Child & Vulnerable Adult Protection Policy

Innovative and Equal (Նորարար ու Հավասար, MOJ: 211.171.1242074, 'the Organisation') exists to advance the rights and welfare of children, youth and vulnerable communities across Armenia. Because our programmes bring staff, volunteers, contractors and partners into direct or indirect contact with children and vulnerable adults, the Organisation adopts this Child and Vulnerable Adult Protection (Safeguarding) Policy as a binding, non-negotiable component of its governance framework.

This Policy is grounded in the United Nations Convention on the Rights of the Child (UNCRC, 1989), to which the Republic of Armenia is a party, and in particular Articles 19 (protection from all forms of violence), 34 (protection from sexual exploitation) and 36 (protection from all other forms of exploitation). It further implements the Republic of Armenia Law on the Rights of the Child (1996, as amended), the RA Family Code, the RA Criminal Code provisions on offences against minors, and relevant Government of Armenia decrees on child welfare and guardianship. Where international and domestic standards diverge, the Organisation applies whichever standard offers the child or vulnerable adult the greater protection.

This Policy applies to every individual who acts in the name of, on behalf of, or in association with the Organisation: employees, board members, interns, volunteers, consultants, contractors, visiting researchers, donors participating in field visits, and partner-organisation personnel present at our activities. Compliance with this Policy is a condition of engagement and is referenced in every employment contract, volunteer agreement, contractor agreement and partnership memorandum the Organisation signs.

The objectives of this Policy are: to prevent harm before it occurs through careful recruitment, training and activity design; to enable early recognition and confident reporting of concerns; to ensure a swift, competent and child-centred response when concerns arise; and to hold the Organisation itself accountable through regular review and audit.

'Child' means any person under the age of 18, regardless of national age of majority, in accordance with Article 1 of the UNCRC and Article 1 of the RA Law on the Rights of the Child.

'Vulnerable adult' means any person aged 18 or over who, because of disability, mental illness, cognitive impairment, age-related frailty, displacement, extreme poverty, or dependency on others for daily care, is or may be unable to protect themselves from harm, exploitation or abuse, or to give informed consent to participation in an activity.

'Safeguarding' means the proactive measures the Organisation takes to protect children and vulnerable adults from harm, and the reactive measures it takes to respond appropriately when harm has occurred or is suspected.

'Designated Safeguarding Lead' (DSL) means the senior staff member appointed under Section 7 of this Policy with overall responsibility for safeguarding practice, reporting and liaison with authorities.

'Person of concern' means any individual whose behaviour towards a child or vulnerable adult has given rise to a safeguarding concern, whether that person is Organisation personnel, a family member, a community member or a stranger.

Physical abuse: the deliberate infliction of physical harm, including hitting, shaking, burning, or the inappropriate use of restraint.

Emotional abuse: persistent emotional mistreatment causing severe adverse effects on emotional development, including humiliation, threats, isolation, or exposure to domestic violence.

Sexual abuse: forcing or enticing a child or vulnerable adult to take part in sexual activities, including non-contact acts such as exposure to sexual material, grooming, or exploitation via digital means.

Neglect: persistent failure to meet a child's or vulnerable adult's basic physical, medical, educational or emotional needs, likely to result in serious impairment of health or development.

Financial abuse: theft, fraud, exploitation or improper use of a vulnerable person's funds, property or assets, including coercion regarding wills, benefits or donations.

Online abuse: grooming, cyberbullying, sextortion, non-consensual sharing of images, or exposure to harmful content facilitated through the internet, social media or mobile devices, including any misuse of Organisation communication channels.

The Organisation operates a policy of zero tolerance towards any form of abuse, exploitation or harm to a child or vulnerable adult, committed by any person associated with the Organisation, in any context, on or off Organisation premises, during or outside working hours.

Any substantiated breach of this Policy by staff, board members, volunteers or contractors will result in immediate suspension pending investigation, and, where the investigation confirms wrongdoing, in dismissal, termination of contract, and referral to the police and to the RA Ministry of Justice. There are no exceptions for seniority, length of service, donor relationship or programmatic value.

The Organisation will never delay reporting a credible safeguarding concern in order to protect its own reputation, funding relationships or programme continuity. The welfare of the child or vulnerable adult always takes precedence over institutional interests.

All prospective staff, volunteers, interns and contractors whose role involves any contact with children or vulnerable adults must complete the Organisation's safer recruitment process before being confirmed in post.

This process requires: (a) a valid police clearance certificate (no criminal record certificate) issued within the preceding six months, or, for foreign nationals, an equivalent certificate from their country of residence together with an Armenian police clearance covering the period of residence in Armenia; (b) two independent character and competence references, at least one from a previous employer or supervisor in a role involving children or vulnerable adults, obtained directly by the Organisation and never via the candidate; (c) a structured interview that includes safeguarding-specific questions probing the candidate's understanding of appropriate boundaries, their motivation for working with children or vulnerable adults, and their response to hypothetical scenarios involving disclosure or suspected abuse; (d) verification of identity documents and, where relevant, professional qualifications; and (e) a signed acknowledgement of this Policy and the accompanying Behaviour Code.

Gaps in employment history, reluctance to provide references, evasive answers to safeguarding questions, or any indication of prior disciplinary action involving children or vulnerable adults will be explored fully before any appointment decision is made, and may result in the application being declined.

Safer recruitment checks are repeated every three years for continuing personnel in child-facing or vulnerable-adult-facing roles, and a fresh police clearance certificate is required at each renewal.

One-adult rule: no member of staff or volunteer may be alone with a single child or vulnerable adult in a closed or unobserved space. At least two authorised adults, or an open, observable setting, must be present at all times during Organisation activities.

Transport: children and vulnerable adults may only be transported by Organisation personnel with prior written parental or guardian consent, using a vehicle driven by a background-checked adult, with a second adult present wherever practicable, and with the route and timing recorded before departure.

Physical contact: physical contact must be limited to what is necessary, appropriate, and requested or clearly welcomed by the child or vulnerable adult, such as assisting a person with a mobility impairment. Contact that could be perceived as intimate, secretive or inappropriate is strictly prohibited.

Digital contact and photography: personnel must not contact children or vulnerable adults via personal social media accounts or personal phone numbers; all digital communication for programme purposes must occur through Organisation-approved channels and be visible to a supervisor. Photography or video of a child or vulnerable adult requires prior written consent from the person and, for a minor, their parent or guardian, and images must never be published in a way that identifies a child's location, school or home address without explicit consent.

Personnel must not accept gifts from, or give personal gifts to, individual children or vulnerable adults; must not develop exclusive personal relationships outside the Organisation's programmes with people they meet through their role; must report immediately any physical injury or unusual behaviour observed in a child or vulnerable adult; and must never make a promise of confidentiality when a child or vulnerable adult begins to disclose a concern.

Before any activity involving children or vulnerable adults — a workshop, a field visit, a residential camp, an online session or a public event — the responsible programme manager must complete a written risk assessment identifying: the nature and location of contact, the ratio of authorised adults to children or vulnerable adults required, transport and venue risks, medical and dietary needs, digital communication arrangements, and emergency contact procedures.

Residential or overnight activities require an enhanced risk assessment covering sleeping arrangements (never sharing a room between an adult and an unrelated child), night-time supervision rotas, and a written incident-response plan, all of which must be approved by the Designated Safeguarding Lead at least two weeks before the activity.

Risk assessments are living documents: they must be revisited whenever the nature of an activity changes, following any incident, and at minimum annually for recurring programmes.

Any person — staff, volunteer, contractor, beneficiary, family member or member of the public — who has a concern, suspicion or disclosure regarding the safety of a child or vulnerable adult must report it immediately, and in any event within 24 hours, to the Designated Safeguarding Lead (DSL), a senior staff member appointed by the Executive Director and named in the Organisation's internal directory and on notice boards at all programme sites.

Reports may be made verbally or in writing, in Armenian, English or Russian, and may be made anonymously; anonymous reports will be investigated to the fullest extent possible. Staff must never investigate a concern themselves, confront the person of concern directly, or promise confidentiality to the reporter or the affected person.

Upon receiving a report, the DSL must, within 24 hours: record the report in writing using the Organisation's confidential safeguarding incident form; assess whether the child or vulnerable adult is in immediate danger, and if so, contact the police (emergency line 911/102) or emergency medical services (103) without delay; determine whether the concern meets the threshold for referral to the territorial division of social services or the Guardianship and Trusteeship authority; and inform the Executive Director, unless the Executive Director is the person of concern, in which case the Board Chair is informed instead.

Where the concern involves suspected criminal conduct, the DSL refers the matter to the police within 24 hours of assessment, regardless of whether the family or beneficiary consents, in line with mandatory reporting obligations under RA law for offences against minors.

The DSL maintains a log of every report, the actions taken, the timeline followed, and the outcome, and provides a redacted summary to the Board on a quarterly basis and an unredacted summary to the Board Chair immediately in cases of suspected criminal conduct.

The Organisation fully cooperates with the Police of the Republic of Armenia, the territorial divisions of the Unified Social Services, and the Guardianship and Trusteeship authorities in any investigation concerning a child or vulnerable adult connected to its programmes, including by providing requested records, facilitating interviews on Organisation premises, and suspending the person of concern from contact with beneficiaries pending the outcome.

The Organisation will not conduct its own parallel disciplinary process in a manner that could compromise a criminal investigation, but may take interim protective measures, such as suspension with pay, immediately upon referral.

Information about a safeguarding concern is shared strictly on a need-to-know basis: with the DSL, the Executive Director or Board Chair as appropriate, relevant authorities, and, where necessary, the individual's own legal guardian, unless the guardian is the person of concern.

All safeguarding records are stored in a locked, access-restricted file (physical and encrypted digital) separate from general personnel or beneficiary files, retained for a minimum of ten years or until the affected child reaches the age of 28, whichever is longer, in line with statute of limitations considerations for offences against minors, and are never disclosed to the media or the general public.

The Organisation guarantees that no one who raises a genuine safeguarding concern in good faith will suffer retaliation, demotion, harassment or any other detriment as a result, even if the concern is not ultimately substantiated.

The DSL offers the reporter access to confidential emotional support, keeps them informed of the general progress of the case to the extent consistent with confidentiality obligations, and provides a named point of contact throughout the process.

All personnel with any contact with children or vulnerable adults must complete safeguarding induction training before starting their role, and refresher training every 12 months thereafter, covering this Policy, recognising abuse, the reporting procedure, and the Behaviour Code.

The DSL and members of senior management complete an enhanced safeguarding course, delivered by a recognised child-protection training provider, every 24 months, and the Organisation maintains a training register documenting attendance and assessment outcomes for every staff member and volunteer.

This Policy, together with the effectiveness of its implementation, is audited annually by the Board's Governance and Risk Committee, which reviews the safeguarding incident log, training register, safer recruitment records and any external assessments, and reports its findings and recommendations to the full Board.

The Board approves any amendments to this Policy, which are then communicated to all personnel within 30 days and incorporated into the next scheduled training cycle. This Policy was last reviewed on the date shown above and remains in force until superseded.