Safeguarding & Whistleblowing Policy

This policy applies to all individuals working within or on behalf of Sapling & Stone Care, including permanent staff, agency workers, volunteers and visiting professionals, as well as those with leadership, management and oversight responsibilities - including the Responsible Individual, Registered Manager, senior leaders and those involved in governance and quality assurance.

It must be read in conjunction with:

• Statement of Purpose
• Code of Conduct
• Behaviour Support Policy
• Allegations Against Staff Protocol
• Safer Recruitment and Induction Procedure
• Complaints & Representations Policy

This policy is informed by and complies with the following:

• Children Act 1989 & 2004
• The Children's Homes (England) Regulations 2015 and Quality Standards
• Working Together to Safeguard Children (DfE, 2026)
• Keeping Children Safe in Education (DfE, 2025)
• The Prevent Duty Guidance (HM Government, 2023)
• Public Interest Disclosure Act 1998
• Human Rights Act 1998
• Data Protection Act 2018 & UK GDPR
• Northamptonshire Safeguarding Children Partnership procedures (NSCP)
• Ofsted: Children's Homes – Guide to Registration (2025)

We refer to and seek guidance from the Threshold Framework held by Northamptonshire Children's Trust - the multi-agency tool used to consider how best to meet the needs of individual children and young people.

Prevent. As a specified authority under Section 26 of the Counter-terrorism and Security Act 2015, we have a duty to identify vulnerable young people and prevent them from being drawn into terrorism. All staff complete the Government's Prevent Duty Training together with a Level 2 module on Radicalisation and Extremism.

Confidentiality & information sharing. All employees, volunteers and visitors are expected to maintain confidentiality. Information is shared only in line with UK GDPR and the Data Protection Act 2018 - except where a child is deemed to be at risk of significant harm (information will be shared with the local authority) or in immediate danger or a crime has been committed (the police will be contacted).

Safer recruitment. Recruitment processes are thorough, values-based and intentionally paced. Vetting, robust referencing and reflective interviews explore how applicants understand trauma, relationships and behaviour alongside skills and experience, in line with Regulation 32 and Keeping Children Safe in Education.

We recognise abuse in many forms, including:

• Bullying and cyber-bullying
• Child sexual exploitation
• Child criminal exploitation
• Child trafficking
• Domestic abuse
• Emotional and psychological abuse
• Female genital mutilation
• Grooming
• Financial abuse
• Neglect
• Non-recent abuse
• Online abuse
• Physical abuse
• Sexual abuse

When a child shares something - current or historic - that may indicate harm, it must always be recognised as a significant and courageous step. Disclosures do not always happen in a clear or direct way; they may emerge gradually through conversation, behaviour, play, creative expression or seemingly casual comments.

Staff must never:

• Promise to keep secrets, or say they won't tell anyone
• Press for more details or information
• Ask leading questions (e.g. "Did he hit you?")
• Share information with anyone who doesn't need to know
• Assume someone else has already reported it

If you are unsure whether something is a disclosure - or even if you believe it is already known - report to a Designated Safeguarding Lead anyway. Always consult a DSL if you are not sure.

Designated Safeguarding Leads hold operational responsibility for safeguarding in each home. Their role includes assessing risk and deciding whether involvement from external agencies such as the local authority, LADO, police or other safeguarding partners is required; ensuring appropriate follow-up, reflection and emotional support for the young person and staff; and recording every action, decision and rationale on the electronic case-recording system to maintain a transparent audit trail.

If a child is at immediate risk of significant harm, staff must call 999 and inform the DSL as soon as it is safe to do so.

Any allegation against an adult working with children is taken seriously and managed in line with statutory guidance and our Allegations Against Staff Protocol. The Local Authority Designated Officer (LADO) is consulted where the threshold is met.

Where necessary, staff may be suspended on a neutral basis while enquiries are undertaken; this is not a presumption of guilt, but a protective measure to allow a thorough and unbiased investigation. Throughout the process, communication, support and confidentiality are maintained for all involved. Staff who are the subject of allegations are informed at the earliest opportunity, provided with written information on the process, and given access to a senior contact for ongoing support and liaison. Children involved are supported by a trusted adult and offered advocacy where appropriate.

• Safeguarding training is delivered annually, ideally face-to-face.
• Safeguarding is a non-negotiable agenda item in monthly team meetings and monthly 1:1 supervisions.
• DSLs receive advanced and refresher training biannually.
• Incidents are debriefed in trauma-informed discussions focused on learning and accountability.
• Monthly Learning Circles allow staff to share best practice and routinely cover safeguarding scenarios.
• Online monitoring is used in a proportionate, transparent and individualised way, with young people involved in conversations about their online safety wherever possible.

Staff sometimes struggle to recognise what should be raised, particularly where behaviour is 'grey', familiar or low-level. This policy aims to remove ambiguity: if in doubt, raise it.

Examples of reportable concerns include:

• A colleague repeatedly sharing inappropriate humour in front of children
• A staff member using pet names, private nicknames or favouritism
• Withholding key information from the team during handover
• A manager dismissing a child's distress as "manipulative" or "attention-seeking"
• A team that routinely ignores agreed routines or risk-management plans

Good whistleblowing is embedded within a culture of openness, trust and shared responsibility for safeguarding. Staff should feel confident to speak up at any time, knowing concerns will be listened to respectfully and taken seriously, regardless of how small they may seem. Protection from detriment is provided under the Public Interest Disclosure Act 1998.

If a member of staff is not satisfied with our internal response, or feels a concern is unresolved, they can contact the Ofsted Whistleblowing Hotline on 0300 123 3155.

• Ofsted: 0300 123 1231 - gov.uk/ofsted
• Ofsted Whistleblowing: 0300 123 3155
• LADO (Northamptonshire): LADOConsultations@NCTrust.co.uk
• NSPCC Helpline: 0808 800 5000
• Childline: 0800 1111
• Police (emergency): 999

This policy is owned by the Responsible Individual, approved by the Board, and reviewed at least every six months - or sooner in response to legislative change, inspection findings or learning from practice.