CODE OF CONDUCT POLICY

This Code of Conduct defines expected standards of behaviour for all apprentices engaged with Digital Native UK. It applies during all apprenticeship activities, including online sessions, face‑to‑face meet‑ups, OTJT and within the workplace.

Principles

Digital Native UK commits to providing a safe, inclusive, respectful learning environment; ensuring apprentices contribute positively; and fulfilling statutory obligations including Safeguarding, Prevent, Equality & Diversity, and Health & Safety.

Attendance

Digital Native’s apprenticeships are planned around apprentices completing their Off The Job Training flexibly, taking into account the needs of their employer. Apprentices have one day per week dedicated to their apprenticeship and for three weeks in a month, this day will be delivered remotely over Teams and on the fourth week, there is the option to replace the remote day and join one of Digital Native’s face-to-face meet ups.

Remote delivery is 9:30am–4:30pm with a 30‑minute break and face-to-Face meet ups are 10.00 – 16.00 to allow for commuting time.

Apprentices must attend all scheduled sessions and absences must be reported by 9:00am.

Unreported absences will be reported to the employer and ongoing attendance concerns may be shared with employers and parents/guardians (for children or vulnerable adults).

Attendance and punctuality are the responsibility of all apprentices and will be closely monitored by Digital Native coaches with OTJT being recorded in the apprentices OTJT tracker.

Where attendance and/or punctuality does not meet the above, the apprentice’s employer will be informed.

Digital Native recognise that from time-to-time apprentices may be unable to attend their nominated apprenticeship day. In these circumstances apprentices must inform their coach or email the attendance email address before 9am on the day of absence and the apprentice’s employer will be notified of this absence.

Behaviour Expectations

Apprentices must demonstrate professionalism, respect to all, punctuality, active engagement, appropriate language and compliance with Digital Native staff instructions.

Apprentices will be supported to develop positive relationships both at work and in their personal lives and have a clear understanding and display British values.

Inclusion, Equality & Adjustments

Digital Native supports disadvantaged learners, SEND learners, vulnerable learners, and those facing barriers to maximise their potential and reasonable adjustments will be made where appropriate.

In all interactions with Digital Native (online, face to face, 1-2-1) learners should feel safe and able to effectively engage with their learning.

Where needs are identified during initial assessment and onboarding, the agreed reasonable adjustments will be regularly reviewed by the coach.

Safeguarding

Digital Native maintains safer recruitment, staff safeguarding training, reporting pathways, multi‑agency work, and a culture enabling apprentices to report concerns.

Prevent Duty

Apprentices must not engage in extremist, discriminatory, or radicalising behaviour. Digital Native monitors risks and reports concerns when necessary.

Face‑to‑Face Conduct

Apprentices will treat people with respect, listen to those with differing points of view, move calmly, use designated eating areas, follow H&S signage, use litter bins and treat facilities with care.

Dress Code

For all apprenticeship activities, (online and face-to-face) apprentices are expected to wear clothing that is clean, tidy, with no offensive slogans, symbols or graphics and suitable for a professional learning environment.

Mobile Phones

Apprentices are expected to comply with DN123 Mobile Phone Policy.

Plagiarism

Apprentices are expected to comply with DN32 Plagiarism Policy.

Prohibited Items & Substance Misuse

Apprentices are strictly prohibited from using or being under the influence of illegal drugs, alcohol, tobacco/vapes and weapons. There is a zero‑tolerance for being in possession of these items or drug dealing and being in breach of this will result in the apprentice being removed from the programme.

Online Behaviour

During all apprenticeships interactions via Teams cameras will be on, with blurred backgrounds unless agreed otherwise and apprentices are expected to display professional conduct and respect to all, including an appropriate dress code.

Leadership & Governance

Leaders maintain high behavioural expectations for all apprentices and create an inclusive culture that promotes a positive learning environment for everyone. Leaders will monitor attendance / behaviour / safety and use data to ensure safeguarding compliance and promote belonging.

Reporting Concerns

Apprentices are encouraged to raise any concerns either with their coach, DSL or a director. Examples of concerns that apprentices would be expected to raise with a member of staff include bullying, harassment, radicalisation, mental‑health concerns, discrimination. (Please see the Safeguarding and Prevent Duty Policy for detailed information on how concerns regarding these areas will be reported and escalated)

Disciplinary Actions

Where an apprentice is alleged to be in breach of this code of conduct, this will be investigated. Where action needs to be taken, this could include verbal or written warning to the apprentice, informing the employer, removal from the programme and / or referral to a third party including the police.

Media Contact

Where an apprentice observes or is involved in an incident or issue it is important that this is reported to Digital Native and their employer and where necessary, a director of Digital Native UK will deal with all media matters.

Review Cycle

This policy is reviewed annually or upon publication of government updates and revised legislation.

THE COMPLAINTS POLICY

Digital Native is committed to delivering high‑quality apprenticeship provision where all learners feel safe, supported, respected and able to raise concerns without fear of disadvantage. Complaints are an important source of feedback and contribute directly to our continuous improvement processes and leadership oversight. All complaints will be taken seriously, handled promptly, and used to strengthen the quality of education, training, and learner experience.

PURPOSE

This policy sets out a clear, fair and transparent process for apprentices and other stakeholders to raise concerns. It ensures:

• Learners and stakeholders know how to raise issues quickly and safely.

• Leaders and managers respond appropriately

• Complaints inform organisational self‑assessment, quality improvement planning and governance reporting.

• All parties are treated with dignity, impartiality and without discrimination.

SCOPE

This policy applies to all apprenticeship and training services delivered by Digital Native. It covers concerns relating to:

• Training, coaching, and assessment

• Behaviour or conduct of staff

• Quality or timeliness of services

• Administrative or operational processes

N.B. Where the word Learner is used this applies equally to employers and stakeholders.

N.B. Safeguarding concerns must be raised immediately via the Safeguarding Policy and are not managed through this procedure.

HOW TO MAKE A COMPLAINT

We encourage learners to raise concerns as early as possible so they can be resolved quickly and informally where appropriate. Complaints can be submitted via any of the following routes:

• Coach (either verbally or email)

• Feedback form (these are reviewed by the Board of Directors)

• Email: hello@dn‑uk.com (this mailbox is monitored by the Board of Directors)

• Director (either verbally or email)

• Phone: 0121 623 7230 – Option 2

We also welcome positive feedback to help identify strengths and share good practice across the organisation and this is captured by:

• Feedback forms (Apprentice and Employer)

• Direct communication – verbal and email)

DEFINITION OF A COMPLAINT

A complaint is any expression of dissatisfaction about a service, decision, action or behaviour which the complainant believes has negatively affected their experience. Issues should normally be raised with the relevant staff member before initiating the formal process.

PRINCIPLES OF HANDLING COMPLAINTS

• Confidentiality: All complaints will be handled sensitively. Where confidentiality cannot be maintained, the reasons will be explained.

• Timeliness: We respond promptly at all stages.

• Impartiality: Investigations will be objective and evidence‑based.

• Accessibility: Support will be offered to any learner requiring help to submit or present their complaint.

• Continuous Improvement: information from complaints will inform the Quality Improvement Plan (QIP) and leadership monitoring.

RESPONSE TIMESCALES

• Acknowledgement: within 2 working days

• Full response: within 5 working days, or an update with expected resolution timeframe

COMPLAINTS PROCEDURE

Stage 1 – Informal Resolution

Once a complaint has been raised (see How to Make a Complaint) the aim is to resolve this quickly and informally.

Learners may request an informal meeting with a director within 2 days of making the compliant and the aim is to clarify the concern and agree solutions quickly. If resolved, a brief record is retained for quality monitoring and improvement and no further action will be taken.

Stage 2 – Formal Investigation (Formal 1)

If unresolved, the complaint will be escalated to director will meet with the relevant parties to review the issue.
A written summary of actions and timescales will be shared with the learner within 3 working days.

If the matter remains unresolved within the agreed timescale, the learner may progress to Stage 3.

Stage 3 – Governance Review (Formal 2)

The learner must submit a written complaint to a Director within 10 days of Stage 2 concluding.

The Director will:

• Acknowledge receipt

• Schedule the complaint for review by the Board of Directors/Governance Board

• Notify external agencies if required

The Board will consider the complaint within 28 working days and record:

• Findings

• Decision

• Required actions

Possible outcomes include:

• Complaint upheld (actions such as staff training, supervision, counselling, procedural changes)

• Complaint dismissed

• Complaint redirected to another procedure

All outcomes are logged and reported through leadership and governance structures.

EQUALITY, DIVERSITY AND INCLUSION

All learners have the right to raise complaints without discrimination. Digital Native promotes the fundamental British Values of democracy, rule of law, individual liberty, and mutual respect and tolerance. These principles underpin this policy and guide our approach to fair treatment.

EXTERNAL ESCALATION

If a learner has completed all internal stages and remains dissatisfied, they may escalate their concerns to:

Education and Skills Funding Agency (ESFA) and guidance is available on the GOV.UK website.

Awarding organisations and End‑Point Assessment (EPA) organisations may also be contacted where relevant to assessment or certification queries.

ASSESSMENT, EXAMINATION AND EPA APPEALS

Learners may appeal assessment decisions they believe to be unfair:

1. Raise concern with the coach within 2 weeks of receiving feedback.

2. Submit a formal appeal to the Curriculum Director within 2 weeks if unresolved.

3. The Curriculum Director reviews evidence and responds.

4. If still unresolved, the appeal progresses to the EPA organisation.

5. Learners may then appeal to the awarding body within 7 days of the EPA decision.

All appeals are logged and monitored by the Quality Manager.

QUALITY ASSURANCE

The directors oversee the implementation and effectiveness of this policy.
This includes:

• Reviewing complaint trends

• Feeding outcomes into the Self‑Assessment Report (SAR) and QIP

• Ensuring records are kept securely and confidentially

• Reporting to senior leadership and governance boards

LEARNER SUPPORT

At any stage, learners may request guidance or support from:

• A member of the senior management team

• Their coach (where appropriate)

Support is confidential, and learners may withdraw their complaint at any time.

REVIEW CYCLE

This policy is reviewed annually or upon publication of Ofsted/Safeguarding/Prevent updates.

COUNTER FRAUD AND ERROR POLICY

INTRODUCTION & PURPOSE

The purpose of this policy is to ensure that Digital Native UK prevents, detects, and responds appropriately to any fraud, error, or financial irregularity across all areas of our work. This includes every funding stream we deliver, i.e. Apprenticeships. The policy helps us protect public money, uphold our responsibilities to the Department for Education, and meet the financial control requirements set out in the DFE handbooks. It also ensures that our employees, learners, employers and partners understand their role in keeping our organisation accurate, transparent, and compliant at all times.

APPLICATION & SCOPE

This policy applies to all activities undertaken by Digital Native and all employees, partners and suppliers.

POLICY STATEMENT

Digital Native UK is committed to protecting public funds by preventing, identifying and responding to fraud, error and financial misconduct across our organisation. We expect all employees, learners, employers and partners to act honestly and responsibly and to follow our procedures for reporting any concerns. Our approach includes clear internal controls, regular checks on funding records and learner information, strong cybersecurity measures and careful oversight of procurement and employee activity. We provide training so employees know how to spot and report risks and investigate all suspected cases promptly and fairly. When issues arise, we take immediate action to contain the risk, report it where required, and put things right. This policy helps us uphold high standards, meet Department for Education requirements and ensure that our funding is used properly to support apprentices and employers.

DEFINITIONS

FRAUD

Fraud is when someone deliberately acts dishonestly to gain something for themselves or cause a loss to someone else. This can include providing false information, concealing important details or misusing a role or authority for personal gain. In the education and training sector, this may involve “ghost learners,” false attendance records, falsified off‑the‑job training logs or employers claiming funding they are not entitled to. Fraud can also include procurement scams, banking fraud, qualification fraud, cyber‑enabled attacks such as phishing or malware and other deceptive activities designed to obtain money or other unlawful advantages.

ERROR

An error is a mistake that occurs unintentionally or through dishonesty. These are accidental slip‑ups such as incorrect ILR data entry, mis‑recorded training hours, inaccurate funding claims or mistakes in financial records and payments. Although errors are not fraud, they can still lead to financial losses, compliance failures and reputational damage if not identified and corrected promptly.

IRREGULARITY

An irregularity is any action, behaviour or omission that breaks rules, guidance, funding requirements or internal procedures but is not necessarily dishonest. Irregularities may include noncompliance with financial controls, failure to collect required evidence, inconsistent use of systems or failure to comply with contractual or regulatory obligations. While not inherently fraudulent, irregularities increase the risk of fraud, error or financial loss if ignored.

BRIBERY & CORRUPTION

Bribery and corruption involve offering, giving, receiving or requesting something of value to improperly influence a decision, gain an advantage or misuse power. This includes actions covered by the Bribery Act 2010, such as offering or accepting bribes, facilitation payments or abusing a position for personal gain. In a training provider setting, this could involve influencing procurement decisions, recruitment activities, grading outcomes or funding claims through improper incentives or relationships.

CYBERCRIME

Cybercrime is a criminal activity committed using digital systems or online tools. In the education and training sector, this often includes phishing attacks, malware infections, ransomware, system hacking, attempts to steal data or attempts to redirect payments through compromised accounts. These attacks can lead to financial losses, data breaches and operational disruption and can also be used to commit broader fraud. DfE fraud‑awareness guidance highlights cybercrime as a major and growing threat to colleges and training providers.

ROLES AND RESPONSIBILITIES

Under this policy, the following roles are responsible for the listed responsibilities.

FRAUD PREVENTION LEAD

• Our approach to the identification of risks

• The drafting and implementation of policies and procedures designed to prevent fraud

• The development of a culture which complies with our policies and procedures

• The creation and delivery of error and fraud awareness and the training of employees and associates

• The investigation of any issues which need further examination

• Presenting the results of any error or fraud Investigations to the Governance Board

• Notifying the DfE of any identified cases of fraud.

DIRECTORS/SENIOR MANAGEMENT TEAM

• The safeguarding of public funds, i.e. ensuring that Digital Native accurately claims government funds and is run in a compliant manner and provides value for money

• Creation and management of a Governance Board.

• Risk identification/management and mitigation

• Developing a culture of prevention, detection and reporting

• Implementing DfE anti-fraud guidance

• Review financial accounts with the external accountant

GOVERNANCE BOARD

• Provide strategic oversight

• Ensures adequate internal systems and controls

• Reviews fraud and error assurance activities

• Challenge directors on emerging fraud risks

• Receives fraud reports

ALL DIRECTORS/EMPLOYEES

• Must complete annual training

• Maintain accurate apprentice records and master data

• Complete required processes and controls

• Follow the segregation of duties

• Report any suspicions of fraud.

ERROR IDENTIFICATION

All staff and associates are responsible for addressing/ reporting errors when identified.  Senior Managers have a responsibility to put in place policies, procedures and training to:

• Prevent errors from being made

• Identify errors when they are made

• Rectify errors where rectification is possible

All staff are encouraged to promote a ‘right first time’ culture, address minor errors promptly and effectively and alert managers where more significant errors have been identified.

Most errors identified will be low-level, will be discussed with the line manager and corrected – most errors will be resolved with little drama.  However, some errors have more significant consequences and errors are expected to be reported:

• If the error has a potential financial consequence (positive or negative) of over £1000

• If the time needed to correct the error (opportunity cost) is estimated to be over 4 hours

• If the error requires discussion with third parties (employers, learners, EPAO, DFE, etc.)

EXAMPLES OF ERRORS

MINOR ERRORS

(need correcting, but do not need to be reported)

• A learner’s Planned End Date on the MIS system has been entered incorrectly (but this error was made in the last few days, and the error hasn’t been recorded on an ILR returned to the DfE)

• A learner was wrongly identified as having attended a recent online class. This is not something that happens regularly.

SIGNIFICANT ERRORS

(need reporting and corrective action agreed with manager)

• Funding claimed for a learner who we have now identified as being ineligible to participate in the programme/ course

• Certificates claimed from the awarding body when the course has not been completed by the learner

• Incentive payments received from the DfE but not passed on to the employer in the required time.

RISK IDENTIFICATION

The following areas of activity have been identified as potential risks for fraud in the education industry. The Directors have identified the following prevention and mitigation approaches.

Risk	Impact	Mitigation
Learner-related fraud: Ghost learners, false enrolments, falsified attendance, manipulated OTJ logs, falsified support claims.	Claimed funding from DfE that is not due.	All 3 Directors are involved in the employer/learner recruitment process. No single director can create or start a learner. External employer signatures are required before learners can be created on the LMS.
ILR and funding fraud: Incorrect coding, overstated hours, misreported breaks and inflated achievement data.	Claimed funding from DfE that is not due.	2 Directors are responsible for validating and loading the ILR. Achievements are not claimed till the grades are received from the BCS.
Employer-related fraud: Ineligible apprentices, falsifying employment duration, co‑investment fraud.	Claimed funding from DfE that is not due.	No employees have an apprentice headcount target. All employers are spoken to and the reasons for the apprenticeship are understood. Employees are interviewed, CVs and LinkedIn profiles are reviewed and right-to-work checks are completed before a learner can start.
Staff-related fraud: False expenses, misuse of procurement processes  and conflict of interest	Increased costs,	Expense claims are reviewed by a director and challenged before payment. Course and exam procurement is handled by a director. Procurement of additional learning materials is through the Amazon portal, which requires Director approval.
Procurement & subcontracting fraud: Bid rigging, false invoicing.		No subcontracting, Digital Native does not subcontract any provision. Procurement is handled through a single portal (Amazon) and requires director approval.
Cyber-enabled fraud: Invoice redirection, credential theft, and data theft		Annual Cyber Essentials certification by an external consultant. A privacy-by-design approach is adopted for all systems. MFA is required for employees using M365 M365 credentials are used for all systems.

REPORTING SUSPICION OF ERROR OR FRAUD

Any employee who has a concern about something that does not appear right – whether it may be an error, an irregularity or suspected fraud – is expected to report it to the Fraud Prevention Lead without delay.

Concerns may be raised in several ways:

by speaking to the Fraud Prevention Lead directly

Sending an email to Error_Fraud@dn-uk.com from either a work, personal or anonymous account.

Placing the details in a sealed envelope marked “Private” and addressed to Digital Native C/o Bennett Corner House, 33 Coleshill Street, Sutton Coldfield, West Midlands, United Kingdom, B72 1SD.

Or ask a colleague to pass on the information without naming them.

All employees are protected under the organisation’s whistleblowing arrangements, and anyone who raises a concern in good faith will not face retaliation or disadvantage of any kind. All concerns will be handled sensitively, with information shared only on a need-to-know basis. Where a concern involves serious issues such as safeguarding, misuse of public funds or matters that could affect the integrity of leadership, any employee may also contact Ofsted directly through their concerns and complaints route. The organisation expects all employees to support a culture of honesty and transparency, including providing complete and accurate information as required by the various regulating bodies.

ERROR OR FRAUD RESPONSE PLAN

PURPOSE

This response plan provides a documented framework for the Fraud Prevention Lead (and, if necessary, other managers) to follow if fraud or theft is suspected or reported.

The plan seeks to ensure that, in the event of fraud or theft, timely and effective action is taken to prevent further losses, identify fraudsters, safeguard evidence, minimise adverse effects on the organisation and learn lessons.

All actual or suspected incidents of fraud and theft should be reported without delay to the Fraud Prevention Lead, who will normally also be the Investigating Officer.

Where the Fraud Prevention Lead is suspected of fraud or theft, the report should be made to one of the Directors or to the Governance Board, who shall, in turn, appoint an Investigating Officer.

When reports of fraud or theft are made, the matter will be taken seriously, and all details will be recorded accurately and promptly. Reporting suspected fraud can be traumatic, and those who do are assured that all information will be treated in the strictest confidence.

Anonymity will be preserved where it is reasonably practicable to do so.

The Fraud Prevention Lead will be responsible for liaising with the Board and this should be done promptly in all instances where a potential theft or fraud is reported.  At this stage, management should take steps to prevent further losses, for example, by suspending payments without compromising evidence or alerting the alleged fraudsters.

The Fraud Prevention Lead must also consider whether to report the issue to the DfE or other funding bodies, as required by contracts or funding rules.

INITIAL DISCLOSURE

Upon receiving details of a suspected theft or fraud, the Fraud Prevention Lead will conduct an initial review and determine whether any further action is required and will liaise promptly with the Directors and the Board.

The further action may include referral to:

Board of directors: fraudulent activity is a breach of contract and where there are reasonable grounds for suspicion, then suspension may be required pending the outcome of enquiries.

The Police: delays in contacting the Police may prejudice the gathering of evidence and future enquiries.

DfE/Other Funders: in accordance with contractual obligations and funding rules.

CONDUCTING AN INVESTIGATION

The Fraud Prevention Lead should determine the detailed remit and scope of the investigation  and set the investigation timescales, reporting arrangements and deadlines, ensuring that any police investigation is not compromised.

The Fraud Prevention Lead, or another employee nominated by the Fraud Prevention Lead, should conduct an internal investigation and produce a report of their findings, with all details recorded fully and accurately.  If the issue is complex, the Fraud Prevention Lead may need to produce interim reports documenting progress and intended next steps.

The report should seek to identify (where possible) any losses attributable to the fraud/theft.  This report may need to be made available to the police and also to insurers.

Where necessary and appropriate, the disciplinary policy will also be followed.

CONCLUDING AN INVESTIGATION

At the end of the investigation, regardless of the outcome, the Fraud Prevention Lead should review the position and identify lessons learned. Such reviews will help identify any weaknesses in controls that initially led to the fraud/theft and should highlight any deficiencies that should be addressed.

On completion of the review, a detailed report should be submitted to the Governance Board for consideration. The report should include a description of the incident, the loss incurred, the people involved  and the means by which the fraud was perpetrated. It should set out the measures taken to prevent recurrence and any timetabled monitoring actions.

Equality Policy Statement

 

Digital Native’s vision is to be a company that is valued by all its stakeholders, which achieves exceptional results in all different aspects of its business. Key to achieving this, Digital Native is committed to providing an excellent training service, contributing to the wider regeneration and sustainability of local communities. We understand that in order to provide the commitment necessary to realise this vision, we must exemplify the principles of promoting equality and valuing diversity in all our activities, as a service provider and as an employer. These ambitions can only be achieved through people. Digital Native employees will reflect the culture, values and ambitions that Digital Native will aim to achieve.

 

Digital Native priority will be to tackle all forms of discrimination and exclusion across the main protected characteristics, recognising that any one person may be disadvantaged on more than one of these grounds. We also recognise that there may be other groups who may be vulnerable to discrimination. Digital Native Equality Policy applies to the recruitment, selection, education and assessment of apprentices and in the recruitment, selection, training, appraisal, development and promotion of staff, the only consideration must be that the individual’s abilities and needs, in relation to the requirements of the programme post.

If requirements are met, no apprentice or employee will be discriminated against on the basis of their sex, sexual orientation, race, colour, ethnic origin, nationality (within current legislation), disability, marital status, sexuality, caring or parental responsibilities, age, or beliefs on matters such as religion and politics. Digital Native is committed to provide a learning, working and social environment in which the rights and dignity of all its members are respected, and which is free from discrimination, prejudice, intimidation and all forms of harassment including bullying.

This policy means that all apprentices and employees of Digital Native have the right to study or work in an environment free from discrimination, prejudice and all forms of harassment or bullying. Digital Native has a ZERO tolerance approach to bullying and harassment.

Digital Native is committed to a programme of action to ensure that this and other equalities policies are implemented and monitored at an organisational and individual level. Digital Native seeks to employ a workforce which reflects the diversity of the wider community. It does so because it values the individual contribution of people irrespective of sex, age, disability, sexual orientation, race, religion or belief, gender, gender reassignment, maternity, or because someone is married or in a civil partnership, or any other personal characteristics. Digital Native will treat all employees with dignity and respect and will provide a working environment free from unlawful discrimination, victimisation or harassment on the grounds of any of the protected characteristics or other personal characteristics. The protected characteristics are:

• Age
• Disability
• Sex
• Gender reassignment
• Pregnancy & maternity
• Race
• Sexual orientation
• Religion or belief
• Married or in a civil partnership

 

 

Digital Native will not tolerate acts that breach the Equality and Diversity policy and all instances of such behaviour, or alleged behaviour, will be taken seriously, be fully investigated and may be subject to the Company’s disciplinary procedures. Additionally, any person found to be inciting, encouraging or condoning discriminatory actions or behaviour may be subject to disciplinary action.

Digital Native values innovation and feels that diversity within the team and client base brings positive benefits that will improve and strengthen the business.

The adoption of a Diversity Policy goes further than simply complying with the letter of the law. It aims to get the best from people by treating them fairly and with respect and providing a safe and rewarding working environment. There are sound operational as well as ethical reasons for having a policy which supports and encourages staff to develop and demonstrate their full potential, including:

• Attracting and retaining employees from the wider community
• Selecting the best person for the role
• Improving individual and corporate performance
• Creating a healthy and constructive working atmosphere and organisational culture
• Enhancing staff morale
• Demonstrating to clients and the community that the Company is a fair and diverse organisation, representative of the local community.

 

The Senior Leadership Team are committed to developing and maintaining policies and working practices designed to promote equality of opportunity and to address the elimination of discrimination of any form, in particular discrimination in relation to ‘protected characteristics’.

Digital Native will ensure that discrimination in any form is challenged and addressed in all its activities. It will through systematic reviews, ensure that its policies, procedures and practices address any potential or actual discrimination or disadvantage and regular monitoring and evaluation of their effectiveness will be undertaken.

Digital Native will actively challenge discrimination through reviewing its processes, attitudes and behaviour supported with appropriate staff training programmes. Digital Native grievance procedure will make it clear that instances of discrimination and/or harassment should be raised with the coach in the first instance to reflect Digital Native intolerance of such behaviour.

Digital Native will monitor and evaluate the effectiveness of the Equality and Diversity policy with its employees, customers and associated partners. Recruitment records, along with reports from complaints, incidents, safeguarding and feedback interviews will be discussed by the directors and, where necessary, any changes can be implemented

Equity for staff will be supported by policies and practices which foster:

 

• equitable recruitment and promotion procedures for all staff
• a staff composition which reflects closely the communities we serve
• a non-sexist, non- racist and disability supportive working environment
• a monitoring and feedback system capable of highlighting areas for improvement
• considering and acting upon feedback from staff when reasonably practical to do so.

 

 

 

 

 

 

 

 

 

WHAT IS MEANT BY “EQUALITY”?

 

Equality is ensuring individuals or groups of individuals are treated fairly and equally and no less favourably, specific to their needs, including areas of race, gender, disability, religion or belief, sexual orientation and age.

Promoting equality should remove discrimination in all of the following factors; sex, sexual orientation, marital status, ethnic origin, race, religion, colour, nationality, political beliefs, disability and age should not be taken into account for the purposes of:

 

STAFF:

Recruitment, appointment, training, appraisal, promotion, discipline etc.

APPRENTICES:

Application to and acceptance on to a course of study, and assessment of academic performance

Selection for a course of study or for a job should be made solely on merit

 

RESPONSIBILITIES

 

The Directors are responsible for ensuring:

• The Company implements and follows its equality and diversity policies and codes of practice and meets its legal responsibilities.
• A consistent and high-profile lead on equality and diversity.
• Promotion of equality and diversity inside and outside the training organisation.
• Policies and procedures are in place to comply with all applicable legislation.
• The Company implements its equality and diversity policies and codes of practice.
• Quality audits are carried out in all areas of Equality & Diversity.
• There is baseline data on admission used to ensure learner progression and for staff recruitment and career progression and this is reported to the board of directors
• That all staff and apprentices know their responsibilities and receive the necessary support and training.
• Making sure that staff know about Digital Native Equality and Diversity policy and that any kind of harassment or discrimination is not acceptable.
• Keeping a look out for changes in behaviour
• Challenging inappropriate behaviour, taking prompt action wherever there is evidence of bullying or harassing behaviour, whether or not anyone has complained.
• Checking that office banter is appropriate and not upsetting anyone
• Always take issues seriously where required
• Investigate all allegations with consistency and an open mind
• Listen carefully without bias to what employees have to say
• Making sure that staff know they can approach you if they have a problem.
• Do not jump to premature conclusions about the validity of a particular complaint
• Always do a follow up after any issue or complaint to ensure that the matter has been properly resolved
• Discuss promptly with your coach any complaint of bullying or harassment
• Ensure you are familiar with all HR policies and procedures
• Ensure you lead your team by observing the Digital Native Code of Conduct at all times
• Relevant procedures and actions are followed in cases of unfair discrimination, harassment or bullying.

 EMPLOYEES AND VOLUNTEERS ARE RESPONSIBLE FOR:

 

• Co-operating with the Company to ensure that this policy is effective to ensure equal opportunities and to prevent discrimination.
• Promoting equality and diversity, and avoiding unfair discrimination.
• Reviewing on an annual basis the existing policy.
• Challenging, reporting and analysing any incidents of unfair discrimination racial, sexual or other stereotyping perpetrated by staff, volunteers and apprentices.
• Keeping up-to-date with equality law and participating in equality and diversity training.
• Employees should also bear in mind that they can be held personally liable for any act of unlawful discrimination.
• We all have a responsibility to help create and maintain a work environment which celebrates diversity and promotes equality.
• Being aware of how your own behaviour may affect others and changing it, if necessary – you can still cause offence even if you are ‘only joking’
• Treating your colleagues with dignity and respect
• Making it clear to others when you find their behaviour unacceptable unless it should be obvious in advance that this would be the case
• Taking steps to stop harassment or bullying and giving support
• Making it clear that you find harassment and bullying unacceptable
• Reporting equality and diversity issued and harassment or bullying to your director and supporting the Company in the investigation of complaints
• If a complaint relating to equality and diversity or harassment or bullying is made, not prejudging or victimising the complainant or alleged harasser.
• Staff who feel they require support and guidance should contact a director.

 

 

APPRENTICES ARE RESPONSIBLE FOR:

 

• Participating in equal opportunity and diversity training.
• Respecting others in their language and actions.
• Having an input into policy amendments.
• Reporting instances of unfair discrimination, or racial, sexual or other stereotyping.
• Implementing the Company’s equality and diversity policies and codes of practice.

 

 

Digital Native will seek to involve and consult staff on the Equality and Diversity policy, action points and any other equality and diversity initiatives as appropriate. Digital Native has a number of methods of consulting with and involving staff including:

 

• Team meetings and daily stand up

• Cultural events
• Information bulletins and information
• Interactive quality management system

 

DISCRIMINATION

 

   The following are the kinds of discrimination which are against the Company’s policy:

 

Direct discrimination: where a person is less favourably treated than another person because of a protected characteristic they have or are thought to have. An example is if someone is refused entry onto a learning programme on the grounds that he or she is black, disabled, homosexual, of a

particular religion or belief or she is a woman

Associative discrimination: this is direct discrimination against someone because they associate with another person who possesses a protected characteristic.

Perceptive discrimination: this is direct discrimination against an individual because others think they possess a particular protected characteristic. It applies even if the person does not actually possess that characteristic.

Indirect discrimination: where a requirement or condition which cannot be justified is applied equally to all groups but has a disproportionately adverse effect on one particular group. Some examples are:

• where an age limit for new recruits may exclude many women of that age group because they are unable to apply for the job as a result of family commitments, or
• the restricting of recruitment to areas where there are few ethnic minorities, or
• Victimisation: where an individual is treated less favourably because they have made or supported a complaint or raised a grievance under the Equality Act; or because they are suspected of doing so. An employee is not protected from victimisation if they have maliciously made or supported an untrue complaint.

 

 

HARASSMENT

 

Harassment may be defined as unwanted conduct related to a relevant protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.

The key is that the actions or comments are viewed as demeaning and unacceptable to the recipient. Please refer to our Bullying and Harassment policy for more information.

We will treat all our Employees with dignity and respect and will provide a working environment free from bullying or harassment on any grounds.

We will not tolerate acts that breach this policy and all instances of such behaviour, or alleged behaviour, will be taken seriously, be fully investigated and may be subject to our disciplinary procedures. Additionally, any person found to be inciting, encouraging or condoning such behaviour may be subject to disciplinary action.

Digital Native will not tolerate acts which breach this policy including third parties such as employers and clients. Staff who feel they require guidance and support should contact their director.

Employees are also protected from harassment because of perception and association.

 

 

 

GENDER EQUALITY

 

We will work with our partners to eliminate sexual harassment, support victims and take action against perpetrators.

Definitions:

• Sexual Discrimination: Occurs when someone is treated unfairly or less favourable than others in the same circumstances, on the basis of their gender.
• Direct Discrimination: Direct sexual discrimination occurs when a person is treated less favourably than others, in comparable circumstances, on the basis of their gender. For example- An assumption that women are more suited (or not suited) to certain types of work, or are more (or less) available for certain jobs than their male counterparts.
• Indirect Discrimination: Indirect sexual discrimination occurs when a condition or requirement is applied which adversely affects or favours one particular group more than another- For example “must have two years’ unbroken service” as a requirement would discriminate unfairly against women, due to women having maternity leave. Indirect discrimination can also occur where sexual harassment is used to create a hostile, abusive or offensive working environment.
• Sexual Harassment: “unwanted conduct of a sexual nature, or other conduct based in sex, affecting the dignity of men and women at work. This can include unwelcome physical, verbal and non-verbal conduct” (European Commission)
• Sexual Victimisation: Occurs when a person victimises another person for bringing a claim or giving evidence in connection with a claim of discrimination or harassment.

 

 

Digital Native believes that the organisation will benefit from engaging employees at all levels of responsibility and across all areas of work regardless of their sexual orientation. Digital Native recognises the right of every person to be treated in accordance with these values. Digital Native employees of all sexual orientations have a statutory right to fair treatment under s12 Equality Act 2010. The Act sets out a framework for eliminating employment or occupational inequalities based on sexual orientation, i.e. to ensure there will be no discrimination against employees, either directly or indirectly, on the grounds of sexual orientation in access to employment, training, promotion or dismissal, in the provision of work-place benefits, or the provision of references.

It is Digital Native’s aim to create an inclusive company where people are enabled to meet their full potential and are treated as individuals. This includes recognising and supporting a person’s self-identity as male or female. Digital Native is committed to ensuring that transgender people are treated with respect and that it does not discriminate unlawfully. This commitment is an important aspect of our overall commitment to providing equal opportunities in employment and to ensure that no current or prospective members of staff are subject to discrimination or victimisation as a result of the gender in which they present themselves.

 

  DISABILITY EQUALITY

 

We will ensure that the working environment is accessible and meets the needs of disabled people, taking into consideration particular needs as required.

Ensure that we work with our partners to eliminate harassment of disabled people, support victims and take action against perpetrators.

 

Ensure that information we provide is accessible to disabled employees.

Definitions:

S6 Equality Act 2010 defines a disabled person as someone with ‘A physical or mental impairment, which has a substantial and long term adverse effect on his or her ability to carry out normal day to day activities’. The definition is complex and it is important not to think too narrowly when considering whether a person is disabled or not. For example hidden disabilities such as epilepsy and diabetes are included within the definition.

 

 

• Mental impairments include learning, psychiatric and psychological impairments. However where an impairment concerns mental health, it falls within the definition only if the condition is clinically recognised, such as schizophrenia, manic depression, and severe and extended depressive psychoses.
• A person’s impairment amounts to a disability only if it affects their ability to carry out day to day activities.
• Staff who have a disability and consider that they may fall within the definition may wish to record this with Digital Native and contact their director.

 

 

REASONABLE ADJUSTMENTS:

 

• Digital Native has a statutory duty to make reasonable adjustments and conduct health and safety risk assessments to avoid discrimination against disabled employees or prospective employees. Adjustments are a means of levelling the playing field to help disabled people contribute fully to the work force and enable that person to perform the job.

 

• Adjustments apply to all aspects and stages of employment and needs are always considered during: recruitment, selection, training and induction, transfers, promotion, opportunities for training and career development, terms and conditions, employee benefits, retention, redundancy and dismissal.
• Types of adjustments will be discussed with the directors and, in conjunction with advice from a medical professional and other professional advisory bodies may include: alter premises, allow absences during working hours for rehabilitation assessment or treatment, supply additional training, acquire special equipment or modify existing equipment, modify instructions or reference manuals (this list is not exhaustive).

 

 

 

RACE EQUALITY

 

We will ensure that we work with all partners to eliminate racial harassment and racially motivated crime, support victims and take action against perpetrators.

Digital Native will take steps to ensure that applications are attracted from all races and will ensure that there are equal opportunities in all stages of the recruitment process. Where appropriate, staff responsible for recruitment will receive training in equal opportunities, and guidance will be available to all staff. Promotion within the Company is based solely on merit.

 

Digital Native main centre is in a diverse area of the United Kingdom and where ever possible we actively promote applications from clients from our local centre for jobs at Digital Native.

 

 

RELIGION OR BELIEF

Digital Native welcomes all people regardless of their religions, philosophical beliefs and faiths and is strongly committed to promoting equality of opportunity in all its activities. Members of any religion, followers of any faith or belief and those without religious belief will be treated with equal dignity, respect and fairness.

Digital Native is committed to protecting and promoting the rights of every member of the community to freedom of thought, conscience and religion, freedom of expression and freedom of association. These rights apply to people with or without formal religious affiliation, of all faiths and none, and provide for the principle of respecting other people’s freedom to express their beliefs and convictions. However, any expression of belief has to take account of the rights and reasonable sensitivities of others.

Some religions require their followers to pray at specific times during the day. Staff may therefore request access to an appropriate quiet place to undertake their religious observance. Many religions or beliefs have special festival or spiritual observance days. An employee may request holiday in order to celebrate festivals or attend ceremonies. Digital Native are sympathetic and will consider such a request where it is reasonable and practical for the employee to be away from work, and they have sufficient holiday entitlement in hand.

If it is practical and safe to do so, staff may welcome the opportunity to wear clothing consistent with their religion. Staff should contact their director for guidance.

 

 

AGE

Age discrimination in employment is unlawful. The UK legislation protects people of all ages in employment. Direct and indirect discrimination, victimisation and harassment are covered in all aspects of employment including unfair dismissal and redundancy provisions.

Digital Native recognises the contributions that people of all ages can bring, and welcomes and believes that all employees should, wherever possible, be permitted to continue working for as long as they wish to do so.

 

 

RECRUITMENT

 

The Company applies selection processes for both internal and external applicants which ensure the appointment of the highest quality staff.

As part of our commitment, Digital Native will aim to:

• Ensure all appointments are fair and free from discrimination;
• Ensure that the operation of the Recruitment and Selection policy processes delivers fair and evidenced equality of treatment for all applicants.
• Improve retention rates as the right people are recruited for the right roles

 

 

 

The Company’s selection criteria are designed to give applicants every opportunity to demonstrate their skills and abilities in a variety of relevant activities and to learn as much as they can about our Company and the role they are applying for. Activities may include: criteria based interviews, presentations and written exercises.

A person specification should link to the job description and outline the skills, experience and knowledge a person needs.

It is our policy to advertise vacancies in publications that are relevant to the nature and level of the job.

In line with our policy Digital Native positively encourages applications from suitably qualified and eligible candidates regardless of sex, gender, race, disability, age, sexual orientation, or religion or belief, gender reassignment, maternity or because someone is married or in a civil partnership. At the interview or selection stage questions are asked, and where appropriate tests set, to check for the skills and competences needed for the post. Interviewers will not ask personal questions which may be perceived to be intrusive and imply potential discrimination. Where applicants volunteer personal information, those selecting will not to be influenced by such information.

The Company will take steps to ensure that applications are attracted from all sexes, races and from disabled people, and will ensure that there are equal opportunities in all stages of the recruitment process. Where appropriate, staff responsible for recruitment will receive training in equal opportunities and guidance will be available to all staff.

Promotion within the Company is based solely on merit and without regard to race, sex, disability, sexual orientation, religion or belief.

The business development director will monitor recruitment and selection practices through the collection of equal opportunities monitoring data, which will be reviewed and used to inform improvements and changes in processes where required.

 

DISCIPLINARY

 Acts of discrimination or harassment by employees of the Company may result in disciplinary action. The Company will treat seriously and consider resolutions when any employee has a grievance as a result of discrimination or harassment.

It may be difficult for individuals experiencing discrimination or harassment to bring the matter formally into the open. Support and guidance will therefore be made available, in confidence, to people wishing to pursue this avenue. Formal complaints may be made in writing initially to their director.. All investigations will be carried out in the strictest confidence and all people involved in the investigation will be expected to respect this confidentiality. Only once the facts have been established will a course of action be recommended.

Should any person feel that an investigation has been managed in an inappropriate or unfair manner

they may appeal to the Managing Director.

Please refer to the Disciplinary and Grievance policies for further information.

​HARASSMENT AND ANTI-BULLYING POLICY 

Giving every child the best start in life (2025) sets out the plan to ensure there are the opportunities to learn, grow and thrive that this government wants for every one of our children and that this must be there right from the beginning.

This document details how Digital Native aims to prevent and tackle unpleasant and intimidating behaviour at our premises or via Teams calls, so allowing the fulfilment of the above strategy and permitting apprentices to fulfil their potential.

​• We will take bullying seriously

• ​We will make sure learners who experience bullying know how to get help and support.

• ​We will offer services to learners who bully others to help understand the consequences of their actions.

• ​We will monitor our internal systems to make sure they are working to the agreed anti bullying standards.

​The Ethos of Digital Native UK 

In order for learners to fulfil their potential both academically and socially, we want to ensure the safety and welfare of learners at Digital Native. We believe in an ‘inclusive approach’ for all people and any barriers to their learning or development need to be minimised. We recognise social barriers such as bullying do exist. This will not be tolerated and needs to be tackled. It is made clear to all our learners that bullying will be dealt with seriously. Challenging bullying effectively will improve the safety, happiness and performance of learners. It also improves confidence, performance and attendance of vulnerable learners and provides guidelines and controls for learners whose behaviour is a concern.

​What is Bullying? 

The Anti-Bullying Alliance (ABA) defines bullying as:
“The repetitive, intentional hurting of one person or group by another person or group, where the relationship involves an imbalance of power. Bullying can be physical, verbal or psychological. It can happen face-to-face or online”

Bullying is a form of discrimination. This is when a person or a group of people are treated differently because of a perceived difference and/or prejudice. These differences can be a range of things for example; race, educational achievement, height, sexuality, weight, accent, gender or name.

​Types of Bullying: 

• Racist, Religious and Cultural bullying. Racial taunts, graffiti, gestures. The Race Relations Act 1976 states that schools and governing bodies have a duty to ensure that learners do not face any form of racial discrimination, including attacks and harassment. We see this to include Digital Native as an apprenticeship provider.

​• Physical – pushing, poking, kicking, hitting, biting, pinching etc.

• Verbal  – name calling, sarcasm, spreading rumours, threats, teasing, belittling.

• Emotional – isolating others, tormenting, hiding books, threatening gestures,  ridicule, humiliation, intimidating, excluding, manipulation and coercion.

• Sexual – unwanted physical contact, inappropriate touching, abusive comments, homophobic abuse, exposure to inappropriate films etc.

• Online /Cyber – posting on social media, sharing photos, sending nasty text messages, social exclusion

• Indirect – Can include the exploitation of individuals.

• Bullying may occur in the form of name-calling or exclusion or it can escalate to aggressive and intimidating actions that prevent learners from taking advantage of the opportunities that Digital Native provides.

​If Bullying Occurs – A General Overview 

Digital Native has a range of options for learners to seek advice and get help. We consistently reinforce the message to inform someone of any incidence of bullying immediately and that dealing with bullying is everyone’s responsibility.

​Coaches– encourage learners to discuss issues/problems with them. This information will be treated with respect and due seriousness.
Directors – Discuss any issues with a director of Digital Native
Web-based Reporting and information – where learners can email coaches directly to report incidents of bullying.

​How Digital Native UK will deal with bullying 

• When a bullying incident is reported, those accused of bullying and witnesses of the incident will be asked to write down an account of what has taken place. All those involved will be interviewed by their coach.

​• Bullying incidents will be recorded by the coach for future reference and all documentation to do with specific incidents will be placed on the learner’s files.

• ​If a learner either admits to bullying or it can be been proved beyond reasonable doubt that they have taken part in this behaviour then the following methods and sanctions can be used:

• ​The incident will be reported to their parents (under 18 as per Safeguarding Policy) or their employer and a meeting arranged face to face to discuss the matter and the action to be taken.

​• Once the bullying incident has been resolved, and the victim of the bullying considers the matter closed, a support programme will be put in place for the person who did the bullying. We recognise that people who bully have often been victims themselves. Employers may have a meeting with their apprentice to discuss the incident and to agree the appropriate action to be taken. Digital Native relies on the support of employers or parents in matters such as this to stop the problem continuing and to help the learner improve their behaviour

​How we can prevent bullying: 

• We must all raise awareness of bullying by addressing all learners, coaches and employers

• ​We must all publicly acknowledge that Digital Native considers bullying to be unacceptable and is committed to dealing with it.

• ​We must all help to create and support a culture of care and consideration for others.

​Coaching Staff 

The important thing is to establish environments where bullying is less likely to occur. This may be by setting boundaries around ‘courtesy’ and ‘respect’. You may need to get some background information on a group and how they work together.
You also need to:

• Set clear boundaries about expected standards of behaviour

​• Act on information given out by other members of staff

• ​Encourage learners to talk to you about their concerns

• ​Think carefully about the seating plan when delivering face to face sessions

• ​Minimise problems by seating learners away from potential difficulties

• ​Discuss the role of the ‘bystander’ in bullying – talk about what bystanders need to do if they witness bullying

​Apprentices 

• The Golden Rule is to tell someone!

• ​Bullying can happen through no fault of your own, don’t let it build up. You must act immediately when anything happens

​• Try not to be confrontational or spiteful.

• ​Don’t act as an ‘audience’ for bullies. So don’t stand and watch or encourage, either walk away or go and tell someone

• ​Don’t be a ‘bystander’. If you witness something, report it (even if it’s anonymous). You’d like someone to do the same if it was you being bullied

​Parents 

If an apprentice is classed as a child (under 18) parents are often best placed to detect changes in behaviour or attitude which might indicate that a learner is upset or unhappy and that bullying may be taking place.
Parents should also:

​• Set clear boundaries about expected standards of behaviour at home

​• Encourage their child to talk to you about their concerns

• ​Use a ‘significant other’ adult if your child doesn’t wish to talk to you

• ​If necessary, approach Digital Native to discuss any difficulties

​• Report any incidents of bullying to staff as soon as possible. Please do not wait until for the bullying to ‘develop’.

​• Discuss the role of the ‘bystander’ in bullying – talk about what bystanders need to do if they witness bullying

How can we help?

​Staff and Directors 

• Learners, employers and parents need to have faith in the system and learners need to feel confident that Digital Native will take the matter seriously.

​• Digital Native will encourage learners to empathise with others and encourage social and emotional behavioural skills throughout .

• ​Coaches will take every opportunity to make it clear to all learners that bullying is unacceptable. This will be done through reinforcement within the apprenticeship days

• ​Learners will be told that bullying (verbal or physical) is not tolerated at Digital Native. Everyone is expected to ensure that bullying does not happen and everyone has the responsibility to tell someone – this is not telling tales.

​Apprentice 

• Learners need to work as a team and realise they are all members of the same community.

• ​Learners need to support the efforts of each other, and celebrate the different skills and interests that each person brings and practise British values of mutual tolerance and respect.

​• It is unrealistic to assume that everyone will get on with each other at all times, but no learner has the right to make their apprenticeship an unpleasant experience for another learner.

• ​Tell a member of staff telling about bullying isn’t ‘telling tales’ or ‘grassing’. You have the right to be safe from attacks and harassment and you should not be silent when you are being hurt.

​• Tell a friend or work colleague what is happening. Ask them to help you. It will be harder for the bully to pick on you if you have a friend

​• Try to ignore the bullying or say ‘No’ firmly, then turn and walk away. Don’t worry if people think you are running away. Remember, it is very hard for the bully to go on bullying someone who won’t stand still to listen.

​• Try not to show that you are upset or angry. Bullies love to get a reaction. If you can keep calm they might get bored and leave you alone.

• ​Don’t fight back if you can help it.

​Parents 

• Encourage your child to be assertive but not confrontational in their manner.

​• Encourage them to talk openly with them about any social problems at work or on apprenticeship days and reiterate that bullying’ is not something that should be tolerated.

​What is Restorative Justice? 

Digital Native is committed to moving towards Restorative Justice as a way of resolving bullying issues. ‘Restorative Justice’ brings the ‘victim’ and ‘perpetrator’ together to discuss their actions and

​be aware of how their actions have affected another person. It accepts conflict is part of life and it allows learners to take responsibility for their feelings and behaviour and is a good way to repair the damage caused. It does not make the ‘perpetrator’ less responsible, but looks at reparations for damage done.

​Apprentice Friendly Advice and Guidance on Bullying 

In most cases the two-people involved will be encouraged to eventually come face to face and realise the hurt and pain they may have caused, restoring justice and building bridges.
What you can remember to do:

• ​Treat others as you want to be treated!

• ​Be respectful to everyone in the community

​• If you witness something unpleasant, report it (even if it’s anonymous).

• ​If you are unhappy – tell someone! The sooner we know the sooner we can help!

• ​Don’t act as an ‘audience’ for bullies. So don’t stand and watch, walk away and tell someone

• ​Everyone is different and that is what makes us so special – difference is not a bad thing – celebrate it!

• ​If someone is being unpleasant to you, be ‘assertive’ but not ‘aggressive’ when dealing with bullying. If you feel able, tell the bully clearly to stop – this isn’t always easy. If no one knows you need help then no one can help you!

​If you have a problem to do with friends or bullying then you can talk to any of the people mentioned below, but you should have a good relationship with your coach or work mentor/line manager so they would be a good starting point.

​We would hope that you feel comfortable talking to at least one member of staff about your problems, but if you don’t, then you might want to contact the following people:

• ​Anti Bullying Alliance 0800 1111

• ​NSPCC helpline 0808 800 500

• ​nspcc.org.uk.

• ​National Bullying Helpine

• Young Minds

• ​​Samaritans 0345 909090 / 01452 306 333

​Cyber Bullying 

Technology is utilised both in and out Digital Native as a source of valuable information to further learners learning. However Digital Native recognises that cyber-bullying is on the increase and needs to be tackled.
Cyber bullying includes:

• ​Text messaging

• ​Mobile phone calls

​• Picture/video clips (via mobile phone cameras)

​• Email

​• Chat rooms

​• Instant Messaging

​• Social Media (Facebook, TikTok, X)

What to do – coping and reporting strategies

​Apprentices 

• Do not reply to any message

• ​Report it to a member of staff at Digital Native (if it occurs out of the apprenticeship environment then it will become an employer or police matter)

• Report it to the social platform

• Block the bully

​• Document the evidence – Take screenshots

​Staff: 

• We realise that you cannot control what learners do with their mobile phones and computers outside of Digital Native

• ​Make it clear that bullying of any kind will not be tolerated and will be dealt with.

• ​Ensure mobile phones are not used during sessions unless specific to a task

​ 

HEALTH AND SAFETY POLICY

Digital Native UK is committed—so far as is reasonably practicable—to safeguarding the health, safety and welfare of its employees, apprentices/learners, contractors and visitors, and of others who may be affected by our activities, on our own premises and at host‑employer sites. We will provide and maintain safe systems of work, safe equipment, competent supervision, and appropriate information, instruction and training.

As an apprenticeship provider, we will ensure our arrangements meet legislative requirements and the expectations set out by Ofsted’s renewed Education Inspection Framework (EIF) and FE & Skills inspection toolkit, which focus on statutory compliance and embedded practice across the evaluation areas (including Safeguarding, Leadership & governance, and provision‑level areas for apprenticeships).

SCOPE

This policy applies to:

• All Digital Native UK employees, workers and volunteers.

• All apprentices/learners engaged with Digital Native UK, whether learning face to face, remotely, or on employer premises.

• Contractors and visitors on our controlled premises.

• Employers with apprentices that we are training under defined agreements and due diligence.

Where learners are under 18, safeguarding duties apply as per Keeping Children Safe in Education (KCSIE) and are integrated with this policy through the Safeguarding and Prevent Duty Policy.

ROLES AND RESPONSIBILITIES

Board/Directors

• Provide leadership, review performance and approve this policy annually.

Director of Delivery (H&S Lead) – Policy Owner

• Responsible for completion of face to face venue risk assessments, employer H&S assessments, working from home assessments, staff training and for reporting performance, incidents and lessons learned to the Board.

Tutors/Assessors/Coaches

• Monitoring that the apprentice is safe in their workplace, recording findings in the apprentices monthly review and escalating to a director when concerns are identified.

All Employees and Learners

• Take reasonable care for own and others’ safety; follow training and instructions; report hazards, near misses, incidents and safeguarding concerns promptly.

Designated Safeguarding Lead (DSL)

• Lead safeguarding; ensure effective interface with H&S where concerns overlap; ensure KCSIE compliance for under‑18s.

Employers

• Provide a safe workplace for their apprentices that complies with UK H&S regulations including risk assessments, competent supervision and first aid. Employers will also report incidents concerning apprentices to Digital Native.

RISK ASSESSMENT AND RISK CONTROL

• We will conduct and record suitable and sufficient risk assessments for activities under our control, including the apprentice’s workplace, face to face venues and working from home for Digital Native employees.

Young persons (<18)

• We will complete specific risk assessments for young persons, considering inexperience, immaturity and lack of awareness of risks and ensure appropriate controls are in place.

APPRENTICES ON EMPLOYER PREMISES

Before the apprenticeship starts, we will complete due diligence on the employer, including H&S risk assessment, supervision arrangements, first aid arrangements, induction content and confirming employers’ liability insurance. The apprentice will also be asked about their workplace H&S at each monthly review.

We reserve the right to pause or stop an apprenticeship where risk control is inadequate and we will align our quality oversight with the Apprenticeship Provider Accountability Framework, using indicators and self‑assessment to identify and mitigate risk.

SAFEGUARDING INTERFACE

Where learners are under 18, we follow KCSIE in full and ensure H&S concerns that have a safeguarding dimension (e.g., neglect, exploitation, harassment) are escalated to the DSL without delay. Staff receive training on recognising and reporting concerns.

FIRST AID

Employer Premises

• Before the apprentice start we will confirm with the employer that appropriate measures are in place such as first aid kits, qualified 1^st aiders and how the apprentice will be made aware of these.

Face to Face Venues

• A risk assessment will be completed that evidences that the venue has appropriate first aid measure in place such as first aid kits, qualified 1^st Digital Native staff attending these sessions will be made aware of the 1^st aid arrangements in place and how to access these.

INCIDENT REPORTING, INVESTIGATION AND RIDDOR

Employer Premises

• Where an apprentice is involved in an incident at their workplace the employer is responsible for investigating and reporting where it meets RIDDOR thresholds

• The employer is also responsible for all corrective actions identified from the investigation

• The employer shall inform Digital Native as soon as possible

• Digital Native will liaise with the employer and complete all steps necessary to confirm that the workplace is safe for the apprentice to continue to work there and reserves the right to halt the apprenticeship where this is not the case.

Face to Face Venue

• Where an apprentice is involved in an incident at a face to face venue Digital Native is responsible for investigating and reporting where it meets RIDDOR thresholds

• Digital Native has responsibility to work with the venue to ensure that all corrective actions identified from the investigation have implemented

• Digital Native shall inform the employer as soon as possible

• Digital Native will complete an investigation to establish whether it can continue to use the venue

FIRE AND EMERGENCY ARRANGEMENTS

Employer Premises

• We ensure apprentices are inducted on the employer’s emergency procedures and know how to raise the alarm and evacuate the premises

Face to Face Venues

We cooperate and coordinate with the venues nominated individuals and ensure fire and emergency arrangements are communicated to apprentices at the start of each meet up.

DISPLAY SCREEN EQUIPMENT, MANUAL HANDLING, LONE WORKING AND STRESS

Apprentices

• We ensure that apprentices are aware of the relevant legislation and how to raise concerns

• Training and guidance is given on how to conduct a DSE assessment and ensure their workplace is safe

Digital Native Staff

• We ask all employees to complete a home working assessment

• Training and guidance is given on how to conduct a DSE assessment and ensure their workplace is safe

• Digital Native will supply any equipment needed to ensure the employees workplace is comfortable and safe (e.g. operators chairs, large / multiple monitors etc)

CONSULTATION AND COMMUNICATION

We encourage an open and transparent culture where apprentices, employers and employees and encouraged to discuss and concerns that they have and H&S is raised at every apprentice review.

RECORDS AND DATA PROTECTION

We keep H&S records (risk assessments, home working assessments and indent log) in line with legal minimums and our Data Protection Policy.

NON-COMPLIANCE

Breaches of this policy or associated procedures may result in disciplinary action and/or cessation of the apprenticeship. Serious breaches may be reportable to regulators (e.g., HSE, DFE) depending on circumstances.

COMMUNICATION

This policy will be published on Digital Native’s website and stakeholders including apprentices, employers and employees know how to access this.

REVIEW CYCLE

This policy is reviewed annually or upon publication of Ofsted/Safeguarding/Prevent updates.

Introduction

Digital Native is committed to preventing modern slavery and human trafficking in all its operations and supply chains. We uphold the highest standards of integrity and ethical conduct in all our business dealings. This policy details the action Digital Native takes to prevent modern slavery.

Application & Scope

This policy applies to all persons working for Digital Native or on our behalf in any capacity, including employees, directors, officers, agency workers, volunteers, interns, agents, contractors, and business partners.

Our Commitment

Modern slavery is a serious crime and a violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour, and human trafficking. We have zero tolerance for modern slavery in our organisation and in our supply chains. We are committed to acting ethically and with integrity, being transparent about risks, and taking prompt action where concerns arise. We will continuously improve our approach in line with government guidance.

Although only larger organisations must publish a formal modern slavery statement, we voluntarily follow the spirit of the law and the government’s statutory guidance for small organisations to help prevent exploitation and improve transparency.

Roles and Responsibilities

Governance Board

• Review/approve this policy;

• Oversee risk management and progress;

• Review any modern slavery incident report.

Directors

• Maintains this policy;

• Runs risk assessments and due diligence;

• Logs and investigates concern;

• Report material issues to the Board and relevant authorities;

• Coordinate staff training.

Coaches and Employees

• Raise concerns immediately

• Complete training

• Follow due diligence steps

• Keep accurate records

Suppliers and Partners (incl. Employers of Apprentices)

• Cooperate with checks and investigations.

• Comply with our Supplier Code of Conduct and this policy;

• Cascade equivalent standards to their supply chains;

Identifying and Assessing Risk

We recognise that modern slavery can occur in any sector, including services and subcontracted functions. Given our size and relatively short UK‑based supply chain, we consider our risk is low, but not zero. We therefore:

• Perform a risk assessment whenever we start working with a new supplier or partner. This includes checking Companies House, the company’s website, including the existence of a modern slavery statement, media stories and ensuring apprentices have a contract of employment.

• Consider the country, sector, nature of services, use of agency/temporary labour, and any red flags (e.g., unusual payment terms or reluctance to provide basic compliance information).

• Acknowledge that reporting “no risk” may indicate insufficient due diligence, rather than a genuinely risk‑free supply chain.

Our Practices

• Risk Assessment and Due Diligence: We conduct regular risk assessments of our operations and supply chains to identify and mitigate the risk of modern slavery.

• Supplier Code of Conduct: We expect our suppliers to adhere to the same high standards and take steps against forced, compulsory, or trafficked labour; this includes productive, value-adding, unpaid internships.

• Training and Awareness: We train our employees to ensure they understand the risks of modern slavery and how to report any concerns.

• Reporting and Whistleblowing: We encourage all employees and business partners to report any concerns related to modern slavery to one of the directors. We have a confidential whistleblowing policy in place to protect those who report in good faith.

Due Diligence on Suppliers and Partners

We apply proportionate checks suitable for a small provider and document the results:

• Review the supplier’s own modern slavery policy/statement or, if out of scope, written confirmation they align with the Modern Slavery Act’s principles.

• Check public information (e.g., company website, policy statements), and where relevant ask for proof of basic controls (e.g., right‑to‑work checks, use of contracted staff, escalation routes).

• Prefer UK‑based suppliers where appropriate and cost‑effective; where we engage non‑UK services, we seek additional assurance.

• Record decisions, any follow‑up actions, and contract terms that allow us to audit/terminate for non‑compliance

Supplier Code of Conduct (Summary)

Our suppliers, contractors, assessment/awarding partners, and employers hosting apprentices must:

• Prohibit forced, bonded or involuntary labour, trafficking, and child labour.

• Ensure fair working conditions, lawful wages, and no retention of identity documents.

• Provide safe channels for workers to raise concerns without retaliation.

• Cascade these standards to their own suppliers and cooperate with our checks.

• Accept that a serious breach may lead to suspension or termination of the relationship.

Training and Awareness

• Induction training for all new staff covers modern slavery risks, how to spot red flags, and how to raise concerns.

• Annual refresher for all staff; targeted updates if government guidance changes (e.g., March 2025 update).

• Managers and anyone involved in procurement, contracting, employer engagement or apprenticeship onboarding receive additional, role‑specific guidance.

Reporting Concerns (Including Anonymous Routes)

Any employee, supplier, employer, partner, learner, or member of the public may raise a concern if something does not look right. Concerns should be reported immediately to a Director.

Options include:

• Speaking directly to the Compliance Lead/Director.

• Emailing directors@dn-uk.com from a work or personal email address.

• Placing the details in a sealed envelope marked “Private” and addressed to Digital Native C/o Bennett Corner House, 33 Coleshill Street, Sutton Coldfield, West Midlands, United Kingdom, B72 1SD.

We log each concern, acknowledge receipt (where contact details are provided), and assess it promptly. We will handle all concerns sensitively and only share information on a need‑to‑know basis. Retaliation is strictly prohibited; anyone raising a concern in good faith will not face any disadvantage.

Escalation, Whistleblowing and External Reporting

If a concern is serious (e.g., exploitation, safeguarding issues, or criminal activity) or involves senior staff, it will be escalated to the Board for oversight.

• Where required, we will report to law enforcement and relevant agencies without delay.

• Individuals may also raise serious concerns through external channels, including the Home Office modern slavery helplines, or, where the issue affects learners or public funds in education settings, via Ofsted’s concerns/complaints route.

Remediation and Support

If we identify a modern slavery risk or incident, we will:

• Prioritise safety and welfare of affected individuals and take immediate steps to stop the harm.

• Work with appropriate authorities and specialist organisations as needed.

• Review and, where necessary, terminate relationships linked to exploitation; or, if appropriate, agree a time‑bound corrective action plan with the supplier and monitor progress.

• Record lessons learned and adjust our processes, training and due diligence. The updated statutory guidance encourages organisations to be transparent about incidents and remediation where safe and lawful to do so.

Sector‑Specific Expectations (Apprenticeships)

Because we deliver apprenticeships, we will also:

• Investigate all employers before engaging with them.

• Make it easy for apprentices to raise concerns about working conditions at their employer, including through confidential channels.

• Act swiftly if a job appears unsafe, coercive or exploitative; we will pause learning, contact the employer, and, where necessary, notify relevant authorities.

• Include modern slavery and fair‑work expectations in employer onboarding and ongoing reviews.

Records and Evidence

We keep records of risk assessments, due diligence checks, supplier confirmations, training logs, investigations, decisions, and remediation actions. This supports transparency and provides an audit trail consistent with government guidance that now expects clearer, evidence‑based reporting.

Policy Review and Approval

This policy is reviewed periodically and whenever relevant laws or guidance change. It is approved by the Board and published internally and on DN-UK.COM.

The Privacy Policy

This privacy policy is for this website; [www.dn-uk.com] and served by Digital Native Ltd, Innovation Birmingham, Holt Street, Birmingham, West Midlands B7 4BB and governs the privacy of its users who choose to use it. It explains how we comply with the GDPR (General Data Protection Regulation), the DPA (Data Protection Act) [pre GDPR enforcement] and the PECR (Privacy and Electronic Communications Regulations).

This policy will explain areas of this website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights under the GDPR, DPA & PECR are adhere to. Additionally it will explain the use of cookies or software, advertising or commercial sponsorship from third parties and the download of any documents, files or software made available to you (if any) on this website. Further explanations may be provided for specific pages or features of this website in order to help you understand how we, this website and its third parties (if any) interact with you and your computer / device in order to serve it to you. Our contact information is provided if you have any questions.

The DPA & GDPR May 2018

We and this website complies to the DPA (Data Protection Act 1998) and already complies to the GDPR (General Data Protection Regulation) which comes into affect from May 2018. We will update this policy accordingly after the completion of the UK’s exit from the European Union.

Use of Cookies

This website uses cookies to better the users experience while visiting the website. As required by legislation, where applicable this website uses a cookie control system, allowing the user to give explicit permission or to deny the use of /saving of cookies on their computer / device.

What are cookies?

Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website. Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit.

Website Visitor Tracking

This website uses tracking software to monitor its visitors to better understand how they use it. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.

Adverts and Sponsored Links

This website may contain sponsored links and adverts. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.

Clicking on any such adverts will send you to the advertisers website through a referral program which may use cookies and will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computers hard drive. Users should therefore note they click on sponsored external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Remarketing

This website uses cookies when you visit our website and the websites and apps where we display advertisements. This information may include the content you view, the date and time you viewed this content and the location associated with your IP address. We use this information to serve you more relevant advertisements. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings. You can opt out of personalised advertisements on Facebook by visiting Facebook’s Ad settings.

Downloads & Media Files

Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti virus software or similar applications.

We accept no responsibility for third party downloads and downloads provided by external third party websites and advise users to verify their authenticity using third party anti virus software or similar applications.

Contact & Communication

Users contacting this us through this website do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.

Where we have clearly stated and made you aware of the fact, and where you have given your express permission, we may use your details to send you products/services information through a mailing list system. This is done in accordance with the regulations named in ‘The policy’ above.

Email Mailing List & Marketing Messages

We operate an email mailing list program, used to inform subscribers about products, services and/or news we supply/publish. Users can subscribe through an online automated process where they have given their explicit permission. Subscriber personal details are collected, processed, managed and stored in accordance with the regulations named in ‘The policy’ above. Subscribers can unsubscribe at any time through an automated online service, or if not available, other means as detailed in the footer of sent marketing messages (or unsubscribe from all HubSpot lists). The type and content of marketing messages subscribers receive, and if it may contain third party content, is clearly outlined at the point of subscription.

Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

Our EMS (email marketing service) provider is; HubSpot and you can read their privacy policy in the resources section.

External Website Links & Third Parties

Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites.

Shortened URL’s; URL shortening is a technique used on the web to shorten URL’s (Uniform Resource Locators) to something substantially shorter. This technique is especially used in social media and looks similar to this (example: https://bit.ly/2u6Xfmo). Users should take caution before clicking on shortened URL links and verify their authenticity before proceeding.

We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Policy & Usage

We adopt a Social Media Policy to ensure our business and our staff conduct themselves accordingly online. While we may have official profiles on social media platforms users are advised to verify authenticity of such profiles before engaging with, or sharing information with such profiles. We will never ask for user passwords or personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.

There may be instances where our website features social sharing buttons, which help share web content directly from web pages to the respective social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about some social media privacy and usage policies in the resources section below.

Resources & Further Information

• Overview of the GDPR – General Data Protection Regulation

• Data Protection Act 1998

• Privacy and Electronic Communications Regulations 2003

• The Guide to the PECR 2003

• Twitter Privacy Policy

• Facebook Privacy Policy

• Google Privacy Policy

• Linkedin Privacy Policy

• HubSpot Privacy Policy

SAFEGUARDING AND PREVENT DUTY POLICY 

Digital Native are fully committed to safeguarding the welfare of our apprentices. The development and implementation of this policy and procedures are an integral part of Digital Native’s determination to provide high-quality responsive services, which meet the needs of our customers and service users.

All staff, associates and volunteers have a responsibility to take appropriate steps to protect our apprentices at risk and to understand their responsibility to operate within this policy. Good safeguarding includes arrangements for prevention as well as responding to allegations of harm and abuse. Harm and abuse may include physical, sexual, psychological, financial and institutional abuse, acts of neglect and omission and discrimination. All allegations concerns or suspicions of abuse or neglect are taken seriously by Digital Native and responded to in line with our procedures and within the reporting structures of the local authority in which we work.

Allegations made against members of staff will be dealt with. Digital Native handle all disclosures in accordance with the requirements of a national framework of standards and good practice and outcomes in Adult protection (ADASS 2006). This policy states our approach to preventing and responding to safeguarding issues.

INTRODUCTION 

Digital Native fully recognises its statutory and moral duty to promote the safety and welfare of those apprentices who are under the age of 18 years and those adult learners who are deemed to be vulnerable; however; Digital Native has a moral duty and is committed to the safeguarding of all learners regardless of their age and vulnerability.

This policy has been developed in accordance with the principles established by the:

• Children and Social Work Act 2017

• The Education Act 2011, and in line with the government publication:

• ‘Keeping Children Safe in Education 2025’ the statutory guidance.

• The Local Safeguarding Children Board (LSCB) procedures.

All staff should ensure that they have read and understood the associated policies to support the effective implementation of the safeguarding policy and procedures.  In addition, as a minimum all coaching staff should read and understand KCSE 2025 Part 1.

SCOPE 

This policy and its procedures will apply to:

• The Board of directors

• The Governance board

• Employees of Digital Native

• Apprentices

• Contractors

• Employers providing an apprenticeship

• All other users of Digital Native

• All Digital Native activities

The Policy and Procedures will apply at all times when Digital Native is providing services or activities that come under the responsibility of the organisation.

COMMUNICATION AND DISSEMINATION OF THE POLICY 

Digital Native recognises that safeguarding and promoting the welfare of its apprentices is everyones responsibility. Everyone who comes into contact with an apprentice and their families, carers and employers has a role to play in safeguarding. The safeguarding policy is shared with all staff, apprentices and employers on an annual basis and as and when any in-year updates are made aligned to legislation changes.

The policy, its purpose and reporting procedures will be reinforced via team and employer meetings, staff training, learning resources and literature. Additional support and guidance will be provided to ensure that any apprentice with a learning difficulty or language barrier can access the policy, its aims and supporting literature.  All staff have read and confirmed their understanding of the Keeping Children Safe in Education 2025 Part One.

SAFER RECRUITMENT AND TRAINING FOR STAFF 

When recruiting new members of staff, Digital Native follows the government guidance “Safeguarding Children: Safer Recruitment in Education” and Safer Recruitment principles and pays due regard to the Safeguarding Vulnerable Groups Act 2006 (including the 2025 amendment of sharing barred list information) and the Protection of Freedoms Act 2012. In addition, Digital Native is aware and adheres to the Safer Recruitment areas in KCSIE September 25. As part of employment contracts, staff are made aware that Digital Native can make a referral to DBS, if appropriate, following investigation.

Digital Native adapts the guidelines within the Baseline Security Standard (BPSS) for all appointments and ensures that the relevant staff member uses the Enhanced DBS checking service to assess applicants’ sustainability for positions of trust. The company also compiles fully with the Code of Practice and aims to treat all applicants for positions fairly. DBS checks are undertaken in line with government guidance and current legislation, alongside appropriate references being obtained and ensuring qualifications are verified. Safer Recruitment training has been undertaken by senior members of staff who conduct recruitment activities in accordance with statutory guidance.

Newly appointed staff will have a job role induction to include a robust introduction into the safeguarding of children, young people and adults at risk policy and procedures. This includes mandatory reading of internal and external policies and e-learning modules.

DEFINITIONS 

Although legislation is specifically related to children and vulnerable adults as defined below, Digital Native is committed to the safeguarding of all apprentices and the term apprentice is used throughout this policy.

Child – In terms of this policy, a child is defined as anyone who has not reached their 18th birthday.

Vulnerable Adults – In terms of this policy, a vulnerable adult is defined as a person aged 18 years or over and who is or may be in need of community care services by reason of mental or other disability, age or illness and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation. This may include a person who has a learning difficulty, a physical or sensory disability or a mental illness.

Definition of Safeguarding: Safeguarding and promoting the welfare of learners is defined in ‘Working Together to Safeguard Children (2023)’ as:

• Protecting children from maltreatment whether that is within or outside the home including online

• Providing help and support to meet the needs of children as soon as problems emerge

• Preventing impairment of children’s mental and physical health or development

• Ensuring that children are growing up in circumstances consistent with the provision of safe and effective care

• Promoting the upbringing of children with their birth parents or otherwise their family network through a kinship care agreement whenever possible and where this is in the best interest of the children.

• Taking action to enable all children to have the best outcomes in line with the outcomes set out in the  Children’s Social Care National Framework

Note: Apprentices with additional needs and/or disabilities can face further safeguarding challenges. It is essential that these apprentices are given the support and guidance to remove barriers. 

SAFEGUARDING ACTIONS MAY BE NEEDED TO PROTECT APPRENTICES FROM THE FOLLOWING: 

• Physical abuse

• Emotional abuse

• Sexual abuse

• Neglect

• Bullying including cyberbullying

• Child missing from education

• Child missing from home or care

• Child sexual exploitation (CSE)

• Domestic violence

• Drugs

• Fabricated or induced illness

• Faith abuse

• Female genital mutilation (FGM)

• Forced marriage

• Gangs and youth violence

• Gender-based violence / violence against women and girls (VAWG)

• Mental health

• Private fostering

• Preventing radicalisation

• Relationship abuse

• Sexting

• Trafficking

• Sexual Violence

• Sexual Harassment

Staff need to have an awareness of the different types of safeguarding issues and explanations and definitions (Appendix A). Staff should also be aware that behaviours linked to, for example, drug taking, alcohol; abuse, absence from work and apprenticeship days and sexting also put apprentices in danger.

Digital Native take their safeguarding responsibilities very seriously and as such will not tolerate any forms of abuse, bullying or harassment.

LOOKED AFTER CHILDREN 

All staff need to be aware of issues around safeguarding looked after children. The most common reason for young people becoming looked after is as a result of abuse and/or neglect.

APPRENTICES WITH SPECIAL EDUCATIONAL NEEDS AND DISABILITIES 

All staff need to be aware that additional barriers can exist when recognising abuse and neglect in apprentices with special educational needs (SEN) and disabilities.
This can include:

• Assumptions that indicators of possible abuse such as behaviour, mood and injury relate to the apprentice’s disability without further exploration.

• Apprentices with SEN and disabilities can be disproportionally impacted by issues such as bullying without outwardly showing any signs.

• Communication barriers and difficulties in overcoming these barriers.

• Staff should refer to the apprentice’s education, health care plan (EHCP). This will provide additional guidance specific to the apprentice’s support needs.

• Digital Native recognises that safeguarding is not just about protecting apprentices from deliberate harm, neglect and failure to act. It relates to the broader aspects of care and education and the following procedures should be read in conjunction with this policy:

• Health and Safety Policy

• Safer Recruitment Policy and Guidelines

• Learner Behaviour Policy

• External Speakers and Events Policy

PROCEDURE FOR STAFF 

If Digital Native staff have concerns about a apprentice:

• If staff members have any concerns about an apprentice, this must be referred to the Designated Safeguarding Lead to agree a course of action. All referrals need to go to safeguarding@dn-uk.com. Options can include referral to specialist services or early help services. Digital Native recognises its role in identifying apprentices who may benefit from early help and providing support as soon as a problem emerges in a apprentice’s life.  Providing early help is more effective in promoting the welfare of young people than reacting later. Staff may be required to support other agencies and professionals in an early help assessment and share information support early identification and assessment. The DSL will be required to report a referral immediately to the local safeguarding authority.

• If early help is appropriate, the Designated Safeguarding Lead (DSL) will support the staff member to liaise with external agencies. The apprentice should then be monitored and if the situation does not appear to be improving, a referral will be made by the Designated Safeguarding Lead to the Local Authority Designated Officer (LADO) or Local Safeguarding Board to ensure the apprentice’s situation improves.

• Prevent related concerns should also be escalated to the designated safeguarding lead immediately who will refer to the regional Prevent Coordinator for advice and guidance.

IF DIGITAL NATIVE STAFF BELIEVE AN APPRENTICE IS IN IMMEDIATE DANGER OR AT RISK OF HARM:

This immediate concern must be reported to the Designated Safeguarding Lead and if an apprentice is in immediate danger or is at risk of harm, a referral will be made to the Local Authority Designated Officer (LADO), Safeguarding Board or to the police immediately.
Staff responsibilities or 5Rs are summarised as:

1. Recognise

2. Respond

3. Record

4. Report

5. Refer

IF AN APPRENTICE MAKES A DISCLOSURE TO A MEMBER OF STAFF 

• If an apprentice makes a disclosure to a member of staff, the apprentice should be acknowledged, taken seriously and listened to.

• As soon as it becomes clear that the apprentice is talking about a safeguarding issue, you need to gently stop them and inform them that you have a legal obligation to pass this information on to a Designated Safeguarding Lead. You cannot promise confidentiality to the apprentice. Reassure the apprentice but tell them that a record of information given will be made.

• It is important not to ask too many questions as you must not under any circumstances investigate any accusations.

• Allow the apprentice to freely recall significant events, keeping questions to the absolute minimum necessary to ensure a clear and accurate understanding of what has been said. Record the factual details of what has been told to you and send this to the safeguarding@dn-uk.com email.  If urgent, this needs to be followed up by a teams call to the DSL.

• The Designated Safeguarding Lead will outline the action that he/she has to take so that you can explain this to the apprentice. It may be appropriate for the Designated Safeguarding Lead to meet the apprentice. You must not take any further action yourself. This includes contacting parents/carers or outside agencies. The DSL will be required to report a referral immediately to the local safeguarding authority.

MEMBER OF STAFF RECEIVES INFORMATION ABOUT AN APPRENTICE FROM ANOTHER PERSON 

If a member of staff receives information about an apprentice, which suggests that there is a safeguarding issue or that this is likely, this must be reported immediately to the Designated Safeguarding Lead using the email safeguarding@dn-uk.com.  Digital Native has a duty to refer these concerns to the Local Authority Children’s Social Care Office for the area in which the apprentice lives or to the police if the learner is in immediate danger.

IF A MEMBER OF STAFF SUSPECTS AN APPRENTICE HAS A SAFEGUARDING CONCERN 

If a member of staff suspects that an apprentice is at risk from a safeguarding issue, they must discuss these concerns with the Designated Safeguarding Lead and not take any independent action. The concerns must be recorded through the safeguarding@dn-uk.com email.

All contact with outside agencies over issues of safeguarding must be approved by the Designated Safeguarding Lead. The Designated Safeguarding Lead will decide whether to make  a referral to children’s social care, Local Safeguarding Board or Local Authority Designated Officer (LADO).

Local authorities, with the help of other organisations as appropriate, have a duty to make enquires under section 47 of the Children Act 2004 if they have reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm. Such enquiries enable them to decide whether they should take any action to safeguard and promote the child’s welfare and must be initiated where there are concerns about maltreatment, including all forms of abuse and neglect, female genital mutilation or other so called honour based violence, and extra-familial threats like radicalisation and sexual exploitation. Parents / carers have the right to be informed in respect of any concerns or any action taken to safeguard and promote their welfare, providing this does not compromise the learner’s safety. Keeping Children Safe in Education (2025).

ALLEGATIONS OF ABUSE MADE AGAINST OTHER YOUNG PEOPLE 

Staff must recognise that young people are capable of abusing their peers and be aware that safeguarding issues can manifest themselves via peer on peer abuse. Peer on peer abuse is abuse young people may experience from their peers (people of their own or similar age) perpetrated by a young person/s (under the age of 18 years)/vulnerable adult/s on young person/s/vulnerable adult/s.

Staff need to be aware that abuse is abuse and should never be tolerated or passed off as ‘banter’ or ‘part of growing up’. Digital Native will take any concerns of this nature very seriously and concerns should be raised in the same way as any other concerns, directly to their coach or to the Safeguarding Team.

Peer on peer abuse can take the form of bullying (including cyber-bullying) sexting and any other form of sexual or physical abuse. Gender based issues can also occur for example girls being sexually touched/ assaulted or boys being subject to initiation/hazing type violence.

VISITORS 

All official visitors to Digital Native rented locations are required to report to reception on arrival and sign in. Visitors are issued with a visitor pass which must always be worn and visible. Visitors are asked to wait in reception until they are collected by a member of staff. Visitors are not permitted to enter access-controlled areas unless accompanied by a member of staff. Guest Speakers will be subject to the guest speaker policy vetting procedure. All centres must carry out appropriate checks on the material that is being presented prior to a guest speaker event. The relevant checks must be made against all guest speakers before any event is approved. Guest speakers are not permitted to work alone with any apprentices and will always be accompanied by a coach.

APPRENTICES WORK SETTINGS 

Digital Native has a responsibility to ensure the health, safety and welfare of all apprentices undertaking apprenticeships with employers. Digital Native will ensure that employers are aware of this policy and their responsibilities for compliance in relation to Safeguarding and the Prevent duty for any apprentice who is placed with them and that arrangements are in place to ensure that an apprentice’s wellbeing is safeguarded. This is checked as part of the role scan with the employer before commencing the apprenticeship.

APPRENTICES WITH CRIMINAL CONVICTIONS 

Digital Native is committed to the fair treatment of all apprentices and welcomes applications from a wide range of individuals, including those with criminal convictions. Digital Native is committed to the equality of opportunity and selects individuals based on their skills, qualifications and experience and not on their background or personal circumstances. Having a criminal conviction will not necessarily prevent someone from studying at Digital Native.

Digital Native is mindful, however, of the duty of care it owes to its apprentices, staff and the wider community to act reasonably to protect their health, safety and welfare. As a consequence, Digital Native requires all applicants to disclose any criminal convictions on application and re-enrolment. If a criminal conviction is disclosed or otherwise brought to our attention, Digital Native will work with that person to determine the level of risk posed by the conviction to both the individual and/or to others. The individual will be required to complete a safeguarding risk assessment, providing Digital Native with further information about the offence and contact details for any relevant third party e.g. a Probation Officer.

The information given on the Disclosure Form will then be used to assess whether there is any risk posed should the individual enrol on a course at Digital Native. An interview must take place with the Designated Safeguarding Lead before enrolment to approve the application and consent to onboading. Where medium/high risk has been identified, this will be referred to the board of directors and onboarding deferred until a decision is reached.

CONCERNS ABOUT A STAFF MEMBER 

A low-level concern is any concern that an adult has acted in a way that:

• is inconsistent with the staff code of conduct, including inappropriate conduct outside of work

• does not meet the allegations threshold or is not considered serious enough to refer to the local authority designated officer (LADO).

Examples of low-level concerns could include being

• Over friendly with apprentices

• Having favourites

• Taking photographs of apprentices on their mobile phone

• Engaging with an apprentice on a one-to-one in a secluded area or behind a closed door

• Using inappropriate sexualised, intimidating or offensive language

• Consistently not recording teams calls or taking screenshots of individuals on teams

Low-level concerns should be reported to the DSL or a director. If there are concerns about a DSL, these should be reported to the directors and the governance board. The DSL will record all low-level concerns. Records should include the details of the concern, how the concern arose and the actions taken.

On receipt of an allegation that is a high-level concern, Digital Native’s Disciplinary Procedures relating to allegations of abuse will be followed.

• Suspension on full pay while the issue is investigated. We will take a sensible approach

• Consult our HR advisor or local safeguarding board for advice

• In everyone’s interests, aim for a swift but thorough investigation

• Maintain confidentiality

• Should the employee leave the organisation, the investigation continues to its conclusion as though they were still in employment.

Additionally, the governance board will be notified if the allegations relate to any of the directors of Digital Native and the above procedure will be followed.

CONCERNS ABOUT SAFEGUARDING PRACTICES 

All staff should feel able to raise concerns about poor or unsafe practice and potential failures in Digital Native’s safeguarding practices and that such concerns would be taken seriously by the Leadership Team.

If staff members have any concerns about the safeguarding regime, they should raise this initially with their director. If no immediate action is taken, then appropriate Whistleblowing Procedures are in place for such concerns to be raised with additional directors and the governance board. Where a staff member feels unable to raise an issue with Digital Native or feels that their genuine concerns are not being addressed, other whistleblowing channels may be open to them: General guidance can be found below – Advice on whistleblowing.

The NSPCC whistleblowing helpline is available for staff who do not feel able to raise concerns regarding child protection failures internally. Staff can call: 0800 028 0285 – line is available from 8:00 AM to 8:00 PM, Monday to Friday and Email: help@nspcc.org.uk

RESPONSIBILITIES 

THE BOARD OF DIRECTORS 

The Board will: 

• Ensure that Digital Native has an effective Safeguarding Policy in place which is updated annually and that Digital Native contributes to inter-agency working in line with statutory guidance ‘Working Together to Safeguard Children 2023’ and ‘Keeping Children Safe in Education 2025’.

• Ensure that the Safeguarding arrangements take into account the procedures and practice of the local authority as part of the inter-agency safeguarding procedures set up by the Local Safeguarding Children Board (LSCB).

• Ensure that Digital Native complies with the Prevent Duty as set out in the Prevent Duty Guidance for England and Wales 2023

• Ensure that the policies and procedures in place enable appropriate action to be taken in a timely manner to safeguard and promote apprentice welfare.

• Appoint a Board Member with responsibility for Safeguarding and Prevent who will liaise with the Designated Safeguarding Lead.

• Ensure that a Designated Safeguarding Lead is appointed to lead on safeguarding, advise/support staff and liaise with the Local Authority and other agencies. He/she will have status/authority to carry out the role e.g. commit resources to safeguarding and direct staff as appropriate.

• Give scrutiny to regular reports which will provide detail on the numbers and types of safeguarding incidents and concerns which have arisen

• Ensure that any deficiencies or weaknesses in safeguarding arrangements are remedied without delay.

• Ensure that a member of the Governance Board is nominated to liaise with the designated officer for the relevant local authority and partner agencies in the event of a safeguarding allegation being made against the board of directors

THE QUALITY DIRECTOR 

The Quality Director has the overall responsibility for and oversight of Safeguarding within Digital Native and will ensure through the Digital Native Management and Leadership Team that:

• Safeguarding policies and procedures and any linked Safeguarding polices are fully implemented and followed by all staff.

• All staff feel able to raise concerns about poor or unsafe practice regarding apprentices and that concerns will be addressed sensitively and in a timely and appropriate manner.

• Policy / procedures are available to parents / carers and employers on request.

THE DESIGNATED SAFEGUARDING LEAD (DSL) 

The Designated Safeguarding Lead/s will:

• Ensure that the Safeguarding Policy, including Prevent, is reviewed annually and the procedures and implementation are reviewed regularly by the directors and governance board.

• Ensure that the Safeguarding Policy is made public (via website) and that parents/carers and employers are aware of the fact that referrals about suspected abuse or neglect may be made and the role of Digital Native in this.

• Report to the board quarterly, detailing any changes to the policy and procedures; training undertaken by self, staff with specific responsibility and all other staff and board members and number and type of incidents/cases.

• Ensure the quality assurance of the provision of safeguarding information, advice and guidance and procedures.

• Ensure there is liaison with employers providing apprenticeships to ensure proper safeguarding arrangements are in place.

• Act as a source of support, advice and expertise to staff on matters of safety and safeguarding and, when deciding to make a referral, by liaising with relevant agencies.

• Keep detailed, accurate, confidential and secure written records of concerns, disclosures and referrals. Ensure all such records are kept confidentially and securely.

• Liaise with the Safeguarding Team / any other relevant staff to inform of any issues/ongoing investigations.

• Ensure the Safeguarding Team acts as a key point of referral for apprentices/ staff /parents / carers/employers, offer advice, assess information promptly, take action or refer on to the Designated Safeguarding Lead so that Digital Native can respond swiftly and appropriately to all concerns referrals and disclosures.

• Have access to resources and attend any relevant or refresher training courses at least every two years.

• Ensure that a member of the Safeguarding Team attends case conferences, core groups, or other multi-agency planning meetings, contributes to assessments, and provides a report if applicable.

PREVENT DUTY

The Prevent Duty, introduced as part of the Counter-Terrorism and Security Act 2015, came into effect for key bodies including schools, health bodies and police on 1 July 2015. The duty commenced for further and higher education institutions from the 18 September 2015.

The aim of the Prevent Strategy is to reduce the threat to the UK from terrorism by stopping people becoming terrorists or supporting terrorism. In the Act this has simply been expressed as the need to have “due regard to the need to prevent people from being drawn into terrorism”. This includes not just violent extremism but also non-violent extremism, which can create an atmosphere conducive to terrorism and can popularise views which terrorists exploit.

Where deemed appropriate, Digital Native will seek external support for apprentices through referrals to the Channel Programme. This programme aims to work with the individual to address their specific vulnerabilities and prevent them becoming further radicalised.

AIMS OF THE PREVENT POLICY

This policy has the following aims:

• To create a safe space for free and open debate.

• To promote a sense of community cohesion.

• To ensure that apprentices are safe and that we create an environment that is free from bullying, harassment and discrimination.

• To support apprentices who may be at risk from radicalisation and to be able to signpost them to further external sources of support where appropriate.

• To ensure that staff are aware of their responsibilities under this policy and are able to recognise and respond to vulnerable apprentices.

• To promote and reinforce a set of shared values, founded on tolerance and respect for others.

BRITISH VALUES

For the purposes of this policy British values will be defined as:

“Democracy, the rule of law, individual liberty and mutual respect and tolerance for those with different backgrounds, characteristics, beliefs and faiths”

WHAT IS TERRORISM / EXTREMISM?

Terrorism covers all forms of extremism both violent and non-violent and is defined in the national Prevent Strategy as any vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty, and mutual respect and tolerance of different faiths and beliefs. Prevent covers international and domestic terrorist threats, and includes the activities of far-right groups, and animal rights groups.

WHAT IS RADICALISATION?

Radicalisation is defined as the process by which people come to support terrorism and extremism and, in some cases, to then participate in terrorist groups. There is no obvious profile of a person likely to become involved in extremism or a single indicator of when a person might move to adopt violence in support of extremist ideas.

The process of radicalisation is different for every individual and can take place over an extended period or within a very short time frame. Safeguarding from extremism is no different to how staff would share a concern about drugs, physical and sexual abuse or any other safeguarding concern.

WHAT IS CHANNEL?

Channel is a key element of the Prevent Strategy. It is a multi-agency approach to protect people at risk from radicalisation using collaboration between local authorities, statutory partners, the police and local community to:

• Identify individuals at risk of being drawn into terrorism

• Assess the nature and extent of that risk

• Develop the most appropriate support plan for the individual concerned

The following indicators identify factors that may suggest a young person or their family may be vulnerable to being drawn into extremism:

• Identity crisis – distance from culture religious heritage and uncomfortable with their place in the society around them.

• Personal crisis – family tensions, sense of isolation, adolescence low self-esteem, disassociation from existing friendship groups and becoming involved with a new and different group of friends searching for answers to questions about identity, faith and belonging.

• Personal circumstances – migration, local community tensions, events affecting Country and region of origin, alienation from UK values having a sense of grievance that is triggered by personal experience of racism or discrimination or aspects of Government policy, unmet aspirations, perceptions of injustice feeling of failure, rejection of civic life, criminality, experiences of imprisonment, poor resettlement, reintegration, previous involvement with criminal groups.

The process of radicalisation is different for every individual and can take place over an extended period or within a very short time frame. Potential indicators of radicalisation are listed below:

• Use of inappropriate language

• Possession or accessing violent extremist literature

• Behavioural changes

• The expression of extremist views

• Advocating violent actions and means

• Association with known extremists

• Articulating support for violent extremist causes or leaders

• Using extremist views to explain personal disadvantage

• Joining or seeking to join extremist organisations

• Seeking to recruit others to an extremist ideology

Any prejudice, discrimination or extremist views, including derogatory language, displayed by apprentices or staff will always be challenged and where appropriate will be dealt with in line with the Learner Disciplinary Policy and the Code of Conduct for staff.

Staff should use their professional judgement and discuss with a Designated Safeguarding Person if they have any concerns. As with Safeguarding, concerns will be referred through the safeguarding@dn-uk.com email. Once assessed, and if appropriate, this will be referred into the Channel Panel Process as per the flowchart on page 15.

Digital Native has a Prevent Risk Assessment that is reviewed annually and has identified a single point of contact (SPOC) in relation to Prevent which is the Designated Safeguarding Lead.  To ensure compliance with the Prevent duty, all staff must make sure that they:

• Undertake training in the Prevent duty as identified by Digital Native to ensure they have an understanding of the factors that make people vulnerable to being drawn into terrorism and that they are able to recognise this vulnerability and are aware of what action to take.

• Exemplify British/Community Values into their work and practice and that opportunities in the delivery of the apprenticeship are used to promote these values to apprentices

MANAGING RISKS AND RESPONDING TO EVENTS

Embedding values within the provision

Equality and Diversity, the values of respect and tolerance will be embedded within all learning sessions, learning materials and progress review meetings. Coaches will be empowered to encourage open and safe debate with support from specialist staff where this is deemed necessary.

The Designated Safeguarding Lead, will have overall responsibility for the coordination of Prevent activity.

SAFEGUARDING LEARNERS PROCEDURE FLOW DIAGRAM

Learner discloses a safeguarding concern to a member of staff

Learner discloses a safeguarding concern directly to the Designated Safeguarding Lead

Member of Staff suspects a safeguarding concern

A third party reports a safeguarding concern to a member of staff

Follow the process for taking the disclosure and record via email. Contact the Designated Safeguarding Lead to discuss and take the relevant action

The disclosure will be taken and recorded, or the learner contacted to arrange a disclosure. Relevant reporting action.

Follow the ‘Third Party’ procedure

Record the concerns via email and contact the Designated Safeguarding Lead to take the relevant action

Relevant action identified by the Designated Safeguarding Lead

Referral Not Required Early intervention and support agreed by the DSL

Learner considered vulnerable. Monitored by the DSL and coach. Referrals made if concerns escalate

Referral made by DSL Local Authority Informed Reported to the Governance Board and board of directors

APPENDIX A DEFINITIONS

(Definitions taken from Keeping Children Safe in Education (KCSE) 2025 and the supplementary guidance within KCSE)

Staff should be aware that abuse, neglect and safeguarding issues are rarely standalone events that can be covered by on definition or label. In most cases multiple issues will overlap with one another.

Abuse: a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults or another child or children.

Physical Abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.

Emotional Abuse: the persistent emotional maltreatment of a child such as to cause severe and adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill treatment of another. It may involve serious bullying (including cyberbullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Sexual Abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.

Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: provide adequate food, clothing and shelter (including exclusion from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate care-givers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.

Specific Safeguarding Issues: Bullying, including cyberbullying: Under the Children Act 2004, a bullying incident should be addressed as a child protection concern when there is ‘reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm’. Where this is the case, Digital Native staff should report their concerns to a member of the Safeguarding Team. Even where safeguarding is not considered to be an issue, Digital Native may need to draw on a range of external services to support the learner who is experiencing bullying, or to tackle any underlying issue which has contributed to a learner engaging in bullying.    Bullying is behaviour by an individual or group, repeated over time, that intentionally hurts another individual or group either physically or emotionally. Bullying can take many forms (for instance, cyber-bullying via text messages or the internet), and is often motivated by prejudice against particular groups, for example on grounds of race, religion, gender, sexual orientation, or because a child is adopted or has caring responsibilities.

It might be motivated by actual differences between children, or perceived differences. Stopping violence and ensuring immediate physical safety is obviously the Digital Native’s first priority but staff need to be aware that emotional bullying can be more damaging than physical. Many experts say that bullying involves an imbalance of power between the perpetrator and the victim.

This could involve perpetrators of bullying having control over the relationship which makes it difficult for those they bully to defend themselves. The imbalance of power can manifest itself in several ways, it may be physical, psychological (knowing what upsets someone), derive from an intellectual imbalance, or by having access to the support of a group, or the capacity to socially isolate. It can result in the intimidation of a person or persons through the threat of violence or by isolating them either physically or online.

Missing from Education: A young person going missing from education is a potential indicator of abuse or neglect. Digital Native staff should follow the Digital Native’s procedures for dealing with learners that go missing from education, particularly on repeat occasions, to help identify the risk of abuse and neglect, including sexual exploitation, and to help prevent the risks of their going missing in future. It is essential that all staff are alert to signs to look out for and the individual triggers to be aware of when considering the risks of potential safeguarding concerns such as travelling to conflict zones and forced marriage. Any concerns should be referred to a member of the Safeguarding Team.

Looked after Child: a child who is looked after by a local authority by reason of a care order or being accommodated under section 20 of the Children Act 2004

Care Leaver: an eligible, relevant or former relevant child as defined by the Children Act 2004.   

Sexual Exploitation and Grooming: Grooming is when someone builds an emotional connection with a child to gain their trust for the purposes of sexual abuse or exploitation. Children and young people can be groomed online or in the real world, by a stranger or by someone they know – for example, a family member, friend or professional. Groomers may be male or female. They could be any age.

Child Sexual Exploitation (CSE): is a type of sexual abuse in which children are sexually exploited for money, power or status. Children or young people may be tricked into believing they’re in a loving, consensual relationship. They may also be groomed online. Some children and young people are trafficked into or within the UK for the purpose of sexual exploitation. Sexual exploitation can also happen to young people in gangs.

Signs and Symptoms: go missing from home, care or education, be involved in abusive relationships, intimidated and fearful of certain people or situations, hang out with groups of older people, or antisocial groups, or with other vulnerable peers, associate with other young people involved in sexual exploitation, get involved in gangs, gang fights, gang membership, have older boyfriends or girlfriends, spend time at places of concern, such as hotels or known brothels, not know where they are, because they have been moved around the country, be involved in petty crime such as shoplifting, have unexplained physical injuries, have a changed physical appearance, for example lost weight.

Domestic Violence: The definition of domestic violence and abuse is any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse can encompass, but is not limited to: • Psychological • Physical • Sexual • Financial • Emotional

Drugs: This includes alcohol, tobacco, illegal drugs, medicines, new psychoactive substances (‘legal highs’) and volatile substances.

Fabricated or Induced Illness: There are three main ways of the parent / carer fabricating or inducing illness in a child. These are not mutually exclusive and include:

• Fabrication of signs and symptoms which may include fabrication of past medical history

• Fabrication of signs and symptoms and falsification of hospital charts and records, and specimens of bodily fluids. This may include falsification of letters and documents

• Induction of illness by a variety of means

Faith Abuse: is child abuse linked to faith or belief. This includes: belief in concepts of witchcraft and spirit possession, demons or the devil acting through children or leading them astray (traditionally seen in some Christian beliefs), the evil eye or djinns (traditionally known in some Islamic faith contexts) and dakini (in the Hindu context); ritual or muti murders where the killing of children is believed to bring supernatural benefits or the use of their body parts is believed to produce potent magical remedies; and use of belief in magic or witchcraft to create fear in children to make them more compliant when they are being trafficked for domestic slavery or sexual exploitation.

This is not an exhaustive list and there will be other examples where children have been harmed when adults think that their actions have brought bad fortune, such as telephoning a wrong number which is believed by some to allow malevolent spirits to enter the home.

Honour Based Violence (HBV): So-called ‘honour based violence’ encompasses crimes which have been committed to protect or defend the honour of the family and/or the community, including Female Genital Mutilation (FGM), forced marriage and practices such as breast ironing. All forms of so-called HBV are abuse (regardless of the motivation) and should be handled and escalated as such. If in any doubts, staff should speak to one of the Safeguarding Team.

Female Genital Mutilation (FGM): Female Genital Mutilation (FGM) comprises all procedures involving partial or total removal of the external female genitalia or other injury to the female genital organs. It is illegal in the UK and a form of child abuse with long-lasting harmful consequences. Although the age of learners at Digital Native is such that they are not necessarily in the high risk category for FGM, a learner may disclose that she is at risk of FGM, has suffered FGM or that a sister or family member is at risk. Digital Native staff need to be alert to the possibility of a girl being at risk of FGM, or already having suffered FGM. The new mandatory reporting duty for FGM, introduced via the Serious Crime Act 2015, came into effect on 31 October 2015. This duty requires Digital Native to report known cases of FGM in under 18 year olds to the police. Signs and Symptoms: a long holiday abroad or going ‘home’ to visit family, relative or cutter visiting from abroad, a special occasion or ceremony to ‘become a woman’ or get ready for marriage, a female relative being cut – a sister, cousin, or an older female relative such as a mother or aunt.

Forced Marriage: Forcing a person into a marriage is a crime in England and Wales. A forced marriage is one entered into without the full and free consent of one or both parties and where violence, threats or any other form of coercion is used to cause a person to enter into a marriage. The pressure put on people to marry against their will can be physical (including threats, actual physical violence and sexual violence) or emotional and psychological (for example, when someone is made to feel like they’re bringing shame on their family).

Financial abuse: (taking wages or not giving money) can also be a factor.

A lack of full and free consent can be where a person does not consent or where they cannot consent (if they have learning disabilities, for example). Nevertheless, some communities use religion and culture as a way to coerce a person into marriage.

Gangs and Youth Violence: Gang Activity – Groups of children and young people often gather together in public places to socialise, and peer association is an essential feature of most children’s transition to adulthood. Groups of children and young people can be disorderly and/or anti-social without engaging in criminal activity. Young people on the periphery of becoming involved with street gangs and those young people already involved in some way can be described as ‘A relatively durable, predominantly street based group of young people who see themselves (and are seen by others) as a discernible group for whom crime and violence is integral to the group’s identity’.

Youth Violence: Youth violence, serious or otherwise, may be a function of gang activity. However, it could equally represent the behaviour of a child acting individually in response to his or her particular history and circumstances. ‘Serious youth violence’ is defined as ‘any offence of most serious violence or weapon enabled crime, where the victim is aged 1-19’, i.e. murder, manslaughter, rape, wounding with intent and causing grievous bodily harm. ‘Youth violence’ is defined in the same way, but also includes assault with injury offences. Most children and young people do not become violent overnight. Their behaviour represents many years of (increasingly) anti-social and aggressive acts.

Mental Health: Mental health problems can include depression, anxiety, eating disorders, self-harm, suicidal tendencies and the potential risk of harming others.

Youth Produced Sexual Imagery (Sexting): Making, possessing and distributing an imagery of someone under 18 which is indecent is illegal.  This includes imagery created by under 18s themselves. The relevant legislation is contained in the Protection of Children Act 2004 (England and Wales) as amended in the Sexual Offences Act 2003 (England and Wales). Specifically, it is an offence to possess, distribute, show and make images of children.  The Sexual Offences Act 2003 defines a child, for the purposes of indecent images, as anyone under the age of 18.    The latest guidance from the UK Council for Child Internet Safety (UKCCIS) introduces the phrase ‘youth produced sexual imagery’ instead of ‘sexting’. (August 2016).  This guidance refers to sexual imagery and not indecent imagery as indecent is subjective and has no specific definition in law.

The type of incidents covered by this guidance are:

• A person under the age of 18 creates and shares sexual images of themselves with a peer under the age of 18

• A person under the age of 18 shares sexual imagery created by another person under the age of 18 with a peer under the age of 18 or an adult

• A person under the age of 18 is in possession of sexual imagery created by another person under the age of 18

The sharing of sexual imagery of people under 18 by adults constitutes child sexual abuse and this should be reported to the police.

Handling Incidents

• All incidents involving youth produced sexual imagery should be reported to the Safeguarding Team.

• An initial review meeting will be held and subsequent interviews with the young people involved, if appropriate.

• Parents should be informed at an early stage and involved in the process unless there is good reason to believe that involving parents would put the young person at risk of harm.

• At any point in this process if there is a concern that a young person has been harmed or is at risk of harm, a referral should be made to children’s social care and/or the police immediately.

An immediate referral to the police and/or children’s social care will be made at this initial stage if:

• The incident involves an adult.

• There is reason to believe that a young person has been coerced, blackmailed or groomed, or if there are concerns about their capacity to consent, for example due to a learning difficulty.

• What is known about the imagery suggests the content depicts sexual acts which are unusual for the young person’s development age or are violent.

• The imagery involves sexual acts and any child in the imagery is under 13.

• There is reason to believe that a young person is at risk of harm owing to the sharing of imagery, for example, the young person is presenting as suicidal or self-harming.

If none of the above apply Digital Native may decide to respond to the incident without involving the police or children’s social care.  Although the sharing of sexual imagery is illegal, the National Police Chief’s Council (NPCC) is clear that ‘youth produced sexual imagery should be primarily treated as safeguarding issue’ and the law was also created to protect children and young people and not to criminalise them.    The decision to respond to the incident without involving the police or children’s social care will be made when the Designated safeguarding Lead is confident that there is enough information to assess the risks to the young people involved and that the risks can be managed within the Digital Native’s learner coaching policy.

Emotional abuse: can include constant insults and name calling, isolation from friends and family, controlling what someone wears / where they go, checking up on someone all the time (checking emails, texts, social networking sites etc) and making someone feel responsible for the abuse.

Physical abuse: can include hitting, punching, pushing, biting, kicking, using weapons etc.

Sexual abuse: can include unwanted kissing or touching, forcing someone to have sex, being made to watch pornography against their will and pressure not to use contraception.

Financial abuse: can include the taking and controlling of money, forcing someone to buy things for someone, forcing someone to work or not to work.

Trafficking:  is defined as ‘the recruitment, transportation, transfer, harbouring or receipt of children by means of threat, force or coercion for the purpose of sexual or commercial sexual exploitation or domestic servitude’ (NSPCC). The Palermo Protocol establishes children as a special case for whom there are only two components – movement and exploitation. Any child transported for exploitative reasons is considered to be a trafficking victim – whether or not he/she has been deceived, because it is not considered possible for children to give informed consent.

A child may be trafficked without crossing any national borders, e.g. only within the UK.  A child may be trafficked between a number of countries prior to being trafficked into/within the UK. The child may have entered the UK illegally or legally (i.e. with immigration documents). The intention to exploit the child underpins the entire process.

The Modern Slavery Act 2015 consolidates current offences of trafficking and slavery and details the different forms of exploitation that a victim of trafficking may be forced into.  The exploitation can take place in a number of ways including:

• Sexual Exploitation

• Labour Exploitation

• Criminal Exploitation

• Domestic Servitude

• Organ Harvesting

Distinction between human trafficking and smuggling: Human trafficking does not include people smuggling, which requires the consent of the person being moved. A smuggled person is, however, a potential victim who may be vulnerable to being trafficked at any point in their journey, and the distinction can be blurred. Perpetrators may smuggle people with the intention of exploiting them, or with the intention of facilitating exploitation. Alternatively, the smuggled can become vulnerable to traffickers upon arrival at their destination and subsequently be exploited and/or harmed.

Financial or Material Abuse: This can include theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions or the misuse, misappropriation of property, possessions or benefits.

APPENDIX B REFERRALS CONTACT DETAILS

For all safeguarding and Prevent concerns and referrals you must contact the Designated Safeguarding Lead (DSL), following both the safeguarding and/or Prevent referral procedure. If you are not able to contact the DSL you must contact the senior management Safeguarding and Prevent representative. Failure to contact any of the above, immediately contact the local authority designated officer.

• Designated Safeguarding and Prevent Lead:  Suzanne Higginson   suzanne@dn-uk.com   07885267251

• Deputy Designated Safeguarding and Prevent Lead (Director): Martin Stilgoe   martin@dn-uk.com

• Deputy Safeguarding and Prevent – Naziyah Miah naziyah@dn-uk.com Drew Joseph  drew@dn-uk.com

• Prevent Coordinators as per region  (West Midlands –  Alamgir.SHERIYAR@education.gov.uk)

• Head of network is Chris Rowell   Chris.rowell@education.gov.uk  07384 872518   Contact Chris Rowell if you require another region as a complete list of coordinators by region is no longer available since 2023.

SEXUAL HARASSMENT AND ABUSE POLICY

Digital Native is committed to providing a safe environment for all its apprentices and staff free from discrimination on any ground and from harassment at work including sexual harassment. We will operate a zero-tolerance policy for any form of sexual harassment, treat all incidents seriously and promptly investigate all allegations of sexual harassment.

Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from their apprenticeship or employment. All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint.

Definition of sexual harassment

Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated. It includes situations which create an environment which is hostile, intimidating or humiliating for the recipient. Sexual harassment may be physical, verbal and non-verbal.

Examples of conduct or behaviour which constitute sexual harassment include, but are not limited to:

• Unwelcome physical contact including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching

• Physical violence, including sexual assault

• The use of threats or rewards to gain sexual favour

• Comments on an individual’s appearance, age, private life, etc.

• Sexual comments, stories and jokes

• Sexual advances

• Repeated and unwanted social invitations for dates or physical intimacy

• Insults based on sex

• Sending sexually explicit messages (by phone/email or social media)

• Display of sexually explicit or suggestive material

• Sexually suggestive gestures

• Wolf-whistling

Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser. We recognise that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.

We recognise that sexual harassment can be a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and staff member or coach and apprentice. All sexual harassment is prohibited whether it takes place within our training environment face to face, teams call on apprenticeship days or outside, including at social events.

Child on Child Abuse (Peer on Peer Abuse) (Keeping Children Safe in Education Part One 2025)

All staff should be aware that children can abuse other children (often referred to as peer on peer abuse). And that it can happen both inside and outside of the apprenticeship and online. It is important that all staff recognise the indicators and signs of peer on peer abuse and know how to identify it and respond to reports.

All staff should understand, that even if there are no reports into Digital Native, it does not mean it is not happening, it may be the case that it is just not being reported. As such it is important if staff have any concerns regarding peer on peer abuse they should speak to their designated safeguarding lead.

It is essential that all staff understand the importance of challenging inappropriate behaviours between peers, many of which are listed below, that are actually abusive in nature. Downplaying certain behaviours, for example dismissing sexual harassment as “just banter”, “just having a laugh”, “part of our workplace culture” can lead to a culture of unacceptable behaviours, an unsafe environment for apprentices and in worst case scenarios a culture that normalises abuse leading to apprentices accepting it as normal and not coming forward to report it. Peer on peer abuse is most likely to include, but may not be limited to:

• bullying (including cyberbullying, prejudice-based and discriminatory bullying);

• abuse in intimate personal relationships between peers;

• physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse);

• sexual violence, such as rape, assault by penetration and sexual assault; (this may include an online element which facilitates, threatens and/or encourages sexual violence);

• sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse;

• causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or to engage in sexual activity with a third party;

• consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth produced sexual imagery);

• upskirting which typically involves taking a picture under a person’s clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification or cause the victim humiliation, distress or alarm

• initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).

All staff should be clear as to Digital Native’s policy and procedures with regard to peer on peer abuse and the important role they have to play in preventing it and responding where they believe an apprentice may be at risk from it.

What will happen following a complaint of sexual harassment

Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. We recognise that it may not be possible for the victim to inform the alleged harasser. If a victim cannot directly approach an alleged harasser, he/she can approach the Designated Safeguarding Lead or any staff member at Digital Native

When a staff member receives a complaint of sexual harassment, he/she will

• Reassure the victim that the complaint will be taken seriously

• Record the dates, times and facts of the incident(s)

• Ascertain the views of the victim as to what outcome he/she wants

• Ensure that the victim understands the company’s procedures for dealing with the complaint

• Discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally may still result in pursuing a formal complaint if he/she is not satisfied with the outcome

The DSL at Digital Native will liaise with specialist organisations to assist victims of sexual harassment.

Support

We recognise that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. We understand the need to support victims in making complaints.

If the victim wishes to deal with the matter informally, the person receiving the complaint will give an opportunity to the alleged harasser to respond to the complaint and ensure that the alleged harasser understands the complaints mechanism.

Facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to the Designated Safeguarding Lead who will ensure that a confidential record is kept of what happens.

Ensure that the above is done speedily and within one day of the complaint being made.
If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

Sanctions and disciplinary measures

Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions:

• verbal or written warning

• suspension

• dismissal

The above sanctions adhere to staff members at Digital Native. If there is not a satisfactory outcome in the apprentice’s workplace, Digital Native will pursue this with the employer alongside the employer’s internal policies to resolve.

Furthermore, Digital Native, in consultation with the apprentice, can move the apprentice to a different employer if not resolved to the apprentice’s satisfaction and the request is made by the apprentice.
The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence or actual abuse, will result in the immediate dismissal of the harasser.

Implementation of this policy

We will ensure that this policy is widely disseminated. It will be included in apprentice induction policies, staff code of conduct policy and on our website. We also inform our employers about this policy.
All apprentices and staff will be trained on the implementation of this policy as part of their induction into the company.

We will ensure frequent updating of apprentices and staff on the implementation of this policy.
It is the responsibility of every manager to ensure that all his/her employees are aware of the policy.
Digital Native recognises the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective. Data will include reports of low-level concerns.

Our governance board will receive regular reports on the effectiveness of this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done on a yearly basis as a minimum. As a result of this report, Digital Native will evaluate the effectiveness of this policy and make any changes needed.