Circles of Safety Virtual Classroom Series
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A Code of Conduct is another prevention tool that helps YSOs clearly identify acceptable and expected behaviors of anyone in a position of responsibility for the children and youth in their care – from junior employees and volunteers to senior management. Among common items addressed in such codes are boundaries of physical, sexual and verbal behavior; staff-to-child ratios; guidance about being alone with children/youth; awareness of power differentials and abuse of power; bullying, harassment, and discrimination; interpersonal communication with children using electronic and social media; and compliance with the policies and procedures of the organization and the state’s child abuse reporting laws.
Codes of Conduct can be used to address interactions between the staff and children/youth; among the staff members; between staff members and parents; and – in simplified form – among the children and youth themselves. On this last point, for example, a simple set of “rules and regulations” for participant behavior can list the expected behaviors for children and youth, emphasize that the rules are there to keep everyone safe, and identify to whom the children/youth should report if the rules aren’t being followed.
Codes of Conduct should be written in clear language and define behaviors that the organization considers appropriate, inappropriate, or harmful. Depending on the kinds of services the YSO provides, a Code of Conduct should anticipate and contain guidance for interactions that are typical and can be expected – from 1-on-1 contact to small and large group situations – both in and outside the YSO’s facilities – and their duration (e.g., 1-hour small group instruction, all day events, overnight trips, multi-week residential camps, etc.). If a YSO is constructing a Code of Conduct for the first time, input from front-line staff (those in regular contact with children/youth), parents, and the children/youth themselves may prove helpful and contribute to a sense of shared awareness and responsibility.
Since a Code of Conduct cannot possibly contain descriptions of all the situations and interactions that might be encountered, it is helpful for it to incorporate, or be prefaced by, a Mission Statement (the purpose of the organization) and a set of ethical practices (Code of Ethics) that reflect the core standards and principles upon which the organization is built and which guide its activities. In combination, organizational Mission Statements and Codes of Ethics can be used as guidance by staff and volunteers in making decisions when circumstances are uncommon, unclear or unexpected. The section also provides examples of each, and expanded guidance for their construction in Appendix 9.
As mentioned in the previous section, the Task Force recommends that a YSO’s Code of Conduct should be integrated into the screening and hiring process for all prospective administrators, staff and volunteers. It should be given to the applicants, read and discussed as part of the personal interview, and signed to acknowledge both its receipt and the applicant’s agreement to comply with its requirements – with a copy retained in the applicant’s personnel file if he or she is hired. A sample Code of Conduct and a Statement of Receipt and Agreement with signature block are provided in Appendix 9.
A Code of Conduct should also include a clear description of the organization’s reporting lines, and the process that follows when behavioral concerns or breaches of the Code are observed and/or reported. YSOs should take care to define, and help staff and volunteers understand the expectation that all inappropriate behavior must be reported according to internal policies including those that could possibly be handled internally by a supervisor or manager, and behaviors that “cross the line” into causing harm and which must be reported to police or DCF. In either case, administrators and supervisors must then ensure that once reported, all allegations are addressed in line with the organization’s protocol and Massachusetts law. Staff and volunteers must trust that their reports will be responded to, and will be handled quickly and appropriately. They must also trust that they will not be penalized for coming forward and raising issues, questions or concerns. Negative consequences to a person who reports a concern will prevent others from coming forward – thus increasing the potential risk to children. Monitoring and documentation strategies for those in leadership positions are also included.
Table 3 presents the basic elements of a Code of Conduct. Smaller organizations with clear, uncomplicated reporting lines or few staff may not require all elements. For example, small YSOs could collapse a simplified Code into a set of “Rules and Regulations” that pertain to staff, volunteers, parents, and youth (see example in Appendix 9).
|Basic Elements of a Code of Conduct|
|Ethical principles and standards|
|Guidance on, and definitions of specific behaviors/interactions common and relevant to the YSO|
|Appropriate, inappropriate, harmful, encouraged behaviors and interactions vs. prohibited behaviors and interactions|
|Reporting obligations, procedures and process|
|Investigation and monitoring procedures|
|Statement of receipt and agreement|
When safety policies and a Code of Conduct are reinforced through staff meetings, and other training or professional development opportunities, it ensures that the topic is addressed on a regular basis, and makes it easier for staff to talk about their concerns and highlight the day-to-day behaviors that may be giving them some concern. In this way, a Code of Conduct becomes not only a guide for supervisors, employees and volunteers to follow in terms of their daily interactions, but also a tool that fosters awareness and conversations about behaviors – both those that are appropriate and beneficial, and those that fall outside of the defined boundaries. Implemented thoroughly and consistently, a Code of Conduct serves as an “early warning system” that can detect inappropriate or harmful behaviors as they occur and allow supervisors, managers and staff to address them before they become chronic, and before children and youth are harmed.
Integrating the Code of Conduct into the YSO’s performance appraisal process also reinforces the Code of Conduct as a shared responsibility that serves to protect everyone in the organization and thus promotes a sense of both personal and professional ownership. This, in turn, can help to create an organizational culture that promotes mutual respect, empathy, reciprocity, and dignity, and that encourages people to come forward and helps them to feel safe in doing so.
Key Findings and Recommendations
STEP 1: Developing the Code of Conduct
STEP 2: Implementing the Code of Conduct
STEP 3: Monitoring and Documenting the Code of Conduct
To ensure that all individuals involved with child and youth serving organizations have clear guidance on both appropriate and inappropriate interactions with children and youth.
The public and private conduct of administrators, staff, employees and volunteers acting on behalf of any youth serving organization can inspire and motivate those with whom they interact, or can cause great harm if inappropriate. An additional tool to help ensure child and youth safety, and to prevent child sexual abuse is a Code of Conduct. The purpose of a Code of Conduct is to identify the expected and acceptable behaviors and interactions between the YSO’s adults (and, in some cases, older teen volunteers or aides) and the children and youth who come to the organization for the services and activities it provides.
Codes of Conduct can be used to address interactions between the staff and children/youth; among the staff members; between staff members and parents; and – in simplified form – among the children and youth themselves. Codes of Conduct can also speak to issues of risk, physical, emotional and sexual boundaries, staff-to-child ratios, 1-on-1 contact with children and youth, sensitivity to the appearance of impropriety, interpersonal communication using electronic and social media, and compliance with the policies and procedures of the organization and the child abuse reporting laws of the Commonwealth.
In addition to guidance on behaviors, Codes of Conduct should also include a clear description of the lines of communication and reporting procedures should a staff member or volunteer wish to discuss and/or report behavior that they are concerned about or that is clearly contrary to the Code, and a description of the actions that will follow in terms of investigation and resolution.
Codes of Conduct should also stress that there will be no adverse consequences for staff who come forward to report. Building a corporate “culture” that supports and encourages open communication about behaviors involving children and youth is one of the most effective ways to ensure that staff will not be afraid to come forward. Training and education for staff and volunteers about the Code and its purpose can reinforce that it exists to protect them as well as the children/youth, and provides the skills and information that will help them distinguish and talk about behaviors that are inappropriate (and could be corrected internally) and behaviors that are harmful and should be reported to DCF or law enforcement (More on these issues below, and also see section on Reporting and Responding).
When all staff and volunteers see the Code as protective of all members of the organization, and comply with the guidance it contains, it is easier to identify and stop individuals who are not complying – and are exhibiting behaviors that may be intended to harm children (see section on Grooming). In this way, the Code functions as an “early warning system” that can prevent abuse before it occurs.
YSOs should draw attention to the existence (and include a copy) of the Code of Conduct in their policies and procedures, on their websites and in any marketing, recruitment and advertising activity, along with a statement about the YSO’s commitment to maintaining a safe environment for all children and youth in their care. Providing copies to parents and other caregivers also demonstrates the commitment to monitor the behavior of all individuals who come into contact with their children as part of the organization’s safety protocol.
To support implementation, the Task Force strongly suggests that Codes of Conduct should be integrated into the screening and hiring process of the organization (see Screening section), and included in the performance appraisal process. Copies of the Code should be distributed to all personnel, and accompanied by their signature on a statement that indicates agreement with its contents and a pledge to abide by its requirements. Strategies for monitoring behaviors and providing feedback to the organization should also be drafted. Implementation strategies and the implications of these requirements for smaller organizations are also addressed below.
Since Codes of Conduct, in large part, contain guidance on the specific behaviors and interactions that are anticipated by the nature of the YSO’s activities and services, they usually take the form of a list of “do” and “don’t” actions around behaviors that are most common. This has several implications.
First, Codes of Conduct should be considered “living” dynamic documents and should be evaluated and revised periodically. For example, you can make the Code of Conduct a regular agenda item at staff meetings or professional development days, ask for feedback on how it’s being applied in practice, and get feedback on what’s working well and where improvements can be made. This ensures that existing parts of the Code that are not working, or not working as anticipated are revised accordingly, and that missing or unanticipated behaviors and circumstances are added. In both cases, the revisions and modifications are informed by the experiences of the staff and volunteers who are responsible for implementing the Code and its requirements. This helps with staff “buy-in” and a sense of ownership.
Second, since Codes of Conduct, at any point, cannot contain all possible behaviors and circumstances that staff and volunteers may experience, it will be important to provide additional guidance that can help to support decision making in a wide range of situations. This can be accomplished through the development of Mission Statements and/or Codes of Ethics.
Many YSOs, whether large or small, are familiar with the concept of a “Mission Statement” – a short, foundational statement designed to capture the reasons why the organization exists, and what it hopes to accomplish. These statements are designed to motivate and inspire staff and leadership toward the “higher goals” they express, and can also help guide the day-to-day activities of the organization (Sample Mission Statements from large and small organizations can be found in Appendix 9).
Closely associated with the Mission Statement, and often included with it, the “character” of an organization can be described more fully by expanding upon the Mission Statement and expressing a set of ethical standards – sometimes called a “Code of Ethics.” The Code of Ethics can be very broad and describes the vision and guiding principles for an organization, what it aspires to accomplish, and how children and youth will benefit from its efforts. It should also reflect a commitment to child/youth safety (See examples in Appendix 9).
Depending on the size of the organization and available resources, some YSOs may have developed only a Mission Statement or a Code of Ethics, or even combined them. There are no hard and fast rules. The benefit they provide, however, is that they can help to guide staff and volunteers in making decisions in day to day interactions with coworkers and with children and youth – especially in those unique or emergency situations where there may be a lack of clear direction. Again, a Code of Conduct is limited in that it usually refers only to the most common and expected behaviors one is likely to encounter in day to day operations. Should behaviors occur that are not covered under the Code, individuals can refer to the Mission Statement/Code of Ethics to determine an appropriate response. For additional information, see “Guidance on Constructing Codes of Ethics and Conduct” in Appendix 9.
Appropriate, positive interactions among youth and between employees/volunteers and youth are essential in supporting positive youth development, making children and youth feel valued, and providing the caring connections that serve as protective factors for them (see “What is the Positive Youth Development Approach” in Appendix 9). Conversely, inappropriate or harmful interactions put children and youth at risk for adverse physical and emotional outcomes.
Organizations should identify behaviors that fall into the categories of appropriate, inappropriate, and harmful. These categorizations, and the expected responses when they are observed (up to and including making a report to the Department of Children and Families), can be spelled out in the Code of Conduct. 2
For example, Codes of Conduct for child and youth serving organizations generally try to draw attention to the power differential that exists between adults (and others in authority) and children/youth, and the responsibility to maintain appropriate physical, emotional and verbal boundaries. They emphasize the use of discretion when touching a child – with examples of appropriate and inappropriate touch. Examples of various kinds of appropriate, inappropriate and harmful behaviors can be found below:
Physical contact between adults and the children/youth they supervise should always be public, age-appropriate, and non-sexual in nature. Organizations will need to find a balance between encouraging positive and appropriate interactions and discouraging inappropriate and harmful interactions. When accomplished, strategies with this balance in mind help to ensure that youth can benefit from program participation without risk of sexual abuse or harm.
When inappropriate or potentially harmful behaviors occur, it is important that organizations work to ensure that anyone observing those behaviors feels free to speak up even if the individual is unsure about to what to do next. Suggestions as to how this can be accomplished are presented below and will outline a multi-pronged approach.
The boundaries between appropriate, inappropriate and harmful behaviors are not always clear in every situation. Some can be handled internally by closer supervision, and others need to be reported to law enforcement and/or DCF (see Reporting and Responding section below). Communication from leadership and supervisors will be key. When general safety policies and a Code of Conduct are talked about and reinforced through supervision, at staff meetings, and during other training or professional development opportunities, it becomes easier and safer for staff and volunteers to talk about the day-to-day behaviors that are causing them some concern. The less reluctance there is, the safer the environment becomes for everyone.
Other behaviors and circumstances that can be addressed in Codes of Conduct include how to handle 1-on-1 meetings with children – either prohibiting them or setting guidelines as to when and how they may take place (i.e., only meet with children where other adults can have open access or the ability to observe); prohibitions against smoking, alcohol and drug use, profanity or jokes with sexual innuendo when around children; prohibiting contact with children outside of the professional or organizational relationship; and a clear statement about the requirement to comply with the Massachusetts child abuse and neglect reporting laws (See sample Code of Conduct in Appendix 9).
Implementing a Code of Conduct
Once a Code of Conduct is in place, it is important to implement it, through training and disseminating the information widely and in a variety of ways. All current staff and volunteers should receive in-person training and sign acknowledgement of having received the Code of Conduct for their personnel file. Similarly, reading and signing the Code of Conduct should be integrated into the hiring process for new employees and volunteers. Training and acknowledgement should be renewed annually.
Consider sharing some of the main points from the Code of Conduct with parents and participants, in appropriate language and detail. For example, if the organization prohibits children and youth from being alone with staff, any employee or volunteer who observes a staff member alone with a child or youth participant should know to intervene, and either talk to the staff member, or talk to a supervisor to have the behavior corrected. Sharing that rule with children and youth could also increase safety by making them aware that a staff member who tries to get them alone is breaking the rules, and that they should tell someone. Likewise, a parent, hearing a child report that they were alone with a staff member, would know to notify the organization.
Smaller organizations can also create abbreviated Codes of Conduct for adults, children and youth (for example, as part of a studio handbook) that include such things as behaving appropriately; speaking respectfully to staff, instructors, parents, and other children (even competitors); and respecting the rights of others (See sample format in Appendix 9).
Goal: To reinforce positive, age-appropriate, healthy behaviors and interactions, and to prevent, recognize, and respond to behaviors that cause concern but are correctable, or to behaviors that are inappropriate or harmful.
Monitoring involves observing interactions and reacting appropriately. This includes both employee and volunteer with children/youth, and child-on-child and youth-on-youth interactions. Youth leaders often require more supervision and monitoring because they are young, lack experience, may lack judgment, and are harder to screen. Define areas requiring monitoring based on the organization’s mission and activities.
All staff must be able to easily discern inappropriate behavior and harmful actions. Leadership should always model appropriate interactions and utilize staff meetings, and individual and group supervision to give frequent feedback, both positive and constructive, providing staff with motivation to maintain a safe environment. Staff members will look to their leadership to set the tone, and show that communication about behaviors is a normal part of doing business – not a taboo. These actions help to build and maintain a culture of open communication about matters pertaining to child and youth safety.
Monitor inappropriate or harmful behaviors
Organizations should use multiple monitoring methods to get a clear picture of how individuals are interacting.
Monitor potential risk situations
Acknowledge that some situations pose more risk for inappropriate or harmful behavior than others. When situations are more risky, more protective strategies will need to be implemented.
Classrooms provide spaces where the interactions between students and between students and other adults (aides, parents, tutors) entering that space are easily observed. Studios, usually with an instructor and one or more aides, also conduct their classes in a confined area and many offer space for parents to observe their activities. These are relatively safe environments because there are multiple “eyes” on the children in a small space.
However, interactions during an overnight trip are harder to monitor than are interactions in a classroom or studio. Taking any of these classes – even with parents/chaperones – on an overnight field trip, an out-of-state performance, a camping experience, or to a competition can vastly multiply risk as well as the steps that must be taken to accommodate and lower that risk. Adult-to-child/youth ratios that allow supervision of all participants 24 hours a day; safe transportation and appropriate sleeping arrangements; bathing and toileting accommodations; limiting or prohibiting the use of alcohol by adults who accompany the children and are responsible for their safety and supervision; and protocols for emergency situations are just a few of the additional protective strategies that must be employed to ensure the safety of overnight events (Also see section on Safe Environments).
It is also important that staff is trained to be even more vigilant during the times where children and youth have been shown to be more vulnerable to abuse: non-structured program time (time between programs, meals, etc.) shower time, trips to the restroom, changing for the pool, etc. No matter where children or youth are during an overnight event, they must always be there with the knowledge of staff – and always under either staff supervision or observation.
Monitoring and responding to inappropriate behavior is a part of the job of every individual involved in the organization. Supervisors and managers carry additional responsibility for remaining vigilant and available to staff and volunteers who deal directly with children and youth. Staff will also need to know how to respond to behaviors that appear inappropriate or are causing concern, how to intervene appropriately and effectively, and how to report when those behaviors are harmful. Staff are also responsible for helping other staff, especially new staff, understand the Code of Conduct and adhere to its principles. The bottom line is that if a staff member or volunteer sees something, and does not correct or report it, they become part of the problem.
Critical Strategies for Monitoring Behavior
Organizations must be prepared to respond to observed interactions among youth and between employees/volunteers and youth.
Develop a monitoring protocol so that employees/volunteers are clear about their roles and responsibilities. Employees/volunteers should be prepared to respond immediately to inappropriate or harmful behavior, potential risk situations, and potential boundary violations.
Create a Clear Reporting Structure Within the Organization
If an organization prepares and encourages its staff and volunteers to be aware of behaviors and works to build a culture that supports them in speaking up when they see something that needs correction or is harmful and needs reporting, they need to know clearly and unambiguously who they should be contacting and speaking to.
A reporting structure should define the “chain” of people to whom reports are to be made when staff and volunteers observe inappropriate or harmful behaviors. It is also important to let them know that they can use the reporting structure to question confusing or uncertain behaviors and practices. Seeing the individuals in the reporting structure as a source of information, clarification and support, and not only as a reporting authority, can make it easier for staff to initiate contact with them. Encouraging staff to ask questions, as well as requiring them to report situations and behaviors that are inappropriate or harmful, can help build trust and establish a communication flow that results in a safer environment for all.
In cases where a report involves the behavior of an immediate supervisor or someone in direct-line authority to the person reporting, organizations will also need to establish a “back-up” reporting option to ensure that the situation comes forward.
Consider publishing and distributing a 1-page flow chart of reporting responsibilities that clearly shows the steps to follow, people to contact and phone numbers to use if abuse is suspected. Also post the chart in all public spaces (See samples in Appendix 11).
Document that monitoring has occurred
Documenting that monitoring has occurred emphasizes to staff and volunteers that the Code of Conduct is taken seriously and that it is an essential part of the organization’s child sexual abuse prevention efforts. Periods during which informal workplace monitoring has occurred should be recorded, as should the number and types of incidents observed or reported. Documentation in performance appraisals shows that more formal monitoring is taking place and promotes a personal and professional stake in helping to maintain a safe environment. These strategies help to ensure accountability, provide opportunities for group and individual recognition, and show that those who have come forward have had their concerns taken seriously. The data generated can also be used (without attribution) in internal audits and in providing updates to the organization and its stakeholders (See also section on Analysis, Review and Self Audit).
1 For example, if a YSO employs licensed clinical social workers, and is drafting a Code of Conduct, it may want to incorporate standards already adopted by the Code of Ethics of the National Association of Social Workers: (https://www.socialworkers.org/About/Ethics/Code-of-Ethics)
2 Saul J, Audage NC. Preventing Child Sexual Abuse Within Youth-serving Organizations: Getting Started on Policies and Procedures. Atlanta (GA): Centers for Disease Control and Prevention, National Center for Injury Prevention and Control; 2007.
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