COMUNI-CO is a private Language Coaching and Services provider. Our school provides English study holiday programmes including language tuition, host family accommodation and excursions for both adults and teenagers ranging from 12 to 17 years old.

The safety of children is our primary concern. We seek to maintain a safe and supportive environment for the children in our care. We accept and recognise our responsibilities as follows:

  • to safeguard the welfare of children who join our school
  • to continually develop awareness of any issues which might harm these children
  • to avoid making ourselves vulnerable to suspicion of any form of abuse


We will endeavour to safeguard children as follows:

  • by adopting child protection guidelines and accepted procedures
  • by ensuring that all students under 18 are protected from potential abuse from hosts, staff and fellow students
  • by providing children and staff with codes of behaviour and ensuring they understand what those are
  • by sharing information and acting promptly and professionally to any concerns

The lead person with regard to safeguarding issues is Concetta Laquintana, the director and principal of Comuni-co. Comuni-co commits to reviewing this policy every 12 months and will seek to involve staff and students in its development.


  • This policy applies to all children attending our courses regardless of gender, ethnicity, nationality, disability, sexual orientation or religion.
  • ‘Safeguarding’ refers to our commitment to reduce risk and provide appropriate general care for children.
  • ‘Child Protection’ refers to our commitment to protect children from any kind of abuse.
  • This policy covers all staff and any other adults involved in delivering courses for children in our care.
  • Comuni-co will take all reasonable steps to ensure that adults who work with our pupils but are not directly employed by Comuni-co (eg. Host families, transport contractors, sports coaches) have enhanced DBS certificates and are aware of our code of conduct.
  • This policy applies to both real world and online environments.
  •  This policy has been formulated in accordance with the provisions of the Children Act 1989, the Human Rights Act 1998, and the United Nations Convention on the Rights of the Child (ratified by the United Kingdom Government in 1991)

Our principles in framing this document:

1) All children have the right to be treated with respect and to be safeguarded from harm.

2) We welcome students from all backgrounds and will not permit discrimination by students or staff on the grounds of religion, gender, sexual orientation, or ethnicity. We will show particular sensitivity to students who are from territories in the midst of internal or international conflict.

3) Adults working with our pupils must recognise the trust placed in them by children and must treat this trust and this power with the highest responsibility.

4) Any sexual relationship or activity by an adult involving a child or any attempt to encourage this (= ‘grooming’) is unacceptable and will lead to disciplinary and legal action.

5) All children have the right to say ‘No’ if any person tries to do something to them which they feel is wrong.

6) All children have the right to be supported against bullies.

7) All children must feel they can tell an adult about any incident that frightens or confuses them or makes them unhappy.

8) All children must know that if they go to an adult for help, they will be listened to seriously and supported.


On a day-to-day basis all adults working with our pupils must agree to the following code of conduct. This will also help to protect adults against finding themselves in situations that might be misconstrued as being harmful to children.

  • Treat all pupils with respect regardless of age, gender, ethnicity, religion or sexual orientation
  • Maintain a professional relationship with all pupils. Act in a friendly, supportive manner to all pupils but do not make particular friends. Try to recognise if a student is developing a ‘crush’ on you. Do nothing that might be construed as encouraging this. Never flirt with a student or make sexually suggestive or provocative comments, even in fun. If a child makes such comments, enforce these boundaries in your response.
  • Do not act aggressively towards a pupil verbally or physically! Never hit, throttle, push, kick or otherwise act aggressively either physically or verbally towards a child even in pretence! Do not engage in rough physical games, including horseplay. When you have to admonish a child, focus on the unacceptable behaviour, not the person (E.g. ‘That was a dangerous thing to do because….’ rather than, ‘You stupid fool you could have…’)

Children can be very demanding. Recognise if you are reaching the limits of your patience and remove yourself safely from the situation,

  • Try to avoid being alone with a pupil or situations and actions that might be misconstrued. If you are unable to avoid being alone, for example if a child wants to talk to you privately, try to find a place where you can talk while still being seen by other people or where a colleague is discreetly present. Do not share changing rooms, washrooms, toilets or bedrooms with children. Always warn children before entering these places. Avoid being in these places with children unless necessary and pay particular attention to avoid being alone with a child in these places. If you have to touch a child (for example to comfort a crying child, if someone is injured or if you have to separate two fighting children) try to ensure that there are other students and/ or adults present.
  • Listen to what pupils tell you and report any sensitive incident or disclosure. Follow our guideline on how to react if a child discloses something to you. Always log and record any sensitive incident as soon as possible after it happens and ensure that the log is seen and signed by the Course Manager.
  • Be cautious if communicating with any pupil using social media (See ‘Electronic contact with children’ below).
  • Smoking, alcohol and illegal drugs must be avoided at all times when you are working with children


Child Abuse is most often used to describe ways in which children are harmed with damage to their physical or mental health. There are 4 broad categories of abuse as follows:

  • Physical: through hitting, shaking, squeezing etc.
  • Sexual: through inappropriate physical contact, the taking of indecent images of children, or the encouragement of sexual activity by children for the purpose of adult gratification.
  • Emotional: through persistent lack of affection, unrealistic adult demands, verbal bullying including cyber-bullying.
  • Neglect: failing to provide basic needs of food, proper clothing, safe supervision.

Identifying child abuse

It can be difficult to identify child abuse as it has various forms. Below are some typical indicators to watch for:

  • unexplained injuries
  • a child describing an abusive act that has happened to them
  • another child telling you of their concern about a friend / fellow student
  • sexually explicit behaviour in games / activities
  • serious distrust of adults
  • difficulty in making friends / socialising with other children

The last two might appear naturally as summer school is a new and strange environment for visiting children, sometimes from very different cultures. Be alert also to the possibility of (undiagnosed?) autism.

How to react if you suspect child abuse  

  • If you notice any physical or behavioural signs, tell the Course leaders.
  • If you suspect an adult is a threat to a child in some way tell the Course leaders or Course Directors and continue to monitor the situation.
  • If a child tells you they are being abused react calmly as follows:

What to do

  • Stay calm
  • Listen, hear and believe
  • Give time to the person to say what they want. It may help to remember TED: Tell me, Explain to me, Describe to me
  • Reassure that they have done the right thing in telling.
  • Explain that you will need to inform the Directors in order to provide the best possible support
  • Act immediately in accordance with the procedure in this policy
  • Record in writing as near verbatim as possible what was said as soon as possible
  • Report to the Course Manager

What not to do

  • Don’t panic. Don’t over-react. It is unlikely that the alleged victim is in immediate danger.
  • Don’t probe for more information. Questioning the participant may affect how the disclosure is received at a later date.
  • Don’t make assumptions, don’t paraphrase and don’t offer alternative explanations   
  • Don’t promise to keep secrets or that everything will be OK (it might not)    
  • Don’t delay or try to deal with it yourself: listen and refer, don’t investigate  
  • Don’t make negative comments about the alleged abuser. Don’t ‘gossip’ with colleagues about what has been said to you. Don’t make a child repeat a story unnecessarily 


Bullying – the deliberate and repeated act of causing another person to be unhappy – is perhaps the likeliest threat to a child’s wellbeing on our courses and is not tolerated. People who abuse others verbally or physically will be cautioned and if this has no effect will be sent home.

Bullying can take many different forms; it may be physical, emotional, name-calling, showing a lack of respect for another’s property, excluding somebody from a social group; there are many possibilities. One person ‘having a joke’ might be another person suffering bullying. Sometimes it is obvious, sometimes it is done subtly and in such a way that children will be worried about telling staff what is happening.

For this reason it is vital that all staff and hosts are vigilant in noticing changes in behaviour of children, particularly if they become withdrawn.

If you suspect bullying:

  1. Investigate all reports, however seemingly trivial.
  2. Ensure that all reports of suspected bullying are recorded in the Incidents Form. Ensure also that the follow up and resolution / consequence is recorded.
  3. Once it has been established that bullying has taken / is taking place, refer the incident to the Course Director. With the Course Director, explain to the person acting unkindly that their actions are unacceptable and tell them the effect it has had on another / others.
  4. Ask them to consider an appropriate way of putting things right and, if necessary support them in carrying out an apology.
  5. Ensure that any apology / reconciliation is done with staff present so that it can be accurately recorded.
  6. Alternatively, bring both parties (bully and bullied) together for a ‘no blame’ meeting. The aim is to clarify the situation through discussion and allow both sides to work out a solution that is satisfactory to them both. This will be logged and signed by a staff member.
  7. Give details to the Director or Course leaders who will inform parents of both parties what has happened and how it has been resolved.
  8. If, after this meeting, the bullying continues then it must be seen as deliberate or that the perpetrator (for example if suffering from fits of anger) is unable to control himself or herself. The Course Director will take immediate action to protect the bullied person and will begin procedures to restrict the activities of the bully. The Leaders and the Director will keep parents of both parties fully informed.
  9. Any further incidents of bullying by the same person will result in them being sent home as quickly as possible.


Staff must exercise the same discretion and maintain the same professional distance in any electronic contact with children (anyone under 18) as they would in normal day-to-day life. Electronic contact includes telephone communications (including texting) and on-line environments. In particular:

  • Never initiate electronic contact with a child unless for clear pedagogical purposes that have been approved by your employer.
  • If a child contacts you electronically, keep your tone friendly, professional and neutral.
  • Avoid situations that involve the exchange of personal information, personal photos, virtual gifts or the use of any application that suggests or encourages the sharing of personal feelings.
  • If a child seeks to develop an inappropriate personal relationship with you electronically, do nothing to encourage this; inform your employer and send a copy of any relevant communications.
  • If a child confides sensitive information to you electronically, such as details of abuse, react as shown in the table above, ‘If a child discloses abuse’. Record the details and send a copy of all relevant communications to your employer.
  • While a school may have good reasons to create an online social community, social forums such as Facebook present particular risks. Staff should not initiate or accept ‘friendship’ requests from children, however innocent these requests may seem, as this provides access to photos and other intimate details of each other’s personal lives.


Comuni-co will:

  • Immediately remove the adult from all possible contact with pupils
  • Carry out immediate investigations and inform the child’s parents
  • If there is evidence to support the allegation the matter will be referred to the Local Authority Designated Officer (LADO) and to the NSPCC who will advise on the next steps. This may include criminal prosecution and the informing of referees and the Disclosure and Barring Service.


Student Agreements

All Comuni-co students and their parents/ guardians are required to sign an Agreement form before the commencement of the course. They are informed of procedures following potential breach of the school and state law rules. They are reminded of expected standards of behaviour on and outside of school premises as well as host family accommodation, including the need to tell someone if they have a problem.

Excursions and Outdoor activities

Basic guidelines and ‘what to do if’ risk assessment for all excursions and outdoor activities are given at staff briefings and the commencement of the course.

Road safety 

Pupils are advised to take care with traffic driving on the left in England. All pupils practise crossing the road and orientation shortly after arrival as part of induction with their classroom teacher.

Absence from school

The age of students is clearly indicated in class registers.  All teachers are instructed to inform the School Office immediately if an under-18 is absent from their class. In instances of repeated lateness or absence, the Course leader will discuss the matter with the Director and will inform the student’s parents or guardian.


Students under the age of 18, who do not form part of a group and are not accompanied by an adult family member or guardian, are only permitted to be accommodated in homestay accommodation. There is a 22.00 pm curfew in place for students who are under the age of 16, and 23.00 (Sunday to Thursday) and 00.00 (Friday and Saturday) for students aged 16 and 17, unless otherwise instructed by the parents or guardians. The students are only allowed to go out in the evening if approved by Group leaders and the Director. They should always go out with the fellow students in a group.

In cases where a child does not return before the curfew begins the host family should phone the child to ensure they are safe and should inform the school the next day.  If the homestay provider is unable to contact the child they should phone Comuni-co emergency phone on 07922454487.  The emergency phone holder will continue to attempt to make contact with the child and if necessary will inform the police.

Outside of school

All under-18s receive a student ID card with the school and host family’s contact details. Under-18s are given advice about how to stay safe in Peterborough on their first day of stay by the Course director. For further information and concerns students can be advised by the teacher or ask to talk to the Course director. Advice includes, but is not limited to, the following: ways of travelling (stay in pairs and groups), plan how to get home in advance of evenings out, ensure their mobile phone is fully charged, save the number of a reputable taxi firm, inform about the laws that apply to under-18s, and tell friends and hosts where they are going.


As a starting point all members of staff and homestay providers receive a copy of the School’s Safeguarding & Child Protection Policy.

They are required to sign it to say that they have read and understood this Safeguarding Policy and agree to the Code of Conduct.

All staff at Comuni-co are required to undergo Basic Awareness Safeguarding training/ supervision.

Staff Recruitment Policy

Comuni-co is committed to the safer recruitment of staff, homestay providers, group leaders and other service providers.

To ensure that employees working for Comuni-co are suitable for work with children, the following procedures will be followed:

All staff must submit a CV with their application and all gaps in CVs must be explained satisfactorily. Proof of qualifications will be required and a minimum of two references will be followed up. The reference request will ask if the referee has any reason to believe that the employee is unsuitable for work with children.  Staff will be required to affirm that there is no reason why they should not be employed in situations where they have responsibility for, or substantial access to, persons under 18. At interview prospective employees will be asked about their attitude to working with under-18s. Staff members are asked to agree to undergo a fresh enhanced DBS check before they commence employment with the school.

Additional Resources

  1. 1.“Keeping Children Safe in Education” is statutory guidance published in April 2014 and updated in October 2014.  It is available here:
  2. Ofsted Safeguarding children and young people Policy, updated 17 July 2015
  3. Free online Child Protection training from Barnardo’s
  4. Local Authority Designated Officer (LADO)
    Contact Details: Tel: 01733 864038
  5. Further information about child abuse
  6. UK Safer Internet Centre
    This site contains advice on how to use the internet and new technologies safely and responsibly.
  7. Childline provides advice and help on a wide range of issues. Tel. 0800 1111

*Last updated in January 2016 by the Manager and Principal of Peterborough Language School,

 Nina Williams