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Safeguarding Policy

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In the UK, safeguarding means protecting peoples’ health, wellbeing, and human rights, and enabling them to live free from harm, abuse, and neglect. At Galapagos Conservation Trust (GCT), we understand it to mean protecting people, including children and at-risk adults, from harm that arises from coming into contact with our staff or programmes.

Purpose of this Policy

The purpose of this policy is to protect people, particularly children, at-risk adults and beneficiaries of assistance, from any harm that may be caused due to their coming into contact with GCT. This includes harm arising from:

  • The conduct of staff or personnel associated with GCT (including contractors and volunteers)
  • The design and implementation of GCT’s programmes and activities

This policy lays out the commitments made by GCT and the responsibilities of staff and associated personnel in relation to safeguarding.


GCT personnel
Any person who is working for GCT (either paid or unpaid) including staff, volunteers, Trustees and contractors.

Measures to protect the health, well-being and human rights of individuals, which allow people, especially children, young people and vulnerable adults, to live free from abuse, harm and neglect.


  • All staff contracted by GCT
  • Associated personnel whilst engaged with work or visits related to GCT, including but not limited to the following: Trustees; ambassadors; consultants; volunteers; contractors; programme visitors including journalists, celebrities and politicians

GCT complies with all the legal obligations placed upon it by the Safeguarding Vulnerable Groups Act 2006 (England and Wales) and the Protection of Vulnerable Groups (Scotland) Act 2007 (Scotland).

GCT’s commitment

GCT believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect and exploitation. GCT will not tolerate abuse and exploitation by staff or associated personnel. GCT also requires its partner organisations to also have a zero-tolerance policy to any behaviour which may harm others, including GCT staff or volunteers, or other people they are in contact with (e.g. local communities or visitors to Galapagos).

GCT commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.


GCT responsibilities

GCT will:

  • Ensure all GCT personnel have access to, are familiar with, and know their responsibilities within this policy
  • Ensure all GCT personnel are vigilant and on the lookout for anything that may constitute as abusive behaviour
  • Design and undertake all its programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with GCT. This includes the way in which information about individuals in our programmes is gathered and communicated
  • When working with partner organisations, ensure those organisations are aware of GCT’s safeguarding policy including who to contact if they have a concern and have their own safeguarding policy and procedures
  • Implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel
  • Ensure GCT personnel receive training on safeguarding at a level commensurate with their role in the organisation
  • Follow up on reports of safeguarding concerns promptly and according to due process
  • Annually review all of its policies including our safeguarding policy

Staff responsibilities

Child safeguarding

GCT staff and associated personnel must not:

  • Engage in sexual activity with anyone under the age of 18
  • Sexually abuse or exploit children
  • Subject a child to physical, emotional or psychological abuse, or neglect
  • Engage in any commercially exploitative activities with children including child labour or trafficking

Adult safeguarding

  • GCT staff and associated personnel must not:
  • Sexually abuse or exploit at-risk adults
  • Subject an at-risk adult to physical, emotional or psychological abuse, or neglect

Protection from sexual exploitation and abuse

GCT staff and associated personnel must not:

  • Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance
  • Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics

Additionally, GCT staff and associated personnel are obliged to:

  • Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy
  • Report any concerns or suspicions regarding safeguarding violations by an GCT staff member or associated personnel to the appropriate staff member

Enabling reports

GCT will ensure all staff and volunteers are adequately trained in understanding, recognising and reporting safeguarding breaches. All staff should be made aware of this policy and how to go about making a report.

GCT will treat all complaints, allegations, or suspicions of abuse with the utmost seriousness. GCT will investigate all concerns and issues raised in a confidential, serious, and timely manner. Safeguarding issues or concerns can be raised by anyone in contact with GCT or our projects, including staff, volunteers, Trustees, project partners, contractors and members of the public.

Any staff reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by GCT’s Whistleblowing Policy.

GCT will also accept complaints from external sources such as members of the public, partners and official bodies.

How to report a safeguarding concern

GCT personnel who have a complaint or concern relating to safeguarding should report it immediately to their Safeguarding Focal Point [as appropriate] or line manager. The Safeguarding Focal Point or line manager will need to be informed of the names of the people involved (if known), what type of abuse is or may be occurring, and the dates and times this occurred (if known). An official written report of the alleged act may be requested at this stage as part of the evidence gathering procedure.

If the staff member does not feel comfortable reporting to their Safeguarding Focal Point or line manager (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to any other appropriate staff member or Trustee. For example, this could be a senior manager or a member of the HR Team.

Staff members may be asked to refrain from discussing alleged abuse with fellow colleagues, other than those specified by their Safeguarding Focal Point or line manager, to avoid the spread of potentially harmful misinformation and to protect the validity of any investigation.

Members of the public or those external to GCT who have a complaint or concern regarding safeguarding should report it either via the complaints process as detailed on our website or by contacting GCT’s safeguarding focal point or designated Trustee (contact details below).

Safeguarding Focal Point Contact Details

Head of Finance, Claire McKinley
Telephone: (+44) 207 399 7440
Email: [email protected]

Designated Trustee:
Marta Tufet
Email: [email protected]


GCT will follow up safeguarding reports and concerns (including those reported by grantees) according to policy and procedure, and legal and statutory obligations. GCT will ensure that concerns raised about staff are acted upon in an appropriate, proportionate, and sensitive manner. GCT will apply appropriate disciplinary measures to staff found in breach of policy.

GCT may be under a duty to disclose allegations of abuse to the Disclosure and Barring Service or Disclosure Scotland as appropriate. GCT may also consider it necessary to inform the police of allegations under investigation.

GCT will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation). Decisions regarding support will be led by the survivor.


It is essential that confidentiality in maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management should be shared on a need-to-know basis only and should be kept secure at all times. Any paper files should be kept by the Head of Finance in a locked cabinet.

For further information around safeguarding including more advice visit:

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