What should a safeguarding policy contain? The complete model for a club or a federation

By Géraldine Heinen28 August 202618 min read

A safeguarding policy is the document that formalises a club's or a federation's commitment to protecting minors and adults at risk, and that organises prevention and response in practical terms. This article sets out, chapter by chapter, what a complete policy should contain, with the reference definitions and the appendices that make it operational. It draws on the expertise of Actitude 360, built through training and international and national references, including the FIFA Guardians programme, UEFA's child safeguarding toolkit and the ADEPS recommendations on ethics in sport, and on the experience of writing and rolling out safeguarding policies in a federation. The model presented applies to any sports organisation, club or federation (Word template to download). The legal references are those of Belgium; if you are based elsewhere, replace them with the equivalent provisions of your own country.

1. Why a written policy

Safeguarding minors and adults at risk must be an absolute priority for anyone working with these groups. A written policy gives the organisation an official means of assuming this duty: it makes commitments visible, it sets the procedures and it allows everyone, adult or child, to know what they have to do. It builds on the existing regulations and legislation on sport in Belgium and puts the emphasis on two complementary movements: preventing and responding.

A good policy opens with a foreword signed by the leadership. This message affirms zero tolerance of all forms of violence or harassment, whether they occur during sports practice, outside it or online, regardless of hierarchical level. It reminds everyone that each individual deserves a safe and respectful environment in which to flourish and express their talent without fear or intimidation.

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2. The fundamental principles

The fundamental principles guide all the organisation's actions. A complete model retains seven:

• No type of violence or harassment has any place in sport.
• The well-being of every person, in particular minors and adults at risk, must always come first.
• Every person, whatever their age, sex, disability, culture, language, origins, religious beliefs or sexual orientation, has the right to be protected from violence and discrimination.
• All suspicions and allegations of violence or harassment are taken seriously and dealt with appropriately.
• Every adult involved in sport, closely or from a distance, has a role to play in protecting vulnerable groups.
• Collaboration with other organisations, with minors and their parents (or guardians), and with adults at risk, is essential to prevent and respond effectively.
• It is essential that everyone knows how to report a concern.

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3. The two pillars: prevention and response

Prevention covers any act or statement that may harm children and adults at risk. It relies in particular on the appointment of a safeguarding lead, safer recruitment procedures, background checks on candidates and the training of employees, volunteers and athletes.

Response provides clear procedures in the event of an incident or concern affecting the interests of a child or an adult at risk. Compliance with the code of ethics and the codes of conduct (Word template to download) is mandatory for all coaches, staff and athletes in the organisation's care. In handling incidents, the designated services are the ones empowered to take decisions internally.

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4. Definitions and key terms

A policy can only be applied if everyone speaks the same language. The definitions below are the reference definitions in sport; they distinguish two broad categories of abuse, violence and harassment, and clarify essential notions such as grooming, consent and discrimination.

Violence

Interpersonal violence in sport can take different forms. Four main types are distinguished.

Harassment

Key terms

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5. Scope and target group

The policy specifies which teams, events and activities it applies to. Everyone in sport is entitled to protection from harassment and violence: when a member of the sporting community, whether athletes, coaches, officials, volunteers or staff members, is a victim or a perpetrator of abusive behaviour, it is the very mission of the organisation, founded on respect, safety and integrity, that is compromised.

Particular attention is paid to two vulnerable groups, which form the target group of the policy:

• Minors (under 18) have specific rights to protection, under the United Nations Convention on the Rights of the Child (1989), because of their vulnerability, their dependence and their need for special care.
• Adults at risk include in particular young adults, young people in transition to professional sport, women, minorities and people with disabilities. These groups are particularly exposed to certain risks and require increased vigilance and appropriate measures. The desire to reach professional sport, among many young people and their parents, can be exploited by people with malicious intentions: the pressure to get there makes these young people more vulnerable to all forms of abuse.

Around this target group revolve the stakeholders: athletes, coaches, officials, volunteers, staff, parents, spectators. They are the ones the policy must inform and train.

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6. Legal framework and responsibilities

The policy rests on a legal framework at three levels. The examples below are those of Belgium; the structure (international, national, regional) is the same in most countries.

• International: the International Convention on the Rights of the Child (CRC), adopted by the UN on 20 November 1989 and ratified by Belgium, recognises a set of fundamental rights for children in 54 articles, around four guiding principles: non-discrimination (art. 2), the best interests of the child (art. 3), the right to life and development (art. 6) and respect for the views of the child (art. 12).
• Belgian federal level: the Criminal Code defines and severely punishes sexual violence, sexual harassment and violence, with heavier penalties when the victims are minors or in a situation of vulnerability, or when the perpetrator is in a position of authority. Rape is punishable by 10 to 15 years' imprisonment, up to 20 to 30 years in aggravating circumstances; violation of sexual integrity by 6 months to 5 years, aggravated if the victim is a minor or vulnerable; non-consensual acts of a sexual nature committed against a minor by 20 to 30 years.
• Belgian regional level: in the Wallonia-Brussels Federation, the Code on prevention, youth assistance and youth protection provides for the intervention of the Youth Assistance Service (SAJ) for minors whose health, safety or morality is threatened, and the decree on assistance to child victims of abuse requires any professional to provide help and protection to a child who is, or is suspected of being, a victim.

The policy then allocates responsibilities: each organisation (federation, regional league, club) protects the groups in its care, guarantees them access to resources and ensures adequate training for all the staff involved. A table allocating target groups by organisation avoids grey areas. The services to clubs (training, lists of specialised bodies, awareness material, support for designated persons) are described in this chapter. In the Wallonia-Brussels Federation, this role is generally carried by the club's ethics officer, trained for the purpose.

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7. Prevention actions

The safeguarding lead

A person is appointed to coordinate and guarantee the implementation of the policy. They ensure risk prevention, the handling of reports, the training of stakeholders and the development of suitable tools and procedures, in close collaboration with regional designated persons and the other departments concerned.

The listening desk and trusted persons

The listening desk is a network of identified trusted persons, from different departments or groups, trained to receive a report safely and appropriately. It is known to all the organisation's audiences. A single person is enough to receive a report and start the process. The members of the listening desk do not take the decisions; their role is to receive reports with attention and care, to carry out the first analysis according to the established protocols, to pass on the necessary information to the competent person or body and to accompany the steps of the process. In a federation, it typically brings together representatives of human resources, the legal department, the sports and social department, the trusted persons and other specifically trained staff.

A safer recruitment process

Anyone can behave inappropriately towards minors or adults at risk. A safer recruitment process (Word template to download) reduces the risks and rules out people who are not suited to working with these groups.

Before hiring: mention the values of the policy in job advertisements and descriptions for any role involving contact with the target group; check at least one professional reference, ideally related to positions involving work with minors; ask the candidate to explain any period without employment, to better understand their background; request a criminal record extract (in Belgium, model 2, known as 596-2) and, for candidates from a country without an equivalent system, have them complete a self-declaration form for criminal history.

After hiring: become familiar with the programme and complete the mandatory training within the year following the start of the role; read and sign the code of conduct (Word template to download) for working with children and adults at risk.

The code of conduct

Codes of conduct are one of the basic elements of the programme. They set out the organisation's expectations regarding the behaviour of its staff, its volunteers and the other people it involves. They help everyone recognise acceptable and unacceptable behaviour, as well as the consequences of non-compliance. Everyone signs to confirm that they have read, understood and will comply with the code. The minimum standards of behaviour apply to all members, whatever their seniority, rank or reputation. A complete policy provides a code for coaches and staff (respect, ethics and exemplary behaviour; well-being and development of athletes; protection, safety and safeguarding; communication and social media; personal responsibilities; sanctions) and a code for athletes (respect and fair play; safety, health and well-being; group life; communication and social media; personal commitment).

The annual self-evaluation

Every year, the organisation measures the implementation of its policy using a structured tool that covers the main areas: safeguarding policy, designated person, recruitment and training, engagement of target groups, parents and partners, safety in practice, response to concerns and monitoring of progress. Each area is assessed on three levels, with comments and an action plan (Word grid to download). The self-evaluation includes a risk matrix based on the FIFA model and a checklist for verifying reporting processes. It makes it possible to track progress, identify priorities and ensure continuous improvement.

The needs analysis and the training plan

Every year, the safeguarding lead carries out a training needs analysis in three stages: identifying the skills staff need to assume their responsibilities, role by role; comparing each person's current level with these skills; identifying the gap and proposing training or other learning opportunities.

At the start of each season, this analysis feeds a training plan that specifies when, which training and how it will be delivered to each group. Three levels are distinguished: essential training (basic introduction to safeguarding), intermediate training (which explores safeguarding in more depth) and role- or context-specific training (tailored for specialised roles, for example members of the listening desk or safeguarding leads). The people with the most contact with children and vulnerable adults come first. The target groups themselves and all supervising adults (coaches, officials, volunteers, contractors) are concerned.

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8. Response actions

The reporting form

A form, available online, makes it possible to report any worrying situation concerning a child or an adult at risk. It is not the responsibility of those reporting to decide whether violence is taking place, but it is everyone's responsibility to report any concern. Information is only shared on a "need to know" basis, in accordance with data protection legislation, and confidentiality is maintained when an allegation is under investigation.

The process for responding to concerns

The approach is victim-centred: the interests of those who have suffered violence are placed at the centre of the process. Reporting is an obligation for all members, without it being necessary to be certain that harm has occurred. The process is reviewed every three years or after any significant case. It unfolds in four steps.

1. Receipt: any concern, whatever the place or the connection with the sports activity, is passed on to the listening desk and then to the safeguarding lead.
2. Initial orientation: the lead analyses the nature of the report. With no clear connection to the organisation but with a criminal risk, they consult the legal department and, depending on whether the victim is a minor or an adult, contact the competent services or encourage the filing of a complaint. With a connection to the sports activity (victim, alleged perpetrator or witness who is a staff member, athlete, parent, spectator), they assess the need to contact external authorities and identify the internal procedures to activate (safeguarding, ethics, disciplinary).
3. Assessment of the level of seriousness: low (limited internal investigation and immediate appropriate response), medium (referral to the competent department, with the possibility of contacting external authorities), high (immediate transmission, after legal consultation, to the competent authorities and the internal bodies concerned). The level can change if new information emerges.
4. Investigation, decision and appeal: the investigation begins on receipt and is conducted impartially. Evidence includes testimonies, documentary elements (recordings, photos, messages) and expert opinion. Interviews begin with the person who made the report, continue with the victim, then the witnesses, and finally the person implicated. Five principles guide the investigation: honesty, fairness and impartiality, confidentiality, efficiency and adaptability, timeliness. Even when an external investigation is conducted by the police or the courts, the organisation initiates and completes its own internal processes, with sound and defensible decisions.

In the event of an allegation of serious violence or a criminal offence, the organisation assesses whether continuing the internal investigation risks prejudicing the judicial procedure; if so, it is suspended until the official investigations are concluded. A temporary suspension of the person concerned can be applied without delay, depending on the seriousness of the facts and the risks identified.

Centralising reports

All reports are centralised via a secure system that guarantees an overview, follow-up and coordinated action, and makes it possible to spot any repeated behaviour in order to prevent revictimisation. The listening desk records each report in a confidential register, which contains no detailed medical or sensitive information. Individual files (reporting form (Word template to download), chronological summary, evidence documents, decisions taken, any referrals) are stored in a protected space, with access strictly limited to the people concerned. Each file carries a status ("in progress", "urgent", "awaiting information", "closed") and a summary note keeps track of the actions taken and the lessons learned. Retention periods are defined: at least ten years for serious cases involving minors, five years for cases without prosecution.

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9. The visibility of the programme

A policy only has an effect if it is known. The organisation's website centralises the presentation of the programme, its objectives, its actions and the available resources, with a section dedicated to reporting. Beyond online material, awareness campaigns are regularly run to promote a culture of protection, encourage responsible behaviour and strengthen knowledge of prevention and reporting tools.

The policy ends with a clause recalling that it is dynamic, regularly reviewed in line with the legislation in force and the evolution of society, and that it replaces neither the law nor the applicable regulations.

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10. The appendices that make the policy operational

The body of the policy fits in about twenty pages. It is its appendices that make it usable on a daily basis. A complete policy has twelve. For those that lend themselves to a template, we provide a free standardised Word version, to adapt to your organisation: click on "Download the Word template" in the cards concerned.

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11. What next?

Writing the policy is the second step of a five-step journey: taking stock of what exists, establishing the policy, developing procedures and guidelines, communicating and training, then monitoring and evaluating. This journey, with its own tools (action plan, reporting form, recruitment procedure, risk assessment guide, supervision and changing room rules, all downloadable in Word format), is the subject of our article Implementing a safeguarding policy in your club: the 5-step toolkit.

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