Safeguarding Policy

Protecting children and adults at risk from abuse and exploitation

Updated: January 2026

1.1 The staff of BAFROW Medical Centre engage daily with vulnerable populations, groups, and individuals through the implementation of clinical activities.

1.2 This Safeguarding Policy outlines the requirements necessary to ensure the safety and protection of all persons who may be at risk of abuse or exploitation. It also details the arrangements in place to address such incidents within the context of our clinical services.

1.3 The policy further serves to reassure the public that robust mechanisms exist to safeguard them from abuse and exploitation while accessing our services or interacting with anyone representing BAFROW Medical Centre.

1.4 We regard abuse and exploitation as serious violations of human rights and offensive behaviours that can negatively impact the health and wellbeing of those affected, as well as the reputation and integrity of the Hospital.

BAFROW Medical Centre is committed to:

2.1 Promoting the safety and protecting the well-being of children and adults who may be at risk of abuse or exploitation while in contact with our staff.

2.2 Complying with national legislation and international human rights instruments that safeguard people—especially women and children—including, but not limited to:

  • The Children’s Amendment Act, 2016
  • The Women’s Act, 2010
  • The Sexual Offences Act, 2013
  • The Domestic Violence Act, 2013
  • The Persons with Disabilities Act, 2021
  • The Gambia Labour Act, 2023
  • The Criminal Code Laws of The Gambia, 1933
  • The Gambia Constitution, 1997
  • The Convention on the Rights of the Child (CRC)
  • Convention on the Elimination of All Forms of Discrimination against Women (CEDAW)

2.3 Minimizing situations where abuse or exploitation could occur—whether in person, online or through other means of interaction—by implementing strong safeguarding policies and procedures across the institution, and involving authorities when legally, ethically or morally required.

2.4 Ensuring the staff understand their responsibility to:

  • Protect children and adults at risk from harm when making decisions or carrying out duties related to their work.
  • Treat all safeguarding matters with seriousness and urgency.

2.5 Creating safe spaces for children and adults at risk, where they are actively involved in decisions, their opinions are valued and staff uphold BAFROW’s Core Values: compassion and respect; ethics and integrity; and diversity, inclusion, and equity.

2.6 Providing support to women and girls during emergency situations, recognizing their heightened vulnerability to abuse and exploitation in such circumstances.

3.1 The goal of this Policy is to provide clear guidance for the staff of BAFROW Medical Centre on protecting children and adults at risk from abuse and exploitation.

3.2 The principal objectives of the Policy are to:

  • Define acts of abuse and exploitation within the scope of our work.
  • Outline safeguarding procedures for identifying, reporting and addressing cases of abuse and exploitation.
  • Establish roles and responsibilities to ensure a safe environment for vulnerable individuals and groups.

3.3 By effectively implementing this Policy, we expect the following outcomes:

  • A strengthened working environment in which the safety of children and adults at risk is safeguarded through robust protection policies and procedures.
  • A workforce equipped with the knowledge and capacity to recognize, proactively prevent and report cases of abuse and exploitation.

4.1 This Policy is mandatory for all individuals engaged in the work of BAFROW Medical Centre or visiting our facilities in connection with our activities. The provisions of this Policy apply to:

  • Board Members
  • Employees
  • Volunteers
  • Service providers (including consultants and contractors)
  • Other individuals visiting our clinical facilities who may come into contact with children and adults at risk

4.2 Partners and donors of BAFROW Medical Centre are expected to maintain their own Safeguarding Policies. In view of our shared values and commitments, we trust that they will demonstrate the same level of dedication as BAFROW Medical Centre in protecting children and adults at risk within the scope of our collaboration.

4.3 To ensure accessibility, this Policy will be made readily available to all interested parties by maintaining a copy in our Administrative Office and publishing it on our website.

Terminology in the area of protecting vulnerable individuals, especially children, is extensive and continues to evolve with emerging issues and services. The following terms are defined within the scope of this Policy:

General Definitions

5.1 Safeguarding: The practice of promoting the wellbeing of children and adults at risk, and protecting them from abuse and exploitation through preventative, protective and compliance measures across the Institution.

5.2 Our staff: All individuals carrying out the work of BAFROW Medical Centre in any capacity, including Board Members, employees, volunteers, contractors, consultants and any other persons who may come into contact with children and adults at risk while on our premises.

5.3 Child: Any person under the age of 18.

5.4 Adult at risk: Any person aged 18 years or above who is vulnerable to, or unable to protect his or herself from, acts of abuse and exploitation.

5.5 Person: A child or an adult at risk.

5.6 Vulnerable individuals and groups: Children and adults at risk.

5.7 Person affected: A person who has experienced, or reported experiencing, abuse or exploitation.

5.8 Reporting staff: A staff member who has filed an incident report concerning abuse or exploitation of a child or adult at risk.

5.9 Perpetrator: A staff member alleged to have committed, or found to have committed, an act of abuse or exploitation.

5.10 Incident: A reported act of abuse or exploitation.

5.11 Misconduct: Any act of abuse or exploitation.

5.12 Abuse: Ill-treatment directed towards a person that causes harm, endangers life or violates human rights. Abuse can occur in person, offline (e.g., calls, SMS) or online (e.g., social media, emails, direct messages).

5.13 Exploitation: The abusive act of coercing or manipulating a person for personal gain. This may involve the use of power or influence to threaten, intimidate or deceive, including false promises of safety, affection or material benefits. Exploitation can occur in person, offline or online.

Prohibited Actions

This Policy prohibits physical, sexual and emotional abuse; neglect; sexual and financial exploitation; and modern slavery. Staff must not engage in any actions associated with these forms of abuse or exploitation against persons using our facilities or services. While the list of abusive actions is not exhaustive, examples are provided below as guidance:

5.14 Physical abuse: Acts intended to cause physical pain or injury, such as slapping, hitting, kicking, shoving, tripping, pinching, stabbing, burning or strangling. It also includes destroying personal property or forcing substance use (e.g., alcohol, drugs, addictive medicines).

5.15 Sexual abuse: Any inappropriate or unwanted sexual act, including unwelcome advances, inappropriate remarks, sexually explicit jokes, inappropriate touching, rape or any sexual act between a child and an adult.

5.16 Emotional abuse: Acts that intimidate, manipulate or cause psychological distress, such as threats, insults, spreading harmful rumours, belittling, humiliating, dismissing feelings, discrimination, unfair criticism, favouritism or stalking.

5.17 Neglect: Failure to provide protection, care or wellbeing, including denial of medical care, safety monitoring or emotional support. It also includes isolating individuals.

5.18 Sexual exploitation: Forcing, intimidating or manipulating a person into sexual acts; exchanging money, goods or services for sexual favours; or engaging in adult–child sexual relations, including through marriage

5.19 Financial exploitation: Acts intended to extort or steal money or assets through force, intimidation, deceit (e.g. scams) or blackmail.

5.20 Modern slavery: Any form of abuse intended to manipulate or force a person to work or provide services against his or her will.

For BAFROW Medical Centre to effectively implement this Safeguarding Policy and foster a culture of safety, all staff must recognize their responsibility to protect children and adults at risk from abuse and exploitation.

Specific roles and responsibilities are outlined below:

6.1 Designated Safeguarding Officer

  • Ensuring all cases of abuse and exploitation are handled in accordance with the Standard Operating Procedure for Addressing Misconducts (see Annex 2).
  • Presenting all reported cases to the Safeguarding Committee for assessment, investigation and action.
  • Referring or reporting incidents outside the scope of this Policy to the appropriate national authorities.
  • Documenting and sharing final reports on abuse and exploitation cases, along with actions taken, with the Board of Directors.

6.2 Safeguarding Committee

  • Taking action when abuse or exploitation is implied or reported.
  • Reviewing incident reports and assessing whether they fall within the scope of this Policy.
  • Conducting investigations into alleged incidents when required.
  • Determining and executing appropriate punitive measures.
  • Ensuring persons affected by abuse or exploitation receive the necessary support.

6.3 Board Members

  • Electing the Designated Safeguarding Officer and Committee Members.
  • Reviewing and endorsing the hospital’s Safeguarding Policy.
  • Supporting fundraising efforts to implement the Policy.
  • Monitoring compliance with the Policy.
  • Reviewing safeguarding reports and updates.

6.4 Management

  • Providing resources necessary for the effective implementation of the Policy.
  • Monitoring Policy implementation.
  • Reviewing and updating safeguarding policies and procedures when required.
  • Ensuring that strong measures are in place to prevent, identify and respond to abuse and exploitation.
  • Ensuring that staff understand reporting procedures, the individuals involved and measures protecting them from retribution.
  • Providing additional safeguarding training to the staff who work closely with children and adults at risk.
  • Embedding safeguarding requirements in contracts with service providers, referencing the Policy.
  • Conducting background checks on new employees and volunteers.

6.5 Department Heads

  • Ensuring that staff recruitment includes appropriate background checks, conducted with consent.
  • Overseeing Policy implementation within their department and units.
  • Providing guidance on safeguarding matters.
  • Addressing challenges that may hinder Policy implementation.

6.6 Administrative

  • Including safeguarding orientation in the staff induction program.
  • Ensuring that all new staff read and sign the Policy.
  • Maintaining signed copies of the Policy in staff files, along with other safeguarding-related documents.
  • Maintaining a copy of this Policy on file and online for public access.

6.7 All Staff

  • Complying with this Safeguarding Policy.
  • Proactively learning about safeguarding issues and recognizing risks.
  • Promptly reporting any suspected, observed or alleged cases of abuse or exploitation.

Preventing Abuse and Exploitation

7.1 Recruitment of Staff and Volunteers: BAFROW Medical Centre’s recruitment process is guided by national laws, organizational policies and values, and best practices. We take all reasonable steps to ensure individuals with a proven history of abuse or exploitation are not employed or placed in positions requiring direct or close contact with children and adults at risk.

7.2 Background Checks: Although no national laws currently mandate background checks prior to employment, BAFROW Medical Centre conducts these checks—with employee consent—for all positions involving direct or close contact with vulnerable individuals. The level of investigation depends on the employee’s degree of involvement with children and adults at risk.

7.3 Induction of Staff and Volunteers: As part of induction, all new staff and volunteers are briefed on this Policy and required to read and sign it as a demonstration of compliance. For those with limited literacy, the Policy is explained then signed or thumb-printed. Signed copies are kept in employee files for reference in the event of future transgressions.

7.4 Training of Staff and Volunteers: Board Members, staff and volunteers receive basic safeguarding training to:

  • Recognize potential risks of abuse and exploitation.
  • Understand measures in place to address misconduct.
  • Know the channels for advice, reporting and support.
  • Staff working directly with children and adults at risk receive role-specific training appropriate to their responsibilities.

7.5 Reinforcing a Safe Workplace Culture: All staff are responsible for demonstrating behaviours that do not cause harm or place others at risk, whether directly or indirectly, while representing BAFROW Medical Centre.

7.6 Conduct Outside the Workplace: Staff are expected to uphold the same standards of conduct in their personal lives as they do within the workplace.

7.7 Expected Behaviours and Practices:

Staff must:

  • Comply with BAFROW policies—including Safeguarding, Harassment and Bullying, Privacy, and Code of Ethics and Conduct—and report abuse or exploitation in accordance with established processes.
  • Cultivate an environment that encourages safe and open discussions about safeguarding issues.
  • Protect and respect the privacy of all persons, keeping records and information confidential unless disclosure is morally, ethically or legally required.
  • Use only official communication channels for BAFROW Medical Centre-related interactions with all patients and visitors, including children and adults at risk.
  • Wear approved uniforms and identification badges during working hours and while carrying out the work of BAFROW Medical Centre.
  • Avoid being alone or isolated with a person while performing BAFROW Medical Centre duties.
    Seek permission from individuals (and parents/legal guardians in the case of children) before any physical contact during clinical examinations or other interactions.

Reporting and Responding to Cases of Abuse and Exploitation

7.8 All staff and vulnerable individuals are encouraged and expected to report suspected, observed or alleged cases of abuse and exploitation. Each case will be treated with equal importance and addressed promptly.

7.9 Reporting Process: If misconduct is suspected, observed or alleged, the reporting staff must complete the Safeguarding Incident Report Form (Annex 3) and submit it to a Designated Safeguarding Officer (DSO). Two DSOs are available to provide options for staff to report to someone they feel comfortable with.

7.10 Anonymous Reporting: Incident reports may be submitted anonymously. In such cases, all available details—including information about the affected person and the alleged perpetrator—should be included.

7.11 Emergency Reporting: In urgent cases, such as sexual abuse, a preliminary report must be submitted in person by email to accelerate the investigation before evidence is lost. The reporting staff will then be advised to complete and submit the Incident Report Form within one day.

7.12 Pre-Investigation: The DSO will ensure all cases follow safeguarding reporting processes. Upon receiving a report, the DSO will verify completeness, clarify any uncertainties and forward the case to the Safeguarding Committee for assessment and possible investigation.

7.13 Investigation Scope: The Safeguarding Committee will review the report to determine whether it falls within the scope of misconducts identified in this Policy. If not, the case will be referred to Management or the appropriate authority.

7.14 Investigation Process: For incidents covered by this Policy, the Committee will:
Inform all parties involved of the investigation.
Conduct interviews and discussions with relevant individuals.
Collect and document additional information, including physical evidence (images, written content, physical signs, etc.), if available.

7.15 Assessment of Findings: Upon completing the investigation, the Committee will determine whether the case should be handled internally or referred to national authorities.

7.16 Referral to Authorities: If outside the scope of this Policy, the DSO, with Committee approval, will contact the appropriate authority and provide necessary documentation and support, in line with BAFROW Medical Centre’s Privacy Policy.

7.17 Internal Disciplinary Measures: For cases handled internally, disciplinary measures will be taken against staff found guilty of abuse or exploitation. Actions will depend on the severity of the misconduct. Both the person affected and the perpetrator will be informed in writing of the final decisions and actions taken.

7.18 Documentation and Reporting: Once resolved, the DSO will prepare a detailed report outlining the case and processes involved. This report, along with supporting documentation, will be securely stored according to BAFROW’s information management policy. A copy will be shared with the Board of Directors for review and feedback.

8.1 In implementing safeguarding procedures, BAFROW Medical Centre takes every precaution to protect the right to privacy and confidentiality of all individuals involved in cases of abuse and exploitation. In line with our Privacy Policy, personal information will not be shared with unauthorized persons within the organization or with third parties outside the organization without the consent of the information owner.

8.2 Exceptional circumstances may arise where disclosure of personal information is morally, ethically or legally required, such as when a life is threatened. In such cases, the information owner will be notified, and the reason for disclosure will be clearly explained.

BAFROW Medical Centre’s policies are reviewed and updated annually, or as required.

This Safeguarding Policy was last updated in January 2026.

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