Safeguarding Policy

1. Our Commitment

Heroes of Hope UAE Organisation and Events LLC (“Heroes of Hope”) is committed to providing a safe, inclusive, respectful and positive sporting environment for every athlete.

Our athletes are at the heart of everything we do. Every athlete has the right to participate in sport free from abuse, neglect, bullying, discrimination, intimidation or any other form of harm.

Safeguarding is everyone’s responsibility. This policy applies to all Heroes of Hope activities, including:

• Training sessions.
• Sporting activities.
• Competitions.
• Events.
• Trips.
• Transport arrangements.
• Social activities.
• Online and digital communications.
• Any other activity carried out on behalf of or representing Heroes of Hope.

Heroes of Hope will take reasonable and proportionate steps to protect athletes and respond appropriately to safeguarding concerns.

2. Who Does This Policy Protect?

This policy protects all Heroes of Hope athletes, with particular care given to children, young people and athletes who may require additional support or assistance. It applies to:

• Coaches.
• Junior Coaches.
• Athletes.
• Volunteers.
• Staff and Management.
• Parents, carers and guardians when participating in Heroes of Hope activities.
• Anyone else representing or acting on behalf of Heroes of Hope.

Everyone covered by this policy has a responsibility to contribute to a safe environment.

3. What Does Safeguarding Mean?

Safeguarding means taking reasonable steps to protect athletes from harm and responding appropriately when a concern arises. Safeguarding includes protection from:

• Physical abuse or inappropriate physical contact.
• Sexual abuse, harassment or inappropriate behaviour.
• Emotional or psychological abuse.
• Neglect.
• Bullying or intimidation.
• Discrimination.
• Exploitation.
• Humiliation or degrading treatment.
• Unsafe coaching or sporting practices.
• Inappropriate online communication or contact.
• Other behaviour or circumstances that place an athlete at risk of harm.

Heroes of Hope has zero tolerance for abuse or behaviour that places an athlete at risk. A safeguarding concern does not need to be proven before it is reported.

4. Our Safeguarding Principles

Heroes of Hope will:

• Put the best interests, safety and wellbeing of the athlete first.
• Treat every athlete with dignity, kindness and respect.
• Provide an inclusive environment where athletes feel safe to participate.
• Listen to athletes and take their concerns seriously.
• Recognise that some athletes may require additional support to communicate concerns.
• Never discriminate against an athlete because of disability, ability, age, gender, nationality, race, religion or any other characteristic.
• Take safeguarding concerns seriously and act promptly.
• Maintain appropriate professional boundaries.
• Protect anyone who raises a genuine safeguarding concern from retaliation.
• Maintain appropriate confidentiality and share information only with those who have a legitimate need to know.
• Handle personal and sensitive information responsibly and in accordance with applicable UAE data-protection requirements, including Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data.
• Where a concern involves a child or young person, act in accordance with applicable UAE child-protection requirements, including Federal Law No. 3 of 2016 Concerning Child Rights (Wadeema’s Law).

Safeguarding requirements will always take priority where there is a risk of harm.

5. Responsibilities of Coaches

All Coaches are expected to:

• Put athlete safety and wellbeing before winning or performance.
• Maintain professional boundaries at all times.
• Use appropriate and respectful language.
• Treat every athlete with dignity and respect.
• Never use physical punishment, threats, humiliation or intimidation.
• Only use physical contact when it is appropriate, necessary and in the athlete’s best interests.
• Follow safe coaching and emergency procedures.
• Avoid being alone with an athlete wherever reasonably possible.
• Follow Heroes of Hope procedures for one-to-one support.
• Communicate with athletes professionally and appropriately.
• Follow Heroes of Hope procedures for photographs, videos and social media.
• Protect confidential athlete information.
• Report any safeguarding concern, disclosure or suspected abuse promptly.
• Complete all safeguarding training required by Heroes of Hope.

Coaches must never:

• Shout at, threaten, ridicule or deliberately embarrass an athlete.
• Use physical activity or exercise as punishment.
• Use physical contact as punishment, intimidation or humiliation.
• Develop inappropriate personal, romantic or sexual relationships with athletes.
• Send inappropriate messages, photographs or content to athletes.
• Ask athletes to keep secrets from parents, carers, guardians or Heroes of Hope Management.
• Ignore, conceal or deliberately delay reporting a safeguarding concern.
• Investigate safeguarding allegations themselves where doing so could compromise an appropriate safeguarding response.

6. Responsibilities of Junior Coaches

Junior Coaches are role models and must follow the same fundamental safeguarding standards as Coaches. Junior Coaches must:

• Treat athletes with patience, respect and kindness.
• Follow the instructions of the Lead or Senior Coach.
• Remain within appropriate professional boundaries with athletes.
• Never supervise or communicate with athletes inappropriately or outside their role.
• Follow Heroes of Hope safeguarding procedures.
• Never attempt to investigate a safeguarding concern themselves.
• Immediately tell the Lead Coach or Safeguarding Lead if they see, hear or become aware of something that concerns them.
• Never promise an athlete that they will keep a safeguarding disclosure secret.
• Maintain appropriate confidentiality.
• Complete required safeguarding training.

Being young, inexperienced or a volunteer does not remove a Junior Coach’s safeguarding responsibility.

7. Responsibilities of Athletes

Every athlete has the right to:

• Feel safe and respected.
• Be treated fairly and without discrimination.
• Participate at a level appropriate to their ability and needs.
• Say “no” to inappropriate behaviour or contact.
• Tell a trusted adult if something makes them feel uncomfortable, unsafe or worried.
• Have concerns listened to and taken seriously.
• Receive appropriate support to communicate concerns where required.

Athletes are expected to:

• Treat Coaches, Junior Coaches, volunteers and fellow athletes respectfully.
• Follow reasonable safety instructions.
• Avoid bullying, threatening or deliberately hurting others.
• Tell a Coach, parent, guardian or trusted adult if they are worried about someone’s safety.

Where an athlete has communication or additional support needs, Heroes of Hope will make reasonable efforts to provide appropriate ways for that athlete to communicate concerns.

8. One-to-One Situations

Where possible, Coaches and volunteers should avoid being alone with an athlete. Where one-to-one support is necessary:

• It should take place in an observable or appropriately supervised environment wherever reasonably possible.
• The Coach or volunteer must maintain professional boundaries.
• A parent, carer, guardian or another appropriate member of staff should be informed where appropriate.
• Any physical assistance must be necessary, appropriate and respectful.
• The type and level of support should be consistent with the athlete’s known needs and, where relevant, the Athlete Support Snapshot.
• Information about the athlete’s support needs should be shared only with personnel who need the information to provide safe and appropriate support.

Additional care must be taken where an athlete requires personal, physical or communication support. Coaches and volunteers must not disclose an athlete’s disability, medical information, behavioural information or other sensitive information to other athletes, families or unauthorised persons.

Where a one-to-one situation results in a safeguarding concern, injury, incident or other significant event, the matter must be reported and recorded in accordance with Heroes of Hope procedures. Any record created must contain only information relevant to the incident or support provided and must be stored securely with access limited to authorised personnel.

9. Changing Rooms, Toileting and Personal Care

Heroes of Hope will respect the privacy, dignity and individual needs of every athlete. Coaches and volunteers should not enter changing or toileting areas unless there is a genuine safety, medical or safeguarding reason.

Where an athlete requires assistance with personal care:

• Assistance should be appropriate to the athlete’s identified needs.
• The athlete’s dignity, privacy and independence should be respected.
• Wherever reasonably possible, another responsible adult should be aware that assistance is being provided.
• Physical contact must be appropriate, necessary and proportionate.
• Assistance should be provided in accordance with relevant support arrangements communicated through the Athlete Support Snapshot.
• Information about an athlete’s personal-care needs must be treated as confidential.
• Personal-care information should be shared only with individuals who need the information to provide safe and appropriate care.

Personal-care information should not be discussed in public areas or shared with other athletes or families unless there is a legitimate reason and appropriate authorisation. Any records relating to personal care, medical needs or an incident involving personal care must be handled as confidential information and stored securely in accordance with Heroes of Hope’s data-protection and safeguarding procedures.

Where an athlete is unable to provide consent or authorisation because of age, communication needs or circumstances, Heroes of Hope will act in accordance with applicable law, the athlete’s best interests, safeguarding requirements and any appropriate authorisation provided by a parent, carer or guardian.

10. Photography, Video and Social Media

Photographs and videos can be an important part of celebrating Heroes of Hope athletes. However, images and recordings that identify an athlete are personal information and must be handled responsibly. Coaches, Junior Coaches and volunteers must:

• Follow Heroes of Hope’s consent and authorisation requirements before taking or sharing photographs or videos.
• Explain, where appropriate, how photographs or videos will be used, including whether they may appear on Heroes of Hope’s website, social media or other public communications.
• Use only approved devices, channels and accounts when representing Heroes of Hope.
• Never take or share inappropriate, humiliating or intrusive images.
• Never photograph or record an athlete in changing, toileting or other private areas.
• Never ask an athlete to send personal photographs or videos through private messaging or personal accounts.
• Never share an athlete’s name, medical information, disability information, support needs, location or other personal information alongside an image unless there is an appropriate and legitimate reason to do so.
• Never share photographs or videos with third parties for purposes unrelated to Heroes of Hope activities without appropriate authorisation.
• Store photographs and videos securely.
• Restrict access to authorised personnel.
• Follow any applicable withdrawal or restriction of consent or authorisation.

Consent or authorisation for photography and video should be obtained separately from consent for participation in sporting activities where appropriate. Refusing permission for non-essential photography or publicity should not, by itself, prevent an athlete from participating in Heroes of Hope activities.

Where an athlete is a child or requires assistance with decision-making or communication, Heroes of Hope will use an appropriate consent or authorisation process consistent with applicable law and the athlete’s circumstances.

Heroes of Hope may take or use photographs or recordings without relying solely on individual consent where this is necessary for safeguarding, security, emergency response or another lawful purpose, where permitted by applicable law. Such use must remain proportionate and limited to the relevant purpose.

Private or inappropriate communication between Coaches, volunteers and athletes is not permitted. Any photograph, video or recording that is no longer required for its stated purpose should be securely deleted or disposed of, subject to applicable legal, safeguarding or operational retention requirements.

All photographs, videos and related personal information will be handled in accordance with Heroes of Hope’s applicable privacy and data-protection requirements, including Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data.

Where an image, recording or communication raises a safeguarding concern, safeguarding requirements take priority and the information may be retained and shared with authorised personnel or relevant authorities where necessary or required by law.

11. Recognising a Safeguarding Concern

A safeguarding concern may arise from:

• Something an athlete says.
• Something an athlete does.
• An injury or unexplained change in behaviour.
• Something a Coach or volunteer witnesses.
• Something reported by a parent, carer, guardian or another athlete.
• An online message, photograph or interaction.
• A concern about the behaviour of another Coach, volunteer or adult.
• Information received from another organisation or professional.
• A pattern of behaviour or circumstances that causes concern.

A safeguarding concern does not need to be proven before it is reported. People should not wait for certainty before raising a genuine concern.

Where the concern relates to a child or young person, Heroes of Hope will respond in accordance with its safeguarding procedures and applicable UAE child-protection requirements, including Federal Law No. 3 of 2016 Concerning Child Rights (Wadeema’s Law).

12. What To Do If an Athlete Tells You Something

If an athlete makes a disclosure, the person receiving the disclosure should remain calm and respond appropriately.

DO:

• Stay calm.
• Listen carefully.
• Take the athlete seriously.
• Allow the athlete to speak in their own words.
• Reassure the athlete that they have done the right thing by speaking up.
• Explain that you may need to tell someone who can help keep them safe.
• Record the facts as soon as possible using factual and objective language.
• Report the concern promptly to the Heroes of Hope Safeguarding Lead or Management Team.

DO NOT:

• Promise to keep it a secret.
• Investigate the allegation yourself.
• Ask leading or unnecessary questions.
• Confront the person alleged to have caused harm.
• Dismiss the concern.
• Blame or judge the athlete.
• Ask the athlete to repeatedly recount the incident unnecessarily.
• Share details of the concern with people who do not have a legitimate need to know.

Where a disclosure indicates that a child may have been subjected to abuse, neglect, exploitation or another form of harm, the matter must be escalated promptly in accordance with Heroes of Hope safeguarding procedures and applicable UAE child-protection requirements, including Wadeema’s Law (Federal Law No. 3 of 2016 Concerning Child Rights).

13. Reporting a Safeguarding Concern

Any Coach, Junior Coach, athlete, volunteer, parent, guardian, carer or staff member who has a safeguarding concern must report it as soon as possible to the designated Heroes of Hope Safeguarding Lead or Management Team.

A report should include, where known:

• What happened or what was observed.
• Who was involved.
• When and where it happened.
• Any immediate safety concerns.
• Any information provided directly by the athlete.
• Any immediate action that has already been taken.

Concerns should be recorded accurately, objectively and factually. Safeguarding records must be stored securely and access must be limited to those who need the information to respond to the concern or fulfil their safeguarding or legal responsibilities.

Heroes of Hope will assess safeguarding concerns promptly and take appropriate protective action. Where a concern involves a child or young person, Heroes of Hope will comply with applicable UAE child-protection requirements, including Federal Law No. 3 of 2016 Concerning Child Rights (Wadeema’s Law), including applicable obligations to report suspected abuse, neglect or harm to the relevant authorities.

Information will be shared only where there is a legitimate safeguarding, legal or operational need to do so. Confidentiality must not be used as a reason to delay or prevent a required safeguarding referral or report.

If there is an immediate risk of serious harm, the priority is to ensure the athlete’s immediate safety and contact the appropriate emergency or statutory authority.

13.1 Emergency Safeguarding

Where there is an immediate risk of serious harm to an athlete, the priority is to protect the athlete and obtain appropriate emergency assistance. All Coaches, Junior Coaches, staff and volunteers should:

1. Act immediately to protect the athlete from further harm where it is safe and appropriate to do so.
2. Contact the appropriate emergency or statutory service where there is an immediate risk of serious injury, abuse, neglect or other harm.
3. Notify the Heroes of Hope Safeguarding Lead or Management Team as soon as reasonably possible.
4. Stay with the athlete, or ensure appropriate supervision, until responsibility has been transferred to an appropriate responsible adult or emergency/statutory service where this is safe and appropriate.
5. Record the concern and actions taken as soon as possible using factual and objective language.
6. Preserve relevant evidence where appropriate, including messages, photographs, communications or other records.
7. Do not alter, delete or circulate potential evidence.
8. Maintain confidentiality and share information only with people who have a legitimate safeguarding, emergency or legal need to know.

Where the concern involves a child or young person, Heroes of Hope will respond in accordance with applicable UAE child-protection requirements, including Federal Law No. 3 of 2016 Concerning Child Rights (Wadeema’s Law) and any applicable reporting obligations.

Where a safeguarding concern involves the Safeguarding Lead, a Management Team member, Coach, volunteer, parent, carer or another person who would normally receive or manage the concern, the concern should be reported to an alternative responsible person or directly to the appropriate authority where necessary.

No person should delay reporting an emergency while attempting to obtain internal approval. Immediate safety takes priority.

Safeguarding records created following an emergency will be stored securely and handled in accordance with Heroes of Hope’s safeguarding procedures and applicable UAE data-protection requirements, including Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data.

14. Confidentiality and Non-Retaliation

Safeguarding information, including information relating to an athlete’s health, disability, support needs, disclosures or safeguarding concerns, will be treated as confidential and handled securely. Heroes of Hope will:

• Collect and use personal and sensitive information only where necessary for safeguarding, athlete support, safety, administration or another legitimate purpose.
• Limit access to information to authorised individuals who have a legitimate need to know.
• Take reasonable measures to protect information against unauthorised access, loss, misuse, alteration or disclosure.
• Share information only where necessary for safeguarding, the delivery of appropriate athlete support, legal compliance, or where otherwise permitted or required by applicable law.
• Retain safeguarding and personal information only for as long as necessary for the relevant purpose and applicable legal or operational requirements.
• Ensure that records are kept accurate and updated where relevant.
• Securely dispose of or delete information when it is no longer required, subject to applicable legal or safeguarding retention requirements.

Heroes of Hope will handle personal and sensitive information in accordance with applicable UAE data-protection requirements, including Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data. For child-protection matters, confidentiality will be balanced with the legal and safeguarding duty to protect children. Where disclosure or reporting to a relevant authority is required or permitted by applicable UAE law, information may be shared for that purpose.

Non-Retaliation

No athlete, Coach, Junior Coach, volunteer, staff member, parent, guardian or other person will be punished, intimidated or treated unfairly for:

• Raising a genuine safeguarding concern in good faith.
• Reporting a concern.
• Making a disclosure.
• Participating appropriately in a safeguarding process.
• Providing information relevant to a safeguarding concern.

Retaliation against a person who raises a genuine safeguarding concern will not be tolerated.

15. Recruitment and Training

Heroes of Hope will take reasonable and proportionate steps to ensure that people working directly with athletes are suitable for their role and do not present an avoidable safeguarding risk.

Before working with athletes, Coaches, Junior Coaches, staff and volunteers will complete the screening and suitability checks required for their role. At a minimum, this may include:

• A completed application and role-appropriate interview or assessment.
• Verification of identity.
• Verification of relevant qualifications or experience where applicable.
• Appropriate references, including employment or role-related references where reasonably available.
• Appropriate criminal record, police clearance or equivalent background screening for personnel whose role involves regular or unsupervised contact with children or young people, subject to applicable UAE law and the screening mechanisms available for the role.
• Additional screening or checks where the nature of the role, level of responsibility or safeguarding risk requires them.
• Safeguarding and child-protection induction before commencing work with athletes.
• Safeguarding and child-protection training appropriate to the person’s role.
• Data-protection and confidentiality awareness.
• Ongoing supervision and support.

Heroes of Hope will not knowingly place a person in a role involving regular or unsupervised contact with children or young people where required safeguarding screening has not been completed, unless an appropriate interim arrangement has been formally approved and the person is not left unsupervised with children.

Screening requirements will be reviewed periodically and may be repeated or updated where required by law, organisational policy, a change in role or a safeguarding concern. All Coaches and Junior Coaches are expected to understand and follow this policy before working with athletes.

Personnel who work with children or young people will receive appropriate awareness of their responsibilities under Federal Law No. 3 of 2016 Concerning Child Rights (Wadeema’s Law), including their responsibility to promptly escalate concerns about suspected child abuse, neglect or harm in accordance with applicable law and Heroes of Hope’s safeguarding procedures.

Completion of screening and training requirements will be documented securely. Access to screening and background-check information will be restricted to authorised personnel with a legitimate need to know and handled in accordance with applicable UAE data-protection requirements, including Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data.

16. Safeguarding Lead

Heroes of Hope will appoint a Safeguarding Lead/Child Protection Coordinator who has overall responsibility for coordinating safeguarding arrangements and responding to safeguarding concerns. The Safeguarding Lead is responsible for:

• Receiving and responding to safeguarding concerns.
• Ensuring immediate safety measures are taken where required.
• Maintaining confidential and secure safeguarding records.
• Ensuring concerns are assessed and escalated appropriately.
• Making or coordinating referrals to relevant authorities where required or appropriate.
• Supporting Coaches, Junior Coaches, staff and volunteers in responding to safeguarding concerns.
• Coordinating safeguarding and child-protection training.
• Reviewing and updating safeguarding procedures.
• Monitoring compliance with this policy.
• Liaising with parents, carers and relevant authorities where appropriate.
• Ensuring safeguarding information is shared only with those who have a legitimate need to know, subject to applicable safeguarding and legal requirements.

The Safeguarding Lead should not undertake an internal investigation where doing so could compromise an external investigation, create a conflict of interest or otherwise prejudice the safety or interests of an athlete.

Any person may report a safeguarding concern directly to the relevant authorities where they reasonably believe that immediate action is required, where a legal reporting obligation applies, or where they believe the concern has not been appropriately addressed internally.

Heroes of Hope will identify an alternative responsible person or Deputy Safeguarding Lead to receive concerns when the Safeguarding Lead is unavailable or has a conflict of interest. The name and contact details of the Safeguarding Lead and Deputy Safeguarding contact should be communicated to Coaches, Junior Coaches, staff, volunteers and families and displayed where appropriate at Heroes of Hope venues.

Safeguarding Lead

Deputy Safeguarding Contact

17. Breaches of This Policy

Any breach of this policy will be taken seriously and responded to in a manner proportionate to the nature and seriousness of the concern. Depending on the circumstances, Heroes of Hope may:

• Provide additional guidance, supervision or training.
• Require remedial action or additional safeguarding measures.
• Restrict or remove an individual from contact with athletes while a concern is assessed.
• Remove an individual from coaching, volunteering or other athlete-facing duties.
• Suspend or terminate a volunteer, coaching or other role, subject to applicable procedures.
• Require completion or renewal of mandatory safeguarding screening or training before an individual returns to an athlete-facing role.
• Report concerns to the appropriate authorities where required or appropriate.
• Take any other action reasonably necessary to protect athletes.

Temporary removal or restriction from athlete-facing duties is a protective measure and does not, by itself, imply that an allegation has been substantiated.

Serious safeguarding concerns, including concerns involving children or young people, will be dealt with in accordance with applicable UAE legislation and safeguarding requirements, including Federal Law No. 3 of 2016 Concerning Child Rights (Wadeema’s Law) where applicable.

Heroes of Hope will maintain appropriate records of safeguarding concerns, decisions and actions taken. Such records will be handled confidentially, securely and in accordance with applicable UAE data-protection requirements, including Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data.

18. Our Safeguarding Promise

At Heroes of Hope, we believe every athlete deserves to feel:

Safe. Respected. Included. Valued.

We will work together to create a sporting community where athletes can develop their skills, confidence and independence in an environment where their safety and wellbeing always come first.

Everyone at Heroes of Hope has a role in safeguarding. If something does not feel right, speak up.

No one should be discouraged from raising a genuine concern. Heroes of Hope will not tolerate retaliation against anyone who raises a safeguarding concern in good faith.