Safeguarding Children at Risk Policy

Approved by: Acting Chairman April 20th 2023
Date: March 2023
Version Number: 1.0
Status: Draft
Review Frequency: Every 2 year
Next review date: 2025
Relevant Legislation / Licences: The Childcare Act 2006 (amended 2018)
The Children Act, 1989
The Children Act 1989 (as amended).
The Children and Social Work Act 2017.
The Safeguarding Vulnerable Groups Act 2006.
NSPCC Code of Conduct for Staff and Volunteers (updated 2018)
Related Policy / Document: Safeguarding Adults at Risk
Equality, Diversity, and Inclusion Policy
  1. Purpose

    1. Heulwen Trust (the Trust) is committed to promoting the safeguarding and welfare of children and young people (which we define as ‘children’ in this policy). The purpose of this policy statement is to:
      • Protect children and young people using The Trust services from harm. This includes the children of adults who use our services.
      • Provide THE TRUST staff and volunteers, as well as children and young people and their user groups/families, with the principles that guide our approach to child protection.
    2. All children are entitled to feel safe and protected from any form of harm, abuse and neglect and have the right to take part in The Trust projects in a positive and enjoyable environment.
    3. Our staff, Trustees volunteers or people involved with our projects have a responsibility to safeguard children and promote their welfare. This policy is designed to achieve this and to promote a climate where children, young people and adults will feel confident about sharing any concerns that they may have about their own safety or the well-being of others. It complies with current safeguarding legislation and relevant guidelines for working with children, such as the NSPCC Code of Conduct for Staff and Volunteers.
    4. Children and young people using The Trust services will nearly always do so as part of a group brought and controlled by a user organisation whose staff will have appropriate training and qualifications in accordance with the user organisation’s safeguarding policy and who will have primary responsibility at all times for the children and young people within their group. However, The Trust staff and volunteers nonetheless continue to have a responsibility to safeguard the children and young people and to promote their welfare. The NSPCC Code of Conduct is encapsulated in this policy and should be read in conjunction with this policy.
  2. Policy Scope

    1. This policy applies to anyone working on behalf of the Trust’s, including its Board of Trustees, paid staff and volunteers who have contact with children or young people through our work.
    2. Where this document refers to a ‘child’ or ‘young person’ we mean anyone who has not yet reached the age of 18 years. Where we refer to ‘child’ or ‘children’ we also mean ‘young person’ or young people’.
  3. Policy Principles

    1. Our policy statement is based on the following key principles:
      • The welfare of the child is paramount
      • Children and young people should never experience abuse of any kind
      • We have a responsibility to promote the welfare of all children and young people, to keep them safe and to practice in a way that protects them
      • All participants regardless of age, sex, ability or disability, race, colour, nationality, ethnic or national origin, religion or belief, size, or sexual orientation have the right to protection from harm and the right to enjoy the activities of the group in a happy, safe and secure environment
      • Some children are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues and we take this into account
      • Working in partnership with children, young people, youth workers from user organisations, parents, carers and other agencies is essential in promoting young people’s welfare
      • All allegations, suspicions of harm and concerns will be taken seriously and responded to swiftly, fairly and appropriately
    2. This policy and procedure will help us to achieve these principles by:
      • Setting out our safeguarding practices, defining abuse and providing clear guidelines on what where we suspect abuse
      • Ensuring all THE TRUST employees, Trustees and volunteers (‘staff’) understand and adhere to this policy and protection procedures
      • Being clear on the roles and responsibilities we all have in safeguarding
      • Ensuring children, young people and their families know about our safeguarding policies and what to do if they have a concern by publishing this policy on the Trust web site ( and including it in our booking confirmations, as appropriate
      • Appointing a nominated safeguarding lead in The Trust and a member of the Trustee’s board who takes lead responsibility for safeguarding
  4. Types of Abuse and Neglect

    1. Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family setting or in an institutional or community context (such as gang warfare and knife crime) by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults or another child or children.
    2. The key categories of abuse and neglect are:
      1. Physical AbusePhysical abuse 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.
      2. Emotional AbuseEmotional abuse is the persistent emotional maltreatment of a child resulting in severe and persistent adverse effects on the child’s emotional development. This may include:
        • Conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person.
        • Not giving the child opportunities to express their views, deliberately silencing them or “making fun” of what they say or how they communicate
        • Age or developmentally inappropriate expectations being imposed on children.
        These may include interactions that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction
        • Seeing or hearing the ill-treatment of another
        • Serious bullying (including on-line bullying) causing children frequently to feel frightened or in danger
        • The exploitation or corruption of children
        Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone. In this context, potential examples of emotional abuse could include:
        • Subjecting a child to constant criticism, name-calling, sarcasm or bullying
        • Regular exclusion of a child from an activity
        • Staring at or ignoring a child
      3. Sexual AbuseSexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening, including prostitution. Such activities may involve physical contact, including penetrative acts (e.g. rape, buggery or oral sex) or non-penetrative acts (e.g. masturbation, kissing, rubbing and touching outside of clothing). Sexual abuse may include non- contact activities, such as involving children in:
        • Seeing or looking at, or in the production of, sexual photographic or online images, or watching sexual activities
        • Seeing or receiving or sending sexually suggestive emails or text-messages
        • Internet harm, such as Internet chat rooms
        • Encouraging children to behave in sexually inappropriate ways
        • Grooming a child in preparation for abuse (including via text or the internet)
        • Sexual abuse is not solely perpetrated by adult men and women. Other children may also commit acts of abuse.
      4. NeglectNeglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may involve a parent or carer failing to:
        • Provide adequate food, clothing and shelter (including exclusion from home or abandonment)
        • Protect a child from physical and emotional harm or danger
        • Ensure adequate supervision (including the use of inadequate caregivers Ensure access to appropriate medical care or treatment
        • Take care of or respond to a child’s basic emotional needs
        Potential examples of neglect relating to our projects could include:
        • Ensure children are safe or exposing them to unnecessary risk of injury
        • Exposing children to undue cold or heat or unsuitable weather conditions
      5. BullyingShould bullying occur it usually has elements of one or more of the four categories identified above. Bullying takes many forms, but ultimately it is the perception of the victim that determines whether or not they are being bullied rather than the intention of the bully. The bully can be any adult or another child who pushes too hard. Bullying can also take place in the virtual world of social networking sites, emails or text messages (online bullying sometimes referred to as cyberbullying). The Trust considers any act of bullying seriously and will work to stop it immediately.
      6. Other Forms of Harm
        • Female Genital MutilationFemale genital mutilation (FGM) is typically performed on girls of 4 -13 years but may be performed on new born babies or on young women. FGM can result in death. FGM is a criminal offence (Prohibition of Female Circumcision Act 2003) and it is an offence to arrange, procure, aid or abet female genital mutilation. Parents/carers may be liable under this act. Should he Trust become aware that a girl is at risk of FGM a referral should be made to Children’s Social Care.
  5. Safeguarding Children with Additional Needs

    1. Children with additional needs may need more support. These include children with any major physical impairment, severe illness and/or a moderate to severe learning difficulty or an ongoing high level of dependency on others for personal care and the meeting of other basic needs.
    2. Such children are at increased risk of abuse and can be disproportionately impacted by bullying without outwardly showing any signs, creating additional safeguarding challenges for those involved in safeguarding and promoting the welfare of this group of children.
    3. Children with a disability or additional needs may be more susceptible to harm than other participants and additional barriers can exist when detecting any abuse or neglect of these children because they may:
      • Have fewer social contacts than other children and so lack the mutual support and protection of a peer group
      • Receive intimate personal care from a larger number of carers making it more difficult to identify the abuser
      • Have an impaired capacity to understand what they are experiencing is abuse or to challenge the abuser
      • Have communication difficulties resulting in difficulties in telling people what is happening
      • Be reluctant to complain for fear of losing services
    4. It is also important to be aware of the additional needs some children experience as a result of a wide spectrum of issues such as autism, attention deficit hyperactivity disorder and a variety of other disorders.
  6. Policy Implementation and Compliance

    1. The Trust aim is to maintain a culture of protecting children and where everyone feels confident to raise legitimate concerns without prejudice to their own position.
    2. Concerns about the behaviour of any person involved in our projects which may be harmful to a child must be reported to our Designated Safeguarding Person (DSP).
    3. While the safety and welfare of children is of paramount importance, there will be times when those responsible will need to exercise discretion and common sense to ensure their wellbeing.
    4. We detail below how we maintain a safe, friendly and welcoming environment for children.
  7. Designated Safeguarding Person

    1. The Trust have a named Designated Safeguarding Person (DSP) The DSP will provide regular support and supervision to new Trustees, members of staff and volunteers in all areas of their work including child protection and safeguarding.
    2. User organisations or parents/carers, as appropriate, will be advised of the name of the DSP in their booking confirmation, to whom they may report any worries or concerns.
    3. Employees/volunteers are responsible for reporting suspected cases of child abuse to the DSP as a matter of urgency.
    4. In the event of any concerns regarding a child the DSP must be informed at the earliest available opportunity. If appropriate, the DSP will inform the relevant Social Services Department without delay and Chair of the Trust.
    5. The DSP will also ensure that The Trust safeguarding procedures are reviewed annually.
  8. Risk Assessment

    1. The Trust will carry out a Risk Assessment prior to any offsite visits or new types of activities.
    2. Where children and young people are part of and/or supervised by a user organisation, The Trust will ensure that the user organisation has carried out such a Risk Assessment, and if it has, The Trust will not carry out our own Risk Assessment save in exceptional circumstances where the user organisation’s Risk Assessment is considered obviously defective or inadequate.
  9. Recruitment and Checks

    1. The Trust will take all reasonable steps to ensure unsuitable individuals are prevented from having any involvement with the Trust. In practice we will:
      • Carry out an appropriate Disclosure Barring Service (DBS) check on every Trustee, employee or volunteer who may have access to children. This includes a self-declaration and reference checks
      • Interview all potential employees and volunteers
      • Ensure that all employees/volunteers have appropriate qualifications and training
    2. Where any concerns arise from the DBS check, we will:
      • Bring this to the attention of The Trust Executive Committee and Powys Children’s Safeguarding Board and seek appropriate guidance.
      • Assess the level of risk the subject poses to children, other service users, colleagues, general public and/or our organisation
    3. This risk assessment will include consideration of:
      • Whether the offence relates directly to work with children
      • The seriousness of the offence(s) and the circumstances surrounding it
      • Length of time since the offence was committed
      • Whether the person has a pattern of offending
      • Whether the person’s situation has changed since the offence occurred
      • The person’s explanation of the offence
      • Whether the person declared the offence prior to the DBS check
    4. Where all these questions are not answered satisfactorily the prospective employee/volunteer will not be allowed to join The Trust in any capacity.
  10. Training of Staff and Volunteers

    1. The Trust will make all staff aware of this policy as part of their initial induction process and provide regular briefings and updates. Additionally, we will:
      • Require all new staff and volunteers to read this Safeguarding Children and Young People Policy and sign Appendix F: Policy Compliance for THE TRUST Staff, Trustees and Volunteers to indicate that they have understood and will comply with it. This will enable our staff and volunteers to identify the signs of abuse and know what steps to take and who to report any concerns
      • Provide induction and awareness raising to all new employees/volunteers, including relevant training
      • The Trust will provide ongoing training and supervision will ensure all employees and volunteers are adequately supported.
      • Where appropriate, staff and volunteers will attend external training on child protection provided by the London Borough of Islington, Local Network Fund or other relevant providers
      • Until external training is possible, child safeguarding training will be cascaded by The Trust Designated Safeguarding Person
  11. Safe Activities

    1. The Trust staff working with children will:
      • Be appropriately trained and qualified to ensure the safe provision of services, use of equipment, activities etc.
      • Carefully plan activity sessions with the care and safety of children as their main concern including the use of activities at an appropriate age/ability level
    2. The Trust has First Aid kit on the boats and skippers are qualified First Aiders.
    3. Any accidents involving an adult or child should be recorded in The Trust Accident Book immediately, or as soon as practicably possible.
    4. Appropriate Trust staff should have access to any parent consent/emergency consent forms for all children obtained by The Trust or made available to the Trusts by a user organisation taking part in any activities. this information should be confidential in a locked filing cabinet in The Trust office.
    5. User organisations will be responsible for keeping a register of names, addresses, next of kin and contact addresses and telephone numbers for emergencies but where the user organisation has not done so, or in the absence of a user organisation, The Trust will do so.
    6. Similarly, where the user organisation has not done so, or in the absence of a user organisation parents/carers, and where appropriate older children, will be given a copy of a written statement which specifies the action which will be taken in the event of a child becoming ill or being injured. This will also indicate that any information which results in a suspicion that a child may be or may be at risk of being abused will be passed on to the Social Services Department and/or the police.
    7. The Trusts contingency plan will ensure that if a there is an incident or an accident occurs requiring the involvement of an THE TRUST staff member, that levels of supervision can be maintained by suitably DBS-checked adults.
    8. However, in an emergency, such as an injury, the first attention must be paid to the injured person. If there are insufficient suitably DBS-checked adults available to supervise the remaining children, clearly, other responsible adults will need to be asked to step in.
  12. Open Environment

    1. The Trust aims to provide a safe and open environment by avoiding private or unobserved situations and discouraging the keeping of secrets. To support this, The Trust staff should:
      • Ensure that they are not alone with a child at any time, out of the sight or presence of youth workers, parents or other THE TRUST staff. When this is unavoidable, it should be done with the full knowledge and consent of someone in charge of THE TRUST and/or the user organisation and/or the children’s parents/carers
      • Avoid using the same changing or wash room facilities at a venue, such as a swimming pool, or to shower or change at the same time.
      • If children need supervising in such facilities, two DBS-checked adults should be present
  13. Supervision and Staffing Ratios

    1. The Trust staff and volunteers will keep a check on visitors and guests whether their visit is by invitation or unsolicited.
    2. The Trust minimum adult to young person ratio requirement is a minimum of two adults who will usually be provided by the user organisation with every group of young persons (up to a maximum of ten). This exceeds laid down best practice standards.
    3. Communication is central to maintaining a safe environment. This includes:
      • Providing information to user groups before participating in an THE TRUST project or trip
      • Choosing the appropriate method of providing information to children and their parents before a trip
      • Listening to children’s views on matters which affect, such as activities to be undertaken during a trip.
    4. Messages relating to children (e.g. sent via ‘phone, emails, texts and other messaging systems), should be through the youth workers or parents responsible for them.
    5. The Trust will avoid direct personal communication with children at all times, unless there are except circs such as risk of harm.
  14. Transportation

    1. It is the responsibility of the user organisation to provide transport for children to and from the boats adhering to their own safeguarding policies.
    2. Arrangements for youth workers, parents or carers dropping off and collecting children from activities/trips will be clearly stated and agreed by the user organisation and/or parents/carers, children and the THE TRUST employees/volunteers.
  15. Inappropriate Relationships with Children

    1. An adult in a position of trust must not enter into a sexual or inappropriate relationship with a child in their care. ALL TRUST personnel should:
      • Clearly understand the need to maintain appropriate boundaries in their dealings with children and young people.
      • Ensure that their relationships with children are appropriate to the age and gender of the children and take care that their language or conduct does not give rise to comment or speculation. Attitudes, demeanour and language all require care and thought, particularly when adults are dealing with adolescent boys and girls
    2. From time-to-time Trust staff may encounter young people who display attention-seeking behaviour, or profess to be attracted to them. All adults should aim to deal with those situations sensitively and appropriately but ensure that their behaviour cannot be misinterpreted. In these circumstances, the adult should also ensure that The Trust Designated Safeguarding Person is aware of the situation.
  16. Photographic Images

    1. As a normal part of The Trust activities to promote our community work, we welcome suitable photographs of any person enjoying our facility.
    2. The Trust will check the organisation’s policy on taking and using photographs with the group leader, but The Trust will rely on the group leader to take and provide photos to us, as appropriate and in line with the user organisation’s policy.
    3. The Trust is responsible for our website content and The Trust will not include any image which could harm any person, directly or indirectly.
  17. Trip Sheet

    1. Trust staff will keep an attendance register (Trip Sheet) for all organised sessions so we have evidence on who was on the boat in case of potential future allegations.
  18. Procedures

    1. Safeguarding children is everyone’s responsibility. Every THE TRUST staff member and person using our facility has a responsibility to respond to any concerns that they or others may have about harm to a child or the behaviour of an adult. This relates to concerns which arise both within and outside the the Trust environment.
    2. The Trust will deal with poor practice and any suspicion of harm, whether physical, sexual, emotional, bullying or neglect. THE TRUST staff must always report any suspicion of harm as a priority. Where an allegation is made about a Trust staff member, The Trust will deal with this quickly and in the same way. The detail procedures for dealing with situations are:
      • A child or other person has disclosed information or reported to an a Trust staff member an incident or complaint involving the behaviour of an adult in relation to a child that may be considered to be abuse or poor practice; or
      • An Trust staff member has witnessed an incident involving the behaviour of an adult in relation to a child that may be considered to be abuse or poor practice.
  19. Disclosure of a Complaint

    1. Suspicions of potential abuse or neglect or actual complaints may arise in a number of ways:
      • The child raising issues of concern about him/herself or another child;
      • A complaint or allegation of abuse or neglect is made to an THE TRUST employee or volunteer; or
      • A Trust employee or volunteer witnesses an incident or behaviours that causes concern.
    2. If a child discloses information to a member of THE TRUST staff which gives concern, he/sheshould not:
      • Try to stop the child from recalling events
      • Take a decision as to whether or not abuse has taken place
      • Ask leading questions, i.e. questions which suggest its own answer
      • Interrogate the child; it is not their responsibility to investigate
      • Ask the child to repeat the information for another member of staff
      • Promise confidentiality or make other promises they cannot keep as there may be a duty to share this information and refer it to Children’s Social Care Services
      • Aproach or contact the alleged abuser[s]
    3. The Trust staff member should:
      • Stay calm – ensure the child is safe and feels safe
      • Be aware of his/her own reactions – showing shock or disapproval may stop the child from continuing with their disclosure
      • Listen to what the child is saying, without giving an indication of believing or disbelieving him/her
      • Ask open questions (without interrogating) such as ‘Anything else to tell me?’
      • Do reassure and alleviate guilt if the child refers to it. For example, by saying: ‘You’re not to blame’
      • Reassure the child, but only as far as is honest and avoid promises that it may not be possible to keep, e.g., ‘Everything will be alright now’, ‘You’ll never have to see that person again’, ‘I’ll keep it confidential’
      • Reassure the child that he/she is right to have spoken about the issue
      • Tell the child that you will offer support
      • Explain what he/she has to do next, e.g., pass on the information in accordance with this policy so that the correct action can be taken
      • Write up the notes of the conversation as soon as possible. See x. Recording the Concern for details
      • Monitor the child/children concerned; encourage them to continue to take part in The Trust activities
    4. Any complaint made to an THE TRUST Trustee, employee or volunteer must be reported immediately to the Designated Safeguarding Person (DSP). See 7.2. Reporting a Concern or Complaint.
    5. Where an THE TRUST staff member has suspicions or concerns about the safety or welfare of a child, or witnesses an incident, he/she must report this to the Designated Safeguarding Person (DSP) as soon as possible. If he/she feels the child is at immediate risk of abuse then a statutory agency (local children’s services or the police) should be contacted immediately as well as the Chair of THE TRUST. If the matter concerns the Designated Safeguarding Person, the issue must be raised immediately with the Chair of the THE TRUST.
  20. Reporting a Concern or Complaint

    1. If any person has a concern about a child or young person whilst using our facility, they should report it immediately to the Designated Safeguarding Person. The DSP will take the necessary action in accordance with this policy, including contacting the appropriate authorities where appropriate.
    2. However, depending on the seriousness of any issue, and whether it concerns an issue on our facility or in the child’s environment, this may be reported to children’s services or the police.
    3. The issue should also be reported to the Chair of the Trust. If the matter is urgent and none of the above can be contacted, then contact Social Services or the police. Concerns would normally be shared with parents/carers by the Designated Person as soon as possible. However, there could be circumstances when this could put the child at greater risk or there may be concerns that parents/carers will not respond appropriately.
    4. Every effort will be made by Social Services to respect the anonymity, if requested, of the person reporting the abuse, however, if allegations result in Court proceedings this may not be possible. If an allegation of abuse is made against a member of staff or volunteer, Social Services will follow the same procedure as they do to investigate allegations of abuse for a family.
  21. Dealing with Potential Cases

    1. The Trust will respond to potential cases of abuse or neglect quickly. It is not the responsibility of employees/volunteers to deal with suspected abuse. Instead, they must report concerns immediately to the Designated Safeguarding Person (DSP).
    2. If employees/volunteers notice any social changes in the behaviour of a child, worrying marks or bruises or hear a child/children talking about things which give cause for concern, their first responsibility is to the child. It is not safe to assume that someone else will take action, so it is critical to raise any concerns quickly with the DSP.
    3. If an allegation is made directly a staff member or volunteer, he/she should advise the DSP as soon as possible, even if the allegation appears to be trivial.
    4. If an allegation of abuse is made against a member of THE TRUST staff, the DSP will:
      • Advise the person concerned that this is the case
      • Carry out a thorough investigation, with due regard for confidentiality. An investigation should not be interpreted as indicating culpability, rather that we have a duty of care to protect people both using our services and those working with us from any unfounded allegation.
      • Provide moral and practical support if an unwarranted allegation of misconduct is made against an THE TRUST staff member.
    5. Where a member of the Trust staff’s behaviour contravenes this policy and guidelines, it will be treated as gross misconduct. Where the employee has concerns about how an allegation against them f or anyone else is being dealt with, he/she should inform the Chair of the Trust
  22. Recording an Incident or Concern

    1. Any concern or incident concerning a child should be recorded in writing at the time. When convenient (for example on return to Angel II’s permanent mooring) this should be entered in the Child Protection register which is kept in the locked filing cabinet in the Trust office.
    2. The record should be factual and signed and dated, with the name of the signatory clearly printed in writing. This record may be used as evidence where a complaint or allegation is made. It should include:
      • The child’s details: name, date of birth, address and family details
      • This record should include:
        1. the date and time of the conversation.
        2. the place of the conversation; and
        3. the essence of what was said and done by whom and in whose presence.
      • Date and time of the alleged event / concern
      • The words used by the child (do not paraphrase) and record any non- verbal behaviours. Record what the child actually says rather than any interpretation or assumptions
      • The action taken and by whom
      • The name and position of the person making the record
    3. This should be signed by the person making it, using names and not initials.
    4. If there is evidence, for example, scribbled notes, mobile phones containing text messages, clothing, computers, these should be kept securely with the written record and passed on when reporting the matter in accordance with this policy.
  23. The Trust Staff Responsibilities

    1. The DSP Responsibilities include:
      • Ensuring all Trust personnel members are aware of their safeguarding responsibilities
      • Identifying any signs of harm or concerns and reports them to the appropriate authority and Chair of the Trust
      • Ensuring that Trust staff have up-to-date DBS checks in accordance before working with children
    2. The Trust personnel and volunteers must:
      • Understand, comply with and follow all guidance in this policy and so create and maintain an environment that creates a safe, friendly and welcoming environment and treats children with respect
      • Adhere to thew NSPCC Code of Conduct
      • Take care to avoid showing any favouritism
      • Take steps to prevent the abuse of younger or weaker children by older or stronger children through bullying, cruelty or any other forms of humiliation
      • Work to prevent safeguarding violations and promotes the implementation of the Safeguarding Policy
      • Completes any safeguarding training considered appropriate for their role
      • Report any concerns or suspicions regarding safeguarding violations by any THE TRUST personnel staff member or associated personnel to the Designated Safeguarding Person
    3. The Trust personnel must not:
      • Make racist, sexist or any other remarks which may upset or humiliate
      • Subject a child to physical, emotional or psychological abuse, or neglect
      • Sexually abuse or exploit children or young people
      • Engage in any commercially exploitative activities with children, including child labour or trafficking
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