Safeguarding Policy

1. Introduction

The Amaefule and Astudillo Empowerment Foundation (T.A.A.E Foundation) is a Nigerian non-profit organisation dedicated to empowering children and adults with disabilities. We deliver outreach programmes, medical interventions, disability support, scholarship initiatives, food aid, and community development across Nigeria. In the course of this work, we come into regular contact with children, persons with disabilities, vulnerable adults, and marginalised communities.

The Foundation holds an unconditional duty of care toward every person we serve and every person who serves alongside us. This Safeguarding Policy formalises that duty. It sets out who is protected, what conduct is required, how concerns must be reported, and how the Foundation will respond.

This policy is informed by and consistent with:

• The Companies and Allied Matters Act (CAMA) 2020
• The Nigeria Not-For-Profit Governance Code (NFPGC) 2023, issued by the Financial Reporting Council of Nigeria
• The Child Rights Act of Nigeria 2003
• The Discrimination Against Persons with Disabilities (Prohibition) Act 2018
• The Violence Against Persons (Prohibition) Act (VAPP) 2015
• The Nigeria Data Protection Act 2023
• The United Nations Convention on the Rights of the Child (UNCRC)
• The United Nations Convention on the Rights of Persons with Disabilities (UNCRPD)

Safeguarding is not an optional addition to our work. It is the foundation on which our work stands.

2. Purpose of This Policy

This policy exists to:

• Protect every child, adult at risk, volunteer, staff member, and community partner connected to the Foundation from harm, abuse, exploitation, neglect, harassment, and discrimination
• Define the safeguarding responsibilities that apply to all persons acting on behalf of the Foundation
• Establish clear, confidential, and accessible reporting channels for safeguarding concerns
• Ensure that safeguarding concerns are taken seriously, investigated fairly, and resolved promptly
• Promote disability inclusive safeguarding that recognises the specific vulnerabilities and rights of persons with disabilities
• Protect children in line with the Child Rights Act of Nigeria 2003
• Ensure compliance with the NFPGC 2023 whistleblowing and governance requirements
• Embed a culture of accountability, transparency, and continuous learning within the Foundation

3. Scope of This Policy

This policy applies to every individual who acts in any capacity on behalf of T.A.A.E Foundation, including:

• Board members and trustees
• Executive leadership and management
• Paid staff
• Volunteers
• Consultants and independent contractors
• Interns and mentees
• Community mobilisers and field agents
• Partner organisations and their representatives
• Donors visiting or engaging in Foundation activities

This policy applies across all Foundation activities, including but not limited to community outreaches, medical and healthcare interventions, disability support visits, educational and skills programmes, food and aid distribution, photography and media documentation, social media engagement, and any form of home visit or field interaction.

4. Our Safeguarding Commitment

T.A.A.E Foundation is unconditionally committed to the safety and dignity of every person we encounter. We believe that:

• Every child has the right to protection from abuse, exploitation, and neglect, as guaranteed by the Child Rights Act of Nigeria 2003
• Every person with a disability has the right to dignity, autonomy, and equal protection under the Discrimination Against Persons with Disabilities (Prohibition) Act 2018
• Every adult has the right to live free from violence, harassment, and exploitation, as protected by the VAPP Act 2015
• Every beneficiary, staff member, and volunteer has the right to report a concern without fear of retaliation

The Foundation operates a strict zero-tolerance position on sexual exploitation and abuse, all forms of physical or emotional abuse, child labour or child exploitation, financial exploitation of beneficiaries, harassment and bullying, discrimination on any grounds, and abuse of authority or power.

5. Key Definitions

Child

Any person below the age of 18 years, as defined by the Child Rights Act of Nigeria 2003 and consistent with the United Nations Convention on the Rights of the Child.

Adult at Risk

An adult whose circumstances, including disability, illness, age, social exclusion, dependency, or trauma, may limit their ability to protect themselves from harm or exploitation.

Safeguarding

The range of measures, systems, policies, and actions put in place to protect individuals from harm, abuse, exploitation, neglect, and violations of their rights.

Abuse

Abuse may take several forms. Physical abuse includes any act that causes bodily harm. Emotional or psychological abuse includes humiliation, intimidation, isolation, and degrading treatment. Sexual abuse includes any non-consensual sexual act or exploitation. Financial abuse includes theft, fraud, or manipulation of a person's resources. Neglect is the failure to provide necessary care, support, or protection. Discriminatory abuse targets a person because of their disability, gender, age, religion, ethnicity, or other characteristic.

Sexual Exploitation and Abuse (SEA)

Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. This includes, but is not limited to, profiting monetarily, socially, or politically from the sexual exploitation of another person. Exchanging aid, assistance, employment, or support for sexual favours constitutes sexual exploitation and is strictly prohibited.

Whistleblowing

A person who reports, in good faith, a safeguarding concern, illegal act, unethical behaviour, or policy violation within the Foundation. Consistent with the NFPGC 2023, the Foundation guarantees the anonymity and protection of every whistleblower.

6. Guiding Principles

The Best Interests of the Child

In every decision that affects a child, the best interests of that child shall be the primary consideration. This reflects the requirement of the Child Rights Act of Nigeria 2003 and the UNCRC.

Dignity and Respect

Every individual shall be treated with dignity, humanity, and respect at all times, regardless of disability, gender, age, social background, ethnicity, or religion.

Disability Inclusion

Persons with disabilities must be fully included in safeguarding systems. Their communication needs, autonomy, and rights must be respected. The Foundation recognises that persons with disabilities may face elevated safeguarding risks due to dependency, communication barriers, and societal exclusion.

Do No Harm

All Foundation programmes, outreaches, and interactions must be designed and delivered in ways that minimise risks and avoid causing physical, emotional, psychological, or social harm.

Survivor Centred Response

The safety, dignity, and wishes of a person who has experienced harm shall always be prioritised above institutional reputation or administrative convenience.

Confidentiality

All safeguarding concerns shall be handled with appropriate discretion. Information will only be shared on a need-to-know basis, consistent with the Nigeria Data Protection Act 2023.

Accountability

Every person acting on behalf of the Foundation is personally accountable for safeguarding. Leadership is accountable for ensuring safeguarding systems are in place, functional, and effectively implemented.

Non-Retaliation

No person who reports a safeguarding concern in good faith shall face any adverse consequence, dismissal, demotion, harassment, or intimidation as a result of making that report. Retaliation is a serious disciplinary offence.

7. Code of Conduct

All persons acting on behalf of T.A.A.E Foundation are required to:

• Treat every individual with dignity and respect at all times
• Maintain professional boundaries in all interactions with beneficiaries, particularly children and persons with disabilities
• Obtain clear informed consent before taking photographs, recording videos, or collecting personal testimonials
• Never be alone with a child in an isolated or unsupervised setting
• Use language that is respectful, inclusive, and appropriate to the context
• Report any safeguarding concern immediately upon becoming aware of it
• Never exchange aid, money, employment, goods, or services for sexual favours or personal benefit
• Never engage in romantic, sexual, or exploitative relationships with beneficiaries
• Never physically punish, humiliate, restrain without justification, or intimidate any person
• Never consume alcohol or substances during Foundation activities in the field
• Never make promises to beneficiaries that exceed the Foundation's capacity to deliver
• Maintain respectful, professional, and transparent communication in all online interactions
• Never share beneficiary photographs or personal information on personal social media without prior authorisation

Violation of this Code of Conduct may result in immediate suspension, termination of engagement, and where appropriate, referral to relevant Nigerian authorities including the National Agency for the Prohibition of Trafficking in Persons (NAPTIP), the Nigerian Police Force, or the National Commission for Persons with Disabilities.

8. Safe Recruitment and Vetting

The Foundation is committed to ensuring that only suitable individuals are engaged in work that involves contact with children and vulnerable persons. The following practices apply to all recruitment, whether paid or voluntary:

• Identity verification for all applicants
• Minimum of two written or verbal reference checks, with specific questions relating to safeguarding conduct
• Safeguarding screening questions during interview
• Declaration of any previous misconduct, criminal conviction, or safeguarding concern
• Mandatory reading and signing of this Safeguarding Policy and the Foundation Code of Conduct prior to commencement
• Safeguarding orientation training within the first two weeks of engagement

The Foundation reserves the right to withdraw an offer of engagement where safeguarding concerns are identified at any stage of the recruitment process.

9. Safeguarding Responsibilities

Board of Trustees

The Board bears ultimate responsibility for safeguarding within the Foundation. The Board shall ensure that this policy is formally adopted, adequately resourced, and reviewed annually. The Board shall designate a Safeguarding Lead at leadership level and receive regular safeguarding reports. This responsibility is consistent with the board accountability provisions of the NFPGC 2023.

Chief Executive Officer

The CEO is responsible for the operational implementation of this policy, for ensuring all staff and volunteers are trained, and for ensuring that safeguarding concerns are escalated appropriately. The CEO is the primary point of accountability to the Board on safeguarding matters.

Safeguarding Focal Person

The Foundation shall appoint a designated Safeguarding Focal Person who is responsible for:

• Receiving, documenting, and managing all safeguarding reports
• Maintaining a secure and confidential safeguarding incident register
• Coordinating the Foundation's response to safeguarding concerns
• Referring cases to appropriate authorities where necessary
• Supporting affected individuals throughout the reporting and response process
• Monitoring overall compliance with this policy
• Leading safeguarding training and awareness activities

All Staff and Volunteers

Every person acting on behalf of the Foundation is responsible for understanding this policy, maintaining professional conduct, and reporting any safeguarding concern immediately. Ignorance of this policy does not constitute an excuse for a failure to act.

10. Reporting a Safeguarding Concern

Any person who witnesses, suspects, or is told about a safeguarding concern must report it immediately. Reports must not be delayed pending further evidence or confirmation. The Foundation operates on the principle that it is always better to report a concern that proves unfounded than to remain silent about a concern that proves to be real.

What to Report

A concern should be reported if you have witnessed any form of abuse or misconduct, if a beneficiary has disclosed abuse to you, if you suspect that a person is being harmed or is at risk of harm, or if you have observed conduct by a staff member, volunteer, or other representative that violates this policy.

How to Report

Reports may be made verbally or in writing. The preferred method is in writing to ensure accuracy and create a proper record. The following contact channels are available:

Where a concern involves the Safeguarding Focal Person, the report should be made directly to the CEO or the Board Chairperson.

All reports will be acknowledged within 48 hours. The reporter will be kept informed of progress to the extent that confidentiality permits.

No person who makes a report in good faith shall face any adverse consequence. Retaliation against a reporter is a disciplinary offence that may result in termination and referral to the relevant authorities. This protection is consistent with the whistleblower protection provisions of the NFPGC 2023.

11. Responding to Safeguarding Concerns

Upon receipt of a safeguarding report, the Safeguarding Focal Person shall:

• Acknowledge receipt of the report promptly
• Ensure the immediate safety of any person at risk
• Document the concern accurately and confidentially
• Assess the level of risk and determine whether immediate referral to external authorities is necessary
• Consult with the CEO and, where appropriate, the Board
• Communicate with the affected person in a trauma-informed, respectful manner
• Maintain confidentiality throughout the process, sharing information only on a need-to-know basis

Where a concern relates to the potential commission of a criminal offence, the Foundation shall refer the matter to the Nigerian Police Force, NAPTIP, the National Commission for Persons with Disabilities, or other relevant statutory bodies without delay.

The Foundation shall document all steps taken in response to a safeguarding concern in a secure confidential register. This register shall be accessible only to the Safeguarding Focal Person, CEO, and designated Board members.

12. Child Protection

The Foundation works regularly with children, including children with disabilities, children from disadvantaged communities, and scholarship recipients. Child protection is therefore a specific and elevated safeguarding priority for T.A.A.E Foundation.

Consistent with the Child Rights Act of Nigeria 2003, the Foundation upholds the following child protection standards:

• No child shall be subjected to physical, emotional, or sexual abuse in connection with Foundation activities
• No child shall be used in fundraising imagery or materials in a manner that is exploitative, degrading, or that reveals identifying information without parental or guardian consent
• No staff member or volunteer shall be alone with a child in an isolated setting
• Any disclosure of abuse made by a child shall be taken seriously, documented carefully, and referred to the appropriate authorities
• Children shall be encouraged to express their views and their voices shall be respected in matters that affect them
• No child below the age of 15 shall be engaged in any form of work, errand, or activity on behalf of the Foundation, consistent with the prohibition of child labour under the Child Rights Act

Where the Foundation becomes aware that a child connected to its programmes is at risk of harm in any environment, including the home, the Foundation shall take appropriate steps to refer the matter to the relevant child welfare authority.

13. Disability Inclusive Safeguarding

As a disability-centred organisation, T.A.A.E Foundation recognises that persons with disabilities are at statistically elevated risk of experiencing abuse, neglect, exploitation, and exclusion. This risk is compounded by dependency on caregivers, communication barriers, social stigma, and limited access to reporting mechanisms.

The Foundation commits to the following disability inclusive safeguarding standards, consistent with the Discrimination Against Persons with Disabilities (Prohibition) Act 2018 and the UNCRPD:

• Communication support shall be provided in all formats necessary to ensure that persons with disabilities can understand and participate in safeguarding processes
• Reporting channels shall be designed to be accessible to persons with physical, intellectual, and communication-related disabilities
• The autonomy and consent of persons with disabilities shall be respected at all times, including consent to physical assistance, medical interventions, and media documentation
• Staff and volunteers shall receive specific training on the safeguarding risks faced by persons with disabilities and on disability-affirming communication and conduct
• The Foundation shall never make assumptions about a person's capacity to consent or to participate based solely on their disability
• Discriminatory, dehumanising, or patronising conduct toward persons with disabilities constitutes a safeguarding breach and will be treated as such

14. Safeguarding in Media and Communications

The Foundation uses photographs, videos, case stories, and social media content to document and communicate the impact of its work. The dignity, privacy, and rights of every individual represented in Foundation media must be protected at all times.

The following standards apply to all media and communications activity:

• Informed consent must be obtained from every adult before their image, voice, or story is used in any Foundation material
• For children, written consent must be obtained from a parent or legal guardian
• For persons with intellectual disabilities or limited capacity, consent must be sought in an accessible format and with appropriate support
• Identities shall be protected where a person faces risk as a result of identification
• Photographs and stories shall represent beneficiaries with dignity and shall not portray them in ways that are degrading, exploitative, or designed solely to elicit pity
• No beneficiary shall be photographed in a state of undress, medical vulnerability, or emotional distress without specific ethical justification and explicit consent
• Photographs must not be shared on personal social media accounts of staff or volunteers without prior authorisation from the Foundation
• Metadata from photographs, including location data, shall be managed to protect beneficiary safety

15. Data Protection and Confidentiality

The Foundation collects and processes personal data as part of its safeguarding and programme activities. All personal data shall be handled in accordance with the Nigeria Data Protection Act 2023.

The following data protection principles apply:

• Personal data of beneficiaries, staff, and volunteers shall be collected only for legitimate Foundation purposes
• Data shall be stored securely and access limited to authorised personnel
• Safeguarding records shall be kept separately from general personnel records
• Data shall not be shared with third parties without consent, except where legally required or where the safety of a person is at risk
• Individuals have the right to know what personal data the Foundation holds about them

Safeguarding records, including incident reports and response documentation, shall be retained for a minimum of seven years to ensure accountability and facilitate review.

16. Partner and Third Party Safeguarding

T.A.A.E Foundation works alongside partner organisations, community groups, and contractors. The Foundation expects all partners and third parties to uphold safeguarding standards that are consistent with this policy.

Where the Foundation enters into a formal partnership or contractual arrangement, safeguarding expectations shall be clearly articulated in writing. The Foundation reserves the right to discontinue any partnership or contractual arrangement where safeguarding concerns arise that are not adequately addressed.

Partner organisations shall be informed of this policy and shall agree to its principles as a condition of engagement with T.A.A.E Foundation.

17. Training and Capacity Building

The Foundation is committed to ensuring that all persons acting on its behalf are equipped to recognise, respond to, and report safeguarding concerns. The following training provisions apply:

• All new staff and volunteers shall receive safeguarding induction training before beginning any field or beneficiary-facing activities
• Refresher training shall be provided at least once per year
• Training shall include how to recognise the signs of abuse, how to respond to a disclosure, how to report a concern, professional boundaries, disability inclusive safeguarding, child protection principles, and the contents of this policy
• Training shall be delivered in accessible formats to ensure that all staff and volunteers, including those with disabilities, can participate fully
• Records of training completion shall be maintained by the Safeguarding Focal Person

18. Monitoring and Review

This policy shall be reviewed annually by the Safeguarding Focal Person and the Foundation leadership. An earlier review may be triggered by a significant safeguarding incident, changes in Nigerian law, changes in the Foundation's operational context, or the identification of gaps in policy effectiveness.

The Board of Trustees shall receive a safeguarding report at least once per year. This report shall include the number and nature of concerns received, outcomes of investigations, training completion rates, and any recommendations for policy improvement. This reporting requirement is consistent with the governance and accountability provisions of the NFPGC 2023.

This policy will be published and made available to all staff, volunteers, and where appropriate, to beneficiaries and community partners.

19. Policy Breaches and Disciplinary Action

A breach of this policy is a serious matter and will be treated accordingly. Depending on the nature and severity of the breach, the Foundation may take the following actions:

• Verbal or written warning
• Suspension from duties pending investigation
• Termination of employment or voluntary engagement
• Referral to the Nigerian Police Force
• Referral to NAPTIP
• Referral to the National Commission for Persons with Disabilities
• Referral to other relevant statutory or regulatory bodies

No person shall be subject to disciplinary action solely on the basis of having reported a concern in good faith, even if that concern is subsequently found to be unsubstantiated.

20. Declaration and Adoption

This Safeguarding Policy has been adopted by the Board of Trustees of the Amaefule and Astudillo Empowerment Foundation. It is a living document that reflects the Foundation's ongoing and unconditional commitment to the protection of every person we serve.

Every staff member, volunteer, consultant, and representative of T.A.A.E Foundation is required to read, understand, and comply with this policy. Engagement with the Foundation constitutes acceptance of this commitment.

Appendix B: Safeguarding Policy Acknowledgement

I confirm that I have read and understood the T.A.A.E Foundation Safeguarding Policy. I understand my responsibilities and agree to uphold the standards set out in this policy in all my activities on behalf of the Foundation.