Policy statement 

This policy sets out how we, as an international network, will prevent and respond to safeguarding concerns, and how we hold ourselves accountable. This policy is intended to compliment and reinforce other Mary’s Meals policies and procedures that are relevant to Safeguarding – for example Code of Conduct, Health & Safety, Teaching Quality Standards, and Data Protection. 

We will use this policy in conjunction with relevant laws (including criminal, employment and privacy for example), and our duty of care to make decisions about how to respond to any concerns raised. 

Mary’s Meals is committed to achieving full, ongoing implementation of international best practice relating to prevention of Sexual Exploitation and Abuse. International frameworks such as the Six Core Principles by the Inter-Agency Standing Committee (IASC) Working Group on Prevention and Response to Sexual Exploitation and Abuse, the Inter-Agency Standing Committee Minimum Operating Standards on Prevention of Sexual Exploitation and Abuse (PSEA)1 and the Core Humanitarian Standard on Quality and Accountability have influenced this policy. 

There are several key pieces of legislation and guidance that inform the principles underpinning this policy, and our practice in relation to safeguarding children and adults, these include: 

• United Nations Convention on the Rights of the Child 1989
• Human Rights Act 1998
• Keeping Children Safe in Education 2020
• The six Core Principles are from the UN Secretary-General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)
• International Labour Organization (ILO) Convention 190. 

Safeguarding and Mary’s Meals values and culture: 

Mary’s Meals’ commitment to safeguarding is consistent with our values: 

We have confidence in the innate goodness of people: Mary’s Meals depends on the generosity, goodwill and cooperation of millions of people globally, and we believe that individuals are good and well intentioned. However, we are not naïve to the risks that comes with working in such diverse contexts, and that Mary’s Meals is not immune from attracting people with harmful intentions. 

We respect the dignity of every human being and family life: We will implement policies and procedures to strive to ensure that no individual who comes into contact with our work is subject to abuse, harm or degrading treatment. 

We believe in good stewardship of the resources entrusted to us: We will be open and accountable to all of our stakeholders, and we will regularly assess the effectiveness and appropriateness of the policies and practices in place relating to Safeguarding. We will always be willing to adapt and improve our methods when necessary to create a safe environment for anyone who comes into contact with our work.

Scope and applicability 

This policy is applicable to MMI, National Affiliates, International Fundraising Groups and Programme Affiliates. It applies to all employees, trustees, volunteers, agents, partnering agencies, consultants, contractors and to any other people or bodies associated with Mary’s Meals, within all regions, areas and functions, wherever located. This policy will apply both during and outside normal working hours. 

In countries where this policy is more stringent than local legislation, this policy will still apply. 

This policy sets out our approach to preventing safeguarding incidents from occurring. This includes: 

• Our commitments to prevent sexual exploitation, abuse and harassment across all parts of the Mary’s Meals network;
• Our commitment to ensure effective action is taken when issues occur;
• Principles upon which we will base our decision making and actions;
• Our expectations of all those who represent Mary's Meals globally. 

Mary’s Meals will be responsible when harm has occurred (or is alleged to have occurred) by a representative of the charity. Mary’s Meals will not be responsible for any harm that occurs within the communities where we work that are not connected with or caused by Mary’s Meals. In a school feeding context, this could include harm caused by a teacher, parent or community member. 

Where the term “representative” is used in this policy, it includes the following categories of people: 

MM employee refers to anyone who works for Mary’s Meals as an employee of any part of the network.

MM representatives refers to a range of paid and non-paid individuals who represent or support Mary’s Meals. This includes the following categories: 

• Board members
• Volunteers including but not limited to event volunteers, expert volunteers, fundraising volunteers.
• Consultants, contractors and agency workers
• Anyone representing one of our suppliers who is likely to come into contact with children, vulnerable adults and other project participants.
• Visitors to our school feeding programmes including supporters, donors, journalists, celebrities and politicians. 

Other key definitions used in this policy: 

Subject of concern (SOC): A person about whom a concern is raised. 

Victim/survivor: The individual or individuals to whom harm has occurred. The terms ‘victim-survivor’ can be used interchangeably. Those affected by sexual abuse and exploitation can choose the term they prefer. 

Mary’s Meals Safeguarding Principles: 

• Mary’s Meals believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm including sexual exploitation, abuse, and harassment.
• Mary’s Meals will not tolerate exploitation, abuse, bullying and harassment and applies a robust approach to any breach of this and associated policies.
• Sexual exploitation and abuse by a Mary's Meals representative will be taken seriously and will constitute an act of gross misconduct for employees. For any other persons, sexual exploitation will be grounds for termination of /volunteer agreement and/or contract for services or relationship with Mary’s Meals.
• Sexual harassment by any Mary's Meals employee is grounds for disciplinary action up to and including dismissal for employees and will be cause for termination a contract for services or volunteer agreement.
• Sexual activity with children (any persons under the age of 18) is prohibited regardless of the age of consent locally. Mistaken belief in the age of the child is not an excuse.  
• Exchange of money, employment, goods or services for sex, sexual favours or other forms of humiliating, degrading or exploitative behaviour by Mary's Meals representatives is prohibited at all times. This includes buying sex or the exchange of assistance that is due to programme participants.
• To avoid any conflict of interest, power imbalance or perceived conflict of interest or power imbalance, Mary’s Meals representatives are required to declare any pre-existing relationships between themselves, other staff members, volunteers, anyone under the age of 18 or project participants.
• Where a Mary's Meals representative develops concerns or suspicions regarding sexual abuse, exploitation or sexual harassment by a fellow representative, they should report this concern via one of the established reporting mechanisms.
• Mary's Meals representatives are expected to create and maintain an environment that prevents sexual exploitation, abuse and harassment and any form of child abuse. Mary's Meals managers at all levels have responsibilities to support and develop systems, which maintain a safe environment. 

Standards based approach 

Mary’s Meals has developed and will apply six safeguarding standards which must be met for us to fully demonstrate a safeguarding culture across all parts of the network: 

Standard 1: Safe Policy and Conduct: Safeguarding policies will be implemented across the network. They will be translated and made available to all representatives. The Safeguarding Code of Conduct is signed by all employees and volunteers and representatives. Global policies may be supplemented by additional documents that include any necessary context-specific details. 

Standard 2: Awareness Raising & Knowledge sharing: We will ensure that everyone who works on behalf of Mary's Meals and those we serve have information about how to access safe reporting channels, including messaging that is suitable for children and people of other diversities. This should include posting reporting procedures in local languages and regularly raising awareness of options available. We will provide information to all Mary's Meals representatives to ensure they understand their right and obligations created by this and other safeguarding policies. We will also raise awareness of the importance of good safeguarding practice to supporters and donors, particularly those that are likely to come into contact with project participants. 

Standards 3: Safe Media and Communications: Use of information and images in all communications activities will feature appropriate images and stories of communities and children and will ensure that they are not exposed to harm and abuse. Informed consent processes will be followed for all images. All relevant representatives will be briefed on guidelines around ethical image gathering, storage, usage, and use of social media to ensure that standards are consistently upheld. 

Standard 4: Safe People: HR policies, processes and systems set out, and implement, organisational responsibilities around the employee lifecycle including recruitment, induction, training, staff conduct, equal opportunities and exit. Training and support will be provided to anyone with responsibilities for safeguarding. 

Standard 5: Safe Response: Mary’s Meals will treat any safeguarding concerns extremely seriously. We will ensure that we have multiple channels for Mary's Meals employees, associates, visitors or programme participants and others to safely report their concerns. We will also ensure that genuinely held concerns are thoroughly investigated in a survivor centred manner. 

Standard 6: Safe Governance: Governance arrangements across all parts of the network will be based on our values, and will promote transparency, probity and accountability. All Boards will be responsible for ensuring safeguarding compliance and culture is in place in their location. All Boards will ensure that we meet all external reporting requirements in all locations. 

Implementing Safeguarding standards across the Mary’s Meals Network 

Safe Programme Affiliates: Safeguarding arrangements in our Programme Affiliates are outlined in the Programme Affiliates Safeguarding Procedures. These procedures ensure that Mary’s Meals’s safeguarding responsibilities are clearly outlined. Any safeguarding risks associated with our school feeding programmes are mitigated and that all reasonable measures are put in place to prevent harm and abuse from occurring by any Mary’s Meals representative. 

Our Programme Affiliates rely on a large network of community volunteers. Safeguarding roles and responsibilities of different groups, such as School Feeding Committees, are clarified in the Programme Affiliates Safeguarding Procedures, as is the support made available to them by Mary’s Meals. 

Safe Programme Partners: Mary’s Meals will hold its programme partners to similarly high safeguarding standards which are outlined in the Programme Partner Safeguarding Policy and Guidelines. If there is reason to believe that standards within a partner organisation do not meet Mary’s Meals’ standards, the partnership arrangement will be reviewed, and it may be necessary to withdraw funding and bring the partnership to an end. 

Safe National Affiliates and IFGs: National Affiliates and IFGs will ensure that all supporter engagement, fundraising and awareness raising activities are conducted in line with our commitment to global safeguarding. All National Affiliates and IFGs must appoint a focal point who is responsible for safeguarding implementation and compliance. In National Affiliates, this will most likely be the Executive Director. National Affiliates and IFGs must report any safeguarding incidents to MMI immediately. Support will be provided to any NAs or IFGs if they don’t have the capacity to carry out a thorough response. 

How to report at Mary’s Meals 

Concerns can be reported anonymously. Anyone can raise a concern to Mary’s Meals about something they have experienced or witnessed. Reports are encouraged at all levels of the organisation. Concerns can be made in any language and arrangements will be made for a confidential translation. Any Mary’s Meals representative can do this verbally or in writing to your Programme Affiliate, National Affiliate or IFG Focal Point, Safeguarding Advisor or by using the whistleblowing helpline service. 

Verbally: Concerns can be raised with any of Safeguarding Focal Point, member of your local People or HR Team, your line manager of supervisor. 

Safeguarding Email: HQ-UK based: Safeguarding@MarysMeals.org 

Whistleblowing line: Concerns can also be raised via one of the Mary’s Meals Whistleblowing email addresses. Please see Whistleblowing Policy for further details. 

MMI: whistleblowmmi@marysmeals.org 

Zambia: raiseaconcernzambia@marysmeals.org 

Malawi: whistleblowmalawi@marysmeals.org 

Liberia: whistleblowliberia@marysmeals.org 

Kenya:whistleblowkenya@marysmeals.org 

External Reporting 

Donors and other supporters: Some donors, especially institutional donors (such as USAID and FCDO) have strict incident reporting guidelines. Failure to report safeguarding incidents in a timely manner could be considered mismanagement and/or a serious governance issue. All incidents must be reported as soon as possible to enable us to make an assessment of external reporƟ=ting. 

Regulating bodies: As a charity registered in Scotland, Mary’s Meals is accountable to the Scottish Charity Regulator (OSCR) for operating in the interests of their charity and in particular to act with care and diligence. OSCR expect us to be able to demonstrate that safeguarding vulnerable beneficiaries is a key governance priority. 

Regulatory authorities in different locations have different reporting requirements in relation to safeguarding incidents. National Affiliates, IFGs and Programme Affiliates will be required to research and understand obligations in their locations. Representatives have the right to report directly to regulatory authorities within their country, but they must also, in tandem, report to MMI immediately. Mary's Meals will assist victim/survivor to submit a report if they request this. 

Police and other law enforcement agencies: We will refer any reports involving criminal activity to the relevant authorities responsible for investigation, when safe to do so. As a rule, internal investigations will take place only when criminal investigations have been concluded. 

Responding to safeguarding concerns 

Survivor-centred approach: Across the Mary’s Meals family, we will take a victim/survivor centred approach when responding to concerns. A survivor-centered approach creates a supportive environment in which the survivor’s rights and wishes are respected, prioritised, their safety is ensured, and they are treated with dignity and respect. A survivor-centered approach is based on the following guiding principles:

• Safety: The safety and security of the survivor and their children will be the primary consideration. Where necessary, we will develop and implement an appropriate safety plan that manages the risks for victim/survivors.
• Respect: All actions taken will be guided by respect for the choices, wishes, rights and dignity of the survivor. The role of safeguarding teams is to facilitate recovery and provide resources to aid the survivor.
• Non-discrimination: Survivors will receive equal and fair treatment regardless of their age, gender identity, disability, sexual orientation or ethnic origin or any other characteristic.
• Agency: We will involve survivor in decision making, where safe and appropriate to do so. We will provide comprehensive information throughout the response process. We will seek to learn from Victim/Survivors. 

Additionally, we expect all decisions and actions in response to safeguarding concerns to be trauma informed. Our expectations are that: 

• Support will be provided to all survivors. Support can include specialist psycho-social counselling, and/or access to other appropriate support including medical and legal. Survivors can choose whether they would like to take up the support options available to them.
• Recognition will be given to the potential and actual impacts of trauma on survivors and witnesses, with the aim of preventing re-traumatisation or causing harm during any investigation processes.
• We will be guided by the safety, rights, needs, wishes of the victim/survivor, while ensuring procedural fairness to all parties.
• Incidents of a potentially criminal nature will be referred to law enforcement or relevant authorities in line with local mandatory reporting requirements, where safe to do so.
• Support will be offered to victims/survivors regardless of whether an investigation is carried out.
• Support will also be offered as appropriate to others involved in an incident management process, recognising the impact this can have, for example, on witnesses. This could include specialist psychosocial counselling, medical support, legal support and/or access to other specialist appropriate support as needed. Victim/Survivors and complainants should be able to choose if/when they would like to take up the support options available to them. 

Investigation 

A Safeguarding investigation will take place when there is a concern that a Mary’s Meals’ representative has caused harm to someone. An investigation plan will be developed and will be implemented by trained Safeguarding representatives. 

During any investigation process, anyone who is accused will be afforded just processes and wellbeing support. 

Mary’s Meals will not be responsible for conducting an investigation when harm is alleged to have been caused by a member of the community within which we work. In a school feeding context this could include community members or a family member causing harm to a student. In a national affiliate context, this could involve a family member causing harm to an employee or volunteer. 

Confidentiality 

Every effort will be made to maintain confidentiality throughout any response and investigation processes. Information that identifies any individuals involved will be limited to essential personnel only and will not be shared further without obtaining the consent of those involved, except if someone’s immediate safety is at risk, or a child is at risk, or as required by law in consultation with legal counsel and where safe to do so. Non-identifying information will be shared in all internal and regulatory reports. Individuals involved in response and investigation processes, either as witness, victim/survivor, investigator or subject of concern (SOC) will be made aware of the importance of maintaining confidentiality and may be asked to sign a confidentiality agreement. Employees who breach confidentiality may be subject to disciplinary action up to and including termination of employment, and others who work with Mary’s Meals may have their relationship or contractual arrangement with Mary’s Meals terminated. In some cases, such breaches may constitute breaking the law.

Roles and responsibilities 

MMI is responsible for setting global standards in relation to safeguarding and for supporting all parts of the network to implement safeguarding requirements. 

MMI & Local Boards: are accountable for the implementation of this policy. They have a duty to ensure that appropriate policies and procedures are in place to prevent abuse from taking place and to appropriately manage any concerns. They must satisfy themselves that safeguarding risks have been properly identified and managed. The Boards also have responsibility to ensure that appropriate reporting takes place to relevant external bodies and that the safeguarding arrangements in place in their location comply with any local/national requirements and expectations. The MMI Board have an additional responsibility to oversee and monitor the implementation of this policy across the global network. 

Mary’s Meals Senior Leaders globally: Are expected to develop a comprehensive understanding of the safeguarding risks in their location and ensure that appropriate mitigations are in place. Leadership Teams have a responsibility for building a culture of openness to enable issues and concerns about safeguarding to be raised and discussed. In addition, they must ensure that the standards set out in this policy are implemented locally and they must ensure that appropriate resources are allocated to support safeguarding activities in their location. 

Management responsibilities: All managers have a particular responsibility to uphold the standards set out in this policy and to set an example ensuring that a culture of dignity and respect is maintained across the network. As well as upholding standards themselves, managers are expected to ensure that all staff and volunteers and other representatives understand the provisions clearly and challenge any unacceptable behaviour. In addition, managers must ensure that any reports are taken seriously and investigated promptly and thoroughly. 

All Mary's Meals Employees and volunteers: Everyone who works or volunteers on behalf of Mary's Meals is required to report any safeguarding concerns. Employees and volunteers will often be the first to know when there is cause for concern and all individuals should be prepared to take action and understand what to do in the event there is a concern to raise. Failure to report to a concern is a breach of Mary's Meals’ policy and could lead to disciplinary action being taken against employees and the termination of Mary's Meals’s relationship with non-employees. There is no obligation for an individual to report any incident that has happened to them. 

Policy Monitoring 

To ensure this policy remains relevant and appropriate, it will be reviewed annually. MMI’s Safeguarding Committee will meet quarterly to review progress with global implementation. National Affiliates, IFGs, Programme Affiliates are also encouraged to establish appropriate means of monitoring and reporting on progress. Global progress on implementation of this policy and associated standards will be reported to the MMI Board every six months in a biannual report which is submitted in May and December every year. 

Annex – Key definitions in addition to those listed in this policy: 

Abuse: Abuse includes all forms of physical or mental violence, injury or violence, neglect or negligent treatment, emotional ill-treatment or psychological violence, sexual abuse and exploitation, harassment, and commercial or other exploitation. Acts of abuse can also take place online through, for example, the web, social media or mobile phones. It may be an intentional act involving the use of physical force or power or it may be failing to act to prevent abuse. 

Abuse of Power: When someone misuses their relative power, influence or control over another person to cause them harm or distress or to benefit in some way. 

Child: Every human being below the age of 18. 

Child Abuse: Child abuse involves the abuse of children’s rights and includes all forms of violence against children: physical, emotional and sexual abuse, neglect, family violence, sexual exploitation, abduction and trafficking, including for sexual purposes, involvement of a child in online child sexual exploitation and child labour as defined below. 

Concern: A concern is a feeling or worry that a child or adult may be at risk of harm, or may have been harmed. 

Sexual Exploitation: Any actual or attempted abuse of a position of vulnerability, differential power or trust, for any purposes, including profiting monetarily, socially or politically from the sexual exploitation of another. 

Focal Point: The role of a focal point can vary but this term is typically used to describe someone who is trusted and trained point of contact to whom concerns can be reported. 

Harm: Any detrimental affect including psychological, physical or emotional suffered by an individual. Harm may be caused by abuse or exploitation whether intended or unintended. 

PSEAH: Stands for Prevention of Sexual Harassment, Exploitation, Abuse and Harassment. It refers to the responsibilities; preventative, responsive and referral measures that we undertake to prevent sexual harassment, sexual exploitation and sexual abuse from happening to anyone who comes into contact with our work by a representative of Mary’s Meals. 

Sexual Abuse/Violence: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual offences including but not limited to: attempted rape, and sexual assault (which includes non- consensual kissing and touching). All sexual activity with someone under the age of consent is considered to be sexual abuse. 

Sexual Harassment: A term used to describe an unwelcome sexual advance or an unwelcome request for sexual favours or any other unwelcome conduct of a sexual nature. Sexual Harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated or one- off and perpetrated by any person of any gender towards any person of any gender. 

Visitor: A range of people who visit our offices or programmes/projects and who may come into contact with children and young people. A visitor could be a journalist, researcher, supporter, donor, celebrity or ambassador. 

Employees and representatives: Includes all employees of Mary's Meals plus board members, volunteers, interns, and international and local consultants, day labourers, in addition to individual and corporate contractors of these entities and related personnel. This includes non-Mary's Meals entities and their employees and individuals who have entered into partnership, subgrant or sub-recipient agreements with Mary's Meals. 

Victim-Survivor: The terms ‘victim’ and ‘survivor’ can be used interchangeably. In the context of this policy, these terms are used to refer to anyone who has been subject to a safeguarding abuse. Victim-Survivors may include adults and children, Mary's Meals staff and people from the communities in which we work. 

Survivor-Centred Approach: A Survivor-centred approach is one where the wellbeing and the wishes of the Victim-Survivor of an incident are put at the centre of all actions taken. This includes ensuring: The safety and security of the Victim-Survivor, any dependents, witnesses, or whistleblowers. Assurance that issues will be handled in confidence. The Victim-Survivor’s wishes (self-determination) and best interests are taken into account. The Victim-Survivor is treated with dignity and respect, demonstrating belief and trust. Empowerment of the individual, their family, friends, and community. A timely response at each stage. No limitations on who reports or when they report. An individual can report a concern or incident at any time after it happens.