Safeguarding Policy

1. Purpose and Commitment

The Climate Energy and Livelihoods Initiative (“the Association” or “CELI”) delivers climate and energy education in schools, community training, and other programmes that bring its representatives into contact with children and with adults who may be at risk. The Association recognises that this contact creates a duty of care.

The Association is committed to the principle that the welfare of the child or adult at risk is paramount, and that this principle overrides every other consideration, including the reputation of the Association, the convenience of a programme, or the interests of any trustee, employee, volunteer, partner, or funder.

All forms of abuse and exploitation are unacceptable. The Association has a zero-tolerance position on sexual exploitation and abuse, physical or emotional abuse, neglect, and the exploitation of any person the Association works with or on whose behalf it works.

2. Scope

This Policy applies to every person acting for or on behalf of the Association, without exception:

• Trustees and members of the Board.
• Employees, whether full-time, part-time, or temporary.
• Volunteers, interns, and contributors.
• Consultants, contractors, suppliers, and their personnel where they attend Association programmes or premises.
• Partner organisations and their personnel when delivering activities jointly with the Association.
• Any other person authorised to represent the Association at any activity.

Adherence is a condition of appointment or engagement. Every person within scope must read this Policy, sign an acknowledgement, and comply with it in full.

3. Definitions

Child. Any person under the age of 18 years, in line with the Child's Rights Act 2003.

Adult at risk. Any person aged 18 or over who, by reason of disability, illness, age, or circumstance, is less able to protect themselves from harm or exploitation.

Safeguarding. The action the Association takes to prevent harm to children and adults at risk arising from its work, and to respond appropriately where harm is suspected, alleged, or disclosed.

Abuse. Includes physical abuse, emotional abuse, sexual abuse and exploitation, neglect, financial exploitation, and any conduct causing a child or adult at risk harm or distress.

Safeguarding concern. Any information, observation, allegation, or disclosure suggesting that a child or adult at risk has been, is being, or is at risk of being harmed, whether or not the harm is connected to the Association.

4. Guiding Principles

• The welfare of the child or adult at risk comes first, always.
• Every child has an equal right to protection, without discrimination on any ground.
• Prevention is better than response. The Association designs its programmes to reduce risk before it arises.
• Everyone has a responsibility to report. Safeguarding is not the job of one person.
• Concerns are acted on, not weighed against the Association's reputation.
• Reports are handled confidentially, on a strict need-to-know basis.
• No person is penalised for reporting a concern in good faith.

5. Code of Conduct

5.1 Every person within scope must

• Treat all children and adults at risk with respect and dignity.
• Plan and organise work so as to minimise risk, including by working in open, visible settings.
• Ensure that another adult is present or within sight during activities involving children.
• Challenge and report any behaviour by any person that breaches this Policy, regardless of that person's seniority.
• Report every safeguarding concern immediately, in accordance with section 8.

5.2 Every person within scope must never

• Be alone with a child. All activities involving minors are supervised by the Executive Director or another designated programme lead.
• Engage in any sexual activity or sexual relationship with a child, irrespective of any local law, custom, or claim as to age of consent. Mistaken belief about a child's age is not a defence.
• Engage in any exchange of money, employment, goods, services, or assistance for sex or sexual favours with any person. This applies to every beneficiary and community member, adult or child, and applies absolutely.
• Hit, physically assault, or physically discipline a child, or use language or behaviour that is inappropriate, harassing, abusive, sexually provocative, demeaning, or culturally insensitive.
• Take photographs or video of a child except on the Association's equipment and with documented consent under section 7.
• Collect or retain the personal contact details of a child, or contact a child outside programme activities, including through social media or messaging applications.
• Offer a lift, accommodation, or gift to a child other than as part of a documented programme activity approved in advance.
• Use the Association's equipment, premises, or connectivity to access, produce, or distribute material that sexually exploits or abuses children.

Breach of section 5 results in immediate suspension pending investigation and, where established, termination of the engagement, in addition to any referral to the police or other lawful authority.

6. Safe Recruitment and Induction

The Association applies the following controls to every person who will have contact with children or adults at risk:

• Volunteers must be aged 18 years or over.
• Every applicant completes an application or expression of interest and provides at least one referee or a means of identification where requested.
• Every prospective trustee, employee, and volunteer declares that they have no record of offences against children or vulnerable persons, and consents to a safeguarding check.
• Every person within scope signs this Policy, or the Volunteer Agreement incorporating it, before commencing any activity.
• Every person within scope completes a safeguarding induction covering this Policy, the code of conduct, and the reporting route, before first contact with children.
• The safeguarding briefing status of each volunteer is recorded in the Volunteer Register.

No person may commence an activity involving children until the requirements above are complete and recorded.

7. Images, Media, and Data

The Association photographs and films its programmes for reporting, education, and communications. The following rules are mandatory:

• No image, video, or audio recording of a child may be captured without a signed Media Consent Form from the parent or legal guardian, and, where the activity is held at a school, the written authorisation of the school.
• Consent is specific and informed. The person consenting is told where the material may appear and for how long, and consent may be withdrawn at any time.
• A child's assent is sought in addition to guardian consent. A child who does not wish to be photographed is not photographed, regardless of guardian consent.
• Images are captured only on the Association's equipment. Personal devices may not be used.
• Images must portray children with dignity and respect, in appropriate dress, and never in a manner that is sexualised, degrading, or that emphasises vulnerability for effect.
• The Association does not publish the full name, school, address, or any contact detail of a child alongside their image. First name only, where a name is used at all.
• Images are stored securely on Association-controlled storage with access restricted to Editor-level accounts, and are retained only as long as the consent permits.
• Where consent is withdrawn, the material is removed from the Association's website and channels within a reasonable period, and is not reused.

Existing material. Any image or footage of an identifiable child already held or published by the Association must have a signed Media Consent Form obtained retrospectively, or be removed from publication. No further content featuring identifiable children is published until consent is on file.

Personal data of children and of adults at risk is processed in accordance with the Nigeria Data Protection Regulation and the Association's data protection policy, on a lawful basis, minimised to what the programme requires, and never shared with a third party without consent or lawful authority.

8. Reporting a Concern

Anyone who witnesses, suspects, or receives a disclosure of a safeguarding concern must report it. Reporting is mandatory, not discretionary, and applies whether the concern involves a person within scope, a partner, a family member, or any other person.

8.1 Immediate steps

• Ensure the child or adult at risk is safe. If there is immediate danger, contact the police or emergency services first.
• Do not investigate, question the child, or attempt to verify the allegation yourself.
• Do not promise confidentiality to the person disclosing. Explain that the information must be passed on to keep them safe.
• Record what was said and observed in the words used, as soon as possible, and keep the record secure.
• Report to the Designated Safeguarding Lead the same day, and in any event within 24 hours.

8.2 Reporting route

Designated Safeguarding Lead: the Executive Director, Jennifer Ugwueze, jennifer@celi.org.ng.

Where the concern involves the Designated Safeguarding Lead, or where the person reporting considers it inappropriate to report to her, the report is made instead to the Chairman of the Board of Trustees, Peter Banigo, peter@celi.org.ng.

Where the concern involves both, the report is made to any other trustee, who brings it to the Board.

A report may be made in person, by telephone, or by email. Reports made in good faith are protected; no person will be penalised, dismissed, or disadvantaged for making one, even if the concern is not ultimately substantiated. Deliberately false or malicious reports are treated as misconduct.

9. Responding to a Concern

• The Designated Safeguarding Lead records the concern in the Safeguarding Incident Register within 24 hours.
• The Lead makes an immediate assessment of risk and takes any step necessary to protect the child or adult at risk, including suspending the person concerned from all activities pending the outcome.
• Where the concern discloses a possible criminal offence, the matter is referred to the Nigeria Police Force. The Association does not substitute its own process for a criminal investigation.
• The Chairman of the Board is informed of every concern. The Board is informed of every substantiated concern and of any referral to authority.
• Where a funder's grant agreement requires notification, the Lead notifies the funder within the period specified in that agreement.
• The outcome, the actions taken, and the lessons identified are recorded and reported to the Board at its next meeting.
• Records are kept confidentially and securely, accessible only to the Lead and the Board.

10. Roles and Responsibilities

10.1 The Board of Trustees

• Owns this Policy, adopts it, and reviews it at least annually.
• Appoints the Designated Safeguarding Lead and ensures the role is resourced.
• Receives reports on every substantiated concern and satisfies itself that the response was adequate.
• Ensures safeguarding is considered in programme design, budgeting, and partner selection.

10.2 The Designated Safeguarding Lead

• Is the first point of contact for all concerns.
• Maintains the Safeguarding Incident Register and the consent records.
• Ensures every person within scope is briefed and has signed an acknowledgement.
• Ensures activities involving children are adequately supervised.
• Reports to the Board and, where required, to funders and to lawful authority.

10.3 Everyone within scope

• Complies with the code of conduct in section 5.
• Reports every concern immediately under section 8.

11. Partners, Schools, and Contractors

• Every partner organisation delivering activities jointly with the Association is required to have its own safeguarding policy of an equivalent standard, or to sign up to this one.
• Where a programme is delivered in a school, the Association obtains the school's written authorisation and complies with the school's own safeguarding requirements in addition to this Policy.
• Safeguarding obligations are written into partnership agreements, contracts, and grant sub-agreements.
• A partner's failure to meet these obligations is grounds for suspension or termination of the arrangement.

12. Training and Awareness

• Safeguarding induction is mandatory before first contact with children and is repeated at least annually.
• This Policy is provided to every trustee, employee, and volunteer, and is published on the Association's website.
• The reporting route is displayed at every programme activity involving children.
• Children and communities are told, in terms they can understand, what behaviour they may expect from the Association's representatives and how to raise a concern.

13. Records and Review

• The Association maintains a Safeguarding Incident Register, a record of signed acknowledgements, and a record of media consents.
• Records are retained securely and confidentially in accordance with the Nigeria Data Protection Regulation.
• This Policy is reviewed by the Board at least annually, and immediately following any safeguarding incident or material change in the Association's programmes.
• The Association discloses this Policy and its safeguarding record to funders during due diligence.

14. Relationship with Other Policies

This Policy is the Association's primary safeguarding instrument. The safeguarding provisions of the Volunteer Policy and Volunteer Agreement are subordinate to it and are to be read consistently with it. Where any inconsistency arises, this Policy prevails.

15. Adoption

This Safeguarding Policy was adopted by resolution of the Board of Trustees of the Climate Energy and Livelihoods Initiative, and takes effect from the date of adoption.

Adopted by resolution of the Board of Trustees of the Climate Energy and Livelihoods Initiative on 27 July 2026.