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HR Procedure
Safeguarding

Mitie Group Plc | Resourcing Procedure | Version 1.0 August 2019

Mitie Group Plc | Safeguarding Procedure | November 2022

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Intro…
We are committed to ensuring a safe environment and the duty of care we have towards
the welfare of the people who use the facilities in which Mitie operate. All employees
working within a setting that includes children, young or vulnerable people have a
responsibility to safeguard and promote their welfare, including the responsibility to be alert
to possible abuse and to record and report concerns to the designated senior member of
staff for Safeguarding. It is unacceptable for any member of staff to keep such concerns to
themselves, including concerns about the conduct of another member of staff

The primary aim of this procedure is to raise awareness, promote good practice and
demonstrate our commitment to safeguarding children and vulnerable people from abuse,
neglect and exploitation.

Who does this procedure apply to?

This procedure applies to anyone directly employed by Mitie in the UK, whether on a
permanent or fixed term basis. It applies to any location or operation within which an
employee or subcontractor is required to attend for the purposes of their employment and
may come into contact with a child or vulnerable person. This procedure is non-contractual
and may be amended or varied at any point.

What is safeguarding?
Everyone working with children or young people has a responsibility to understand what
safeguarding means and what their responsibilities are in relation to keeping children and
young and or vulnerable people safe.

Safeguarding is about embedding practices throughout an organisation to ensure the

protection of children and/or vulnerable people wherever possible. In contrast, child and adult
protection is about responding to circumstances that arise.

Although policy and legislation dictates that the response to dealing with safeguarding
concerns for vulnerable people should differ from the approach taken with children and
young people, the majority of principles are the same.

We believe that a child or young and/or vulnerable person should never experience abuse
of any kind. We have a responsibility to promote the welfare of all children, young and/or
vulnerable people and to keep them safe and we are committed to operating in a way that
protects them.

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Why do we need this procedure?

The Children Act 2004 places a statutory duty on key individuals and bodies, to make
arrangements to ensure the need to safeguard and promote the welfare of children.

Similarly, there is statutory guidance (Keeping Children Safe in Education 2022) for schools
and colleges on safeguarding children and safer recruitment. These statutory provisions
extend to third party service providers who undertake work for these bodies.

Key bodies covered by the duty include local authorities, education providers, the police,
the probation service, NHS bodies, Governors/Directors of Prisons, Directors of Secure
Training Centres and Young Offender Institutions. Mitie, as a contractor delivering services
to these bodies therefore has a duty.

What do you mean by child or adult?

A child is considered to be anyone under 18 years old. A vulnerable adult is anyone 18 or
over who may not be able to take care of themselves or protect themselves from harm or
being exploited, it may include someone who,

• Is elderly and frail

• Has a mental illness including dementia
• Has a physical or sensory disability or a severe physical illness
• Has a learning disability
• Is a substance misuser
• Is homeless

What is considered as poor practice?

Examples of poor practice include,

• Spending unnecessary or excessive time alone with children and vulnerable adults
• Taking children and vulnerable adults alone to another location, on car journeys or
home
• Engaging in rough, physical or provocative games or communication style
• Allowing or engaging in inappropriate touching
• Allowing allegations to go unchallenged, unrecorded or not acted upon

In appendix 1 you will find guidelines for how you should conduct yourself when working in
an environment that brings you into contact with young or vulnerable people.

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What is considered as abuse?

Abuse is an act of oppression and injustice, exploitation and manipulation of power by those
in a position of authority. This can be caused by those inflicting harm or those who fail to act
to prevent harm. Abuse may consist of a single act or repeated acts and can occur in any
relationship; it may be an act of neglect or an omission to act.

It may occur when a child or vulnerable person is persuaded to enter into a financial or sexual
transaction to which he or she has not consented or cannot consent. Abuse is not restricted
to any socio-economic group, gender or culture. It can take a number of forms, including the
following,

• Physical abuse
• Sexual abuse
• Emotional abuse
• Bullying
• Neglect
• Financial (or material) abuse

How do I identify abuse?

It’s not always easy to recognise a situation where abuse may occur or has already taken place.
Whilst it is not a requirement for you to become an expert in recognising abuse, you must
have an awareness of indicators so that you can report concerns and allegations appropriately.

The main types of abuse are physical, sexual, psychological/emotional, neglect and financial
abuse. The abuser may be a family member, carer, someone they encounter whilst in receipt
of services, one of your colleagues or another child or vulnerable person. You must not
hesitate to report any allegations or strong suspicions of poor practice and potential abuse.

Physical abuse occurs where adults physically hurt or injure a child or vulnerable person and
examples include hitting, shaking, throwing, poisoning, burning, scalding, biting, supplying
alcohol and/or drugs. Signs to look out for,

Visible Signs:
• Injuries to any part of the body
• Children or vulnerable people who find it painful to walk, sit down, to move their
jaws or are in some other kind of pain
• Injuries which are not typical of the bumps and scrapes associated with usual
activities
• The regular occurrence of unexplained injuries
• They are frequently injured, where even apparently reasonable explanations are
given

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Behavioural Signs:
• Furtive, secretive behaviour
• Uncharacteristic aggression or withdrawn behaviour
• Compulsive eating or sudden loss of appetite
• Suddenly becoming uncoordinated
• Difficulty in staying awake
• Repeatedly absent
What to listen for:
• Listen for confused or conflicting explanations of how the injuries were sustained
• Evaluate carefully what is said and preferably document it verbatim
• Consider if the explanation is in keeping with the nature, age, and site of injury
Consider:
• What do you know about the family?
• Is there a history of known or suspected abuse?
• Has the family been under stress recently?
• Do you have concerns about the family?

Psychological / emotional abuse is the persistent emotional ill treatment of a child or

vulnerable person such as to cause severe and persistent adverse effects on emotional
development. It may involve making a child or vulnerable person feel or believe that they
are worthless or unloved, inadequate or valued only insofar as they meet the needs of
another person.

The recognition of emotional abuse is based on observations over time of the quality of
relationships between parent/carer and the child or vulnerable person. Things to watch out
for are,

Watch for parent/carer behaviours

• Poor attachment relationship with the child or vulnerable person
• Unresponsive or neglectful behaviour towards their emotional or psychological
needs
• Persistent negative comments about them
• Inappropriate or inconsistent developmental expectations
• Parental problems that supersede the child or vulnerable person’s needs
• Dysfunctional family relationships including domestic violence
Watch for child/vulnerable person behaviours:
• Emotional indicators such as low self-esteem, unhappiness, fear, distress, anxiety
• Behavioural indicators such as attention seeking, withdrawn, insecure
• Physical indicators such as failure to thrive/faltering growth, delay in achieving
developmental, cognitive or educational milestones in the case of a child

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Sexual abuse occurs when adults, male or female or other young people use children or
vulnerable adults to meet their own sexual needs and examples include all levels of sexual
activity, providing access to pornography or talking to them in a sexually explicit manner.

There may be no recognisable signs of sexual abuse, but the following indicators may be
signs that a child or vulnerable person is or has been sexually abused:
Physical signs
• Signs of blood or other discharge on under clothes
• Awkwardness in walking or sitting down
• Tummy pains
• Regression into incontinence
• Tiredness
Behavioural signs:
• Extreme variations in behaviour (e.g., anxiety, aggression, or withdrawal)
• Sexually provocative or inappropriate behaviour or knowledge that is incompatible
with the persons age and understanding
• Drawings and/or written work which are sexually explicit (indirect disclosure)
• Direct disclosure: It is important to recognise that children have neither the
experience nor the understanding to be able to make up stories about sexual assault.

Neglect occurs when an adult fails to meet the child or vulnerable person’s basic physical
and/or psychological needs. Examples of neglect may include withdrawal of food, shelter and
clothing, failing to protect from physical harm or danger or failing to access appropriate
treatment or care.

Indicators of neglect are recognisable in the child or vulnerable person, in the parent/carers’
behaviours and within the home environment.
Physical signs
• Abnormal growth including failure to thrive
• Underweight or obesity
• Recurrent infection
• Unkempt dirty appearance
• Smelly
• Inadequate/unwashed clothes
• Hunger
• Listlessness
Behavioural signs:
• Attachment disorders
• Indiscriminate friendliness
• Poor social relationships
• Poor concentration
• Developmental delays
• Low self esteem

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Environmental signs
• Insufficient food, heating and ventilation in the home
• Risk from animals in the household
• Inappropriate sleeping arrangements and inadequate bedding
• Dangerous or hazardous environment

Financially abuse the use of a person’s property, assets, income, funds or any resources
without their informed consent or authorisation and is a crime. It includes theft, fraud,
exploitation, undue pressure in connection with wills, property, inheritance or financial
transactions and the misuse or misappropriation of property, possessions or benefits.
This can be difficult to spot however, possible indicators of financial or material abuse
include,

• Missing personal possessions.

• Unexplained lack of money or inability to maintain lifestyle.
• Unexplained withdrawal of funds from accounts.
• Power of attorney or lasting power of attorney (LPA) being obtained after the
person has ceased to have mental capacity.

What should I do if child or vulnerable person

reports abuse to me?
It is important to take the following action if a child or vulnerable person decides they want
to confide or disclose to you:

• Do not promise to keep it a secret – be clear that you will have to pass on the
information
• Do listen to what they have to say
• Do not judge them or show your own emotions i.e. do not show disgust; feelings of
abhorrence or shock at what you are being told
• Do not give views about the allegations or the person about whom allegations are
being made
• Reassure the them that they have done the right thing in speaking about what they
are experiencing
• Reassure them that whatever is happening to them is not their fault
• Take notes of what they say, if you are not able to write it down while they are
disclosing, then do so as soon as possible after they have spoken to you
• Do not ask leading or probing questions or try to investigate it further yourself –
this will be done by safeguarding professionals
• Any questions being asked should be to seek clarification only

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• Do not speak to other members of staff, colleagues, children or anyone else unless
they are professionally involved in the case, such as the designated safeguarding lead,
the police, a social worker assigned to the case etc. You must maintain
confidentiality about what has been disclosed and not share information
inappropriately.

How do I report it?

It is not your responsibility make judgements about whether or not abuse is taking place. It is
however a responsibility on all to identify and report allegations or strong suspicions of poor
practice and potential abuse. Following the correct procedure will ensure the appropriate
action is taken.

Allegations of abuse may surface in a variety of ways: from being notified directly by the child,
young or vulnerable adult to observations you might have whilst carrying out your role or via
anonymous reports. If abuse is reported, you must ensure as much information is recorded
at the time of the disclosure on the Safeguarding Alert Form which will be available on site.
The record must be confined to facts and not include personal opinion before submitting the
information. Information should include where possible:

• Name, age and date of birth of complainant

• Whether they are making a report about themselves or another individual
• Nature of the allegation including dates, times, relevant information
• Description of any injuries
• Details of witnesses

All suspicions and allegations must be reported immediately. You should inform your line
manager and the client’s designated senior member of staff for safeguarding or their deputy
who will inform the appropriate authorities. This person is sometimes known as the Child
Protection Representative or the Safeguarding Lead. It is your responsibility to know who the
correct member of staff is for safeguarding. If in doubt check with your line manager.

Any breach of this procedure may lead to you being subject to the Company disciplinary
procedure which may ultimately result in dismissal.

What should I do if I suspect abuse?

If a child or vulnerable person’s behaviour or appearance make you concerned then you
should do the following,

• Record observations. If the child or vulnerable person needs attention for physical
injury, follow accident procedures.
• Speak to the designated senior member of staff for safeguarding on your site in
private.

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• If they feel more corroboration is needed, they will have a confidential discussion
with the other workers. Observations are shared. Have other members of the team
noticed anything? Is there a consensus of concern?
• They may contact social services at this stage, or possibly other agencies for advice,
e.g. NSPCC.
• They may discuss staff concerns with the parents/carers of the child or vulnerable
person depending on the situation.
• Maintain records of observations and concern throughout the process.

What about confidentiality?

All matters relating to child protection are highly confidential and Mitie employees will share
information with the Designated Safeguarding Officer (DSO) on a strictly ‘need to know,
what and when’ basis. Concerns should never be discussed elsewhere, inside or outside of
Mitie, unless in confidential meetings organised for that purpose.

What training will I receive?

Employees who are likely to work in an environment where they will come across children
or vulnerable adults, will be required to complete the Safeguarding Children and Vulnerable
Adults training. The training is concerned with individuals knowing what signs to look for
which may indicate possible harm and knowing who to contact about a child’s safety or
welfare.

Knowledge and competency will be reviewed from time to time in the form of refresher
training via a workbook/toolbox talk. Completion of the training will be recorded locally via
a signed declaration for each employee.

Is there anything else I should know?

As part of the day-to-day most you will come into contact with children, vulnerable people
during the course of your work. It is important to remain polite and respectful towards
service users but on no account to form friendships either in person or on social media. If
service users or close relatives, such as a parent, request you to join their social media
circle, you must refrain from doing so.

To keep yourself safe from false allegations, ensure that you are never alone in a room or a
lift with a child or vulnerable person. Never offer to give lifts or gifts, no matter how small,
to child or vulnerable person. In addition, if, in your role, you need to enter changing rooms
or toilets, make sure that you knock and check that there is no-one inside. Wait till the
rooms or toilets are vacated before entering.

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Be a positive role model and professional in your behaviour towards other staff, service
users, and visitors. If any service users are rude, disrespectful or are behaving badly and no
member of client staff is present, follow the client policy and report this to the appropriate
person. It is important not to get involved in any dispute or argument with a child or
vulnerable person.

Need more info?

If you need further advice you can contact People Support via AskHR on
People Hub or call 0330 1234 005 to speak to an Advisor

The Employee Assistance Programme (EAP) offers confidential

advice, and you can access their support by calling 0800 1116 387You
can also access the online portal for further guidance and support: http://my-
eap.com/login

Organisation code: mitiewell

Mitie online GP service 24/7- 0345 3193107

Employee Wellbeing

We also have an intranet site dedicated to wellbeing. You can access this site
via the Celebration Hub. You will find information on healthy eating as well as
mental, physical and financial wellbeing. If any of your team members are
experiencing mental health issues, you will find a list of our Mental Health First
Aiders who will be able to talk you through the resources that are available to
you.

Optima Occupational Health - Wellbeing portal

Further reading:
____________________________________________________________________

Disciplinary procedure (MG(HR)567)

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Appendix 1

Code of Conduct for working with young or

vulnerable people
This Code of Conduct sets out clear guidelines for all Mitie employees working in an
environment that brings them into contact with young or vulnerable people. This code
should be read in conjunction with the MITIE Employee Handbook MG(HR)500HB

The following guidelines apply:

• Never use toilets designated for young or vulnerable people

• Always ensure the relevant CRB/Disclosure Scotland checks have been carried out
for visitors to the site, where applicable
• Do not confront young or vulnerable people who are involved in unruly behaviour;
report any incidents to members of client staff immediately
• Report any accidents involving young or vulnerable people to members of client staff
immediately and follow our accident procedures
• Never use offensive language whilst at work
• Never contact young or vulnerable people by mobile phone or social media or allow
your mobile phone or social media accounts to be used by them.
• Dialogue with young or vulnerable people should be kept to the minimum that is
necessary in course of duties
• Never accept gifts from young or vulnerable people or the client without the prior
approval from your line manager
• Never smoke on site
• Be presentable at all times, wearing your issued uniform and protective clothing
whilst in work
• Do not lend or provide Mitie’s tools, equipment or chemicals to any non-authorised
personnel
• Do not leave Mitie’s tools, equipment or chemicals unattended when the site is
occupied
• The plant rooms, cleaners’ cupboards, riser cupboards etc. should be locked when
not in use
• Wear your Mitie ID badge at all times

Please contact your line manager should any further clarification be required. Employees who
breach this code will be subject to the Company Disciplinary procedure up to and including
dismissal.

Mitie Group Plc | Safeguarding Procedure | November 2022