained injury must be treated seriously and reported.

Reporting and Responding

Anyone who has a concern must report it immediately to the DSL or, in their absence, to a deputy. If there is an imminent risk of serious harm, emergency services must be contacted without delay (dial 999) and the DSL informed thereafter. The DSL will decide, within twenty‑four hours, whether to refer the matter to the Isle of Man Safeguarding Board, the Department of Health and Social Care’s Children and Families Division, the Police, or other statutory authorities, and will keep a secure record of the decision‑making process. The reporter will receive confirmation that the concern has been logged and advice on next steps. Confidentiality will be maintained as far as possible, but information may be shared with agencies that need to know in order to protect the individual.

Support for Those Affected

The Company recognises that raising or being subject to a safeguarding concern can be distressing. Counselling or employee‑assistance services are available to all employees. Where an allegation is made against a member of staff, the Company will provide support while the matter is investigated and will follow its Disciplinary Procedure, ensuring fair treatment and the presumption of innocence until proven otherwise.

Record‑Keeping and Data Protection

All safeguarding records, including reports, decisions and action taken, will be kept securely and separately from personnel files. Access is limited to the DSL, deputies and senior leadership on a need‑to‑know basis. Records will be retained for the longer of six years after case closure or, in the case of children, until the subject reaches twenty‑five years of age, unless legislation mandates a longer period.

Review

This policy is to be reviewed every two years, or earlier if there are significant changes in law or our operations.

Latest update: June 30, 2025.

This Policy is non‑contractual and may be amended at the Company’s discretion.