Safeguarding Policy

Dementia Active is committed to creating a safe, supportive and respectful environment for everyone who comes into contact with our charity. Safeguarding is central to the way we work, particularly because many of our members are adults at risk by virtue of their dementia diagnosis and may need additional support to express their wishes, make decisions, or raise concerns.

Our Safeguarding Adults at Risk and Children Policy and Procedures explains how Dementia Active works to prevent abuse, neglect and harm. It sets out the responsibilities of our staff, volunteers, trustees, self-employed staff, patrons and visitors, and makes clear that safeguarding is everyone’s responsibility.

The policy covers how concerns should be recognised, recorded and reported, including what to do if someone makes a disclosure or if a member of the team notices a change in a person’s wellbeing, behaviour, appearance or circumstances. It also explains how Dementia Active works with families, carers, Oxfordshire safeguarding services and other relevant agencies when concerns arise.

A key part of our safeguarding approach is prevention. This includes safer recruitment, appropriate DBS checks, induction, staff and volunteer training, clear codes of conduct, supervision, and regular review of safeguarding practice by the charity’s leadership and trustees.

The policy also includes guidance on confidentiality, consent, mental capacity, whistleblowing, record keeping, and reporting serious incidents where required. These procedures help ensure that concerns are handled carefully, proportionately and in the best interests of the person involved.

The full Dementia Active Safeguarding Adults at Risk and Children Policy and Procedures booklet can be downloaded from this page. It provides detailed information about our safeguarding standards, reporting processes and the steps we take to protect members, volunteers, students, staff and visitors.

This Code of Conduct should be considered in conjunction with the Safeguarding Policy  Please also read Dementia Active’s Whistleblowing Policy

Dementia Active seeks to support people who have a dementia diagnosis and are consequently deemed to be vulnerable and therefore at risk  Vulnerability is the condition of being unable to protect oneself against harm or exploitation. 

This code of conduct outlines the behaviour expected of everyone working for or visiting  Dementia Active groups in whatever capacity in whatever capacity.

The aim of defining a code of conduct is to:

• everyone understanding and maintaining expected behaviour 
• protecting members from abuse and inappropriate behaviour 
• reducing unfounded allegations against anyone “in the team”

Working With Adults at Risk:

When supporting those at risk we are acting in a position of trust and must behave in an appropriate manner at all times. The following list provides a guide as to what we consider to be important and appropriate. It is not exhaustive and there is an expectation that common sense will inform staff and volunteers as to what is acceptable/not acceptable. 

• Avoid favouritism and treat all members fairly and without prejudice or discrimination. It goes without saying that some people are more likeable than others regardless of a dementia diagnosis, so it is important to try to respond to all members with equal levels of warmth. 
• Encourage and support members to interact during the activities, try not to speak for them unless they give you permission to do this.
• Listen to and respect people at all times.
• Ask about personal preferences such as forms of address or how much help a person might need to carry out an activity.
• Never assume that because a person is not contributing verbally to group conversations that they are not understanding what is going on in the group.
• Do not make promises or commitments to members on the assumption that they will not remember what has been said.
• Value and take everyone’s contributions seriously, actively involving members in planning activities wherever possible.
• Ensure that your language and tone of voice are not overfamiliar particularly when meeting a new member. Always follow the person’s lead when responding to their conversation. Some people enjoy banter immediately, others may feel shy or anxious. Relate to members in exactly the same way you would to your own friends. 
• Respect a person’s right to personal privacy.
• Do not assume a person needs physical contact when distressed, always ask first whether they would like a hug, or their hand held. Likewise do not withhold physical contact because of concerns that this may be misinterpreted by others. As long as it is clear that the reason for touching someone is to give comfort and you ensure that it occurs within the group and never in private there is no room for misinterpretation. 
• Recognise that special caution is required when you are discussing sensitive issues for instance family relationships, childhood experiences.
• Ensure that members' personal belongings are kept safe.
• If a member loses something refrain from checking pockets, handbags etc unless requested to. Ensure that this is done in front of another member of staff.
• Seek advice from your Group Leader/Safeguarding Lead if you are uncomfortable with something you have experienced in your role. 

Under no circumstances must the following ever occur:

• Developing a personal friendship with a member which extends beyond the group setting.
• Making private arrangements to meet members or their families outside of the sessions.
• Linking up with a member on social media/messaging platform.
• Giving your personal contact details (mobile number, email or home address) to any member.
• Offering personal care to someone (for instance assisting a member in the toilets) if this is not part of your agreed role and therefore you do not have the required enhanced DBS check.
• Administering any prescribed medication unless this is an agreed part of your role.
• Offering your own personal medication to members for example any form of pain relief. If a member is in pain a carer must be contacted and if necessary the person may need to return home.  
• Discussing any information about a member or their family with anyone who is not involved with Dementia Active. Members' rights to privacy are paramount. This boundary is not always easy to keep in a small town where people have friendship circles which may overlap, but it must be adhered to.
• Patronising or treating Dementia Active members as if they are silly by virtue of their illness.
• Making sarcastic, insensitive, derogatory or sexually suggestive comments or gestures to or in front of members or to other members of your team.
• Acting in a way that could be perceived as threatening or intrusive when trying to persuade a member to do something they would prefer not to do.
• Conducting a sexual relationship with a Dementia Active member or engaging in any form of sexual contact regardless as to whether it was felt that the member had invited this. Any such behaviour by anyone working for the charity/CIC would be seen as gross misconduct (see Disciplinary Policy) and would if after a 5 day period of investigation found this to be true - lead to instant dismissal.
• Wearing clothes which are overly revealing and which therefore may be misinterpreted as deliberately sexually provocative. 
• Allow allegations about abuse or misconduct to go unreported.
• Coming to work in a group while under the influence of alcohol or drugs.
• Coming to work smelling of alcohol even though this has been consumed the evening before.
• Drinking alcohol at Dementia Active events e.g. Christmas parties.
• Giving or receiving gifts from members (other than token presents at Christmas or birthday celebrations). 
• Giving or receiving gifts of money directly from members.
• Lending or borrowing money from members. 
• Selling to/buying from a member or their family. 
• Taking photographs of activities is prohibited unless it is a defined part of your role.

Upholding this Code of Conduct

All members of staff and volunteers are expected to abide by these guidelines and report any observed breaches of this code as soon as possible. 

Action in the event of a breach of this Code of Conduct

Staff may be subject to disciplinary procedures.

Any serious breaches may result in a referral being made to a statutory agency such as the police or the Oxfordshire Adults Safeguarding board.

Reviewed  14/06/2026

Next Review date 14/06/2027

This Whistleblowing Procedure sets out the framework for dealing with allegations of illegal and improper conduct. Dementia Active is committed to the highest standards of transparency, integrity and accountability. This procedure is intended to provide a means of making serious allegations about standards, conduct, financial irregularity or possible unlawful action. It is designed to ensure confidentiality and protect those making such allegations from being victimised, discriminated against or disadvantaged, in the reasonable belief that it is in the public interest to do so. This procedure is intended to ensure that Dementia Active complies with its duty under the Public Interest Disclosure Act 1998. 

The policy applies to all Dementia Active employees and volunteers. It does not replace other Dementia Active policies or procedures. For example, if an employee has a grievance about their working conditions they should use either the Dementia Active Grievance Policy or the Complaints Policy. Similarly if an employee has a concern about the conduct of a fellow employee in the working environment (e.g. that they are not treating colleagues with respect) they should raise these in the first instance with their Group Leader or if the issue is connected to this person then the chair of directors. 

This procedure applies to, but is not limited to, allegations about any of the following:

· Conduct which is an offence or breach of the law 

· Alleged miscarriage of justice 

· Serious Health and Safety risks 

· The unauthorised use of public funds 

· Possible fraud and corruption 

· Sexual, physical or verbal abuse, or bullying or intimidation of employees, customers or service users 

· Abuse of authority 

· Other unethical conduct 

Depending on the nature of the allegation and who it might involve, report either verbally or in writing to: 

the Safeguarding Lead – Joanne Gill or 

the Chair of the Trustees.

Allegation

Whether a written or oral report is made it is important that relevant information is provided including: 

• The name of the person making the allegation and a contact point. 
• The background and history of the allegation (giving relevant dates and names and positions of those who may be in a position to have contributed to the allegation); 
• The specific reason for the allegation. Although someone making an allegation will not be expected to prove the truth of any allegations, they will need to provide information to the person they have reported to, to establish that there are reasonable grounds for the allegation. 

Dementia Active recognises that the decision to make an allegation can be a difficult one to make. However, whistleblowers who make serious allegations in the reasonable belief that it is in the public interest to do so have nothing to fear because they are doing their duty either to Dementia Active and/or to those for whom Dementia Active is providing a service. Dementia Active will take appropriate action to protect a whistleblower who makes a serious allegation in the reasonable belief that it is in the public interest to do so, from any reprisals, harassment or victimisation. 

All allegations will be treated in confidence and every effort will be made not to reveal a whistleblower’s identity unless the whistleblower otherwise requests this, unless the matter becomes the subject of disciplinary proceedings against the whistleblower due to a malicious allegation. Similarly, if the allegation results in court proceedings then the whistleblower may have to give evidence in open court if the case is to be successful. Dementia Active will not, without the whistleblower’s consent, disclose the identity of the whistleblower to anyone other than the person leading the investigation.

This procedure encourages whistleblowers to put their name to an allegation wherever possible as anonymous allegations may often be difficult to substantiate/prove. Allegations made anonymously are much less powerful but anonymous allegations will be considered at the discretion of the Trustees. 

In exercising discretion to accept an anonymous allegation the following factors need to be taken into account: 

· The seriousness of the issue raised 

· The credibility of the allegation; and 

· Whether the allegation can realistically be investigated from factors or sources other than the complainant.

No disciplinary or other action will be taken against a whistleblower who makes an allegation in the reasonable belief that it is in the public interest to do so even if the allegation is not substantiated by an investigation. However, disciplinary action may be taken against a whistleblower who makes an allegation without reasonable belief that it is in the public interest to do so (e.g. making an allegation frivolously, maliciously or for personal gain where there is no element of public interest). Someone making an allegation may be accompanied by another person of their choosing during any meetings or interviews in connection with the allegation. However, if the matter is subsequently dealt with through another procedure the right to be accompanied will at that stage be in accordance with the relevant procedure.

The person receiving the allegation will record details of the allegation gathering as much information as possible, (within 5 working days of receipt of the allegation) including:

· The record of the allegation: 

· The acknowledgement of the allegation; 

· Any documents supplied by the whistleblower

The investigator will ask the whistleblower for his/her preferred means of communication and contact details and use these for all communications with the whistleblower in order to preserve confidentiality. 

If the allegation relates to fraud, potential fraud or other financial irregularity the Treasurer will be informed within 5 working days of receipt of the allegation. The Treasurer will determine whether the allegation should be investigated and the method of investigation. 

If the allegation discloses evidence of a criminal offence it will immediately be reported to the Board of Trustees and a decision will be made as to whether to inform the Police. If the allegation concerns suspected harm to Dementia Active members OSAB (Oxfordshire Safeguarding Adults Board) will be informed immediately. 

o An acknowledgement of the allegation in writing within10 working days with

o An indication of how Dementia Active propose to deal with the matter 

o An estimate of how long it will take to provide a final response 

o An indication of whether any initial enquiries have been made 

o Information on whistleblower support mechanisms 

o An Indication as to whether further investigations will take place and if not, why not 

Clearly where the allegation has been made anonymously, Dementia Active will be unable to communicate what action has been taken.

Dementia Active will take steps to minimise any difficulties which may be experienced as a result of making an allegation. For instance, if a whistleblower is required to give evidence in criminal or disciplinary proceedings Dementia Active will arrange for them to receive advice about the procedure and advise on the support mechanisms that are available. Dementia Active accepts that whistleblowers need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, we will inform those making allegations of the outcome of any investigation. 

Get independent advice

You can also get advice from your trade union or from Citizens Advice.

The Chair of Trustees has overall responsibility for the operation of this procedure and for determining the administrative processes to be followed and the format of the records to be kept. 

A Register will record the following details: 

· The name and status (e.g. employee) of the whistleblower 

· The date on which the allegation was received 

· The nature of the allegation 

· Details of the person who received the allegation 

· Whether the allegation is to be investigated and, if yes, by whom 

· The outcome of the investigation 

· Any other relevant details 

The Register will be confidential and only available for inspection by the Board of Trustees. 

Andrew Gill CEO - 08/06/2025

Review date - 07/06/2026