Global Safeguarding Policy

1. Policy Statement

  1. We believe that everyone we come into contact with, regardless of age, sex, gender identity, disability, sexual orientation, race, ethnic origin or religion has the right to be protected from all forms of harm, abuse, neglect and exploitation.

  2. We are committed to the responsive safeguarding of all children, young people and adults at risk of harm from all forms of violence. We take seriously our responsibility and duty to ensure that we, and anyone who represents us, do not in any way harm, abuse or commit any other act of violence against children, young people or adults at risk or place them at risk of the same.

  3. We will not tolerate abuse or exploitation by Staff or Associates. We therefore commit to addressing safeguarding throughout our work, through the three pillars of prevention, reporting and response.

2. Application

  1. This policy applies to all Staff (UK and US) and Associates.

  2. Staff refers to any employees and workers (including agency workers) of Big Win Philanthropy UK and Big Win Philanthropy US1.

    Associate refers to anyone who is undertaking duties for, on behalf of or in association with Big Win Philanthropy UK or US, and includes partners, consultants, volunteers, trustees, contractors.

3. Purpose

  1. The purpose of this policy is to protect people, particularly children, young people, adults at risk and any other recipients of assistance, from any harm that may be caused due to their coming into contact with Big Win Philanthropy. This includes harm arising from:

    • The conduct of Staff or Associates who act on behalf of Big Win Philanthropy; and/or

    • The design and implementation of programmes and activities funded by Big Win Philanthropy.

    Note that misuse of power can also apply to the wider community that Big Win Philanthropy serves, and can include exploitation by giving the perception of being in a position of power.

  2. This policy lays out the approach of and commitments made by Big Win Philanthropy to enabling safer environments that minimise the risk of harm and abuse, and informs Staff and Associates of their responsibilities in relation to safeguarding.

  3. This policy does not cover:

    • Sexual harassment in the workplace – this is dealt with under Big Win Philanthropy’s Anti-Harassment and Bullying Policy; or

    • Safeguarding concerns in the wider community not perpetrated by Big Win Philanthropy Staff or Associates.

4. What is Safeguarding?

  1. Safeguarding is about protecting people’s health, wellbeing and human rights, and enabling them to live free from harm, abuse, exploitation and neglect.

  2. In the sector in which Big Win Philanthropy operates, we understand safeguarding to, in practical terms, be: (i) taking all reasonable steps to prevent harm, including exploitation, abuse and harassment of all kinds from occurring; (ii) protecting people, including children, young people and adults at risk, from harm that arises from their coming into contact with our Staff or Associates who act on behalf of Big Win Philanthropy in the course of our work; and (iii) responding appropriately when harm does occur.

  3. Further definitions relating to safeguarding are provided in Annex 1.

5. Prevention – Roles and Responsibilities

  1. The UK and US Boards of Directors (Trustees) have ultimate responsibility for ensuring that Big Win Philanthropy protects the safety and wellbeing of all those who the charity comes into contact with, particularly children, young people and adults at risk. The Boards have oversight of this policy and Big Win Philanthropy’s handling of safeguarding reports. The UK Board is also responsible for determining whether any safeguarding matters meet the threshold for reporting as a serious incident to the Charity Commission for England and Wales in relation to safeguarding incidents, with delegated authority to the designated Safeguarding Lead on the UK Board to take decisions on behalf of the Board where urgent action is required.

  2. The Executive Team (which comprises Big Win Philanthropy’s Chief Executive Officer, Chief Operating Officer and President) is responsible for ensuring that appropriate resources, systems and training are in place to support effective safeguarding. The Executive Team promotes a culture of openness and accountability, where concerns are encouraged, taken seriously, and acted upon promptly without fear of retaliation.

  3. Programme Staff and Associates, as those with direct contact with vulnerable groups, are responsible for identifying and managing safeguarding risks in their day-to-day work. Line Managers (of Staff) and Big Win Philanthropy key contacts (for Associates who act on behalf of Big Win Philanthropy) support those they supervise or oversee to understand and fulfil their safeguarding responsibilities and actively encourage the timely reporting of all safeguarding concerns to the Safeguarding Focal Point.

  4. The operational staff have responsibility for ensuring that appropriate safeguarding due diligence is undertaken on prospective Staff and Associates.

  5. The Safeguarding Focal Point is responsible for owning, implementing and the continuous development of this policy. They act as the main point of contact for safeguarding concerns, receive and manage reports, ensure concerns are responded to appropriately, provide guidance to Staff and Associates who act on behalf of Big Win Philanthropy, and support ongoing improvement of safeguarding practice across the organisation.

    Regardless of these specific roles, all Staff and Associates who act on behalf of Big Win share safeguarding responsibility generally, are accountable for the protection of children, young people and adults-at-risk.

  6. In connection with this shared responsibility, Big Win Philanthropy will:

    • Ensure all Staff and Associates who act on behalf of Big Win Philanthropy have access to, are familiar with, and know their responsibilities within this policy.

    • Design and undertake all its programmes and activities in a way that protects people from the risk of harm that may arise from their coming into contact with Big Win Philanthropy. This includes the way in which information about individuals affected by our programmes is gathered and communicated.

    • Put in place stringent safeguarding procedures when recruiting, managing and deploying Staff and Associates.

    • Ensure Staff receive training on safeguarding at a level commensurate with their role in the organisation.

    • Follow up on reports of safeguarding concerns promptly and according to due process.

  7. Additionally, Staff and Associates who act on behalf of Big Win Philanthropy are obliged to:

    • Abide by the Safeguarding Code of Conduct set out in Annex 2;

    • Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of this Global Safeguarding Policy;

    • Report, without delay, any concerns or suspicions regarding safeguarding violations by a Big Win Philanthropy Staff member or Associate to the appropriate person. See Section 7 for further information on reporting.

6. Working with Others

  1. Big Win Philanthropy relies on partnerships with others in order to carry out its charitable purposes, and recognises that conceptions of safeguarding and the legal frameworks governing child protection and adults at risk may vary across countries and contexts. While local laws and practices are respected, this policy establishes the minimum standards that all Staff and Associates who act on behalf of Big Win Philanthropy are expected to meet.

  2. Big Win Philanthropy must be confident that there are clear lines of responsibility and accountability for safeguarding, particularly when working with other organisations to implement initiatives that benefit the populations served. Big Win Philanthropy should therefore be satisfied that any partner organisation has in place adequate safeguarding policies, procedures and mechanisms to provide assurance on compliance. This is particularly important for Big Win Philanthropy, which undertakes development work overseas.

  3. Accordingly, it is Big Win Philanthropy’s policy to ensure that:

    • All individuals engaged directly by Big Win Philanthropy (whether, for example, an independent contractor, consultant or volunteer) sign or otherwise agree to comply with the Safeguarding Code of Conduct set out at Annex 2;

    • All partner organisations and governments to whom Big Win Philanthropy provides funding are provided with a copy of the Guidelines set out at Annex 3; and

    • All partner organisations and governments that we work with have in place safeguarding policies and procedures of their own. Staff should feel free to contact the Safeguarding Focal Point for guidance on whether a partner’s policy and procedural documentation are appropriate for Big Win Philanthropy’s purposes.

7. Recognising and Reporting Concerns

  1. Concerns about risk of harm to children, young people and adults at risk may come to our attention in a number of different ways including through observation; a report from a survivor or another individual that harm has occurred; recruitment checks identifying potential risks or past concerns or risk assessments highlighting situations or activities that may give rise to safeguarding risks.

  2. The primary duty of Staff and Associates acting on behalf of Big Win Philanthropy in respect of responding to safeguarding incidents is to report any and all concerns immediately. Reports can be made directly to the Safeguarding Focal Point, or, if they are not available, to their line manager (for Staff), or Big Win Philanthropy key contact (for Associates acting on behalf of Big Win Philanthropy). Subject to paragraph 7.3, any report made to a line manager or key contact must then be shared promptly with the Safeguarding Focal Point.

  3. If the Staff member or Associate acting on behalf of Big Win Philanthropy does not feel comfortable reporting to the Safeguarding Focal Point or their line manager / Big Win Philanthropy key contact (for example, if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to a member of the Executive Team.

  4. Staff or Associates (acting on behalf of Big Win Philanthropy) raising safeguarding concerns through formal whistleblowing channels (or if they request it) will be protected by Big Win Philanthropy Whistleblowing Policy, where applicable.

  5. Big Win Philanthropy will also accept reports of safeguarding concerns from external sources such as members of the public, partners and official bodies.

Safeguarding Focal Point: Legal Officer, legal@bigwin.org

8. Investigating Reports

  1. All safeguarding concerns reported to Big Win Philanthropy will be investigated in accordance with the Global Safeguarding Procedures (Annex 5), and applicable legal and regulatory obligations. Investigations will be conducted proportionately and appropriately based on the nature and circumstances of the concern, ensuring fairness, confidentiality, and protection for all parties involved.

  2. If, following an investigation, a Staff member or Associate is found to have breached this policy, appropriate sanctions will be applied. This may include, for Staff, disciplinary action leading to possible dismissal; or, for Associates acting on behalf of Big Win Philanthropy, termination of all relations including contractual and partnership relationships. In all cases, where relevant, appropriate legal or other such action may also be taken.

  3. If a safeguarding concern regarding a child, young person or vulnerable adult is raised in good faith but is not substantiated upon investigation, no action will be taken against the reporter. Deliberately false and malicious reports, however, may result in appropriate sanctions being applied.

  4. We will also offer support to survivors of harm caused by Staff or Associates. Decisions regarding support will be led by the survivor.

9. Referrals to External Bodies, Confidentiality and Data Protection

  1. It is essential that confidentiality is maintained at all stages of the process when dealing with a safeguarding concern. Information relating to the concern and subsequent investigation will be shared on a need to know basis only, within Big Win Philanthropy and externally, and will be kept secure at all times.

  2. Decisions to report concerns to regulators, agencies and other external authorities will be made in accordance with applicable legal and regulatory obligations.

    Examples of reports of this kind include the filing of a serious incident report to the Charity Commission for England and Wales2, or reports made to the relevant police and/or safeguarding authorities in line with applicable laws and regulatory guidance3 where there is evidence that criminal activity may have taken place, or concerns have been raised in relation to a child or vulnerable adult.

  3. Data protection considerations will be taken into account but will not prevent the sharing of information where this is necessary to safeguard individuals, provided that any disclosure is made in accordance with applicable data privacy laws. Where possible and appropriate, consideration will be given to anonymisation or pseudonymisation of personal data.

Notes

1 Big Win Philanthropy comprises of two entities; Big Win Philanthropy which is an English charitable company limited by guarantee with company registration number 09595920 and charity registration number 1162036 and Big Win Philanthropy Inc., the US s501(c)(3) entity with employer identification number 82-0843080.
2 The Charity Commission has published guidance as to what constitutes a serious incident and how to make a report, which is updated from time to time and available at https://www.gov.uk/guidance/how-to-report-a-serious-incident-in-your-charity.
3 For example, The Charity Commission has published guidance on the criminal reporting of safeguarding offences (including overseas), which is updated from time to time and available at gov.uk.

Last updated April 2026.

Annexes not included here can be requested from the Legal Officer at legal@bigwin.org.

Annex 1 – Definitions

Adult(s)-at-risk is sometimes also referred to as ‘vulnerable adults’. A person who is or may be (i) in need of care by reason of mental or other disability, age or illness, and (ii) unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.

Associate refers to anyone who is undertaking duties for, on behalf of or in association with Big Win Philanthropy UK or US, and includes partners, consultants, volunteers, trustees, contractors, programme visitors.

Child is a person below the age of 18.

Harm is psychological, physical and any other infringement of an individual’s rights.

Psychological harm is emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation.

Recipient(s) of assistance is someone who directly receives goods or services from Big Win Philanthropy’s programmes.

Sexual abuse means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual exploitation means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.

Survivor is the person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.

Young person / youth, in line with United Nations definitions, includes individuals aged 15 years to 24 years old. This group spans the categories of ‘children’, ‘adolescents’ and ‘adults’ but regards young people as having particular safeguarding needs and requiring distinct consideration aside from younger children and older adults.