1. Trustee Governance and Decision-Making

Purpose. Keeps important decisions with the Board, makes delegation clear and leaves an audit trail that shows how trustees reached significant decisions.

Who this covers. Trustees, committees, staff, volunteers and anyone acting under delegated authority.

Policy

• Trustees act collectively, within Freedom’s purposes and powers, in good faith and in the charity’s best interests.
• The Board remains accountable when work or decisions are delegated. High-risk, novel or strategically significant decisions normally stay with the Board.
• Routine decisions need a simple record. More significant decisions should show the options considered, the main risks, any conflicts and the reasons for the decision.
• Trustees are expected to challenge constructively. Any trustee may ask for an important disagreement to be noted in the minutes.

In practice

• Follow the governing document and the Charity Commission decision-making principles when taking significant decisions.
• Maintain a Delegated Authority Schedule covering spending, contracts, banking, communications, safeguarding escalation and other reserved matters.
• Keep terms of reference for any committee or person given delegated decision-making power.
• Revisit long-running or high-impact decisions when the circumstances change significantly.
• Seek professional advice where the Board does not have enough information or expertise to decide responsibly.

Records

• Board and committee minutes; written resolutions; Delegated Authority Schedule; significant decision papers; professional advice relied upon where applicable.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

2. Conflicts of Interest and Related-Party Decisions

Purpose. Protects Freedom’s independence and ensures decisions are made for the charity rather than for a trustee, founder, donor, supplier or connected person.

Who this covers. Trustees and anyone taking a delegated decision for Freedom.

Policy

• Both financial conflicts and conflicts of loyalty must be recognised. The appearance of a conflict can matter even where nobody has acted improperly.
• Interests are declared early, not after a decision has been made.
• An affected person does not influence a decision where the conflict cannot be safely managed.
• No policy automatically permits a trustee benefit. Any benefit must have a lawful authority and be in Freedom’s best interests.

In practice

• Maintain a standing register of trustee interests and ask for conflicts at the start of relevant meetings.
• Record the nature of the conflict, how it was managed, whether the person withdrew and the final decision.
• For connected-party purchases or contracts, consider value, alternatives, authorisation and whether independent advice is needed.
• Refer significant or difficult conflicts to the full Board. Seek Charity Commission or legal advice if the Board is unsure about its authority.

Records

• Register of Interests; meeting minutes; procurement or comparison evidence; trustee-benefit authority where relevant.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

3. Safeguarding Governance

Purpose. Sets Freedom’s Board-level safeguarding standard for children, adults at risk, survivors, staff, volunteers and anyone who comes into contact with the charity.

Who this covers. All Freedom activities, including helpline and enquiry routes, schools, professional training, campaigning, events, digital services, volunteers and partnerships.

Policy

• Safeguarding comes before reputation, fundraising or convenience.
• Freedom’s role is to provide specialist information, prevention education and routes to help; it does not replace police, social care, health services, the Forced Marriage Unit or other statutory bodies.
• Forced marriage, FGM, virginity testing, hymenoplasty and Dishonour Abuse can involve multiple perpetrators, overseas risk, family or community pressure and monitored communications. Unsafe mediation or family contact can increase risk.
• Confidentiality is important, but information may need to be shared where the law, a serious risk or safeguarding duty requires it.

In practice

• Maintain a current operational safeguarding procedure with named internal leads in a restricted schedule, not in the public policy.
• Use recruitment and role checks matched to the work, including DBS checks where the role is legally eligible and a check is appropriate.
• Provide induction and role-specific safeguarding training to trustees, staff and relevant volunteers.
• Ensure people know how to report a concern internally and how urgent concerns are escalated to statutory or specialist services.
• Do not ask friends, pupils or volunteers to investigate suspected abuse, gather evidence, contact family members or mediate.
• Consider digital safety before sending messages, storing information or recommending app/device changes to a person who may be monitored.
• Review serious safeguarding concerns for learning and consider Charity Commission seriousincident reporting where appropriate.

Records

• Restricted safeguarding log; referral/escalation records where necessary; training record; safer recruitment checks; incident review; serious-incident decision record.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Use the separate public Safeguarding Policy and restricted safeguarding response procedure. Where policies differ, follow the safer lawful escalation route and resolve the discrepancy promptly.
• Maintain a named safeguarding lead, deputy and independent alternative in a restricted schedule. Do not publish private direct contact numbers.
• Check how externally answered helpline messages are transferred securely and urgently. Call-handling staff are not Freedom’s specialist safeguarding advisers.
• Distinguish the personal statutory FGM reporting duty for certain professionals from the safeguarding responsibilities of everyone who receives concerns.

4. Safer Recruitment, Volunteers and Conduct

Purpose. Helps Freedom bring in trustees, staff and volunteers safely and gives everyone a clear standard of behaviour.

Who this covers. Trustees, employees, contractors, volunteers, ambassadors, group leads and other representatives.

Policy

• Recruitment checks are matched to the role and to the level of contact with children, adults at risk, money, personal data or systems.
• Volunteers are valued but are not asked to act beyond their competence or become informal caseworkers.
• Nobody is entitled to use Freedom’s name, data, safeguarding information or systems after their role ends.

In practice

• Use role descriptions, references where appropriate, identity checks and legally eligible DBS checks for relevant roles.
• Provide induction covering safeguarding, confidentiality, data protection, conduct, expenses, conflicts and raising concerns.
• Set boundaries on contact with beneficiaries, social media, gifts, photographs, personal devices and confidential information.
• Provide supervision appropriate to risk and respond promptly to conduct concerns.
• Remove system access, return charity property and complete a handover when a role ends.

Records

• Role descriptions; recruitment checklist; training record; volunteer agreement or code of conduct; access-removal record where relevant.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Confirm eligibility and level of DBS checks for each role. Do not make blanket claims that all trustees or volunteers have been checked.
• Maintain written expectations of conduct, including boundaries on informal private contact with children.

5. Complaints and Feedback

Purpose. Provides a fair, accessible route for concerns about Freedom’s services, fundraising, conduct or communications and makes sure lessons are not lost.

Who this covers. Complaints from beneficiaries, donors, customers, schools, professionals, partners, volunteers and members of the public.

Policy

• People should be able to complain without being disadvantaged for doing so.
• Complaints are handled fairly, at the right level, and without unnecessary delay.
• A complaint about safeguarding, fraud, discrimination, data protection or serious misconduct is routed immediately to the relevant procedure rather than treated only as customer service.
• Fundraising complaints are handled in line with the Code of Fundraising Practice and any external escalation rights that apply.

In practice

• Acknowledge complaints promptly and explain who is handling them.
• Use a person who is sufficiently independent of the matter where practicable.
• Give the complainant a clear outcome and, where appropriate, explain review or escalation options.
• Look for recurring themes and report serious or significant complaints to trustees.
• Publish a clear complaints procedure, including how fundraising complaints can be made and any external escalation route that applies, without exposing private staff or trustee contact details.

Records

• Complaints log; outcome; actions taken; anonymised trend reporting to trustees.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Make sure concerns about Freedom’s own conduct can be raised without relying solely on the person complained about. Keep independent escalation routes in restricted arrangements.

6. Whistleblowing and Speaking Up

Purpose. Gives people working with Freedom a safe route to raise serious concerns that may not fit the normal complaints process.

Who this covers. Trustees, employees, volunteers, contractors and others working on Freedom’s behalf.

Policy

• Freedom wants concerns raised early, especially about safeguarding, fraud, illegality, serious misconduct, data misuse or attempts to conceal wrongdoing.
• Freedom will not tolerate retaliation against anyone who raises a serious concern honestly. Statutory whistleblowing protection depends on the person’s legal status and the circumstances of the disclosure.
• This policy is not a confidentiality promise where Freedom must share information to protect someone or comply with law.

In practice

• Provide at least two internal escalation routes so a concern is not blocked by the involvement of one individual.
• Allow concerns to be raised in writing or verbally and keep access to information limited to those who need it.
• Assess whether specialist, regulatory or legal reporting is required.
• Record outcome and learning without circulating unnecessary personal details.

Records

• Restricted speaking-up log; investigation record where needed; Board oversight of significant themes.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Where a concern involves the chair, founder or safeguarding lead, it must be capable of being reported to an independent alternative or the appropriate external authority.

7. Serious Incident Reporting

Purpose. Ensures trustees identify and report serious incidents promptly and take action to limit harm.

Who this covers. Events or allegations involving significant harm, loss of charity money or assets, damage to property, serious disruption, or serious harm to Freedom’s work or reputation.

Policy

• Reporting a serious incident is part of good governance and does not by itself mean Freedom has done something wrong.
• Immediate protection, safeguarding and crime reporting take priority over regulatory paperwork.
• Trustees need enough information to make and evidence a reporting decision.

In practice

• Take immediate steps to prevent or minimise further harm, loss or damage.
• Notify police, safeguarding bodies, insurer, ICO, bank or other regulator where appropriate.
• Decide promptly whether a Charity Commission serious-incident report is required and who is authorised to submit it on behalf of the Board.
• Review the incident afterwards and update controls where needed.

Records

• Serious incident decision log; copy of any regulatory report; Board minutes; remedial-action record.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Record promptly whether a serious incident report to the Charity Commission is required, alongside any police, safeguarding or other regulatory referral.

8. Financial Controls and Fraud Prevention

Purpose. Protects Freedom’s money and assets and gives trustees reliable financial information.

Who this covers. All income, expenditure, banking, purchasing, donations, shop sales, grants, Gift Aid, expenses and assets.

Policy

• All trustees remain responsible for financial management even where bookkeeping or administration is delegated.
• Controls must fit Freedom’s current size and become stronger as income, staffing or programme complexity grows.
• No one person should control a transaction from start to finish where reasonable separation or an independent review can be achieved.
• Freedom does not create impressive-looking financial thresholds for funders; the Board approves limits that fit the charity’s real scale.

In practice

• Approve an annual budget and receive enough financial information to understand cash, income, expenditure, restricted funds, liabilities and significant variances.
• Maintain a Delegated Authority Schedule for spending, contracts, bank access, refunds, write-offs and commitments.
• Reconcile active bank and payment accounts regularly and normally monthly.
• Require supporting evidence for payments and independent approval of expenses claimed by the approver.
• Keep cash handling to a minimum. Where cash is used, record it, count it and bank it promptly, using a second check where the risk justifies one.
• Protect online banking and payment access with individual accounts and multi-factor authentication where supported.
• Escalate suspected fraud, theft or financial abuse and consider bank, insurer, police/Report Fraud and Charity Commission reporting.

Records

• Budget; management information; bank reconciliations; payment evidence; delegated authority; asset record; fraud/irregularity log.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Before spending grant money on printing, check quotations, grant restrictions, who owns or licenses the material, the real cost of set-up, printing and carriage, and the proper payment approval.

9. Reserves

Purpose. Sets a rational approach to the unrestricted funds Freedom keeps available for resilience and continuity.

Who this covers. Trustees and anyone preparing budgets, accounts or major funding proposals.

Policy

• There is no universal “correct” reserve. Freedom’s target must reflect its own commitments, income reliability and risks.
• Restricted funds are not treated as general reserves.
• Being below a target is not hidden. Trustees agree how to rebuild reserves without misrepresenting the financial position.

In practice

• Approve a reserves target or range after considering essential operating costs, safeguarding responsibilities, cash-flow timing, loss of funding, contractual commitments, technology, insurance and controlled closure costs.
• Monitor reserves during the year and explain any significant departure from the agreed target.
• Review the target before or after a significant increase in funding or obligations.
• Record the method used to calculate the target in the controlled financial schedule.

Records

• Board-approved reserves calculation; monitoring in management information; annual-report disclosure where required.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

10. Gift Acceptance, Refusal and Return

Purpose. Helps trustees accept support confidently while protecting Freedom’s purposes, independence and reputation.

Who this covers. Donations, major gifts, grants, legacies, gifts in kind, anonymous donations and other voluntary support.

Policy

• The normal starting point is to accept and keep a lawful donation because donations help Freedom carry out its purposes.
• A donation is not refused simply because a donor is unpopular. Decisions must be evidence-based and in Freedom’s best interests.
• Freedom will not accept unlawful funds, impossible conditions or donor control over safeguarding, beneficiaries, research findings, policy positions, staffing or trustee decisions.
• Returning a donation is not a routine customer-service decision; Freedom must have the legal power or obligation to do so.

In practice

• Check significant or unusual gifts according to the level of risk. This may include the donor’s identity, source-of-funds concerns, sanctions, unusual conditions, conflicts and possible private benefit.
• Put restrictions in writing and confirm that Freedom can administer and deliver them.
• Escalate substantial, unusual or potentially contentious gifts to trustees.
• Record the reasons for refusing or returning a significant gift and obtain legal or regulatory advice if the trustees are unsure about their power to act.
• Protect donor confidentiality but do not promise anonymity where law or regulation may require disclosure.

Records

• Gift due-diligence record for higher-risk cases; restriction agreement; conflict record; refusal/return decision.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

11. Fundraising and Donor Care

Purpose. Keeps Freedom’s fundraising lawful, respectful and transparent and protects people from pressure.

Who this covers. Public fundraising, digital appeals, events, community fundraising, major gifts, corporate support, legacies and third-party fundraising.

Policy

• Fundraising serves Freedom’s charitable purposes and is overseen by trustees.
• Appeals say clearly what money is being raised for. Freedom avoids accidentally creating a restricted fund through careless wording.
• Donors are treated fairly. Freedom does not exploit vulnerability, apply undue pressure or make claims it cannot evidence.
• Fundraising materials may be persuasive but must remain accurate about Freedom’s services, evidence and financial need.

In practice

• Follow the Code of Fundraising Practice and Charity Commission fundraising guidance.
• Use a clear public fundraising complaints route and learn from complaints.
• Check professional fundraisers, commercial participators and significant fundraising partners before appointment, and use written agreements where required.
• Provide volunteers with approved fundraising materials, safe cash/payment routes and boundaries on use of Freedom’s name.
• Respect communication preferences and data-protection rules.
• For donors in vulnerable circumstances, slow down or stop the interaction where necessary and never take advantage of confusion, distress or impaired decision-making.
• Keep fundraising costs and expected returns under review and report significant fundraising risks to trustees.

Records

• Fundraising plan; appeal copies; fundraising complaints; partner agreements; donor preference records; relevant due-diligence records.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

12. Restricted Funds and Major Grants

Purpose. Ensures restricted money is used for the purpose for which it was given and that major grants do not create hidden liabilities.

Who this covers. Restricted donations, grants, corporate funding and major programme agreements.

Policy

• Freedom accepts a restriction only where the purpose fits its objects and is clear enough to administer.
• A large grant is not automatically good for the charity. Trustees consider full delivery cost, capacity and risk before acceptance.
• Positive funder relationships never justify altering results or overstating delivery.

In practice

• Before acceptance, understand purpose, period, payment profile, eligible costs, outputs/outcomes, reporting, data, publicity, IP, safeguarding, termination and underspend provisions.
• Cost staffing, supervision, safeguarding, technology, accessibility, evaluation, administration and contingency where relevant.
• Track restricted income and expenditure separately in the accounting records.
• Any significant change to the agreed purpose of restricted funding must follow the proper legal or funder process; the money must not simply be redirected.
• Close significant grants properly, including financial reconciliation, final reporting, any outstanding obligations and the treatment of underspend or assets.

Records

• Grant agreement; approved budget; restricted-fund ledger; reports; change approvals; closure record.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Where funding would expand delivery beyond current capacity, trustees agree a practical delivery plan and cash-flow forecast before accepting it, and protect resources required for existing safeguarding responsibilities.

13. Risk Management

Purpose. Gives trustees a practical way to see the risks that could stop Freedom achieving its purposes and to act before they become crises.

Who this covers. Governance, safeguarding, operations, finance, fundraising, people, technology, data, reputation and external risks.

Policy

• Risk is part of charitable activity. The aim is informed action, not eliminating every uncertainty.
• The Board owns the risk framework; named people may manage individual risks.
• Risk appetite must reflect Freedom’s financial resilience, safeguarding responsibilities and capacity.

In practice

• Maintain a live risk register with risk, likelihood, impact, controls, owner, further action and review date.
• Review the highest risks often enough to manage them, and review the whole risk register at least once a year.
• Assess significant new projects, partnerships, grants and technology before commitment.
• Escalate rapidly changing or inadequately controlled risks immediately.
• Use incidents and near misses to improve controls.

Records

• Risk register; Board review record; project risk assessments; incident learning.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

14. Data Protection and Confidentiality

Purpose. Sets Freedom’s internal standard for lawful, fair and careful handling of personal information, including sensitive safeguarding information.

Who this covers. Personal data handled through enquiries, safeguarding, donations, shop orders, training, volunteers, events, research, mailing lists and digital services.

Policy

• Freedom collects only information it needs for a clear purpose and does not keep personal data “just in case”.
• Access is limited to people who need it for their role.
• Safeguarding information receives particular care. Information may still need to be shared where there is a serious risk, a legal requirement or a safeguarding duty.
• Public policy wording is not treated as proof that controls operate; Freedom keeps evidence of implementation.

In practice

• Keep the privacy notice current and maintain an internal record of the main ways Freedom uses personal information.
• Identify a lawful basis and any additional condition needed for special-category or criminal-offence data.
• Use data protection by design for new forms, projects, apps, surveys or systems and carry out a DPIA where high risk is likely.
• Use written processor terms where required and assess suppliers handling personal data.
• Respect rights requests and report personal-data breaches to the ICO where the legal threshold is met.
• Do not publish signatures, private contact details, bank details or other personal information simply because a governance document is public.

Records

• Privacy notices; processing record; DPIAs where needed; processor agreements; rights-request log; breach log.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Document the external call-handling provider’s data protection role, lawful sharing, access arrangements, secure onward transfer, retention and incident notification. A donated service is not exempt from these duties.

15. Records Retention and Disposal

Purpose. Prevents Freedom keeping personal or organisational records indefinitely without a reason while preserving records needed for safeguarding, law, finance and accountability.

Who this covers. Paper and electronic records, email, safeguarding, finance, Gift Aid, grants, contracts, complaints, governance, volunteer, research and donor records.

Policy

• Retention is based on purpose, legal need, safeguarding need and accountability, not convenience.
• Different records need different periods. Sensitive data is reviewed rather than automatically kept forever.
• Legal claims, regulatory enquiries or safeguarding reasons may justify a longer period in a particular case.

In practice

• Maintain a controlled Retention Schedule showing category, purpose, normal period, owner and disposal method.
• Review records when the period expires and delete, anonymise or justify further retention.
• Pause routine deletion where a relevant legal, safeguarding or regulatory hold is required.
• Dispose of confidential paper and electronic records securely.

Records

• Retention Schedule; disposal or review record for higher-risk categories; legal hold where relevant.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

16. Information Security and Cyber Security

Purpose. Protects Freedom’s systems, money, data and digital services against loss, misuse and cyber attack.

Who this covers. Email, websites, cloud storage, devices, payment systems, databases, social media, passwords and supplier access.

Policy

• Security should reflect the sensitivity of the information and the real risk, rather than how sophisticated a system appears.
• Individual accounts and least-privilege access are preferred to shared credentials.
• People, suppliers and process failures are treated as security risks alongside malware and hacking.

In practice

• Use multi-factor authentication on important systems where it is available, together with strong, unique passwords managed securely.
• Keep supported software updated and remove access promptly when roles end.
• Protect devices that hold sensitive information with appropriate encryption, locking and remotemanagement measures where practicable.
• Back up critical information and periodically confirm that recovery is possible.
• Keep an internal systems/access register and supplier list.
• Escalate suspected phishing, unauthorised access, data loss or malware promptly and preserve evidence.
• Use Cyber Essentials or comparable controls as a practical benchmark where they suit Freedom’s systems and risks.

Records

• Systems/access register; incident log; backup/recovery checks; supplier records; security review actions.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

17. Technology and Digital Safeguarding

Purpose. Ensures Freedom’s websites, App and other digital tools are described and managed safely and realistically.

Who this covers. Freedom-controlled or commissioned digital products, websites, apps, forms, alerts, online content and digital suppliers.

Policy

• Digital access can improve safety but can also leave traces on monitored devices or accounts.
• Freedom never promises that a digital service is invisible, anonymous, untraceable, fully secure or continuously available unless it can substantiate the claim.
• Historic download figures are reach measures, not current active-user figures or evidence that harm was prevented.

In practice

• Keep an internal record for each important digital asset, covering ownership, administration, supplier, contract or licence, data processed, maintenance, platform availability, accessibility, security and continuity.
• Review device-safety wording before major changes to the App or safeguarding content.
• Check privacy, accessibility, security and support arrangements before launching a digital tool or making a significant change to one.
• Ensure Freedom can retrieve its data and content if a supplier relationship ends.
• Review public availability claims when platforms, suppliers or service arrangements change.

Records

• Digital asset register; supplier agreements; privacy/security assessment; change records.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• School and online learning materials must include age-appropriate routes to help, accessible formats and clear safety advice. Never promise an immediate safeguarding response without confirmed capacity.

18. Business Continuity and Succession

Purpose. Keeps essential functions running if a key person, system, supplier or location suddenly becomes unavailable.

Who this covers. Critical governance, safeguarding, finance, website, donor, system and statutory functions.

Policy

• Freedom values individual expertise but does not deliberately build essential services around one person’s memory, passwords or availability.
• Continuity arrangements protect confidential information; “backup” does not mean giving everyone access to everything.
• Succession planning is part of resilience, not a judgement on any individual.

In practice

• Identify critical functions, key dependencies and minimum viable arrangements for disruption.
• Maintain organisational ownership or recoverable access to critical accounts where practicable.
• Document major funder relationships, statutory deadlines, supplier contacts and essential handover information.
• Provide alternative escalation routes where a founder, Chair, safeguarding lead or other key person is unavailable.
• Review trustee skills and succession needs periodically and whenever Freedom changes significantly.

Records

• Continuity plan; key-dependency register; emergency contacts in restricted schedule; annual review note.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

19. Intellectual Property, Publishing and Related Parties

Purpose. Makes ownership, permissions and financial arrangements clear where Freedom uses books, educational materials, campaign assets, media, photographs or other intellectual property.

Who this covers. Books, lesson resources, branding, campaign marks, websites, films, photographs, written content and software.

Policy

• Freedom only uses intellectual property where it owns it or has sufficient permission or licence.
• Where an author, publisher, supplier or rights-holder is a trustee, founder or connected person, the relationship is declared and managed rather than hidden.
• A related-party relationship is not automatically improper; the Board must be able to show lawful authority, charity benefit and appropriate value.

In practice

• Maintain an IP and Publishing Register stating the owner, rights, licence, restrictions and any payment or royalty arrangement for important assets.
• For books sold or distributed through Freedom, record who owns copyright, who publishes, where sales income goes, what costs Freedom bears and how Freedom benefits.
• Apply the conflicts policy to related-party arrangements and exclude an interested trustee from decisions where required.
• Get permission for photographs, recordings and third-party material where needed.

Records

• IP/Publishing Register; licences/permissions; related-party decisions; contracts.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• For every educational book, record its author, copyright owner, publisher, printer, set-up costs, usage rights and any related-party interests before spending charitable funds.

20. Evidence, Evaluation and Public Claims

Purpose. Protects Freedom’s credibility by separating what was done, who was reached, what changed and what can genuinely be attributed to the charity.

Who this covers. Website copy, reports, bids, fundraising, media, awards, campaigns, training, research, books, App figures and policy claims.

Policy

• Reach is not the same as outcome, and outcome is not automatically the same as impact.
• Freedom will say when a figure is cumulative, self-reported, historical, estimated or externally verified.
• Awards, registrations and endorsements show recognition or status; they are not outcome evidence.
• Freedom will correct significant public errors rather than defend a claim that cannot be supported.

In practice

• For important public claims, keep the source, date, definition, denominator where relevant, limitations and the name or role of the reviewer.
• Agree evaluation measures at the start of substantial funded programmes where possible.
• Do not turn attendance or satisfaction feedback into claims of changed professional practice or reduced harm without stronger evidence.
• Use survivor or beneficiary stories only with appropriate consent, safeguarding and context and never imply a story is statistically representative.
• Maintain a clear process for correcting significant factual errors.

Records

• Claims/evidence register; evaluation plan; source files; consent record where relevant; corrections log.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

21. Partnerships, Corporate Support and Brand Use

Purpose. Helps Freedom work with companies, foundations, public bodies and other organisations without losing independence or exposing beneficiaries to avoidable risk.

Who this covers. Corporate partnerships, sponsorship, co-branded campaigns, charity-of-the-year relationships, joint events and strategic collaborations.

Policy

• Partnerships must further Freedom’s purposes and be in the charity’s best interests.
• Funding does not buy control of safeguarding, evidence, beneficiaries or Freedom’s independent judgement.
• Brand association is considered separately from whether a donation can lawfully be accepted.

In practice

• Check significant partners before an agreement is made. The review should cover fit with Freedom’s purposes, reputation, financial or legal concerns, safeguarding, data, conflicts and the likely public association.
• Use a written agreement for significant partnerships, covering purpose, money, responsibilities, data, safeguarding, brand, intellectual property, publicity, reporting, termination and dispute handling.
• Approve use of Freedom’s name and logo and withdraw permission where terms are breached.
• Do not allow a partner to imply endorsement beyond the agreed relationship.

Records

• Partner due-diligence record; agreement; brand approval; monitoring/review record.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

22. Equality, Dignity and Non-Discrimination

Purpose. Sets a respectful standard for Freedom’s work while recognising that safeguarding sometimes requires discussion of sex, age, disability, culture, religion, family and other sensitive factors.

Who this covers. Trustees, staff, volunteers, services, training, events, recruitment, communications and partnerships.

Policy

• Freedom treats people with dignity and does not tolerate unlawful discrimination, harassment or victimisation.
• Prevention work does not stereotype communities or treat abuse as inherent to a religion, ethnicity or nationality.
• Freedom can discuss patterns of harm honestly while focusing on behaviour, risk and rights.
• Accessibility is considered when Freedom plans services, information and events.

In practice

• Use fair recruitment and volunteer processes.
• Make reasonable adjustments where the Equality Act requires them, and consider wider accessibility improvements where practicable.
• Challenge discriminatory conduct and route serious concerns through safeguarding, complaints or conduct procedures.
• Review public language to avoid stigma while retaining accurate safeguarding terminology.

Records

• Relevant complaints or conduct records; reasonable-adjustment records where needed; periodic review.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Check public materials for readable text, clear headings, keyboard navigation, meaningful image descriptions and accessible alternative formats. Do not rely on PDFs alone when a webpage is feasible.
• Equity means recognising barriers. A single route to help will not suit everyone; consider different accessible formats, safe communication methods and circumstances.
• Diversity means recognising that people with shared characteristics do not all have the same experience. Inclusion means being heard, participating safely and being free not to disclose personal history.
• Survivor involvement in educational materials and focus groups must be voluntary, consent-based and supported by safeguarding and confidentiality arrangements. Use findings to improve the work without exposing personal information.

23. Health, Safety and Lone Working

Purpose. Protects people carrying out Freedom activity in offices, schools, events, travel, home working and other settings.

Who this covers. Trustees, staff, volunteers, contractors and organised Freedom activities.

Policy

• Freedom takes reasonable steps to prevent foreseeable harm. Being a small charity is not a reason to accept avoidable risk.
• Host organisations retain their own responsibilities; Freedom still considers risks created by its own activity.
• Lone working and home visits, if undertaken, require specific consideration because help may not be immediately available.

In practice

• Assess the main risks in activities such as travel, events, school visits, lone working, violence or aggression and emergencies where relevant.
• Confirm host-site arrangements for significant visits or events.
• Provide a check-in or escalation arrangement for higher-risk lone activity.
• Record accidents and near misses and seek medical/emergency assistance where needed.
• Review insurance against actual activities.

Records

• Risk assessments where required; accident/near-miss log; insurance review; lone-working arrangements.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

24. Media and Public Communications

Purpose. Keeps Freedom’s public statements accurate, safe and consistent without making communications unnecessarily bureaucratic.

Who this covers. Website, press, broadcast, social media, speeches, reports, newsletters and public statements made on Freedom’s behalf.

Policy

• Accuracy and safeguarding come before speed or publicity.
• Freedom distinguishes organisational positions from personal views.
• Case information is never disclosed for publicity simply because it is compelling.
• Legal and policy claims are dated or reviewed where change is likely.

In practice

• Authorise suitable spokespeople and make clear when additional Board approval is needed for significant policy or reputational matters.
• Check high-risk factual claims against reliable sources and the Evidence and Public Claims Policy.
• Obtain appropriate consent and safeguarding review before using identifiable stories, photographs or recordings.
• Correct significant errors promptly and retain an archive note where historical material may otherwise mislead.

Records

• Approved statements where needed; consent records; source notes; correction and archive records.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

25. Gifts, Hospitality and Anti-Bribery

Purpose. Protects Freedom from decisions being influenced, or appearing to be influenced, by personal gifts, hospitality or improper inducements.

Who this covers. Trustees, staff, volunteers and others acting on Freedom’s behalf.

Policy

• Modest hospitality can be legitimate; anything intended to influence a decision improperly is not.
• Cash or cash-equivalent personal gifts connected to a Freedom decision are not accepted.
• No one offers, promises or accepts a bribe, kickback or secret commission.

In practice

• Declare gifts or hospitality that could reasonably create a sense of obligation or perceived conflict.
• Record higher-value or sensitive gifts/hospitality in the controlled register and refer uncertainty to an unconflicted trustee.
• Apply the conflicts policy where a donor, supplier or partner also offers a personal benefit.
• Report suspected bribery, fraud or corruption promptly.

Records

• Gifts and hospitality register; conflict record; investigation/escalation record where necessary.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

26. Responsible Use of Artificial Intelligence and Automation

Purpose. Allows Freedom to use useful technology without outsourcing judgement, confidentiality or accountability.

Who this covers. Generative AI, automated drafting, transcription, analysis, image tools, chatbots and similar systems used for Freedom work.

Policy

• AI output is assistance, not evidence. A human remains responsible for decisions, public claims and safeguarding.
• Confidential safeguarding information, donor data, passwords, bank details and other sensitive personal information are not entered into public consumer AI tools unless Freedom has specifically assessed and authorised the processing.
• AI-generated people, survivor stories, endorsements, evidence or product images must not be presented as genuine.
• Freedom does not describe text as independently researched merely because an AI system produced references.

In practice

• Use human review for public, legal, policy, fundraising and safeguarding content.
• Check factual claims against primary or reliable sources where accuracy matters.
• Assess data-protection, contractual and confidentiality terms before using AI with personal or sensitive information.
• Keep genuine photographs of Freedom’s people, books, badges and products authentic; do not alter them in a way that misrepresents reality.
• Disclose AI use where law, contract, funder rules or the context requires it.

Records

• Approved-tool guidance where needed; DPIA or supplier review for higher-risk use; evidence and source records for important claims.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

27. Research, Surveys and Consultation

Purpose. Ensures Freedom learns from people responsibly and does not present informal consultation as stronger research than it is.

Who this covers. Surveys, interviews, focus groups, school consultation, professional feedback and research partnerships.

Policy

• The strength of the method should match the claim Freedom intends to make.
• Participation is voluntary unless another lawful basis and process clearly applies.
• Questions about abuse can create distress or disclosure risk and need safeguarding planning.
• Data collection involving children or high-risk sensitive information receives additional scrutiny.

In practice

• Before significant research begins, define its purpose, population, recruitment, participant information or consent, data fields, safeguarding route, analysis and retention.
• Use ethics or independent review where the design, population, sensitivity or proposed publication warrants it.
• Report sample size, response basis, limitations and any important exclusions honestly.
• Do not identify individuals or communities as “at risk” from survey data unless the evidence and safeguarding basis support that conclusion.
• Use appropriate agreements for university or external research partners covering roles, data, publication and safeguarding.

Records

• Research plan; participant information/consent where relevant; data-management plan; analysis record; publication approval; partner agreement.

Review. Once a year, and sooner if the law, Freedom’s work or the level of risk changes.

Additional practice

• Record whether beneficiaries and survivors helped shape material before publication, what changed following their feedback and what cannot safely be shared. Trustee lived experience alone does not prove that a particular project was co-designed.