Safeguarding Policy

This policy has been prepared and approved to provide a framework for safeguarding and promoting the welfare of young people and vulnerable adults at PureGym.

The Safeguarding Policy applies to all team members across PureGym UK, as well as our members, and other third parties that use or operate in our UK facilities.

This policy serves as an extension of our Safeguarding Policy Statement, and provides additional guidance on defining, identifying, and reporting possible abuse, and has been developed with reference to the Safeguarding Children and Adult Boards as well as procedures, Acts, and guidance issued by relevant bodies and groups.

Related policies and procedures which all staff should be aware of, and are accessible via Connect are:

• PureGym Code of Conduct

• Hiring Policy

• Mental Health Awareness Policy

• Anti-Bullying and Harassment Policy

• Modern Slavery and Human Trafficking Policy

• Grievance Policy

• Disciplinary Policy

• Whistleblowing Policy

• Data Protection and Privacy Policy

• IT Security Policy

Caring for our people and keeping them safe is at the heart of our culture, and it’s an important legal duty that we do the right thing to help those team members and members who may be at risk of harm, by reporting allegations and incidents when young people and vulnerable adults are involved.

The Designated Safeguarding Leads (‘DSLs’) have a legal and moral duty to refer allegations and incidents of abuse to external agencies when appropriate. Please refer to page 2 of this policy to see who our DSLs are at PureGym.

Ultimate responsibility for the overall governance and implementation of this policy sits with the Executive team who are fully committed to this policy and its implementation.

A child or young person is legally defined as any person who is under the age of 18 years old.

The broad definition of a ‘vulnerable adult’ is an individual over the age of 18 that may be vulnerable permanently or temporarily, due to having a mental illness, physical or learning disability, being dependent on drugs or alcohol or being at risk of exploitation or radicalisation.

Safeguarding incidents are distinct from other sorts of concerns. To constitute a safeguarding incident it must relate to a child, young person or vulnerable adult and there must be an allegation of abuse, or suspected or actual evidence of abuse (which can be to themselves or to others).

There are different types of abuse:

• Physical abuse- this may be done deliberately or recklessly or be the result of deliberate failure to prevent injury occurring

• Sexual abuse - this involves forcing or enticing a child or vulnerable adult to watch or take part in sexual activities whether or not they are aware of what is happening

• Emotional abuse - this occurs where there is persistent emotional mistreatment which causes a severe and persistent negative effect on a person's emotional wellbeing. It causes severe and adverse effects on their behaviour and emotional development, resulting in low self-worth

• Financial abuse - this usually relates to theft or misuse of a young person or vulnerable person's money

• Neglect - this is the persistent or severe failure to meet a person's basic physical and/or psychological needs. It is likely to result in serious impairment of their health or development

There are other specific issues that have become critical issues in Safeguarding, and below are some of the current key concerns:

• Sexting

• Child sex exploitation

• Domestic violence

• Drugs

• Fabricated or induced illness

• Faith abuse

• Forced marriage

• Honour-based violence

• Gangs and youth violence

• Gender-based violence/violence against women and girls

• Radicalisation

• Teenage relationship abuse

• Trafficking

• Psychoactive Substances

At The PureGym Group we are committed to ensuring we provide a safe environment and that we identify young or vulnerable adults who are at risk of, or experiencing, significant harm. We are also committed to the safeguarding of our younger members aged below 18 years old.

The first point of contact if you have a safeguarding concern or issue is contacting the Hub team via our dedicated safeguarding inbox: [email protected]. All safeguarding concerns need to be reported via the safeguarding reporting form available via Connect under the Library section. This form will automatically be sent through to [email protected].

Each safeguarding issue or concern is flagged as low, medium, or high risk depending on the nature of the concern.

All safeguarding concerns received are flagged and a Service Level Agreement (SLA) for response to the submitted reporting form is two hours from opening for medium, and high risk concerns and 24 hours for low risk concerns. All high risk concerns are escalated to a Designated Safeguarding Lead (DSL).

There are five Designated Safeguarding Leads at PureGym. These are:

• Becky Prifti - Central People Director

• Claire Williams - Head of ER & Reward

• George Pickstock - Employee Relations Partner

• Lisa Sandys - Head of People UK

• Louise Anderton - Gym Operations People Director

Our Designated Safeguarding Leads will review our Safeguarding Policy and procedures at least twice yearly so that they continue to be effective in raising awareness of safeguarding issues, helping with the identification of potential safeguarding risks and setting out clear processes to deal with concerns. The DSLs will also meet at least twice yearly to discuss and check how well safeguarding duties are being discharged and will review current reported concerns along with actions taken/needed.

The Hub Advisors, ER Partner, HRBPs and the Designated Safeguarding Leads will complete appropriate safeguarding training to equip them to make decisions on when to refer a safeguarding matter internally, or to the appropriate external agency, and how to do this correctly. They also participate in training updates and share general safeguarding knowledge as a group and with all team members across The PureGym Group, to raise and maintain awareness.

They are responsible for:

• Overseeing the referral of cases of suspected abuse or allegations to any external agencies including but not limited to; services access team, Child Protection Officer of the local police, local police, and safeguarding boards, as appropriate

• Providing support and advice to other team members on issues relating to child or vulnerable adult protections, and Safeguarding including the Prevent duty

• Ensure appropriate full records are maintained and stored appropriately, for any child protection or Safeguarding concern (even when that concern does not lead to an external referral)

• Ensuring that the relevant team members are receiving training in safeguarding issues and are aware of PureGym's Safeguarding procedures (refresher training to be completed every 2-3 years)

• Report any deficiencies in policy, procedures, or training provision to the Senior Leadership Team without delay

They are responsible for:

• Completion of all relevant safeguarding internal training to ensure they maintain knowledge of company safeguarding processes and procedures

• Giving appropriate advice and guidance to team members when contacting them that may raise potential safeguarding concerns

• Completion of detailed notes on the case management system, appropriately tagged for any child protection or Safeguarding complaint or concern (even when that concern does not lead to a referral) to aid reporting

• Seek clarification or guidance from relevant Employee Relations Partner and Head of ER & Reward as and when needed or appropriate

• Refer any concerns considered 'Medium' or 'High' risk to the Employee Relations Partner and/or Head of ER & Reward in the first instance

• Employee Relations Partner and/or Head of ER & Reward to link in with the relevant HR Partner for any 'Medium' risk concerns as and when deemed appropriate and HRBPs and DSLs for all 'high' risk concerns so they remain informed of any potential safeguarding concerns

All team members are in a position of trust and so a high standard of behaviour is expected.

A relationship of trust can be described as one in which one party is in a position of power or influence over the other by virtue of their work or nature of the activity being undertaken.

Team members must always maintain appropriate professional boundaries with others and avoid behaviour which might be misinterpreted by others and should always consider the following boundaries:

• Those working with young people and vulnerable adults have a responsibility to maintain public confidence in their ability to safeguard

• Where a team member aged 16 or over is in a specified position of trust with a young person it may be illegal for that person to engage in sexual activity with or in the presence of that young person or to cause or incite that young person to engage in or watch sexual activity

• No young person should live in or be invited to the home of a team member who works with them unless the reason for this has been firmly established and agreed with the parents and line manager in advance

• Occasionally a young person may develop an infatuation with a team member who works with them or is a member. If a team member becomes aware of such a situation they should discuss this with one of the DSL immediately to avoid any hurt, distress, or embarrassment on behalf of either party

• All communication between team members and young people by any means should take place within clear professional boundaries; this includes the use of technology including mobile phones, text messaging, emails, WhatsApp, and social media. Team members should not share personal information with a young person, nor should they request or respond to any personal information from a young person.

• One to one situations should be avoided at all times. One to one situations have the potential to make a young person more vulnerable to harm by those who seek to exploit their position of trust. Team members working one to one with young people may also be more vulnerable to unjust or unfounded allegations being made against them.

All team members are expected to demonstrate exemplary behaviour at all times in order to promote young people's welfare and to reduce the risk of being vulnerable to allegations. The following points are examples for team members on how to create a positive culture:

• Always work in an open environment, avoiding private, or unobserved situations

• Encourage open conversations and have no 'secrets'

• Treat all young people equally, with respect, and dignity

• Always put the welfare of young people first

• Be an excellent role model

• Give positive and constructive feedback, rather than negative criticism

• Record all safeguarding incidents as per PureGym processes

The following is never to be sanctioned by a team member. Never:

• Fail to act upon and record any allegations made by a young person or about a young person (or vulnerable adult) that are a safeguarding issue or concern

• Allow or engage in any form of inappropriate touching

• Let inappropriate language or conversations go unchallenged

• Make sexually suggestive comments or insinuations of a sexual nature, or what may wrongly be considered jokes or in fun

• Effect control over a young person or vulnerable person

All team members are responsible for reporting allegations, suspicions, and actual cases of any type of abuse involving any team members, including young or vulnerable team members:

• Report safeguarding concerns of incidents of suspected abuse to the Hub as soon as possible via the Safeguarding reporting form

• All team members should be made aware of the Safeguarding Policy and their line managers should check that they know how to report potential or actual safeguarding incidents involving themselves or others

• Complete all mandatory safeguarding training

For all team members the simple flowchart below can be followed:

We take all potential safeguarding concerns extremely seriously. If a young person or vulnerable adult tells you about possible abuse:

• Inform the individual that you must pass the information on to the Hub in line with our safeguarding processes, and that the Hub may also need to refer the allegation or incident onto a Designated Safeguarding Lead and a third party if required; however, this will be the limit of the disclosure.

• If they then decline to discuss it with you, you must still inform the Hub team

• Listen carefully and stay calm

• Do not interview them, but question normally and without pressure, in order to be sure, you understand what they are telling you

• Do not put words into their mouth or influence what they are telling you

• Make a detailed note of the date, time, place, what the team member said/did and your questions

• Be clear in your note taking and try to write down/relay information exactly as it has been told to you by the individual

• Team members should not investigate concerns or allegations themselves but should report them immediately or as soon as practically possible to the Hub

• Reconfirm that the incident will be referred to the appropriate people

• The record of the discussion must be relayed to the Hub as soon as possible via the safeguarding reporting form

The information you provide to the Hub could include the following examples:

• You notice any signs that may indicate possibility of abuse, e.g. unexplained bruises or sudden changes in behaviour

• An individual mentions to you that they are in danger at home

• An individual mentions they want to harm themselves or others

• You believe that an individual may be suffering any kind of abuse either within or outside the workplace

Where a concern is classed as 'Medium' or 'High', it will be passed onto a designated DSL who will support/investigate the allegation/concern.

Depending on the nature or seriousness of the allegation, the DSL may carry out the following:

• Contact the team member concerned and arrange a meeting with them to determine a course of action

• Where allegations are made against another team member, an investigation possibly involving them will occur. At this point, the line manager or Senior Leader will be informed of the allegation and may be involved in the process. The team member may be prevented from having contact with the person concerned and others until the investigation has been carried out and we may also consider suspension. Where abuse has been proven, the Company's disciplinary policy and procedures will apply.

• The young person or vulnerable adult will be informed of the outcome of the investigation by the DSL

• At any point throughout the investigation, other DSLs may be contacted for support or advice

• In some cases, it may be appropriate to refer the case/individual to our employee assistance service or occupational health referral process

• In some cases, the DSL may contact external support agencies immediately to report the incident or obtain advice. Such cases may include situations where the individual is deemed to be in danger.

• In all cases of safeguarding incidents, a clear record of the investigation and outcomes will be maintained by the Hub team in a separate safeguarding case tracker which stored securely

• Information will be restricted to those who have a need to know in order to protect the individual and will comply at all times with the requirements of the Data Protection Act

Information about any safeguarding concerns raised may be placed on the team member’s personnel file, along with records of any investigation evidence, outcome, any other relevant notes or other documents compiled during the process. These will be processed in accordance with our Data Protection and Privacy Policy.

Please refer to all relevant policies mentioned in this document (available on Connect > Library), as well as our Safeguarding Policy Statement for more information.

In line with safer recruitment requirements, depending on the role applied for, either a basic or enhanced Disclosure and Barring Service (DBS) check will be conducted as part of our recruitment process. Any false information provided by the applicant may lead to the position being withdrawn. Where unspent convictions relating to safeguarding and child abuse are identified within the DBS, under current legislation, PureGym will be unable to approve an appointment under the DBS and the job offer will be withdrawn.

Team members will be invited to disclose any incidents of current, outstanding convictions, that are not spent within the interview process. Team members will be asked to complete ‘self-declaration’ on an annual basis, and have a duty to inform their line manager of any changes to the self-declaration that may impact working with young or vulnerable people. We will also seek consent to conduct a Social Media check.

Further guidance is provided in the Hiring Policy.

SeeHearSpeakUp

Available to all team members to address wrongdoing concerns of any nature, SeeHearSpeakUp is our internal Whistleblowing portal. Employees can access this service via a 24-hour confidential hotline (00800 9687 4357); by emailing [email protected] or, by providing information via www.seehearspeakup.co.uk/file-a-report.

For more information, please refer to our Whistleblowing Policy.

SafeSpace

The SafeSpace team are available to support members and offer a confidential means of reporting any concerns. The SafeSpace email address ([email protected]) can be used by internal and external sources.

For more information about the above resources, please refer to the Who to Contact section on Connect.

This policy is not contractual, and we may amend it from time to time.