InterGreatEducation GroupGuardianship services

UK guardianship · Policy documents

Child Safeguarding and Protection Policy

Public copy updated 1 November 2026 · Review annually and when requirements change

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Introduction

The aim of this policy is to ensure transparency in the actions of any adult within the organisation's scope of work and to safeguard and promote the welfare of all young people. If any parent or young person/child has concerns about the conduct of any member of the organisation, these concerns should be raised initially with Terence Murray (Designated Safeguarding Lead - (+44) 0203 856 8180).

In accordance with Keeping Children Safe in Education (2026), the definitions of safeguarding and promoting the welfare of children for the purposes of this policy include: "protecting children from maltreatment; preventing impairment of children’s mental and physical health or development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes."

InterGreat Education Group acknowledges that safeguarding encompasses the responsibilities of child protection and the promotion of the rights and welfare of children. Therefore, InterGreat Education Group maintains the following principles:

In alignment with Keeping Children Safe in Education (2026), InterGreat Education Group recognises that:

Safeguarding statement

InterGreat Education Group is dedicated to ensuring the welfare and protection of children and young people. We expect all staff, volunteers, host families, and individuals associated with the organisation to share this commitment. This commitment is evident in our comprehensive child protection policies, rigorous safer recruitment practices, our ongoing training program, and the additional welfare support provided to our students. It is our fundamental goal that every young person under the care of InterGreat Education Group feels secure and shielded from any form of abuse or neglect.

Recognising that a commitment to safeguarding and child protection begins at the leadership level, both Directors of InterGreat Education Group have previous experience as DSL/DDSL. They continually enhance their knowledge in this area by staying updated with Government and NSPCC updates relevant to their roles. The Directors oversee all arrangements, and all procedures are guided by policy, demonstrating a steadfast dedication to keeping young people safe from harm.

InterGreat Education Group firmly believes in the following principles:

Policy background and relevant legislation

The Safeguarding and Child Protection Policy is interconnected with and guides all policies and procedures adhered to by InterGreat Education Group. This includes but is not limited to the following policies and documents:

InterGreat Education Group will fulfil local and national responsibilities as laid out in the following documents.

These government documents inform the below policy and are referred to throughout for guidance:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/550416/Children_ Missing_Education_-_statutory_guidance.pdf

Safeguarding and Child Protection Policy aims

InterGreat Education Group aims to:

Definition of terms, and how to recognise abuse and neglect

Safeguarding constitutes the proactive measures taken to enhance the well-being of children and shield them from harm. It involves:

Child Protection is an integral facet of the safeguarding process. It concentrates on shielding individual children identified as suffering or likely to endure significant harm. This encompasses detailed child protection procedures outlining responses to concerns about a child.

Guidance and legislation on safeguarding children and young people, along with child protection, extend to cover all individuals up to the age of 18.

It is crucial for all staff, volunteers, and host families to recognise that instances of abuse, neglect, and safeguarding concerns rarely exist in isolation, often intertwining with multiple issues.

Abuse signifies a form of maltreatment inflicted upon a child. It can manifest through intentional harm or the failure to act to prevent harm. Children may experience abuse within familial, institutional, or community settings, perpetrated by individuals known to them or by strangers (e.g., online). Perpetrators can be adults or other children.

Physical Abuse

Physical abuse, while widely recognised, can be challenging to pinpoint. It encompasses any act causing physical harm to a child, such as hitting, shaking, throwing, poisoning, burning, scalding, drowning, suffocating, or any action leading to physical harm. Instances where a parent or caregiver fabricates or deliberately induces illness in a child also fall under this category. Physical abuse may extend beyond individual acts, often intertwining with cases of domestic abuse, 'honour'-based violence, child-on-child abuse, and other related situations. Identifying these instances requires careful consideration and awareness.

Indicators may include but are not limited to:

Emotional abuse

Persistent maltreatment causing severe and detrimental effects on a child's mental health and development is categorised as emotional abuse. It can manifest in various subtle ways, making it challenging to detect compared to other forms of abuse. Emotional abuse plays a role in almost all abuse types, leaving a profound impact on the well-being of a young person. Examples of maltreatment include, but are not limited to:

Indicators may include, but are not limited to:

Sexual Abuse

Sexual abuse involves coercing or enticing a child or young person to participate in sexual activities. The extent of violence is not necessarily high, and the child or young person may or may not be cognizant of what is occurring. This category encompasses both physical and non-physical acts of sexual abuse, with penetrative or non-penetrative acts typically involving physical contact. Penetrative acts include rape, oral assault, and digital penetration, while non-penetrative acts comprise activities like kissing, rubbing, masturbation, or touching over clothes—all of which are considered forms of sexual abuse. Non-contact activities, such as involving children in viewing or participating in the creation of sexual images, watching sexual activities, encouraging children to engage in sexually inappropriate behavior, or grooming a child in preparation for abuse, are also classified as sexual abuse. It is essential to dispel the misconception that sexual abusers are solely adult males; women and other children can also commit acts of sexual abuse.

Indicators may include but are not limited to:

Neglect

Neglect is the persistent failure to meet a child's basic physical and/or psychological needs, likely resulting in the serious impairment of the child's health or development. Neglect can occur at various stages in a child's life, from pregnancy (due to maternal substance abuse) to the failure to provide adequate food, clothing, or shelter. Neglect may involve exclusion from the home or abandonment, representing a failure to protect a child from physical/emotional harm or danger. Neglectful behaviours encompass inadequate supervision, the use of insufficient caregivers, and the failure to provide access to appropriate medical care or treatments. It may also involve unresponsiveness to a child's basic emotional or physical needs.

Indicators may include but are not limited to:

Child Criminal Exploitation (CCE), Child Sexual Exploitation (CSE) and Female Genital Mutilation (FGM)

Child Criminal Exploitation (CCE)

Child Criminal Exploitation (CCE) is a form of emotional or physical abuse targeting vulnerable children for monetary gain, power, or elevated status. Activities associated with CCE encompass, but are not confined to, pickpocketing, shoplifting, county lines involvement, drug trafficking, and participation in violent crimes. Once children fall victim to this exploitation, they may face coercion into additional acts of violence or criminal behaviour. Both boys and girls are susceptible, and there is a concern about potential association with Child Sexual Exploitation (CSE). Due to the nature of the abuse, victims of CCE may not always be recognised as vulnerable, given the nature of the crimes involved, leading to a sense of being trapped in an abusive situation.

Indicators of Child Criminal Exploitation may include, but are not limited to:

Child Sexual Exploitation (CSE)

Child Sexual Exploitation (CSE) is a form of sexual abuse where children are sexually exploited for monetary gain, power, sexual gratification, or elevated status. This can involve violent, humiliating, and degrading sexual assault. In certain instances, children may be coerced or compelled to engage in sexual activity in exchange for money, drugs, affection, gifts, or status. It is crucial to emphasise that consent cannot be given, even if a child believes they are willingly participating in sexual activity with the exploiter. CSE does not necessarily require physical contact and can occur online or via mobile phones. Similar to Child Criminal Exploitation (CCE), victims of Child Sexual Exploitation may feel trapped in a cycle of abuse due to their exploitative nature. Many victims of CSE may go missing from home, care, or education at some point.

Indicators of Child Sexual Exploitation may include, but are not limited to:

Female genital mutilation (FGM)

Female Genital Mutilation (FGM) is a deliberate practice involving the intentional alteration or injury of female genital organs for non-medical reasons. recognised as a violation of human rights, it is illegal in many countries, including the UK. Unfortunately, it remains a surprisingly common form of abuse for young women in the UK. Under the Female Genital Mutilation Act 2003 (inserted by Section 74 of the Serious Crime Act 2015), teachers and professionals with a duty of care have a mandatory reporting duty to report any concerns (disclosure or visual confirmation) about FGM on an individual under 18 to the police.

The prevalence of FGM varies based on the child's community and background, occurring shortly after birth, during childhood or adolescence, before marriage, or during the first pregnancy. FGM poses severe short and long-term physical and psychological health risks. InterGreat Education Group takes concerns about FGM and the mandatory reporting duty seriously, ensuring that staff and hosts are aware of possible signs and indicators that may suggest FGM.

Risk Factors

Indicators

Indicators that a girl or woman has been subjected to FGM include, but are not limited to:

Under mandatory reporting requirements, professionals must report cases where they discover that an act of FGM appears to have been carried out on a girl under 18, either through victim disclosure or visual evidence. Staff, volunteers, and host families are encouraged to report any FGM concerns directly to the local police or to the DSL, who can make the report on their behalf if needed. If a direct referral is made to the police, the Designated Safeguarding Lead should be informed promptly.

Radicalisation and the PREVENT duty

Radicalisation is the process through which individuals come to support terrorism or violent extremism and may choose to participate in activities associated with terrorist organisations. This process varies for each individual and unfolds over time, rather than occurring as a single event. Recognizing potential signs and indicators of radicalisation is crucial for staff and volunteers.

Similar to grooming or general online safety concerns, children and young people may be susceptible to exposure or involvement with individuals promoting radical ideologies or advocating violence for political or ideological purposes. Exposure to extreme ideologies can happen through various channels, including family members, friends, direct contact with extremist groups, online platforms, and social media. The risk of radicalisation increases the likelihood of involvement in criminal activities, posing a significant threat.

PREVENT is an integral part of the UK's counter-terrorism strategy, focusing on supporting and safeguarding vulnerable individuals at risk of exploitation by radicalizers and potential engagement in terrorist-related activities. Not centred around race, religion, or ethnicity, PREVENT aims to prevent the exploitation of susceptible individuals. Regular PREVENT training for all staff and host families enhances vigilance and awareness, enabling early intervention, prevention, and support for the young person.

Indicators may include, but are not limited to:

If staff members observe concerning changes in behaviour or witness anything that raises alarms, they are encouraged to seek advice from the Designated Safeguarding Lead, who serves as the Prevent Lead for InterGreat Education Group. This proactive approach allows for early intervention, prevention, and support for individuals at risk of radicalisation.

For further information on the Prevent (anti-radicalisation policy) the full policy is available on all websites.

Non-urgent advice is available from the DfE on 020 7340 7264 or via email at: counter-extremism@education.gsi.gov.uk

Domestic Abuse, ‘Honour’ based violence and Child-on-child Abuse

Domestic Abuse

Domestic abuse encompasses any incident or pattern of incidents involving controlling, coercive, threatening, violent, or abusive behaviours between individuals aged 16 or over who are or have been intimate partners or family members. This definition is not restricted by gender or sexuality and encompasses various forms of abuse, including psychological, physical, sexual, financial, and emotional.

The risk to children and young people is significantly elevated in households experiencing domestic abuse. Prolonged exposure to such environments increases the risk of significant or long-term harm, which may impact future relationships.

Host families and schools, given their close relationships with children, are well-positioned to provide appropriate support, either independently or in collaboration with other agencies. Recognizing signs of domestic abuse or potential risk allows for timely interventions and referrals to relevant support services.

‘Honour’ based violence

'Honour' based violence constitutes crimes committed with the intent of protecting the 'honour' of a family or community. This includes, but is not limited to:

InterGreat Education Group acknowledges that all instances of 'honour' based violence fall within the safeguarding and child protection framework, and they will be handled accordingly. Any concerns will be reported to the relevant authorities, and support systems will be recommended to best assist the victims.

Child-on-child abuse

Child-on-child abuse encompasses various behaviors that children or young people may encounter, and it can manifest in diverse ways. While our behaviour agreement and anti-bullying policy typically cover most interactions among children and young people, certain allegations may be of such severity that they raise additional safeguarding concerns. InterGreat Education Group acknowledges that children are capable of abusing others, and such behaviour will not be dismissed as 'banter' or 'part of growing up.' The various forms of child-on-child abuse are detailed below:

The term "child-on-child abuse" can encompass all these definitions, and a child may experience one or multiple forms of abuse simultaneously. Consequently, our response will cut across these definitions to address the complex web of their experiences. Gender issues may also be prevalent in cases of child-on-child abuse, such as girls being sexually touched/assaulted or boys being subjected to initiation/hazing type violence.

Research suggests that young people rarely disclose instances of child-on-child abuse, and if they do, it is likely to be to their friends. Therefore, we will educate the children and young people we work with on how to support their friends if they are concerned, encouraging them to talk to a trusted adult or someone at their school, and informing them of services they can contact for further advice. In line with our Anti-Bullying Policy and KCSIE (2023) advice, we will collaborate with the school and the young person to provide effective contextual safeguarding relevant to their individual experience.

Any concerns, disclosures, or allegations of child-on-child abuse in any form should be reported to the Designated Safeguarding Lead. If the DSL deems it necessary, advice and guidance will be sought from LSCP. In cases where a crime has been committed or there is a risk of a crime being committed, the police will be contacted.

Online Safety

With continuous updates on the risks of encountering potentially harmful information, experiences, images, or people online, InterGreat Education Group recognises its duty to safeguard children and young people through education, support, and ongoing vigilance. The online issues that may arise can be broadly categorised into the following four sections, as outlined in Keeping Children Safe in Education (2026):

Content: Exposure to illegal, inappropriate, or harmful content, such as pornography, fake news, racism, misogyny, self-harm, suicide, anti-Semitism, radicalization, and extremism.

Contact: Harmful online interaction with other users, including child-to-child pressure, commercial advertising, and adults posing as children or young adults with the intention to groom or exploit them for sexual, criminal, financial, or other purposes.

Conduct: Online behaviour that increases the likelihood of, or causes, harm, such as making, sending, and receiving explicit images (consensual and non-consensual sharing of nudes and semi-nudes), sharing other explicit images, and online bullying.

Commerce: Risks like online gambling, inappropriate advertising, phishing, and financial scams.

To ensure the promotion of safer internet use, the Designated Safeguarding Lead will regularly undertake 'Keeping Children Safe Online,' and staff and hosts will receive annual updates on best practices for online access as part of their safeguarding training. Regarding filtering and monitoring, host families are strongly encouraged to set up parental controls on their home WiFi, and schools have filtering and monitoring systems in place. While personal devices may have access to unfiltered websites, young people should be encouraged to remain vigilant about potential online harm. Students are required to read and agree to an online usage policy and be made aware of potential online issues, as detailed in Keeping Children Safe in Education 2026.

Specific issues to raise with students and be aware of include, but are not limited to:

Sexting

Dealing with incidents involving nudes or the sharing of nudes is complex due to legal considerations. In accordance with the Protection of Children Act (1978) and the Criminal Justice Act (1988), taking, making, circulating, or possessing indecent photographs or pseudo photographs of a child is a criminal offence. The Sexual Offences Act (2003) defines a child as anyone aged 18 or below, making the taking, possessing, and sharing of nudes illegal.

In cases where images are shared consensually as part of normal development or experimentation, the focus would be on safeguarding the young person rather than criminalising them. Any incidents involving indecent images kept or shared of a person under 18 would be assessed with contextual information to ensure a fair and safe environment for the young person. Concerns related to bullying, coercion, or sexual exploitation would involve the police in line with KCSIE recommendations.

Staff receive regular training in preventing the distribution of indecent images of a child and aim to educate, alongside the school, on appropriate peer contact to safeguard young people from the potential harm and significant impact sexting may provoke. Incidents are dealt with proportionately to the displayed behaviour, with the safeguarding of the child paramount at all times.

Advice for children and young people is available at: http://www.thinkuknow.co.uk https://www.childline.org.uk/explore/onlinesafety/pages/sexting.aspx

Advice for Host families and parents is available at:

Keeping children safe online | NSPCC

Addressing child-on-child abuse: a resource for schools and colleges (farrer.co.uk)

Safeguarding Responsibilities

All Staff, Volunteers, and Host Families

Every member of InterGreat Education Group, including staff, volunteers, and host families, plays a crucial role in safeguarding and child protection for our students. The organisation is committed to ensuring that the social and emotional welfare needs of the children and young people in its care are met, emphasising that safeguarding and child protection are collective responsibilities.

All staff, volunteers, and host families must familiarise themselves with the Safeguarding and Child Protection Policy and adhere to the outlined procedures. Their shared responsibility includes providing a safe environment for the children and young people under their care.

Host families, following their Safeguarding and Child Protection training, are obliged to follow documented procedures when a child or young person makes an abuse allegation or when concerns about possible abuse arise. Any concerns should be reported to the InterGreat Education Group Designated Safeguarding Lead within 24 hours of disclosure. Alternatively, staff or host families may directly refer the matter to their Local Safeguarding Children Partnership (LSCP) and then inform the InterGreat Education Group Designated Safeguarding Lead.

Designated Safeguarding Lead

InterGreat Education Group has designated Terence Murray as the Designated Safeguarding Lead (DSL), a senior manager within the company. Terence can be contacted at (+44) 0203 856 8180. Parents, staff, host families, volunteers, and schools are encouraged to reach out to Terence if they have concerns about the welfare of a child or young person in the care of InterGreat Education Group.

The DSL's responsibilities include:

Initial training is conducted through a formal online course (Introduction to Safeguarding) with relevant follow-up training and annual updates for host families and staff. Host family updates are provided via email, while staff receive office training led by the Designated Safeguarding Lead.

Promotion of Safeguarding and Child Protection

Four Key Skills for Promoting a Healthy Environment and Preventing Safeguarding Issues:

Cause for Concern:

Disclosure

A disclosure occurs when a child or young person reports abuse or neglect directly. It is essential to capture this report verbatim, in the child's own words. In cases of disclosure, the following responses are crucial:

Once the Designated Safeguarding Officer is informed, they will discuss necessary steps to protect the individual who disclosed. The staff, volunteer, or homestay member should continue providing support and monitor the situation. While passing on any new concerns to the DSL, they should refrain from investigating the matter, as this could prejudice other agencies' investigations and cause additional distress to the child or young person. Staff, volunteers, or host families should not actively seek disclosures but rather observe, inquire, listen, be available, and make time to talk when necessary.

Observed Behaviour

Observed behaviour typically entails changes in behaviour or actions noticed by staff or witnessed by host families, reported to staff or the Designated Safeguarding Lead. InterGreat Education Group's procedure for observed behaviour aligns with the same practices as with any disclosure, involving the submission of a detailed Cause for Concern form to our secure system.

It is crucial to emphasise that staff, volunteers, or host families should not take on the role of diagnosing or investigating observed behaviours. Their responsibility is to recognise when something might be wrong, inquire about it, listen attentively, be available, and make time to talk. Once the Designated Safeguarding Lead is informed of the observed behaviour, the staff, volunteer, or host family should continue providing support to the child or young person and carefully monitor the situation. They must convey any additional information or new concerns to the DSL but refrain from investigating the matter themselves, as it may potentially prejudice the investigations of other agencies and cause further distress to the child or young person.

Discussion of Concerns

A common pathway for cause for concern at InterGreat Education Group involves input from other professionals at school or parents. Continuous communication with both schools and parents enables the expectation that any issues will be raised through this avenue. By addressing concerns, collaborating with school partners or local authorities, we can provide additional support to the student.

Concerns raised in this manner should be reported through a detailed Cause for Concern form submitted to our secure system. Any correspondence from parents or schools should also be submitted promptly.

Staff, volunteers, or host families should not attempt to resolve or provide suggestions for the concerns raised by other parties. Their role remains focused on observation, inquiry, listening, availability, and making time to talk. Once the Designated Safeguarding Lead is informed of the concern, the staff, volunteer, or host family should persist in providing support to the child or young person and diligently monitor the situation. While conveying any further information or new concerns to the DSL, they should refrain from investigating the matter independently to prevent potential prejudice to the investigations of other agencies and minimise distress to the child or young person.

Staff, volunteer and host family response to any cause for concern

Staff, volunteers, and host families who suspect abuse, notice signs of neglect, or hear a complaint of abuse involving a student under the care of InterGreat Education Group should promptly notify the Designated Safeguarding Lead. In the absence of the Designated Safeguarding Lead, the Deputy Designated Safeguarding Lead should be contacted. Subsequently, they are required to complete the Cause for Concern form available in Appendix 1 or through the online link.

Once the Designated Safeguarding Lead is informed, the staff, volunteer, or host family should vigilantly monitor the situation. Any additional information or new concerns should be communicated to the DSL, but they should refrain from investigating the matter independently to avoid prejudicing other agencies' investigations and causing further distress to the child or young person.

Actions and Responses by the Designated Safeguarding Lead:

Designated Safeguarding Lead's Actions When Abuse is Suspected or a Complaint is Made:

The Designated Safeguarding Lead considers the inter-agency procedures of the Local Safeguarding Children Partnership and follows the guidance from Working Together to Safeguard Children (2026) and Keeping Children Safe in Education (2026). The nature and seriousness of the suspicion or complaint are carefully assessed.

The Designated Safeguarding Lead engages with the child or young person, considering their wishes, provided they are of sufficient understanding and maturity. However, in serious situations, decisions may be made after appropriate consultation, even if they override the child or young person's wishes.

Discussion with parents may occur, provided there is no conflict of interest and they are properly informed. If disclosing information to parents might put a child at risk, further advice is sought from relevant professionals before making a disclosure decision.

If it is likely that a child or young person has suffered significant harm or is at risk, a referral to Children’s Social Care (LSCP) is made promptly, and certainly within 24 hours. In cases of doubt, the Designated Safeguarding Lead consults with the Local Authority Designated Officer or Multi-Disciplinary Team on a no-names basis.

If the Designated Safeguarding Lead decides not to refer concerns to the relevant authorities, the person raising the concern is given a clear statement of reasons. There is no retribution or disciplinary action against a staff member for making a report in good faith.

If the initial referral is made by telephone, the Designated Safeguarding Lead confirms the referral in writing to Children Social Care within 24 hours. If no response is received within three working days, the Designated Safeguarding Lead contacts Children Social Care again.

Allegations against InterGreat Education Group Staff / Host families

It is imperative that InterGreat Education Group's staff feel confident in reporting concerns about potentially unacceptable or unsafe conduct towards colleagues, children, or young people under their care. All concerns raised should be treated with fairness and equality, with a commitment to taking every allegation seriously.

InterGreat Education Group has established procedures for addressing allegations against its staff, volunteers, and host families. These procedures aim to strike a balance between protecting children and young people from abuse and safeguarding staff, volunteers, and host families from false or unfounded allegations. These procedures align with the guidance provided in the Department for Education's Keeping Children Safe in Education, 2026.

Any concern or allegation involving a member of InterGreat Education Group's staff or host families must be promptly reported to the Designated Safeguarding Lead. In the absence of the Designated Safeguarding Lead, the matter can be referred to the Local Authority Designated Officer, whose contact details are available through the Local Safeguarding Children Partnership.

Automatic suspension of staff or removal of a child or young person from a homestay will not be the immediate response to an allegation. Comprehensive consideration will be given to all options, taking into account the need to ensure:

All staff and host families associated with InterGreat Education Group should avoid placing themselves in vulnerable positions with children or young people and should respect the child/young person's right to privacy.

Staff and host families are expected to be familiar with and adhere to InterGreat Education Group's policies on Staff Conduct. Guidance on conduct and safe practices, including the appropriate use of ICT and mobile phones by staff, will be provided during the induction for all new staff.

Low-Level Concerns Policy

InterGreat Education Group is committed to sustaining a strong safeguarding culture, allowing for the identification and discussion of any concerns within the organisation.

Staff at InterGreat are recruited in accordance with Safer Recruitment guidelines, and receive training in safeguarding as well as in our professional code of conduct. All staff at InterGreat are informed of the expectations regarding appropriate behaviour towards children and the necessity to report any concerning behaviour to senior members of staff, or, if necessary, directly to the Local Authority if the concerns involve senior members of staff.

This policy aims to define what is considered a “low-level concern”, and outlines the procedures for addressing and reporting these issues. Additionally, this policy encourages all staff to report any concerns, no matter how minor, to foster a robust safeguarding culture.

This policy is informed by Farrer & Co’s Low Level Concern Guidance 2020.

What is a Low-Level Concern:

According to the guidance provided by Farrer & Co, a low-level concern incorporates any issue, regardless of its perceived insignificance or even if it's merely a “nagging doubt,” where an adult may have behaved in a manner that:

is inconsistent with the organisation’s code of conduct, and/or

relates to their behaviour outside of work which, although not linked to a specific action or omission, raises doubts about the adult’s suitability to work with children.

Low-level concerns are distinct from allegations against adults who work with children. An allegation involves behaviour that has harmed, or might harm, a child, potential crimes committed against or related to a child, or behaviour towards a child or children indicating they may pose a risk of harm. However, it is not the responsibility of the person making the report to determine if it is a low-level concern or an allegation; this will be assessed by the Designated Safeguarding Lead (DSL).

Reporting Process:

Concerns must be reported immediately to the DSL, Terence Murray, or, in his absence, to the DDSL, Alex Lindon-Morris. Reports may be made verbally or in writing. Any concern or allegation about either Terence Murray or Alex Lindon-Morris should be referred to the appropriate Local Authority Designated Officer (LADO) or another statutory agency.

Confidentiality of anonymous reports will be respected as far as possible, though absolute anonymity cannot be assured.

Procedure for Handling a Report of a Low-Level Concern:

The DSL (or Deputy DSL) receives the report verbally or in writing.

If the report is verbal, the DSL documents the report as it is made or immediately thereafter.

This documentation is securely stored in our system with only limited access to the DSL or DDSL.

If the report is not anonymous, the DSL consults with the reporter to assess whether the concern violates the Code of Conduct and determines whether it should be treated as a low-level concern or escalated to the LADO as an allegation.

If there is uncertainty, the DSL consults the LADO.

Once determined as a low-level concern, the DSL speaks with the individual involved, making a record of all conversations, decisions taken, actions carried out, and the rationale.

Even if not considered a low-level concern, the DSL still informs the implicated individual about the report to allow for their response. The decision and actions are explained to the person who reported the concern.

If confirmed as a low-level concern, resolution might involve a discussion, closer management, additional training, or a combination of these approaches.

The DSL approaches the individual involved in a calm and sensitive manner, avoiding critical or threatening language.

If misconduct or poor performance is also identified, the DSL consults HR and decides on the best course of action. Involvement of other external agencies might be necessary.

If a pattern of low-level concerns as a whole constitutes an allegation, a referral to the LADO is required. If in doubt, the DSL consults the LADO.

All notes related to low-level concerns are kept securely in our internal system during the duration of employment and reassessed upon the employee's departure to determine if retention is still necessary.

False, unsubstantiated, or malicious concerns or allegations should not be reflected in references for future employment, ensuring InterGreat maintains the provision of accurate information.

Allegations about the Designated Safeguarding Lead (Whistleblowing)

Report concerns about the conduct of the DSL directly to the appropriate Local Authority Designated Officer (LADO). Use the local authority route appropriate to the concern; IEG maintains the relevant contacts in its safeguarding records. If a child is in immediate danger, call 999.

Children & Families Team

We hold contact details of each Local Safeguarding Children Partnership, for reporting purposes. The local partnership for each area is detailed in Student, Parent and Host Family Handbooks and the details for the LSCP and Local Authority Designated Officer (LADO) are kept on InterGreat Education Group systems.

Allegations made to Police or Children's Social Care

Allegations made to the police or Children’s Social Care regarding InterGreat Education Group’s staff or host family may impact the individual's ability to fulfil their role, either because they are the subject of the allegation or because they may be party to safeguarding measures resulting from the allegation.

When allegations are made to the police, discussions will be facilitated by the police’s designated liaison officer with the Local Authority Designated Officer (LADO). The same process applies if an allegation is reported directly to Children’s Social Care. The LADO will then pursue the allegation with the school and also with InterGreat Education Group’s DSL (where relevant) to obtain further details of the incident(s) and circumstances. This collaboration should determine whether or not the allegation is substantiated.

If the allegation is upheld and there is cause for concern that a young person is suffering, at risk of, or likely to suffer significant harm, the LADO should refer immediately to Children's Social Care and initiate a strategy discussion. The LADO, InterGreat Education Group’s Designated Safeguarding Lead, and Directors should be involved in any ensuing activity and outcomes.

If a criminal offence has occurred, the LADO should immediately involve the police and decide whether or not an investigation is needed. InterGreat Education Group’s Designated Safeguarding Lead should be involved in any such discussion.

InterGreat Education Group’s DSL will make a referral to the Disclosure and Barring Service if a person in regulated activity has been dismissed or removed due to safeguarding concerns or would have been if they had not resigned.

If a member of staff, volunteer, or Homestay tenders their resignation or ceases to provide their services, any child protection allegations will still be followed up by InterGreat Education Group. Resignation will not prevent a prompt and detailed report being made to the Disclosure and Barring Service or another relevant body, as determined by future legislation in appropriate circumstances.

In cases where the allegation does not involve a criminal investigation, InterGreat Education Group’s Directors should review the Safeguarding and Child Protection training for all staff, volunteers, and host families.

Allegations made to School Staff

If a child or young person, or their parent(s), discloses information about their host family, staff, or another person they have encountered outside of school to a member of school staff, the School Designated Safeguarding Lead (DSL) should contact the InterGreat Education Group’s DSL to discuss these concerns, unless there is an allegation involving a criminal offence.

Upon receiving such contact from a school, InterGreat Education Group’s DSL should investigate the allegation urgently and inform the child or young person’s parents where appropriate.

At this time, the Local Authority Designated Officer (LADO) may be referred to, with contact initiated by the school or InterGreat Education Group as deemed appropriate. InterGreat Education Group’s DSL would collaborate with the LADO for support, advice, and to report further if required, meeting the relevant threshold.

During the investigation period, the member of InterGreat Education Group staff or host family concerned will be relieved of their guardianship or host family responsibilities, and alternative arrangements will be made for the child or young person involved.

Allegations against Children or Young People under the care of InterGreat Education Group

If a child or young person under the responsibility of InterGreat Education Group is accused of abusing another child or young person within our care, we will take all necessary steps to ensure the safety and well-being of both individuals, including the one accused of abuse. This may involve offering alternative accommodation for one or both parties.

In cases where a child or young person needs to be interviewed by the police regarding abuse allegations, InterGreat Education Group will ensure, in consultation with the relevant school or college, that parents or guardians are informed promptly. Additionally, the child or young person will be supported during the interview by an appropriate adult.

If the school or college decides to suspend the child or young person during the investigation, InterGreat Education Group will provide suitable support, assistance, and accommodation.

These procedures will be applied accordingly if a child or young person under our responsibility is accused of abuse against any individual for whom we do not have responsibility.

Appendix 1: confidential Cause for Concern record

Use IEG’s secure safeguarding reporting process. Record the student’s name, the incident location, what was observed, heard or disclosed and when, using the child’s own words for a direct disclosure. Distinguish direct observations, discussions with others and disclosures.

Record whether the child and parents are aware of the concern, any information-sharing discussion, who has been notified, previous concerns, relevant correspondence or evidence, and the reporter’s name. Share only with those who need to know. Do not promise secrecy, investigate the allegation yourself or delay an urgent referral while completing a form.

Confidential Cause for Concern Form

Use this form to document any worries regarding a child or young person's well-being. Please refrain from interpreting or investigating the situation; focus on recording the facts. Once completed, promptly hand this form to the Designated Safeguarding Lead. If they are unavailable, pass it to another Senior Staff member for attention.

When interacting with the child or young person, employ 'open' questions, avoiding leading questions, and allow them to express themselves in their own words. Listen attentively and maintain an open mind throughout the conversation.

Lastly, never commit to keeping information confidential or promise secrecy to the child or young person. Explain that the details may need to be shared with the Designated Safeguarding Lead, who will take any necessary action, while reassuring them of your ongoing support.

Local authority and safeguarding contacts

Use the safeguarding partnership, Children’s Social Care service and Local Authority Designated Officer (LADO) appropriate to the child’s location and the concern. Do not assume that the authority covering IEG’s London office is the correct authority for every student.

IEG maintains the relevant local contacts in its restricted student and safeguarding records. Schools and homestays should also follow their own local safeguarding arrangements.

To find the appropriate council reporting route, use GOV.UK: report child abuse to a local council. Call 999 if a child is in immediate danger.

Communication and emergency contact arrangements

Our UK office and correspondence address is 25 Southampton Buildings, London WC2A 1AL.

Use guardian@intergreat.com for routine matters. The office telephone, +44 (0)20 3856 8180, is an office-hours contact.

For safeguarding concerns, contact the DSL at dsl@intergreat.com, or the DDSL, Alex Lindon-Morris, at alex.lm@intergreat.com.

IEG provides the current 24-hour emergency number directly to students, parents, staff, homestays and partner schools. Use that number for urgent support outside office hours. Do not rely on email for an urgent response. If someone is in immediate danger, call 999.

Additional support

The DSL can help students and families find appropriate current support. See NHS mental health information and NSPCC safeguarding information. In an emergency, call 999.

Current statutory and accreditation framework

This policy must be implemented in accordance with Keeping Children Safe in Education 2026, Working Together to Safeguard Children 2026 and the relevant local multi-agency safeguarding arrangements. IEG is seeking renewal of its AEGIS Preliminary accreditation and will continue to comply with the AEGIS Code of Practice and all applicable AEGIS Quality Standards. Any reference elsewhere in this document to an earlier edition of statutory guidance is superseded by the current edition.

AEGIS safeguarding requirements update

IEG maintains a child-centred approach to every safeguarding decision. The child’s best interests are paramount, and their wishes and feelings will be heard and taken into account in an age-appropriate way. Staff and homestays must remain professionally curious: a child may not feel ready or know how to disclose abuse, exploitation or neglect, and may not recognise an experience as harmful. This must never prevent concerns being discussed promptly with the DSL.

For urgent safeguarding concerns at any time, use the private 24-hour emergency number supplied to families and schools. If the DSL is unavailable, the DDSL, Alex Lindon-Morris, provides cover. Report concerns about the DSL to the appropriate LADO or statutory agency. Office telephone and email are not 24-hour emergency channels.

IEG takes a coordinated, multi-agency approach and will liaise with schools, Local Safeguarding Partners, the LADO, Children’s Social Care, police and other agencies whenever required. Information will be shared lawfully, proportionately and on a need-to-know basis; safeguarding information received by staff, volunteers or homestays must remain confidential and safeguarding records must be securely restricted to authorised personnel.

IEG has zero tolerance for racism and discrimination. Safeguarding practice will be inclusive and will respond sensitively to protected characteristics and individual needs. Any matter involving a child who is questioning their gender will be handled in accordance with current statutory guidance, on a case-by-case and child-centred basis, with appropriate safeguarding oversight and without stereotyping or discrimination.

The DSL will ensure that staff, volunteers and primary homestay carers complete appropriate safeguarding training before starting their role, renewed at least every three years, together with annual safeguarding updates. Where two adults share primary caring responsibilities in a homestay, both must complete the required training. DSL training must be renewed at least every two years; a person undertaking their first DSL course must first complete suitable basic online safeguarding training.