Group Safeguarding and Prevent Policy​ and Language in Action Addendum

Language in Action: Safeguarding & Prevent Operational Implementation Addendum

This addendum is an operational implementation schedule subordinate to and governed by the Malvern International PLC Group Safeguarding & Prevent Policy (v2.0). It does not create a separate or independent safeguarding framework. Group-level accountability, governance and escalation routes remain as set out in the main policy. Central oversight by the Group Safeguarding & Prevent Coordinator and the COO (Executive Sponsor) applies to all activities covered by this addendum.

1. Purpose and Scope of This Addendum

Language in Action (LIA) operates summer residential and day centres across multiple locations in England. The seasonal nature of LIA operations, the engagement of temporary and seasonal staff, and the fact that all participants are under the age of 18 create specific operational safeguarding requirements that complement the Group Safeguarding & Prevent Policy.

This addendum sets out how the Group policy is implemented operationally across LIA summer centres. It provides:

• Named DSL and Deputy DSL designations at centre level, with confirmation of training status
• LADO contact details mapped to each operating borough
• Confirmation that the LIA Single Central Record meets the Group standard
• Confirmation of training log completeness for seasonal staff
• The escalation chain from centre level to Group oversight
• Centre-specific operational protocols for welfare, disclosures and absence

This addendum must be completed and co-signed before each summer season opens. It must be made available to all LIA staff, the Group Safeguarding & Prevent Coordinator, and the COO. It will be reviewed as part of the Group’s annual policy review cycle each September.

2. Governance and Central Oversight

LIA safeguarding sits within the Group safeguarding governance framework. The following governance principles apply throughout the summer season and are non-negotiable:

• The COO acts as Executive Sponsor for safeguarding across all Group operations including LIA. This does not change during the summer season.
• The Group Safeguarding & Prevent Coordinator provides oversight of all LIA safeguarding activity, receives regular reports from LIA DSLs, and is the escalation point above centre level.
• All DSLs and Deputy DSLs named in this addendum are appointed under the Group policy framework. Their authority derives from that framework, not from this addendum.
• The Group safeguarding inbox (safeguarding@malvernplc.com) remains active and monitored throughout the summer season. LIA centre staff may use this route in addition to direct DSL contact.
• No safeguarding decision that meets the referral threshold (LADO, MASH, police, children’s social care) may be taken at centre level without notifying the Group Safeguarding & Prevent Coordinator and the COO. They are both informed immediately. Once the internal escalation has taken place, the DSL makes the referral.

2.1 Managing Director ELT — Safeguarding Responsibilities

The Managing Director ELT holds operational accountability for the implementation of this addendum across all LIA summer centres. They are also the Designated Safeguarding Lead for the LIA division. Specific responsibilities include:

• Ensuring all DSL and Deputy DSL appointments named in Section 3 are confirmed, trained, and have KCSIE 2025-compliant job description clauses before centres open.
• Ensuring the LIA Single Central Record is complete and signed off before the season opens, in liaison with the HR manager.
• Ensuring all seasonal staff complete Level 1 safeguarding induction before they work with students.
• Receiving and reviewing safeguarding summary reports from the Group Safeguarding & Prevent Coordinator during the season.
• Escalating any systemic safeguarding concern to the Group Safeguarding & Prevent Coordinator and the COO without delay.

In the absence of the LIA Managing Director, these responsibilities are to be covered by the Group Safeguarding & Prevent Coordinator, supported by the Head of Juniors and the COO.

3. Named DSL and Deputy DSL Designations — Summer 2026

In accordance with KCSIE 2025, a Designated Safeguarding Lead must be available in person or by telephone at all times when students are on site. For LIA summer centres, this means a named, trained DSL or Deputy DSL must be identifiable and contactable for every centre, every day, throughout the season.

Deputy DSLs must be trained to the same Level 3 standard as the DSL and must have a job description containing the KCSIE 2025-compliant safeguarding clause. The safeguarding clause must be inserted into each job description before the individual commences work. In each centre a DDSL cover is present and trained at level 3.

Note: A person cannot act as DSL or Deputy DSL unless they hold current Level 3 safeguarding training, their job description contains an explicit safeguarding responsibility clause, and they are named in this addendum.

3.1 Group Safeguarding & Prevent Coordinator (Group Oversight)

3.2 Named DSLs and Deputy DSLs by Centre

3.3 Out-of-Hours DSL Cover

A DSL or Deputy DSL must be reachable outside normal teaching hours for the duration of the programme, including evenings, weekends and UK bank holidays.

3.3.1 Definition of Out-of-Hours

• Weekdays: 18:00 to 09:00 the following morning
• Weekends: continuous from Friday 18:00 to Monday 09:00
• UK bank holidays falling within the programme dates: 24 hours

3.3.2 Centre-Level Cover — Two-Tier Model

Each LIA centre operates a two-tier Deputy DSL cover model for out-of-hours: Tier 1 is the on-rota Deputy DSL; Tier 2 is the Cover Deputy DSL. The Cover Deputy DSL is activated when the on-rota Deputy DSL is off-rota or does not respond within the SLA.

3.3.3 Centre Welfare Staff On Site

All LIA Summer 2026 centres are residential. Each centre has a designated welfare staff member on site. Welfare staff provide physical presence with students out-of-hours and report operationally to the on-rota Deputy DSL. Welfare staff are not designated DSLs.

3.3.4 Contact Channels

• Each centre operates a dedicated safeguarding phone line, active 24 hours, 7 days a week.
• The number is published to all centre staff at induction, displayed at reception and front-of-house, and provided to students aged 16 in welcome packs.
• WhatsApp may be used only as a supplementary channel for non-urgent communication. Urgent concerns must be initiated by phone call.

3.3.5 Response Time SLA

• Urgent: within 15 minutes of first contact attempt.
• Non-urgent: within 60 minutes of first contact attempt.

3.3.6 Out-of-Hours Escalation Flow

1. Tier 1 — On-rota Deputy DSL
2. Tier 2 — Cover Deputy DSL
3. Tier 3 — LIA Managing Director (DSL)
4. Tier 4 — Group Safeguarding & Prevent Coordinator
5. Tier 5 — Chief Operating Officer

3.3.7 Edge Case — Both Centre Deputy DSLs Unreachable

• Contact the LIA Managing Director directly.
• If there is immediate risk to life or physical safety, call 999 first.
• Document the failure of Tier 1 and Tier 2 cover.

3.3.8 Documentation

All out-of-hours concerns and disclosures must be logged immediately by the on-rota Deputy DSL.

3.3.9 Items to be Confirmed Before Centres Open

• Per-centre welfare staff identification
• Morning handover protocol
• Group sign-off on use of WhatsApp
• COO cover arrangements

3.4 Centre Safeguarding Monitoring

The LIA HO co-lead has a monitoring and supervisory function in relation to safeguarding across designated centres, reviewing anonymised weekly safeguarding summaries to monitor themes and patterns.

4. LADO Contact Mapping by Operating Borough

Where an allegation is made against a person who works with children and the allegation meets the harm threshold, the LADO must be contacted within one working day.

5. LIA Single Central Record (SCR)

All individuals working with students at LIA summer centres must appear on the LIA Single Central Record before they commence work.

• Identity check confirmed
• Enhanced DBS check date obtained
• Children’s barred list check confirmed
• Prohibition from teaching check date
• Section 128 direction check date
• Right to work check date
• Overseas criminal records check where applicable
• References date received and from whom
• Date commenced in post

5.1 SCR Ownership and Location

5.2 SCR Pre-Season Confirmation

6. Safeguarding Training — LIA Staff

All LIA staff must be familiar with the Group Safeguarding Policy and this addendum and must complete safeguarding training appropriate to their role before working with students.

6.1 Training Requirements by Role

6.2 Training Log — Pre-Season Confirmation

7. Centre-Level Operational Protocols

The following protocols set out how the Group policy is applied operationally at LIA centre level during the summer season.

7.1 Daily Welfare and Safeguarding Check

Every student under 18 must be accounted for at least once per day, every day of the programme including weekends and bank holidays. The Daily Welfare and Safeguarding Check is performed once per day at end of day, consolidating inputs collected throughout the day.

Teachers record class attendance, Campus Coordinators run roll-calls and head counts, and Tour Coordinators manage excursion head counts. The Centre Manager consolidates all inputs into the Daily Welfare Log.

Any student whose status cannot be verified triggers the Missing and Unaccounted Student Policy timeline immediately.

7.1.5 Excursion Days — Ad Hoc Procedure

On excursion days, the Tour Coordinator is the accountable consolidator. Head counts take place at departure, arrival, before and after group splits, and on return. Any missing student triggers the Missing and Unaccounted Student Policy Section 5.A timeline immediately.

7.1.6 Daily Welfare Log

The Daily Welfare Log is maintained as a shared Excel workbook, one log per centre, archived in a shared cloud folder accessible to relevant safeguarding staff. It records student status, welfare flags, cross-references and Centre Manager sign-off.

7.1.7 Review and Escalation

• Any single welfare flag with safeguarding dimension is escalated same-day to the LIA DSL.
• Two welfare flags concerning the same student within seven days are escalated to the LIA DSL.
• Three or more welfare flags across different students within seven days at the same centre are escalated to the Group Coordinator.

7.1.8 Welfare Signals

Welfare signals include visible distress, withdrawal, behaviour or mood changes, unexplained injuries, harmful peer relationships and disclosures or partial disclosures.

7.2 Disclosure Handling at Centre Level

All staff must follow Annex G of the Group Safeguarding & Prevent Policy. All disclosures, safeguarding concerns and cases must be recorded in the central Safeguarding Form.

7.3 Absence and Missing Student Protocol

Unexplained absence of any student under 18 must be treated as a potential safeguarding concern from the outset. The full procedure is set out in the LIA Missing and Unaccounted Student Policy (v2.0, May 2026).

• On excursion: parent contact at 1 hour, police contact at 2 hours daytime or 1.5 hours evening/night.
• On site during classes: parent contact at 1 hour, police contact at 2 hours.
• Evening or non-academic activities: parent contact at 1 hour, police contact at 1.5 hours.
• In residence: parent contact at 1 hour after curfew or missed activity, police contact at 1.5 hours.

All missing or unaccounted incidents must be logged on the LIA Safeguarding Form within 24 hours of resolution. Any police contact or serious incident triggers a post-incident debrief within 5 working days.

7.4 Out-of-Hours Safeguarding Incidents

This protocol covers disclosures of abuse, allegations against staff, peer-on-peer incidents, welfare concerns about mental health or behaviour, and any matter that may meet a safeguarding threshold.

• Contact the on-rota Deputy DSL immediately.
• Call 999 first where there is immediate risk to life or physical safety.
• Listen, do not lead, do not promise confidentiality, and record the student’s own words.
• No investigative action should be taken by the receiving staff member.

The on-rota Deputy DSL must log concerns immediately, assess severity and escalate to the LIA DSL where required.

7.5 Communication with Parents and Guardians

• A named parent, guardian or responsible adult must be identified for each student under 18.
• Contacts must be notified promptly and within 24 hours for unexplained absence, welfare concerns, safeguarding referrals, medical incidents or where the DSL considers it appropriate.
• All attempts and outcomes must be documented.
• Parent and guardian details are collected pre-arrival and verified on enrolment day.
• Primary contact channel is voice call followed by confirmation email.

8. Escalation Chain

An exception occurs if a LIA student goes missing. In that case, the escalation timelines in the Missing and Unaccounted Student Policy Section 5 must be followed.

9. British Council Accreditation — Implementation Notes

10. Sign-Off

This addendum must be signed by all three parties before it is published and before any LIA summer centre opens for the season. An unsigned addendum has no standing.

By signing, each party confirms that all highlighted fields have been completed, all named DSLs and Deputy DSLs hold current Level 3 safeguarding training, the LIA SCR is complete and audited, all LADO contacts are verified, and central oversight applies throughout the season.

To read our Group Safeguarding and Prevent policy, visit the Malvern International website.