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European Leaders Group (Trello)

Let's Do It - World Ethical Funding Policy

Last update: 25 Jan 2022

This policy follows two premises:

  • it applies to the World Cleanup Day project

  • it focuses on solving the plastic crisis

The aim is to create a document and work structure that can also be adapted to other projects in the network.

Save the brand. Stop greenwashing.

Language used in this document: American English

Wording used in this document: we use positive, inclusive wordings

I. Purpose and Core Elements

i. The four Core Elements

ii. “Owner of this agreement”

II. Collaboration:

i. Columns of collaboration: 6+1

A. Types of collaboration: 3x natural person

“Patron”

„Ambassador“

„Supporter“

B. Types of collaboration: 3x legal person

“Collaborator”

“Partner” (“Co-Organiser”)

“Funder”

C. Critical types of collaboration (+1)

ii. Principles of collaboration

1. Engagement by mutual trust

2. Conditions & Exclusions

3. Restrictions

III. Process

IV. Entry into force

V.Review

VI. Appendixes

Appendix 1: Ethical Screening Guidance

Appendix 2: Guidance for engagement with Mass Polluters (“+1 Group”)

Appendix 3: Decision-making process on how to become whitelisted

Appendix 4: Our Code of Fundraising

Appendix 5: Proclamation Agreement

Appendix 6:  Child Protection Policy

I. Purpose and Core Elements

Let’s Do It World (LDIW) is a global organisation and movement that tackles the environmental challenges related to the global mismanaged solid waste problem by mobilising millions of positive-minded people into coordinated local and global actions. Its mission is to connect and empower people and organizations to encourage change towards smarter choices in design, production, consumption and resource management.

The goal is to catalyze the positive change in societies toward a clean and waste-free world through raising awareness of the waste problem, organising local and global environmental actions and education programs. 

To influence this societal shift, Let’s Do It World brings people’s positive energies and mutual trust into all forms of cooperation and collaboration, Let’s Do It World NGO’s core values are people, cooperation and positivity. 

Let’s Do It World and the Let’s Do It country organizations seek and receive financial and material support from a range of sources: government, public and private foundations, organisations, individual donations and earned incomes. Let’s Do It World and Let’s Do It country organizations may also collaborate with for-profit organizations to achieve shared objectives. Let’s Do It World is open to opportunities for support  through funding and partnerships with organizations that share our purpose and our values. In all cases, it is vital that 

  • all actions are aligned with Let’s Do It World purpose and core values

  • independence as an organization is maintained. External organizations or individuals do not affect Let’s Do It World name or reputation. 

This policy provides the basis for any collaboration between LDIW and its member organisations with other organizations, individuals and social actors. It has been devised to ensure clarity and transparency to all stakeholders.

The policy is co-created by different LDI-related stakeholders to encompass multiple perspectives.

i. The four Core Elements

The policy for LDI is characterized by the following 4 core elements:

  • Fundamental protection of LDI to protect from greenwashing

  • Establishing a whitelist with organizations that support a waste free world  and willing to make their processes plastic-free

  • Establishing and calling on a committee to assess the integrity of any organization willing to support LDI (FTC)

  • Brand audits of potential partners with regard to the plastic poisoning potential

 

ii. “Owner of this agreement”

“LDI” is an umbrella term, encompassing “Let’s Do It World / LDIW” and all Let’s Do It country organizations and Let’s Do It chapters and other organizations that are an incremental part of the success of here meant activities. The term is not legally defined and is used as a reference for the future direction described in this policy.

“Let’s Do It World / LDIW” refers to the legally registered non-profit organization based in Estonia, and the adjoining organizational units, which should normally be explicitly mentioned.

“Let’s Do It country organization” refers to a legally registered non-profit entity representing Let’s Do It in any given country. The named entity does not have to have an “Let’s Do It”-reference in its name or be necessarily a member of “Let’s Do It World” with voting rights. 

“Let’s Do It chapter” refers to a local community group authorised to carry out here meant activities and campaigns. The use of the name “Let’s Do It”, of the corporate design and other “Let’s Do It”-related aspects are possible, but not mandatory, in order to be defined as such.

II. Collaboration: 

i. Columns of collaboration: 6+1

Interaction and collaboration knows many kinds of different faces. In general any LDI entity is supposed to also work with individuals, organizations and other socially relevant actors, as long as they remain consistently in line with the values and objectives of LDI.

As a citizens‘ movement, LDI also wants to show faces in its collaborations also. Therefore only persons and organizations can become collaborators who are willing to get involved by showing theirs. And also make their goals, behavior, processes and financing transparent.

There are two kinds of collaboration: on the one hand the collaboration with natural persons, on the other hand the collaboration with legal persons.

The following models are advised for those:

 

A. Types of collaboration: 3x natural person

LDI receives direct support from a natural person. The basic requirement for this is a specific face that is also made public. An active commitment to LDI is also a fundamental condition. Cash benefits and donations do not play an overriding role, personal commitment for the achievement of the LDI goals is decisive. LDI is allowed to reject any benefits and donations that are not in line with the given policies.

“Patron”

Patron refers to a person, especially from the political and societal environment, who represents the defined concerns of LDI in the public sphere and calls on the public to support them.

Example: Environment Minister, Chancellor, President of a non-profit organization

„Ambassador“

Ambassador is a person who is the face for a campaign or activity from LDI and is characterized by its active commitment within a defined framework and is available free of charge for national media inquiries, negotiations, events and campaign communication.

Example: celebrities, social media influencers, musicians, media personalities

„Supporter“

A supporter is an individual who is committed to the activities of LDI on site, who personally support them through their commitment or by freely given donation, equipment or services without expectation of anything in return.

B. Types of collaboration: 3x legal person

LDI receives direct support from a legal entity. A fundamental condition is an active commitment to LDI and consistently in line with the values and objectives of LDI.

“Collaborator”

Collaborators support LDI by communicating and activating their network and the public to join or support the activities of LDI. Collaborators do not join LDI activities by themself. 

Example:  Earth Day, Estonian Government, Cleanup Network, Allianz

“Partner” (“Co-Organiser”)

Partners support LDI by co-organizing specific LDI activities. LDI benefits from their activities directly. It’s based on a formal agreement or arrangement. Partners share the same values and objectives as LDI, which justify the mutual benefit of both parties resulting from this partnership. Partners support by payment in kind, not money. 

Example:  Plastic Soup Foundation, Break Free From Plastic, LDI members

“Funder” (“Donor”)

Funding means either monies, goods or services freely given by an organization without expectation of anything in return (beyond a receipt); these gifts may be unrestricted or restricted or grants, which are resources provided with a set of expectations and conditions attached that underline the values and objectives of LDI.

Example:  Fundings by European Union, Fundings by United Nations, national funding programs supporting a clean nature, grants from private institutions promoting LDI objectives

 

C. Critical types of collaboration (+1) 

Every legal person is a collaboration candidate and needs to go through a verification process to ensure that it is aligned with the values and objectives of LDI. Aim of this process is to provide clear guidelines on how to work with other organizations based on the defined ESG-standards of LDI. Organizations identified as positive for collaboration in accordance to the LDI standards are recorded in a whitelisting. If a collaboration candidate becomes whitelisted he may be sorted into one of the aforementioned types of collaboration. In case a collaboration is allowed, continuous monitoring and evaluation will be necessary to avoid any deviation in the course of this collaboration.

A collaboration with a candidate not being whitelisted is not possible. LDI can give guidance to those organizations to improve their sustainability processes.

Natural persons are generally excluded from this.

ii. Principles of collaboration

1. Engagement by mutual trust

LDI actively solicits relationships with organizations that act to safeguard the environment in a positive, inclusive, transparent and non-violent way.The partnerships are entered into out of free will. We seek for collaborations, as far as it is practical and within the constraints of local law, donations, sponsorships and partnerships, that: 

  • are compatible with LDI’s values and objectives; 

  • do not compromise the independent status of LDI; 

  • will not damage the reputation of LDI;

  • foster openness and transparency; and 

  • attain mutually beneficial outcomes; 

While LDI practices avoidance when it comes to funding from certain organizations, it does not preclude working with these organizations, if  they are committed to making concrete changes to their policies and practices. Collaborations of this nature will be considered on a case by case basis, and any organization that is felt to be lacking commitment, “greenwashing”, or directly working against our aims will be declined. Practical guidance can be found in Appendix 2. 

LDI has refused and will continue to refuse to accept donations, sponsorships or partnerships with:

  1. organizations whose activities, policies, aims, values or objectives clearly contradict or compromise LDI’s, 

  2. organizations, including charitable foundations or trusts, that are owned and / or substantially funded by any organization included in point 1.

Accepting funds from these sources is not in interests of LDI, due to the following risks: 

  1. it may promote inaccurate or misleading messages about our commitment to our goals and values 

  2. it may damage our reputation and cause the loss of support and trust earned from our volunteers and other stakeholders. 

  3. it undermines our effectiveness in achieving our objectives 

These risks far outweigh the benefits that any such funding may bring. But the principle described shall also apply in the case of partnerships where LDI receives no income.

 

2. Conditions & Exclusions

LDI are not permitted to accept monetary donations, monetary sponsorship or engage in any form of monetary or income-generating collaborations with not whitelisted organizations. In the case of offers for financial or national or international support, this must be subjected to the process used here. 

The overall goal is to protect the LDI network as a whole, and to find a way to decide about future collaboration together and on a global level.

The mentioned process and its committees can be found in C. and in Appendix 3.

3. Restrictions

Fundraising or collaborative activity can only be initiated by a LDI country organization with other organizations located within its territory. Fundraising or collaborative activity can only be initiated by a Let’s Do It country organization outside of its territory with the prior consent of the country organization in which the activity is to take place, or with the prior consent of the LDIW in case of transnational and international fundraising or collaborations.

III. Process

  1. All organizations and (if applicable) the proposed terms of any collaboration will be screened by a FTC according to the criteria set out in Appendix 1. 

  2. Any not whitelisted collaboration candidate will be flagged for further consideration. This may include independent checks through an ethical screening service. 

  3. These not whitelisted collaboration candidates, and all partnerships, sponsorships and donations involving commercial organizations, must be reported to and approved by the LDIW Board. 

  4. All approved collaborations shall be based on a written agreement. In addition to detailing the support offered by both parties; contact persons on both sides; the outcomes / outputs expected; how the agreement will be monitored and enforced; and if, when and how progress reports will be provided, the agreement should contain the following terms:

    1. Any communications used by the concerned organization, including but not limited to papers, marketing material, advertisements and packaging, shall be reviewed and reviewed and approved by LDIW. 

    2. Use of the LDI name, logo or any other intellectual property in publicity material in any medium, must be approved in advance by LDI. 

    3. Unless explicitly agreed, there shall be no endorsement, branding or promotion of products or the companies concerned. 

    4. LDI shall be permitted to withdraw from any agreement in case of changes with high risk of breaching this ethical funding policy.

IV. Entry into force

The Let’s Do It World Ethical Funding Policy Framework will be confirmed by the LDIW Board and enter into force at the time of its approval by the General Assembly of LDIW.

V.Review

LDI will communicate its commitment to this policy to its stakeholders, and make it publicly available. The policy will be reviewed every two years by the LDIW board as long as no adjustments are necessary.

 

VI. Appendixes

Appendixes are like Implementing ordinances or rules of procedure.

  1. Ethical Screening Guidance

  2. Guidance for engagement with Mass Polluters (“+1 Group”)

  3. Decision-making process on how to become whitelisted

  4. Appendix 4: Our Code of Fundraising

  5. Proclamation Agreement

  6. Child Protection Policy

 not defined at the moment

  • FTC – fundraising trustee committee

  • Dealing with trademark rights, 

  • Process, Sources and Structure of a Brand Audit, 

  • Data collection and data protection

  • Greenwashing awareness and trainings

  • How to find whitelisted organizations?

Appendix 1: Ethical Screening Guidance 

The aim of the efforts is a comprehensive whitelist that is constantly checked and grows. Any facility that meets the ethical criteria of this policy can be whitelisted nationally and globally. The FTC regularly checks, advises and recommends to the general assembly of LDIW organizations that are to be whitelisted or not to be listed.

Members of the FTC do not consist of functionaries and those responsible from the supporting organization, e.g. LDIW!

Our initial risk assessment will examine the following: 

  1. If the organization is part of a larger group

  2. If, how and to what extent the activities of the organization conflict with or support our own mission and / or policies 

  3. The size and source of the funding

  4. The size and reach of the organization 

  5. Any expected benefit to LDIW, in additions to funds received 

  6. The organization’s motives for giving (actual and perceived) 

  7. Any conditions imposed by the organization (e.g. on the use of funds or the expected acknowledgment) 

  8. The reputation of the organization in all LDI countries of operation 

  9. If acceptance of funds is likely to significantly impact current or future support from our volunteers, other donors etc. contrary to the herementioned values and objectives

  10. If the relationship will create any conflicts of interest or unauthorised benefit to connected parties 

  11. If the relationship requested is exclusive or designed to give the organization a material advantage over its competitors For all potential partner, donor or sponsor organizations, we will carry out standard due diligence (a review of publicly available information) and, if appropriate, further investigation via an independent ethical screening service such as the Corporate Critic Database. 

Further, LDI will exercise caution with any funding offered by the following categories of organizations (not conclusive): 

 

  • producers of virgin plastic and their subsidiaries

  • any other manufacturer of single-use goods made from or packaged in virgin plastic

  • Any regional, national or multinational chain retailer producing and / or stocking and distributing large quantities of single-use plastic

  • packaging companies

  • manufacturer or seller of recycled plastic (packaged) goods

  • FMCG (fast moving consumer goods), fashion and furniture companies, multinational corporations and their brands

  • producers of any kind of products making intense use of plastic

  • Landfill management or incineration facilities including companies that operate waste-to-energy, waste-to-fuel, gasification, pyrolysis, or any other type of “energy recovery” or “chemical recycling” facility. 

  • Fossil fuel companies, any company involved in fracking or the extraction of shale gas, coal, oil or natural gas. 

  • Foundations or trusts belonging to or substantially funded by any of the companies in categories; foundations that receive their funding from plastic bag taxes or similar. 

 

Appendix 2: Guidance for engagement with Mass Polluters (“+1 Group”)

LDI remains open to work with any organization that shows real commitment and proves it by their actions to really change their business policies and practices. Any organization not having passed the +1 process should not fund any kind of LDI activity. Nevertheless, LDI can remain in communication with the organization concerned and support the clean and sustainable orientation of the organizational activities.

For example, we may, subject to the standard risk assessment, consider working with organizations identified in Appendix 1 under the following circumstances: 

 

  1. They join our activities as “invisible” corporate volunteers

    1. their staff join a cleanup without any company banners, shirts or other corporate branded items

    2. they do not use the event or our name to promote their green credentials (e.g. in a CSR report or other marketing material) 

    3. any donation is provided in kind only and at the organisational level (e.g. t-shirts, waste free refreshments) with standard acknowledgment from our side and no additional promotion. 

    4. any publicity material they share on social media and media has to be mutually agreed on with LDI.

 

  1. They engage in education about, or finding solutions for, plastic pollution and their role in it 

    1. They take part in a brand audit or other type of waste audit 

    2. They engage LDI to deliver speeches, trainings, workshops or other educational activities for their employees and/or stakeholders 

    3. They engage LDI as advisors to consult on issues of reducing waste, design plastic waste free product life cycles and improve their praligned to LDI’s standards. 

Appendix 3: Decision-making process on how to become whitelisted

Every potential collaborator must first go through a quick check in order to make them classifiable according to the categories described here. This quick check consists of six questions and can be done by anyone who can assess the organization.

If the process ends with the approval of the potential collaborator, he will be added to the for LDI visible whitelist. 

If the result is negative, the potential collaborator enters the verification process „+1“.

The core element of the +1 process is the review of the potential collaborator by a professionally experienced, critical body, the Fundraising Trustee Committee (FTC).

Task of the FTC (which is fluent and ad hoc, based on each person’s competency, and NOT a stable „board“-like body) is to build up a short and clear report on the requesting organization with references to their recommendation. This report will be published to the holders of this agreement and validated by a vote on it, if necessary. 

All reports will be transparently documented. 

Quick Check for Collaboration (Process)

  1. Online Test Form: WCD Collaboration Funnel – World Cleanup Day

  2. Fill out the „Quick Check for Collaboration“ below to find out whether your collaboration candidate is suitable for our network.

  3. If No whitelisting approved

  4. Next step: Consult FTC (fundraising trustee committee) write a E-Mail to ethics-validation@worldcleanupday.de 

Details: 

https://prezi.com/i/w_uuheewomqf/wcd-collaboration-funnel/

Interaction and collaboration knows many kinds of different faces. In general any LDI entity is supposed to also work with individuals, organizations and other socially relevant actors, as long as they remain consistently in line with the values and objectives of LDI. 

In order to check whether a collaborator is in line with our own values and goals before the first contact is made, answer the following questions of our „Quick Check for Collaboration“ in advance.

process landscape:

Process landscape online version:

https://www.yworks.com/yed-live/?file=https://gist.githubusercontent.com/worldcleanupday/23856709d2e7d1757bcaa5688ea722d2/raw/61819254257eb56e1cec3553aa34a07de8becabe/WCD%20Collaboration%20Funnel%2004052021

LDIW reports according to agreed contracts and requirements transparently and honestly to its funders. A biannual report on partnerships and financing will be published on the Let’s Do It  World’s official website

Professional support from qualified and tested partners in decision-making is permitted, but requires legitimation by the members of LDI, analogous to the FTC’s committee members. Complete transparency and traceability of the decision-making process is imperative and does not require any additional justification.

 

Appendix 4: Our Code of Fundraising

Ethical fundraising practices 

This sets out the way in which LDIW will carry out fundraising as an organization: 

  • All requests for funds will be honestly reflect available facts and be put forward with sincere intentions:

    • they will accurately describe our work 

    • they will accurately describe the intended uses and destinations of the donation (if applicable) 

    • they will not encourage unrealistic expectations of what the gift will achieve 

  • Donations will be used to support our published mission and will be in line with the purpose for which they are solicited 

  • Spending on fundraising and administration will be kept as low as is cost-effective 

  • Our accounting and accountability will comply with the highest legal, accounting and ethical standards and be fully transparent     

    • We will regularly report on our financial activities 

    • We will make clear the percentage of income spent on raising funds 

    • We will make clear the percentage of income spent on administration 

  • All personal data will be held securely and in compliance with locally and internationally prevailing Data Protection legislation (for LDI organisations in EU based on EU Data protection regulations) and donors’ privacy will be respected and safeguarded at all times. 

  • Donors’ requests to remain anonymous externally will be respected as far as is legally, practically and ethically possible 

  • Fundraisers will cease solicitation of a prospective donor immediately on request 

  • Fundraisers will disclose any conflicts of interest that may arise

  • We will not pay any fundraiser a finder’s fee or commission-based fee

  • No selling of Data

  • Marketing activities: Materials do not include anything and language or pictures that could be rassistic, sexistic or lead to religious or cultural intollerance.

  • As much as paper free as possible -> digital way

  • If a donor doesn’t want to receive any materials anymore this will be accepted by LDIW

  • No money from political parties are accepted 

Appendix 5: Proclamation Agreement

If you want to become a partner, first sign this document.

If he does not sign, we “almost” know that whitelisting is impossible

Example:

World Cleanup Day (WCD)

Proclamation Agreement

The „World Cleanup Day (WCD)“ is a project of the citizens‘ movement „Let’s Do It World ”, which was created in Estonia in 2008, when 50,000 people worked together to rid the entire country of illegally disposed trash in one day. In 2019, 21 million people worldwide took part in the “WCD”. With their cleanups they set a strong example for a clean, healthy and plastic-free world.

Our common goal is to activate at least 5 percent of the population on World Cleanup Day and to sensitize decision-makers, business and politics to the problem of plastic pollution on our earth through their commitment.

Every 3rd Saturday in September

let’s cleanup for 2 hours

and that once a year.

Together with the whole world

We thereforewe therefore call for World Cleanup Day!

– represented by – 

expresses its interest in supporting World Cleanup Day with its worldwide visibility through marketing measures. A benevolent interpretation of the agreed commitment with a view to achieving the goals of the World Cleanup Day is assured at all times.

The caller’s role is to proactively promote World Cleanup Day by publishing calls to participate in WCD to a broad population within the caller’s access area. These are aimed at increasing visibility, reach and social participation on the World Cleanup Day. Concrete contents are to be agreed with the organizers of the WCD. In principle, the following framework is recognized as fundamental:

  • All activities and statements carried out in the context of the WCD support the visibility of the WCD.

  • The calling party undertakes to actively advertise the WCD in its own online and offline media channels and to make it visible.

  • Necessary media materials and templates for further use in the named context will be made available if required.

  • The WCD is a stand-alone brand. Merging or contextualising with other word-image trademarks is strictly prohibited and must be avoided at all points.

  • All activities under this agreement focus on the following messages:

  • Communication of the date of the WCD,

  • Call for active participation in the WCD (5% target),

  • Mention of the official website for the WCD worldwide www.worldcleanupday.org,

  • Use of the hashtag #worldcleanupday in the social media posts affecting the content of the WCD.

  • Media inquiries that are sent to the caller within the framework of the WCD must be coordinated with the organizers of the WCD and made available for further use.

  • Media data on the postings and publications are to be made available to the organizers of the WCD afterwards for their knowledge.

Signature of the person responsible for the calling organization

Appendix 6:  Child Protection Policy

LDI values children and young people as being a vital part of our movement and desires to see them learn and fulfil their potential in a healthy and safe environment. LDI also has a strong commitment to family and whole community action and, wherever possible, ensures its program delivery is inclusive, with a parent, carer or teacher also participating, in a direct supervisory role for any children.

While LDI representatives (staff or volunteers) are therefore unlikely to be in situations where they are directly responsible for children or young people, we recognise our general responsibility to safeguard the welfare of all children and young people who participate in our programs, by committing to the following policy and practice which protects them. We believe that it is always unacceptable for a child or young person to experience abuse or neglect of any kind.

This policy is based on the following principles:

  • The welfare of the child/young person is paramount

  • All children, regardless of age, ability, gender, racial heritage, religious belief, sexual orientation or identity, have the right to equal protection from all types of harm or abuse

  • Working in partnership with children, young people, their parents, carers and teachers is essential in promoting their welfare.

The purpose of this policy is:

  • To provide protection for the children and young people who participate in LDI activities worldwide, including the children of adult volunteers.

  • To provide staff and volunteers with guidance on procedures they should adopt while children are in their care.

This policy applies to all staff, including senior managers and the board of trustees, paid staff, volunteers, interns or anyone working as a representative of LDI.

We seek to “do no harm” to children and young people by implementing the following code of conduct:

PHYSICAL SAFETY

  • Cleanup and other activity sites must be assessed for risk and potential dangers for children, e.g. steep drops, open water etc.

  • All activities should be age appropriate, avoiding excessive physical exertion, and held during daylight hours

  • Children and their carers must be warned of potential hazards while carrying out activities, e.g. finding glass or sharp objects when cleaning, and that these must be handled by an adult

  • Good hygiene standards need to be met: gloves and anti-bacterial hand-wash as a minimum at cleanups

  • There must be adequate provision for first aid and agreed procedures for emergency medical assistance

  • No children under 16 should be left unattended at any time

PERSONAL SAFETY

  • LDI will request the presence of parent, carer or teacher with direct supervisory responsibility at all activities at which a child attends

  • Children who nonetheless attend activities without the presence of a parent, carer or teacher must provide written parental consent, and emergency contact number(s)

  • All LDI activities will be carried out in an open, public environment, with more than one adult present, not in any private or unobserved situations

  • LDI representatives will not allow or engage in suggestive remarks, gestures or touching which could be misunderstood

ONLINE SAFETY

  • Children and their parents / carers must give explicit permission for their images and / or names to be used for LDI`s own or any other media channels

  • Images of children used in, or released to, any channel must not show them in states of undress or in inappropriate poses

  • Details attached to images and included in stories must not allow that child to be identified or traced to his or her home

EMOTIONAL & SPIRITUAL WELLBEING

  • LDI will work together with parents, children and their communities to create a safe, friendly and accessible environment for their activities

  • All children who participate will be treated with equal concern, respect and dignity, with no favouritism

  • LDI representatives will seek to be excellent role models, provide enthusiastic and constructive feedback to reinforce positive behaviour, and avoid any criticism of children, their communities or culture

  • LDI representatives will similarly not punish or negatively discipline any child by physical or verbal means for any reason; reasonable and calm intervention is acceptable in cases where a child’s safety is in question

LDI will ensure this code of conduct is adopted by

  • Recruiting staff and volunteers safely, ensuring checks are made / references obtained where possible

  • Communicating our values and expected conduct to all volunteers and staff

  • Providing on-going support, training and supervision for all volunteers and staff

  • Ensuring that the child protection policy informs program design

  • Responding quickly to any concerns or allegations of misconduct raised from within, and externally

We are also committed to annually reviewing our policy and best practice.

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