Relevant Legislative Background
Fostering Services (England) Regulations 2011: Reg: 11; 12; 13
The Children Act 1989 Guidance and Regulations Volume 4
The Children and Young Persons Act 2008
National Minimum Standards: Standards: 4; 5
Sexual Offences Act 2003
Modern Slavery Act 2015
Crime and Policing Bill 2025
The Agency believes that the safety, wellbeing and best interests of every child or young person must be safeguarded and promoted at all times. Every staff member and every foster carer shares responsibility for promptly reporting any incident or suspicion of abuse involving a child or young person placed with the Agency.
In accordance with the Children Act 1989 & 2004, when a child is experiencing, or is likely to experience, significant harm, immediate action must be taken to help protect that child. Action should also be taken to promote the wellbeing of a child who needs additional support, even if they are not currently harmed or at immediate risk. Agency staff and carers are particularly important because they can notice concerns early and offer help to children and young people, preventing issues from escalating. As part of the wider safeguarding system for children outlined in Working Together to Safeguard Children 2023, the Agency’s staff and carers collaborate with social care, the police, health services and other professionals to promote children’s welfare and protect them from harm.
Safeguarding children and young people is a central element of the Agency’s responsibility toward those placed with its foster carers. All children and young people have an unequivocal right to safety and protection from abuse, exploitation and harm, and will receive a sensitive, compassionate and timely response tailored to their individual circumstances if they disclose or allege any form of mistreatment.
Awareness of safeguarding roles and responsibilities—preventing and protecting children and young people from abuse and neglect—is essential for everyone connected to the Agency, including volunteers and self-employed independent staff. We aim to uphold the highest standards of care and protection when working with children and young people.
General Background
Child trafficking is a form of child abuse. It is defined as recruiting, moving, receiving or harbouring children for the purpose of exploitation (HM Department for Education (DfE) and Home Office, 2011). As a crime, child trafficking violates human rights, and the key pieces of legislation used to protect victims are:
• Sexual Offences Act 2003
• Modern Slavery Act 2015
• Crime and Policing Bill 2025
Crime and Policing Bill
This bill introduces a standalone offence of Child Criminal Exploitation (CCE) targeting adults who coerce or exploit children into criminal activity. It recognises that children cannot legally consent to such exploitation, aiming to close a gap in the law.
Mandatory reporting duties: Certain professionals working with children (e.g., teachers, health workers) would be legally required to report suspected child sexual abuse, with penalties for refusal. These measures, while primarily focused on abuse, feed into broader frameworks around exploitation and trafficking.
Amended safeguarding measures: The Bill includes provisions that reinforce checks on those working with children and civil preventive orders to disrupt exploitation before it occurs.
Procedures to be followed where there are concerns for a Child:
While all children in care may face vulnerabilities, those who have experienced trafficking need Supervising Social Workers and foster carers to remain especially vigilant. Risk assessments must be thorough and regularly reviewed, as must the foster family’s Safer Caring Policy* see below. Everyone who has contact with these children must stay alert to the risk of abduction or ongoing grooming strategies.
A child who has survived trafficking may not feel able to share their worries, but any changes in behaviour, mood or presentation should be noticed, and foster carers must report these changes to their supervising social worker and the child’s social worker. The supervising social worker must discuss any behavioural changes with their Team Manager.
If a child discloses that they have been trafficked or held against their will at any time, the foster carer must share this information with the supervising social worker the young person’s social worker and follow safeguarding/child protection processes. This will include informing the Registered Manager and, in their absence, a Senior Manager, who will refer the matter to the LADO where the foster carer resides. If the child is believed to be at immediate risk, the concern must be reported to the police and to the child’s social worker or the Emergency Duty Team (EDT) if out of hours.
If a foster carer believes a child or young person is in immediate danger, they must contact the police.
*When a child or young person is known, or suspected, to be at risk, the Supervising Social Worker will ensure the child or young person’s Safer Caring Policy reflects the identified concerns and associated risks. This will be further informed by the completion of a Child trafficking Risk Matrix.
During risk assessment, the Child trafficking Risk Matrix must be used to determine the level of risk by weighing likelihood against potential severity. This straightforward tool helps Supervising Social Workers to highlight risks and to guide and support foster carers in managing them while caring for children and young people.
Alongside mandatory safeguarding training, foster carers looking after children who are known, or potentially, at risk must complete training on recognising signs of Child trafficking.
Foster carers must also keep detailed records in line with statutory requirements. In addition, monthly service meetings review children and young people known to be at risk and update their RAG rating.
Indicators of Child Trafficking
Experiencing trafficking is, in itself, a form of abuse. Trafficked children may also experience other forms of abuse and neglect that affect their physical health, mental health, and social and emotional development. These include:
• Sexual abuse and exploitation
• Physical abuse
• Emotional abuse
• Neglect
Impacts of child trafficking and exploitation include:
• Poor health and illness that may go untreated.
• Limited or no access to education.
• Physical and mental exhaustion.
Children and young people may also experience emotional challenges, such as missing family, friends, communities and cultures. This can lead to:
• Feeling isolated and lonely.
• Disturbed sleep patterns.
• Depression and/or anxiety.
• Headaches
• Panic attacks.
• Eating difficulties
• Self-harm and suicidal thoughts.
• Drug and alcohol use as a means of coping.
• Post-traumatic stress disorder (PTSD)
Our Ethos & Principle of Practice
This policy is informed by relevant legislation, statutory guidance and good practice guidance. To fulfil our commitment to safeguard and promote the welfare of children and young people, we will take all necessary steps to ensure that our policies, procedures and processes reflect the essential safeguards identified in Working Together to Safeguard Children 2023, National Minimum Standards: Standards 4; 5, the Sexual Offences Act 2003 and the Modern Slavery Act 2015, and we will therefore adhere to the following principles:
• A clear commitment by senior management and managers, with transparent lines of accountability, to safeguarding and promoting children’s welfare through both the commissioning and the provision of services.
• A culture of listening to and engaging in dialogue with children and young people—seeking their views in ways appropriate to their age and understanding, and taking account of those views both in individual decisions and in the development and improvement of service delivery.
• All children and young people, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all forms of harm and abuse.
• Children and young people feel respected and their self-esteem is nurtured.
• When following procedures and processes, positive outcomes for children and young people are always the priority. Every child and young person will have an individual Safer Caring Policy and risk assessment that reflects their unique needs and circumstances.
• Recruitment procedures for staff and foster carers recognise the need to safeguard and promote the welfare of children and young people.
• Staff and foster carers receive training in all aspects of safeguarding children and young people, remain alert to their vulnerabilities and risks of harm, and are confident about how to implement safeguarding procedures.
• Arrangements ensure that all staff and carers engage in ongoing relevant training to equip them to carry out their responsibilities effectively and keep up to date with best practice.
• Procedures comply with National Minimum Standards and Regulation 11 and 12—arrangements for the protection of children and young people on a daily basis—and align with local authority and locally agreed inter-agency procedures.
• Arrangements are in place for effective information-sharing and inter-agency collaboration to safeguard children and young people and promote their welfare.
• Complaints procedures are clear, effective and user-friendly, and are readily accessible to children and young people, including those with disabilities and those for whom English is not their preferred language. Procedures address informal as well as formal complaints. Children and young people can genuinely raise concerns and suggest changes and improvements, which are taken seriously.
To achieve the objectives above and to achieve a safe ethos, we will:
• Ensure that the safety of children and young people is paramount.
• Listen to children and young people, consider what they tell us, and advocate on their behalf.
• Take every reasonable step to protect children and young people from harm.
• Regularly assess and review any risks that arise.
• Take all suspicions and allegations of abuse seriously and respond promptly and appropriately.
• Ensure that all Agency staff and carers are recruited and assessed in full in accordance with.
• Be clear about everyone’s roles and responsibilities.
• Ensure staff and foster carers recognise the importance of understanding children’s wishes and feelings and know how each child communicates, whether verbally or non-verbally.
• Ensure bullying is effectively countered.
• Maintain rigorous recruitment and selection procedures that set a high threshold of entry to deter abusers.
• Provide effective supervision and support to both permanent and temporary staff and foster carers.
• Maintain clear procedures for referring safeguarding concerns about a child to the relevant local authority.
• Ensure contractor staff are effectively checked and supervised when on site and/or in contact with children and young people.
• Ensure clear procedures and support systems are in place for dealing with concerns raised by staff and carers about other staff and carers.
• Maintain a code of conduct that reminds staff of their duty to the Agency and their professional obligation to raise legitimate concerns about the conduct of colleagues or managers. Procedures must guarantee that these concerns can be raised without jeopardising the whistle-blower’s position or prospects.
• Promote respect for diversity and sensitivity to race, culture, religion, gender, sexuality and disability.
• Ensure staff and carers remain alert to risks outside the home posed by individuals who may exploit the additional vulnerability of children living away from home.
Please refer to the following policy and procedure documents:
Missing from Care
Child Sexual Exploitation
Child Criminal Exploitation
Female Genital Mutilation
Social Media
Recording
Supervision of carers
Complaint Procedures
Whistleblowing
Radicalisation & Extremism
The time and uncertainty involved in clarifying the full situation can be extremely stressful for carers and their families. The Agency will make sure carers receive as much information as circumstances allow about any allegations made against them. Carers will have access to independent support and will be encouraged to share their perspective, to learn, and to move forward once situations are resolved.
If an investigation concludes that a carer has abused, or failed to adequately protect, a child placed with them, the local authority where the carers live, the placing authority (if different), and the Agency’s Foster Panel will be informed with a view to withdrawing approval and de-registering the foster carers. This may lead to a referral being made to the appropriate authority.
Where appropriate, the Agency will work in partnership with the relevant authorities to refer de-registered carers, in line with the Safeguarding Vulnerable Groups Act 2006, to protect other children and young people from any possible recurrence. Any carer who wishes to challenge the Fostering Panel’s decision in these or any other circumstances is entitled to appeal under the Agency’s policy as described in the Complaints Procedure and the Fostering Panel Procedure and has the right to appeal through the Independent Review Mechanism.
Roles and Responsibilities
It is not the role of anyone working for the Agency to determine whether a child is being or has been abused. However, safeguarding is everybody’s responsibility, so we must act on any concerns to protect children and enable the appropriate agencies to make enquiries and take any necessary action.
The following procedures and guidance assist Agency staff when dealing with safeguarding concerns. They are divided into the following sections:
The process to follow if staff have any safeguarding concerns about a child
Advice to foster carers and staff members on what to do when a child makes a disclosure
The process to follow when an allegation has been made against a member of staff
Designated Persons
While everyone shares responsibility for safeguarding within the Agency, the designated safeguarding leads are the Registered Manager and the Responsible Individual. They will:
• Ensure all staff remain fully aware of the Agency’s safeguarding procedures.
• Support Team Managers with safeguarding and ensure supervising social workers and all other staff have access to the Local Safeguarding Procedures for every authority the Agency works with.
• Liaise with the Local Safeguarding Children Board (LSCB) to ensure compliance.
• Resolve any inter-agency issues and ensure effective collaboration with other agencies.
• Provide strategic leadership in the development of safeguarding procedures.
