Safeguarding Policy

Preamble

This policy aims to ensure all involved in the organisation and attending the Bloomberg Square Mile Relay (BSMR) are kept free from harm, within a safe and positive environment. This policy reflects the BSMR’s commitment to safeguard all participants in all aspects of the events activities from non-accidental violence that includes physical, emotional, sexual abuse and harassment, as well as neglect and exploitation. This policy is officially endorsed by staff at the highest level of the organisation (Square Mile Sport Ltd, part of Benchmark Sport Ltd).

Definitions

Affected persons/parties: Those affected by or involved with the event whose human rights must be protected, respected and fulfilled.

Child abuse or maltreatment: constitutes all forms of physical and/or emotional ill-treatment, sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to a child’s (individual under the age of 18) health, survival, development or dignity in the context of a relationship of responsibility, trust or power.

Interpersonal violence: involves the intentional use of physical force or power against other persons by an individual or small group of individuals. It can occur online, be perpetrated by different actors and take different forms.

Non-accidental violence: acts of harm or abuse inflicted on individuals, as opposed to injuries or harm caused unintentionally or unexpectedly. This type of violence encompasses physical, psychological (emotional), sexual, and financial abuse, as well as neglect and exploitation.

Physical violence: an act attempting to cause, or resulting in, pain and/or physical injury. Physical violence includes beating, burning, kicking, punching, biting, maiming or killing, or the use of objects or weapons.

Psychological violence (emotional abuse): involves the regular and deliberate use of a range of words and non-physical actions used with the purpose to manipulate, hurt, weaken or frighten a person mentally and emotionally; and/or distort, confuse or influence a person’s thoughts and actions within their everyday lives, changing their sense of self and harming their wellbeing. In sailing, it could also take the form of non-physical actions that could cause physical or psychological harm to the individual. Psychological violence could occur online and offline in different forms.

Safeguarding: all proactive measures to prevent and appropriately respond to concerns related to harassment and abuse as well as the promotion of holistic approaches to athlete welfare.

Sexual violence (including sexual harassment): Any sexual act, attempt to obtain a sexual act, unwanted sexual comments or advances, or acts to traffic, or otherwise directed against a person’s sexuality using coercion, by any person regardless of their relationship to the victim, in any setting including but not limited to home and work. The different forms of sexual violence can occur both online and in person.

Article 1. Scope of Application

All Covered Persons are bound by this policy. A Covered Persons is defined as any person who:

Is employed or is contracted in any way to provide services and support for the organisation or the BSMR events that the organisation participates in or organises including administration, volunteers, suppliers, contractors.
Receives accreditation, registers for and/or otherwise attends, competes, coaches, officiates, or otherwise participates in a BSMR event.
Is a parent, legal guardian or chaperone of any Covered Person, if a minor.

Each of the above Covered Persons is deemed to have submitted to the authority of the organisation to enforce this Policy, including any consequences for breach thereof, and to the jurisdiction of the disciplinary process of the organisation.

All Covered Persons must comply with all relevant national laws with the applicable criminal laws taking primacy over provisions laid out in this policy.

Article 2. Violations

The respect of human rights and dignity is a fundamental requirement. This Policy applies to all conduct that infringes upon the human rights of a Covered Person and risks damaging integrity and reputation. A violation is committed under this Policy, for:

Any non-accidental violence as defined by this Policy including, but not limited to, sexual violence, sexual harassment, physical or psychological violence.
Where there is:
1. reasonable cause to suspect someone has harmed one or more Covered Persons and/or
2. may pose a risk of such harm.

Article 3. Aid, abetment or attempt

Any form of aid, abetment, attempt, agreement, encouragement, conspiracy, or coverup by a Covered Person that could result in a violation of this Policy shall be treated as if a violation had been committed, whether such an act in fact resulted in a violation and/or whether that violation was committed deliberately or negligently.

Article 4. Retaliation and victimisation

Any retaliation against, or victimisation of, any person involved in bringing a complaint of wrongdoing under this Policy will be considered a violation of this Policy.

Article 5. Cooperation with an investigation

Covered Persons shall cooperate fully will any investigation conducted into a violation under this Policy.
Refusing or failing, without compelling justification, to cooperate with any reasonable investigation carried out by the organisation or other competent authority in relation to a possible violation of this Policy, shall constitute a violation of the Policy, including, without limitation:
1. refusing or failing to provide accurately, completely and without any undue delay any information and/or documentation and/or access or assistance requested, including but not limited to records relating to the alleged violation (such as itemised telephone bills, internet service records, computers, hard drives and other electronic information storage devices), and/or a statement setting out the relevant facts and circumstances around the alleged violation;
2. obstructing or delaying any investigation;
3. concealing, tampering with or destroying any documentation or other information that may be relevant to the investigation.

Article 6. Obligation to Report

If a Covered Person is aware of any other individual breaching this Policy, then Covered Persons should intervene or challenge the behaviour if safe to do so. Covered Persons are encouraged to be open to raise concerns or issues at any time and to avoid being enablers of harassment and abuse to occur.
Every Covered Person has an obligation to report, as soon as practicable, any act, thing or information which they become aware of, which may constitute a violation of this Policy. Any such information shall be reported to the organisation or police as appropriate if Covered Persons feel the person is in immediate danger or at risk.
Reports can be made to designated Safeguarding Officer(s) or to [email protected].
An Incident Report Form may be completed and submitted to the organisation.

Article 7. Safeguarding Officer and Safeguarding Inquiries

The organisation will appoint a Safeguarding Officer, the key point of contact for safeguarding matters with the following roles and responsibilities:

To raise awareness of this Policy and associated procedures for reporting concerns.
To act as the main point of contact for anyone reporting alleged concerns of non-accidental violence and to ensure they are appropriately supported and to determine how reported concerns should be resolved.
To assess the seriousness of an incident and determine what action is required, except in circumstances where police and/or medical intervention is required urgently, and consultation would cause an unacceptable delay upon which immediate action may be taken by the organisation. In cases of a clear criminal nature, the local law enforcement authorities should immediately be informed.
To assess any risks posed by the accused person and whether there is a need to remove the person from the organisation/event or impose other protective measures.
To determine the jurisdiction for the Covered Persons involved and to coordinate referral of cases to law enforcement or other statutory authorities as is appropriate and to promptly inform them of any allegations (where possible) and/or sanction(s) imposed on any person under their jurisdiction relating to any non-accidental violence case(s).
To assess whether the responsible organisation with jurisdiction has a policy in place to respond appropriately and/or whether the response is adequate.
To define what, if any, support is required for the affected parties.
To undertake an inquiry into an alleged case, with the support of a Safeguarding Committee. Such an inquiry may involve interviews of affected persons or other evidence for which appropriate cautions will be given and written statements taken. Appropriate trauma informed practices and protective measures should be taken at this time such as taking of testimonies anonymously; ensuring that live evidence is only required to be given once throughout the procedure (including appeal.
To monitor and take appropriate steps in relation to contractual obligations which require compliance with this Policy.

Article 8. Safeguarding Committee

The organisation may establish a Safeguarding Committee that will, amongst other tasks, determine the appropriate sanctions in a safeguarding case.
The Safeguarding Committee should be composed of ideally three individuals, potentially from outside of the organisation and where there are no conflicts of interest with the persons involved. Members of the Committee should have expertise and experience in addressing safeguarding concerns such as through trauma-informed interview training, human rights expertise, and an understanding of the relevant local laws.
The Committee shall determine in his sole discretion whether a hearing shall be held by telephone, video conference or in person.

Article 9. Applicable law and coordination with statutory investigations

Conduct which may constitute the commission of a violation of this Policy may also amount to a criminal offence and/or a breach of other applicable laws or regulations.
In case of any report to the relevant local authorities, the applicable law will be the national law of the country where the incident happened.
This Policy is intended to supplement such laws and regulations with further rules of conduct for those involved in the organisation or event. It is not intended, and should not be interpreted, construed or applied, to prejudice or undermine in any way the application of such laws and regulations (which must always be complied with).
Regardless of criminal proceedings, the organisation may also consider disciplinary measures under this Policy, or alternatively to not commence or to suspend an investigation. Whether or not to continue an investigation is a fact specific exercise.
The organisation shall coordinate with law enforcement authorities’ investigations on the same facts.

Article 10. Rights of the concerned person

In all procedures linked to violations of this Policy, the following rights must be respected:

The right to be informed that a prima facie case has been found, informed of the alleged violations, details of the alleged acts and/or omissions, and the range of possible sanctions.
The right to a fair, timely and impartial hearing either by appearing personally in front of the organisation and/or submitting a defence in writing; and
The right to be accompanied and/or represented.
Fairness of procedure for all parties must be ensured.

Article 11. Legal standing

Affected persons are to be considered as parties to the proceedings, not only as witnesses. The following rights should be accorded to all those with legal standing:

Right to legal representation
Right to ask questions and cross-examine witnesses
Right to appeal decisions
Right to receive a copy of the final decisions

Article 12. Burden and standard of proof

The organisation shall have the burden of establishing that a violation has been committed. The standard of proof in all matters under this Policy shall be the balance of probabilities, a standard that implies that on the preponderance of the evidence it is more likely than not that a breach of this Policy has occurred.

Article 13. Admissibility of Evidence

The Safeguarding Committee shall review any evidence and facts submitted, including but not limited to, admissions, evidence of third parties, witness statements, video or audio evidence, expert reports, journalistic reports, documentary evidence and other analytical information and evidence based on electronic media in any form and any such other form of proof as the Committee may deem to be reliable.

Article 14. Confidentiality

The principle of confidentiality must be strictly respected by the organisation during all the procedure; information should only be exchanged with entities on a need-to-know basis, as deemed necessary by the organisation and permitted by law. Confidentiality must also be strictly respected by any person concerned by the procedure until there is public disclosure of the case.
Information can only be shared without consent of a Covered Party where the duty to protect a Covered Person from harm supersedes the Covered Party’s right to privacy or else if required by law.
The organisation should also ensure that all Covered Persons affected by the procedure understand the importance of confidentiality and know the consequences of breaching confidentiality.

Article 15. Data protection

The organisation will ensure compliance with national and regional data protection requirements and be aware of exemptions and special category data that may be applicable and all consent that is required.
The organisation will consistently log chains of custody of data, providing a summary of findings and listing all evidence sources including documentation, physical, digital etc.

Article 16. Anonymity

The organisation will ensure that the identity of affected persons is comprehensively protected through measures such as:

Redacting names and other immediately identifiable details in published materials.
Limiting the number of people within the organisation involved in the procedure from knowing the identity of affected persons.
Using protective measures such as videos for hearings, screens, voice distortion etc.

There may be certain circumstances where we the organisation is required to share information such as where there is reason to believe that someone is at risk of serious harm, abuse, or neglect, or if the disclosure relates to an individual under the age of 18, or where there is a legal obligation to do so. In such circumstances, information may be shared with the appropriate authorities.

Article 17. Protection of Whistleblowers

The organisation will provide a confidential channel through which individuals can report.
Whistle-blowers who report a breach of this Policy through the confidential channel will be provided with anonymity and protection from retaliation.
When Covered Persons feel that they have suffered retaliation for making a report, The organisation will investigate and adjudicate the allegation of retaliation and when appropriate, prosecute the offending party.

Article 18. Provisional Measures and Sanctions

The Safeguarding Committee may impose provisional measures, including a provisional suspension, on the Covered Person where there is a particular risk to the reputation of the organisation, or risk of harm.

Where it is determined that a violation of this Policy has been committed, the Committee shall impose an appropriate sanction upon the Covered Person from the range of permissible sanctions, which may range from a minimum of a warning, removal of accreditation to a maximum of life ban.

The Committee shall render a written, dated and signed decision with reasons. In urgent matters, it may issue a decision without reasons and provide the reasons at a later time.

Article 19. Mutual recognition of sanctions

Subject to the right of appeal, any decision issued in compliance with this Policy should be recognised and respected by all other organisations and event organisers.
All organisations should recognise and respect the relevant decision(s) made by any court of competent jurisdiction which is not a Organisation or Event Organiser as defined under this Policy.

Article 20. Appeals

Any preliminary decision of the Committee may be appealed to the organisation’s leadership.

Article 21. Protection and Support

The organisation will provide signposting to protection and support as well as options for remedy.
The organisation will liaise with the relevant entities and facilitate access to the support.

Article 22. Statute of Limitations

The organisation will cooperate with the relevant organisations in the case of reporting of historic wrongdoing whereby the persons may still be Covered Persons at the organisation.

Entry into force

This policy takes effect on 6th February 2026 and will be reviewed and updated periodically to ensure continued compliance with relevant legislation, standards, and best practice.