Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
DIRECTORY  
ACKNOWLEDGEMENT BY HOST FAMILY .........................................................4  
RECORD KEEPING .......................................................................................27  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
CONTACT DETAILS FOR LSP AND LADO WHERE THE GUARDIANSHIP  
ORGANISATION IS LOCATED.........................................................................30  
CONTACT DETAILS FOR LSPs AND LADOs ACROSS THE AREAS THAT COMPASS  
CULTURE AND EDUCATION OPERATES.........................................................30  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Compass Culture and Education Ltd.  
Safeguarding and Child Protection Policy  
POLICY STATEMENT  
Compass Culture & Education Ltd recognises its responsibility to safeguard and promote the welfare  
of every child in its care. We acknowledge that “it could happen here”. The safety and best interests  
of the child are paramount. We provide an environment in which children feel safe, heard, valued  
and respected, and in which concerns are acted on promptly.  
The purpose of this policy is to provide staff, volunteers and homestays with the framework they  
need in order to keep children safe and secure whilst they are in our care. The policy also informs  
parents, agents and partner schools how we will safeguard their children whilst they are in our care.  
This policy draws on Keeping Children Safe in Education 2026 (KCSIE 2026), Working Together to  
Safeguard Children 2026, the Children Acts 1989 and 2004 and relevant safeguarding, equality and  
data protection requirements. KCSIE applies directly to schools and colleges; Compass applies its  
relevant safeguarding principles to the guardianship and homestay context in line with AEGIS Quality  
Standards (September 2026).  
KEY SAFEGUARDING CONTACT DETAILS  
Role  
Name  
Telephone Number  
07743 386699  
Email  
Yuexuan Wang  
(Sunny)  
Designated Safeguarding Lead (DSL)  
Deputy Designated Safeguarding Lead (DDSL)  
Tianlun Liu (Tina)  
Lu Jin (Lucy)  
07405 844198  
24-hour emergency contact (routes  
safeguarding to DSL/DDSL)  
07912 847858  
CHILD PROTECTION PRINCIPLES  
The following principles underpin our provisions and practices in relation to safeguarding and child  
protection:  
Registered in England No. 9024815  
 
 
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Compass Culture and Education will provide a safe and secure environment for all  
students;  
Homestays and transfer companies provide a safe and secure environment for all  
students;  
All students feel safe, secure and protected from harm;  
All students know who to turn to for help, advice or support, can access services  
confidentially, quickly and easily and have access to 24-hour support;  
The company director of the company has overall responsibility and accountability for the  
safeguarding and welfare of the students;  
All staff, homestays and volunteers share in the responsibility to protect students from  
harm, remain vigilant in identifying safeguarding and child protection issues and to follow  
policies and procedures relating to safeguarding and child protection;  
Students and staff have effective means by which they can raise child protection concerns  
or report issues;  
Staff have at least one reliable means to contact all students quickly and directly;  
Staff are aware of the medical or learning needs of individual students via the Student  
Record and these are shared with the homestay on a need to know basis;  
In cases where the whereabouts of a student under Compass Culture and Education is not  
known or the student is believed to be at risk of harm, procedures to locate the student by  
the safest and quickest means possible, or secure the safety of the student will be invoked  
immediately by following the Missing Student policy;  
The company has procedures in place that enable child protection concerns and incidents  
to be dealt with promptly and effectively and in line with relevant legislation.  
Compass Culture and Education is committed to the protection of all children in its care. We are  
committed to safeguarding student welfare and undertake rigorous checks on all who work with us  
and we expect all staff, volunteers and homestays to share this commitment.  
Safeguarding students is the responsibility of us all, including full-time, part-time, contracted, agency  
and volunteer staff including those who do not have cause to come into direct or regular contact  
with students in order to carry out their daily duties. It also applies to those who provide homestay  
accommodation for our students and third party contractors.  
When any safeguarding concern arises, Compass will use a child-centred, coordinated approach,  
listen to the child and take their wishes and feelings into account while acting in their best interests.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Children receive age-appropriate guidance in the Student Handbook and at induction on staying  
safe, contacting their guardian, reporting concerns and obtaining 24-hour help. Disclosures are  
treated seriously and information is shared only as appropriate for safety.  
All staff and homestays should be aware that children may not feel ready or know how to tell  
someone that they are being abused, exploited, or neglected, and/or they may not recognise their  
experiences as harmful. This should not prevent staff from having a professional curiosity and  
speaking to the DSL if they have concerns about a child.  
Staff and homestays should build trusted relationships with children and understand barriers to  
disclosure, including language, culture, disability, fear, embarrassment or dependence on adults.  
They must retain professional curiosity and refer concerns even if a child is not ready to disclose  
abuse.  
The safety and welfare of children, or Child Protection, means protecting children from physical,  
emotional or sexual abuse or neglect where there is an identified risk. Safeguarding is the  
minimisation of the risk to children from all forms of child abuse including for example:  
Child sexual exploitation  
Child on child abuse  
Radicalisation and extremism  
Female genital mutilation  
Physical, emotional, sexual abuse or neglect  
Domestic abuse  
Online abuse  
Bullying and cyber bullying  
We aim to ensure that the students in our care experience at all times a caring and secure  
environment in which they feel safe, respected and valued. In pursuit of this aim, Compass Culture  
and Education undertakes the following:  
1. We ensure that we lead from the top by ensuring that our Director has the appropriate  
safeguarding knowledge and involvement in the procedures we have in place. This includes  
having oversight of arrangements.  
2. Training is provided for all staff and homestays to a level appropriate for their role (see  
training section below);  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
3. We promote an environment of trust, openness and clear communication between  
students, school and Compass Culture and Education staff and our Homestays, so that  
student welfare, safety and pastoral care is recognised as the top priority;  
4. We respond to any reported allegation or suspicion of child abuse in accordance with the  
Compass Culture and Education procedures as outlined below;  
5. Compass applies safer recruitment, suitability and appropriate DBS and Children’s Barred  
List checks for staff, homestays and contractors as applicable to their duties, eligibility and  
regulated activity. No person is treated as suitable solely because they are supervised.  
Details and evidence are maintained under the Safer Recruitment Policy.  
6. We maintain links with the appropriate agencies who have a statutory responsibility to  
deal with child welfare and child protection concerns.  
If you believe a child is at risk of abuse, neglect or exploitation, report your concern IMMEDIATELY to  
the DSL or DDSL. For immediate danger call 999 first. The 24-hour emergency contact can alert the  
DSL/DDSL outside office hours. Do not wait until the next working day or assume another person has  
reported.  
24-hour safeguarding escalation: DSL Yuexuan Wang (Sunny) — 07743 386699; DDSL Tianlun Liu  
(Tina) — 07405 844198; 24-hour emergency contact Lu Jin (Lucy) — 07912 847858. Lucy receives  
out-of-hours emergency calls and must promptly alert the DSL/DDSL. If neither can be reached and a  
child is at risk, report directly to statutory services rather than waiting.  
Organisation contact details and urgent reporting routes must be communicated to children,  
parents, schools, staff, volunteers and homestays, with staff briefed on what to do when the DSL is  
unavailable.  
SUPPORTING PROCEDURES AND DOCUMENTS  
This policy is to be read in conjunction with the following policies and documents:  
Anti-Bullying and Cyberbullying Policy  
Anti-Radicalisation / Prevent Policy  
Online Safety Policy and annual online safety risk assessment  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Emergency Procedure, including school removal, 24-hour coverage and medical  
emergencies  
Low-Level Concerns Policy, allegations management and self-reporting  
Missing Student Policy  
Safer Recruitment Policy  
Staff and Homestay Code of Conduct  
Whistleblowing Policy; Data Protection Policy and Privacy Notice; Student, Parent and  
Homestay Handbooks; and the mental health support and school-removal procedures set  
out within this policy.  
GOVERNMENT GUIDANCE  
Keeping Children Safe in Education 2026 (Department for Education):  
Working Together to Safeguard Children 2026 (Department for Education):  
KEEPING CHILDREN SAFE IN EDUCATION  
KCSIE 2026 Part One sets out safeguarding information for all staff. Although written for schools and  
colleges, the relevant principles inform Compass’s staff and homestay induction, training and daily  
practice. Compass expects all staff, including those not normally working directly with children, to  
read the current Part One and understand the organisation’s own safeguarding procedures.  
KCSIE 2026 no longer contains the former condensed Part One Annex A. In the 2026 edition Annex A  
contains further safeguarding information, Annex B describes the DSL role, and Annex C summarises  
changes. References in this policy use the 2026 edition.  
DEFINITIONS  
Term  
What this means  
Safeguarding and Safeguarding means providing early help and support when problems emerge;  
promoting the  
welfare of  
protecting children from abuse, neglect and exploitation inside or outside the home,  
including online; preventing impairment of their physical and mental health or  
Registered in England No. 9024815  
 
 
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
children  
development; promoting safe and effective care; and taking action to enable the best  
outcomes. All decisions must be child-centred.  
Is a part of safeguarding and promoting welfare. It refers to the activity that is  
undertaken to protect specific children who are suffering, or are likely to suffer,  
significant harm.  
Child Protection  
Designated  
Safeguarding  
Lead (DSL)  
This is the person identified as taking the lead in safeguarding matters in an  
organisation. This person (and any deputy) will be trained to a higher level.  
Prevent is the name given to part of the government's strategy to prevent terrorism by  
reducing the possibility of radicalisation.  
Prevent  
Local safeguarding arrangements bring together three statutory safeguarding partners:  
the local authority, the Integrated Care Board (ICB) and the chief officer of police. They  
coordinate safeguarding and publish local threshold and referral procedures. The 2026  
guidance also uses “LSP” to mean Lead Safeguarding Partner; Compass therefore uses  
“local safeguarding arrangements” rather than “LSP” for the partnership.  
Local multi-  
agency  
safeguarding  
arrangements  
The role of the Local Authority Designated Officer (LADO) is to coordinate all allegations  
and concerns made against a person who works with children.  
LADO  
Children  
‘Children’ includes everyone under the age of 18.  
WHAT IS ABUSE AND NEGLECT?  
Knowing what to look for is vital to the early identification of abuse and neglect. All staff  
and homestays should be aware of indicators of abuse and neglect so that they are able  
to identify cases of children who may be in need of help or protection. If staff or  
homestays are unsure, they should always speak to the DSL (or DDSL).  
All staff and homestays should be aware that abuse, neglect and safeguarding issues are  
rarely stand-alone events that can be covered by one definition or label. In most cases,  
multiple issues will overlap with one another.  
Contextual safeguarding: risk may arise beyond the child’s family or school, including in  
homestays, local communities and online. Risks include sexual violence, harassment,  
exploitation, teenage relationship abuse (including stalking), criminal or financial  
exploitation, serious violence, organised criminal activity, county lines and radicalisation.  
Staff and homestays refer concerns to the DSL/DDSL and support appropriate inter-agency  
action.  
Technology is a significant component of safeguarding. Harms can occur online and offline  
together, including cyberbullying, misogynistic or discriminatory messages, grooming,  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
coercion, non-consensual making or sharing of nudes or semi-nudes, and AI-  
generated/deepfake sexual imagery. All such reports require a safeguarding response; staff  
must not forward images or carry out their own investigation.  
TYPES OF ABUSE AND NEGLECT  
The following definitions are informed by KCSIE 2026, Part One. They should be read together with  
the current guidance, not as a substitute for it.  
Abuse is the maltreatment of a child by causing harm or failing to prevent it. It may occur in the  
family, community, school, homestay or online. Harm can include witnessing the ill-treatment of  
others or child-to-parent/caregiver abuse, as well as direct physical, emotional or sexual abuse.  
Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or  
scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also  
be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a  
child.  
Emotional abuse is persistent emotional maltreatment causing serious adverse effects on  
development. This can include belittling, name-calling, repeated criticism, humiliation, intimidation,  
silencing a child, exposure to domestic abuse, bullying and other harmful behaviours, online or  
offline.  
Sexual abuse includes forcing, causing or inciting a child to take part in sexual activities, with or  
without physical contact, whether or not the child understands what is happening. It includes sexual  
assault, penetration offences, sexualised touching, grooming, creation or sharing of sexual images,  
and online-facilitated offences. A child under 13 cannot consent to sexual activity; sexual activity  
with a child under 16 raises specific criminal offences. Staff refer any concern immediately to the  
DSL/DDSL and do not conduct investigative interviews.  
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to  
result in serious impairment of health or development. This can include lack of adequate food,  
clothing, shelter, safe supervision, medical care, medication or response to emotional needs.  
Health, disability, additional needs, language barriers or caring responsibilities may increase  
vulnerability or create additional barriers to disclosure. Such circumstances must not be assumed to  
explain away indicators of abuse.  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
(For specific types of abuse, please see the additional information at the end of this policy).  
SIGNS OF ABUSE AND NEGLECT  
The following information has been taken from the NSPCC website https://www.nspcc.org.uk/what-  
is-child-abuse/types-of-abuse/.(This website page also includes further details on other specific signs  
of abuse including bullying and cyberbullying, child sexual exploitation, child trafficking, criminal  
exploitation and gangs, domestic abuse, FGM, grooming, non-recent abuse, and online abuse.)  
Common signs  
The NSPCC list the following as common signs that there may be something concerning happening in  
a child’s life include:  
unexplained changes in behaviour or personality  
becoming withdrawn  
seeming anxious  
becoming uncharacteristically aggressive  
lacks social skills and has few friends, if any  
poor bond or relationship with a parent  
knowledge of adult issues inappropriate for their age  
running away or going missing  
always choosing to wear clothes which cover their body  
These signs don’t necessarily mean that a child is being abused, there could be other things  
happening in their life which are affecting their behaviour – but we can help you to assess the  
situation.  
You may also notice some concerning behaviour from adults who you know have children in their  
care, which makes you concerned for the child/children’s safety and wellbeing.  
Indicators of Physical Abuse  
Bumps and bruises don't always mean a child is being physically abused. All children have accidents,  
trips and falls. And there isn't just one sign or symptom to look out for. But it's important to be  
aware of the signs.  
If a child regularly has injuries, there seems to be a pattern to the injuries or the explanation doesn't  
match the injuries, then this should be reported.  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Physical abuse symptoms include:  
bruises  
broken or fractured bones  
burns or scalds  
bite marks  
It can also include other injuries and health problems, such as:  
scarring  
the effects of poisoning, such as vomiting, drowsiness or seizures  
breathing problems from drowning, suffocation or poisoning  
Head injuries in babies and toddlers can be signs of abuse so it's important to be aware of  
these. Visible signs include:  
swelling  
bruising  
fractures  
being extremely sleepy or unconscious  
breathing problems  
seizures  
vomiting  
unusual behaviour, such as being irritable or not feeding properly  
Indicators of Emotional Abuse  
There might not be any obvious physical signs of emotional abuse or neglect. And a child might not  
tell anyone what's happening until they reach a 'crisis point'. That's why it's important to look out for  
signs in how a child is acting.  
As children grow up, their emotions change. This means it can be difficult to tell if they're being  
emotionally abused. But children who are being emotionally abused might:  
seem unconfident or lack self-assurance  
struggle to control their emotions  
have difficulty making or maintaining relationships  
act in a way that's inappropriate for their age  
The signs of emotional abuse can also be different for children at different ages.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Children might:  
use language you wouldn't expect them to know for their age  
act in a way or know about things you wouldn't expect them to know for their age  
struggle to control their emotions  
have extreme outbursts  
seem isolated from their parents  
lack social skills  
have few or no friends.  
Indicators of Sexual Abuse  
Knowing the signs of sexual abuse can help give a voice to children. Sometimes children won't  
understand that what's happening to them is wrong or they might be scared to speak out. Some of  
the signs you might notice include:  
Emotional and Behavioural signs  
Avoiding being alone with or frightened of people or a person they know  
Language or sexual behaviour you wouldn't expect them to know  
Having nightmares or bed-wetting  
Alcohol or drug misuse  
Self-harm  
Changes in eating habits or developing an eating problem  
Physical Signs  
Bruises  
Bleeding, discharge, pains or soreness in their genital or anal area  
Sexually transmitted infections  
Pregnancy  
If a child is being or has been sexually abused online, they might:  
spend a lot more or a lot less time than usual online, texting, gaming or using social  
media  
seem distant, upset or angry after using the internet or texting  
be secretive about who they're talking to and what they're doing online or on their  
mobile phone  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
have lots of new phone numbers, texts or email addresses on their mobile phone, laptop  
or tablet  
Children and young people might also drop hints and clues about the abuse  
Indicators of Neglect  
Neglect can be really difficult to spot. Having one of the signs doesn't necessarily mean a child is  
being neglected. But if you notice multiple signs that last for a while, they might show there's a  
serious problem. Children and young people who are neglected might have:  
Poor appearance and hygiene  
being smelly or dirty  
being hungry or not given money for food  
having unwashed clothes  
having the wrong clothing, such as no warm clothes in winter  
Health and development problems  
anaemia  
body issues, such as poor muscle tone or prominent joints  
medical or dental issues  
missed medical appointments, such as for vaccinations  
not given the correct medicines  
poor language or social skills  
regular illness or infections  
repeated accidental injuries, often caused by lack of supervision  
skin issues, such as sores, rashes, flea bites, scabies or ringworm  
thin or swollen tummy  
tiredness  
untreated injuries  
weight or growth issues  
Housing and family issues  
living in an unsuitable home environment, such as having no heating  
being left alone for a long time  
taking on the role of carer for other family members  
Change in behaviour  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
becoming clingy  
becoming aggressive  
being withdrawn, depressed or anxious  
changes in eating habits  
displaying obsessive behaviour  
finding it hard to concentrate or take part in activities  
missing school  
showing signs of self-harm  
using drugs or alcohol  
PROCEDURES  
All staff, volunteers, homestays and relevant contractors receive the current DSL/DDSL details, the  
24-hour emergency escalation route, guidance on reporting concerns and access to this policy during  
induction. The safeguarding reporting route is via the DSL/DDSL; any individual may contact  
children’s social care or police directly where necessary to safeguard a child. LADO enquiries concern  
allegations about adults in positions of trust and are a separate referral route.  
Compass will self-report to AEGIS by promptly informing them of any significant safeguarding  
concerns, incidents that could be perceived as compromising or subject to misinterpretation, or  
instances where behaviour falls below expected standards. This will be done through formal  
communication channels to ensure transparency and compliance with safeguarding regulations.  
Actions when there are concerns about a child or young person  
Concern or disclosure → ensure immediate safety → inform DSL/DDSL immediately → record the  
facts → decide promptly whether to contact local authority children’s social care, police or health  
services → document advice, decisions, action and follow-up. Contact 999 for immediate danger.  
The applicable children’s social care team is the authority responsible for the child’s circumstances,  
not automatically the authority of the office.  
All staff and homestays must identify and respond to suspected abuse, exploitation or  
neglect. A report or disclosure must be passed immediately to the DSL or DDSL, not within  
24 hours. The person receiving the disclosure listens without leading questions, makes a  
factual record, avoids promises of secrecy and does not investigate the allegation.  
If there is an immediate threat to life or serious harm, call 999 and take protective action.  
For urgent safeguarding concerns requiring children’s social care, contact the relevant local  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
authority children’s social care/MASH by telephone, including its out-of-hours emergency  
duty service where appropriate. The DSL/DDSL should be informed as soon as practicable;  
their unavailability must not delay emergency action.  
For non-emergency safeguarding referrals, the DSL/DDSL follows the relevant authority’s  
current published online referral portal or secure referral process and its local threshold  
guidance. Consider community-based early help / Family Help support where appropriate,  
but do not delay a statutory referral where there is a risk of significant harm.  
The DSL may also seek advice from Social Care or another appropriate agency about a  
concern, if we are unsure how to respond to it.  
Where concerns arise at school, Compass liaises promptly with the school DSL and relevant  
statutory agencies. Allegations about a member of school staff are reported in accordance  
with the school’s safeguarding procedure and relevant LADO route; an allegation about the  
school head is not reported solely to that person. Any immediate risk is reported to police  
or children’s social care without delay.  
Where a concern does not yet meet the threshold for a statutory referral, the DSL/DDSL  
records the concern, identifies proportionate early help or Family Help and reviews the  
child’s safety. If concern escalates, the DSL/DDSL makes a prompt referral to the relevant  
local authority children’s social care service and, where appropriate, police. Local  
thresholds must never delay action where significant harm is suspected.  
Parents/carers are normally consulted and informed where appropriate and safe; however,  
consent is not a prerequisite to sharing or referring information where necessary to  
safeguard a child. Do not alert a parent/carer if doing so might increase risk, undermine  
protection or impede police enquiries; consult statutory agencies where needed and  
record the decision.  
If a member of staff or homestay continues to have concerns about a child and feels the  
situation is not being addressed or does not appear to be improving, the staff member or  
homestay concerned should press for re-consideration of the case with the designated  
safeguarding lead.  
If the DSL/DDSL is unavailable or is implicated, staff and homestays must not wait or route  
concerns solely through the person complained about. They may contact the Director  
where not implicated, and contact the relevant children’s social care service, LADO (for  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
allegations involving adults in the children’s workforce) or police directly. Any immediate  
danger requires 999. The concern and action taken must be recorded securely.  
The DSL/DDSL ensures a confidential safeguarding record is created promptly for every  
concern, capturing the original disclosure, risks, referrals, advice, decisions, rationale,  
safeguarding actions, people informed and review dates. Records are separate from  
routine student files and available only to the DSL/DDSL and authorised senior managers  
on a strict need-to-know basis.  
Safeguarding and mental health response decisions should be recorded in the secure electronic  
student safeguarding record following each incident; communications held in WeChat or email must  
be transferred where relevant. The DSL must track unresolved actions and follow-up dates.  
How Compass will respond to child on child Abuse  
All staff and homestays should be aware that children can abuse other children (often referred to as  
child on child abuse) and that it can happen both inside and outside of school or college and online.  
That may mean it happens whilst students are in the care of homestays. It is important that all staff  
and homestays recognise the indicators and signs of child on child abuse and know how to identify it  
and respond to reports.  
All staff and homestays should understand, that even if there are no reports in their organisation it  
does not mean it is not happening, it may be the case that it is just not being reported. As such it is  
important if staff or homestays have any concerns regarding child on child abuse they should speak  
to the designated safeguarding lead (or deputy).  
Compass does not tolerate abuse or discriminatory behaviour, including racism, faith-targeted  
abuse, sexual harassment, misogyny, misandry, homophobic or other prejudice-based abuse. Staff  
challenge harmful behaviour and do not dismiss incidents as banter. A report may raise safeguarding  
needs for both the child harmed and the child alleged to have caused harm. Immediate safety,  
support and proportional risk assessment come first.  
Child-on-child abuse can include (whether online or offline):  
bullying (including cyber bullying, prejudice-based and discriminatory bullying);  
abuse in intimate personal relationships between children (sometimes known as  
‘teenage relationship abuse’)  
physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing  
physical harm (this may include an online element which facilitates, threatens and/or  
encourages physical abuse);  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
sexual violence, such as rape, assault by penetration and sexual assault; (this may  
include an online element which facilitates, threatens and/or encourages sexual  
violence);  
sexual harassment, such as sexual comments, remarks, jokes and online sexual  
harassment, which may be standalone or part of a broader pattern of abuse;  
causing someone to engage in sexual activity without consent, such as forcing someone  
to strip, touch themselves sexually, or to engage in sexual activity with a third party;  
consensual or non-consensual making or sharing of nudes and semi-nudes, including  
digitally altered or wholly AI-generated sexualised images; each report must be considered  
as a safeguarding concern;  
upskirting, which typically involves taking a picture under a person’s clothing without  
their permission, with the intention of viewing their genitals or buttocks to obtain sexual  
gratification, or cause the victim humiliation, distress or alarm; and  
initiation/hazing type violence and rituals (this could include activities involving  
harassment, abuse or humiliation used as a way of initiating a person into a group and  
may also include an online element).  
Compass Culture and Education has the following procedures that help to minimise the  
risk of child on child abuse:  
Regular training for staff and homestays  
Educating students through our handbooks and through discussion  
Providing students with clear guidelines within the student handbook on how to raise a  
concern.  
Fostering effective channels of communication so that students feel comfortable  
approaching their homestay carer or guardian with any concerns.  
Effective communication between the DSL (and DDSL) with the DSL in schools where  
students are placed.  
In the event of a report of child on child abuse, staff and homestays should inform the DSL  
or DDSL as soon as possible.  
How students can raise a concern  
It is important that students understand that any concern they raise will be treated  
seriously.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Students will be encouraged to talk to any trusted adult, including school staff, their  
parents, homestay carer, their guardian or the guardianship organisation DSL/ DDSL. This  
will be explained to them verbally, with a written reminder included in the student  
handbook.  
How allegations will be recorded, investigated and dealt with  
All reports of child on child abuse will be made on a case by case basis with the DSL or  
the DDSL taking a leading role using their professional judgement and supported by  
other agencies such as social care or the police as required.  
Compass Culture and Education asks staff and homestay to follow the procedures  
outlined within this policy for person and for actions to be followed if there are concerns  
about a child or young person.  
Where a report involves nude or semi-nude imagery, staff/homestays must not request,  
download, copy, print, forward or routinely view images. Preserve relevant information  
without circulating the content, notify the DSL/DDSL immediately, follow current UKCIS  
guidance and the school’s safeguarding procedure, and contact statutory services or police  
as required.  
The DSL will notify the DSL of the school that the student attends as soon as possible.  
Risk Assessment  
When sexual violence, serious physical harm, harmful sexual behaviour or harassment is reported,  
the DSL/DDSL must assess immediate safety and support needs, considering the child harmed, the  
child alleged to have caused harm, other children, any homestay household and school  
arrangements. The risk assessment and safety plan must be documented, reviewed and coordinated  
with the school and relevant agencies.  
The victim, especially their protection and support;  
The alleged perpetrator; and  
All the other children (and, if appropriate, homestay family members) residing at a  
homestay, especially any actions that are appropriate to protect them;  
Risk assessments and safeguarding decisions are recorded in Compass’s centrally managed  
confidential electronic safeguarding file, with access limited to the DSL/DDSL and authorised senior  
management, and reviewed as circumstances change.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
The DSL/DDSL follows the published thresholds, referral protocols and joint working arrangements  
of the relevant local authority and safeguarding partners, and keeps an accurate record of contacts  
and decisions.  
How victims, perpetrators and any other children affected by child  
on child abuse will be supported  
Compass Culture and Education will support students who have been involved in child on child  
abuse. This could include:  
Maintaining regular contact with the student/s to check on their welfare and provide an  
opportunity to talk.  
Providing homestays and staff information on a need-to-know basis so that they are able  
to offer support where appropriate.  
Working with the student’s school to provide consistent support  
Making available the details of charities and helplines who can help students who have  
been affected by child on child abuse.  
Management of the report  
The DSL coordinates the response to child-on-child abuse in line with the relevant local authority’s  
safeguarding thresholds, the school’s safeguarding arrangements and advice from appropriate  
statutory agencies. Depending on severity and risk, the following responses may be required:  
Manage internally (including liaising with the students’ school DSL where appropriate)  
Community-based early help or a Family Help assessment, with school and statutory-  
partner liaison as appropriate;  
Referral to children’s social care where a child is harmed, at risk of harm or needs statutory  
assessment; immediately where significant harm is suspected;  
Report to the police. Where a report of rape, assault by penetration or sexual assault is  
made, Compass Culture and Education will consult with the police regarding how this  
case should be managed.  
Compass Culture and Education expects all staff and homestays to be clear on the policy and  
procedures with regards to child on child abuse outlined in this policy and the important role they  
have to play in preventing it and responding where they believe a child may be at risk from it.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Compass Culture and Education acknowledges that addressing inappropriate behaviour (even if it  
appears to be relatively innocuous) can be an important intervention that helps prevent  
problematic, abusive and/or violent behaviour in the future.  
Serious violence or weapons: concerns about knives, threats, serious assault, coercion, gang  
involvement or exploitation must be promptly risk assessed. The DSL liaises with the school and,  
where appropriate, children’s social care and police; the safety plan addresses the child harmed,  
others at risk and the child alleged to have acted violently.  
ALLEGATIONS OF ABUSE AGAINST A MEMBER OF STAFF OR HOMESTAY  
Allegations that meet the threshold  
This guidance should be followed where it is alleged that anyone working, volunteering  
or hosting students for Compass Culture and Education has:  
behaved in a way that has harmed a child, or may have harmed a child and/or;  
possibly committed a criminal offence against or related to a child and/or;  
behaved towards a child or children in a way that indicates he or she may pose a risk  
of harm to children; and/or  
behaved or may have behaved in a way that indicates they may not be suitable to  
work with children (known as transferable risk)  
In the event that there is an allegation against a member of staff, volunteer or homestay,  
Compass Culture and Education will follow the guidance in the most recent version of  
Keeping Children Safe in Education Part 4.  
Allegations about Compass staff, volunteers or homestays are reported without delay to  
the Director, Lu Jin (Lucy), unless she is implicated. The Director acts as case manager and  
contacts the relevant LADO promptly in accordance with local requirements, before  
conducting an internal investigation. If the Director is implicated, the reporter must use the  
independent LADO and/or children’s social care/police route directly; no concern may be  
suppressed or investigated solely by its subject.  
Compass Culture and Education will report promptly to the DBS any person whose  
services are no longer used for regulated activity because they have caused harm or  
posed a risk of harm to a child.  
Any historical allegations should be referred to the police.  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Allegations that do not meet the threshold  
Low level concerns: Compass Culture and Education has a Low Level Concerns policy that outlines  
the processes we will follow to deal with concerns (including allegations) which do not meet the  
harm threshold set out above. We also have a staff code of conduct that explains professional  
boundaries. Staff, homestays and volunteers are expected to act within these boundaries, and in  
accordance with the ethos and values of Compass Culture and Education Ltd. It is imperative that  
staff understand the importance of reporting any concerns that they may have.  
Concerns may arise in several ways and from a number of sources. For example: suspicion;  
complaint; or disclosure made by a student, parent or other adult within or outside of the  
organisation; or as a result of vetting checks undertaken.  
The term ‘low-level’ concern does not mean that it is insignificant, it means that the behaviour  
towards a child does not meet the threshold set out above. A low-level concern is any concern – no  
matter how small, and even if no more than causing a sense of unease or a ‘nagging doubt’ - that an  
adult working in or on behalf of the school or college may have acted in a way that:  
is inconsistent with the staff code of conduct, including inappropriate conduct outside of  
work, and  
does not meet the allegations threshold or is otherwise not considered serious enough to  
consider a referral to the LADO.  
Examples of such behaviour could include, but are not limited to:  
being over friendly with children;  
having favourites;  
taking photographs of children on their mobile phone;  
engaging with a child on a one-to-one basis in a secluded area or behind a closed door;  
or,  
using inappropriate sexualised, intimidating or offensive language.  
Such behaviour can exist on a wide spectrum, from the inadvertent or thoughtless, or behaviour that  
may look to be inappropriate, but might not be in specific circumstances, through to that which is  
ultimately intended to enable abuse.  
Prompt reporting of any low-level concern or self-report about an adult’s conduct is required,  
however small. Staff, volunteers and homestays should report concerns to the DSL or Director unless  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
that person is involved; use the independent LADO/statutory route for allegations meeting the harm  
threshold. Records are confidential, patterns are reviewed, and outcomes are documented.  
Learning Lessons  
Throughout the process of handling allegations and at conclusion of a case in which an allegation is  
substantiated, the LADO should review the circumstances of the case with the case manager to  
determine whether there are any improvements to be made to our procedures to help prevent  
similar events in the future.  
This should include issues arising from any decision to suspend the member of staff, the duration of  
the suspension and whether or not suspension was justified. Lessons should also be learnt from the  
use of suspension when the individual is subsequently reinstated.  
The LADO and case manager should consider how future investigations of a similar nature could be  
carried out without suspending the individual.  
For all other cases, where the allegation concluded to be either, unfounded, false, malicious or  
unsubstantiated the case manager (and if they have been involved the LADO) should consider the  
facts and determine whether any lessons can be learned and if improvements can be made  
How to receive a disclosure from a child or young person  
Victims should be taken seriously, kept safe and never be made to feel like they are  
creating a problem for reporting abuse, sexual violence or sexual harassment  
Reassure the child and listen carefully – it is important that they know you believe them  
Do not say you will not say anything to anyone – in fact you have a duty to disclose this  
to another person so do not promise confidentiality  
Make sure you take detailed notes, write everything down. If you are unable to take  
notes at the time, you should do so as soon as you are able.  
Ask open questions if appropriate, do not lead the conversation to find out what has  
happened. Use words such as tell me, explain or describe, and allow the student to speak  
Avoid words such as what, why, how when – these will be asked by the relevant agency  
if appropriate.  
Ensure that you notify the police by calling 999 if you believe that the young person is at  
immediate or serious risk of harm  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Inform the Designated Safeguarding Lead, Yuexuan Wang (Sunny), on 07743 386699, or  
Deputy DSL, Tianlun Liu (Tina), on 07405 844198, IMMEDIATELY. Do not wait for a 24-hour  
period or for office hours.  
Outside office hours, contact the 24-hour emergency line (Lu Jin / Lucy: 07912 847858),  
which must ensure immediate escalation to the on-duty DSL/DDSL. If the emergency  
contact or DSL/DDSL cannot be reached and the child is at risk, contact children’s social  
care, LADO (where appropriate) or police directly; call 999 for immediate danger.  
Sharing Safeguarding Information  
There will be occasions when safeguarding information will need to be shared with other parties in  
order to safeguard the individual/s concerned. Information will be shared with guardianship  
organisation staff, homestays and the school’s DSL (of the school that the student attends) who  
‘need to know’ and with children’s social care, the safeguarding partners, other organisations,  
agencies, and practitioners as required. Staff and homestays must ensure that any confidential  
information shared with them remains confidential and is handled in line with our data protection  
policy.  
Compass Culture and Education will be proactive in sharing information as early as possible to help  
identify, assess, and respond to risks or concerns about the safety andwelfare of children, whether  
this is when problems are first emerging, or where a child is already known to the local authority  
children’s social care.  
Where safeguarding requires disclosure, Compass identifies and records an appropriate lawful basis  
under Article 6 UK GDPR and, where special-category information such as medical or mental health  
data is involved, an additional condition under Article 9 and relevant provisions of the Data  
Protection Act 2018. The Data (Use and Access) Act 2025 is also taken into account. The appropriate  
bases are assessed case by case; Compass does not assume that public-task processing automatically  
applies to it. Necessary safeguarding disclosures can be made without consent where a valid lawful  
basis applies; do not delay urgent protection while seeking routine permission.  
All staff and homestays must be aware that they cannot promise a child to keep secrets which might  
compromise the child’s safety or wellbeing. However, staff and homestays are aware that matters  
relating to child protection and safeguarding are personal to children and families, in this respect  
they are confidential and the DSL and DDSL will only disclose information about a child to other  
members of guardianship organisation staff, homestays the DSL of the school that the student  
attends on a need to know basis.  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
The DSL/DDSL records who shared the information, with whom, when, its safeguarding purpose, the  
Article 6 lawful basis and any Article 9 condition, and the reason why disclosure was necessary and  
proportionate. Access and onward sharing must be limited to what each recipient needs to  
safeguard the child. The child and parents are informed when safe to do so; information must not be  
withheld solely because of uncertainty about ordinary consent.  
Where appropriate, seek the views of the child and involve their parent/carer, unless this is unsafe  
or would hinder safeguarding action. Safeguarding referrals and necessary disclosures must not be  
delayed while seeking consent when a child may be at risk. Record any decision to inform or not  
inform parents.  
ROLE OF DSL AND DDSL  
The DSL has lead responsibility for safeguarding and child protection, including liaison with local  
authority children’s social care, LADO (allegations against adults), partner-school DSLs, police and  
other professionals. The DSL must be a senior staff member resident in the UK with authority to act.  
The role is recorded in the job description and the Director provides oversight.  
The DDSL supports or acts for the DSL, receives concerns and makes referrals when the DSL is  
unavailable. Compass will maintain adequate 24-hour escalation arrangements, including the  
emergency contact’s ability to reach the DSL/DDSL; where neither is available, direct statutory  
referral must not be delayed. Training and competence at the required level must be evidenced and  
maintained.  
The designated safeguarding lead is expected to:  
refer cases of suspected abuse to the local authority children’s social care as required;  
support staff and homestays who make referrals to local authority children’s social care;  
refer cases to the Channel programme where there is a radicalisation concern as  
required (this may also be undertaken by the Prevent Lead, if the Prevent Lead is not the  
DSL);  
support staff and homestays who make referrals to the Channel programme(this may  
also be undertaken by the Prevent Lead, if the Prevent Lead is not the DSL);  
refer cases where a crime may have been committed to the Police as required.  
act as a point of contact with the three safeguarding partners;  
liaise with the Company Director (Lu Jin / Lucy), except where a concern involves the  
Director, in which case the independent statutory referral route applies;  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
liaise with staff and homestays on matters of safety and safeguarding (including online  
and digital safety) and when deciding whether to make a referral by liaising with relevant  
agencies;  
act as a source of support, advice and expertise for all staff and homestays.  
understand the importance of information sharing, both within the guardianship  
organisation, and with the safeguarding partners, the DSL for the school the student  
attends, other agencies, organisations and practitioners  
encourage a culture of listening to students and taking account of their wishes and  
feelings, among all staff, homestays and volunteers and in any measures the  
guardianship organisation may put in place to protect them; and,  
understand the difficulties that students may have in approaching staff and homestays  
about their circumstances and consider how to build trusted relationships which  
facilitate communication.  
ensure the guardianship organisation’s child protection policies are known, understood  
and used appropriately;  
ensure the child protection policy is reviewed at least annually, updated when statutory  
guidance or procedures change and submitted to the Company Director for approval;  
ensure the current, approved safeguarding policy is available to staff, volunteers and  
homestays and published on the organisation’s website (https://www.compassedu.co.uk/),  
and to parents and partner schools on request;  
The DSL ensures appropriate cover during absence or leave, including a clear out-of-hours chain of  
contact and rapid access to relevant secure records for authorised safeguarding decision-makers.  
The person receiving a report should know who is covering; absence must never postpone an  
emergency referral.  
The DSL/DDSL monitors local safeguarding arrangements, updated referral thresholds  
and available multi-agency training and ensures staff and homestays receive relevant  
updates.  
CONTACT DETAILS FOR THE DSL AND DDSL  
Role  
Name  
Telephone Number  
Email  
Yuexuan Wang  
(Sunny)  
Designated Safeguarding Lead (DSL)  
07743 386699  
Registered in England No. 9024815  
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Deputy Designated Safeguarding Lead (DDSL)  
Tianlun Liu (Tina)  
Lu Jin (Lucy)  
07405 844198  
07912 847858  
24-hour emergency contact (routes  
safeguarding to DSL/DDSL)  
PREVENT  
Compass Culture and Education has a separate policy that outlines our procedure for Anti-  
Radicalisation and Prevent. This can be requested from guardians.  
PREVENT LEAD CONTACT DETAILS  
Role  
Name  
Telephone Number  
Email  
Prevent lead (role to  
confirm in annual review)  
Lu Jin (Lucy)  
07912 847858  
RECORD KEEPING  
All safeguarding concerns, disclosures, professional discussions, referral decisions, reasons, follow-  
up and outcomes must be recorded contemporaneously and accurately in a confidential  
safeguarding record distinct from ordinary student files. Access is restricted to the DSL/DDSL and  
specifically authorised senior management. Do not keep the sole record in WeChat or personal  
devices; relevant correspondence must be securely transferred to the organisational record.  
Records will be detailed and accurate (either handwritten or using appropriate secure online  
software). These will include all concerns about a student even if there is no need to make an  
immediate referral and record the rationale for decisions made and action taken.  
In summary, records should include:  
a clear and comprehensive summary of the concern;  
details of how the concern was followed up and resolved;  
a note of any action taken, decisions reached and the outcome.  
Copies of correspondence and records of discussions with local authority children’s social care, the  
school DSL, LADO, police, health services or other professional agencies are retained securely in the  
child’s safeguarding record.  
Registered in England No. 9024815  
 
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
A restricted notation may indicate the existence of a separate safeguarding record in the student file  
without revealing its sensitive contents. Disclosures are need-to-know, appropriately logged and  
compliant with the Data Protection Policy. Retention, legal holds, annual review and secure disposal  
follow the Director-approved Data Retention Schedule once adopted; until approval, do not bulk-  
delete safeguarding records.  
If in doubt about recording requirements, staff or homestays should discuss with the DSL (or DDSL).  
TRAINING AND UPDATES  
All staff, volunteers and homestay primary carers receive appropriate safeguarding training and  
induction before starting duties, together with timely updates. The DSL maintains a training register  
recording provider, course, completion date, evidence of certification, refresher due date and  
relevant briefing attendance.  
DSL AND DDSL  
The DSL (and DDSL where applicable) must complete basic safeguarding awareness training before  
undertaking their first DSL course, followed by appropriate DSL training delivered face-to-face, live  
remotely or online. DSL training must be renewed at least every two years in accordance with AEGIS  
Standard 6.2.2. Completion dates and certificates must be verified; this policy does not itself confirm  
training has been completed.  
OTHER STAFF AND HOMESTAYS  
The DSL and DDSL must remain resident in the UK for their roles as required by AEGIS and maintain  
relevant training evidence. AEGIS minimum requirements for training are monitored by the Director.  
All staff, volunteers and homestay primary carers complete suitable safeguarding awareness training  
before starting their roles, renewed at least every three years under AEGIS 6.3.1. Where two adults  
share primary childcare responsibilities in a homestay, both should complete training. Existing  
certificates may be recognised only after suitability and date checks; every person must understand  
Compass’s reporting and emergency procedures.  
Compass also encourages staff and homestays to self-report any situations where their actions may  
be misinterpreted or fall short of the required standards outlined in the code of conduct. A clear,  
confidential reporting system will be in place to document these incidents and escalate them to the  
Registered in England No. 9024815  
 
 
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
safeguarding team for review. Compass will manage these reports promptly, taking appropriate  
action to address concerns and ensure ongoing compliance with safeguarding standards.  
At least annually, Compass provides safeguarding and online-safety updates to staff and homestays,  
and records attendance or circulation and acknowledgement. Staff know how to report concerns,  
including out of hours and where the DSL or Director is implicated.  
WHISTLEBLOWING  
Compass Culture and Education has a separate policy that outlines the whistleblowing procedures.  
These protect staff members who report colleagues they believe are doing something wrong or  
illegal, or who are neglecting their duties.  
LOCAL MULTI-AGENCY SAFEGUARDING ARRANGEMENTS AND REFERRAL CONTACTS  
Compass uses each child’s relevant local multi-agency safeguarding arrangements, children’s social  
care service and published referral thresholds, rather than assuming that the organisation’s  
registered office is the correct referral area. The DSL/DDSL liaises with statutory safeguarding  
partners and school counterparts as appropriate.  
Where a student attends school in one borough and stays with a homestay in another, the DSL  
coordinates with the appropriate children’s social care teams and partner-school DSL. For an  
allegation about a person working with children, the relevant LADO must be consulted. For  
immediate danger call 999. Out-of-hours numbers must be used where urgent statutory  
safeguarding input is needed.  
local-council (official GOV.UK service). Maintain a separate current local-authority directory for all  
areas where students are placed.  
The tables below provide contact routes for Hackney, Barnet and Enfield. They distinguish children’s  
social care referrals, out-of-hours duty, local safeguarding partnerships and LADO routes for adult  
allegations. These entries must be verified against each council’s current official guidance before  
director approval and at every scheduled register review; this is not a complete list of all current  
placements.  
If there is immediate danger, contact 999. If the appropriate council number cannot be located  
quickly, use the GOV.UK local-council directory, police or 101 for non-emergencies; do not delay  
action because an internal list is incomplete.  
Registered in England No. 9024815  
 
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
The DSL maintains a separate CONTROLLED LOCAL AUTHORITY SAFEGUARDING CONTACT REGISTER  
for every area in which Compass currently supports children at school or in homestays. The register  
must show the local safeguarding partnership, children’s social care referral channel, emergency  
duty contact, LADO, links to official sources, the person checking the details and the last verification  
date. This draft is not ready for public release until the live placement audit and full contact register  
are completed.  
For any student living in Scotland, the DSL uses the relevant local authority children’s social work  
service and Police Scotland emergency routes, following local guidance; this must be recorded in the  
student’s safeguarding plan if relevant.  
For any student living in Wales, the DSL contacts the appropriate local authority children’s services  
and follows local inter-agency safeguarding procedures. Details are verified at the time of placement  
and referral.  
HACKNEY — LOCAL PARTNERSHIP, CHILDREN’S SERVICES AND LADO (OFFICE AREA)  
families/if-youre-worried-about-child-or-young-person/local-authority-designated-officer-lado.  
Professionals use the council’s current LADO contact form before phoning unless directed otherwise.  
For an urgent child protection concern use MASH, out-of-hours duty or 999.  
Function  
Safeguarding  
Service  
Telephone / route  
Email / online route  
Children  
City & Hackney Safeguarding Children Partnership  
020 8356 4183  
Partnership  
Children’s  
Social Care /  
MASH  
Hackney Children and Families Services  
020 8356 5500  
Out-of-hours  
Children’s  
Services  
Hackney Emergency Duty Team  
020 8356 2710  
via emergency duty line  
LADO – adult  
allegations  
Hackney LADO online contact form  
see official LADO webpage  
hackney.gov.uk → LADO form  
BARNET AND ENFIELD — CHILDREN’S SERVICES, OUT-OF-HOURS AND LADO  
safeguarding-referral; Enfield LADO:  
should be reviewed at least annually.  
Area  
Service / role  
Telephone  
Email / route  
Council safeguarding referral  
Barnet  
Children’s Social Care (Family Access and Support)  
020 8359 4066  
portal  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Barnet  
Barnet  
Out-of-hours duty  
LADO – allegations  
020 8359 2000  
020 8359 4066  
Telephone for urgent cases  
via Barnet Family Access and  
Support  
Enfield  
Enfield  
Enfield  
Children’s MASH  
Out-of-hours duty  
LADO – allegations  
020 8379 5555  
020 8379 1000  
020 8379 2850  
Telephone, option 2  
LIAISON WITH PARENTS / AGENTS AND PARTNER SCHOOLS  
Compass coordinates support with the student, their parents or carers where safe, the partner  
school’s DSL, the homestay and relevant statutory or healthcare professionals. The child’s own  
account, wishes and feelings are sought, decisions and professional advice are documented, and  
each person receives only the safeguarding information necessary for their role. The responsible  
DSL/DDSL must consider whether language, disability, culture or other communication barriers  
require additional support. Where language barriers affect understanding, the DSL/DDSL provides an  
age-appropriate explanation and considers independent qualified interpreting or suitable translation  
when reasonably needed; do not rely on a child or alleged perpetrator to interpret a safeguarding  
disclosure. These arrangements and any unmet needs are recorded; urgent referrals must never be  
delayed.  
The guardianship organisation may be required to share confidential safeguarding  
information with the DSL of the school or college that the student attends. When a  
student moves school or college, safeguarding information may be shared with the DSL  
of the new school. All schools and colleges have their own safeguarding and child  
protection policies that outline their procedures. These can be found on their websites.  
Compass works openly with parents and carers where safe and appropriate. However,  
when necessary to protect a child, the DSL/DDSL may contact local authority children’s  
social care or police before informing parents, especially if notifying them might increase  
risk or compromise an enquiry. The reason must be documented.  
Compass Culture and Education will not usually share safeguarding information with  
agents unless it is necessary to safeguard the student. In this case information will be  
provided on a need-to- know basis and on the understanding that it should be kept  
strictly confidential.  
FURTHER DETAIL ON SPECIFIC TYPES OF ABUSE  
The following topics are informed by the current KCSIE 2026 Part One and Annex A. They are  
adapted for the guardianship context. Consult the full guidance for additional detail; none of these  
short summaries replaces statutory agency advice.  
Registered in England No. 9024815  
 
 
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
Safeguarding issues  
Staff and homestays should recognise overlapping safeguarding risks including substance misuse,  
prolonged absences or missing episodes, serious violence, financial or criminal exploitation, modern  
slavery, radicalisation, and consensual or non-consensual making or sharing of nudes and semi-  
nudes (including AI-generated imagery). All concerns must be promptly reported and considered in  
the round.  
Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE)  
Both CSE and CCE are forms of abuse that occur where an individual or group takes advantage of an  
imbalance in power to coerce, manipulate or deceive a child into taking in sexual or criminal activity,  
in exchange for something the victim needs or wants, and/or for the financial advantage or  
increased status of the perpetrator or facilitator and/or through violence or the threat of violence.  
CSE and CCE can affect children, both male and female and can include children who have been  
moved(commonly referred to as trafficking) for the purpose of exploitation.  
Child Criminal Exploitation (CCE)  
Some specific forms of CCE can include children being forced or manipulated into transporting drugs  
or money through county lines, working in cannabis factories, shoplifting or pickpocketing. They can  
also be forced or manipulated into committing vehicle crime or threatening/committing serious  
violence to others.  
Children can become trapped by this type of exploitation as perpetrators can threaten victims (and  
their families) with violence, or entrap and coerce them into debt. They may be coerced into  
carrying weapons such as knives or begin to carry a knife for a sense of protection from harm from  
others. As children involved in criminal exploitation often commit crimes themselves, their  
vulnerability as victims is not always recognised by adults and professionals, (particularly older  
children), and they are not treated as victims despite the harm they have experienced. They may still  
have been criminally exploited even if the activity appears to be something they have agreed or  
consented to.  
It is important to note that the experience of girls who are criminally exploited can be very different  
to that of boys. The indicators may not be the same, however professionals should be aware that  
girls are at risk of criminal exploitation too. It is also important to note that both boys and girls being  
criminally exploited may be at higher risk of sexual exploitation.  
For current definitions and signs of child criminal exploitation, see KCSIE 2026 Part One and Annex A  
(Further Information). Annex B in KCSIE 2026 concerns the DSL role, not child criminal exploitation.  
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Child Sexual Exploitation (CSE)  
CSE is a form of child sexual abuse. Sexual abuse may involve physical contact, including assault by  
penetration (for example, rape or oral sex) or no penetrative acts such as masturbation, kissing,  
rubbing, and touching outside clothing. It may include non-contact activities, such as involving  
children in the production of sexual images, forcing children to look at sexual images or watch sexual  
activities, encouraging children to behave in sexually inappropriate ways or grooming a child in  
preparation for abuse including via the internet.  
CSE can occur over time or be a one-off occurrence, and may happen without the child’s immediate  
knowledge e.g. through others sharing videos or images of them on social media.  
CSE can affect any child, who has been coerced into engaging in sexual activities. This includes 16  
and 17 year olds who can legally consent to have sex. Some children may not realise they are being  
exploited e.g. they believe they are in a genuine romantic relationship.  
Further guidance and indicators for CCE/CSE are provided in KCSIE 2026 Part One and Annex A.  
MENTAL HEALTH  
Mental health concerns may themselves become safeguarding concerns, including self-harm,  
suicidal ideation or risk of suicide, and may indicate underlying abuse, neglect or exploitation. Staff  
and homestays should be alert to behavioural changes, disrupted sleep, withdrawal, loss of interest,  
self-injury or neglect of self-care and report concerns promptly, without diagnosing a condition.  
Only an appropriately qualified healthcare professional may diagnose mental health conditions.  
Guardianship staff and homestays can identify concerns, respond safely and refer to the DSL/DDSL,  
school staff and clinical services; they must not attempt clinical risk diagnoses or substitute  
unsupervised transport for appropriate care.  
A mental health concern affecting immediate safety is treated as an emergency safeguarding matter.  
The DSL/DDSL coordinates with the school, considers the student’s wishes and the available clinical  
advice, identifies who will supervise the child, and assesses any travel or temporary accommodation  
risks. Records are created and reviewed without delay.  
If a child is in immediate danger, call 999 or arrange immediate A&E assessment by a suitable  
responsible adult, as directed by emergency services. Where urgent mental health help is needed  
without immediate danger, contact NHS 111 (mental health option). The school and parents are  
involved when appropriate and safe; professional services lead clinical assessment and treatment.  
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Any safeguarding-linked mental health concern must be reported to the DSL/DDSL immediately.  
Compass coordinates with partner-school safeguarding/pastoral staff, statutory agencies and  
healthcare professionals as necessary. The person making a report must not assume another person  
has acted.  
Schools may notify Compass by email or telephone to the office, designated guardian, or out-of-  
hours emergency contact. The guardianship team establishes why school removal is proposed, what  
the school has already done, the student’s immediate safety, safeguarding/medical advice,  
supervision and appropriate follow-up. A coordinated plan is recorded before a planned removal.  
For a planned removal from school, Compass requests that school staff complete and return the  
Student Removal Form (Appendix 2) BEFORE collection, so that risks and arrangements are  
documented. However, a form must never delay essential emergency treatment or immediate  
safeguarding action; where emergency removal is unavoidable, Compass documents the reasons  
and requests the completed form as soon as practicable afterwards. Collection may involve the  
designated guardian, another trained team member or an approved driver subject to assessment; a  
driver does not replace required adult supervision or medical support.  
Pre-acceptance assessment: before Compass agrees to provide guardianship, parents are asked to  
complete the Medical Form. The guardianship team reviews relevant health, mental health, SEND  
and additional support needs, considers whether accommodation, school liaison and emergency  
support are feasible, records any identified risks and support arrangements, and decides whether  
Compass can meet the child’s needs. No acceptance decision is deemed risk-free merely because a  
form has been completed.  
Post-removal safety plan: after any removal, the DSL/DDSL records who took responsibility for the  
student, how transport and temporary accommodation were assessed, any clinical advice and  
follow-up plan, school/parent communications, review arrangements and eventual return-to-school  
or alternative plan.  
SEXUAL VIOLENCE AND SEXUAL HARASSMENT BETWEEN  
CHILDREN IN SCHOOLS AND COLLEGES CONTEXT  
Sexual violence and sexual harassment can occur between two children of any age and sex from  
primary to secondary stage and into colleges. It can also occur online. It can also occur through a  
group of children sexually assaulting or sexually harassing a single child or group of children.  
Children who are victims of sexual violence and sexual harassment will likely find the experience  
stressful and distressing. This will, in all likelihood, adversely affect their educational attainment and  
will be exacerbated if the alleged perpetrator(s) attends the same school or college. Sexual violence  
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and sexual harassment exist on a continuum and may overlap, they can occur online and face to face  
(both physically and verbally) and are never acceptable.  
It is essential that all victims are reassured that they are being taken seriously and that they will be  
supported and kept safe. A victim should never be given the impression that they are creating a  
problem by reporting sexual violence or sexual harassment. Nor should a victim ever be made to feel  
ashamed for making a report. Detailed advice is available in Part five of the full version of KCSIE.  
Staff and homestays should be aware that some groups are potentially more at risk. Evidence shows  
girls, children with special educational needs and disabilities (SEND) and LGBT children are at greater  
risk.  
Staff and homestays should be aware of the importance of:  
challenging inappropriate behaviours;  
making clear that sexual violence and sexual harassment is not acceptable, will never be  
tolerated and is not an inevitable part of growing up;  
not tolerating or dismissing sexual violence or sexual harassment as “banter”, “part of  
growing up”, “just having a laugh” or “boys being boys”; and  
challenging physical behaviours (potentially criminal in nature), such as grabbing  
bottoms, breasts and genitalia, pulling down trousers, flicking bras and lifting up skirts.  
Dismissing or tolerating such behaviours risks normalising them.  
WHAT IS SEXUAL VIOLENCE AND SEXUAL HARASSMENT?  
Sexual violence  
It is important that guardianship organisation staff, homestays and any volunteers are aware of  
sexual violence and the fact children can, and sometimes do, abuse their peers in this way and that it  
can happen both inside and outside of school/college. When referring to sexual violence we are  
referring to sexual violence offences under the Sexual Offences Act 2003135 as described below:  
Rape: A person (A) commits an offence of rape if: he intentionally penetrates the vagina, anus or  
mouth of another person (B) with his penis, B does not consent to the penetration and A does not  
reasonably believe that B consents.  
Assault by Penetration: A person (A) commits an offence if: s/he intentionally penetrates the vagina  
or anus of another person (B) with a part of her/his body or anything else, the penetration is sexual,  
B does not consent to the penetration and A does not reasonably believe that B consents.  
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Sexual Assault: A person (A) commits an offence of sexual assault if: s/he intentionally touches  
another person (B), the touching is sexual, B does not consent to the touching and A does not  
reasonably believe that B consents. (Schools should be aware that sexual assault covers a very wide  
range of behaviour so a single act of kissing someone without consent, or touching someone’s  
bottom/breasts/genitalia without consent, can still constitute sexual assault.)  
Causing someone to engage in sexual activity without consent: A person (A) commits an offence if:  
s/he intentionally causes another person (B) to engage in an activity, the activity is sexual, B does not  
consent to engaging in the activity, and A does not reasonably believe that B consents. (This could  
include forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a  
third party.)  
What is consent?  
Consent is about having the freedom and capacity to choose. Consent to sexual activity may be given  
to one sort of sexual activity but not another, e.g. to vaginal but not anal sex or penetration with  
conditions, such as wearing a condom. Consent can be withdrawn at any time during sexual activity  
and each time activity occurs. Someone consents to vaginal, anal or oral penetration only if s/he  
agrees by choice to that penetration and has the freedom and capacity to make that choice. Further  
information about consent can be found here: Rape Crisis England & Wales -Sexual consent  
a child under the age of 13 can never consent to any sexual activity;  
the age of consent is 16;  
sexual intercourse without consent is rape.  
Sexual harassment  
When referring to sexual harassment we mean ‘unwanted conduct of a sexual nature’ that can occur  
online and offline and both inside and outside of school/college. When we reference sexual  
harassment, we do so in the context of child on child sexual harassment. Sexual harassment is likely  
to: violate a child’s dignity, and/or make them feel intimidated, degraded or humiliated and/or  
create a hostile, offensive or sexualised environment.  
Whilst not intended to be an exhaustive list, sexual harassment can include:  
sexual comments, such as: telling sexual stories, making lewd comments, making sexual  
remarks about clothes and appearance and calling someone sexualised names;  
sexual “jokes” or taunting;  
physical behaviour, such as: deliberately brushing against someone, interfering with  
someone’s clothes (schools and colleges should be considering when any of this crosses a  
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line into sexual violence - it is important to talk to and consider the experience of the  
victim) and displaying pictures, photos or drawings of a sexual nature; and  
online sexual harassment. This may be standalone, or part of a wider pattern of sexual  
harassment and/or sexual violence. It may include:  
o consensual and non-consensual sharing of nudes and semi-nudes images and/or videos. As set out  
young people (which provides detailed advice for schools and colleges) taking and sharing nude  
photographs of U18s is a criminal offence;  
sharing of unwanted explicit content;  
upskirting (is a criminal offence);  
sexualised online bullying;  
unwanted sexual comments and messages, including, on social media;  
sexual exploitation; coercion and threats.  
UPSKIRTING  
The Voyeurism (Offences) Act 2019, which is commonly known as the Upskirting Act, came into force  
on 12 April 2019. ‘Upskirting’ is where someone takes a picture under a persons clothing (not  
necessarily a skirt) without their permission and or knowledge, with the intention of viewing their  
genitals or buttocks (with or without underwear) to obtain sexual gratification, or cause the victim  
humiliation, distress or alarm. It is a criminal offence. Anyone of any sex, can be a victim.  
The response to a report of sexual violence or sexual harassment  
The initial response to a report from a child is incredibly important. How a school, college or  
guardianship organisation responds to a report can encourage or undermine the confidence of  
future victims of sexual violence and sexual harassment to report or come forward. Schools, colleges  
and guardianship organisations not recognising, acknowledging or understanding the scale of  
harassment and abuse and/or downplaying of some behaviours can actually lead to a culture of  
unacceptable behaviour. It is essential that all victims are reassured that they are being taken  
seriously and that they will be supported and kept safe. A victim should never be given the  
impression that they are creating a problem by reporting sexual violence or sexual harassment. Nor  
should a victim ever be made to feel ashamed for making a report.  
Where a child raises a concern, staff or homestays follow the current reporting and referral  
procedures in KCSIE 2026 Part One and this policy. Seek immediate advice from the DSL or DDSL if  
unsure.  
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SERIOUS VIOLENCE  
All staff and homestays should be aware of the indicators, which may signal children are at riskfrom,  
or are involved with serious violent crime. These may include increased absencefrom school, a  
change in friendships or relationships with older individuals or groups, a significant decline in  
performance, signs of self-harm or a significant change in wellbeing,or signs of assault or  
unexplained injuries. Unexplained gifts or new possessions couldalso indicate that children have  
been approached by, or are involved with, individualsassociated with criminal networks or gangs and  
may be at risk of criminal exploitation(see above).  
All staff and homestays should be aware of the range of risk factors which increase the likelihoodof  
involvement in serious violence, such as being male, having been frequently absent orpermanently  
excluded from school, having experienced child maltreatment and havingbeen involved in offending,  
such as theft or robbery. Advice for schools and colleges isprovided in the Home Office’s Preventing  
youth violence and gang involvement and its Criminal exploitation of children and vulnerable adults:  
county lines guidance. This is also useful advice for guardianship organisations.  
CHILDREN MISSING FROM EDUCATION  
All staff and homestays should be aware that children going missing, particularly repeatedly, can act  
as a vital warning sign of a range of safeguarding possibilities. This may include abuse and neglect,  
which may include sexual abuse or exploitation and can also be a sign of child criminal exploitation  
including involvement in county lines. It may indicate mental health problems, risk of substance  
abuse, risk of travelling to conflict zones, risk of female genital mutilation, ‘honour’-based abuse or  
risk of forced marriage. Early intervention is necessary to identify the existence of any underlying  
safeguarding risk and to help prevent the risks of a child going missing in future. Staff should contact  
the students’ school or college should they suspect a student is missing from education. The school  
or college will have a procedure for reporting this absence.  
COUNTY LINES  
County lines is a term used to describe gangs and organised criminal networks involved in exporting  
illegal drugs using dedicated mobile phone lines or other form of “deal line”. This activity can happen  
locally as well as across the UK - no specified distance of travel is required. Children and vulnerable  
adults are exploited to move, store and sell drugs and money. Offenders will often use coercion,  
intimidation, violence (including sexual violence) and weapons to ensure compliance of victims.  
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Children can be targeted and recruited into county lines in a number of locations including schools  
(mainstream and special), further and higher educational institutions, pupil referral units, children’s  
homes and care homes.  
Children are also increasingly being targeted and recruited online using social media. Children can  
easily become trapped by this type of exploitation as county lines gangs can manufacture drug debts  
which need to be worked off or threaten serious violence and kidnap towards victims (and their  
families) if they attempt to leave the county lines network.  
A number of the indicators for CSE and CCE as detailed above may be applicable to where children  
are involved in county lines. Some additional specific indicators that may be present where a child is  
criminally exploited through involvement in county lines are children who:  
go missing and are subsequently found in areas away from their home;  
have been the victim or perpetrator of serious violence (e.g. knife crime);  
are involved in receiving requests for drugs via a phone line, moving drugs, handing over  
and collecting money for drugs;  
are exposed to techniques such as ‘plugging’, where drugs are concealed internally to  
avoid detection;  
are found in accommodation that they have no connection with, often called a ‘trap  
house or cuckooing’ or hotel room where there is drug activity;  
owe a ‘debt bond’ to their exploiters;  
have their bank accounts used to facilitate drug dealing.  
Further information on the signs of a child’s involvement in county lines is available in guidance  
published by the Home Office.  
MODERN SLAVERY AND THE NATIONAL REFERRAL MECHANISM  
Modern slavery encompasses human trafficking and slavery, servitude and forced or compulsory  
labour. Exploitation can take many forms, including: sexual exploitation, forced labour, slavery,  
servitude, forced criminality and the removal of organs.  
Further information on the signs that someone may be a victim of modern slavery, the support  
available to victims and how to refer them to the NRM is available in the Modern Slavery Statutory  
Guidance. Modern slavery: how to identify and support victims - GOV.UK (www.gov.uk)  
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CYBERCRIME  
Cybercrime is criminal activity committed using computers and/or the internet. It is broadly  
categorised as either ‘cyber-enabled’ (crimes that can happen off-line but are enabled at scale and at  
speed on-line) or ‘cyber dependent’ (crimes that can be committed only by using a computer).  
Cyber-dependent crimes include;  
unauthorised access to computers (illegal ‘hacking’), for example accessing a school’s  
computer network to look for test paper answers or change grades awarded;  
denial of Service (Dos or DDoS) attacks or ‘booting’. These are attempts to make a  
computer, network or website unavailable by overwhelming it with internet traffic from  
multiple sources; and,  
making, supplying or obtaining malware (malicious software) such as viruses, spyware,  
ransomware, botnets and Remote Access Trojans with the intent to commit further  
offence, including those above.  
Children with particular skill and interest in computing and technology may inadvertently or  
deliberately stray into cyber-dependent crime.  
If there are concerns about a child in this area, the designated safeguarding lead (or a deputy),  
should consider referring into the Cyber Choices programme. This is a nationwide police programme  
supported by the Home Office and led by the National Crime Agency, working with regional and local  
policing. It aims to intervene where young people are at risk of committing, or being drawn into, low  
level cyber-dependent offences and divert them to a more positive use of their skills and interests.  
Note that Cyber Choices does not currently cover ‘cyber-enabled’ crime such as fraud, purchasing of  
illegal drugs on-line and child sexual abuse and exploitation, nor other areas of concern such as on-  
line bullying or general on-line safety.  
Additional advice can be found at: Cyber Choices, ‘NPCC- When to call the Police’ and National  
SO-CALLED’ HONOUR’ -BASED ABUSE  
(including Female Genital Mutilation and Forced Marriage)  
So-called ‘honour’-based abuse (HBA) encompasses incidents or crimes which have been committed  
to protect or defend the honour of the family and/or the community, including female genital  
mutilation (FGM), forced marriage, and practices such as breast ironing. Abuse committed in the  
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context of preserving ‘honour’ often involves a wider network of family or community pressure and  
can include multiple perpetrators. It is important to be aware of this dynamic and additional risk  
factors when deciding what form of safeguarding action to take. All forms of HBA are abuse  
(regardless of the motivation) and should be handled and escalated as such. Professionals in all  
agencies, and individuals and groups in relevant communities, need to be alert to the possibility of a  
child being at risk of HBA, or already having suffered HBA.  
Actions  
If staff or homestays have a concern regarding a child who might be at risk of HBA or who has  
suffered from HBA, they should speak to the designated safeguarding lead (or deputy). As  
appropriate, the designated safeguarding lead (or deputy) will activate local safeguarding  
procedures, using existing national and local protocols for multi-agency liaison with police and  
children’s social care. Where FGM has taken place, since 31 October 2015 there has been a  
mandatory reporting duty placed on teachers that requires a different approach (see Annex A of  
KCSIE 2026 for further details).  
Where staff or homestays have concerns about so-called “honour”-based abuse, FGM or forced  
marriage, contact the DSL/DDSL immediately. The DSL/DDSL follows the current statutory referral  
requirements. Any specific statutory duty falling on a teacher or regulated healthcare professional is  
not assumed to apply automatically to every guardianship employee.  
FGM comprises all procedures involving partial or total removal of the external female genitalia or  
other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-  
lasting harmful consequences.  
Whilst all staff or homestays should speak to the designated safeguarding lead (or deputy) with  
regard to any concerns about female genital mutilation (FGM), there is a specific legal duty on  
teachers (and also regulated health and social care professionals in England and Wales). If a teacher,  
in the course of their work in the profession, discovers that an act of FGM appears to have been  
carried out on a girl under the age of 18, the teacher must report this to the police. See Annex B of  
Keeping Children Safe in Education for further details.  
KCSIE 2026 Part One and Annex A contain further information about FGM. A teacher who discovers  
in the course of their professional work that FGM appears to have been carried out on a girl under  
18 has a specific mandatory reporting duty to the police. Other staff and homestays must still report  
concerns immediately to the DSL/DDSL and appropriate statutory services.  
Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered  
into without the full and free consent of one or both parties and where violence, threats or any  
other form of coercion is used to cause a person to enter into a marriage. Threats can be physical or  
emotional and psychological. A lack of full and free consent can be where a person does not consent  
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or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some  
perpetrators use perceived cultural practices as a way to coerce a person into marriage. Schools,  
colleges and guardianship organisations can play an important role in safeguarding children from  
forced marriage.  
The Forced Marriage Unit has published statutory guidance and Multi-agency guidelines, pages 32-  
36 of which focus on the role of schools and colleges. Staff can contact the Forced Marriage Unit if  
they need advice or information: Contact: 020 7008 0151 or email fmu@fcdo.gov.uk.  
DOMESTIC ABUSE  
The Domestic Abuse Act 2021 received Royal Assent on 29 April 2021. The Act  
introduces the first ever statutory definition of domestic abuse and recognises the impact of  
domestic abuse on children, as victims in their own right, if they see, hear or experience the effects  
of abuse. The statutory definition of domestic abuse, based on the previous cross-government  
definition, ensures that different types of relationships are captured, including ex-partners and  
family members. The definition captures a range of different abusive behaviours, including physical,  
emotional and economic abuse and coercive and controlling behaviour. Both the person who is  
carrying out the behaviour and the person to whom the behaviour is directed towards must be aged  
16 or over and they must be “personally connected” (as defined in section 2 of the 2021 Act).  
Types of domestic abuse include intimate partner violence, abuse by family members, teenage  
relationship abuse and child/adolescent to parent violence and abuse. Anyone can be a victim of  
domestic abuse, regardless of gender, age, ethnicity, socioeconomic status, sexuality or background  
and domestic abuse can take place inside or outside of the home. The government will issue  
statutory guidance to provide further information for those working with domestic abuse victims  
and perpetrators, including the impact on children.  
Children may be harmed by domestic abuse in their family, homestay or intimate relationships. This  
can include coercive control, physical, emotional, psychological or financial abuse; a child may  
experience harm by seeing, hearing or experiencing its effects. The child’s welfare and safety remain  
paramount.  
Teenage relationship abuse, stalking or coercive behaviour may arise whether or not the young  
people involved fall within the statutory domestic abuse definition. Safeguarding procedures,  
proportionate safety planning and referral to the school DSL, children’s social care or police must be  
followed as appropriate.  
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Guardianship organisations should be aware that students could potentially experience domestic  
abuse both in their own homes or whilst staying with homestays.  
ANTI-DISCRIMINATION AND ADDITIONAL SAFEGUARDING SUPPORT  
Compass takes a zero-tolerance approach to racism, faith-targeted prejudice, misogyny, misandry,  
homophobic bullying and other discrimination, whether online or offline. Staff and homestays  
should report incidents as safeguarding concerns when they affect safety or welfare. The DSL  
considers the child’s views and needs, the risk of retaliation, and appropriate school or agency  
coordination.  
Children with SEND, disability, medical conditions or allergies, mental health concerns, young-carer  
responsibilities or language and cultural barriers may require tailored communication, support and  
safeguards. Staff must not attribute signs of harm automatically to a child’s disability or condition.  
Relevant information from the parental Medical Form should be shared on a need-to-know basis.  
If a child is questioning their gender, staff respond respectfully, listen without assumptions or  
prejudice, consider the child’s safety, wellbeing and wishes and work with the school and  
appropriate professionals. Compass does not make clinical determinations or independently adopt  
school-specific policies on toilets, sports or boarding accommodation; safeguarding and privacy  
matters are considered in line with applicable law and current guidance.  
ONLINE SAFETY  
Compass is committed to protecting students from online harms, including risks arising from social  
media, gaming, messaging, generative AI, image manipulation and peer interactions.  
Staff/homestays respond promptly to concerns and make safe referrals rather than conducting their  
own investigations.  
Online safety risks are considered in four interrelated categories: content, contact, conduct and  
commerce. The Online Safety Policy and supporting annual risk assessment address how such harms  
may arise during school, travel, homestay stays and other guardianship activities.  
Content: exposure to harmful or illegal material, misinformation, pornography,  
discriminatory content, extremist material, self-harm or suicide content, and AI-generated  
sexual imagery.  
Contact: harmful interaction with other users, grooming, exploitation, coercion,  
impersonation, manipulation and unwanted contact, including via AI-enabled services.  
Conduct: behaviour that causes risk, such as cyberbullying, harassment, sharing or  
threatening to share intimate images, creating deepfake images, risky posting or other  
harmful digital behaviour.  
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Commerce: scams, phishing, gambling risks, inappropriate advertising, fraud, extortion and  
financial exploitation. Staff report concerns to the DSL/DDSL and follow statutory reporting  
routes as appropriate.  
The standalone Online Safety Policy addresses safe communication, student digital awareness,  
reporting pathways and appropriate Wi-Fi filtering/parental controls in homestays. A serious online  
safety report is handled as a safeguarding concern and information is shared on a need-to-know  
basis.  
Compass conducts an annual Online Safety Risk Assessment in line with AEGIS Standard 6.10.2.
The assessment covers cyberbullying, grooming, harmful content and AI-related risks.The DSL and
Director review the findings and identify necessary actions. Risks, training updates and corrective
actions are documented and monitored.
REVIEW  
Version: 2026 – Version 1.0  
Previous Review Date: 20 August 2025  
Review Date: 20 August 2026  
Effective Date: 20 August 2026  
Next Review Date: 20 August 2027  
Approved by: Lu Jin (Lucy)  
Position: Director  
Signature: ________Lucy Jin______________  
Date Approved: 20 August 2026  
INCIDENT FORM  
CHILD PROTECTION RECORD – Report of a Concern  
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Date of record:  
Date of incident:  
Name of referrer:  
Student name:  
Role of referrer:  
use initials for other children / young people involved, unless there is  
a specific need to name them in full  
Details of concern:  
contemporaneous notes, if taken, may be attached to this form  
Role of person  
reported to:  
Reported to:  
Signed:  
For DSL/ DDSL use:  
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Advice sought:  
(from whom and what  
was advice given)  
Action taken:  
Concern / referral  
discussed with  
parent / carer?  
If not, state reasons  
why – if yes, note  
discussion with parent  
If not, state reasons  
why – if yes, record to  
whom and any action  
agreed  
Referral made:  
Feedback to  
referring member of  
staff or homestay:  
By whom  
By whom  
Response to / action  
taken with student:  
Name and contact  
number of key  
workers:  
Name and contact  
details of GP:  
Other notes /  
information /  
concerns:  
Any other action  
required:  
Registered in England No. 9024815  
Compass Culture and Education Ltd.  
66 Paul Street, London EC2A 4NA  
020 84490119  
APPENDIX 2: STUDENT REMOVAL FORM  
In order to support the student safely, Compass asks the school to complete and return this Student  
Removal Form by email to gd2@compassedu.co.uk BEFORE a planned school removal. Where there  
is an immediate safeguarding or medical emergency, necessary emergency action must not be  
delayed while awaiting the form. In those circumstances, the reason for urgent action must be  
recorded, and the completed form requested as soon as practicable afterwards.  
School Name  
Student Name  
Date of Birth  
Reason for request of removal of  
student  
Has the student been assessed by a  
medical professional?  
Yes ☐ No ☐  
Date of assessment if applicable.  
Please provide a summary of  
assessment if applicable.  
Is the student at risk of harm to  
themself?  
Yes ☐ No ☐  
Yes ☐ No ☐  
Is the student a risk to others?  
Has the school followed its mental  
health and child protection policies and  
procedures?  
Please provide a copy of any relevant  
policies and procedures.  
Yes ☐ No ☐  
Any other additional information we  
should be made aware of  
Signature  
Name  
Position  
Date  
Registered in England No. 9024815