SAFEGUARDING & ANTI-DISCRIMINATION

Talent ProMax League (“TPL”) is committed to creating a football environment in which every child, young person and adult at risk is safe, respected, listened to and able to participate without abuse, exploitation, neglect, bullying, harassment or discrimination. The welfare and best interests of the child are paramount.

TPL recognises that safeguarding is everyone’s responsibility. All directors, employees, coaches, managers, medical personnel, match officials, contractors, production crews, photographers, scouts, volunteers, apprentices, work-experience participants and partners acting on behalf of TPL must understand and fulfil their safeguarding responsibilities.

TPL will use prevention, safer recruitment, education, risk assessment, clear reporting routes and prompt referral of concerns. This reflects FA’s safeguarding framework and FA Guardians guidance, and The FA’s approach of preventative safeguards, easy reporting and swift action with statutory agencies.

This Policy applies to all TPL activities and environments, including matches, training or assessment sessions, registration, tournaments, award events, travel, changing areas, medical provision, hospitality, media production, interviews, photography, social media, websites, player profiles, digital scouting, messaging, apprenticeships, work experience and community activities.

It applies whether activity is delivered directly by TPL or by a person or organisation acting for TPL. Contracts with delivery partners should require equivalent safeguarding standards and clear escalation arrangements.

For this Policy, a child is any person who has not reached their 18th birthday. A player aged 16 or 17 is therefore still a child even if playing in an open-age or adult competition. TPL will not treat 16- and 17-year-old players as adults for safeguarding purposes.

The FA specifically requires safeguards for under-18s participating in open-age football. TPL will identify all under-18 players and ensure that relevant coaches, managers, medics, and other adults working with them meet the applicable safeguarding and safer recruitment requirements.

• The welfare, safety, dignity and best interests of children come first.
• Every child has an equal right to protection, regardless of age, disability, sex, gender reassignment, race, ethnicity, religion or belief, sexual orientation, pregnancy/maternity, socio-economic background, football ability or other status.
• Children should be heard and taken seriously. Their views should be considered according to age and understanding.
• Safeguarding must be embedded in governance, recruitment, competition operations, digital systems, media and partnerships—not treated as a separate administrative exercise.
• Concerns will be acted on promptly. TPL will not investigate suspected criminal abuse itself where doing so could compromise a statutory investigation.
• Information will be shared on a need-to-know basis when necessary to protect a child or comply with law; safeguarding is not prevented by promises of absolute confidentiality.
• TPL will work with parents/carers, The FA/County FA, police, children’s social care, the Local Authority Designated Officer (“LADO”) and other competent bodies where appropriate.

TPL intends this Policy to reflect FA’s safeguarding approach. FA’s 2026 Safeguarding Policy formalises a duty-of-care framework across football, while FA Guardians guidance promotes accountability, child-centred policies, safeguarding risk assessment, safer recruitment, codes of conduct, reporting mechanisms, education and appropriate response.

FA alignment does not mean that TPL is endorsed, certified or affiliated by FA. Where TPL is affiliated to or sanctioned by The FA, a County FA or another competent football authority, the applicable safeguarding regulations and reporting requirements of that body will also apply. If a governing body rule sets a higher safeguarding standard than this Policy, TPL will follow the higher applicable standard.

TPL will take reasonable steps to prevent unsuitable people from working with children. Recruitment for child-facing roles will include role descriptions, identity and eligibility checks, employment/volunteer history, references, safeguarding questions, appropriate interviews and required criminal-record checks.

Under the FA framework, people aged 16 or over undertaking potentially unsupervised roles directly working with children may require an Enhanced DBS check, including the Children’s Barred List, where the role is legally eligible. TPL will follow the current FA/County FA and statutory eligibility rules rather than unlawfully requesting checks.

• No person barred from a regulated activity may be placed in a role from which they are prohibited.
• DBS disclosure information will be handled confidentially and in accordance with applicable rules.
• A DBS certificate is only one part of safer recruitment and does not replace supervision, training, references, codes of conduct or ongoing vigilance.
• TPL will reassess suitability when a safeguarding concern, relevant criminal matter or material change in circumstances arises.

All personnel must receive safeguarding information appropriate to their role before undertaking unsupervised child-facing duties. Coaches, managers, medics, welfare personnel, and others in designated roles must complete the safeguarding education required by the FA/County FA, or other applicable governing body and keep it up to date.

Induction will cover recognising abuse, professional boundaries, responding to disclosures, reporting, online communication, photography, changing rooms, transport, anti-bullying, discrimination and whistleblowing.

Adults in positions of responsibility must maintain clear professional boundaries. They must never use their position to groom, exploit, intimidate, humiliate or develop an inappropriate relationship with a child.

• Treat children fairly, respectfully and without favouritism.
• Use age-appropriate, positive coaching and communication.
• Avoid being alone with a child where reasonable alternatives exist; activities should be observable and interruptible.
• Do not engage in sexualised conduct, sexual jokes, inappropriate touching, hazing or humiliating initiation practices.
• Do not consume alcohol or misuse drugs while responsible for children.
• Do not give a child alcohol, tobacco, nicotine products, illegal drugs or inappropriate medication.
• Do not exchange personal gifts, money or favours in a way that creates dependency, secrecy or preferential treatment.
• Do not enter romantic or sexual relationships with an under-18 participant. Adults must also comply with all legal and football-specific position-of-trust restrictions.
• Never ask a child to keep a safeguarding secret.

Safeguarding concerns may include physical abuse, sexual abuse, emotional abuse, neglect, grooming, exploitation, domestic abuse, bullying, cyberbullying, discriminatory abuse, hazing, trafficking, child criminal exploitation, child sexual exploitation, harmful sexual behaviour, self-harm concerns, online abuse, abuse by peers, or unsafe practice by an adult.

A concern does not need to be proven before it is reported. Staff should report reasonable concerns and allow trained safeguarding/statutory professionals to determine the appropriate response.

If a child tells you they have been harmed or are worried about something:

1. Stay calm, listen carefully and take the child seriously.
2. Do not promise secrecy. Explain that you may need to tell people who can help keep them safe.
3. Do not interrogate, investigate or ask leading questions. Ask only what is necessary to establish immediate safety.
4. Reassure the child that speaking up was the right thing to do; do not blame them.
5. Record what was said as soon as possible, using the child’s own words where practical, and note date, time, location and persons present.
6. Report immediately to the TPL DSO/Welfare Officer. If the DSO is implicated, report to the deputy, the senior safeguarding authority, the County FA/The FA, or a statutory agency, as appropriate.
7. If a child is in immediate danger or a crime is in progress, call 999. Do not delay emergency action while trying to contact TPL.

Anyone with a concern about a child’s welfare or an adult’s behaviour towards an under-18 must report it promptly. TPL will maintain simple reporting routes for players, parents, teams, staff and spectators.

• Immediate danger/emergency: Police – 999.
• Non-emergency police matter: 101 where appropriate.
• Children’s Social Care: contact the local authority responsible for the child/event where a statutory referral is required.
• Allegation against a person working with children: TPL will consider referral to the relevant LADO and governing body in accordance with statutory/football procedures.
• Football safeguarding concern: where applicable, refer through the relevant Club/League/County FA DSO or The FA Safeguarding Team.
• Urgent safeguarding concerns: The FA states that urgent safeguarding concerns can also be supported through the FA/NSPCC route; current details should be verified on the FA safeguarding website before publication.

TPL will not require a child or reporter to confront the person who is the subject of a concern. Retaliation against a person who raises a genuine safeguarding concern is prohibited.

Any allegation that an adult working with children has harmed a child, may have harmed a child, committed a relevant offence, or behaved in a way indicating they may pose a risk must be referred immediately to the DSO and managed under applicable statutory and football procedures.

TPL may impose precautionary measures, including temporary suspension or removal from child-facing duties, while a matter is assessed. Such measures are neutral risk-management steps and are not findings of guilt.

TPL will cooperate with police, children’s social care, the LADO, the FA/County FA and DBS where referrals or information sharing are legally required or appropriate.

Because TPL may include 16- and 17-year-old players in open-age environments, additional safeguards are required. Team managers and relevant personnel must know which participants are under 18 while protecting unnecessary disclosure of their personal information.

• Applicable coaches, managers and medics must meet current FA safer-recruitment, DBS and safeguarding requirements.
• Under-18s must receive clear safeguarding information and know who the TPL Welfare Officer is and how to report concerns.
• Adult teammates and staff must understand that 16- and 17-year-olds remain children in law.
• Changing, travel, accommodation, social events, media and digital communication must be risk-assessed for mixed-age participation.
• Alcohol-centred team activities must not place under-18s in inappropriate or unsafe situations.
• Any disciplinary, interview or formal hearing involving an under-18 should include appropriate safeguarding arrangements and, where required by governing-body rules, a responsible adult.

TPL values parents and carers as safeguarding partners. They should receive clear information about competition arrangements, consent, emergency contacts, medical needs, photography/media, travel and reporting concerns.

For younger children, appropriate parental/carer consent will be obtained for participation. The FA notes that 16- and 17-year-olds will often make their own participation decision, although parent/carer involvement may still be appropriate or required in particular circumstances.

TPL may take safeguarding action without parental consent where seeking consent would place a child at greater risk, prejudice an investigation or conflict with lawful safeguarding duties.

TPL has zero tolerance for bullying, discriminatory abuse, harassment, threatening behaviour or victimisation. Reports will be taken seriously whether behaviour occurs face-to-face, in changing rooms, in spectator areas, via team messaging, or on social media.

Responses may include safeguarding action, support for the child, behavioural interventions, removal from activity, competition discipline, referral to governing bodies or statutory authorities, and other proportionate measures.

TPL’s digital scouting and media model creates specific safeguarding responsibilities. Public exposure must never override a child’s welfare or privacy.

• Adults acting for TPL should use approved organisational channels for football-related communication with children.
• One-to-one private messaging between an adult in a position of responsibility and a child should be avoided; communications should include a parent/carer or another authorised adult where appropriate and follow current FA guidance.
• Staff must not use disappearing-message features or personal social-media accounts to create secret communications with children.
• Children’s personal phone numbers, home addresses, precise locations, school details or private contact information must not be publicly displayed on scouting profiles.
• Direct contact functionality between scouts/adults and under-18 players must be safeguarded, verified and appropriately mediated.
• Reports of grooming, sexual messages, threats, extortion or exploitation online must be escalated immediately.

TPL should maintain moderation, access controls, audit trails, and reporting tools that are proportionate to the digital scouting platform’s risks.

TPL intends to record matches and create highlights and media. Photography and filming of children must be managed in accordance with safeguarding, privacy, and data protection requirements.

• Registration materials must clearly explain anticipated filming, photography and media uses.
• Where consent is required, it must be properly obtained and recorded.
• No images should be taken in toilets, showers or changing areas.
• Images should not be accompanied by unnecessary personal details that increase safeguarding risk.
• Media crews and photographers must be authorised and briefed on TPL safeguarding rules.
• One-to-one interviews with children should take place in an observable environment with appropriate adult oversight.
• A child’s refusal or discomfort about an interview or optional promotional activity should be respected.

Match recording needed for legitimate competition purposes should be distinguished from optional promotional/commercial uses, with appropriate notices and controls.

TPL will risk-assess any changes to arrangements, especially where teams include both adults and under-18s. Adults must respect privacy and avoid being present unnecessarily while children are changing.

• Photography, video and mobile-device camera use are prohibited in changing and shower areas.
• Where mixed-age teams use changing facilities, TPL/teams must adopt arrangements appropriate to the venue and age profile.
• Adults should not shower or change at the same time and in the same space as children, where avoidable.
• Any assistance with intimate or personal care must be necessary, agreed, appropriately planned and consistent with the child’s dignity and relevant safeguarding guidance.

Travel and overnight activity involving children must be planned and risk-assessed. TPL will obtain appropriate information and consent, provide emergency arrangements, maintain suitable supervision and set clear behavioural expectations.

• Avoid routine one-to-one transport of a child by an adult unless appropriately authorised and risk-managed.
• Drivers must be suitable, licensed and insured for the relevant use.
• Rooming arrangements must protect children’s privacy and safety; adults should not share bedrooms with children except in properly justified parent/carer circumstances.
• Children must have a clear way to contact a safeguarding lead or trusted adult during trips.
• International travel requires additional consideration of local law, emergency arrangements, travel documents, medical needs and governing-body requirements.

TPL will provide appropriate first aid and medical arrangements for its events. Parents/carers and players should provide relevant emergency and medical information through secure channels.

Emergency treatment should not be delayed where necessary to protect life or prevent serious harm. Medical information will be shared only with those who reasonably need it.

Coaches and staff must not pressure an injured child to continue playing against medical advice or where doing so creates an unreasonable welfare risk.

TPL events involving under-18s have a missing-child procedure. If a child is reported missing, the event safeguarding lead and security/venue management should be informed immediately, relevant areas checked without compromising wider safety, the parent/carer contacted, and police involved promptly where circumstances warrant. Staff must not leave other children unsupervised while searching.

TPL’s family-friendly matchday model may include crowds, music, entertainment, celebrities, giveaways and media. Safeguarding risk assessments must address crowd movement, access to players, photography, lost children, changing areas, alcohol, toilets, VIP/media access, pitch incursions and emergency procedures.

Security personnel must know how to escalate child-welfare concerns and should work with the TPL safeguarding lead rather than treating safeguarding solely as a crowd-control issue.

Access to children is a privilege, not a commercial entitlement. Scouts, agents, sponsors, celebrities, influencers, media guests and VIPs must comply with TPL safeguarding rules.

• Unverified adults must not receive unsupervised access to children or private child contact data.
• Scouting discussions involving an under-18 should use safeguarding-appropriate channels and comply with applicable FA/FA agent and registration rules.
• Sponsors must not use TPL access to contact or market directly to children in an inappropriate manner.
• Photo opportunities and meet-and-greets involving children should be supervised and risk-assessed.

TPL may provide apprenticeships and work experience in sales, marketing, finance, management, digital skills, hospitality and project management. If a participant is under 18, TPL’s child-safeguarding arrangements apply in addition to employment, education, and health and safety requirements.

Placements must have clear supervision, suitable tasks, appropriate working hours, safe transport expectations and a named person to whom the young person can report concerns.

TPL also seeks to protect adults who may be at risk of abuse or neglect. Where applicable, TPL will follow the principles of the Care Act 2014 and the FAs’ safeguarding adults framework. Concerns about an adult at risk will be referred to the appropriate safeguarding lead and, where required, the statutory authority.

Safeguarding records will be factual, dated, securely stored and accessible only to authorised people. Records should distinguish observation, disclosure, action and professional opinion.

TPL will comply with data-protection law but recognises that data protection does not prevent proportionate information sharing for safeguarding. Information may be shared without consent where necessary and lawful to protect a child, prevent serious harm or meet statutory/regulatory obligations.

Safeguarding records must not be kept in ordinary team chats or unsecured personal devices.

TPL encourages personnel to raise concerns about unsafe practice, failures to report, inappropriate conduct or attempts to conceal safeguarding matters. Genuine concerns raised in good faith will be treated seriously. No person should suffer retaliation for making a safeguarding report or cooperating with an investigation.

Breach of this Policy may result in removal from duties, suspension, termination of employment/engagement, exclusion from TPL activity, competition sanctions, referral to the FA/County FA, DBS, professional/regulatory bodies, police or statutory safeguarding agencies, depending on the circumstances.

TPL’s internal action does not replace criminal, statutory, or football regulatory processes.

TPL will carry out proportionate safeguarding risk assessments before activities involving children. Higher-risk activities, including mixed-age football, overnight travel, large events, digital scouting, extensive filming and direct scout access, require specific safeguards and named responsibility.

Risk assessments should be reviewed when circumstances change, after an incident or near miss, and at least as part of the annual safeguarding review.

The Board and DSO will review the implementation of safeguarding at least annually. The review should consider incidents and themes, recruitment compliance, DBS/training status, player and parent feedback, digital risks, partner compliance, changes to FA requirements and lessons from events.

This Policy will also be reviewed after a serious safeguarding incident, a major operational change, or a relevant change in law or football regulation.