pg. 1 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 AFC WIMBLEDON FOUNDATION SAFEGUARDING CHILDREN POLICIES AND GUIDELINES Address: AFC Wimbledon Foundation, Cherry Red Records Stadium, Plough Lane, Wimbledon, London, SW17 ONR. Telephone: 020 8974 5712 Email: enquiries@afcwimbledonfoundation.org.uk Website: www.afcwimbledonfoundation.com pg. 2 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 TABLE OF CONTENTS Section 1 1.1 - Safeguarding Statement from the Board of Trustees 1.2 – Aims of the Safeguarding Policy 1.3 - Safeguarding Policy 1.4 – Review of the policy 1.5 – Safeguarding Contacts 1.6 – Multi Agency Working Section 2 2.1 - An Introduction to Safeguarding Children 2.2 - Raising Awareness 2.3 - Poor Practice 2.4 - Recognising Abuse 2.5 - Key Safeguarding Terminology and Definitions 2.6 - Definitions of Abuse 2.7 - Signs & Indicators 2.8 - Grooming 2.9 - Child Sexual Exploitation (CSE) 2.10 - Female Genital Mutilation (FGM) 2.11 - Anti Radicalisation and the “Prevent Programme” Section 3 3.1 - Inclusion Policy 3.2 - Anti-Bullying Policy 3.3 - Anti-Bullying Policy – Objectives 3.4 - Anti-Bullying Policy - Procedure 3.5 - AFC Wimbledon Recruitment Policy 3.6 - AFC Wimbledon Policy on DBS Portability 3.7 - AFC Wimbledon Policy on Risk Management 3.8 - AFC Wimbledon Policy on Position of Trust 3.9 - AFC Wimbledon Policy on Duty of Care 3.10 - AFC Wimbledon Policy on Gifts and Favouritism 3.11 - AFC Wimbledon Policy on The Employment of Young People 3.12 - AFC Wimbledon Working with External Partners and Organisations Section 4 4.1 - Safeguarding General Staff Code of Conduct - Introduction pg. 3 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 4.2 - Code of Conduct Section 5 5.1 - Disclosure 5.2. - Management of Allegations made by a Child 5.3. - Management of Allegations against a Child by a Child 5.4 - Management of Allegations against a Member of Staff 5.5 - Responding to a concern, incident or allegation 5.6 - Whistleblowing Policy 5.7 - Complaints Policy Section 6 6.1 - Guidelines 6.2. - Physical Contact 6.3 - Behaviour Management 6.4 - One to one situations 6.5 – Foundation Coaches 6.6 – Foundation Medical Department 6.7 – Venue Risk Assessments 6.8 – If a Young Person is not collected 6.9 – Lost Child Section 7 7.1 – Communication with Children & Young People involving technology 7.2 - Texting and Electronic Communication 7.3 – Social Networks 7.4 – Employees & Volunteers 7.5 - Information and Communication Technology (ICT) 7.6 – Information Sharing 7.7 - Best Practice in the Use of Images pg. 4 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 SECTION 8 - APPENDICIES APPENDIX A – SAFEGUARDING INCIDENT REPORT FORM APPENDIX B – COACHES CODE OF CONDUCT - GUIDELINES APPENDIX C - SPECTATOR CODE OF CONDUCT CONSENT FORM APPENDIX D - PLAYER CODE OF CONDUCT FORM pg. 5 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 SECTION 1 1.1 - Statement on Safeguarding Policy 2025 endorsed by the Foundation Board of Trustees AFC Wimbledon Foundation’s “Safeguarding Children Policy” is provided for use by AFC Wimbledon Foundation for the security and protection of all children and, young people who participate in any activities organised and led by the Foundation. This includes young people who participate as volunteers for the Foundation. This document also provides professional support and guidance for all staff. AFC Wimbledon Foundation’s Safeguarding Children Policy applies to all staff, paid or volunteers (whether full-time, part-time, temporary, or seasonal), sessional workers, agency staff, consultants, interns / students, self-employed contractors, or anyone working on behalf of AFC Wimbledon Foundation referred to in this Policy as “staff”, including Trustees. The overriding feature of this policy is that the safety and welfare of every child or young person that meets AFC Wimbledon Foundation through any of its activities is paramount. Safeguarding is everyone’s responsibility, and all staff, volunteers and trustees have a duty to always safeguard the welfare of children. 1.2 Aims of this policy • To safeguard all children and young people under the age of 18 — and up to 25 for those with Special Educational Needs and Disabilities (SEND) — who engage with the Foundation. • To provide a framework for guidance to staff both during the staff recruitment process and whilst carrying out their role for the charity. • To demonstrate best practice in safeguarding Children. • To provide guidance for parents / carers to understand reporting procedures. • To ensure that coaches and other adults who encounter children and young people provide good role models of behaviour. • To promote high ethical standards throughout the Foundation. 1.3 - Safeguarding Children Policy AFC Wimbledon Foundation recognises and accepts its responsibility for the safety and wellbeing of those children and young people who come within the care of the organisation and its staff. This includes young people who volunteer. It accepts that every child has the right to be protected from abuse and exploitation. AFC Wimbledon Foundation accepts its responsibility in the belief that the welfare and protection of children and young people is paramount. AFC Wimbledon Foundation will have in place arrangements that reflect the importance of safeguarding and promoting the welfare of children, including a clear line of accountability for the commissioning and/or provision of service designed to safeguard and promote the welfare of children. A full copy of this policy is available to the public upon request to the Foundation office or can be found on the Foundation’s website. The policy has been written with reference to the Football Association’s (FA) and English Football League (EFL)Trust’s safeguarding processes and safeguarding law and policy. The pg. 6 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 Department for Education (DfE) published and updated version of the statutory safeguarding and child protection guidance for schools in England, Keeping children safe in education (KCSIE) (DfE, 2025) 1 . This guidance will replace KCSIE 2024 when it comes into force on 1 September 2025. The guidance sets out what schools and colleges in England must do to safeguard and promote the welfare of children and young people under the age of 18. • the July 2018 DfE guidance document Working Together to Safeguard Children 2023 - Updated June 2025, the statutory guidance from the DfE ‘Keeping Children Safe in Education’ updates 2025 and • The Equality Act 2010 • Advice from NSPCC when-to-call-the-police--guidance-for-schools-and-colleges.pdf • Prevent duty guidance: England and Wales (2023) The AFC Wimbledon Foundation recognises that it is good practice to reach out to other organisations whose main purpose is safeguarding. Organisations such as the NSPCC | The UK children's charity | NSPCC, The Ann Craft Trust https://www.anncrafttrust.org/ or The NSPCC’s Child Protection in Sport Unit https://thecpsu.org.uk/. Our policy incorporates the safeguarding approach of the Foundation’s local borough partners in Merton, Kingston, and Wandsworth. The policy in its yearly review will implement changes at local and national level as required and will seek advice and guidance from the football authorities where appropriate. The Foundation is committed to supporting its knowledge and delivery of effective safeguarding practice by attending FA, Premier League and EFL Trust safeguarding workshops and training events across the year. 1.4 - Review of the policy The policy will be reviewed yearly by the Board of Trustees, or in the following circumstances: • Following a recommendation within a serious case review and / or from the Local Children’s Services Board or any other regulatory body. • Amendments to existing legislation, introduction of new legislation and /or government guidance. • Any amendment in policy procedures or regulations as advised by the Football Association of English Football League Trust. • As a result of any other significant change or event. Strategic Responsibility and Accountability The Board of Trustees, along with the Foundation CEO are responsible for the implementation of the safeguarding and child protection policy and understand that they will review the progress and successful delivery of safeguarding across the organisation in the following ways: • CEO and staff team to review safeguarding at every monthly review and termly staff INSET. • CEO and staff team to deliver safeguarding training and update casual coaching staff and volunteers in termly INSET meetings. pg. 7 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 • All staff receive information about the organisation’s safeguarding arrangements, the organisation’s safeguarding statement, Staff Behaviour Policy (Code of Conduct), Child Protection Policy, the role and names of the Designated Safeguarding Lead and their deputy(s), and Keeping children safe in education - GOV.UK • Regular observation of delivery sessions as a part of the Quality Assurance process includes a focus on Safeguarding. Observations to determine staff safeguarding training requirements. • Board of Trustees appoint a Trustee with lead responsibility for Safeguarding who reports back to Board at every scheduled meeting • Safeguarding a core agenda item at all Board meetings and within CEO’s report. The policy will be made available on the Foundation website and on request from the office and will be an integral part of staff induction and training along with our Coaches Code of Conduct. This policy was last reviewed by the Board of Trustees in November 2025. During the November 2025 review, the Board and CEO agreed that new a new policy should be written and that a working group of trustees and staff would be formed to create a new policy by September 2026. Signature: Chief Executive Officer Date: 8 th December 2025 Signature: Chair of Trustees Date: 8 th December 2025 1.5 – Safeguarding Contacts AFC Wimbledon Foundation, in line with The FA’s safeguarding policies and procedures, has appointed a Designated Safeguarding Lead (DSL) and three Designated Safeguarding Officers (DSOs) to manage initial reports of poor practice or suspected abuse. This structure reflects the safeguarding recommendations of the English Football League (EFL) and the Premier League, ensuring that our organisation meets recognised standards of best practice. The Designated Safeguarding Officers are responsible for receiving the first reports of any concerns relating to poor practice, welfare issues, or potential abuse. Upon receiving a concern, the DSO will liaise promptly with the Designated Safeguarding Lead. The DSL will then determine the appropriate course of action and make contact with the relevant external agencies as required, which may include the Local Authority Designated Officer (LADO), the police, or the County FA Welfare Officer. All concerns will be handled sensitively, promptly, and in accordance with statutory and football-specific safeguarding procedures. The Trustee Responsible for Safeguarding is Karen Peck, whose role is to oversee and review the implementation of the policy and procedures – she can be contacted at Karen.Peck@afcwimbledonfoundation.org.uk or office hours telephone 07710 224946. Designated Safeguarding Lead (DSL) is CEO Phil Hastings, if staff, partners or clients have a serious safeguarding concern he can be contacted at phil.hastings@afcwf.org.uk or by telephone 07506 623815. pg. 8 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 Designated Safeguarding Officer (DSO) for all Charity Programmes is Cheryl Gill who is the first point of contact for this area of work and, if staff, partners or clients have a serious safeguarding concern she can be contacted at cheryl.gill@afcwf.org.uk or by telephone 07593 444924 Designated Safeguarding Officer (DSO) for Education & Sport is Head of Education & Sport Andrew May who is the first point of contact for this area of work and, if staff, partners or clients have a serious safeguarding concern he can be contacted at andrew.may@afcwimbledonfoundation.org.uk or by telephone 07825 433532. Designated Safeguarding Officer (DSO) for Employment & Skills (mentoring) is Employment & Skills Manager Lana Miller who is the first point of contact for this area of work and, if staff, partners or clients have a serious safeguarding concern she can be contacted at lana.miller@afcwf.org.uk or by telephone 07513 726737 Karen Peck, Foundation Trustee will take lead responsibility for the Foundation’s safeguarding arrangements. Phil Hastings as Designated Safeguarding Lead will also have an overview of all aspects of Safeguarding at the Foundation and with support from Andrew May, Lana Miller and Cheryl Gill will implement staff training in this area and ensure staff are compliant with the Safeguarding policies and procedures. In addition, the Foundation Safeguarding Team will attend an AFC Wimbledon Football Club Senior Safeguarding Panel made up of Elouise Gillette (Club SSM), Kate Shelley (LDSO), and representatives from AFC Wimbledon Academy, AFC Wimbledon Women’s Team and Security Teams. This will meet at least quarterly and as required to discuss current issues, review policy and procedure where required. In general terms the Panel’s role is to ensure that there is an efficient consistent approach to safeguarding across the scope of the umbrella organisations that are the known as or connected to the brand name of AFC Wimbledon. pg. 9 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 1.6 – Multi Agency Working This section sets out the Foundation’s procedures and expectations for working collaboratively with the Multi-Agency Safeguarding Hub (MASH) and the police when safeguarding concerns arise. It aims to ensure that all staff, volunteers, and representatives understand their responsibilities, follow appropriate escalation pathways, and contribute effectively to multi-agency safeguarding responses. Our organisation recognises that safeguarding is a shared responsibility. We understand that timely communication and coordinated action with MASH and the police are essential in protecting children, young people, and vulnerable adults from harm. We will maintain positive working relationships with statutory partners and fully participate in multi-agency processes, including referrals, strategy discussions, investigations, and ongoing risk assessments. Identifying and Reporting Concerns All staff and volunteers must remain vigilant to signs of abuse, neglect, or exploitation. When a concern is identified: • The staff member must report it immediately to the Designated Safeguarding Lead (DSL) or a Designated Safeguarding Officer. • The DSL will determine whether the threshold for a MASH consultation or referral has been met. • If a child or adult is at immediate risk of harm, staff must contact the police via 999 and then notify the DSL at the earliest opportunity. Making Referrals to MASH The DSL (or delegated safeguarding officer) is responsible for making referrals to MASH. Referrals will always: • Be timely, factual, and based on clear evidence or credible concerns. • Include relevant information about the individual, family context, presenting risks, and any actions already taken. • Be documented securely in accordance with our recording procedures. Where the threshold for statutory intervention is not met, the DSL may consult with MASH for advice or signpost to appropriate early help services. Information Sharing We are committed to lawful, proportionate, and necessary information sharing in line with: • The Data Protection Act 2018 • UK GDPR • Relevant statutory safeguarding guidance Information will only be shared with MASH or the police when it is essential to protect an individual from harm, prevent a crime, or support a multi-agency safeguarding response. All sharing decisions will be recorded on the safeguarding file, including what was shared, with whom, and why. pg. 10 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 Working with the Police We will cooperate fully with the police during safeguarding investigations, including: • Providing information in a timely and secure manner • Preserving evidence when required • Ensuring staff are available for interviews or statements if appropriate • Supporting individuals affected by the investigation Where police request information that may conflict with the individual’s expectations of confidentiality, the DSL will follow legal and safeguarding guidance to determine what can be shared safely and lawfully. Record Keeping All safeguarding concerns, referrals, consultations, and inter-agency communications must be recorded clearly, accurately, and without delay. Records will be stored securely, with restricted access, in accordance with our confidentiality and data protection policies. Local Authority Safeguarding Contacts 1. London Borough of Merton, Civic Centre, 12 th Floor, London Road, Morden, SM4 5DX Merton – MASH Team, Safeguarding Children Partnership 020 8545 4226 candfhub@merton.gov.uk LADO – John Shelley 020 85453187 lado@merton.gov.uk 2. Wandsworth – MASH Team, Children’s Social Care, 2 ND Floor, Town Hall Extension, Wandsworth, SW18 2PU Telephone: 020 8871 6622 (out of hrs – 020 8871 6000) Email: mash@wandsworth.gov.uk Local Authority Designated Officer Anita Gibbons Telephone: 07974 586 461 Email: lado@wandsworth.gov.uk 3. Kingston Council – High St, Kingston upon Thames KT1 1EU Single point of access - 020 8547 5008 (outside office hrs 020 8770 5000) pg. 11 AFC Wimbledon Foundation Safeguarding Policy Last Updated November 2025 The designated manager for allegations can immediately submit a LADO referral form, or call the LADO service on 07774 332675 for a consultation before submitting a referral form. LADO@achievingforchildren.org.uk Football Safeguarding contacts Kate Shelley - Lead Designated Safeguarding Officer – AFC Wimbledon Football Club 07562 952001 kate.shelley@afcwimbledon.ltd.uk London FA Designated Safeguarding Officer, Charmain Duberry Football Safeguarding & Welfare Manager 07938489199 Safeguarding@LondonFA.com London FA Football Safeguarding Case Officer, Terese Molyneaux 07525237348 Safeguarding@LondonFA.com Tara Lawson EFL Trust Safeguarding & Incident Manager – office hrs 01772 376797 07964 905652 tlawson@efl.com The FAs Safeguarding Team via 0800 169 1863 # 6300 (during office hours Mon-Fri exec bank holidays) or (including out of hours) the FA/NSPCC Child Protection Helpline 08088005000 If you have an urgent concern that needs immediate attention outside of our working hours, please contact the NSPCC's 24 hour helpline on 0808 800 5000. A 24hr NSPCC helpline for calls around historical abuse within football can aslo be contacted via 08000232642 and /or https://www.victimsupport.org.uk/ and/or https://www.sportingchanceclinic.com/. SECTION 2 2.1 - An Introduction to Safeguarding Children Due to their statutory responsibility for children and young people, all Children’s Services Departments have established procedures that provide guidance and information on safeguarding children and responding to child abuse. Under these procedures, a “child” or “young person” is defined as any individual under the age of 18. This document outlines procedures that are specifically designed for AFC Wimbledon Foundation and applies to all staff who come into direct contact with children and young people who may be, or may become, victims of abuse. The safeguarding of all young people who come into the care of AFC Wimbledon Foundation is the responsibility of all employees of the organisation and the board of trustees. AFC Wimbledon