Policies

Policies

Safeguarding Policy

1. Introduction
More Positive Me C.I.C. is committed to empowering people impacted by domestic abuse who have received safeguarding, MARAC, IDVA, ISVA and/or Outreach Support, who are no longer in an abusive relationship and are ready to move forward. 

2. Additional Needs 
This could include people with learning disabilities, mental or physical health problems, older people and people with a physical disability or impairment. Their need for additional support to protect themselves may be increased when complicated by additional factors such as physical frailty or chronic illness, sensory impairment, challenging behaviour, drug or alcohol dependency, social or emotional problems, poverty or homelessness. This policy relates to adults of 18 years or older. All clients coming to More Positive Me are with additional needs will be encouraged to access further support via organisation within our working alliance. We recognise PTSD, cPTSD, Anxiety & Depression as the impact of domestic abuse.    

3. Definition of Domestic Abuse 
The government definition of domestic violence and abuse is:
“Any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality.”
Section 3 of the Domestic Abuse Act 2021 came into force on 31 January 2022 and specifically provides that a child (under 18 years old) who sees, hears, or experiences the effects of domestic abuse and is related to the victim or the suspect is also to be regarded as a victim.
Psychological abuse - Physical abuse - Sexual abuse - Economical abuse - Emotional abuse - Coercive control. 

4. Whole team awareness
All involved with More Positive Me C.I.C, including directors, contractors, employees and volunteers need to be aware of the prevalence of abuse within our society and its institutions and be able to identify and address matters of concern.

Safeguarding Adults Code of Conduct 

All directors, staff, contractors and volunteers must abide by the principles set out in the Team Safeguarding Agreement below.

More Positive Me Team Safeguarding Agreement 
          
More Positive Me provides peer support groups and signposting for adult survivors of domestic abuse. 

Our purpose is to meet as equals, to support one another, to talk openly and honestly about abuse and the effects that abuse has had on us and society. We do this in order to gain a better understanding of ourselves and one another, through the framework of our Empowerment Course and Rediscovering You Self Care Toolkit.

Anyone working with us must be working towards completing the DASST level 1, 2 & 3 training to grow awareness of domestic abuse and its traits. Team Members can ask Jeanette Brown, Director, for access to this.
Trauma awareness training & Domestic Abuse Champions training alongside DASH risk assessment training and MARAC understandability must be completed within the first 6 months of enrolment.
Further training will always be offered and encouraged. 

In order to create a safe and supportive recovery environment we mutually agree to: 
  1. No alcohol 
  2. No drugs 
  3. No sexual contact 
  4. No physical violence/aggressive behaviour/aggressive language 
  5. No discriminatory language or behaviour based on ethnicity, gender, sexual orientation, religion or disability
  6. Non judgemental approach
  7. Group agreement for confidentiality

In order to protect the identity and honour the confidentiality of group members, we agree not to say anything that would reveal their identity to others outside of the group, and ahere at all times to the Confidentiality Policy. 

We do not rush to rescue or fix, we allow people to feel their feelings in a safe and supportive space. 

If a group member needs to leave the room, a More Positive Me CIC Team Member will follow them to offer support.

More Positive Me CIC aims to work in a manner which protects clients from being abused.

Safeguarding Procedure
If a client or Team Member shares some information that makes you suspect a high risk to the safety of the client, immediately complete a DASH risk assessment and offer client access to the J9 Folder. Team Members can ask for support from a Director to complete this.
Before completing the DASH, explain the following to the at-risk individual:
  • Information shared will be treated as confidential within More Positive Me, in line with our Confidentiality Policy, unless the risk is high, when you have a duty of care to complete the MARAC referral (Multi Agency Risk Assessment Conference).  
  • A MARAC referral would only be made to safeguard them and their family when we believe they are at high risk of harm, and that while we would ideally have their consent for this, a referral may take place even in the absence of their consent.
  • Individuals with a medium-low risk result can only be referred with consent.
Make suitable adaptations to communication and check the individual has understood.
If the DASH scores above 14, or you feel the risk is imminent, then a Director of More Positive Me must be informed and a MARAC form completed and submitted that day. 
  • Respond sensitively and coherently to reported incidents of self- neglect and abuse, in a consistent manner, recording the actual words where possible, checking your understanding with the client.
  • Take every precaution to prevent putting yourself or a client in a position that increases the risk of emotional or physical harm to yourself or them. If unsure what to do, ask a director for guidance.
  • If you feel there is an imminent risk to the safety (including risk of suicide) of any More Positive Me CIC Team Member, group member or yourself, dial 999 and ask for the police.
  • Adhere to all More Positive Me policies and flag any instances where changes may be needed.
  •  Agree to undertake Safeguarding training as advised by the Directors and to ask if you feel you need further training or support.
5. Statement of Intent 

More Positive Me C.I.C. will: 
  •  Provide an abuse-free environment. At the beginning of every group session, the group agreement will be made visible, and a reminder of the agreement will be made when necessary.
  • Recognise internal and external abuse. 
  • Always inform a Director if there are any issues. 
  • Take action against Directors, staff, associates, students and volunteers who are proved to have abused others. 
  • Ensure that Directors, staff, associates, volunteers who work with our clients have appropriate training and undertake a DBS.

6. Responsibilities 
A. More Positive Me C.I.C. will adopt and review the implementation of this policy.
B. The Directors are Safeguarding Leads, will retain overall responsibility and will make all final decisions which relate to
     this policy.
C. More Positive Me C.I.C. are responsible for reviewing and updating this policy and will keep those involved with
     More Positive Me C.I.C. informed of any changes in the law. 
D. All Directors, staff, volunteers and associates are responsible for the implementation of this policy within their
     workplace.
E. You are required to adhere to this policy.

7. Be Alert 
  • Think about what you see and hear. 
  • Take seriously what you are told and take prompt action. 
  • Be aware that the client may not understand they have been abused and so do not realise the significance of what they are telling you. 

8. Checks and Training 
  • All staff, associates and volunteers who work with our clients will be required to complete the appropriate training and undertake an Enhanced Disclosure and Barring Service check.
  • Individual clients will be risk assessed, when appropriate.
9. What you should do 
If you suspect that an adult is being treated in a way that may be harmful to their physical or emotional well-being you should follow the Safeguarding Procedure, raise your concerns, and pass on any information you have to a Director immediately; 
  • Jeanette Brown, Director (07743 563222) jeanette@morepositiveme.co.uk
  • Hannah Hill, Director (07410 403776) hannah@morepositiveme.co.uk
If a Director is unavailable, you should contact Devon Domestic Abuse Support Service (currently FEARFREE), who will be able to advise: Phone 03451551074, retaining a note of what has happened in line with the Data Protection Policy. 

A confidential written record will be made and kept by the Director who will discuss the matter with the staff, associate or volunteer as soon as possible, and decide how to progress the matter.

You will be expected to provide details of your concerns and any evidence you have. You may be asked, at a later stage, to join in a joint discussion with the appropriate agencies to clarify the concerns. You will be provided with support through this process.

Please follow the instructions below 

DO:
 
 Stay calm and try not to react in a way that may cause anxiety to the 
        Vulnerable Adult.
 Listen carefully.
 Be empathetic.
 Explain you must tell one of the Directors and that if there is a high risk information may be passed to MARAC (Multi Agency Risk Assessment Collaboration) with the full intention of supporting their risk. 
Make notes of what the person said using their words and store in line with the Data Protection Policy.
 Tell the person that: - 
They did the right thing by telling you. 
You will treat the information seriously.
It is not their fault. 
Inform the Director the same day of your concerns and actions. 
DO NOT: 

press for more details, 
promise to keep it secret,
discuss with anyone else apart from the Directors or the Devon Domestic Abuse Helpline 0345 1551 074 for support and advice. 
be judgemental e.g. Why didn't you run away? 
stop someone telling you or ignore them. They may never disclose again.

What a Director of More Positive Me C.I.C. should do:

Directors of More Positive Me C.I.C. are responsible for ensuring that staff are aware of the Company’s policies and of the relevant non-policy procedural documents. 

When an alert is raised by a member of the staff, associate or volunteer regarding a client, colleague or member of the public, a Director of More Positive Me CIC will:- 
      • support their member of staff in following the objectives of this
         policy, 
      • safeguard the rights of a Whistleblower, 
      • take responsibility for making an initial decision with their member of
         staff, associate or volunteer as to whether this incident falls within
         the Safeguarding policy. 
      • If in doubt it should be included, a discussion with a Director must
         take place the same day to make a safeguarding decision,
      • make an incident report on the clients section on the database, store
         it in line with the Data Protection Policy, and follow the procedure
         above, 
      • if there is any possibility that a crime has been committed, contact
        the Police Safeguarding Team by phone Tel: 08456051166 

Take steps to ensure that any evidence is protected and is available for a  MARAC referral/ meeting. 
• ensure that the client that disclosed is kept informed of the 'progress' of
   the alert and steps being taken. 

Please note: The Directors of More Positive Me C.I.C. and/or staff will usually be invited to attend the MARAC meeting. They may also make a request to attend.

More Positive Me C.I.C. agree to adhere to and follow the Multi —agency safeguarding protection procedures which require More Positive Me C.I.C. to work in full cooperation with partner agencies, usually through a MARAC meeting. It is important to take an open and non-defensive approach to allegations and to ensure there is a measure of independence within the safeguarding process.

Please also note that complaints made about any members of More Positive Me C.I.C. are covered in our Whistleblower, Complaints, and Grievance policies and procedures. 

 It is important that a Director of More Positive Me C.I.C. takes 'ownership' of the whole process as the ‘responsible manager’. 
The key elements of this, for clarity are: 
the responsibility for overseeing the investigation, 
action plan and outcome communication.

Marac forms https://www.devon.gov.uk/dsva/information-for-professionals/marac/

DASH forms https://safelives.org.uk/sites/default/files/resources/Dash%20for%20IDVAs%20FINAL_0.pdf

This policy should be read in conjunction with Appendices A & B.  
Devon County Council have centralised the three-locality based Safeguarding Adult Hubs, creating one Devon Safeguarding Adults Service. 

Centralisation enables a single point of contact for all Safeguarding Adult Concern referrals made to Devon County Council. The intention is to deliver an equitable and timely response to Safeguarding Adult Concerns referrals and timely decision making and communications in relation to Section 42 of the Care Act (2014). 
The service will consist of a single management and leadership structure operating across the County. The newly appointment service manager for the Devon Safeguarding Adults Service is Carly Stanton.

How to make a Safeguarding Adult Concern Referral to Devon County Council:

All Safeguarding Adult Concern referrals can now be made direct to: adultsc.safeguardingadultservices-mailbox@devon.gov.uk   

To ensure that referrals in progress are not compromised, the mailboxes for the previous locality hubs will remain open until 5th May 2024
(Auto responses have also been set up providing the new shared mailbox address) 
The generic telephone contact details for the Devon Safeguarding Adults Service will be confirmed via further email in due course.

As per current process:
If you feel that you need an urgent response to your email, please telephone the existing locality telephone number, which have not changed, and chose from the list of options 

• Exeter, East and Mid Devon 01392 381206
• South and West Devon 01392 381211
• North Devon 01392 381208 

If you are emailing outside of normal working office hours and the matter is urgent, involving the safety of an adult, please contact our Emergency Duty Service on 0345 6000 388. 

If your concern is for the immediate protection and safety of an adult, please consider the need to call the appropriate emergency service.

Domestic Abuse Policy
Introduction
This policy covers the internal and external support available to employees experiencing, or involved in, domestic abuse. Everyone has the right to live free from abuse in any form and the responsibility for abuse lies with the perpetrator. There is an increased awareness of the prevalence of domestic abuse in society and the Company understands that there may be colleagues who are experiencing domestic abuse, or who want to support friends, colleagues or family members who are going through it.

About this policy
This policy applies to all Team Members of More Positive Me CIC, whether temporary or permanent, and includes Directors, employees, consultants, workers, volunteers, self employed associates and interns.  
The policy will refer to ‘Team’ or ‘Team Member’ throughout, and by this, we are referring to all the people indicated above.

The aims of this policy are to:
· Support all Team Members experiencing domestic abuse and promote their health, safety and well-being at work.
· Recognise that a Team Member’s ability to work may be impacted both directly by the perpetrator of domestic abuse, but also indirectly owing to the physical and mental impacts of domestic abuse.
· Enable Team Members experiencing domestic abuse to remain productive, efficient and at work.
· Aid Directors seeking to help Team Members who are experiencing domestic abuse.
· Assist colleagues of Team Members who are experiencing domestic abuse.
· Reinforce the Company's zero tolerance attitude towards domestic violence.
· Where appropriate, signpost to specialist services perpetrators who voluntarily wish to seek advice and support to address their behaviour.

What is domestic abuse?
Domestic abuse is legally defined as abusive behaviour by one person to another, where they are both 16 or over and they are personally connected. The abusive behaviour can be a single incident or a course of conduct. Behaviour is considered abusive if it consists of any of the following:

• physical or sexual abuse.
• violent or threatening behaviour.
• controlling or coercive behaviour.
• economic abuse; and
• psychological, emotional, or other abuse.

Company support (See also ‘Reasonable Adjustments’ Below)
It is the More Positive Me CIC's intention to deal constructively, compassionately, and sympathetically with cases of domestic abuse. The Company will support all those who endure and/or witness domestic abuse, regardless of any protected characteristics. If you are concerned about your own personal situation or that of a colleague, you are encouraged to seek support.
You can speak in confidence to the Directors, who can provide initial support, signpost you to resources and help you with any disclosure conversations you would like to have with colleagues and, if you have not done so already, with your HR contact, Nicola Brown, nic@br-hr.co.uk, 07752 194837. The Directors or HR contact will work with you to formulate a response including:
(a) Discussing and agreeing ways to help you stay safe in the workplace.
(b) Signposting you to the appropriate domestic abuse resources; and
(c) Facilitating referrals.
Please refer to the paragraph below relating to confidentiality.
Directors have a role to play in enabling Team Members experiencing domestic abuse to seek help and support. 
The role of the Director is to:
· Identify Team Members who may be experiencing difficulties because of domestic abuse, for example, Team Members coming to work with unexplained injuries, who appear distressed, have unexplained periods of time off work, or show an uncharacteristic deterioration in work performance.
· Provide initial help and support, including advice on the options available for the Team Member, and referrals to appropriate sources of professional help, whilst supporting the Team Member to make their own decisions.
· Protect confidentiality as far as possible (see the paragraph on confidentiality below).
· Refer the individual to the appropriate sources of help, both internal and external, with the consent of the Team Member where possible (see the paragraph on confidentiality below).
· Discuss measures to prioritise safety at work and ensure that the health and safety of all Team Members are protected.
· Support the Team Member to remain productive, efficient and at work.

Confidentiality
Where a Team Member has discussions with the Directors, or HR contact, that they are experiencing domestic abuse, confidentiality will be maintained as far as possible in line with Company procedures. There are, however, some circumstances where confidentiality cannot be assured. 
These circumstances occur when:
There are concerns about children or vulnerable adults, where high risk to safety has been identified or;
Where we need to act to protect the safety of members of the public, including other colleagues.
Where we believe an individual or family members are in genuine danger this may be reported to the police. This will be subject to prior discussion with the Team Member wherever it is reasonably practicable to do so.
Personal data will be stored in accordance with the company’s data protection policy.

Safety at work
We acknowledge our duty to protect the health, safety and well-being of all Team Members at work, including those affected by domestic abuse. This includes situations where the perpetrator of the abuse is harassing a Team Member at work, for example, turning up at the workplace unannounced, constantly telephoning/e-mailing/texting the Team Member during the working day or harassing the Team Member’s work colleagues.
Team Members need to disclose to the Company that they are at risk from domestic abuse in order to receive this protection, and the Company therefore actively encourages Team Members to disclose when they are experiencing domestic abuse or are worried about behaviour of a current or former partner or family member towards them. Other Team Members should also disclose to the Company if they are being harassed by a work colleague’s current or former partner or family member.  

Perpetrators of domestic abuse
The Company will not tolerate or condone domestic abuse, regardless of the identity or seniority of the perpetrator. If the Company becomes aware that an employee is or may be perpetrating domestic abuse, it will take appropriate action, which could include disciplinary action under the organisation’s disciplinary policy. 
Any domestic abuse perpetrated by a Team Member that endangers another Team Member, or uses company equipment to inflict that abuse, such as mobile phones or laptops, may result in disciplinary action under the organisation’s disciplinary policy up to and including dismissal for Gross Misconduct. The Company takes a zero tolerance approach to domestic abuse and therefore, disciplinary action may be appropriate in some circumstances even where the perpetrator’s behaviour takes place outside work.

The Company recognises that in some cases it may be appropriate to signpost to specialist services Team Members who disclose that they themselves are perpetrators of domestic abuse and who genuinely want to change their behaviour. This will be decided on a case-by-case basis.

Reasonable adjustments
  • Where a Team Member needs time off to access support, manage any legal issues or family requirements, the Company will provide a reasonable amount of time off per year. Team Members who need time off should discuss this with the Directors to agree how much leave is required, how and when it will be taken, and whether leave will be paid or unpaid. 
  • More Positive Me CIC is a supportive organisation whose aims reflect their commitment to ensuring all Team Members feel safe and supported in the workplace regardless of their background, experiences and home life.  
  • The Company welcomes any discussion or request regarding Flexible Working Hours, and whilst it cannot guarantee to grant these, does commit to giving full consideration to any such request with empathy and respect.
  •  More Positive Me CIC encourages Team Members to speak to the Directors about proposed reasonable adjustments to their work/hours at any time, to enable the Company to support them to live a safer, more fulfilled and positive life as a valued Team Member.

Grievance Policy

Areas of Grievances 

  • Grievances normally arise within the following areas: 
  •  terms and conditions of employment
  •  health & safety
  •  bullying and harassment
  •  working environment
  •  organisational change
  •  discrimination or
  •  personality conflict 

Dealing with grievances informally 
More Positive Me C.I.C. is a small organisation and different combinations of staff and directors will work together at different times. If you have a grievance or complaint to do with your work or the people you work with you should, wherever possible, start by talking it over with the director who is supervising you. You may be able to agree a solution informally between you.

Formal grievance 
If the matter is serious and/or you wish to raise the matter formally you should set out the grievance in writing to the director who is supervising you. You should stick to the facts and avoid language that is insulting or abusive. Where your grievance is against the director who is supervising you and you feel unable to approach them, you should write to another director of More Positive Me C.I.C. using the following email addresses:
Jeanette Brown, Director - jeanette@morepositiveme.co.uk
Hannah Hill, Director - hannah@morepositiveme.co.uk

 Grievance hearing 
The director who is supervising you, will call you to a meeting, normally within ten working days, to discuss your grievance. You have the right to be accompanied by a colleague or trade union representative at this meeting if you make a reasonable written request at least 12 hours in advance (although reasonable discretion will be exercised if the timescales are short). 
More Positive Me CIC may arrange for someone not involved in the grievance to observe the meeting to take notes and act as a witness to what is said by all parties. This may be another More Positive Me director or staff member, or a director or staff member of another organisation. We will notify you at least 12 hours in advance of who this will be (although reasonable discretion should be exercised if timescales are short).
Where the grievance is against the director that is supervising you, the meeting will be with the director with whom you have raised the grievance. 
The purpose of the meeting will be to ascertain the details of the grievance and identify any points requiring further investigation.
 After the meeting, the director with whom you have raised the grievance will investigate your grievance as necessary, and give you a decision in writing, normally within five working days. This will outline how they have investigated the grievance and what, if any, action they have decided to take.

Appeal 
If you are unhappy with the director's decision and you wish to appeal you should let them know in writing at the email address above. You will be invited to an appeal meeting normally within ten working days, and your appeal will be heard by the Clinical Lead of More Positive Me C.I.C. You have the right to be accompanied by a colleague or trade union representative at this meeting if you make a reasonable written request at least 12 hours in advance. 
More Positive Me CIC may arrange for someone not involved in the grievance to observe the meeting to take notes and act as a witness to what is said by all parties. This may be another More Positive Me director or staff member, or a director or staff member of another organisation. We will notify you at least 12 hours in advance of who this will be .
After the meeting the Clinical Lead will give you a decision, normally within five working days. 
The Clinical Lead’s decision will be final. 
If you wish to speak to the HR Department about anything involving a Grievance, you can contact:
       Nicola Brown, nic@br-hr.co.uk, 07752 194837


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