Safeguarding Policy

1Policy Statement

Shepherds Only Foundation (“SOF” or “the Foundation”) is committed to creating and maintaining an environment in which every person who encounters the Foundation is treated with dignity, honour, compassion and respect and is protected, so far as reasonably possible, from abuse, exploitation, neglect, harassment and avoidable harm.

Safeguarding is a fundamental responsibility of the Foundation.

The Foundation recognises that charitable work can create relationships involving trust, access, influence, dependency and unequal power. Individuals receiving assistance may be experiencing financial hardship, illness, bereavement, disability, family difficulty, displacement, old age, social isolation or other circumstances that may increase vulnerability.

Such vulnerability must never be exploited.

No position of spiritual authority, organisational responsibility, financial influence, professional standing, pastoral relationship, donor status or personal relationship places any person beyond the requirements of this Policy.

The Foundation adopts zero tolerance for abuse, exploitation and deliberate safeguarding violations.

This means that credible concerns will be taken seriously, handled appropriately and addressed without favouritism, concealment or retaliation. It does not mean that allegations will automatically be treated as proven. The Foundation will act fairly toward complainants, affected persons, witnesses and persons against whom allegations are made.

2Purpose

The purpose of this Policy is to:

• protect children and adults at risk who encounter the Foundation;
• prevent abuse, exploitation, neglect and harassment;
• establish clear standards of conduct for persons acting for or on behalf of SOF;
• establish procedures for identifying, reporting, escalating and responding to safeguarding concerns;
• protect beneficiaries from sexual, financial, spiritual and other forms of exploitation;
• establish appropriate safeguards for Foundation programmes, visits, communications and digital activities;
• ensure safeguarding concerns are referred to competent authorities where required or appropriate;
• establish accountability for safeguarding throughout the Foundation;
• protect individuals who raise safeguarding concerns in good faith; and
• promote a culture in which dignity, safety and responsible stewardship are integral to the Foundation’s work.

3Scope

This Policy applies to:

• trustees and directors;
• officers and members of committees;
• employees;
• volunteers;
• interns and secondees;
• consultants;
• contractors;
• programme personnel;
• representatives and ambassadors;
• partner organisations where safeguarding obligations form part of the relationship;
• service providers where their activities create contact with beneficiaries;
• visitors participating in Foundation activities; and
• any other person acting under the authority, direction or representation of Shepherds Only Foundation.

For purposes of this Policy, these persons may collectively be referred to as “SOF Representatives.”

The Policy applies to conduct occurring:

• at Foundation premises;
• during Foundation programmes;
• during beneficiary visits;
• at churches and ministry locations;
• during meetings and events;
• during travel undertaken for Foundation purposes;
• through telephone calls, messaging applications, email and social media;
• through Foundation websites, applications and databases;
• during photography, filming and storytelling activities;
• through partner organisations; and
• in any other context where a person is acting on behalf of or representing SOF.

Serious conduct outside Foundation activities may also fall within this Policy where it creates a safeguarding risk or materially affects a person’s suitability to work with children, adults at risk or beneficiaries.

4Legal and Regulatory Framework

The Foundation shall operate this Policy consistently with applicable Ghanaian law and, where appropriate, recognised international safeguarding standards.

Relevant frameworks include, as amended from time to time:

• the Constitution of the Republic of Ghana, 1992;
• the Children’s Act, 1998 (Act 560);
• the Children’s (Amendment) Act, 2016 (Act 937);
• the Domestic Violence Act, 2007 (Act 732);
• the Human Trafficking Act, 2005 (Act 694), as amended;
• the Persons with Disability Act, 2006 (Act 715);
• the Criminal Offences Act, 1960 (Act 29), as amended;
• the Data Protection Act, 2012 (Act 843);
• the Cybersecurity Act, 2020 (Act 1038);
• applicable labour, criminal, social welfare and child protection legislation;
• applicable regulations and governmental safeguarding requirements;
• the United Nations Convention on the Rights of the Child; and
• the African Charter on the Rights and Welfare of the Child.

Where SOF operates outside Ghana, applicable local safeguarding and reporting requirements shall also be observed.

Where this Policy establishes a higher organisational standard than the minimum required by law, SOF may apply the higher standard to the extent lawful.

5Guiding Principles

SOF’s safeguarding activities shall be guided by the following principles.

6Definitions

7Forms of Harm Covered

This Policy covers, without limitation:

8Sexual Exploitation and Abuse

SOF prohibits sexual exploitation and abuse by persons acting for or representing the Foundation.

No SOF Representative may:

• demand or solicit sexual activity in exchange for assistance;
• make financial assistance conditional upon romantic or sexual involvement;
• exploit a beneficiary’s vulnerability for sexual purposes;
• use confidential beneficiary information to pursue a sexual relationship;
• engage in sexual activity with a child;
• facilitate sexual exploitation;
• solicit sexually explicit material from a child;
• groom a beneficiary for sexual purposes; or
• use Foundation authority or resources to facilitate such conduct.

A mistaken belief concerning a child’s age is not an acceptable organisational justification for sexual activity with a child.

9Transactional Sex and Assistance

Foundation assistance must never be exchanged for:

• sex;
• sexual activity;
• romantic involvement;
• sexual images;
• personal services unrelated to the programme;
• political support;
• private payments;
• gifts to Foundation personnel;
• spiritual allegiance; or
• personal loyalty to an SOF Representative.

No beneficiary should be made to believe that continued assistance depends upon satisfying the personal demands of an SOF Representative.

10Financial Safeguarding of Beneficiaries

Because SOF may provide financial and material assistance, financial safeguarding is particularly important.

SOF Representatives must not:

• borrow money from beneficiaries;
• pressure beneficiaries to lend money;
• request personal gifts as a condition of assistance;
• demand commissions, percentages or kickbacks from grants or support payments;
• redirect beneficiary assistance for personal use;
• improperly obtain access to beneficiaries’ bank accounts, mobile-money wallets, PINs or passwords;
• induce beneficiaries to transfer assets to an SOF Representative;
• manipulate elderly or vulnerable beneficiaries into financial transactions; or
• exploit confidential financial information.

Any suspected diversion, theft or exploitation of beneficiary funds shall be treated as both a safeguarding and financial-integrity concern.

12Safeguarding Children

Where SOF programmes involve children, directly or indirectly, additional safeguards shall apply.

SOF Representatives must:

• prioritise the child’s welfare;
• maintain appropriate boundaries;
• avoid unnecessary isolated one-to-one situations;
• obtain appropriate consent for planned activities where required;
• use age-appropriate communication;
• avoid corporal punishment;
• avoid humiliating or degrading treatment;
• avoid sexualised communication;
• never request intimate images;
• never engage in sexual activity with a child;
• never groom a child;
• never exploit a child financially or otherwise; and
• promptly report safeguarding concerns.

Where practicable, activities involving children should be observable and accountable rather than conducted in unnecessarily isolated environments.

13Children of Beneficiaries

Even where a programme primarily supports an adult minister, SOF recognises that its activities may bring personnel into contact with that minister’s children or other children in the household.

The fact that a child is not the direct beneficiary does not remove SOF’s safeguarding responsibility.

Any credible concern relating to the safety of a child encountered through Foundation activities must be handled in accordance with this Policy.

14Adults at Risk

Adults shall be presumed capable of making their own decisions unless applicable law or the circumstances provide otherwise.

SOF shall avoid unnecessarily paternalistic treatment.

At the same time, personnel must remain alert to exploitation involving:

• disability;
• illness;
• cognitive impairment;
• financial dependency;
• bereavement;
• advanced age;
• social isolation;
• coercive relationships;
• homelessness; or
• severe financial distress.

The individual’s wishes should ordinarily be considered when determining appropriate action, subject to applicable law, immediate safety concerns, risks to others and reporting obligations.

15Safer Recruitment

SOF shall take reasonable steps to prevent unsuitable persons from obtaining positions of trust.

Depending on the role and applicable law, measures may include:

• identity verification;
• application screening;
• interviews;
• reference checks;
• verification of qualifications;
• employment-history review;
• criminal-record or police checks where lawful and appropriate;
• safeguarding declarations;
• conflict-of-interest declarations;
• signed acknowledgement of the Code of Conduct; and
• safeguarding induction.

The degree of screening should correspond to the safeguarding risk associated with the role.

Roles involving regular or unsupervised access to children or adults at risk should receive enhanced scrutiny.

16Safeguarding Code of Conduct

Every SOF Representative must:

• treat people respectfully;
• maintain appropriate professional boundaries;
• avoid exploitative relationships;
• report safeguarding concerns;
• protect confidential information;
• avoid discriminatory or degrading behaviour;
• never abuse organisational authority;
• never use Foundation assistance for personal leverage;
• comply with child-protection requirements;
• cooperate with authorised safeguarding investigations; and
• disclose circumstances that may create material safeguarding risks.

Compliance with the Foundation’s safeguarding requirements may be made a condition of appointment, volunteering, contracting or partnership.

17Home and Beneficiary Visits

Where SOF personnel visit beneficiaries in their homes, hospitals, churches or other private environments, reasonable safeguards shall be implemented.

Depending upon circumstances, these may include:

• recording the purpose and location of the visit;
• informing another authorised person of the visit;
• using two representatives where heightened safeguarding risks exist;
• avoiding unnecessary private meetings with children;
• respecting household privacy;
• limiting photography and recording; and
• documenting significant safeguarding concerns arising during the visit.

18Digital Safeguarding

Safeguarding obligations apply equally online.

SOF Representatives must not:

• engage in sexual or exploitative communication with beneficiaries;
• send inappropriate images or messages;
• request sexual images;
• disclose confidential beneficiary information through social media;
• establish inappropriate secret communications with children;
• cyberbully or harass another person;
• impersonate beneficiaries; or
• publish identifying safeguarding information without authority.

Where communication with children is necessary for Foundation purposes, SOF should use appropriate organisational channels and safeguards wherever reasonably practicable.

19Photography, Video and Beneficiary Stories

SOF shall portray beneficiaries with dignity.

Photographs, video recordings, testimonies and case studies shall not be obtained or published in an exploitative, misleading or unnecessarily intrusive manner.

Appropriate consent must be obtained where required.

Additional safeguards apply to children and persons whose circumstances may impair their ability to provide meaningful consent.

SOF should avoid publishing information that could unnecessarily expose a person to:

• stigma;
• retaliation;
• exploitation;
• identification as a survivor of abuse;
• financial targeting; or
• other foreseeable harm.

A person’s receipt of assistance does not give the Foundation unrestricted rights over that person’s identity, story or image.

Where consent for publicity is voluntary, refusal should not by itself disqualify an otherwise eligible person from assistance.

20Data Protection and Safeguarding Records

Safeguarding information is highly sensitive.

The Foundation shall handle personal information in accordance with applicable data-protection law and its Privacy / Data Protection Policy.

Safeguarding records shall:

• be accurate;
• distinguish factual observations from opinions;
• be appropriately secured;
• be accessible only to authorised persons;
• not be circulated unnecessarily;
• be retained according to applicable legal and organisational requirements; and
• be disposed of securely when lawful and appropriate.

Information may nevertheless be disclosed where necessary to protect a person, comply with law, report suspected criminal conduct, obtain professional advice or cooperate with competent authorities.

21Duty to Report Concerns

All SOF Representatives have a duty to report safeguarding concerns arising in connection with Foundation activities.

A person does not need proof before raising a concern.

Reasonable suspicion, a disclosure, observed behaviour or credible information may be sufficient to make a report.

Personnel should not conduct their own unauthorised investigations before reporting.

Reports should contain factual information and avoid unnecessary speculation.

22How to Report a Safeguarding Concern

Safeguarding concerns may be reported to:

Where the allegation concerns the Designated Safeguarding Lead, it should be reported directly to the Chair or designated independent Board member.

Where the allegation concerns the Chair, it should be reported to another authorised trustee or external authority as appropriate.

SOF should maintain more than one reporting route so that no single individual can prevent a safeguarding concern from being raised.

23Emergency Situations

Where a person appears to be in immediate danger, the priority is safety.

Personnel should contact appropriate emergency, police, medical, child-protection or social-welfare authorities where circumstances require immediate intervention.

Internal reporting requirements must never be used to delay emergency assistance.

24Receiving a Disclosure

When someone discloses abuse, the recipient should, as appropriate:

• listen calmly;
• take the disclosure seriously;
• avoid blaming the person;
• avoid unnecessarily interrogating the person;
• not promise absolute confidentiality;
• explain that information may need to be shared with persons who can help;
• record the material facts as accurately as practicable;
• preserve relevant evidence;
• report promptly through the appropriate safeguarding channel; and
• consider immediate safety needs.

The role of ordinary personnel is to receive and report, not to conduct a forensic investigation.

25Reporting to Authorities

SOF shall refer safeguarding matters to the Ghana Police Service, Department of Social Welfare, Domestic Violence and Victim Support Unit (DOVVSU), medical services or another competent authority where required by law or where the nature and seriousness of the concern warrants external referral.

Nothing in this Policy prevents any person from lawfully reporting suspected criminal conduct directly to competent authorities.

The Foundation shall not enter into private arrangements intended to conceal conduct that should properly be reported to law-enforcement or safeguarding authorities.

26Safeguarding Incident Management

Upon receiving a concern, the Designated Safeguarding Lead or authorised substitute should undertake an initial safeguarding assessment.

The assessment should consider:

• immediate danger;
• whether a child is involved;
• whether an adult at risk is involved;
• whether medical assistance is required;
• whether alleged criminal conduct is involved;
• whether other persons may be at risk;
• whether the accused person continues to have access to potential victims;
• whether external authorities should be notified;
• whether interim protective measures are necessary; and
• how confidentiality should be maintained.

A written record of material decisions should be maintained.

27Interim Protective Measures

Where reasonably necessary to protect persons or preserve an investigation, SOF may implement interim measures including:

• temporary reassignment;
• restriction of beneficiary contact;
• suspension from particular activities;
• withdrawal of access to premises or systems;
• increased supervision; or
• temporary suspension from duties.

An interim measure is precautionary and does not, by itself, constitute a finding of wrongdoing.

28Investigations

Where SOF conducts an internal safeguarding investigation, it should be:

• appropriately authorised;
• impartial;
• proportionate;
• confidential;
• documented;
• undertaken by persons with suitable competence; and
• conducted without improperly interfering with police or statutory investigations.

Serious or complex allegations may be referred to independent external investigators or professional advisers.

Persons accused of misconduct shall be treated fairly and given an appropriate opportunity to respond, subject to safety considerations, legal requirements and the integrity of any investigation.

29Protection Against Retaliation

SOF prohibits retaliation against anyone who, in good faith:

• reports a safeguarding concern;
• makes a disclosure;
• supports an affected person;
• provides information;
• participates in an investigation; or
• refuses to participate in abusive conduct.

Retaliation may itself constitute misconduct and may result in disciplinary action.

Knowingly making a malicious or deliberately false allegation may also constitute misconduct.

A report that is made honestly but is ultimately unsubstantiated shall not, merely for that reason, be treated as malicious.

30Confidentiality

Safeguarding matters shall be handled on a need-to-know basis.

The Foundation will not guarantee absolute confidentiality because information may need to be shared to:

• protect a child or adult at risk;
• prevent further harm;
• comply with law;
• obtain legal or professional advice;
• conduct an authorised investigation; or
• cooperate with competent authorities.

All persons handling safeguarding information must respect the dignity and privacy of the individuals concerned.

31Support for Persons Affected by Abuse

Where reasonably practicable and appropriate, SOF may assist an affected person in accessing suitable support.

This may include referral to:

• medical services;
• counselling;
• social welfare services;
• law-enforcement authorities;
• child-protection services;
• legal services;
• domestic-violence services; or
• other specialised support.

Any support offered should avoid compromising investigations or creating inappropriate dependency.

32Partnerships and Third Parties

SOF shall consider safeguarding risks when selecting and working with partner organisations.

Depending upon the nature of the partnership, SOF may require partners to:

• maintain adequate safeguarding policies;
• comply with agreed safeguarding standards;
• report serious safeguarding incidents;
• conduct appropriate personnel screening;
• permit safeguarding monitoring;
• cooperate with investigations; and
• take corrective action where deficiencies are identified.

SOF may suspend or terminate relationships where serious safeguarding failures occur, subject to contractual rights and applicable law.

33Grants and Financial Assistance

Where SOF provides grants or assistance through another organisation, safeguarding considerations should form part of reasonable due diligence.

Funding agreements may include safeguarding provisions proportionate to the programme.

The Foundation reserves the right, subject to applicable agreements and law, to suspend funding where credible safeguarding risks require immediate protective action.

34Events and Programmes

Safeguarding risks should be considered when planning programmes and events.

Relevant considerations may include:

• participant profile;
• presence of children;
• venue security;
• accessibility;
• transportation;
• accommodation;
• supervision;
• photography;
• emergency procedures;
• first aid;
• confidential reporting channels; and
• online participation.

Higher-risk programmes should receive proportionately greater safeguarding planning.

35Safeguarding Risk Assessments

SOF should incorporate safeguarding into its organisational risk-management framework.

Risk assessments should consider:

• who may be vulnerable;
• how harm could occur;
• likelihood and severity;
• existing controls;
• additional safeguards required;
• responsibility for implementation; and
• review arrangements.

Safeguarding risk assessments should be reviewed when programmes materially change or when significant incidents reveal weaknesses.

36Training

Trustees, staff and relevant volunteers shall receive safeguarding orientation appropriate to their responsibilities.

Persons with heightened safeguarding responsibilities should receive additional training.

Training may cover:

• recognising abuse;
• responding to disclosures;
• reporting procedures;
• child safeguarding;
• adults at risk;
• sexual exploitation and abuse;
• spiritual abuse;
• financial exploitation;
• digital safeguarding;
• confidentiality;
• record keeping; and
• emergency escalation.

37Designated Safeguarding Lead

The Foundation shall appoint a Designated Safeguarding Lead (“DSL”).

The DSL’s responsibilities include:

• overseeing implementation of this Policy;
• receiving safeguarding reports;
• coordinating initial risk assessments;
• maintaining appropriate safeguarding records;
• facilitating referrals;
• advising personnel;
• coordinating training;
• monitoring safeguarding risks;
• reporting appropriately to the Board; and
• recommending improvements.

The Foundation should also appoint a suitable deputy or alternative reporting officer.

38Board Responsibility

Ultimate oversight of safeguarding rests with the Foundation’s governing body.

The Board shall seek to ensure that:

• appropriate safeguarding arrangements exist;
• serious concerns are escalated appropriately;
• safeguarding risks are included in organisational risk management;
• management is accountable for implementation;
• sufficient independence exists for allegations concerning senior leadership;
• significant safeguarding failures are addressed; and
• this Policy is periodically reviewed.

At least one trustee may be designated to provide specific Board-level safeguarding oversight.

39Allegations Against Senior Leadership

Safeguarding allegations involving a founder, trustee, senior executive, Designated Safeguarding Lead or other powerful person must not be investigated solely under that person’s authority.

The matter shall be escalated to an appropriate independent governance level and, where warranted, external authorities or independent professional investigators.

No founder, donor, trustee, minister, executive or other person may suppress a safeguarding report because of reputation, financial consequences, relationships or organisational interests.

40Safeguarding and Reputation

The protection of people takes precedence over the avoidance of embarrassment or reputational damage.

Safeguarding concerns shall not be concealed merely to protect:

• the Foundation;
• a church;
• a ministry;
• a donor;
• a trustee;
• a minister;
• an employee;
• a partner; or
• any other person’s reputation.

At the same time, confidentiality and fairness shall be maintained and allegations shall not be publicly presented as established facts before an appropriate determination.

41Breaches of this Policy

A breach may result in measures including:

• additional supervision;
• retraining;
• disciplinary action;
• suspension;
• termination of employment;
• termination of volunteer service;
• termination of a contract or partnership;
• removal from Foundation activities;
• referral to regulatory or professional bodies; or
• referral to law-enforcement or safeguarding authorities.

The appropriate response will depend upon the circumstances and applicable law.

42Record Keeping and Monitoring

SOF shall maintain appropriate records of:

• safeguarding reports;
• actions taken;
• referrals;
• investigations;
• decisions;
• training;
• risk assessments; and
• significant safeguarding improvements.

The Board should receive appropriate safeguarding information periodically while respecting confidentiality.

Serious incidents should be escalated promptly rather than waiting for routine reporting cycles.

43Learning From Incidents

Safeguarding incidents and near misses should be used to strengthen the Foundation’s systems.

Following significant incidents, SOF may conduct a safeguarding review examining:

• what happened;
• whether warning signs existed;
• whether procedures were followed;
• whether existing controls were adequate;
• what organisational weaknesses contributed; and
• what corrective measures are required.

The purpose of such review is prevention and institutional learning in addition to individual accountability.

44Related Policies

This Policy should be read alongside the Foundation’s:

• Code of Ethics;
• Code of Conduct;
• Whistleblower Policy;
• Conflict of Interest Policy;
• Non-Discrimination Policy;
• Privacy and Data Protection Policy;
• Complaints Policy;
• Anti-Fraud and Financial Misconduct Policy;
• Volunteer Policy;
• Human Resources policies;
• Grant-Making Policy;
• Risk Management Policy; and
• other applicable governance policies.

Where policies overlap, the Foundation should apply them consistently and prioritise immediate safeguarding needs.

45Accessibility of Reporting

SOF shall seek to make safeguarding reporting reasonably accessible.

Where appropriate, reporting mechanisms should accommodate persons who:

• have disabilities;
• have literacy difficulties;
• do not use email;
• require language assistance;
• are children;
• fear retaliation; or
• cannot safely report through ordinary management channels.

No person should be denied the opportunity to raise a safeguarding concern merely because they cannot submit a formal written complaint.

46No Waiver by Consent

A person’s apparent agreement does not necessarily make exploitative conduct acceptable where there is coercion, abuse of authority, unlawful conduct or exploitation of significant vulnerability.

In particular, a child cannot provide legally effective consent to conduct prohibited by child-protection or criminal law.

47Duty of Cooperation

SOF Representatives are expected to cooperate honestly with authorised safeguarding processes.

No person may:

• destroy relevant evidence;
• knowingly falsify safeguarding records;
• intimidate witnesses;
• coach persons to provide false accounts;
• conceal relevant information; or
• obstruct a lawful safeguarding investigation.

48Policy Review

This Policy shall ordinarily be reviewed at least every two years, and earlier where:

• relevant law changes;
• the Foundation materially changes its programmes;
• operations expand into new jurisdictions;
• a serious safeguarding incident occurs;
• an audit identifies deficiencies; or
• recognised safeguarding practice materially changes.

Amendments require approval through the Foundation’s appropriate governance process.