1. Policy Statement

1. The purpose of this policy is to establish a framework for protecting children, adults at risk, beneficiaries, staff, volunteers, and community members from harm, ensuring a safe and respectful environment across all organizational activities and operations when working for, on behalf of, or in partnership with GCC.
2. GCC adopts a zero-tolerance approach towards all forms of abuse, exploitation, neglect, harassment, discrimination, retaliation, and any safeguarding breach. Every allegation shall be treated seriously, investigated fairly, and addressed promptly, irrespective of the status, seniority, or relationship of the alleged perpetrator to the Organization.
3. This encompasses assisting GCC to develop a mutual understanding of safeguarding issues and best practice across the diverse and complex areas in which we operate, thereby increasing accountability in this crucial aspect of our work.
4. Every Board member, employee, volunteer, consultant, intern, contractor, partner, donor representative, researcher, visitor and any other individual acting on behalf of GCC shall receive this Policy prior to engagement and shall sign a Safeguarding Declaration confirming that they have read, understood and undertake to comply with its provisions.
5. Any breach of this Policy shall constitute misconduct and may result in disciplinary action up to and including dismissal, termination of contracts, withdrawal of volunteer status, referral to professional regulatory bodies, reporting to statutory authorities and/or criminal prosecution where applicable.
6. This Policy shall be reviewed at least once every two years or earlier where there are legislative changes, significant safeguarding incidents, organizational restructuring or recommendations arising from safeguarding audits.

2. Definition of Key Terms

This list contains the working definitions of terms essential to the effective implementation of this policy. However, GCC is alive to the fact that this is not a comprehensive list and as such shall be updated as the need arises. These key terms include the following:

1. Safeguarding: The responsibility that an organization has to ensure that their employees and volunteers, partners, vendors, operations and programmes do no harm to individuals; do not expose them to the risk of discrimination, neglect, harm, exploitation and abuse; and that any concerns the organization has about the safety of individuals within the communities in which they work, are dealt with and reported to the appropriate authorities. It is also the responsibility of the organization to protect its employees and volunteers when they are vulnerable, for example, when ill or at risk of harm or abuse.
2. Vulnerable Adults/ Adults at Risk: In the context of this policy, a vulnerable adult (also referred to as an adult at risk) is any person aged 18 or over who, due to age, disability, mental or physical health conditions, economic capacity, displacement, or other circumstances, may be unable to protect themselves from abuse, neglect, or exploitation. Some of the individuals engaged by/with GCC live in low-income settings and may experience intersecting vulnerabilities. This includes, but is not limited to persons with disabilities, mental or physical health challenges, individuals facing economic hardship and adults who are socially excluded or lack support networks. GCC recognizes that vulnerability is not always visible or permanent. Anyone may be at risk depending on their situation, and as such, our safeguarding practices will be inclusive, respectful, and responsive to all community members, with special attention to those most at risk.
3. Best Interest of the Child: All decisions affecting children shall prioritize the child's best interests in accordance with Article 53(2) of the Constitution of Kenya and the Children Act, 2022.
4. Child Abuse: This includes physical abuse, emotional abuse, sexual abuse and neglect.

3. Relevant Laws and Legislation

1. At the international level: Article 19 of the United Nations Convention on the Rights of the Child requires that:
   1. States Parties shall take all appropriate legislative, administrative, social and educational measures to protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s) or any other person who has the care of the child.
   2. Such protective measures should, as appropriate, include effective procedures for the establishment of social programmes to provide necessary support for the child and for those who have the care of the child, as well as for other forms of prevention and for identification, reporting, referral, investigation, treatment and follow-up of instances of child maltreatment described heretofore, and, as appropriate, for judicial involvement.
2. At the regional level: African Charter on the Rights and Welfare of the Child which provides for:
   1. Protection against harmful traditional practices, such as early marriage and female genital mutilation (Article 21).
   2. Protection from sexual exploitation (Article 27).
   3. Protection against drug abuse (Article 28).
3. At the national level: The Constitution of Kenya 2010, which provides for:
   1. Protection of children from abuse, neglect, harmful cultural practices, all forms of violence, inhuman treatment and punishment, and hazardous or exploitative labor (Article 53).
   2. Other relevant legislation includes:
      1. The Children Act of 2022 which serves as a foundational umbrella policy instrument on child protection and child welfare services.
      2. The Sexual Offences Act of 2006 which makes provision to protect children at risk of sexual abuse, from being subjected to sexual abuse or having to witness sexual acts. It also prescribes stiffer penalties for sexual offenders especially for the offence of defilement depending on the complainant's age.
      3. The HIV/AIDS Prevention and Control Act of 2006 which provides that no educational institution shall deny admission or expel, discipline, segregate, deny participation in any event or activity, or deny any benefits or services to a person/child on the grounds only of the person's actual, perceived or suspected HIV status.
      4. The Employment Act of 2007 which declares and defines the fundamental rights of employees, provides for basic conditions of employment of children, and to provide for matters connected with the foregoing.
      5. The Counter Trafficking in Persons Act of 2010 which criminalizes acts that promote child trafficking including adopting, fostering or guardianship or offering a child for adoption, fostering or guardianship for purposes of trafficking.
      6. The Penal Code which protects children from acts and omissions, which amount to child abuse, including assault, abduction, kidnapping, abortion, etc and prescribe a penalty against any person found guilty of such offences.
      7. Others include: the National Children Policy (2010); the National Policy for Prevention and Response to Gender Based Violence (2014); the National Plan of Action for Children in Kenya (2015-2022); and the National Policy for the Eradication of Female Genital Mutilation (2019), among others.

4. Scope

1. This policy covers all staff, trustees, contractors, board of directors, employees, volunteers, volunteers of sub-contractors, agency workers, consultants, donors, partners, interns, and all visitors to GCC's work programmes and offices.
2. This Policy applies equally to all physical premises, community outreach programmes, online platforms, virtual meetings, social media engagement, mobile communications and any environment where GCC activities are conducted.
3. This policy demonstrates how GCC will meet its legal obligations and assures volunteers, employees, partners and members of the public of the following:
   1. GCC prioritizes all safeguarding concerns.
   2. Any person can safely voice any safeguarding concerns through the procedures established in this policy.
   3. All reports of abuse or potential abuse are dealt with seriously and effectively.
   4. An efficient recording and monitoring system is in place.
   5. All employees, volunteers, consultants, subcontracted agencies and partners receive appropriate induction on and commit to safeguarding.
   6. GCC shall adopt a risk-based recruitment process. Individuals whose roles involve direct or frequent interaction with children or adults at risk shall undergo enhanced safeguarding vetting, including blacklisting or criminal background checks (where lawful), identity verification, reference checks, and other measures deemed necessary. All persons will sign an employment contract that includes safeguarding, confidentiality, reporting obligation, disciplinary consequences and consent to investigation clauses before interacting with GCC beneficiaries, community members, and children.
   7. GCC's management team will keep abreast with current standards through ongoing, appropriate training and development.
4. All employees of GCC must:
   1. Read, understand, and adhere to this policy.
   2. Strive to promote a zero-tolerance approach to discrimination, sexual harassment, exploitation, and abuse of beneficiaries, staff, and members of the community in all working environments.
   3. Place the safety and welfare of beneficiaries, staff, and members of the community above all other considerations.
   4. Report any concerns they may have about the conduct of a GCC representative in relation to safeguarding.
   5. Ensure appropriate supervision and monitoring of all staff and partners.

5. Action Statement

GCC is committed to creating and maintaining a safe, respectful, and inclusive environment for all individuals we engage with, children, adults at risk, persons with disabilities, staff, volunteers, partners, beneficiaries, and donors. We believe safeguarding is everyone's responsibility and central to our mission, operations, and values.

GCC will:

1. Develop, implement, monitor, and regularly review comprehensive safeguarding policies and practices that protect the rights and well-being of all, especially those at increased risk of harm, including children and adults at risk.
2. Screen and provide orientation information to all individuals and groups visiting GCC projects, including but not limited to Board members, sponsors, supporters, donors, volunteers and any staff.
3. Be vigilant in protecting confidential information about beneficiaries in GCC projects and programs.
4. Appoint a staff or member of the Board to be the custodian of this policy, hereafter referred to as the Safeguarding Lead.
5. Provide advice, support and training on safeguarding to all employees:
   1. What they should do in the event of a disclosure.
   2. What to do if they have concerns about the welfare of a child.
   3. How to recognize signs of abuse.
   4. What to do if they have safeguarding concerns about a GCC employee, volunteer, or employee of a partner organization.
   5. Where to go for advice and support within the organization and other legal institutions.

   Training shall be mandatory upon recruitment and thereafter conducted at least annually or whenever significant amendments are made to this Policy.

6. Provide the necessary documentation to give full effect to this policy as outlined below.

6. Guiding Principles

1. In implementing this policy, GCC will be guided by the following principles:
   1. Do No Harm Principle: The organization is committed to the Do No Harm principle, ensuring that all activities, interventions, and interactions are designed and implemented in ways that avoid causing harm to individuals or communities, whether directly or indirectly. This includes being mindful of power dynamics, cultural sensitivities, and the potential unintended consequences of our actions.
   2. Equality and Inclusion: GCC shall ensure that every individual enjoys equal protection irrespective of age, sex, gender, pregnancy, marital status, disability, health status, ethnic or social origin, colour, race, religion, conscience, belief, culture, language, birth, nationality, migration status, sexual orientation, gender identity, socio-economic status or any other protected characteristic recognized by law.
   3. Confidentiality: GCC will abide by the provisions of the Data Protection Act, 2019 in handling personal data. All safeguarding reports shall be treated with utmost confidentiality, respecting the privacy and dignity of those involved. GCC shall maintain confidentiality throughout the safeguarding process. However, confidentiality shall not prevent GCC from sharing information with law enforcement agencies, child protection authorities, courts, medical professionals or other competent authorities where disclosure is necessary to protect an individual from harm, comply with legal obligations or facilitate investigations.
   4. Consent: GCC is committed to obtaining informed consent before collecting, sharing, or acting upon any personal or sensitive information. Consent must be voluntary, informed, and given by someone with the capacity to do so. Special care will be taken when working with children or vulnerable adults, including obtaining consent from the individual and consent from a parent, guardian, or legal representative, as appropriate.
   5. Cultural sensitivity: GCC recognizes that there are many different ways of thinking. As such, GCC commits to work in ways that are culturally sensitive and that respect the diverse nature of the people we work with.
   6. Best Interests of the Child: In every safeguarding decision affecting a child, GCC shall treat the best interests of the child as the primary consideration in accordance with Article 53(2) of the Constitution of Kenya and the Children Act, 2022.
   7. Survivor-Centered Approach: GCC shall adopt a survivor-centered approach to safeguarding by ensuring that all responses prioritize the dignity, safety, wellbeing, privacy, informed choice, and recovery of survivors while minimizing the risk of re-traumatization.
   8. Accountability: Every employee, volunteer, Board member, consultant, partner and contractor is individually responsible for safeguarding and shall be held accountable for complying with this Policy.
   9. Shared Responsibility: Safeguarding is everyone's responsibility. Every person engaged by GCC has a duty to identify, prevent and report safeguarding concerns.
   10. Continuous Learning: GCC shall continuously review safeguarding incidents, lessons learnt, emerging risks and international best practices to improve safeguarding systems.

Duties of the Safeguarding Lead

The Safeguarding Lead shall:

1. oversee implementation of this Policy;
2. receive safeguarding reports;
3. coordinate investigations;
4. maintain the safeguarding register;
5. liaise with statutory authorities;
6. coordinate safeguarding training;
7. advise the management / Board on safeguarding risks;
8. monitor implementation of safeguarding action plans;
9. prepare quarterly safeguarding reports;
10. maintain confidential safeguarding records.

8. Safeguarding Risk Assessment

Prior to commencing any programme, project, event, outreach activity or partnership, GCC shall conduct a safeguarding risk assessment to identify potential safeguarding risks and establish mitigation measures. Risk assessments shall be reviewed periodically throughout project implementation.

GCC shall maintain a Safeguarding Risk Register documenting identified safeguarding risks, risk ratings, mitigation measures, responsible officers, review dates and residual risks. The Register shall be reviewed at least quarterly by Senior Management and annually by the Board.

Partner Due Diligence

Before entering into partnerships, GCC shall undertake safeguarding due diligence on partner organizations to assess their safeguarding policies, reporting mechanisms, governance structures and safeguarding capacity.

Electronic Communication

GCC recognizes that safeguarding extends to digital environments. All online interactions with beneficiaries shall be conducted through approved communication platforms. Staff shall not communicate privately with children through personal social media accounts or messaging applications unless expressly authorized, documented and subject to appropriate safeguards.

Employees shall use only GCC-approved communication channels when communicating with children and beneficiaries. Personal social media accounts shall not be used to establish private relationships with beneficiaries unless expressly authorized and subject to safeguarding controls.

Gifts

Employees shall not provide gifts, money or personal assistance to beneficiaries outside approved programme activities without prior written approval.

Alcohol and Drugs

Employees shall not consume alcohol or illegal substances while supervising children or adults at risk or while undertaking safeguarding-related responsibilities.

Social Media

Employees shall not post photographs, names, locations or identifying information relating to beneficiaries on personal social media accounts.

Duty to Intervene

Every employee has a duty to intervene safely, where reasonably possible, or immediately report conduct that places a child or adult at risk of harm.

9. Code of Conduct

All employees of GCC are required to observe and abide by the following where children and vulnerable adults are concerned:

1. Maintain professional boundaries and foster respectful, safe, and supportive relationships with all individuals, especially children, adults at risk, and vulnerable groups—based on openness, honesty, and mutual respect.
2. Employees, volunteers, consultants and partners shall avoid situations that may create actual, perceived or potential conflicts of interest or compromise professional boundaries. Any unavoidable one-on-one interaction with a child or adult at risk shall, where reasonably practicable, occur in an open, observable environment or with another responsible adult present.
3. Every individual engaged by GCC shall treat children, adults at risk and all beneficiaries with dignity, respect and courtesy, recognising their inherent worth and promoting their participation in decisions affecting them where appropriate.
4. Strive to promote a zero-tolerance approach to discrimination, exploitation, abuse, harassment, neglect and retaliation. Every representative of GCC has an individual responsibility to prevent, identify and report safeguarding concerns. Place the safety and welfare of stakeholders above all other considerations.
5. Immediately report any safeguarding concern, allegation, disclosure, suspicion or breach of this Policy in accordance with GCC's reporting procedures.
6. Create and maintain a safe and caring environment where concerns about conduct or behavior can be raised safely, confidentially, and without fear of reprisal.
7. Sexual activity with children is prohibited. Mistaken belief regarding the age of a child is not a defence. Avoid situations in which you are alone with children. If necessary, move to a place where you can both be seen by other colleagues or other adults. This prohibition extends to online communication, electronic messaging, social media interactions and any conduct intended to groom or exploit a child.

Employees of GCC must not:

1. Engage in any form of physical, emotional, psychological or sexual abuse, exploitation, neglect, bullying, intimidation, harassment or discrimination against any child, adult at risk or beneficiary.
2. Initiate, encourage, or fail to act upon inappropriate, exploitative, or sexual relationships with any individual that is in a position of vulnerability or dependency. This prohibition applies regardless of whether the relationship appears consensual, where there exists a power imbalance arising from employment, programme participation, dependency or unequal access to resources.
3. Use inappropriate language, gestures, jokes, physical contact, digital communication or behaviour that may humiliate, shame, intimidate, exploit or place another person at risk. Agree to keep any secret shared by an individual that may pose a risk to their safety or the safety of others. Employees shall explain from the outset that confidentiality cannot be guaranteed where disclosure indicates that an individual is at risk of harm.
4. Give, display or distribute pornographic, sexually explicit, violent or otherwise inappropriate materials to children or adults at risk. Delay, conceal or intentionally fail to report safeguarding concerns.
5. Accept or exchange money, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour, promise of employment or favourable treatment. This includes exchange of assistance that is due to beneficiaries. This prohibition includes soliciting, accepting or offering gifts, favours, loans, employment opportunities or preferential treatment in exchange for sexual activity or any exploitative conduct.

Reporting Safeguarding Concerns

1. All safeguarding concerns and issues raised will be handled with the utmost confidentiality. When such concerns arise, all participants will be directed through a formal complaints process involving the GCC Board's legal advisor / appointed board member, 1 GCC management, and 1 staff member. Any individual involved in the complaint or who has an actual, perceived or potential conflict of interest shall immediately recuse themselves from participating in the investigation or decision-making process. Where necessary, GCC may appoint an independent external panelist.
2. Information relating to safeguarding concerns shall only be shared on a strict "need-to-know" basis. Unauthorized disclosure of safeguarding information shall constitute misconduct.
3. No person shall suffer dismissal, intimidation, harassment, discrimination, victimization or any other adverse treatment for reporting a safeguarding concern in good faith or participating in an investigation. Any retaliation shall constitute gross misconduct and may result in disciplinary action.
4. GCC shall permit anonymous reporting of safeguarding concerns through any available reporting mechanism. Anonymous reports shall be assessed and investigated where sufficient information exists to support further inquiry.
5. Incidents of safeguarding may be brought to the attention of a GCC management or safeguarding focal person through numerous ways, including:
   1. Making direct disclosure about him or herself/ their child.
   2. Making direct disclosure about another person/child.
   3. Any person including a child can offer information that is worrying but not a direct disclosure.
   4. An employee of GCC can express concern about a child's appearance or behavior or about the behavior of a parent, caregiver or fellow GCC employee towards another person or child.
   5. A parent can offer information about a child that is worrying to them.
   6. An employee of GCC becoming aware of risk of harm to a child or young person during the course of their engagement with GCC's activities.
   7. Anonymous reporting through secure reporting channels.
   8. Reporting by partner organizations.
   9. Reporting by contractors.
   10. Reporting through confidential digital reporting mechanisms established by GCC.
6. Reports shall be made immediately to the Team Leader, Safeguarding Lead or any designated safeguarding focal person. Where the allegation concerns the Team Leader, Safeguarding Lead, Board member or senior management, the report shall be submitted directly to the Chairperson of the Board or another independent Board member designated for safeguarding oversight.
7. Any person/child who reports an incident must be taken seriously and listened to carefully. The person receiving the concern should:
   1. Stay calm, listen to what they say without prejudice, and accept what they say without judgment.
   2. Reassure the child that telling someone about it was the right thing to do.
   3. Let the person/child know the steps that will be taken to address the concern.
   4. Explain the duty to keep them and everyone safe. Therefore, if someone is being hurt or is in danger, then action must be taken. Thank them for sharing this information with you and explain that they can trust you to honor and respect them in the process.
   5. Avoid asking leading questions or conducting investigations at the point of disclosure. The responsibility of the first recipient is to receive, reassure, record and report.

GCC shall ensure that emergency medical, psychosocial and legal support services are considered immediately following disclosure where appropriate.

If the person/child:

1. Is in immediate danger and is with you, remain with him/her and call GCC line GCC office line/email 0790510707 / giftedcommunitypwd@hotmail.com, the police on 999, Wangu Kanja 1519, COVAW 0722-594794, Childline or relevant institution.
2. Alternatively, contact the police and explain the situation to them.
3. Needs emergency medical attention, call an ambulance and, while you are waiting for it to arrive, get help from your first aider.
4. If the first aider is not available, use any first aid knowledge that you may have yourself to help the child.
5. You also need to contact your supervisor/manager or designated safeguarding officer to let them know what is happening.

8. If you witness/suspect an employee of GCC of abuse or exploitation:
   1. Do not question your instincts or think 'What if I am wrong?' — think 'What if I am right?'
   2. Document the incident ensuring you capture as much detail as possible.
   3. Voice your concern with your line manager, Team Leader or Safeguarding Lead as soon as possible.
   4. See the steps below for reference.
   5. Employees are not required to possess evidence before making a safeguarding report. A reasonable suspicion is sufficient.
   1. GCC employee witnesses/ has concerns about a child's safety or welfare.
   2. Said employee formally documents it capturing as much detail as possible.
   3. Said employee raises these concerns with the Team Leader who must also involve the Safeguarding Lead.
9. Where an incident is alleged to have occurred, the alleged perpetrator is immediately prohibited from any contact with the child until the matter is resolved. Such precautionary measures shall not constitute a finding of guilt but are intended solely to protect affected individuals and preserve the integrity of investigations.
10. As soon as possible (and no longer than 24 hours after the disclosure of the incident) the person receiving the disclosure will fully document the allegation, including the time, place and witnesses to the incident. Documentation shall distinguish clearly between facts, observations, disclosures and professional opinions.
11. Once the incident is reported, the following processes shall be initiated:
    1. Complaint Received – The complaint must be acknowledged within 24 hours of its filing. The Team Leader must constitute a committee to discuss the allegations which must include the Safeguarding Lead and any other member appointed by the Team Leader.
    2. The Committee Convenes (within 48 hours) – The Committee must ensure the confidentiality of the complainant is protected. Assess and manage any immediate security risk or concerns. Engage the Legal Lead. Inform internal and external stakeholders as is necessary. Take a decision on whether the investigation can be carried out internally. Where need be, the Committee shall involve the relevant authorities.
    3. Investigations – The Committee must conduct and finalise investigations within 4 weeks. In this period, it shall conduct interviews, gather any available evidence and produce a report.
    4. Within 72 hours of finalising its report, the Committee shall inform the complainant, subject of complaint and the Board of its findings and decision.
    5. The Committee shall document lessons learned for future reference.
12. If allegations are levelled against an employee, volunteer, partner or consultant of GCC, the organization shall:
    1. Inform the respective person/alleged perpetrator as soon as possible.
    2. Direct the respective employee to take a leave of absence during the period of investigation and for volunteers/consultants/contractors/partners to cease their service until further notice.
    3. Direct the respective person not to make any contact with the victim or try to interfere/influence the investigations in any way.
    4. Conduct a thorough investigation into the allegations and where necessary, shall involve the relevant authorities.
13. If an allegation is made of an employee of GCC, specialist advisor, volunteer, supporter, staff member or someone else representing GCC, the incident must be reported to the GCC management team and confirmed in writing. Where legally required or contractually necessary, GCC shall notify relevant regulators, donors, partner organizations and statutory authorities, taking into account confidentiality, legal obligations and the best interests of affected persons.
14. Any individual directly affected by the outcome of a safeguarding investigation may request a review of the decision within fourteen (14) days where:
    • new evidence exists;
    • procedural irregularity occurred;
    • bias is alleged;
    • or the decision is manifestly unreasonable.

    The review shall be undertaken by an independent reviewer appointed by the Board.

9. Survivor Support

GCC shall adopt a survivor-centered response. Depending on the circumstances, support may include:

1. emergency medical treatment;
2. psychosocial counselling;
3. trauma-informed care;
4. referral to legal services;
5. referral to child protection agencies;
6. temporary protection measures;
7. reasonable workplace adjustments;
8. disability support services;
9. interpreter services where required;
10. follow-up welfare monitoring.

10. Safeguarding Register

GCC shall maintain a confidential Safeguarding Register recording:

• Case Number
• Date Reported
• Category of Incident
• Immediate Protective Measures
• Investigation Status
• Outcome
• Referrals Made
• Disciplinary Action
• Lessons Learned
• Date Closed
• Officer Responsible

Internal safeguarding investigations shall determine findings on the balance of probabilities and shall not require proof beyond reasonable doubt.

Every employee, volunteer, consultant and partner shall cooperate fully with safeguarding investigations.

Safeguarding investigation records shall be securely retained in accordance with GCC's Data Protection Policy.

Upon closure of every safeguarding case, GCC shall conduct a lessons-learned review to identify systemic weaknesses and strengthen safeguarding measures.

Administrative leave shall not be construed as disciplinary action or a presumption of guilt.

GCC recognizes that safeguarding concerns should always be encouraged. However, where an investigation establishes that a complaint was knowingly false, malicious or made in bad faith, appropriate disciplinary action may be taken. A complaint that is made in good faith shall not attract disciplinary action merely because it is unsubstantiated.

ANNEXES

11. Necessary documentation

1. Code of Conduct

               CODE OF CONDUCT AGREEMENT
   
               I have read, understood and agree to abide by GCC's Code of Conduct
   
               Name: ______________________
               Role: _______________________
               Signature: __________________
               Date: _______________________
                                                           

2. Safeguarding Incident Reporting Form (Part 1 & Part 2 as per policy document)
3. Consent form

               I ............................................. grant Gifted Community Center-GCC and its partners permission and consent to use my photos, stories, feedback, videos, and any reproductions or adaptations of the images on their social media platforms, website, or any other medium they may deem essential for the visibility of their work.
   
               By signing below, you agree to all the above terms.
   
               Name: ______________________
               Signature: __________________
               Date: _______________________
                                                           

GIFTED COMMUNITY CENTER (GCC) – CONFIDENTIAL SAFEGUARDING INCIDENT REGISTER

Full register tables (Case Information, Person Making the Report, Survivor Details, Alleged Perpetrator, Incident Information, Risk Assessment, Investigation Management, Referrals, Outcome, Disciplinary Action, Survivor Support, Lessons Learned, Case Closure, Authorization) are maintained in the official policy document.

GIFTED COMMUNITY CENTER (GCC) – SAFEGUARDING RISK ASSESSMENT FORM

Full form with Activity Details, Safeguarding Risk Assessment table, Overall Risk Assessment, Additional Measures, and Approval section is maintained in the official policy document.

GIFTED COMMUNITY CENTER (GCC) – PARTNER SAFEGUARDING DUE DILIGENCE CHECKLIST

Full checklist with Partner Information, 15 due diligence questions, Documents Reviewed, Overall Assessment, Recommendations, Decision, and Approval is maintained in the official policy document.

Policy Approval

Adopted and signed on August 01, 2026, during GCC's board meeting.

Chairperson     Secretary     Treasurer