Child and Youth Safeguarding Guidelines

PURPOSE:

Reflective Learning Education Pty Ltd (“Reflective Learning” or “we”) is an Education Technology company focused on empowering learners to overcome educational barriers using its online learning platform. Reflective Learning aims to provide scalable, accessible, and impactful solutions that advance proven pedagogical strategies. We prioritise an inclusive, safe, and supportive environment for all learners, irrespective of their backgrounds or abilities.

Reflective Learning recognises the importance of ensuring the safety and well-being of children and youth in all interactions with its products and services. We are committed to creating a secure and supportive educational environment that fosters personal development. The policies outlined in this document define Reflective Learning’s moral and regulatory commitments to safeguarding children and youth, adhering to legal and ethical standards, and promoting a culture of respect, equality, and inclusivity.

POLICY STATEMENT:

Reflective Learning is committed to protecting the rights and well-being of children and youth. This commitment aligns with Article 19 of the UN Convention on the Rights of the Child and the Universal Declaration of Human Rights, recognising that children have the right to be protected from all forms of violence, abuse, and exploitation, whether under the care of parents, guardians, or others responsible for their welfare.

Reflective Learning upholds the principles of the Universal Declaration of Human Rights, emphasising the dignity and worth of all individuals, regardless of age, and the equal rights of men and women.

Our safeguarding policies comply with applicable South African legislation, including the Protection of Personal Information Act (POPIA), the South African Council for Educators (SACE) Code of Professional Ethics, and the Children’s Act (Act No. 38 of 2005). Reflective Learning is committed to protecting children and youth from all forms of violence and will not tolerate any abuse or exploitation.

SCOPE:

These guidelines apply to all individuals involved in executing and managing the Reflective Learning program for children and youth, including full-time and part-time employees, contractors, directors, partners, consultants, and affiliates.

This policy applies to everyone working on behalf of Reflective Learning, including senior managers, executives, directors, paid staff, contractors, sessional workers, partners, and consultants. Failure to comply may result in dismissal or exclusion from the organisation.

DEFINITIONS:

• Abuse includes Physical Abuse, Sexual Abuse, Emotional Abuse, and Exploitation.
• Physical Abuse refers to intentional force that causes harm to a child or youth.
• Sexual Abuse occurs when a person exploits a child or youth for sexual purposes without their consent.
• Emotional Abuse involves actions causing serious behavioural, cognitive, or emotional harm to a child or youth.
• Exploitation refers to unfairly benefiting from the power imbalance over a child or youth.
• Neglect occurs when a child’s caregivers fail to provide adequate care, protection, or services despite having the means and knowledge to do so.

BEST INTERESTS OF CHILDREN AND YOUTH:

The principle of the best interests of children and youth requires measures to protect their rights, safety, and well-being. It involves ensuring that their opinions are heard in matters that affect them.

• Child: Any person under the age of 18 years.
• Learner: A pupil or student at an educational institution.
• Other Person: Any person aged 35 years or older.
• Protection: Measures taken to prevent and respond to abuse and violence against children and youth.
• Youth: Any person aged 18 to 35 years.

LEGAL FRAMEWORKS:

• Children’s Act (Act No. 38 of 2005): Defines child protection and well-being in South Africa, addressing abuse, neglect, exploitation, and children’s rights.
• Protection of Personal Information Act (POPIA) (Act No. 4 of 2013): Governs the processing and protection of personal information in South Africa. Reflective Learning complies with this Act to ensure children’s privacy and security.
• SACE Code of Professional Ethics: Outlines ethical standards for education professionals, which Reflective Learning expects all employees to follow in their interactions with children and youth.

CHILD AND YOUTH SAFEGUARDING GUIDELINES:

1. Training and Awareness: Reflective Learning provides safeguarding training to employees and contractors, ensuring they understand their role in protecting children, recognise potential issues, and report safeguarding concerns. The safeguarding policy is available on the company drive, and training is updated annually.

2. Screening & Recruitment: Reflective Learning ensures safe recruitment practices to reduce the risk of harm to children and youth from unsuitable personnel.

3. Social Media: Employees must follow Reflective Learning’s social media policy and code of conduct, in line with POPIA and the safeguarding standards.

4. Use of Mobile Phones and Digital Technology: Employees must follow Reflective Learning’s policies on mobile and digital technology use, including securing parental consent for photographing children.

5. Participation of Children and Youth: Children and youth are treated as individuals whose views are taken seriously. Reflective Learning personnel must disclose any intention to report incidents involving abuse or exploitation.

6. Reporting Channels for Children and Youth: Reflective Learning provides in-application reporting functions and other channels for children and youth to raise concerns. These channels are confidential and child-friendly, and are monitored to ensure compliance with safeguarding policies.

7. Reporting Incidents of Concern: Reflective Learning staff must identify and report any concerns regarding the protection of children and youth, following outlined procedures.

These steps are outlined below:

Steps for Reporting Child, Youth and Safety Concerns	Further Information
1. Document the details.	What are the details of your concern/incident/observation? Note any evidence of this. 2. Who are the people and/or parties involved? 3. Which school/organization/network are they affiliated with? 4. What are their contact details?
2. Immediately notify your direct line-manager.	Share the documented details with your line-manager. Your line-manager will notify the Chief Operating Officer – Mr Eugene Pelteret. Email: [email protected] Cell no.: +27817790093
3. Notify the relevant authorities.	Eugene Pelteret will notify the relevant authorities, which may include: – Reflective Learning’s Chief Executive Officer (CEO), Mr Keelan Whiting – The learner’s school. – The school-appointed social worker. – A Child Protection Officer (CPO) at the South African Police Services (SAPS).
4. Report back.	Eugene Pelteret will notify you and your line-manager in writing of the steps taken and update you regarding any further steps required.
5. Response and Follow up.	This is detailed in Section 8 below.

Any concerns reported regarding Reflective Learning Personnel will take into account the Best Interests of Children and Youth and the Reflective Learning code of conduct.

These steps are outlined below:

Steps for Reporting a Reflective Learning Employee for Concerning Behaviour and/or Child & Youth Safeguarding Violations	Further Information
1. Document the details.	What are the details of your concern/incident/observation? Note any evidence of this. 2. Note the name and position of the Reflective Learning staff member being reported. 3. Note the school the affected learner(s) attend.
2. Immediately notify your direct line-manager.	Share the documented details with your line-manager. Your line-manager will notify the Chief Operating Officer – Mr Eugene Pelteret.
3. Notify the relevant authorities.	Eugene Pelteret will notify the relevant authorities. These may include: – Reflective Learning’s Chief Executive Officer (CEO), Mr Keelan Whiting – The school-appointed social worker(s). – A Child Protection Officer (CPO) at the South African Police Services (SAPS).
4. Report back.	Eugene Pelteret will notify you and your line-manager in writing of the steps taken and update you regarding any further steps required.
5. Disciplinary Measures.	A formal disciplinary hearing will be held with the implicated employee within 48 hours of the reported incident.
6. Report Back.	Reflective Learning staff and relevant authorities will be notified of the outcome of the disciplinary hearing within 24 hours of the decision taken.
7. Response and Follow up.	This is detailed in Section 8 below.

Reflective Learning Personnel are expected to follow the correct internal procedures and channels, as outlined above, to report incidents of concern. This process is visually summarised below:

8. Response and Follow Up

Reflective Learning policies and procedures include appropriate measures to support and protect children and youth when concerns arise. All measures taken to respond to abuse or exploitation respect the rights of children and youth, local laws, and take into account the best interests of the child and/or youth, as applicable, aiming to ensure no further harm comes to the child and/or youth as a result of any actions taken by Reflective Learning. Efforts to work in conjunction with other service providers, specialists, parents, legal guardians, caregivers, and others will be explored when appropriate upon the consent of the child and/or youth in question. After any incident or report of abuse and exploitation, proper measures will be taken to ensure internal learning, evaluation, and follow-up take place.

Reflective Learning will retain written records of all reports of abuse of a child or youth, including, but not limited to, the date of the report and the date of the alleged abuse; the name and address of the child and/or youth and his/her parent(s)/legal guardian(s) (if applicable); the name of the Reflective Learning personnel who made the report; the name of the governmental contact to whom the report was made; and a clear description of the facts that led to the report, as well as any other available information. Reflective Learning will advise its insurance provider of the complaint of child and/or youth abuse, as applicable, and retain records of any such reports. Reflective Learning will also advise the Foundation of any child and/or youth abuse complaints, either in writing or by email.

All such records will be kept within internal files in accordance with Reflective Learning’s privacy and confidentiality policies and best practices.

9. Implementation, Monitoring and Review

The implementation and monitoring of this policy to protect children and youth is designated to Eugene Pelteret, the Chief Operating Officer at Reflective Learning. The policy will be reviewed every year. This will be followed by internal training to ensure that Reflective Learning personnel are up to date with the latest draft of the policy and note any changes/revisions.

10. Medication

Reflective Learning’s personnel will not give or apply any medication to children. Reflective Learning personnel will not give or apply any medication to youth unless the personnel in question is a doctor, nurse, or other professional medical personnel. Reflective Learning also complies with all applicable laws of the jurisdiction with respect to access by youth to prescribed medications (such as asthma inhalers).

11. Code of Conduct

Reflective Learning requires all employees and personnel to abide by the company’s code of conduct in all Reflective Learning activities. All personnel involved in Reflective Learning initiatives must acknowledge and comply with the following statements:

• We give equal opportunity: We believe everyone deserves an opportunity to show their best. We focus on raising the base to enable each person to fulfil their potential.
• We empower: We believe in handing people ownership. By taking responsibility, we’re incentivised to put in maximum effort for the benefit of ourselves and the collective.
• We innovate: We explore the frontiers of global research, guided by our curiosity and academic rigour. We push ourselves to learn and improve continually.
• We are humble: We seek to serve people by adding value. We believe teamwork and partnerships do better work and reach more people than as individuals.
• We are real: We care about real impact, not the façade of success. We have honest conversations and don’t hide from mistakes because they make us better.
• We are intentional: We use each minute we’re given purposefully, staying focused on our overall goal. We plan and execute with accuracy because the details matter.

Additionally, all employees and affiliated individuals that interact directly with children must be aware of and behave in accordance with the SACE Educator’s Code of Professional Ethics (2018), available at: SACE Educator’s Code at all times during learner engagement.

Therefore, these personnel agree to the following:

• Respecting the dignity, beliefs, and constitutional rights of learners and, in particular, children, which includes the right to privacy and confidentiality;
• Acknowledging the uniqueness, individuality, and specific needs of each learner, guiding and encouraging each to realise his or her potentialities;
• Striving to enable learners to develop a set of values consistent with the fundamental rights contained in the Constitution of South Africa;
• Exercising authority with compassion;
• Avoiding any form of humiliation, and refraining from any form of abuse, physical or psychological;
• Refraining from improper physical contact with learners;
• Promoting gender equality;
• Refraining from courting learners from any school;
• Refraining from any form of sexual harassment (physical or otherwise) of learners;
• Refraining from any form of sexual relationship with learners from any school;
• Refraining from exposing and/or displaying pornography material to learners and/or keeping the same in his/her possession;
• Using appropriate language and behaviour in his or her interaction with learners and acting in such a way as to elicit respect from the learners;
• Taking reasonable steps to ensure the safety of the learner;
• Not abusing the position he or she holds for financial, political, or personal gain;
• Not being negligent or indolent in the performance of his or her professional duties; and
• Recognising, where appropriate, learners as partners in education.