Student Protection Policy
Education First Cambodia (EFC) provides education and assistance to impoverished Cambodian young adults and children. This Student Protection Policy arises from EFC’s commitment to the protection of its beneficiaries and its “zero tolerance” approach to abuse and child pornography. EFC is determined to take all necessary steps to manage and minimize any potential risk of abuse for the young adults and children assisted by the organization and to protect them from harm.
EFC takes its duty of care responsibilities seriously, and is committed to ensuring that it maintains a safe, nurturing and joyful environment for the students in its programs. EFC recognizes that any person working closely with young adults or children may have power and influence over them, and works diligently to prevent any abuse.
EFC and all adults involved in EFC accept the duty to safeguard the welfare of all students in the organization, without exception. This policy outlines our commitment to providing the students supported by EFC with the safest possible environment. This requires action to prevent intentional and unintentional abuse and harm of all kinds.
SCOPE
The policy applies to all EFC employees (paid or unpaid), contractors, consultants, volunteers, visitors, donors, supporters, and any partner organization.
EFC expects any organization, employee (paid or unpaid), contractor, consultant, volunteer and any partner organization to act in accordance with the principals detailed in this policy. For the purpose of this policy, “children” shall mean anyone under the age of 18 years and participating in EFC’s programs.
ACTIVE MANAGEMENT APPROACH TO RISK
While it is not possible to eliminate all risk of student abuse, sound and active management can minimize the likelihood or incidence of student abuse.
PURPOSE OF THE POLICY
This Student Protection Policy (SPP) has been developed to provide a practical guide to prevent student abuse in EFC’s facility and programs. It outlines a range of risk management strategies that will be implemented and which will reduce the risk of students being harmed.
• The SPP will demonstrate EFC’s commitment to protect students from harm and abuse.
• The SPP aims to educate staff and others about student abuse and promote a student-safe and friendly culture where everyone is committed to keeping students safe.
• The SPP aims to create an open and aware environment where concerns for the safety and well being of a student can be raised and managed in a fair and just manner that protects the rights of all.
• Additionally, the SPP will provide guidance on how to respond to concerns and allegations of student abuse. It provides guidance to staff and others on how to work respectfully and effectively with students. This will provide all stakeholders, including staff and others with a safe working environment.
• EFC is obliged to adhere to local and international student protection criminal laws that prohibit the abuse and exploitation of students. These include local laws where EFC programs exist, and international laws and conventions in relation to all forms of child abuse and child exploitation, including: child sex tourism, child sex trafficking, child labor and child pornography.
GUIDING PRINCIPLES
The Student Protection Policy is guided by these principles:
1) Zero tolerance of abuse
Student abuse is not tolerated by EFC. EFC takes an active approach to risk management and ensures that its staff are selected, trained and obligated accordingly. EFC will not knowingly employ or use the services of anyone known or likely to pose an unacceptable risk to students.
2) Priority of the interests of the student
EFC places the interests of the students in its programs as its highest priority. Their physical and emotional security and welfare, along with the development of their abilities and characters, are EFC’s major concern and their protection will always be its highest value.
3) Individual and collective responsibility for student protection
EFC recognizes its legal and moral accountability, and the accountability of all individuals concerned for student protection. It regards student protection as the responsibility of all EFC staff at all levels, and requires the active support and cooperation of all individuals involved with the organization, including employees, any organization, employee (paid or unpaid), contractor, consultant, volunteer, visitor, donor, supporter and any partner organization.
DEFINITIONS
1) Duty of care
Duty of care is a common law concept that refers to the responsibility of the organization to provide students with an adequate level of protection against harm. It is the duty of the organization to protect students from all reasonably foreseeable risk of injury.
2) Child or young person
A child or young person is regarded to be any person under the age of 18 years, unless a nation’s laws recognize adulthood earlier. For the purposes of this policy, EFC recognizes a student to be a person under 18 years of age.
3) Student protection
Is the term used to describe the responsibilities and activities undertaken to prevent or stop students from being abused or maltreated.
4) Student abuse
Abuse happens to male and female students of all ages, ethnicity and social backgrounds, abilities, sexual orientation, religious beliefs and political persuasion. Student abuse includes physical, sexual, emotional, neglect, bullying, student labor and domestic violence.
5) Physical abuse
This occurs when a person purposefully injures or threatens to injure a student or young person. This may take the form of slapping, punching, shaking, kicking, burning, shoving or grabbing. The injury may take the form of bruises, cuts, burns or fractures.
6) Emotional abuse
This occurs when a student is repeatedly rejected or frightened by threats. This may involve name-calling, being unduly criticized, or continual coldness from parent or caregiver, to the extent that it affects the student’s physical and emotional growth.
7) Neglect
Neglect is the persistent failure or the deliberate denial to provide the student with clean water, food, shelter, sanitation or supervision. It also includes the persistent failure or the deliberate denial to provide the student with care if the student’s health and development are placed at risk.
8) Sexual Abuse
This occurs when a student or young person is used by an older or bigger student, adolescent or adult for his or her own sexual stimulation or gratification, regardless of the age of the majority or age of consent locally. These can be contact or non-contact acts, including threats and exposure to pornography.
9) Child-Sex Tourism
End Child Prostitution, Child Pornography and Trafficking of Children (ECPAT) International defines child-sex tourism as “…the commercial sexual exploitation of children by men or women who travel from one place to another, usually from a richer country to one that is less developed, and there engage in sexual acts with children, defined as anyone aged under 18 years of age.”
10) Bullying
Bullying is the inappropriate use of power by an individual or group, with intent to injure either physically or emotionally. It is usually deliberate and repetitive. The bullying may be physical or psychological (verbal and non-verbal).
• Physical bullying includes pushing, hitting, punching, kicking or any other action causing hurt or injury.
• Verbal bullying includes insults, taunts, threats and ridicule.
• Psychological bullying includes physical intimidation and ostracism.
11) Exposure to domestic violence
Domestic violence occurs when students and young people witness or experience the chronic domination, coercion, intimidation or victimization of one person by another by physical, sexual or emotional means within intimate relationships.
12) Particularly vulnerable students
Student abuse takes place not only within the family environment, but also outside the family, including: institutions, at work, on the streets, in war zones and emergencies.
PURPOSE OF THE POLICY
EFC recognizes that there are a number of potential risks to students in the delivery of its programs to the vulnerable and disadvantaged. In recognizing these risks, EFC proactively assesses and manages these risks to students in our programs (and in the communities in which we work) to reduce the risk of harm. This is achieved by examining each program and its potential impact on students. Programs that involve direct work with children are considered a higher risk, and therefore require more stringent student protection procedures. However, as children are part of every community in which we work, we are always mindful of potential risks.
Risk management is an ongoing part of every activity, and EFC conducts a student protection risk assessment on every new and emerging program and project.
Staff and others should continually be aware of risks, and be actively minimizing opportunities and situations where students can be harmed.
A student abuse incident reporting sheet has been developed and staff is aware of its existence.
AWARENESS
All representatives will be individually and collectively responsible for student protection and will be made aware of this policy and any related guidelines, codes or protocols. Designated staff are responsible for monitoring student protection issues and will facilitate policy implementation, staff training and awareness, and incident reporting.
EFC staff will talk with students in EFC’s programs to ensure that the students understand about their safety and protection, and feel comfortable about speaking to someone if they have any concerns. Students will be made aware of an independent adult to whom they can refer any concerns. Students will be encouraged to say at any time what they find acceptable and unacceptable regarding the way they are approached by adults or other young people.
RECRUITMENT PROCEDURES
Procedures for staff recruitment contain appropriate student protection measures, including, wherever possible, the provision of background information and references. EFC will reject any persons who might be considered a risk to student safety.
To assist in the recruitment and screening processes EFC will require national police checks (or equivalent standard) to be conducted on all staff and volunteers, both expatriate and Cambodian. References and copies of passports and/or national identity cards will need to be supplied, and referees will be contacted for verbal confirmation of the applicant’s character.
Behavioral-based interviews will be conducted with all applicants applying for positions. All staff, contractors and associates will be required to immediately disclose all charges, convictions and any other outcomes of an offense which occurred before or occurs during their association with EFC that relate to student exploitation and abuse.
All successful candidates and existing representatives will be clearly informed of their contractual requirement to comply with this policy prior to work, and required to sign and comply with EFC’s Student Protection Policy.
TRAINING
EFC personnel are subject to training on student protection and are required to keep their knowledge up-to-date.
Designated EFC contact officers will undergo regular training to ensure that they are capable and competent to conduct the initial complaint handling and comply with the reporting processes.
The Student Protection Manager will have the role of ensuring that all staff are up-to-date with policy changes and the implementing of training regimes for all staff and students alike.
CONDUCT
All individuals are required to behave with students in a manner that fully respects their dignity and rights, and minimizes any possible situation of risk. All representatives will:
• Treat all students with respect regardless of distinguishing factors such as age, race, religion, sexuality, disability or other status.
• Not behave towards them in any manner, physical or verbal, which is or can be construed as inappropriate, harassing, abusive, provocative or demeaning.
• Not engage students in any form of sexual activity or acts, including paying for sexual services or acts, where under relevant legislation the student is below the age of consent or the act(s) constitute an offense.
• Wherever possible, ensure that another adult is present when working in the proximity of students.
• Not invite unaccompanied students into their home, unless they are at immediate risk.
• Will take seriously any complaint of student abuse from whatever source, and will report any known breach of the Student Protection Policy, the Student Protection Code of Conduct, or any concerns relating to the safety of the students to EFC.
• Use any communications or recording technology or social media appropriately; never exploit, harass or put students at risk through the use of such technology; or access child pornography via any medium or from any source.
• Not use physical punishment as a disciplinary tool.
• Not employ students for domestic or other work inappropriate to their age or developmental stage, or which interferes with access to education or recreation or which places them at risk of injury.
• Comply with all relevant laws.
• Report concerns or allegations of student abuse as quickly as possible, as set down in relevant procedures.
• Ensure that adults or personnel who are not permanent approved staff have regular EFC staff present when in contact with students, do not take students out of EFC facilities without EFC staff present, or make independent contact with students’ families.
EFC will always ensure that information or images about students are never used in a way that places students at risk, or compromises their safety or dignity. Regulations governing the use of photography and videos are in place as part of the student protection procedures.
COMMUNICATION AND USE OF STUDENT IMAGES
EFC will at all times portray students in a respectful, appropriate and consensual way.
• A student should always be portrayed in a dignified and respectful manner and not in a vulnerable or submissive manner. Students should be adequately clothed and not in poses that could be seen as sexually suggestive.
• There should be no identifying information of the student used in the publication of images or their location.
• Students should be portrayed as part of their community.
• Local cultural traditions should be assessed regarding restrictions for reproducing personal images.
• Images should be an honest representation of the context and the facts.
• When sending images electronically, file names should not reveal identifying information.
EFC maintains strong communication links with the parents or those otherwise legally responsible for the children in its programs, and ensures that they are appropriately informed about all issues regarding the children and their welfare.
EFC respects the confidentiality of information regarding students’ health, family backgrounds and personal histories. This private information is accessed only by authorized staff on a ‘need to know’ basis.
Guidelines, rules and implementation procedures relating to student protection are available to all EFC personnel.
The Student Protection Policy and all associated policies, such as the Student Protection Code of Conduct and Student Protection Reporting Process, will be reviewed and amended as needed.
REPORTING AND RESPONSE
EFC recognizes the need to implement specific guidelines to manage the student protection risks within its programs. EFC’s guidelines in relation to sponsors and students include:
• All communications between sponsors and children are monitored by qualified EFC staff. Communications that contain inappropriate content, including cultural, political or religious material which may cause offense, are strictly prohibited.
• All visits by sponsors must be arranged in advance with appropriate EFC staff.
• All sponsors will be required to read the Student Protection Policy.
• Supervised outings from EFC facilities may be permitted for students of a suitable age.
• Qualified EFC staff will be present at all times during a sponsor visits and during authorized outings.
• Sponsors and sponsored children and their families must not exchange contact details during visits.
• Students must not be invited to leave or be taken away from their communities.
In the event of any incidents, comments, suspicions or concerns, the case must be immediately reported to senior management and an investigation commenced. All cases of abuse will be investigated thoroughly in line with established procedures. When responding to concerns or allegations of harm or abuse, the ultimate guiding principle will be the best interests and well-being of the student or students involved.
A student reporting concerns or claiming to be the subject of abuse will be protected, taken seriously, and treated with respect. He or she will be reassured that they are not to blame – he or she will never be treated with disbelief or in a manner that might cause shame or embarrassment. EFC will immediately remove a student from an abusive environment, seek medical treatment for any injuries and make any necessary further referrals.
In the event of an allegation made in good faith, which is shown to be unfounded or untrue, no action will be taken against the maker of the allegation. False and malicious allegations are unacceptable and perpetrators will be subject to appropriate action. Failure of an EFC representative to report suspected student abuse will render the representative liable to criminal penalties and/or termination of employment.
All EFC staff and will be made aware of the Student Abuse Reporting Process. The Student Protection Manager will be responsible for the investigation of all initial complaints and will make an assessment on the allegation and take appropriate action, which can range from no-action, behavioral management, counseling, referring the complaint to local law enforcement/police, and dismissal from EFC.
EFC takes its duty of care responsibilities seriously, and is committed to ensuring that it maintains a safe, nurturing and joyful environment for the students in its programs. EFC recognizes that any person working closely with young adults or children may have power and influence over them, and works diligently to prevent any abuse.
EFC and all adults involved in EFC accept the duty to safeguard the welfare of all students in the organization, without exception. This policy outlines our commitment to providing the students supported by EFC with the safest possible environment. This requires action to prevent intentional and unintentional abuse and harm of all kinds.
SCOPE
The policy applies to all EFC employees (paid or unpaid), contractors, consultants, volunteers, visitors, donors, supporters, and any partner organization.
EFC expects any organization, employee (paid or unpaid), contractor, consultant, volunteer and any partner organization to act in accordance with the principals detailed in this policy. For the purpose of this policy, “children” shall mean anyone under the age of 18 years and participating in EFC’s programs.
ACTIVE MANAGEMENT APPROACH TO RISK
While it is not possible to eliminate all risk of student abuse, sound and active management can minimize the likelihood or incidence of student abuse.
PURPOSE OF THE POLICY
This Student Protection Policy (SPP) has been developed to provide a practical guide to prevent student abuse in EFC’s facility and programs. It outlines a range of risk management strategies that will be implemented and which will reduce the risk of students being harmed.
• The SPP will demonstrate EFC’s commitment to protect students from harm and abuse.
• The SPP aims to educate staff and others about student abuse and promote a student-safe and friendly culture where everyone is committed to keeping students safe.
• The SPP aims to create an open and aware environment where concerns for the safety and well being of a student can be raised and managed in a fair and just manner that protects the rights of all.
• Additionally, the SPP will provide guidance on how to respond to concerns and allegations of student abuse. It provides guidance to staff and others on how to work respectfully and effectively with students. This will provide all stakeholders, including staff and others with a safe working environment.
• EFC is obliged to adhere to local and international student protection criminal laws that prohibit the abuse and exploitation of students. These include local laws where EFC programs exist, and international laws and conventions in relation to all forms of child abuse and child exploitation, including: child sex tourism, child sex trafficking, child labor and child pornography.
GUIDING PRINCIPLES
The Student Protection Policy is guided by these principles:
1) Zero tolerance of abuse
Student abuse is not tolerated by EFC. EFC takes an active approach to risk management and ensures that its staff are selected, trained and obligated accordingly. EFC will not knowingly employ or use the services of anyone known or likely to pose an unacceptable risk to students.
2) Priority of the interests of the student
EFC places the interests of the students in its programs as its highest priority. Their physical and emotional security and welfare, along with the development of their abilities and characters, are EFC’s major concern and their protection will always be its highest value.
3) Individual and collective responsibility for student protection
EFC recognizes its legal and moral accountability, and the accountability of all individuals concerned for student protection. It regards student protection as the responsibility of all EFC staff at all levels, and requires the active support and cooperation of all individuals involved with the organization, including employees, any organization, employee (paid or unpaid), contractor, consultant, volunteer, visitor, donor, supporter and any partner organization.
DEFINITIONS
1) Duty of care
Duty of care is a common law concept that refers to the responsibility of the organization to provide students with an adequate level of protection against harm. It is the duty of the organization to protect students from all reasonably foreseeable risk of injury.
2) Child or young person
A child or young person is regarded to be any person under the age of 18 years, unless a nation’s laws recognize adulthood earlier. For the purposes of this policy, EFC recognizes a student to be a person under 18 years of age.
3) Student protection
Is the term used to describe the responsibilities and activities undertaken to prevent or stop students from being abused or maltreated.
4) Student abuse
Abuse happens to male and female students of all ages, ethnicity and social backgrounds, abilities, sexual orientation, religious beliefs and political persuasion. Student abuse includes physical, sexual, emotional, neglect, bullying, student labor and domestic violence.
5) Physical abuse
This occurs when a person purposefully injures or threatens to injure a student or young person. This may take the form of slapping, punching, shaking, kicking, burning, shoving or grabbing. The injury may take the form of bruises, cuts, burns or fractures.
6) Emotional abuse
This occurs when a student is repeatedly rejected or frightened by threats. This may involve name-calling, being unduly criticized, or continual coldness from parent or caregiver, to the extent that it affects the student’s physical and emotional growth.
7) Neglect
Neglect is the persistent failure or the deliberate denial to provide the student with clean water, food, shelter, sanitation or supervision. It also includes the persistent failure or the deliberate denial to provide the student with care if the student’s health and development are placed at risk.
8) Sexual Abuse
This occurs when a student or young person is used by an older or bigger student, adolescent or adult for his or her own sexual stimulation or gratification, regardless of the age of the majority or age of consent locally. These can be contact or non-contact acts, including threats and exposure to pornography.
9) Child-Sex Tourism
End Child Prostitution, Child Pornography and Trafficking of Children (ECPAT) International defines child-sex tourism as “…the commercial sexual exploitation of children by men or women who travel from one place to another, usually from a richer country to one that is less developed, and there engage in sexual acts with children, defined as anyone aged under 18 years of age.”
10) Bullying
Bullying is the inappropriate use of power by an individual or group, with intent to injure either physically or emotionally. It is usually deliberate and repetitive. The bullying may be physical or psychological (verbal and non-verbal).
• Physical bullying includes pushing, hitting, punching, kicking or any other action causing hurt or injury.
• Verbal bullying includes insults, taunts, threats and ridicule.
• Psychological bullying includes physical intimidation and ostracism.
11) Exposure to domestic violence
Domestic violence occurs when students and young people witness or experience the chronic domination, coercion, intimidation or victimization of one person by another by physical, sexual or emotional means within intimate relationships.
12) Particularly vulnerable students
Student abuse takes place not only within the family environment, but also outside the family, including: institutions, at work, on the streets, in war zones and emergencies.
PURPOSE OF THE POLICY
EFC recognizes that there are a number of potential risks to students in the delivery of its programs to the vulnerable and disadvantaged. In recognizing these risks, EFC proactively assesses and manages these risks to students in our programs (and in the communities in which we work) to reduce the risk of harm. This is achieved by examining each program and its potential impact on students. Programs that involve direct work with children are considered a higher risk, and therefore require more stringent student protection procedures. However, as children are part of every community in which we work, we are always mindful of potential risks.
Risk management is an ongoing part of every activity, and EFC conducts a student protection risk assessment on every new and emerging program and project.
Staff and others should continually be aware of risks, and be actively minimizing opportunities and situations where students can be harmed.
A student abuse incident reporting sheet has been developed and staff is aware of its existence.
AWARENESS
All representatives will be individually and collectively responsible for student protection and will be made aware of this policy and any related guidelines, codes or protocols. Designated staff are responsible for monitoring student protection issues and will facilitate policy implementation, staff training and awareness, and incident reporting.
EFC staff will talk with students in EFC’s programs to ensure that the students understand about their safety and protection, and feel comfortable about speaking to someone if they have any concerns. Students will be made aware of an independent adult to whom they can refer any concerns. Students will be encouraged to say at any time what they find acceptable and unacceptable regarding the way they are approached by adults or other young people.
RECRUITMENT PROCEDURES
Procedures for staff recruitment contain appropriate student protection measures, including, wherever possible, the provision of background information and references. EFC will reject any persons who might be considered a risk to student safety.
To assist in the recruitment and screening processes EFC will require national police checks (or equivalent standard) to be conducted on all staff and volunteers, both expatriate and Cambodian. References and copies of passports and/or national identity cards will need to be supplied, and referees will be contacted for verbal confirmation of the applicant’s character.
Behavioral-based interviews will be conducted with all applicants applying for positions. All staff, contractors and associates will be required to immediately disclose all charges, convictions and any other outcomes of an offense which occurred before or occurs during their association with EFC that relate to student exploitation and abuse.
All successful candidates and existing representatives will be clearly informed of their contractual requirement to comply with this policy prior to work, and required to sign and comply with EFC’s Student Protection Policy.
TRAINING
EFC personnel are subject to training on student protection and are required to keep their knowledge up-to-date.
Designated EFC contact officers will undergo regular training to ensure that they are capable and competent to conduct the initial complaint handling and comply with the reporting processes.
The Student Protection Manager will have the role of ensuring that all staff are up-to-date with policy changes and the implementing of training regimes for all staff and students alike.
CONDUCT
All individuals are required to behave with students in a manner that fully respects their dignity and rights, and minimizes any possible situation of risk. All representatives will:
• Treat all students with respect regardless of distinguishing factors such as age, race, religion, sexuality, disability or other status.
• Not behave towards them in any manner, physical or verbal, which is or can be construed as inappropriate, harassing, abusive, provocative or demeaning.
• Not engage students in any form of sexual activity or acts, including paying for sexual services or acts, where under relevant legislation the student is below the age of consent or the act(s) constitute an offense.
• Wherever possible, ensure that another adult is present when working in the proximity of students.
• Not invite unaccompanied students into their home, unless they are at immediate risk.
• Will take seriously any complaint of student abuse from whatever source, and will report any known breach of the Student Protection Policy, the Student Protection Code of Conduct, or any concerns relating to the safety of the students to EFC.
• Use any communications or recording technology or social media appropriately; never exploit, harass or put students at risk through the use of such technology; or access child pornography via any medium or from any source.
• Not use physical punishment as a disciplinary tool.
• Not employ students for domestic or other work inappropriate to their age or developmental stage, or which interferes with access to education or recreation or which places them at risk of injury.
• Comply with all relevant laws.
• Report concerns or allegations of student abuse as quickly as possible, as set down in relevant procedures.
• Ensure that adults or personnel who are not permanent approved staff have regular EFC staff present when in contact with students, do not take students out of EFC facilities without EFC staff present, or make independent contact with students’ families.
EFC will always ensure that information or images about students are never used in a way that places students at risk, or compromises their safety or dignity. Regulations governing the use of photography and videos are in place as part of the student protection procedures.
COMMUNICATION AND USE OF STUDENT IMAGES
EFC will at all times portray students in a respectful, appropriate and consensual way.
• A student should always be portrayed in a dignified and respectful manner and not in a vulnerable or submissive manner. Students should be adequately clothed and not in poses that could be seen as sexually suggestive.
• There should be no identifying information of the student used in the publication of images or their location.
• Students should be portrayed as part of their community.
• Local cultural traditions should be assessed regarding restrictions for reproducing personal images.
• Images should be an honest representation of the context and the facts.
• When sending images electronically, file names should not reveal identifying information.
EFC maintains strong communication links with the parents or those otherwise legally responsible for the children in its programs, and ensures that they are appropriately informed about all issues regarding the children and their welfare.
EFC respects the confidentiality of information regarding students’ health, family backgrounds and personal histories. This private information is accessed only by authorized staff on a ‘need to know’ basis.
Guidelines, rules and implementation procedures relating to student protection are available to all EFC personnel.
The Student Protection Policy and all associated policies, such as the Student Protection Code of Conduct and Student Protection Reporting Process, will be reviewed and amended as needed.
REPORTING AND RESPONSE
EFC recognizes the need to implement specific guidelines to manage the student protection risks within its programs. EFC’s guidelines in relation to sponsors and students include:
• All communications between sponsors and children are monitored by qualified EFC staff. Communications that contain inappropriate content, including cultural, political or religious material which may cause offense, are strictly prohibited.
• All visits by sponsors must be arranged in advance with appropriate EFC staff.
• All sponsors will be required to read the Student Protection Policy.
• Supervised outings from EFC facilities may be permitted for students of a suitable age.
• Qualified EFC staff will be present at all times during a sponsor visits and during authorized outings.
• Sponsors and sponsored children and their families must not exchange contact details during visits.
• Students must not be invited to leave or be taken away from their communities.
In the event of any incidents, comments, suspicions or concerns, the case must be immediately reported to senior management and an investigation commenced. All cases of abuse will be investigated thoroughly in line with established procedures. When responding to concerns or allegations of harm or abuse, the ultimate guiding principle will be the best interests and well-being of the student or students involved.
A student reporting concerns or claiming to be the subject of abuse will be protected, taken seriously, and treated with respect. He or she will be reassured that they are not to blame – he or she will never be treated with disbelief or in a manner that might cause shame or embarrassment. EFC will immediately remove a student from an abusive environment, seek medical treatment for any injuries and make any necessary further referrals.
In the event of an allegation made in good faith, which is shown to be unfounded or untrue, no action will be taken against the maker of the allegation. False and malicious allegations are unacceptable and perpetrators will be subject to appropriate action. Failure of an EFC representative to report suspected student abuse will render the representative liable to criminal penalties and/or termination of employment.
All EFC staff and will be made aware of the Student Abuse Reporting Process. The Student Protection Manager will be responsible for the investigation of all initial complaints and will make an assessment on the allegation and take appropriate action, which can range from no-action, behavioral management, counseling, referring the complaint to local law enforcement/police, and dismissal from EFC.