Purpose

Ulula is committed to ensuring that its employees, contractors, suppliers, partners, vendors, interns and business operations do not exploit or cause any harm to children, young people, and vulnerable adults; and to also prevent their exposure to the risk of neglect, harm, discrimination, and abuse. Ulula acknowledges the duty of care to protect and promote the welfare of children, its employees, contractors, interns and vendors, especially when at risk of harm or abuse and to report such cases to the appropriate authorities. We will adopt and continuously establish safeguarding practices that reflect our legal responsibilities, and communicate government stipulations regarding the same and ensure compliance with recommended best practice. This policy seeks to ensure that regardless of age, gender, race, religion or belief, sex or sexual orientation, socio-economic background, ability or disability, we accept the responsibility to take reasonable and appropriate steps to ensure the safety and wellbeing of people impacted by our business  operations and respond appropriately to safeguarding circumstances that may arise.

Definitions

Safeguarding: promoting practices throughout the Company to ensure the protection of the health, wellbeing and human rights of people impacted by our business operations, and enabling them to live free from harm, exploitation, and abuse.

Human Rights: rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more.  Everyone is entitled to these rights, without discrimination.

Abuse: a violation of an individual’s human and civil rights by any other person or persons. It is a selfish act of oppression, injustice, exploitation and manipulation of power by those in positions of authority. This can be caused by those inflicting harm or those who fail to act to prevent harm. It can take the form of physical, emotional, psychological, financial, or sexual abuse, neglect, or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the health, survival, development or dignity of a child, young person, or vulnerable adult. Abuse can be a single act or repeated acts and can be unintentional or deliberate.

Discriminatory abuse: abuse motivated by a vulnerable person’s age, race, nationality, sex, sexual  orientation, disability, or other personal characteristic.

Financial or material abuse: includes theft, fraud, exploitation, pressure in connection with influencing contracts, property or inheritance, financial transactions, or the misuse or misappropriation of funds, possessions, or benefits.

Neglect: purposeful failure to meet  vulnerable person(s) basic physical and/or psychological needs, likely to result in the serious impairment of their health or development. Examples include failure to provide adequate food, clothing and shelter, failure to protect from physical or psychological harm or danger; failure to ensure adequate supervision; or failure to ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a vulnerable person’s basic emotional needs.

Physical abuse: includes hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating or otherwise causing physical harm, misuse of medication, restraint, or inappropriate sanctions.

Psychological abuse: includes emotional abuse, threats of harm or abandonment, deprivation of contact,  humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal  from services or supportive networks. Examples include not giving a vulnerable person opportunities to  express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may promote developmental or age-inappropriate expectations being imposed on a vulnerable person, which may include interactions that are beyond a vulnerable person’s developmental capability. It may involve  serious bullying (including cyber bullying), or the exploitation or corruption of a vulnerable person.

Sexual abuse: involves forcing, enticing, or coercing someone to take part in sexual activities, whether or not  the vulnerable person is aware of what is happening. The activities may involve physical contact, including  assault or non-contact activities, such as involving a  vulnerable person to participate in sexual activities, grooming or encouraging children to behave in sexually inappropriate ways.

Child/children: anyone under the age of 18 years (as defined in the United Nations convention on the Rights of a Child), irrespective of the age of majority in the country in which the child lives or in their home country. It is widely recognised that children are generally more vulnerable to abuse and exploitation due to factors such as age, gender, social and economic status, developmental stage, and dependence on others.

Vulnerable person/people: for the purposes of this policy this is an umbrella term which covers children, young people, and vulnerable adults.

Vulnerable adults: persons, 18 years and above, who by reason of disability, age, gender, social and economic status, or illness, the context they are in, may be unable to take care of or protect themselves against abuse, harm, or exploitation.

Youth or young people: individuals aged 15 to 25 and in some countries up to 35, this group spans the categories of ‘children’ and ‘adults’ but regard young people as having particular  safeguarding needs and requiring distinct consideration aside from younger children and older adults.

Scope

This policy is mandatory for all Ulula workers. For the purposes of this policy, ‘worker’ is defined as anyone who works for or on behalf of Ulula, either in a paid or unpaid capacity. This includes directly employed staff, contractors, sub-contractors, agency workers, consultants, interns, vendors, and all visitors to Ulula’s work programmes and office(s).

It also covers our partners and suppliers who we expect to abide by our safeguarding policy as a  condition of their involvement with Ulula.

This policy demonstrates how Ulula will meet its legal obligations and reassure employees,  clients, partners, and members of the public:

• On expectations from Ulula to protect and safeguard vulnerable people.
• That they can safely voice any concerns through an established procedure.
• That all reports of abuse or potential abuse are dealt with in a serious and effective manner, without retaliation or retribution to the victims, those who report the abuse or those responsible for responding to the reported concern.
• That there is an efficient recording and monitoring system in place.
• That employees, consultants, contractors, sub-contractors, agencies, and partners receive appropriate induction on safeguarding.
• That a ‘safe’ recruitment procedure is in place.

Policy Statement

Ulula acknowledges the need and rights of individuals to live free from abuse or neglect regardless of age, sex, race, ability or disability, religion, sexual orientation, marital or gender status; and is therefore, committed to creating and maintaining a safe and positive environment where people feel free to share concerns without fear of retribution.

Ulula also recognises that safeguarding is everyone’s responsibility and that it has an obligation to put in place reasonable measures to ensure, as far as possible, the safety and wellbeing of vulnerable people in our business operations.

Ulula will adhere to the following key principles to protect vulnerable people:

1. Everyone has an equal right to protection from abuse and exploitation regardless of age, race, sex, sexual orientation, marriage and civil partnership, pregnancy or having a child, gender reassignment, language, religion, political or other opinion, national, ethnic, or social origin, property, disability, birth, or other status.
2. The best interests of vulnerable persons are of utmost importance and shall be the primary consideration in our safeguarding decision making. Ulula will take responsibility to meet our obligations regarding our duty of care towards vulnerable  people, and act where we believe that a child, young person, or vulnerable adult is at risk or is harmed.
3. Ulula will ensure that all partners and suppliers are informed and in compliance with our Safeguarding Standards. When working with or through partners or sub contracted agencies, Ulula will ensure that their safeguarding procedures are consistent and in line with regulations and the principle set out in this policy. Ulula recognises that an element of risk exists, and while we may never be able to totally remove this, we need to do all we can to reduce it or limit its impact.
4. Ulula respects confidentiality and has a responsibility to protect sensitive personal data. Access to the information must be necessary for the conduct of one’s official duties. Only individuals who have legitimate reasons to access the information will be allowed to receive it.
5. Ulula commits to monitoring the implementation of the safeguarding policy, which will be reviewed annually or whenever it is deemed necessary.
6. Ulula will conduct its business in ways that respect the diverse nature of the people we work with. We recognise that there are many ways of thinking and taking care of vulnerable people and making sure they are protected. We appreciate that protecting these groups of individuals and being culturally sensitive can be a difficult balancing act. We endorse the United Nations Convention on the Rights of the Child general principle; that all the rights guaranteed by it must be available to all children without discrimination. Every child matters everywhere in the world. Culture must not be used as an excuse to abuse children, young people, or vulnerable adults.
7. Actions taken by Ulula will be consistent with the principles of safeguarding, ensuring that any action taken is prompt, proportionate and that it includes and respects the voice of those concerned.

Responsibilities

All workers – employees, consultants, contractors, sub-contractors, partner organisations, suppliers and visitors to our office(s)are required to follow this policy and maintain an environment that prevents exploitation and abuse, and which encourages reporting of breaches of this policy using the appropriate procedures.

Ulula workers will:

• Read, understand, and adhere to Ulula’s Safeguarding Policy and Code of Ethics and Business Conduct
• Strive to promote a zero-tolerance approach to discrimination, sexual harassment, and abuse in all work environments
• Strive to develop relationships with stakeholders based on equality, trust, respect, and honesty
• Place the safety and welfare of children and vulnerable people above all other considerations
• Report any concerns about the welfare of a child or vulnerable person
• Report any concerns about the behaviour of an Ulula representative in relation to safeguarding issues
• In a one-to-one situation with a child or young person, where privacy and confidentiality are important, try to make sure that another adult knows the contact is taking place and why. If possible, ensure another adult is in sight and that the child or young person knows another adult is around

Ulula workers will not:

• Sexually harass, assault, or abuse another person
• Physically harass, assault, or abuse another person
• Emotionally abuse another person, such as engaging in behaviour intended to shame, humiliate, belittle, or degrade
• Accept, or participate in behaviour which is abusive, discriminatory, illegal, or unsafe
• Develop, encourage, or fail to act when relationships with children or other vulnerable people is deemed to be sexual, exploitative, or abusive
• Act in ways that may be violent, inappropriate, or sexually provocative
• Agree with a child to keep a secret which has implications for their safety or the safety of other young people.

Managers

Managers at all levels are responsible for ensuring workers are aware of the policy and are supported to implement and work in accordance with it, as well as create a management culture that encourages a focus on safeguarding. Managers are required to respond and act immediately if they become aware of any safeguarding concerns, and support employees or contractors who complain about breaches in this policy.

Designated Safeguarding Officer(s)

The Human Resources team will be Ulula’s designated safeguarding officer(s) and be responsible for handling reports or concerns, about the protection of vulnerable people, appropriately and in accordance with the procedures of this policy.

The designated safeguarding officer is responsible for:

• monitoring and recording safeguarding concerns
• ensuring referrals to the relevant authorities happen without delay
• updating safeguarding training for all staff
• ensuring this policy is reviewed periodically
• ensuring it is implemented throughout the organisation and safeguarding training given
• ensuring monitoring and recording procedures are implemented

Ulula will continuously train and support the designated safeguarding officers on how to protect vulnerable people.

Ulula Board of Directors

Ulula’s Board of Directors is responsible for ensuring the effective implementation of this policy and associated procedures and ensuring that everyone linked with Ulula is equipped and supported to meet their responsibilities.

Procedure Overview

Recruitment and Selection:

• Safe recruitment and vetting processes are followed for all workers. For more details, refer to the Ulula Recruitment Policy. Where an employee, consultant or contractor is engaged in ‘regulated activity’ (direct work with vulnerable individuals), a criminal background check will be undertaken as part of the recruitment process.
• All Ulula employees and contractors must abide by this safeguarding policy and the Code of Ethics and Business Conduct. The code sets out the standards of practice we expect of workers as regards professional competence, integrity, acting as a representative and safeguarding – which supports our vision, mission, and values.

Induction and Support:

Advice, support, and training on safeguarding will be provided to all workers on

• What to do in the event of a disclosure (see section on reporting and responding to concerns below)
• What to do if they have concerns about the welfare of a child
• What to do if they have concerns about Ulula workers
• How to recognise signs of abuse
• Where to go for advice and support 

Ulula will ensure that clear processes for reporting and dealing with safeguarding concerns and incidents are widely communicated, regularly reviewed, and consistently applied.

Data Protection

Ulula will ensure that, according to our Data Protection Policy, all personal information is kept confidential, unless we have the consent of the individual and/or their parent/guardian, except where it is necessary to pass this to a specialised child welfare or law enforcement agency in relation to a safeguarding incident.

Minimum Standards

When working with partners, clients, and vendors, Ulula will brief them on our safeguarding policy and ask for information on how the organisation works to protect vulnerable people and ensure that they meet our Safeguarding Standards.

Social Media

Ulula will ensure the protection of children, young people, and vulnerable adults in its use of names, images, including photographs and recordings in all situations, paying attention to:

• the use of names, images of children, young people or vulnerable adults in a way that shows respect, taking care not to expose them to further vulnerability.
• reproduce images and use the names of children only when we have the written permission of their parents or guardians.
• reproduce images and use the names of young people and vulnerable adults only when we have their written permission or that of their parents/guardians.
• notify workers about this policy in relation to the use of technology, and ensure they understand not to access, produce, or distribute information that is violent or that has sexual images that are harmful to vulnerable people.

Reporting and responding to concerns

It is the responsibility of all Ulula workers to report suspicions, concerns, and allegations of actual or potential abuse or exploitation of vulnerable people or a breach of this policy. The burden to prove actual abuse or exploitation is not the workers responsibility, as long as concerns are reported to the individual’s line manager, or to the designated safeguarding officer(s) who will ensure the reported incidents are appropriately addressed and reported to the relevant authority.

To ensure reported concerns are effectively managed, it is important that:

• Suspicions and concerns should be reported by
  • sending an email on the safeguarding concern to ([email protected])
  • completing the safeguarding report form (for anonymous or guided reporting) or
  • calling peninsula helpline on 1-833-247-3656 (select option #2) (refer to the Whistleblower Policy on reportable conduct hotlines)
• Prompt action should be taken to address all reported concerns, at least within 2 business days of receiving the report.
• Although Ulula is not an investigative authority, the relevant law enforcement agencies must be contacted as deemed necessary to protect and provide needed support to vulnerable individuals, and that evidence is collected in accordance with the law.
• Urgent cases bordering on safety should be reported immediately to the police by calling 911.
• All sensitive and personal data are to be kept confidential (including the identity of workers who report abuse), and only shared when necessary, during the investigation or to respond to the incident
• Where an Ulula worker is the subject of an investigation, the designated safeguarding officer will lead the case and ensure it is appropriately addressed.

Supplier due diligence

Ulula will seek to conduct due diligence on new suppliers during on-boarding and on existing suppliers from time to time to establish their commitment to: 

• health and safety standards
• employment practices
• ensuring no use of forced, compulsory or slave labour
• ensuring employees work voluntarily and are entitled to leave work
• Safeguarding of children and vulnerable persons

Awareness

Ulula wishes to use this safeguarding policy to raise awareness on modern slavery and human trafficking as forms of abuse and commits to communicating to all workers, our commitment in the fight against abuse in all its forms; our responsibilities for safeguarding and how workers should report suspicions of abuse or exploitation.

Training

Ulula will endeavour to train its workers in addition to creating awareness on:

• Various forms of abuse in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How workers can identify the signs of abuse, slavery, and human trafficking
• How workers should respond if they suspect abuse, slavery, or human trafficking, including reporting to relevant authorities
• What external help is available for the victims of abuse
• Steps Ulula will take if a supplier fails to implement safeguarding policies or controls
• Acknowledgement from Ulula workers that they will abide by Ulula’s safeguarding policy

Amendment

Ulula reserves its right to amend or modify this Policy at any time without assigning any reason whatsoever.

Any deviation to this policy must be approved by Management.

Non-compliance and consequences

Violation of this policy by direct Ulula workers is subject to disciplinary action, up to and including termination. Direct Suppliers and partners to Ulula also stand the risk of dis-association or cancellation of business relationships if confirmed to be in violation of this policy and encouraging abuse in any form.