Child safeguarding policy

1. Scope and Purpose

The HALO Trust (HALO) is obliged to adhere to national and international child safeguarding standards, which prohibits the abuse and exploitation of children. These include local laws where HALO programmes operate, and international laws and Conventions in relation to all forms of child abuse and child exploitation, including child sex tourism, child sex trafficking, child labour and indecent images of children.

It is understood that children and young people can be extremely vulnerable to abuses of power, especially in situations of poverty, humanitarian crisis or conflict, and therefore they require a higher level of protection from harm. It is also understood that a child’s personal characteristics, such as age, gender, race, disability, life circumstances as a result of conflict, poverty or natural disaster, will further increase their vulnerability to abuses of power.

The purpose of this Policy is to protect children from harm and to ensure that appropriate action is taken when instances of harm to children do occur. The responsibility for ensuring an environment where children’s safety is paramount lies with all staff, and it is the duty of HALO leadership to ensure that all staff understand their duties to safeguard children.

This Policy will act as guidance as to what is expected from staff in relation to their interactions with children and young people. This Policy provides a framework for HALO’s engagement with anyone under the age of 18 (no matter the age of majority in any country in which HALO operates) and what to do if they have any concerns for the welfare and well-being of any child or young person.

This Policy applies globally to any HALO employees, partners, and other representatives, both during and outside of working hours. This includes the Trustees, senior managers, officers, other employees, consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with HALO, wherever they are located.

2. HALO Child Safeguarding Principles

2.1. Best interests of the child

The best interests of the child must guide all decisions that are made in respect of the child, ensuring their safety, health, and well-being is prioritised.

2.2. Zero tolerance of child abuse and exploitation

HALO has a zero-tolerance approach to any forms of child abuse or exploitation. This will be achieved by ensuring a robust preventative approach and ensuring a professional response to any concern that is reported, holding those responsible for abuse to account.

2.3. Accountability

Everyone has a role to play in ensuring that HALO is a child safe organisation. To achieve this, leadership needs to ensure that all staff understand and abide by this Policy. HALO will ensure that all staff receive training on safeguarding and that those with roles that place them in contact with children have additional child safeguarding training.

2.4. Risk management approach

The safeguarding risk assessment, that forms part of the overall programme risk assessment, must be completed by programmes and must include an assessment in relation to child safeguarding. The programme must ensure that appropriate mitigation measures are in place to ensure a child safe organisation.

Activities and programmes that work directly with children are considered higher risk and therefore require more stringent child safeguarding risk management procedures.

All staff have a duty to report actual or suspected child safeguarding concerns as a priority, using the reporting mechanisms available.

3. Minimum Standards for Child Safeguarding

These minimum standards apply to all HALO programmes and activities:

• All staff or those working on behalf of HALO will complete the Self-Declaration form;

• Ensure child safe recruitment and selection procedures are in place, especially for roles that involve direct contact with children;

• Ensure that all staff having direct contact with children have additional child safeguarding training;

• Ensure that child-friendly reporting mechanisms are in place. Wherever possible, children should be consulted on how they would wish to report a child safeguarding concern;

• Ensure a HALO member of staff who is responsible for leading child safeguarding within a programme is identified and that they coordinate with the Global Safeguarding Lead;

• Ensure child safeguarding risk management processes, as defined by this Policy, are in operation in all HALO programmes and activities;

• Ensure partners and suppliers adhere to the HALO child safeguarding minimum standards, as defined within this Policy. This must be a requirement of agreements with partners;

• Ensure that communities impacted by HALO work are informed of this Policy and minimum standards; and

• Ensure appropriate procedures and processes are in place and adhered to for the ethical collection, storage and use of children’s stories and other data, including photographic and video images.

4. Behaviours Expected of Those Having Contact with Children

Those working for, or on behalf or HALO will:

• Conduct themselves in a manner consistent with this Policy;

• Treat all children with respect, regardless of their race, gender (including gender diverse children), language, religion, opinions, nationality, ethnicity, social origin, property, disability, sexual orientation or other status;

• Immediately disclose all charges, convictions and other outcomes of an offence that they were/are subject to that relates to any form of sexual exploitation, abuse and harassment and child exploitation and abuse, including those under traditional law, which occurred before or occurs during association with HALO;

• Utilise HALO training and awareness sessions to increase their understanding of what constitutes various elements of child abuse;

• Never use language or behaviour towards children that is inappropriate, harassing, abusive, sexually provocative, intended to humiliate or culturally inappropriate;

• Never engage children in any form of sexual intercourse or sexual activity (either in person or on-line), including paying for sexual services or engaging in other transactional forms of sexual services with any person under 18 years old (or under the local age of consent where higher than 18);

• Never engage in any form of child abuse, whether sexual, physical, emotional, neglect, grooming, harassment or exploitation via digital or other means;

• Never engage in family violence which can include (but is not limited to) female genital mutilation, child marriage, trafficking and child labour;

• Never work with children as a lone worker. Always ensure that at least one other adult is present when working with children. If another adult cannot be possible, the activity must be postponed;

• Not visit a child’s home alone or invite unaccompanied children into one’s own home or accommodation (this relates to children from communities impacted by HALO work);

• Not use physical or humiliating punishment on children;

• Not consume alcohol or illicit drugs when working with, or in contact with, children;

• Not discriminate against or act in favour of particular children to the exclusion of others;

• Not seek to make contact or spend time with any child connected with HALO programs or activities outside of the designated programme or activity time;

• Not abuse their position to withhold professional assistance, or give preferential treatment, gifts or payment of any kind to a child, or another person in relation to a child in order to solicit any form of advantage or sexual favour from a child;

• Not engage in physical contact with a child that is: unprofessional, abusive, unnecessary or excessive, that makes a child feel uncomfortable or unsafe, or in a culturally insensitive (necessary physical contact would include attending to an injured child or removing a child from a dangerous situation);

• Comply with all relevant legislation, including labour laws in relation to child labour;

• Not engage in child labour, including hiring of children for domestic or other labour: which is inappropriate given their age or developmental stage, which interferes with their time available for education and recreational activities, or which places them at risk of injury or is exploitative;

• Not use any computers, mobile phones, video cameras, cameras or social media to exploit or harass children, or access child sexual exploitation material through any medium;

• Not condone or participate in behaviour with children which is illegal, unsafe or abusive;

• Immediately report concerns for the safety or wellbeing of a child, or a possible breach of the Child Safeguarding Policy in accordance with the Child Safeguarding Reporting Procedures, as outlined in this Policy;

• Speak with Management about any concerns they may have of their involvement in any situation where their words, actions or behaviour may be interpreted as a breach of this Policy; and

Act professionally towards children with whom they interact, whilst at the same time showing genuine care and compassion.

5. Safer Recruitment

HALO is committed to child safe recruitment, selection and screening practices, knowing that children who come in contact with our programmes may be vulnerable to abuse due to their circumstances. HALO will not knowingly engage – directly or indirectly – with anyone who poses a risk to children.

HALO practices aim to recruit the safest and most suitable people to work in our programmes. Our child safe practices include:

• Promoting our child safe commitment on our website, in other promotional materials and in all job advertisements;

• All positions will be assessed for the level of risk in relation to contact with children. Contact with children is defined as “Working on an activity or in a position that involves or may involve contact with children, either under the position description or due to the nature of the work environment”. Working with children is defined as being engaged in an activity with a child where the contact would reasonably be expected as a normal part of the activity and the contact is not incidental to the activity. Positions which work with children will require the highest level of screening; and

• HALO has signed up to the Misconduct Disclosure Scheme, so information on upheld cases of sexual exploitation, abuse or harassment will be shared with prospective employers, as well as seeking any such disclosure from previous employers.

6. Use of Images Involving Children (Linked to Social Media Policy)

There may be times when using images of children will help to show the work that HALO is doing. Anyone involved in this should be aware of the potential risks that the use of images and stories of children could pose to the child, such as the risk of child trafficking, child exploitation etc. When considering this, the following needs to be applied:

• Is it necessary to use photographic images of children? Are there other ways that could tell the story of the work that HALO does, when children are involved, for example, the use of artwork instead of photographs?

• Will the use of photographic images of children present any risks to the safety and well-being of the child? If so, then photographic images should not be used.

When using photographic or video images of children:

• Informed consent to be obtained from the parent/carer. This means explaining how the images will be used, and who will see the images. Consent can be withdrawn at any time, and the option of withdrawing to be explained to the child at the time of the photograph;

• Ensure that photographic and/or video images of children present them in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive;

• There should be no identifying information for a child used in the publication of images. This includes the child’s name and family name, or their home address;

• Do not take images of children associated with HALO work on personal appliances;

• Do not post images of children associated with HALO work on personal social media accounts;

• Any child whose circumstances make them vulnerable to child abuse should not have their face or other identifying features shown;

• Images are honest representation of facts and context;

• Ensure file labels, meta data, or text descriptions do not reveal identifying information about a child when sending the images electronically or publishing images in any form;

• Take care to ensure that local traditions or restrictions for reproducing personal images are adhered to before photographing or filming a child; and

• A risk assessment should be conducted prior to the publishing of any information about a child to ensure that there are no risks for the child or their family.

7. The Employment of any Person Under the Age of 18

As a humanitarian organisation, HALO works in contexts that may be conflict-affected and where there are high levels of poverty and humanitarian need. In such contexts, the risk of exploitation and abuse is elevated, especially with the increased vulnerability to abuses of power that children and young people experience. Exploitation, whether this is sexual exploitation or commercial exploitation, such as child labour, is often prevalent in such contexts, where those wishing to abuse their power have access to people with high levels of basic needs.

HALO programmes:

• Must not employ anyone under the age of 18. Age should be verified prior to any work commencing;

• Must suspend anyone suspected of being under 18 years of age from operational work whilst their age is established;

• If there are high levels of need, consideration of referrals to child protection services in the country should be made, with the consent of the parent/carer; and

• Take action against anyone who knowingly employees a child or young person under the age of 18.

It is acknowledged that in the UK, for example, HALO is working alongside schools to provide work experience for children and young people. Work experience is a part of the formal educational process for children and young people in the country, and is closely monitored by schools, with child protection systems in place to prevent any form of child abuse.

In contexts where this is in place, any such work experience/internship would need to be agreed by the HQ HR team to ensure that all appropriate child protection processes are in place. There will need to written agreement by HQ HR prior to any such work experience/internship taking place.

For Work experience, a child and young person risk assessment would need to be completed prior to any work commencement of such work experience.

8. Breaches of the Child Safeguarding Policy

Breaches of this Policy will not be tolerated and may result in disciplinary procedures being implemented. For further information on safeguarding investigations, see the safeguarding investigations SOP.

Retaliation (including but not limited to; threats, intimidation, attempts to interfere in an investigation, unfair disciplinary actions) against anyone involved in a child safeguarding incident will not be tolerated and will result in disciplinary action.

Disciplinary action may be taken against anyone found to have made an allegation that they know to be false.

9. Reporting a Child Safeguarding Concern

If you are aware of a suspected or actual child abuse concern, you have a duty to report this as soon as possible – it is vital that any such concerns are reported swiftly to ensure the safety and well-being of the child.

You can use any of the following means of reporting confidentially:

• Line Manager or other Senior Manager

• Global Safeguarding Lead: Xara Church (WhatsApp +44 744359818; Teams; safeguarding@halotrust.org)

• SafeCall (independent, anonymous): safecall.co.uk/report | +44 191 516 7749

• Local reporting mechanisms (e.g. hotline).

• Whistleblowing channel – whistleblowing@halotrust.org

Please ensure that you provide a means of contact so that you can be contacted for further information. You can report anonymously through SafeCall – if you do please follow the instructions in SafeCall so you can be further contacted.

You do not need to have conclusive evidence to report a suspected or actual child safeguarding concern, as long as you are reporting in good faith (not knowing making a false allegation). Your duty is to report. Please do not start to investigate or gather evidence, this could place children and other people at risk of harm.

10. Training Requirements

For training content, please engage with the Global Safeguarding Lead and view Confluence.

Last updated: 12 August 2026

Annex 1

When a child/young person tells you that he or she has been abused, they may be feeling scared, guilty, ashamed, angry or powerless. You, in turn, may feel a sense of outrage, disgust, sadness, anger and sometimes disbelief. If a child discloses abuse, whatever the outcome, the child must be taken seriously.

It is important for you to remain calm and in control and reassure the child/young person that something will be done to keep him or her safe.

When a child or young person’s discloses that they are being harmed you can show your care and concern for the child/young person by:

• Listening carefully;

• Telling the child/young person that their concerns are being taken seriously;

• Telling the child/young person it is not their fault, and he/she is not responsible for the abuse; and

• Thanking the child/young person for having the courage to tell you.

You will not be helping the child/young person if you:

• Show shock/outrage at their disclosure – this may well stop a child from disclosing as they may perceive that they have done something wrong;

• Make promises you cannot keep, such as promising that you will not tell anyone;

• Push the child/young person into giving details of the abuse. Your role is to listen to what the child/young person wants to tell you and not to conduct an investigation (beware of asking any leading questions as this may prejudice any subsequent investigation); and

• Indiscriminately discuss the circumstances of the child/young person with others not directly Involved

Annex 2 - Definitions

Child: any person under the age of 18

Child Abuse: Child abuse involves the abuse of children’s rights and includes all forms of violence against children: physical, emotional, and sexual abuse, neglect, family violence, sexual exploitation, abduction and trafficking, including for sexual purposes, involvement of a child in online child sexual exploitation and child labour as defined below:

Child Labour: International standards define child labour as work that that is hazardous to a child’s health and development, demands too many hours and/or is performed by children who are too young. Usually, child labour interferes with a children’s right to education and play

Child Marriage: A formal marriage or informal union before age 18 is a reality for both boys and girls, although girls are disproportionately the most affected. Child marriage is widespread and can lead to a lifetime of disadvantage and deprivation.

Child Trafficking: the action or practice of illegally procuring and relocating children, typically for the purpose of forced labour of sexual exploitation. Trafficking is where children and young people are tricked, forced or persuaded to leave their homes and are moved or transported and then exploited, forced to work or sold. Traffickers often groom children, families and communities to giant their trust. They may also threaten families with violence or threats. Traffickers often promise children and families that they will have a better future elsewhere.

Commercial Sexual Exploitation of Children: Comprises sexual abuse by the adult and remuneration in cash or kind to the child or a third person or persons. The child is targeted as a sexual object and as a commercial object. The Commercial Sexual Exploitation of Children constitutes a form of coercion and violence against children and amounts to forced labour and a contemporary form of slavery

Emotional Abuse: A persistent attack on a child’s self-esteem. Examples include, but are not limited to - name-calling, threatening, ridiculing, shaming, intimidating or isolating the child. Family violence: Includes verbal, physical, sexual, or emotional violence within the household or family, which the child witnesses, usually on a regular basis.

Neglect: The persistent failure, where there are means, or the deliberate denial to provide the child with clean water, food, shelter, sanitation or supervision or care to the extent that the child’s health and development is placed at risk.

Online Child Sexual Exploitation: Includes all acts of a sexually exploitative nature carried out against a child that have at some stage, connection to the online environment. It includes any use of Information and Communication Technologies (ICT) that results in sexual exploitation or causes a child to be sexually exploited or results in or causes images or other material documenting such sexual exploitation to be produced, bought, sold, possessed, distributed, or transmitted.

Physical Abuse: When a person purposefully injures, or threatens to injure, a child. Physically abusive behaviour includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling, and poisoning. It also includes cultural practices which can alter physicality in ways that cause distress, harm and/or cause lasting health ramifications such as Female Genital Mutilation.

Child Sexual Abuse: When a child is used by another child, adolescent or adult for his or her own sexual stimulation or gratification. Sexual abuse involves contact and non-contact activities which encompasses all forms of sexual activity involving children, including exposing a child to online child sexual exploitation material, or taking sexually exploitative images of children.