Safeguarding & Child Protection Policy.

Section 01

Policy Statement

Sporting Pearls Football Academy is committed to protecting all children and young people involved in its programmes from abuse, neglect, exploitation, bullying, harassment, discrimination and all other forms of harm. Safeguarding is not an administrative requirement attached to our football programme — it is a foundational condition of the programme existing at all. A child cannot develop as a player, a student or a person in an environment that is unsafe, and we therefore treat the creation and maintenance of safe environments as a core deliverable of every session we run.

This policy establishes the principles, responsibilities and procedures through which the academy prevents safeguarding risks, promotes a culture of safety, responds appropriately to concerns, provides safe reporting channels, and works appropriately with parents, guardians and relevant authorities. It applies without exception, and no result, sponsorship, relationship or convenience of any kind justifies a departure from it. Where this policy and any other academy interest conflict, this policy prevails.

Section 02

Scope & Application

This policy applies to everyone involved with the academy — players, coaches, technical staff, volunteers, board members, employees, contractors, parents and guardians, visitors and partners. It covers all age groups from our youngest squads through the U19 senior pathway, and extends equally to the girls’ and women’s pathway under Sporting Pearls Féminin.

The policy operates during training sessions, matches, tournaments, travel and tours, camps, academy events, community activities, digital communication, and any other activity conducted in the Sporting Pearls name or under its branding. It also applies to situations that arise outside formal academy activity where a person’s role within the academy is materially connected to the harm, the risk of harm, or the opportunity for harm to occur.

Contractors, visiting teams, partner organisations and any third party granted access to academy players or facilities are required to accept the standards of this policy as a condition of that access. Where a partner operates under its own safeguarding framework, the academy will satisfy itself that the partner’s standards are at least equivalent before joint activity takes place.

Section 03

Legal & Policy Framework

This policy is drafted with regard to the legal and regulatory context in which the academy operates in Kilifi County, Kenya, and to the international standards that govern safeguarding in youth sport. The academy does not attempt to reproduce the law in full; it commits to operating within it and to reviewing this policy whenever the underlying framework changes.

• The Constitution of Kenya (2010) — in particular Article 53, which makes the best interests of the child a primary consideration in every matter concerning a child.
• The Children Act (No. 29 of 2022) — the principal legislation governing the care, protection and welfare of children in Kenya.
• The Sexual Offences Act (2006) and the Computer Misuse and Cybercrimes Act (2018) — relevant to abuse offences and to harm facilitated online.
• The Data Protection Act (2019) — governing how the academy collects, stores and shares safeguarding records and consent information.
• The UN Convention on the Rights of the Child — which Kenya has ratified, and which frames every child’s right to protection from violence and exploitation.
• The International Safeguards for Children in Sport — the eight-safeguard framework developed by international sport and child-protection bodies, with which this policy is aligned.
• Football Kenya Federation (FKF) requirements — including registration, club-licensing and competition rules affecting youth football.

Section 04

Definitions

The following definitions apply throughout this policy and its companion codes of conduct. They are working definitions intended to help our people recognise concerns early; they are not legal tests, and no person at the academy is expected to make legal determinations about whether harm has occurred.

Child

Any person under the age of 18. Where the academy works with players who turn 18 while in the programme, safeguarding standards continue to apply to them in full for the duration of their involvement.

Safeguarding

The collective set of actions by which the academy prevents harm to children, promotes their wellbeing, and responds effectively when concerns arise.

Child Protection

The specific part of safeguarding that responds to children who are suffering, or are likely to suffer, significant harm.

Abuse

Physical, emotional or sexual abuse, neglect, or commercial or other exploitation of a child. Abuse may be inflicted by adults or by other children, in person or online.

Bullying

Repeated behaviour intended to hurt, frighten, exclude or diminish another person, whether physical, verbal, relational or digital.

Grooming

A process by which a person builds a relationship, trust and emotional connection with a child in order to manipulate, exploit or abuse them.

Position of Trust

A role — such as coach, instructor, mentor or team manager — that carries authority, influence or access in relation to a child.

Concern

Any information, observation or feeling that a child may be at risk of harm. A concern requires no proof, no certainty and no complete account.

Section 05

Guiding Principles

Eight principles govern every safeguarding decision taken at Sporting Pearls. They are published on our safeguarding page and are reproduced here in full because they are the standard against which the Governing Body evaluates this policy in operation.

1. Child First — children’s welfare takes priority over every competing consideration, without exception.
2. Prevention — we seek to identify and reduce risks before harm occurs, through safe recruitment, safe environments, training and awareness.
3. Listening — children have safe and appropriate opportunities to express concerns, and are believed and taken seriously when they do.
4. Respect — every child deserves dignity and fair treatment, regardless of ability, age, background, gender or any other characteristic.
5. Accountability — adults working with children are responsible for their conduct, and the academy is accountable for the systems that govern it.
6. Confidentiality — safeguarding information is handled responsibly and shared only where appropriate and necessary.
7. Non-Retaliation — a person raising a genuine concern is never punished or intimidated for reporting it.
8. Best Interests — actions concerning a child prioritise that child’s safety and wellbeing above all other outcomes.

Section 06

Roles & Responsibilities

Governing Body / Board

The Governing Body holds ultimate accountability for safeguarding at the academy. It approves this policy, appoints the Welfare & Safeguarding Lead, satisfies itself that recruitment and training standards are being met, and reviews every serious incident with a view to improving the system. It does not manage individual cases — that is the role of the Safeguarding Lead and, where applicable, external authorities.

Welfare & Safeguarding Lead (Designated Safeguarding Officer)

The Safeguarding Lead receives safeguarding concerns through any channel — including the confidential online report form and the official academy email — coordinates the initial response, escalates serious concerns to the appropriate authorities, maintains the academy’s safeguarding records, and owns this policy between review cycles. All reports submitted through Form 10 are delivered to this role.

Coaches, Staff & Volunteers

Every adult in the academy is responsible for operating within the Coach & Volunteer Code of Conduct, for maintaining safe practice in sessions and activities, and for passing any safeguarding concern to the Safeguarding Lead promptly. Staff recognise, respond, record and report — they do not investigate.

Parents & Guardians

Families are partners in safeguarding. They receive safeguarding information, know who to approach with a concern, and are asked to uphold the expectations set out in the Player Code of Conduct & Parent Expectations, including how conduct on the sideline and communication with players are managed.

Players

Players are asked to look after one another, to reject bullying and discrimination, and to speak to any trusted adult at the academy — or use the confidential form — when something feels wrong. Children carry no safeguarding responsibility for adults; the responsibility always runs upward.

Section 07

Safe Recruitment & Vetting

Adults working with young people hold positions of trust, so safeguarding checks are built into recruitment rather than appended to it. No person is considered suitable simply because they have football experience, playing pedigree or personal connections to the academy. Depending on the role, joining the Sporting Pearls team involves a structured screening process.

• Application form and identity verification
• References and relevant qualifications
• Safeguarding training
• Appropriate background and vetting checks
• Interview
• Code-of-conduct acknowledgement
• Declaration of safeguarding responsibilities

Vetting checks are renewed on a defined cycle, and a positive criminal record does not automatically exclude a candidate — the Safeguarding Lead assesses relevance to the role, records the rationale, and may impose conditions or decline the appointment. The same standards apply to volunteers and to paid staff: a volunteer session leader holds the same access to children as a salaried coach and is screened accordingly.

Section 08

Safe Environments & Activities

Prevention is designed into the environments and routines of the academy. Training sessions are open, organised and visible — nothing about our setup is hidden — and welfare checks sit in the same routine as cones and bibs. The standards below define what “safe” means in daily operation.

Supervision

Sessions run with appropriate supervision ratios for the age group and activity, and no coach works in complete isolation with an individual child. One-to-one conversations — which are sometimes necessary and valuable — take place within sight of others. Changing areas are supervised appropriately for age, with adults respecting players’ privacy while never creating unobserved spaces.

Facilities

Training and competition venues are assessed for safety before use, and hazards are recorded and addressed. The academy avoids arrangements that require children to wait unsupervised in unmanaged spaces, and arrival and collection procedures are communicated clearly to families.

Travel & Tours

Trips away from the home base operate under a travel plan approved in advance, covering transport, accommodation, supervision and emergency contacts. Drivers and accommodation providers are treated as positions of trust and screened accordingly. Overnight arrangements separate adults’ and children’ accommodation, and no adult shares a room with a child other than their own under arrangements the academy has approved.

Health & First Aid

First-aid provision is available at sessions, medical information and emergency contacts are held for every registered player, and injuries are recorded and communicated to families. Medical decisions about injured or unwell players default to caution: a child is never pressed back onto the pitch to satisfy a competitive situation.

Section 09

Communication & Digital Safety

Most of modern safeguarding risk lives in communication, and the academy therefore manages it deliberately. The governing rule is transparency: communication channels between adults and children are open to observation, and private, hidden or secret channels are prohibited.

• Coaches and volunteers communicate with players through approved channels, with parents or guardians copied or informed as appropriate to the age group.
• Direct personal contact between staff and individual players through personal accounts, private messages or calls outside approved channels is not permitted.
• Team information is shared through group channels rather than one-to-one threads wherever practical.
• Staff do not accept or initiate social-media connections with current players where such connections create private contact outside the academy’s visibility.
• Online abuse, grooming and inappropriate digital contact are treated as safeguarding concerns under this policy, whether they originate inside or outside the academy.

Section 10

Photography, Media & Consent

Player welfare comes before social-media engagement. Images of young players are a safeguarding matter, not a marketing asset, and the rules that govern them are simple and absolute.

• Before any identifiable image of a young player is published, appropriate consent must be in place — recorded and current, using the academy’s media and photo consent process.
• Clear rules govern who may photograph players, in what settings images may be taken, and where they may be used. Official photographers at academy activities are identified and authorised.
• Images are never used in a manner that compromises a child’s dignity, safety or privacy, and are never accompanied by information that could locate or identify a child to a hostile observer.
• Consent can be withdrawn. When a family withdraws consent, published images are removed from channels the academy controls.
• Spectators and visitors may not photograph players without authorisation, and sessions retain the right to challenge unauthorised photography.

The media and photo consent form is the standard instrument by which consent is requested and recorded, and its records are maintained by the Safeguarding Lead alongside other safeguarding documentation.

Section 11

Recognising & Responding to Concerns

The academy’s response procedure is built for the reality that concerns arrive incomplete: a worried feeling, a partial account, a second-hand comment. The procedure does not require certainty to set it in motion. If you are concerned about a child’s safety, report the concern — do not wait for proof.

How a concern can be raised

• Through the confidential online report form — available to players, parents, staff, volunteers and visitors, with the option to submit completely anonymously.
• By email to the official academy address, marked “Safeguarding”, for the attention of the Welfare & Safeguarding Lead.
• In person, to any member of academy staff, who will pass it to the Safeguarding Lead through the established procedure.

How our people respond

1. Listen — allow the person to communicate without unnecessary questioning. Do not interview, do not press for detail, do not suggest answers.
2. Reassure — respond calmly, take the concern seriously, and explain honestly what will happen next. Never promise absolute secrecy.
3. Record — document the information accurately and promptly, in the person’s own words where possible, and preserve any relevant messages or evidence.
4. Report — pass the concern to the designated safeguarding lead through the established procedure without delay.
5. Escalate — where necessary, the safeguarding lead refers the matter to appropriate external authorities or professional services.

Reports made through Form 10 receive a reference number and are handled under confidentiality restricted to the Safeguarding Lead. Anonymous reports are actioned on the strength of the information provided. What our people will never do: promise secrecy, investigate allegations themselves, confront an alleged perpetrator, conduct unnecessary interviews, pressure a child for details, delay because they are uncertain, delete evidence, or attempt to resolve serious concerns informally.

Section 12

Allegations Against Adults

Allegations against staff, volunteers, officials, partners or other adults connected to the academy are managed under this section, separately and more stringently than other concerns. The purpose of the procedure is threefold: to protect children, to deal fairly with the person accused, and to protect the integrity of any external investigation.

When such an allegation is received, the Safeguarding Lead takes immediate steps to prevent the accused adult from having unsupervised contact with children while the matter is assessed — suspension from duties in this context is a neutral protective measure, not a finding. The matter is escalated to the appropriate external authorities where the allegation meets the threshold, and the academy cooperates fully with statutory processes and does not conduct its own investigation in parallel.

The academy manages its internal disciplinary process distinctly from the safeguarding escalation, so that criminal or statutory outcomes are never pre-empted by internal findings. All persons involved are reminded of their confidentiality obligations, and of the absolute prohibition on retaliation against any person who raises a concern in good faith. Concerns about the Safeguarding Lead personally may be raised directly with the Governing Body, and the reporting channels make provision for this.

Section 13

Confidentiality, Records & Information Sharing

Safeguarding information is held on a strict need-to-know basis. Records of concerns, reports and outcomes are maintained securely by the Safeguarding Lead, with access limited to those who require the information to discharge a safeguarding function. Records are retained for the period required by law and good practice, after which they are securely destroyed.

Confidentiality is never a reason for inaction. The academy shares safeguarding information with external authorities — children’s services, law enforcement, medical professionals and sporting bodies — where doing so is necessary to protect a child, and does so promptly and in full. Within the academy, the identity of a person who reports a concern is protected to the greatest extent consistent with a proper response.

All records are handled in accordance with the Data Protection Act (2019): collected for a specified purpose, held securely, accurate, and not kept longer than necessary. Players and families are told, in terms appropriate to their age, what is recorded about them and why.

Section 14

Whistleblowing & Non-Retaliation

A person raising a genuine concern should not be punished or intimidated for reporting it. This protection is absolute at Sporting Pearls and applies to players, parents, staff, volunteers and partners alike. It covers concerns raised in good faith that later prove mistaken; it does not extend to reports known by their maker to be false, which the academy treats as a serious conduct matter in their own right.

The confidential report form exists in part because the hardest concerns to raise are those about people with power — a senior coach, a popular volunteer, an official, a leader. The anonymous submission option exists precisely so that no hierarchy inside the academy can silence a report. Concerns about senior figures, including the Safeguarding Lead, may also be raised directly with the Governing Body.

Section 15

Training, Awareness & Review

Safeguarding competence is maintained, not assumed. All staff and volunteers receive safeguarding induction before working with players, and refresher training on a defined cycle. The Safeguarding Lead maintains more advanced training appropriate to the role, and the academy keeps training records alongside its other safeguarding documentation.

Players and families receive safeguarding information in accessible form — through this policy, the companion codes of conduct, and the summaries published on our safeguarding page — so that everyone knows the standards, the reporting channels, and the named person to approach with any concern.

This policy is reviewed at least annually, and additionally after any significant incident, regulatory change or structural change at the academy. The review is owned by the Welfare & Safeguarding Lead and approved by the Governing Body, and its outcomes are recorded in the version history below.

Section 16

Document Control

Questions about this policy, requests for clarification, and proposals for amendment may be directed to the Welfare & Safeguarding Lead through the academy contact page. This document is published as an accessible web page and will always be available in current form on this site.