
Safeguarding is not only about children. If your charity works with people who may be vulnerable because of displacement, disability, age, crisis or circumstance, your responsibilities go further.
External Conduct Standard 4 asks charities to take reasonable steps to protect all vulnerable individuals from harm, abuse, neglect and exploitation, not only children under 18, but also elderly people, people with a disability, people affected by illness or trauma, displaced people and refugees, and communities facing poverty or marginalisation. It also covers your own staff and volunteers, particularly in isolated or high-risk locations.
Work out your risk profile first
Before you write a policy, understand what you are protecting against. Who are your beneficiaries, and what makes them vulnerable? Do your staff or volunteers have direct, one-on-one contact with them, in private settings like homes or institutions? Does your activity create a dependency relationship, housing, food or medical care, that could be exploited? And what is the local context, weak legal protections and enforcement raise the risk considerably.
Direct delivery by staff in a conflict zone with children or highly vulnerable adults is high risk. Occasional group contact delivered through a partner organisation in a lower-risk country is lower risk. Match your safeguards to where you actually sit on that spectrum, not to the most extreme scenario.
What your policy needs to cover
A safeguarding policy should state plainly that your charity has zero tolerance for abuse, exploitation and harm, and that every staff member, volunteer and partner is expected to uphold it. It should say who it applies to (staff, volunteers, trustees, partner organisations, visitors to your programmes), and define the behaviour that is prohibited.
A code of conduct should be explicit rather than vague. Always treat people with respect and maintain professional boundaries, report concerns through the proper channel, and use the two-adult rule where you can. Never engage in a sexual or romantic relationship with a beneficiary, use physical punishment, share confidential information inappropriately, or give beneficiaries your personal contact details for non-work purposes.
Screen and supervise proportionately
Run criminal background checks where they are legally available, take references that specifically ask about safeguarding concerns, and require self-disclosure of any past issues. Verify qualifications for roles that work directly with vulnerable people. The level of screening should match the risk of the role, direct contact with children or residential care warrants more than an office-based role ever will. Set out how staff working with vulnerable people are supervised, including how lone working is managed.
Make it possible to actually report a concern
This is where most charity safeguarding systems fall down. Beneficiaries, including children, need to know how to report a concern, in a format and language they understand, through more than one channel, and without fear of retaliation. Your policy should set out who receives a report, whether immediate protective action is needed, who investigates, who decides the outcome, and what gets documented. Keep reports confidential, except where someone is at immediate risk or you have a legal reporting obligation.
Your own people are part of this too
Standard 4 covers your staff and volunteers overseas as well as your beneficiaries. That means safe accommodation, adequate food and water, medical and mental health support, appropriate insurance, and a way to communicate with head office and reach help in an emergency. In higher-risk environments, that extends to security risk assessments, evacuation plans and psychosocial support after a difficult incident.
Safeguarding follows your funding through partners
If you work through overseas partners, your safeguarding responsibilities extend to what they do. Require partners to have their own safeguarding policy (or adopt yours), screen and train their own staff, and report incidents to you. Fold safeguarding into your partner due diligence and monitoring, and give yourself the contractual right to terminate for a serious safeguarding failure.
Where to go for help
See the ACNC's guidance on External Conduct Standard 4 directly.
If you need a safeguarding policy that matches your actual risk rather than a generic template, that is exactly the kind of compliance work we do. Explore our services or get in touch.
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Synergaid Team supports humanitarian organisations with practical systems, clear processes and honest advice.