Comic Relief Inc. is a non-profit organization committed to creating a just world free from poverty by harnessing the power of entertainment to promote positive change. Our primary initiative is Red Nose Day whose goal is to end child poverty. As a major foundation supporting grantee partners in the United States and around the world, our funds impact millions of children each year.
With our focus on helping ensure that low-income children are safe, healthy, educated and empowered, Comic Relief US recognizes that we must do all in our power to ensure the dignity and wellbeing of each child and adult with whom we interact. This policy provides the guidelines and principles for our organization to ensure that we hold ourselves, our partners, and our grantees to the highest standards in protecting children, young people and adults in vulnerable circumstances and others with whom we come into contact.
1.1 Safeguarding Principles
Comic Relief’s Safeguarding Policy is undergirded by the following principles:
- Everyone has the right to live in a safe and inclusive environment, free from all forms of abuse, violence, neglect, and exploitation
- Everyone has the right to safety and to be treated with dignity and respect, irrespective of their race, gender, ethnic or social origin, place of birth, language, religious or other beliefs, disability, sexual orientation or other status.
- Vulnerability to abuse may vary depending on the intersection of populations (i.e. refugees, trafficked youth, street-connected youth), and identities (i.e. gender, race, ethnicity, nationality, sexual orientation, age, disability). Organizations need to take steps to assess and address the different levels of risk within their programs.
- All individuals and organizations have a responsibility to foster a caring and protective environment for the people they impact and always act in the best interest of the person.
Child: In line with the UN Convention of the Child, a child is anyone under the age of 18 regardless of the legal age of majority in the country.
Young People: Comic Relief US defines ‘young people’ as aged 18-25 years, reflecting the period of transition from the dependence of childhood to adulthood’s independence.
Adults in vulnerable circumstances: Any person aged 18 or over, who may be at increased risk of abuse or less able to protect themselves from harm due to their age, disability, special educational needs, illness, isolation, socio-economic factors and/or environmental living conditions.
Abuse: Abuse can take many forms and definitions will vary between contexts. The definitions provided in this policy are not exhaustive but serve as a guide for Comic Relief US Personnel:
- Physical: Physical contact that results in discomfort, pain or injury
- Sexual harm: Coercion or force to take part in sexual acts of any kind
- Emotional/Psychological harm: Action or inaction that causes mental distress
- Exploitation: Misuse of power over another person for financial, social, sexual or other benefit
- Bullying & Harassment: Unwanted behavior which causes intimidates or humiliates others
- Sexual Harassment: unwanted verbal, non-verbal or physical conduct of a sexual nature
2. Roles & Responsibilities
2.1 Applicable Persons and Entities
This Policy applies to:
- Officers, Directors, employees, interns, and independent contractors of Comic Relief US;
- Volunteers of Comic Relief US
All those covered by the Policy commit to respecting, promoting, upholding and protecting, at all times, the rights of the child as set out in United States law and in the UN Convention on the Rights of the Child as well as all applicable United States laws for vulnerable adults. We will treat any breach of this policy very seriously. For those who work for us, failure to follow this policy could lead to disciplinary action, which may ultimately result in dismissal. For those who work with us, we reserve the right to immediately terminate your contract and, for Directors, to commence a procedure for your removal.
In addition, the safeguards set out in this policy must be followed by individuals and organization who interact with children or adults in vulnerable circumstances as part of their engagement with Comic Relief. This includes:
- Visitors to grantees and/or to any Comic Relief US event or site visit
- Vendors or corporate partners who have a reasonable likelihood of interacting with children or adults in vulnerable circumstances
For these individuals or entities, failure to follow this policy could possibly result in the severing of any agreements and/or business relationships.
Grantees are made aware of the Comic Relief’s Safeguarding Policy but are expected to have their own safeguarding and protection procedures in place that reflect their unique organization and operating context. Comic Relief US assesses and monitors the safeguarding policies and practice of grantees and any failure to meet agreed standards could result in the severing of the funder/grantee relationship, including the relinquishing of unspent funds on an existing grant.
2.2 Safeguarding Officers
Safeguarding is everyone’s responsibility but Comic Relief US have designated Safeguarding Officers who are responsible for:
- Coordinating the implementation of the Safeguarding Policy and ensuring all staff and volunteers are aware of their safeguarding responsibilities
- Providing advice and support on implementation of safeguarding measures and ensuring regular training is provided to the team
- Acting as the first point of contact for safeguarding concerns and ensuring these are discussed, recorded and dealt with appropriately.
- Ensuring Comic Relief’s Safeguarding Policy is reviewed and updated on an annual basis.
To ensure the Safeguarding Officers are accessible, Comic Relief US have designated staff in each of the key areas of operation:
Safeguarding Officer: Lisa Clark (VP, Human Resources/People)
Safeguarding Officer: Ayo Roach (VP, Grants)
Safeguarding Officer: Ridwan Adhami (Creative Director)
2.3 Senior Leadership
The Senior Leadership team and Board play an important role in ensuring that safeguarding is prioritised across the organization and that staff are adhering to the measures set out in this policy. They are responsible for:
- Championing the importance of safeguarding and acting as a role model
- Attending safeguarding training and ensuring their teams attend training and are aware of their responsibilities
- Ensuring an appropriate response to safeguarding concerns through escalation and oversight from the CEO and Board whenever cases are reported (See section 4)
3. Code of Conduct
Comic Relief’s code of conduct helps to ensure a safe environment for everyone connected with our work and aims to protect the children and communities we engage with. These standards reflect United States Federal, State, Local, and Tribal laws but must be applied at all times irrespective of location.
- Treat everyone with dignity and respect and do not engage in any form of harassment, intimidation, victimization, abuse or exploitation.
- Do not discriminate, directly or indirectly, against any person on the basis of race, ethnicity, sexual orientation, gender identity or expression, nationality, ethnic or social origin, religion, culture, language, age, disability, or any other status.
- Behave in a manner that upholds the values of Comic Relief US and avoid any conduct which could damage the reputation of the Fund.
- Report any concerns about the safety of any individual connected with our work immediately.
Interactions with Children and adults in vulnerable circumstances
- Always treat children and adults in vulnerable circumstances with respect regardless of their gender, ethnic or social origin, language, religious or other beliefs, disability, sexual orientation or other status.
- Use appropriate language and behavior, and avoid any language or behavior which could be deemed harassing, abusive, sexually provocative, or demeaning.
- Sexual activity with children is prohibited, including paying for sexual services, i.e. exchange of money, employment, goods, or services. This applies regardless of the age of consent and mistaken belief regarding the age of a child is not a defense.
- Never engage in sexual activity with adults in vulnerable circumstances who may be participating in Comic Relief US funded programs as the inherent power imbalance is open to exploitation and abuse. This includes the exchange of money, offers of employment, goods or services for sex.
- Never use children for domestic or other labor when it is inappropriate for the child’s age or developmental capacity, in breach of local law, interferes with the time available for education and recreational activities, or places them at significant risk of injury, exploitation, or abuse.
- Never use of adults in vulnerable circumstance for free labor, indentured servitude, or otherwise underpay for work in an exploitative manner.
- Use of any device to access, view, create, download or distribute sexual images of children is prohibited.
- Physical punishment, discipline or use of physical force of any kind is prohibited.
- Always ensure another adult is present when spending time with children and avoid favoring or spending excessive time with specific children to the exclusion of others.
Visits to Partners, Programs and Communities
- Only visit Comic Relief US programs with the prior approval and knowledge of Comic and the grantee.
- Always ask the grantee partner if they have any specific safeguarding measures that should be followed and always adhere to their instructions at all times.
- Only take photos or videos on personal devices with explicit, written approval.
- Never possess, use or be under the influence of alcohol or drugs whilst on program visits
- Do not ask for or accept personal contact details (including social media addresses, Skype details, email, phone numbers) from any child or family supported through or engaged in Comic Relief US activities unless this has been explicitly authorized for business purpose.
Compliance with this code of conduct is mandatory. Any breach will be taken seriously and should be reported to Comic Relief’s Safeguarding Officer.
4. Reporting and Responding to Concerns
4.1 Reporting Safeguarding Concerns
There is a mandatory obligation on all Officers, Directors, employees, interns, independent contractors, volunteers and Visitors to report concerns, suspicions, allegations and incidents that indicate actual or potential abuse and/or any other breaches of this Policy. Failure to do so will be considered a breach of this policy and may result in disciplinary action.
If you become aware of actual or potential harm or abuse or a breach of this Policy:
- Listen and provide re-assurance to the individual reporting the concern.
- Do not investigate or try to address the concerns yourself as this may place you or others at risk.
- If there is an immediate risk of harm or a medical emergency, report the matter to emergency services.
- Never agree to keep secrets – Comic Relief US requires all concerns to be reported to the Safeguarding Officer.
- As soon as possible, and no later than within 24hrs, report the concern, suspicion, incident or allegation to the Safeguarding Officer in your area of operation. If the concern relates to the Safeguarding Officer, then the concern may be raised with one of the other Safeguarding Officers or the CEO of Comic Relief.
4.2 Response to Safeguarding Concerns
Comic Relief US is committed to responding appropriately and effectively to all allegations and suspicions of abuse, both current and historical.
The Safeguarding Officer is responsible for ensuring all concerns are taken seriously and appropriate action taken. This will include, but is not limited to:
- Ensuring that appropriate support is provided to the anyone affected by abuse through referral to relevant agencies.
- Ensuring the matter is reported to local law enforcement if a crime has been committed or suspected.
- Liaising fully with investigations by statutory agencies or, where appropriate, initiating an internal investigation. Where Comic Relief US conducts an investigation, this will be guided by external professional expertise and support.
- Working with the appropriate staff members to address the concern and implement changes based on any learning to prevent similar concerns in the future.
- Maintaining a confidential record of the concern and any actions taken; ensuring this information and is stored securely with access limited to the Safeguarding Officers and CEO.
The Safeguarding Officer will inform the CEO of all safeguarding concerns related to Comic Relief US staff, contractors, Board members or others representing the organization. The CEO will also be informed of any safeguarding incidents within grantees organizations where there is a reputational risk or where the Comic Relief US may have to suspend or withdraw funding due to safety concerns.
If you are concerned that the organization has failed to take action or have wider concerns about the management of safeguarding issues, you can raise these concerns via the Comic Relief’s Whistleblowing Policy.
5. Work with Grantees
Comic Relief US takes a grant cycle approach to safeguarding which means that we assess and promote practices that keep everyone safe at every stage of our funding relationship with grantees.
- Concept Note - applicants are asked to submit their safeguarding and other relevant policies at Concept Note stage as this provides reassurance that the organization has considered its approach to keeping people safe.
- Application – the application form includes key questions to explore how the organization prevents and responds to the risk of harm and abuse.
- Assessment – Comic Relief US reviews submitted policies and the answers to the application questions to ensure that adequate safeguarding measures are in place. Where gaps are identified, the organization may be required to strengthen their safeguarding as a condition on funding. If an organization does not have a safeguarding policy, they will be required to develop one in the first 12 months as a condition of funding.
- Grant Agreement – Grantees are required to maintain up-to-date safeguarding policies and ensure these are implemented. They are also required to ensure that all allegations of abuse are taken seriously and receive an appropriate, timely response
- Monitoring & Support - Safeguarding is included in monitoring calls and visits with grantees. If a grantee is not meeting the obligations set out in the grant agreement, this is escalated to Comic Relief’s Safeguarding Compliance Officer
- Reporting Safeguarding Concerns - As part of the Grant Agreement, Grantee are required to notify Comic Relief US of safeguarding allegations against staff or volunteers involved in the work funded by Comic Relief. Our role is to act as a critical friend to ensure appropriate action has been taken. However, responsibility for responding to the concern, including notifying relevant authorities, rests with the grantee partner and should be undertaken in line with their own safeguarding procedures.
For more detailed information, please refer to ‘Comic Relief US’s Guidelines for Integrating Safeguarding within the Grants Cycle’
6. Safe Story Telling
Capturing images and compelling stories play a critical role in Comic Relief’s work and the safety, dignity and welfare of contributors is at the heart of our story telling. When gathering images, stories or creating appeal films the following four principles must be followed:
6.1 Do No Harm:
The safety and well-being of our contributors, staff and audiences must always be our paramount consideration and we will never prioritize story telling over safety.
- Staff, contractors, local fixers & crew must be given a copy of the safe story telling guidelines, sign the Code of Conduct and attend a safeguarding training or briefing
- A Designated Safeguarding Lead is identified for all story gathering to ensure that safeguarding guidelines are followed and act as the first point of contact for any concerns. - We limit the amount of personal information shared (first names only, limiting the location information to the city or region)
- We will film in neutral enclosed spaces rather than public spaces or private homes wherever possible.
6.2 Dignity & Respect:
We will treat everyone with dignity and respect and avoid telling stories that are based on stereotypical assumptions or could degrade, victimize or shame contributors.
- We avoid presenting individuals as victims without the ability to solve their own problems
- We avoid sensationalizing or exotisizing the stories we tell and aim to provide context and preserve the dignity of those being featured
- We will not request interviews or film people who are critically ill or are experiencing traumatic suffering such loss or potential loss of a loved one, disease, natural disaster or violence.
6.3 Informed Consent:
We will provide clear and honest information and takes steps to ensure that participation is voluntary, and consent is freely given.
- In simple, understandable language, we explain who we are, why we are there and the intended use of the film, story or images.
- We obtain demonstrable, written consent including parental consent for children under the age of 18.
- We inform Grantee Partners and contributors of their right to withdraw consent. If consent is withdrawn, we edit the individual from the content or, if this is not possible, stop using the content.
We prioritize partnership and collaboration, drawing on the expertise of colleagues, Grantee Partners and others to keep people safe.
- The Grants Team are notified of all film projects and serve as a consultative partner to ensure the work of the is depicted in an accurate and transparent manner
- We work closely with Grantees to plan the story gathering, obtain consents and approvals and ensure the safety and welfare of everyone involved.
- We involve Talent that in stories that resonate with their life experiences, background and interests. We brief the talent on safeguarding and ensure they are always accompanied by Comic Relief US staff
For more detailed information, please refer to Comic Relief’s ‘Safe Storytelling Guidelines Cycle’
7. Safe People
7.1 Recruitment and Selection of Staff
Creating safe environments for adults starts with the appointment of suitably qualified, skilled, and vetted staff members who have the desired competencies and skills to carry out their functions in an effective, efficient, and safe manner. To achieve this, Comic Relief:
- Conducts interviews to check the suitability and experience of all candidates
- Obtains 2-3 references
- Conducts comprehensive, legally compliant background checks for new or existing staff who will come in direct contact with children and/or adults in vulnerable circumstances as part of their employment or engagement with Comic Relief.
Temporary personnel are contracted via an agency who will be responsible for ensuring the candidates suitability, obtaining referencing and conducting background checks. Comic Relief’s contracts with the agency will include this obligation.
7.2 Awareness Raising and Training
Comic Relief US will ensure that all Officers, Directors, employees, interns, independent contractors, volunteers and Visitors working directly or indirectly with children and/or adults in vulnerable circumstance are aware of their safeguarding policy and their responsibilities through:
- Providing new staff with a copy of the safeguarding policy
- Including safeguarding in the orientation for new staff
- Ensuring that there is an annual discussion on safeguarding in the all-staff meeting prior to the start of each campaign to refresh everyone’s awareness of the policy and their responsibilities
- Providing refresher training every two years
8. Monitoring and Review
Comic Relief US will ensure that implementation of this Policy is subject to regular monitoring. The Policy will be reviewed annually and whenever there are legislative changes or guidance issued that may impact the Policy, appropriate changes will be recommended to the Comic Relief Board of Directors for approval.
Date Policy Approved: June 23, 2022