Child Safeguarding Policy – Implementation PlanJuly 2014

PurposeThis document sets out the steps MEC will take to ensure compliance with SCI and DFAT Polices. As a part of SCI, MEC adopts SCI Child Safeguarding policy. However, as a key donor, MEC also recognises DFAT Child Protection Policy and, where differences exist, aims to incorporate these into our ways of working.

Terminology – DFAT refer to Child Protection where SCI refer to Child Safeguarding where the requirements are very similar. For the purpose of this document we use the term Child Safeguarding (CS) to remain consistent with SCI policy.

Policy Requirements Review Applies to DFAT contractors and sub-contractors Zero-tolerance policy to abuse of any kind Risk management approach. Acknowledge it is not possible to eliminate all risks, but

identification and active management is essential Immediate notification required in case of any breach of policy

Due Diligence on child protectionNo

Requirement Evidence

1 Every Partner has a child protection policy- Must apply to personnel, partners, contractors,

anyone performing part of a DFAT funded activity

- CP Policy- Awareness of personnel- Documented implementation plan

2 Regular Policy Review (minimum every five years) - Policy review report3 Child Protection Training - Training plan / agenda

- Training materials4 Code of Conduct (DFAT compliant) - CoC

- CoC signature register5 Recruitment Screening

- Criminal records check- Verbal Referee Check- Interviews include behavioural-based questions

around working with children

- Documented criminal checks- Documented referee checks- Interview questions- Applicant request for disclosure of

child exploitation offences6 Reporting Mechanism

- Includes sanctions for breach of policy- Reporting Guidelines- Guidelines for managing reported

incidents- Disciplinary policy

7 Inappropriate people prevented from working with - Employment contract

children- Sanctions include dismissal, suspension or transfer

- HR policy

8 Risk Assessments- Covers all DFAT funded activities where there is

contact with children

- Risk Assessments- Evidence of action points and

monitoring

Child Safeguarding Implementation PlanWe distinguish between the MEC management team activities and partner activities to reflect the very different risk profiles in the project

Risk AssessmentMany MEC management team members will have little or no contact with children. The management team primarily provides support to partners, who themselves often work through teachers and not directly with children. Staff will have some contact with staff through monitoring visits, but this is expected to be in the company of others and for short durations. (Low – Moderate Activity Inherent Risk) MEC is not a “child-focused” organisation according to the DFAT model as we are not providing services directly to children. (Low Organisational Inherent Risk)

Many MEC partners will vary in risk assessment based on both activities, the degree to which they are directly providing services for children and the strength of their systems for child safeguarding. Each partner will require a specific risk assessment. Measures for addressing high or very high risks are outlines below.

RISK FACTOR IDENTIFIED AND DESCRIPTION OF THE

RISK FEATURES

RISK RATING (LOW,MEDIU

M, HIGH)STRATEGIES TO

REDUC RISKRISK MONITORING –

WHO IS RESPONSIBLE AND TIMEFRAME

MEC staff engage in appropriate behaviour with children

MEC staff will have limited contact with children as the management team is engaged mainly in monitoring partner performance rather than beneficiaries.

Low

Med

High

In line with SCI policy, including recruitment checks, training and awareness, reporting requirements and HR policy in case of breach.

No additional monitoring activities outside of normal SCI CS activities.

Partner organisations fail to meet child safeguarding standards

MEC is implemented entirely through partners, representing a wide range of organisations with very

Low

Med

High

All proposals are reviewed to indentify CS risks and mitigation strategies

Decline funding for proposed high-

Proposal review stage. MEC management team.

Proposal Selection Stage. MEC

RISK FACTOR IDENTIFIED AND DESCRIPTION OF THE

RISK FEATURES

RISK RATING (LOW,MEDIU

M, HIGH)STRATEGIES TO

REDUC RISKRISK MONITORING –

WHO IS RESPONSIBLE AND TIMEFRAME

different understanding of CS requirements and some with low capacity in policy development and implementation.

Partner activities generally have limited level of direct contact with beneficiaries.

risk activities where partners do not have demonstrated capacity to manage the risk

CS training with all partners to meet SCI & DFAT requirements

Monitoring implementation and compliance

management team.

Within first quarter of project start date. Capacity Building Team

MERL and CB teams include CS implementation plan monitoring into regular monitoring trips

MEC Management TeamAs above the risk associated with the MEC management team is deemed to be low risk. As part of Save the Children International, MEC adopts SCI child safeguarding policy. Save the Children Australia are an accredited NGO through DFAT and during the visit of an AMNEP consultant (Shelley Casey) visit to support partner risk management procedures (February 2014) a review was made of SCI and DFAT policy and found to be fully compliant. This document outlines the CS implementation plan.

DFAT will conduct training with all MEC staff – planned for August 2014. All staff receive induction on CS as part of the SCI induction. SCI policy is compliant with DFAT requirements and MEC will rely on SCI systems to meet all aspects of the SC policy for the management team.

MEC PartnersMEC partners will have mixed level of experience in understanding and implementing child safeguarding policy and procedures. Child Safeguarding considerations will be included at each stage of the partner management process

Information Sharing – MEC grant materials including statements on the importance of child safeguarding. Detailed child safeguarding training is included at proposal development stage (RFP)

Proposal Review - proposals include a section requiring partners to consider child safeguarding risks and identify their current organisational status in implementing child safeguarding practices and this is specifically considered in the proposal review.

Proposals are reviewed to identify specific child safeguarding risks.

Activities considered very high risk (to date only residential care activities have been deemed very high risk) will be discussed with applicants and unless they can demonstrate experience in managing those risks they will be asked to remove the activity from the proposal.

Partners with activities considered high risk will be required to provide details of their experience and plans to mitigate the risk before taking the proposal forward for consideration

Organisational Assessment – includes a dedicated assessment requirement for child safeguarding.

Contracting – all partner organisations are required to sign against SCI standard CS policy. This is discussed in detail at the project start-up workshop and all participants are made aware of their responsibilities.

Training – all partners unable to demonstrate compliance with child safeguarding requirements are required to attend CS training. The training agenda covers all aspects of SCI / DFAT requirements. The training covers policy development, risk assessment, policy implementation, codes of conduct and HR policy requirements. All partners are required to develop plans to meet CS requirements.

Monitoring – all partners will be visited at least every six months, most on a quarterly basis. Monitoring trips to each organisation will include monitoring implementation of the CS plan.

Review – MEC management team will review the implementation of the CS plan within one year of starting to work with new partners or prior to starting a new grants round, whichever comes first.