OUR COMMITMENT

Make-A-Wish Greece (“MAW GR”) is committed to safeguarding children and young people, always acting in their best interests to keep them safe. Our wish children and their families at Make-A-Wish Greece have the right to have their needs met in a safe, secure and friendly environment, and to have equal protection from all types of harm or abuse. We actively work to provide an environment where all children and young people, regardless of race, culture, religion, ability or sexual orientation, feel empowered to unlock their imaginations to discover their own unique wish in a world free from limitations and judgement.

Make-A-Wish Greece has zero tolerance for child abuse, and considers any form of emotional, physical, sexual abuse or neglect, as intolerable under any circumstances.

Everyone working at Make-A-Wish Greece or its affiliates is responsible for the care and protection of our wish children and for reporting information about child abuse.

This policy falls within our core value of Child Focus at Make-A-Wish.

OUR POLICY

Purpose:

The purpose of this policy is to:

Affirm the commitment of Make-A-Wish Greece to the safety and protection of children and young people and in particular our wish beneficiaries.
Facilitate the prevention of child abuse occurring within Make-A-Wish Greece, ensuring a zero tolerance policy.
Work towards an organizational culture of child safety.
Prevent child abuse within Make-A-Wish Greece.
Ensure that all persons are aware of their responsibilities for identifying possible occasions for child abuse and for establishing controls and procedures for preventing such abuse and/or detecting such abuse when it occurs.
Provide guidance to all Make-A-Wish Greece representatives as to the actions that should be taken where any abuse is suspected within or outside of the organization.
Ensure consistency in child safety practices across the organization.
Provide a clear statement to all employees and volunteers and all other representatives forbidding such abuse.
Outline the responsibilities of partners and suppliers and “wish” partners and supporters.
Provide assurance that any and all suspected abuse will be reported and fully looked into investigated.

Scope:

This policy applies to anyone who represents Make-A-Wish Greece, including employees, employee contractors, volunteers and board members. This policy applies to all Make-A-Wish Greece representatives, in all jurisdictions where Make-A-Wish Greece operates.

This policy also outlines how we work with key stakeholders with regards to child safety, including:

Partners and suppliers who provide services or support to Make-A-Wish Greece
Make-A-Wish Greece Ambassadors

Legislation, Guidance and Reference:

This Safeguarding Children & Young People Policy is to be used in conjunction with the following key Make-A-Wish Greece policies as applicable:

Child Safety Code of Conduct
Code of Ethics and Good Conduct
The UN Convention on the Rights of the Child
Individual Employment Agreements, volunteer agreements, independent contractor agreements and Directors & Officers’ Agreements
Recruitment and HR policies (especially pre-employment checks and relevant ongoing verification updates)
Health & Safety Policies
Make-A-Wish Greece Policies

Policy:

Make-A-Wish Greece is committed to promoting and protecting the best interests of children and young people involved in its programs at all times.

All children, regardless of their gender, race, religious beliefs, age, ability, sexual orientation, or family or social background, have equal rights to protection from abuse.

Child protection is a shared responsibility between Make-A-Wish, all employees, volunteers, board members, workers, contractors, associates, members and all other representatives of the Make-A-Wish Greece community. Make-A-Wish Greece will consider the opinions of the children and young people that it serves and use their opinions to develop child protection policies.

Make-A-Wish Greece supports and respects all children, employees and volunteers. Make-A-Wish Greece is committed to the cultural safety of all children, including those from culturally and/or linguistically diverse backgrounds, and to provide a safe environment for children living with disability.

If any person believes that a child is at immediate risk of abuse, they should call the appropriate emergency phone number for the applicable country or jurisdiction.

Procedures:

Board responsibilities:

The board of each Make-A-Wish Greece Affiliate has ultimate responsibility for the detection and prevention of child abuse and is responsible for ensuring appropriate and effective internal control systems are in place.
The board is also responsible for ensuring that appropriate policies and procedures and a Child Safety Code of Conduct are in place.

CEO responsibilities:

The CEO of a Make-A-Wish Greece Affiliate is responsible for:

Dealing with and investigating reports of child abuse as required.
Ensuring that all employees, employee contractors and volunteers are aware of relevant laws in each jurisdiction served by the affiliate, organizational policies and procedures and the organization’s Child Safety Code of Conduct.
Ensuring that all adults within the Make-A-Wish Greece community are aware of their obligation to report suspected abuse of a child in accordance with these policies and procedures.
Ensuring that all employees, employee contractors and volunteers are aware of their obligation to observe the Child Safety Code of Conduct.
Providing support for employees, employee contractors and volunteers in undertaking their child protection responsibilities.
Ensuring that access to training and development and emotional support (such as access to an independent counselor) is provided to employees and volunteers.
Managing inquiries, including from the media, relating to suspected child abuse.

Program managers’ responsibilities:

Promote child safety at all times, in particular to employees and volunteers within their team.
Assess the risk of child abuse within their area of control and eradicate or minimize any risk to the extent possible.
Educate employees and volunteers about the prevention and detection of child abuse and ensure that they have completed the mandatory training.
Facilitate a culture of supporting children and valuing children’s opinions.
Facilitate the reporting of any inappropriate behaviours or suspected abusive activities.
Ensure that new employees and volunteers are properly screened, have a valid police check or equivalent prior to commencing any interaction with children. Program managers should be familiar with record-keeping requirements for police checks for their own jurisdictions, and apply those requirements.
Management should be familiar with the types of abuse that might occur within their area of responsibility and be alert for any indications of such conduct.

Child Protection Officers’ responsibilities:

Make-A-Wish Greece identifies two Child Protection Officers, the Head of Program and the Wish Families coordinator.

Child protection officers must:

Understand and comply with the Make-A-Wish Greece Safeguarding Children and Young People Policy and the Child Safety Code of Conduct, including the requirement for reporting any suspected child abuse to the relevant jurisdictional child protection authority or police department.
Fully cooperate with the relevant jurisdictional child protection authority or police department in their investigation of suspected child abuse.
Report any suspicions or complaints of child abuse immediately to the CEO and to any external regulatory body such as the police.
Provide advice and support to fellow Make-A-Wish Greece representatives to assist them to comply with the relevant jurisdictional requirements and related policies and procedures.
Respond to any changes in legislation and promptly advise the CEO who will in turn advise the Board.
Act as a key contact for wish families on any matters relating to safeguarding children.
Ensure complaints are accurately and confidentially recorded as appropriate. A template is provided at the end of this document.

Make-A-Wish Greece Representatives:

All Make-A-Wish Greece representatives share the responsibility for the prevention and detection of child abuse and must:

Familiarize themselves with the relevant jurisdictional laws, the Child Safety Code of Conduct and Make-A-Wish Greece policies and procedures in relation to child protection, and comply with all requirements.
Report any reasonable belief that a child’s safety is at risk to the relevant jurisdictional authorities (such as the police and/or child protection service)
Report any suspicion that a child’s safety may be at risk immediately to a Child Protection Officer (or, if a Child Protection Officer is involved in the suspicion, to the CEO. If the CEO is involved in the suspicion, to the Chair of the Board).
Provide an environment that is supportive of the emotional and physical safety of all children and young people.
Complete all compulsory training and development.
Empower and support children to raise their concerns in accordance with child safety standards.
Value and respect the opinions of children.
Comply with all reasonable directions provided by Make-A-Wish.
Notify a Child Protection Officer if they identify a risk to Child safety or, of any procedures they believe should be put into practice to ensure risks are minimized.

Other Make-A-Wish Greece “Ambassadors” (Including partners and suppliers):

Have access to the Child Safety Code of Conduct
Are advised of the obligations of Make-A-Wish Greece as a child safe organization.

Employment of new personnel and recruitment of volunteers:

Make-A-Wish Greece undertakes a comprehensive recruitment and screening process for all new representatives, which aims to:

Promote and protect the safety of all children under the care of the organization.
Identify the safest and most suitable people who share the values of Make-A-Wish Greece and its commitment to protect children.
Prevent a person from working or volunteering at Make-A-Wish Greece if they pose a risk to children.
Make-A-Wish Greece requires all representatives to complete the organization’s recruitment and screening processes prior to commencing their engagement with Make-A-Wish. Make-A-Wish Greece will ensure that new representatives:
Obtain a clear police check prior to the commencement of employment/volunteering and at regular intervals throughout their engagement.
Successfully complete interviews as required by internal procedures, including relevant questions about their suitability to work with children.
Successfully complete reference checks as required under the Make-A-Wish Greece procedures, which include relevant questions about the candidate’s suitability to work with children.
Are provided with and trained on the Make-A-Wish Greece Values, the Code of Ethics and Good Conduct, Child Safety Code of Conduct and this Safeguarding Children and Young People policy and procedures.

Reporting:

Any Make-A-Wish Greece representative who has reasonable grounds to suspect abusive activity must immediately notify the appropriate jurisdictional child protection service or the police as required by jurisdictional legislation. They must also immediately advise the Make-A-Wish Greece Child Protection Officer about their concern.

In situations where the Child Protection Officer is suspected of involvement in the activity, or if the person having the suspicion does not believe the matter is being appropriately addressed or dealt with, the matter should be reported to an alternative Child Protection Officer if any, or to the next highest level of supervision (i.e. CEO, then Board Chair).

Make-A-Wish Greece maintains a confidential reporting culture which respects the privacy of individuals while maintaining adequate record-keeping of child safety issues. All Make-A-Wish Greece representatives have a right to report any concerns that they have of inappropriate behaviours toward children and will not suffer any professional or legal consequences provided they report “in good faith”.

These protections ensure that the report:

Cannot result in the reporter being seen as unprofessional or having breached professional ethics.
Does not make the reporter liable for any disciplinary or legal action (including in cases that are not proven).

Investigating:

If the appropriate jurisdictional child protection service or the police decide to conduct an investigation of a report made, Make-A-Wish Greece representatives must cooperate fully with the investigation.

Make-A-Wish Greece commits to taking action immediately following the receipt of a complaint and will ensure the appropriate representatives actively participate in the investigation process and follow-up with the appropriate jurisdictional regulatory bodies to ensure that the issue has been appropriately addressed and dealt with. Make-A-Wish Greece considers that it is not acceptable to delay taking action against an alleged perpetrator until they have been charged with a criminal offence.

Whether or not the authorities conduct an investigation, the CEO, assisted by legal counsel, will consult with the authorities to determine whether an internal investigation is appropriate. If it is decided that such an investigation will not conflict with any proceeding of the authorities, the CEO may decide to conduct such an investigation. All Make-A-Wish Greece representatives must cooperate fully with the investigation.

The CEO will make every effort to keep any such investigation confidential, however from time to time, other Make-A-Wish Greece representatives may need to be consulted in conjunction with the investigation.

After an initial review and a determination of whether the suspected abuse warrants additional investigation, the CEO shall coordinate the investigation with the appropriate investigators and/or law enforcement officials. Internal or external legal representatives will be involved in the process, as deemed appropriate.

Responding:

If it is alleged that a Make-A-Wish Greece representative may have committed an offence or have breached the organization’s policies or the Child Safety Code of Conduct, the person concerned may be suspended (with pay, where applicable) while the investigation is conducted. Volunteers who are the subject of an investigation are required to cease any Make-A-Wish Greece volunteer activities until such time as they are cleared of the allegations.

Make-A-Wish Greece has full discretion to put safety management plans in place or take disciplinary action where it forms a reasonable belief that it is not safe for an employee or volunteer to interact with children in accordance with its duty of care.

If the investigation concludes that on the balance of probabilities an offence (or a breach of the organization’s policies or Child Safety Code of Conduct) has occurred, then disciplinary action may follow, up to an including dismissal or cessation or involvement with the organization. The findings of the investigation will also be reported to any external authority as required.

Record-keeping and privacy:

All personal information considered or recorded will respect the privacy of the individuals involved unless there is a risk to someone’s safety. Make-A-Wish Greece will have safeguards and practices in place to ensure that any personal information is protected. Make-A-Wish Greece will only inform third parties as required by law, including the relevant jurisdictional child protection authority and police department.

Record-keeping related to cases of abuse or suspected abuse must follow legal requirements as applicable to the jurisdiction within which the instance occurred.

Reviewing:

Affiliate Boards will conduct a review of the Make-A-Wish Greece child protection policies and Child Safety Code of Conduct every two years and following every reportable incident. The review will seek to determine whether the organization’s child protection policies or procedures require modification to better protect children under the organization’s care. The review will also ensure the policies and Child Safety Code of Conduct including any new legislative requirements.

DEFINITIONS:

Child means a person under the age of 18 years unless otherwise stated under the law applicable to the child.

Child abuse means all forms of physical abuse, emotional ill-treatment, sexual abuse and exploitation, neglect or negligent treatment, commercial (e.g. for financial gain) or other exploitation of a child and includes any action that results in actual or potential harm to a child.

Child sexual assault is any act which exposes a child to, or involves a child in, sexual processes beyond his or her understanding or contrary to accepted community standards. Sexually abusive behaviours can include the fondling of genitals, masturbation, oral sex, vaginal or anal penetration by a penis, finger or any other object, fondling of breasts, voyeurism, exhibitionism, and exposing the child to or involving the child in pornography. It includes child grooming, which refers to actions deliberately undertaken with the aim of befriending and establishing an emotional connection with a child to lower the child’s inhibitions in preparation for sexual activity with the child.

Make-A-Wish Greece Representative means any person who is acting on behalf of Make-A-Wish Greece and includes employees, employee contractors, volunteers and board members.

Make-A-Wish Greece “Ambassadors” means any person appointed to act in an Ambassador role for Make-A-Wish Greece as part of fundraising, brand, wish, corporate and community partnerships.

Make-A-Wish Greece “Wish” Partners & Suppliers means business or community organizations or sole traders who are involved in the delivery of a child’s wish.

- Reasonable ground for belief means a belief based on reasonable grounds (see below) that child abuse has occurred when all known considerations or facts relevant to the formation of a belief are taken into account and these are objectively assessed. Circumstances or considerations may include the source of the allegation and how it was communicated, the nature of and details of the allegation, and whether there are any other related matters known regarding the alleged perpetrator.A reasonable belief is formed if a reasonable person believes that:
  - The child is in need of protection;
  - The child has suffered or is likely to suffer “significant harm as a result of physical injury”; or
  - The parents are unable or unwilling to protect the child.

A “reasonable belief” or “belief on reasonable grounds” is not the same as having proof, but is more than mere rumour or speculation.

A “reasonable belief” is formed if a reasonable person in the same position would have formed the belief on the same grounds. For example, a “reasonable belief” might be formed if:

A child states they have been physically or sexually abused;
A child states that they know someone who has been physically or sexually abused (sometimes the child may be talking about themselves);
Someone who knows a child states that the child has been physically or sexually abused;
Professional observations of the child’s behaviour or development leads a professional to form a belief that that the child has been physically or sexually abused; and/or
Signs of abuse lead to a belief that the child has been physically or sexually abused.
Reporting in “good faith” means that a reporter has a valid and reasonable concern and is acting without malice or retaliation towards the alleged offender.

CHILD SAFETY CODE OF CONDUCT*

At Make-A-Wish, we aim to conduct our business according to the highest standards of honesty, integrity, respect and fairness. We require that our employees, employee contractors, volunteers and board members (“representatives”) and Make-A-Wish Greece partners, etc. conduct themselves according to these high standards to ensure that Make-A-Wish Greece maintains its good reputation.

Appropriate behaviour towards children and young people:

It is a requirement that all Make-A-Wish Greece representatives are aware of, and act in accordance with, our expectations of appropriate behaviour specially towards (and in the company of) children and young people. This is set out in our Safeguarding Children and Young People Policy which representatives must comply with in addition to all other expectations detailed throughout this code of conduct.

Make-A-Wish Greece Representatives will:

Ensure that they are never in a position where they are left alone with a child/young person.
Only ever enter the home of a wish child/young person when accompanied by another volunteer (or other appropriate Make-A-Wish Greece representative).
Respect the cultural safety and needs of all children/young people and those with culturally and/or linguistically diverse backgrounds.
Be sensitive to the needs of children/young people with a disability and respect their individual requirements (e.g. methods of communicating with a non-verbal child).
Protect the privacy of children/young people by only sharing confidential information as absolutely required in accordance with the delivery of Make-A-Wish Greece programs and ensuring appropriate consent is obtained before sharing information with outside parties, including any PR and social media.
Only photograph or video a child/young person with the consent of their parent(s)/legal guardian(s). Use, storage and publication of such photos must be authorized by the affiliate.
Promote a safe and welcoming environment where children/young people are encouraged to explore their ideas, opinions, and creativity without fear of judgement.
Empower children and young people to speak up about their safety and listen to their needs, respecting their rights at all times.
Cooperate with regulatory authorities if they are undertaking an investigation.
Participate in and cooperate with any internal investigation by Make-A-Wish Greece if required.
Comply with all reasonable directions provided by Make-A-Wish.
Ensure they have a valid police check.
Adhere to the Make-A-Wish Greece Safeguarding Children and Young People Policy at all times; this includes reporting requirements and contacting the police if a child/young person is at immediate risk of abuse.

Make-A-Wish Greece Representatives will not:

Engage in any sexual activity with a child/young person that they interact with through Make-A-Wish.
Communicate with children/young people (e.g. online, telephone) without knowledge of their parent(s)/legal guardian(s).
Become “friends” with children/young people on social media platforms unless they have a relationship that is external to Make-A-Wish Greece (e.g. the child is the daughter of their friend).
Engage in unnecessary physical contact with children/young people or utilize any form of physical discipline.
Exploit any child/young person’s situation for personal or professional gain.
Leave a child on their own during a wish or in another instance where Make-A-Wish Greece has a duty of care over the child.
Provide gifts, special treatment or develop any “special relationship” with a child/young person or their parent(s)/legal guardian(s) that could be seen as favouritism.
Share a bed or tent with a child.
Share a room with a child without anyone else present.
Ignore or disregard any suspected or disclosed child abuse.
Act in a manner that breaches a child’s confidentiality.
Smoke, being intoxicated with alcohol or any other drug in the presence of a child/young person.
Act in a manner that puts a child at risk of any form of abuse or violence.

Consequences for breach of the Child Safety Code of Conduct:

Disciplinary action up to and including immediate termination of employment or association with Make-A-Wish Greece may be taken for any breach of this Code of Conduct. In cases where the conduct may also involve a breach of the law, the relevant government authorities (or the police) may be notified.

Make-A-Wish Greece has full discretion to put in place safety management plans or take disciplinary action where it forms a reasonable belief that doing so is necessary for it to ensure the health and safety of its wish children, employees, volunteers in its care or the general public.

Safeguarding Concern Form

Complete as much detail as you are able. Don’t delay making a report if there is information missing.

Part 1 – Details of the Child/Children
Name of Child :
Gender:	Age:	Date of Birth:
Any additional needs (e.g. disability, language spoken, interpreter required):
Parent/Caregiver’s name(s):
Home address of child:
Place/time/date where the concern was identified:
Part 2 – Details of a safeguarding allegation against employees/ volunteers/ partners/ third parties
Name and role of person who is the subject of the allegation:
Age and/or Date of Birth:
Home address:
Place/time/date where the concern was identified:
Part 3 – Your Details
Your Name:	Your Position:	Your contact details:
Part 4 – Report
Are you reporting your own concerns or responding to concerns raised by someone else? Responding to my own concerns Responding to concerns raised by someone else
If responding to concerns raised by someone else, please provide their name, role and contact details (if known):
Please provide details of the safeguarding concern or allegation including times, dates or other relevant information. Make it clear whether you are giving a fact, expressing your opinion or expressing the opinion of someone else:
The child or adult’s account of what happened (e.g. of any incident, injury, disclosure, behaviour) if known:
Please provide details of the person alleged to have caused the incident/injury if known (e.g. names(s)/ address/ incident address /relationship to child or adults:
Please provide details (name, role contact details if known) of any witnesses to the incident/concerns:
Part 5 – Actions Taken
State any risk of immediate harm:
Identify any action taken already e.g. contact with police, manager, children’s services, safeguarding helpline etc.:
Are the child and parents/ caregivers aware that a report has been made?
Any known previous history of safeguarding concerns or allegations?
Any further information or comments or actions to be taken?
Date and time of report being submitted
Person to whom the report is being submitted:
Part 6 – Immediate action and decisions by Designated Safeguarding/Child Protection Officer

Part 7 – Outcome