Safeguarding Adults at Risk Policy
1. Purpose and principles
AMCT is committed to protecting adults who may be at risk of abuse or neglect while respecting dignity, autonomy, consent and personal choice. Safeguarding is everyone’s responsibility. The Trust will act proportionately, listen to the adult’s wishes and cooperate with statutory services.
2. Scope and context
This policy applies to trustees, staff, volunteers and contractors and covers adults attending tours, events, volunteering, staying overnight or participating in community programmes. AMCT is a heritage charity and does not ordinarily provide regulated care. External service providers retain their own safeguarding duties; reporting and premises responsibilities must be agreed.
3. Who is an adult at risk?
Under section 42 of the Care Act 2014, adult safeguarding enquiries concern adults aged 18 or over who have needs for care and support, are experiencing or at risk of abuse or neglect, and because of those needs are unable to protect themselves. Age, disability or diagnosis alone does not establish that a person meets this test. AMCT will still respond appropriately to welfare concerns outside the statutory threshold.
4. Legal framework and six principles
This policy is informed by the Care Act 2014 and statutory guidance, Mental Capacity Act 2005, Human Rights Act 1998, Equality Act 2010, UK data protection law and Charity Commission guidance. The six adult safeguarding principles are empowerment, prevention, proportionality, protection, partnership and accountability.
5. Responsibilities
Trustees retain governance responsibility; Helen Rana is the trustee safeguarding contact and alternative escalation route. Christine Olivieri, Chief Executive, is DSL, responsible for receiving and recording concerns, seeking statutory advice and arranging referrals. The DSL does not investigate allegations personally. All personnel must act on concerns and maintain appropriate professional boundaries.
6. Types and signs of abuse
Potential categories include physical, sexual, psychological, financial or material, discriminatory, organisational and domestic abuse, modern slavery, neglect and acts of omission, and self-neglect. Examples may include coercion, unexplained financial transactions, threatening behaviour, isolation, humiliation, poor care or unsafe living conditions. Staff should not make diagnoses or investigate; they should record and report.
7. Consent, capacity and making safeguarding personal
Ask the adult what they want to happen, involve them in decisions and ordinarily seek consent before referral. Capacity is decision-specific and presumed unless established otherwise. A person is not incapable merely because they make an unwise decision. If capacity is in question, seek appropriate advice and follow Mental Capacity Act principles. Information may be shared without consent where justified by serious risk, coercion, risk to others, suspected serious crime or another lawful basis; document the reasons.
8. Code of conduct and inclusive practice
Respect privacy, choice, dignity and communication needs. Do not exploit financial, emotional or other dependencies; avoid inappropriate gifts, private relationships or personal social-media contact. Never carry out intimate care, medication administration or specialist support outside the role and competence of AMCT personnel. Assess access, steps, surfaces, seating, evacuation and communication needs for events and volunteering; agree arrangements with accompanying carers or organisers where appropriate.
9. Responding and reporting
Call 999 if someone is in immediate danger. Otherwise, listen, ask only what is necessary to understand immediate safety, avoid promises of secrecy, do not confront an alleged abuser and write a factual record. Inform the DSL promptly; where unavailable or implicated, contact Helen Rana or adult safeguarding services directly. Seek advice or refer to Wiltshire adult safeguarding as appropriate. Record the adult’s wishes, consent position, decisions, referrals and follow-up.
10. Concerns about people in positions of trust
Report concerns involving staff, volunteers, contractors or trustees to an unimplicated safeguarding contact. Seek advice from Wiltshire adult safeguarding about relevant persons-in-positions-of-trust arrangements. Consider proportionate protective action and employment, DBS and Charity Commission reporting duties; do not begin an internal investigation that might compromise statutory processes.
11. Recruitment, training and information governance
Use proportionate safer recruitment, references, role-specific DBS eligibility assessments, safeguarding induction and ongoing supervision. General awareness refresher training is normally every two years; the DSL receives additional training. Maintain confidential, factual records with restricted access and appropriate retention. Share information only when lawful and necessary.
12. Review
The Board reviews the policy annually and after significant incidents or changes. Read with the AMCT Safeguarding Reporting Procedure and relevant risk assessments. Key safeguarding contacts
AMCT DSL: Christine Olivieri, Chief Executive (contact via AMCT office).
Alternative trustee safeguarding contact: Helen Rana
Emergency: 999.
Wiltshire Children’s Integrated Front Door: 0300 456 0108.
Wiltshire Adult Safeguarding: 0300 456 0111.
Wiltshire Emergency Duty Service: 0300 456 0100.
Reference resources
Resource Centre: https://www.resourcecentre.org.uk/information/safeguarding/
Charity Commission: https://www.gov.uk/guidance/safeguarding-duties-for-charity-trustees
Wiltshire Council safeguarding: https://www.wiltshire.gov.uk
Safeguarding Children and Young People Policy
1. Purpose and principles
AMCT is committed to safeguarding and promoting the welfare of every child under 18 who visits The Hall, uses the grounds or participates in Trust activities. Every child has an equal right to protection regardless of disability, background, identity or circumstances. The welfare of the child is paramount. We will listen to children, act promptly on concerns and work with statutory safeguarding agencies.
2. Scope and activities
This policy applies to trustees, employees, volunteers, contractors and anyone acting for AMCT. Relevant settings include house and garden tours, heritage exhibitions, school visits, family events, community activities, holiday accommodation and the estate grounds. Parents, carers and teachers ordinarily supervise children during public visits unless the Trust expressly agrees to provide supervision. Where nursery, Forest School or other independent providers operate on the estate, their own safeguarding duties remain in place; AMCT will agree site safety, escalation and information-sharing arrangements in writing.
3. Legal and guidance framework
This policy is informed by the Children Acts 1989 and 2004, current Working Together to Safeguard Children statutory guidance, relevant safeguarding partnership procedures, the Equality Act 2010, UK data protection legislation and Charity Commission safeguarding guidance. The DSL will check for updates at annual review.
4. Responsibilities and accountability
The Board of Trustees retains ultimate safeguarding oversight, approves the policy, monitors risk and considers regulatory reporting. Helen Rana is the trustee safeguarding contact and alternative escalation route. Christine Olivieri, Chief Executive, is the Designated Safeguarding Lead (DSL). She receives concerns, makes or coordinates referrals, safeguards records, arranges training and reports appropriately to trustees. The DSL must not conduct an investigative interview or attempt to establish whether abuse occurred.
Every worker and volunteer must follow this policy, maintain safe boundaries, report concerns immediately and cooperate with safeguarding agencies. Where the DSL is implicated or unavailable, contact Helen Rana or statutory services directly. Where both contacts are implicated or unavailable, contact statutory services directly.
5. Types and indicators of abuse
Child abuse can include physical, emotional and sexual abuse; neglect; domestic abuse exposure; online abuse; grooming; exploitation; bullying and harmful practices. Possible indicators include unexplained injury, fearfulness, withdrawal, disclosure, neglect of basic needs or concerning interactions. Indicators are not proof. Record observations objectively and report concerns without attempting to investigate.
6. Code of conduct and safe practice
Treat children with respect, use appropriate language and avoid favouritism, humiliation or discrimination. Never arrange private contact through personal social media, offer inappropriate gifts, or take photographs on personal devices contrary to Trust rules. Avoid isolated one-to-one contact; where unavoidable, keep interactions observable and report unusual circumstances. Physical contact must be necessary, appropriate and consent-aware. Never promise confidentiality to a child who discloses harm. Activity leaders must assess hazards including historic stairs, uneven surfaces, water, garden tools, vehicles, restricted rooms and weather. Agree supervision ratios and collection arrangements with schools or organisers before supervised activities. Children must not enter restricted spaces unsupervised. Seek suitable consent and follow data protection requirements for photography and publicity.
6A. Photography, video, social media and parental consent
AMCT will obtain and record appropriate, informed permission from a parent or person with parental responsibility before publishing an identifiable image or video of a child on its website, social media channels, printed publicity or other promotional material. Consent must explain the intended uses, be voluntary and capable of withdrawal for future use. Consent to attend an event does not constitute consent to publicity.
For school and organised group visits, AMCT will agree photography arrangements with the group leader in advance and obtain confirmation that the necessary parental permissions cover the proposed use by AMCT; where this cannot be confirmed, identifiable images must not be published. Staff and volunteers must follow any photography restrictions communicated by parents, carers or group leaders.
Photographs must not identify children by full name, school, precise location or other personal details unless there is a specific, justified and authorised reason. Images must be appropriate, stored securely, accessed only by authorised personnel and retained in line with the Trust’s data protection arrangements. Staff and volunteers must not post identifiable images of children taken through Trust activities on personal social media accounts. Requests to remove an image must be passed promptly to the Chief Executive for action where reasonably possible.
6B. Lost or missing children on the estate
If a child is reported missing, the staff member or volunteer receiving the report must immediately alert the event lead and Designated Safeguarding Lead (DSL), record the child’s description, last known location and time last seen, and identify the parent, carer or group leader responsible for the child. A coordinated search must begin promptly, with staff allocated to check relevant areas of The Hall and grounds, including entrances and exits, toilets, event spaces and higher-risk locations such as water features, roads, outbuildings and restricted areas. Staff must not place themselves or others at risk during the search.
The responsible adult should be kept informed and, where practicable, a staff member should remain at an agreed meeting point. If there is reason to believe the child is in immediate danger, may have left the estate, may have been taken, or cannot be located promptly, call 999 without delay. There is no mandatory waiting period before contacting the police. The DSL must ensure an incident record is completed, including the search actions, times, persons notified and outcome.
If a child is found without their parent, carer or group leader, a staff member should reassure the child, remain with them in a safe, visible place and inform the DSL or event lead. Wherever practicable, two authorised adults should be present; staff should not take the child off-site or into a secluded room. The child must be reunited only after reasonable checks establish the adult’s identity and responsibility for them. Any suspicious circumstances or safeguarding concerns must be referred in accordance with this policy.
Event risk assessments and briefings must specify the meeting point, staff communication arrangements and responsibilities for lost-child incidents. The procedure should be reviewed after any incident to identify improvements.
7. Responding to a disclosure or concern
If a child is in immediate danger, call 999. Otherwise, listen calmly, take the child seriously, do not ask leading questions, do not confront the alleged perpetrator and explain that information may need to be shared to keep them safe. Record the child’s own words where possible, the date, time, context and any immediate action. Report promptly to the DSL; do not wait if urgent action is needed. The DSL will contact Wiltshire Children’s Services or police as appropriate, record the rationale and follow agency advice. Anyone may refer directly if necessary.
8. Allegations against adults working with children
Report any allegation or concern about an employee, volunteer, contractor or trustee promptly to the DSL, or to Helen Rana if it concerns the DSL. Where relevant, seek advice from the local authority designated officer (LADO) before conducting an internal investigation. Take proportionate steps to protect children, preserve evidence and avoid compromising external enquiries. Consider police, DBS, regulator and Charity Commission reporting obligations where applicable. Do not assume suspension is automatic; decisions should follow appropriate advice.
9. Safer recruitment and training
Use role descriptions, identity and reference checks, proportionate interview processes, induction and supervision. Determine DBS eligibility and level by actual duties; enhanced checks are not universal. Provide all relevant staff and volunteers with safeguarding induction and a clear reporting route. General awareness refresher training is normally renewed every two years; the DSL receives role-specific training.
Maintain a training and checks register.
10. Information sharing, records and whistleblowing
Keep dated, factual records securely and separately from routine visitor records. Limit access and retain information in accordance with an approved retention schedule. Share information lawfully and proportionately to protect children; data protection rules do not prevent justified safeguarding sharing.
Staff can raise concerns directly with Helen Rana, statutory authorities or the Charity Commission where appropriate without fear of retaliation.
11. Review and related procedures
Trustees review this policy annually and after serious incidents or material changes. Read alongside the Safeguarding Reporting Procedure, incident form, recruitment procedures, photography/privacy arrangements, risk assessments and external-provider agreements.
Key safeguarding contacts
AMCT DSL: Christine Olivieri, Chief Executive (contact via AMCT office).
Alternative trustee safeguarding contact: Helen Rana (contact details via AMCT office)
Emergency: 999.
Wiltshire Children’s Integrated Front Door: 0300 456 0108.
Wiltshire Adult Safeguarding: 0300 456 0111.
Wiltshire Emergency Duty Service: 0300 456 0100.
Reference resources
Resource Centre: https://www.resourcecentre.org.uk/information/safeguarding/
Charity Commission: https://www.gov.uk/guidance/safeguarding-duties-for-charity-trustees
Wiltshire Council safeguarding: https://www.wiltshire.gov.uk
Equality, Diversity and Inclusion Policy
1. Policy statement and purpose
The Alex Moulton Charitable Trust (AMCT) is committed to equality of opportunity, dignity, diversity and meaningful inclusion in its employment, volunteering, governance, heritage interpretation, public access and charitable activities. Everyone should be treated fairly and respectfully, and should be able to participate without unlawful discrimination, harassment or victimisation. We recognise that equal treatment does not always produce equitable access. We will identify barriers, make reasonable adjustments where required, and consider proportionate practical measures to widen participation.
This policy sets out standards, responsibilities, reporting routes and how we will review our progress.
2. Scope
This policy applies to trustees, employees, workers, volunteers, contractors and anyone acting for AMCT. It also guides our treatment of visitors, overnight guests, school and community groups, event participants, suppliers, tenants and external activity providers, insofar as AMCT controls the relevant activity or service.
Third-party organisations operating independently on the estate remain responsible for their own employment and service provision duties. AMCT will set appropriate expectations in agreements and cooperate on access and complaints relating to shared spaces.
3. Legal and good-practice framework
AMCT will comply with applicable UK law, including the Equality Act 2010, relevant employment legislation, data protection law and the duty to take reasonable steps to prevent sexual harassment of employees. The Equality Act protects against discrimination relating to age, disability, gender reassignment, marriage and civil partnership (in employment), pregnancy and maternity, race, religion or belief, sex and sexual orientation. The precise protections vary by context.
We will consider direct and indirect discrimination, discrimination arising from disability, failures to make reasonable adjustments, harassment and victimisation. Lawful positive action and occupational requirements will be considered only where the legal conditions are met. This policy does not imply that every part of a Grade I listed building can be physically altered; access barriers must still be assessed and reasonable alternatives considered.
4. Roles and accountability
Board of Trustees: approves the policy, sets expectations, receives annual assurance and ensures material risks and complaints are addressed.
Chief Executive: leads implementation, allocates responsibilities, reviews accessibility and employment practices, maintains an action plan and reports significant matters to trustees.
Managers and activity leads: plan inclusive activities, consider adjustments, address inappropriate behaviour and escalate complaints.
Employees, volunteers and trustees: act respectfully, complete relevant induction, challenge or report unacceptable behaviour and protect confidentiality.
External providers: comply with applicable law and agreed AMCT site standards; identify a contact for access and inclusion concerns.
5. Dignity, conduct and preventing harassment
Bullying, discriminatory remarks, exclusion, sexual harassment, unwanted conduct, retaliation against complainants and other inappropriate behaviour are not acceptable. This includes in-person conduct, electronic messages, social media, work events and interactions with visitors or third parties.
AMCT will take reasonable steps to prevent sexual harassment at work, including assessing risks arising from lone working, public-facing roles, events and third-party contact; setting standards; providing proportionate training; and responding promptly to reports. Concerns will be handled fairly, with support for affected people and appropriate action under relevant procedures.
6. Recruitment, employment and development
Use clear, role-related criteria and inclusive recruitment advertising; offer reasonable adjustments during recruitment and employment.
Base appointment, pay, training, development, flexible working, performance and progression decisions on fair, documented criteria.
Consider accessibility, caring responsibilities, religion or belief and other individual needs in scheduling and workplace arrangements, subject to legitimate operational requirements.
Address discrimination or harassment through appropriate grievance, disciplinary and safeguarding routes; protect individuals from victimisation for raising concerns.
Provide appropriate induction and periodic EDI awareness for staff, volunteers and trustees.
7. Volunteers and community participation
Volunteers are central to the Trust. Recruitment, induction, task allocation and opportunities to contribute will be fair and inclusive. We will discuss reasonable practical adjustments, accessible communication, physical task demands and alternative roles where needed. We will not assume a person cannot contribute because of age, disability or other characteristics.
For community programmes, talks, creative sessions and gardening opportunities, organisers will consider timing, affordability, accessible information, social inclusion and support needs, while ensuring that staff and volunteers do not undertake specialist care beyond their competence.
8. Visitor access, heritage and reasonable adjustments
AMCT manages a historic Grade I listed house and grounds with inherent physical constraints. We will communicate access limitations clearly and in advance, invite requests for adjustments, and consider each request individually and promptly. Possible adjustments may include alternative routes where safe, seating and rest opportunities, adapted tour formats, written or large-print information, clear signage, flexible pacing, assistance arrangements and accessible alternatives when particular rooms cannot reasonably be reached.
We will not make blanket assumptions about an individual’s abilities. Any limitation on access must be supported by a legitimate reason, such as safety or conservation requirements, and alternatives should be considered.
Assistance dogs will be considered in line with applicable equality duties and individual circumstances, including any justified restrictions.
9. Inclusive interpretation, programmes and affordability
The Trust will aim to present The Hall’s history in a balanced, respectful and accessible way, recognising varied experiences and contributions. We will seek to avoid stereotypes in exhibitions, tours, marketing and educational material. Public communications should use inclusive language and accessible formats where practicable.
Our published pricing and concession arrangements should be transparent and consistently applied. Where resources permit, we will consider discounts or tailored access for schools, SEND groups, community organisations, charities and other groups that face barriers to participation. Any concessions will be managed fairly and reviewed for effectiveness.
10. Events, external partners and suppliers
Event and activity planning will consider physical access, accessible booking information, toilet provision, signage, seating, communication needs, dietary needs where catering is offered, safeguarding, and ways to raise concerns. AMCT will clarify which adjustments it can provide and which are the responsibility of external organisers. We will seek proportionate EDI commitments from suppliers and partners, particularly those delivering public-facing activities.
11. Reporting concerns and complaints
Any person may raise an EDI concern verbally or in writing with the Chief Executive. Where the concern involves the Chief Executive, it should be raised with the Chair of Trustees or another unimplicated trustee. Complaints involving a trustee should be directed to an unimplicated trustee. Employees may also use the grievance procedure; safeguarding concerns must be handled under the safeguarding policies without delay.
AMCT will acknowledge concerns promptly, establish an impartial person to review them, consider immediate protective measures, give those involved a fair opportunity to respond, document findings and communicate an appropriate outcome. Where relevant, the Trust will explain review or escalation options. Confidentiality will be maintained as far as practicable, but absolute secrecy cannot be promised. No person should suffer retaliation for raising a genuine concern.
External complainants should be told how to contact the Trust and how their complaint will be handled. Employment tribunal time limits are generally three months less one day, subject to applicable rules and Acas early conciliation; internal procedures do not extend statutory deadlines automatically.
12. Information, monitoring and improvement
We will use proportionate evidence to assess access and inclusion, such as visitor feedback, complaints, adjustment requests, volunteer experience, training completion and accessibility reviews. Any equality monitoring information will be voluntary where appropriate, minimised, securely held and processed with a lawful basis and additional protections for special-category personal data. We will avoid publishing identifiable information about individuals or small groups.
The Chief Executive will maintain a proportionate improvement plan with owners and target dates, and provide an annual summary to trustees. Potential priorities include an accessibility information page, clearer visitor prearrival guidance, volunteer induction, event-planning checks and review of concession arrangements.
13. Related policies and review
This policy should be read alongside the safeguarding children policy, safeguarding adults policy, safeguarding reporting procedure, grievance and disciplinary procedures, complaints arrangements, health and safety, recruitment, privacy and volunteer guidance. The Board will review it at least annually and sooner after material legal, operational or organisational change