Introduction

This purpose of this policy is to set out the principles, criteria and processes that govern how Compassiviste Foundation makes grants. A grant is defined as a financial award the Trust makes from its funds to support charitable activities, usually to registered charities or charitable community groups, which include partner organisations. The Board of Trustees may vary the terms of this policy from time to time. This policy should read in conjunction with all other policies and procedures of Compassiviste Foundation, and in particular, the Grant-Making Policy.

1. Ensuring proper governance

The Board of Trustees ensures proper governance of the Trust’s grant-making in three ways:

• Through assessment of a checklist to ensure that Compassiviste Foundation funds are channelled to and utilised by those most in need;
• Through careful review by the Board of Trustees; and
• Through written and unanimous ratification by the Board of Trustees.

1.1. The checklist

Compassiviste Foundation relies on specific criteria to determine which individuals it benefits and what work it does and/or supports. Those criteria are:

1. Are those individuals we are seeking to help unable to adequately help themselves?

2. Is there a genuine need, compelling emergency or urgent humanitarian reason to lend our support?

3. Would our support have significant benefit that may otherwise not be received?

4. Are those individuals we are trying to help objectively vulnerable and at risk of ongoing or additional harm or inequality without our support?

5. On a basic level, Compassiviste Foundation must do no harm. As such, is there any risk that our involvement and/or financial support could endanger or worsen the circumstances of those vulnerable individuals, their communities, or our frontline partners?

6. Has each frontline partner provided us with sufficient information to know how Compassiviste Foundation funds and/or equipment will be used, protected, and funnelled safely to the intended recipient(s)?

7. Have we as an organisation conducted our own prior due diligence to ensure that any frontline partners with which we choose to work are legitimate charitable organisations?

8. In terms of purchasing equipment directly, where such donations might be requested, have we thoroughly explored the market and established that the price we have been quoted cannot be beaten – and that the brand/manufacturer of such equipment is legitimate?

9. Are there any legal or financial reasons why we should not help – for example, because of international sanctions or because sending money (for instance) may place Compassiviste Foundation in breach of domestic or international legislation?

10. In the case of providing education to displaced school leavers (as per Point 2 in our charitable purpose) has the necessary due diligence been conducted to prove that applicants are indeed aged 18 or over, are eligible for the course in question, and hold refugee status or were otherwise legitimately displaced through climate change?

Compassiviste Foundation support will only be considered in situations where this 10-point checklist has been satisfactorily completed in the affirmative.

The principles which underpin the trustees’ governance of the Trust’s grant-making take into account the scale and range of its grants and strike a balance between proper oversight of decision-making and responsive customer service for both applicants and donors.

1.2. Scrutiny and research

The board of trustees has ultimate collective responsibility for all grant-making decisions in line with the Trust’s charitable purposes and any restrictions agreed with donors and funding partners.

Trustees may assign certain research-based responsibilities to its sub-committees, staff or volunteers. Such delegated tasks must be overseen by at least one trustee.

1.3 Decision-making

Trustees reserve the right not to approve any recommendation or nomination if they determine that the resulting grant would not be charitable, or would conflict with the Trust’s stated policies or damage its reputation.

All trustees must agree on any grant-making decision and their respective decision is final.

2. Who is eligible for a Compassiviste Foundation grant?

In accordance with its Charitable Objectives, the Trust aims to support refugees and those who have been displaced through climate change. Whilst grants are, in principle, available to any registered charity or charitable organisation that provides direct relief to those individuals, Compassiviste Foundation will prioritise those organisations which:

• Are active and working in-person in the region affected;
• Are supporting individuals who are experiencing a current or imminent emergency and could otherwise lose their lives, liberty or livelihoods;
• Do not need to rely on a Trust grant to carry out their work but can put Trust funds to good, practical use;
• Can provide regular updates/situation reports.

3. Measurable objectives

To ensure the Trust’s resources are used solely to further its charitable objectives, and in order that the Trust can report on the impact of its grants, trustees will normally expect that all grants are made with the following conditions:

• Written confirmation from each recipient confirming what percentage of each donation it receives from the Trust will, on average, be used for or otherwise allocated to frontline humanitarian work, and how the balance is likely to be spent;
• A current list of the Trust’s partners’ existing projects and for ad hoc updates regarding emerging humanitarian threats and developments, and confirmation that Compassiviste Foundation can select which of these projects our funding should be used for;
• Written assurance from each partner that its funding will be used for the purposes or project Compassiviste Foundation intended and, wherever reasonably possible, for an update from those organisations about how its funds (whether solely or otherwise) were subsequently used on the ground;
• An assurance that Compassiviste Foundation can promote the grant on its website and social media platforms, and that the recipient will do the same.

4. Grant sizes and frequency

The minimum grant size is £250. There is no upper grant limit. Compassiviste Foundation can, with the unanimous consent of its Board of Trustees, make single ad hoc grants or ongoing grants, subject to:

• The Trust possessing the necessary funds to make any type of grant; and
• The Trust not being contractually obligated to make a grant of any kind or being under any other kind of duty to do so.

5. Grant transfer process

The process of transferring grants from Compassiviste Foundation to a recipient is as follows:

• For the financial security of the Trust, the recipient organisation shall provide Compassiviste Foundation with a notarised letter on which its bank account details are specified. The contact details of the notary must also be included and the Board of Trustees should take reasonable steps to authenticate the notary through research and through direct contact;
• The recipient must provide adequate documentation demonstrating his or her identify, and in the case of an organisation, the ultimate beneficial owners of it, to comply with local laws and regulations;
• Grants are made by bank transfer only. The recipient’s name and bank details must match and the Trust should not proceed with a transfer if they do not.
• The recipient must acknowledge receipt of the grant within 24 hours of receipt.

2. Staff Recruitment and Screening

2.1 Recruitment of Expatriate and Local Personnel, and Short-Term Volunteers

As a condition of working with Compassiviste Foundation, all officers, staff, interns, volunteers, researchers, consultants and advisers of Compassiviste Foundation are required to:

1. Sign acceptance of Compassiviste Foundation Child & Adult Safeguarding policy.
2. Satisfactorily clear a police check conducted by the home country’s Criminal Record Bureau or equivalent where such a facility exists in the sending country, or where it does not exist, a selfdeclaration of no criminal charges in relation to children or adult abuse.
3. Those working with children must also provide the name and contact information of two character references they have known for no less than two years, excluding family members. These references will be asked questions about any record of inappropriate behaviour in relation to children.

2.2 Monitoring and Action in Case of Concern

Project Managers and Team Leaders will be responsible for monitoring activities relating to children and reporting and assessing reported concerns or allegations to the relevant manager or to the Child Protection Officer, if one exists

3. Staff Training and Development

3.1 All personnel will be required to serve a three-month probationary period during which performance will be closely monitored.

3.2 All personnel will receive regular supervision through observation and discussion of their work.

3.3 Safeguarding training will be provided to all personnel to ensure they have the skills to recognise, report, and respond to abuse.

4. Child and Adult Safeguarding Code of Conduct

4.1 Compassiviste Foundation expects all personnel, visitors, partner organisations and all other affiliates to treat all children associated with Compassiviste Foundation with respect and dignity.

4.2 General Conduct

4.2.1 The ‘two-adult’ rule (i.e. no adult should be alone with one or more children at any time) should always be followed whether in the child’s home, on office premises, project premises or elsewhere. If there is an adult family member present in the same room during the service being provided, the twoadult rule will be determined to have been met.

4.2.2 Sexual exploitation and abuse by project workers constitute acts of gross misconduct and are therefore grounds for immediate termination of employment or volunteer service. Compassiviste Foundation staff and all associates must not fondle, hold, kiss, hug or touch a child in an inappropriate and culturally insensitive way. A child should not be ridiculed, belittled, prejudiced nor rejected.

4.2.3 Sexual activity with children is prohibited regardless of the age of the child and age of consent locally. A mistaken belief about a child’s age is not a defence. Adults are solely responsible for their behaviour and cannot blame a child who may be acting in provocative or seductive ways. Adults should avoid vulnerable or compromising situations.

4.2.4 Exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour are prohibited.

4.2.5 Sexual and romantic relationships between personnel and beneficiaries are prohibited. They are prohibited because these relationships are based on inherently unequal power dynamics. Such relationships would undermine the integrity of our work.

4.3 Personnel Guidelines on Touch

• Do not touch a child on areas that would normally be covered by clothing.
• If touching a child, do so in the presence of others. A hug in front of a group is very different to one behind closed doors.
• Touch is in response to the child’s needs, not the needs of personnel. It is advised to ask permission before touching.

4.4 Home Visits

4.4.1 Two-person rule. When visiting children at home, it is strongly encouraged to do so in pairs. When home visits are conducted, there should be a parent, grandparent or other family guardian present. If an adult family member is present, the two-person rule can be considered to have been met.

4.4.2 The project office should be kept informed of the visit. A report mechanism must be created and employed by the Country Office for recording such visits. These records must be maintained and available for inspection.

4.5 Counselling
Compassiviste Foundation does not provide formal counselling. However, there are times in which informal mentoring takes place. Children in their teens, as an example, may have questions regarding dating and male/female relationships. The leader should always be of the same gender as the group being addressed.

4.6 Discipline

4.6.1 Compassiviste Foundation staff are not permitted to physically discipline children or adults who participate in our programs. Doing so is grounds for termination. Staff will not engage in any of the following actions:

1. Deprivation of basic needs (e.g. food, water, clothing, medical treatment). There may be times when withholding food is a response to their refusing to eat, but this must not extend beyond one meal.
2. Restraining methods (e.g. tying a child, taping a child’s mouth, long periods of solitary confinement).
3. Rejecting or blatantly ignoring a child (this is different from using ignoring as an appropriate method of discipline).
4. Threats, put-downs and other verbal or non-verbal gestures that damage the esteem of a child.
5. Punishment that is not proportionate to the child’s physical or mental capacity (e.g. requiring a small child to lift a heavy weight).

4.6.2 The preferred methods of discipline are instructions, encouragement and administering natural or logical consequences, which will more effectively promote self-discipline and independence:

1. Instructions focus on providing children with clear rules, explanations and appropriate behavioural
   alternatives to undesirable ones.
2. Encouragement focuses on the child’s effort and attempt at desirable behaviour and is not just limited to the successful attainment of the behaviour (e.g. encouraging a child who is trying hard and not just praising a child when s/he gets good academic results).
3. Natural consequences are natural outcomes that a child experiences after s/he misbehaves (e.g. if a child wilfully refuses to eat, the consequence is that s/he will go hungry).
4. Logical consequences are outcomes that an adult administers that are logically related to the misbehaviour (e.g. if a child messes up a table, s/he is required to clean up the mess). This is opposed to illogical consequences, which are unreasonable (e.g. depriving a child of food when s/he messes up a table).

4.6.3 If discipline measures are failing to correct repeated misbehaviour in a child, that child should be evaluated for referral to professional counselling, if available.

4.6.4 Staff and volunteers should avoid demonstrating favouritism toward any child. This can inadvertently set up dynamics of rivalry, competitiveness, jealousy and conflict.

4.7 Day Trips and Outings

1. On outings, there must be sufficient supervision for the number and age of the children. As a rule of thumb, the ratio of 1 adult to 8 children should apply.
2. When Compassiviste Foundation is coordinating transportation either by own vehicle or rented arrangement, Compassiviste Foundation will make all efforts to ensure safety measures (i.e. not overloading, using seatbelts when available, consider weather and road conditions).
3. At least two adults (preferably a man and a woman) must be in the transport vehicle. One of the adults must be a staff member.
4. A list of children going on an outing must be properly recorded and the same children must return from that outing, unless there are valid reasons otherwise.
5. For all outings organised by Compassiviste Foundation, a parent or guardian’s consent must be obtained.

4.8 Privacy

Compassiviste Foundation respects children’s personal data and all staff and volunteers must safeguard any personal data collected with regards to children with due skill and care, and in any case, comply with our Privacy Policy.

4.9 Consistency

Compassiviste Foundation has a Constitution and Code of Conduct in place. Staff and volunteers must observe, understand and comply with expectations laid down by both the Constitution and Code of Conduct and the Child and Adult Safeguarding Policy Code of Conduct.

5. Responding to Allegations & Incident Management

5.1.1 Compassiviste Foundation recognises that abuse can take place within the organisation or outside its premises. All staff members, volunteers and other associates are encouraged to discuss issues of abuse openly.

5.1.2 A child protection issue may come to the attention of personnel in several ways:

1. A child may make a direct allegation.
2. A child may make a comment, which seems to suggest abuse. A child may display physical, emotional, or behavioural signs of abuse.
3. A personnel member may display suspicious behaviour that warrants an investigation for abuse.

5.1.3 Team Leaders are responsible for all child protection issues. All allegations of abuse or other complaints brought to the attention of Compassiviste Foundation must be reported to Team Leaders. Any allegation that surfaces at the Country Office level must include the International Director of Compassiviste Foundation at the outset.

5.1.4 Team Leaders must be kept informed of the allegations. Any personnel member who keeps silent of knowledge of alleged abuse may also be subjected to disciplinary action. The reporting person will not be penalised even if the allegation is finally proven untrue, except if there is clear evidence of premeditated defamation of character or malicious intent.

5.1.5 Information related to the allegation and investigations will be kept confidential, and only restricted to those who need to know.

5.1.6 Throughout this process of allegation and investigation, the victim and the accused will be treated with respect, fairness and without prejudice.

5.1.7 During the course of investigation, where necessary, Compassiviste Foundation will provide counselling for the victim. Consistent with the code of confidentiality, the appointed counsellor will not be obliged to provide information for the purpose of investigation unless the withholding of information has a high chance of endangering life.

5.1.8 Relevant local authorities, organisations and child rights agencies will be alerted. Where appropriate and safe, parents or guardians of the victim will also be notified.

5.1.9 When a child discloses abuse, it will not be dismissed under any circumstance. Compassiviste Foundation will appoint a staff member who has been appropriately trained or supervised to talk to the victim.

5.2 Responding to Disclosure

5.2.1 Some children may tell a worker what has been happening to them. In such situations, it is important that the worker listens carefully to what the child is saying. The worker should never promise to keep the information confidential. It is also important that the worker does not start interrogating the child. If a child wishes to speak freely, allow him/her to continue. Ask questions for clarification only. Do not ask leading questions. It is important to remember that it is not the worker’s job to investigate. Their responsibility is only to establish whether or not there is a child protection concern.

5.2.2 Staff should prevent repeated interviewing of children who make disclosure. Such practices in themselves can be abusive and will often leave the child feeling unheard and not believed.

5.2.3 If a child makes an allegation about a specific adult, be they care-giver, worker, or volunteer, the receiving staff member must not under any circumstance question the alleged perpetrator in question.

5.3 When an allegation of abuse is made against Compassiviste Foundation personnel, the following guidelines are essential:

5.3.1 The accused person will be temporarily suspended from all duties until the investigation is concluded. The person will be reinstated only if they are cleared of the allegations and there is no doubt that the person is able to adhere to Compassiviste Foundation’s Child Protection Policy. Investigation will proceed in close consultation with Compassiviste Foundation’s International Directors, the management and any other appropriate external counsel.

5.3.2 If the accused person is a Team Leader, any personnel may inform Compassiviste Foundation’s Directors directly. In this case, Compassiviste Foundation Directors will appoint an appropriate person to handle the investigation.

5.4 When an incident of suspected abuse is identified in the community or through Compassiviste Foundation programs, the personnel needs to report it to their Team Leaders or supervisors to discuss actions to be taken for follow up.

5.5 When abuse happens between children:

5.5.1 All staff and volunteers should take responsibility for preventing the abuse of younger or weaker children by older/stronger ones. Abuse can take place through bullying, humiliation, cruelty, initiation rituals, and others. Staff must never encourage these kinds of behaviours and must at all times model appropriate behaviours and interactions with each other and with the children in their care.

5.5.2 There may be occasions when a child discloses abuse by another child, or a staff member/volunteer suspects it might be happening. All concerns should be reported to Team Leaders/supervisors.

6. Record Keeping and Documentation

6.1 Clear accurate recording is crucial; recording should be done within 24 hours of disclosure. The staff member should write down what the child said, or what they observed as accurately as possible. The record must include the context of the disclosure or the circumstances of the observation. The record should include names, dates, times, and physical and behavioural observations. The record should also reflect if there were any witnesses, or if anyone else heard what the child said.

6.2 In principle, all records are confidential. However, where there are child protection concerns, relevant counselling records will be released to facilitate any investigation, but only with informed consent from the counsellee(s) and their parents/guardians. In instances where the withholding of certain information could result in a high chance of endangerment to life, informed consent will then be unnecessary.

7. Hosting Visitors

7.1 All visitors will be supervised by a Compassiviste Foundation staff member.

7.2 All expatriates and short-term visits will receive a cultural orientation briefing, which explains cultural and behavioural norms.

7.3 If alleged abuse or misconduct by a visitor is reported, the incidence management plan in section 5 above will apply.

8. Advocacy

8.1 Compassiviste Foundation is committed to promoting children’s rights to safety and will work with various individuals, groups and organisations who are concerned about child protection.

8.2 Compassiviste Foundation is also committed to providing child abuse prevention awarenessbuilding activities in different sectors of the local and international community.

8.3 Compassiviste Foundation will aim to remain current on child protection issues and practices in order to maintain best practices in child protection policy. Where possible, Compassiviste Foundation will support or organise training in this area to raise standards of child protection practices.

9. Communications

9.1 In all of Compassiviste Foundation’s communication material, visual aids will only use pictures of children in decent and respectful ways. Photographs or languages that are sexually suggestive are prohibited.

9.2 Special care will be taken to protect the identities of children pictured in communication material, in order to prevent possible harm, abuse or other endangerments.

9.3 The Country Director (or their designate) is the official spokesperson when communicating with the media and/or the local authority. The Country Director must officially appoint any other spokesperson. In relating to the media, the message that child abuse is wrong under all circumstances, and that keeping silent is wrong must be clearly communicated.

9.4 It may sometimes be necessary to communicate information about a child to assist the process of police investigation and prosecution. Information will be disclosed on a need-to-know basis and only after thorough consultation with the Team Leaders.

9.5 Children’s personal and private information that could be used to identify the location of a child should not be used on Compassiviste Foundation’s website or in any other form of communication.

10. Fraternisation between Compassiviste Foundation staff

1. Fraternisation is when positions of power are abused to engage in flirting, dating, romantic involvement, and sexual relations. Any relationship between Compassiviste Foundation staff that interferes with the harmonious work environment or the productivity of employees will be addressed by applying the progressive discipline policy up to and including employment termination.
2. Behaviours that negatively affect the workplace that arise because of romantic relationships will not be tolerated. Those in managerial or supervisory positions should understand that romantic relationships with staff who report to them may be perceived as favouritism, misuse of authority, or potentially, sexual harassment and therefore are prohibited.
3. Any fraternisation with staff whose terms or conditions of employment such as pay raises, promotions, and advancement are potentially affected by the manager, is prohibited. This includes dating, romantic involvement, and sexual relations.
4. A manager or supervisor who dates or becomes romantically involved with an employee creates a serious problem for Compassiviste Foundation. Dating an employee, and extramarital affairs, even when the employee is not in a reporting relationship, may have serious consequences for the organisation. If a manager decides to pursue a close relationship with an employee, he or she needs to inform their manager and Human Resources immediately. The company will then decide what, if any, actions are necessary in regard to assignments and jobs. Employees who disregard this policy will receive disciplinary actions up to and including employment termination.
5. Employees may have different definitions and understandings of what constitutes fraternisation. Consequently, if you have questions or need further clarification, talk with the Country Director or Human Resources. Their goal of implementing policies consistently and fairly will help inform your choices.

11. Implementation and Maintenance of the Policy

1. Country Directors or their designate carry the primary responsibility for implementation.
2. Country Directors (or their designate) are the primary persons to whom staff should report possible or known child or adult endangerment. The Country Director must assign a secondary person to whom people can report if the primary person is the object of concern.
3.  Country Directors (or their designate) must maintain active files for the following:
   a. Copies of staff and volunteer Signed Acknowledgement pages of the Policy
   b. A list of all participants in safeguarding training
4. The International Office will be responsible for:
   a. Setting up a records system to monitor the various Country Offices for compliance, monitoring and timely reporting of any incidents.
   b. Continuing to review the Policy to assure that the safeguarding of children and adults is part of our organisational culture.
   c. The Human Resources Officer will be the primary recipient of child and adult safeguarding issues that surface in the Compassiviste Foundation structure, and as long as it does not involve the International Director, that person will also be involved with the Human Resources Officer to review and investigate the complaint or concern.

12. Other

1. This policy is endorsed by Compassiviste Foundation management and Board of Directors.
2. Compassiviste Foundation is committed to ensuring its Child and Adult Safeguarding policies are relevant and reviewed regularly, and that its policies reflect current best practices.
3. Feedback and consultations will be regularly solicited from children, parents, child rights organisations and other relevant bodies to ensure the relevance of this policy.
4. This policy will be formally reviewed every 3 years or after every critical incident.