Safeguarding Policy | The Association of Corporate Treasurers

Safeguarding Policy

1.            Introduction

At the ACT we are extremely committed to the protection and safeguarding of all learners (including apprentices) who undertake learning with us online or face to face.  We believe that everyone has an equal right to protection from abuse, regardless of their age, race, religion, ability, gender, language, background or sexual identity.

We expect ACT staff, tutors, and anyone else who has direct contact with learners, to have read, understood and adhere to this policy and related procedures.  We will take every reasonable step to ensure that all learners are kept safe and secure so that they can learn and thrive.  ACT will not tolerate abuse and exploitation by staff or associated personnel.

Learners can expect that they will be treated sensitively and with dignity should a safeguarding incidence/concern occur, or an allegation of abuse be made. The ACT requires staff to treat such matters confidentially, notifying colleagues only on a ‘need to know’ basis under the direct guidance of the Director of Learning.  Our team understands that any of our learners who confide in them may want to keep the information shared confidential. But for safety reasons, if there is a concern about safety, our staff may need to report the problem to the relevant organisations.


2.            Safeguarding Definitions

a)            Safeguarding

The term ‘Safeguarding’ describes the approach to planning and procedures that are necessary to be in place to protect peoples' health, wellbeing and human rights, and enabling them to live in safety and free from harm, abuse and neglect.

In our organisation, we understand it to mean having a culture of vigilance where all staff know their responsibilities and act accordingly, and all learners are aware of what they can expect from the ACT.  It is about providing a deep commitment to place the learner at the centre and to build policies, practices and procedures around the learner for them to succeed.


3.            ACT Responsibilities

We commit to addressing safeguarding, through the stages of prevention, reporting and response.  We will:

  • follow up on reports of safeguarding concerns promptly and according to due process
  • ensure all staff and associated personnel have access to, are familiar with, and know their responsibilities within this policy
  • design and undertake all its activities in a way that protects people from the risk of harm that may arise from their contact with us.  This includes the way in which information about individuals on our programmes and activities is gathered and communicated
  • ensure staff and associated personnel undertake suitable training commensurate with their role in the organisation
  • implement safeguarding procedures proportionate to the risk when recruiting, managing and deploying staff and associated personnel
  • review the Safeguarding Policy on an annual basis to ensure it covers any changes in legislation and remains suitable for the needs of the ACT
  • conduct safeguarding risk assessments
  • not use ACT activities to develop relationships with potentially vulnerable adults for personal gain


4.            How to report a safeguarding concern

For the purposes of this procedure, a complaint is an expression of dissatisfaction or concern about the way in which a safeguarding matter has been dealt with by us.

The complainant must be the person directly affected by the issue or an interested party to the person affected (e.g., a close relative or employer), and not an unrelated third party or wider observer.

Anyone who has a complaint or concern relating to safeguarding should report it immediately to the safeguarding team as follows:

  • Natalie Eggins, the Director of Learning. 
  • In the absence of the Director of Learning, Janet Legge, the Director of Awarding Body will assume responsibility for Safeguarding. 
  • Denise Hayden-Hawkins, the Learning Operations Manager will deputise in their absence and support as required. 

The team’s responsibilities include:

  • monitoring ACT Safeguarding enquiries
  • providing a first response to any incidents, disclosures or concerns
  • participating in the review of processes and procedures
  • providing updates and training to their delivery teams.

All reasonable efforts will be made to resolve a concern swiftly and informally if possible, and where appropriate. However, we appreciate that this may not always be possible or appropriate and therefore have the following process in place to deal formally with all complaints raised.


5.            Complaints process

a)            Stage One

In the first instance, the complaint should be made to the Director of Learning via email at using the ACT’s Safeguarding Complaint form available for download at the bottom of this page.

The complaint must include/cover:

  • your full name, contact details and ACT customer number, if applicable
  • what you think went wrong and how it has affected you, including details of your specific complaint(s)
  • the outcomes you are seeking from your complaint(s)

The Director of Learning will acknowledge receipt of the complaints within three working days and a full response will be forwarded within fifteen working days.

Within this timescale, the Director of Learning will do the following:

  • make all necessary and appropriate enquiries to establish the substance of the complaint* and any attempts already made to resolve the matter informally
  • initiate further discussions or meetings with the complainant if required, to fully understand their issue.


*As far as possible the confidentiality of the complainant will be respected, however, to investigate the concerns properly it may be necessary to gain consent for other individuals to be informed. The complainant may request anonymity, but this may affect the team’s ability to investigate the concerns.

If it is not possible to respond within fifteen working days, we will make contact again to advise when a response can be expected.

It is hoped that an acceptable resolution will be found and that the complaint can be resolved to the complainant’s satisfaction at this level.

b)            Stage Two

If the complainant is not happy with the proposed resolution of their complaint at stage one, then within ten working days of being notified of the proposed resolution they must inform the Director of Learning of their decision to initiate stage two.  The Director of Learning will notify the Director of Membership and Governance who will make the final decision and will:

  • acknowledge receipt of the stage two complaint
  • confirm when a response can be expected. The aim will be for complainants to receive a definitive reply within fifteen working days. If this is not possible because, for example, an investigation has not been fully completed, a further letter or email will be sent indicating when a full reply will be given
  • review all documentation and actions taken and, where necessary, seek any further clarification from the complainant
  • where necessary, take advice from such other professionals as may be required.

The reply to the complainant will inform of the action taken to investigate the complaint, the conclusions from the investigation, and any action to be taken as a result of the complaint. The Director of Membership and Governance’s decision shall be final.


6.            Complaint against an ACT member

In the event that a complaint raised under the Safeguarding Policy constitutes a potential breach of the ACT’s Ethical code by an ACT member, then the matter will be referred to the Director of Membership & Governance for investigation in accordance with the ACT’s Ethical Codes & Disciplinary Rules.  However, the Director of Learning will continue to investigate the complaint in accordance with this Safeguarding Policy.


7.            Complaint against an ACT employee

In the event that a complaint is raised against an employee under the safeguarding policy, then the matter will be referred to the Head of HR and Facilities for investigation in accordance with the ACT’s disciplinary rules.  However, the Director of Learning will continue to investigate the complaint in accordance with this Safeguarding Policy.


8.            Underpinning ACT’s Policies

The Safeguarding policy is underpinned by the below policies.



Download the ACT's Safeguarding Complaint Form


Scroll to top