Introduction
This Child Protection Policy is an annex to the Compass Code of Conduct and sets out Compass’ commitments, principles and procedures for safeguarding children. It applies to all Compass staff and to anyone acting on behalf of Compass in a professional capacity.

Compass is committed to upholding the rights of all children, in particular their right to protection from all forms of violence, abuse, neglect and exploitation. Children should be able to grow up healthy, safe and supported to reach their full potential. This commitment is grounded in the United Nations Convention on the Rights of the Child (UNCRC, 1989) and the Council of Europe Lanzarote Convention (2007) on the Protection of Children against Sexual Exploitation and Sexual Abuse.

Any child who comes into contact with Compass staff, volunteers, interns, external collaborators or partner organisations must have their rights respected as set out in the UNCRC. Compass’ work follows the EU Strategy on the Rights of the Child, promotes participation of children in social and democratic life, and supports their social and economic inclusion. Compass advocates for equal access to health, education and protection, prevents violence against children and promotes safe, child-friendly environments offline and online.
Compass recognises that child abuse, exploitation and inappropriate contact with children are serious issues that require proactive, systematic management. This policy demonstrates our determination to prevent abuse and to protect children in all Compass programmes, activities, premises and networks.

Compass is committed to ensuring that all decisions and actions affecting children are guided by the best interests of the child.
This document is structured into six sections:
1. Definitions used in the policy and within Compass’ work
2. Values and principles that all staff must respect and promote
3. Screening and hiring practices at Compass
4. Principles of conduct and procedures for staff working with or in contact with children
5. Reporting procedures for concerns or suspicions of child abuse
6. Cooperation with external organisations, networks and agencies

The Child Protection Policy is prepared by the Child Protection Officer (CPO) and adopted by the Management / Board of Directors of Compass. It is reviewed regularly (at least once per year) and updated in line with EU standards, Austrian legislation and practical experience.

1. DEFINITIONS
For the purposes of this policy, the following definitions apply:

Best Interest of the Child (BIC)
The best interests of the child is at the same time a right, a guiding principle and a procedural rule. It requires an assessment of all relevant elements concerning a child or a group of children in a specific situation, in the public or private sphere. This assessment must be carried out case by case, taking into account the child’s personal situation, context and needs.

The concept is flexible and adaptable, but its purpose is constant: to ensure the full and effective enjoyment of all rights recognised in the UNCRC and to support the child’s holistic development. Applying the best interests principle requires a rights-based approach and the involvement of all relevant stakeholders to safeguard the child’s physical, psychological, moral and spiritual integrity and promote human dignity.

Child: A child is any person under the age of eighteen (18). In this policy, the terms child/children and minor/minors are used interchangeably.

Child Protection: All activities aimed at preventing and responding to violence, exploitation and abuse of children in any context.

Child Participation: Child participation means that children, individually or in groups, have the right, opportunity, information and space to express their views freely on matters that affect them, and to have those views taken seriously in line with their age and maturity. Genuine participation requires appropriate information, age-sensitive methods and support to enable children to speak up and influence decisions.

Child Safeguarding: Child safeguarding refers to preventive actions designed to protect all children from deliberate or unintentional acts that cause, or may cause, harm. It includes policies, procedures and practices that make organisations safe for children.

Staff Members: For this policy, staff members means all persons who work for or represent Compass: paid staff, trainers, board members, volunteers, interns, consultants and external collaborators.

Compass is committed to protecting children from all forms of maltreatment and inappropriate behaviour. Child maltreatment includes abuse and neglect of anyone under 18 years and may be physical, emotional, sexual, or linked to neglect, exploitation or harmful practices. It can occur in person or online, and typically in relationships where there is responsibility, trust or power.

Types of abuse and maltreatment include (non-exhaustive):

Physical Child Abuse: Intentional physical injury caused to a child (e.g. hitting, shaking, burning, poisoning, causing broken bones or other physical harm).

Child Emotional Abuse: Persistent behaviour that makes a child feel worthless, unloved, unsafe or rejected. This can include humiliation, threats, constant criticism, isolation, rejection or unrealistic expectations.

Child Sexual Abuse: Involving a child in sexual activities which they do not fully understand, cannot consent to, are not developmentally ready for, or which violate social or legal norms. It can be committed by adults or by other children in a position of power or trust.

Child Pornography / Child Sexual Exploitation Material: Any representation of a child engaged in real or simulated sexually explicit conduct, or focusing on a child’s sexual organs for primarily sexual purposes.

Grooming: A process where an adult or older child builds trust and emotional connection with a child (often online) in order to exploit or abuse them.

Bullying (including Cyberbullying): Repeated, intentional aggressive behaviour involving an actual or perceived power imbalance. It may be physical, verbal, relational or digital (online).

Neglect or Negligent Treatment: Persistent failure to meet a child’s basic physical and psychological needs, including lack of food, shelter, medical care, education, protection or emotional support, despite having the means and knowledge to do so.

Child Exploitation: Using children for domestic work, forced labour, criminal activities, armed conflict, sexual exploitation, pornography, or any hazardous or harmful work.

Online Sexual Violence and Online Abuse: Use of digital technologies (e.g. social media, messaging apps, gaming platforms) to exploit, threaten, harass or abuse children, causing or risking physical, psychological or emotional harm.

2. PRINCIPLES AND VALUES
Compass is guided by the following values and principles, which are binding for all staff, volunteers, interns and collaborators:

Non-discrimination: Every child is treated with respect, regardless of age, gender, language, religion, political or other opinion, national, ethnic or social origin, residence status, sexual orientation, disability, socio-economic background or any other status.

Zero tolerance for abuse: Compass has a zero-tolerance policy towards all forms of violence, exploitation, abuse or inappropriate behaviour involving children. Any concern is taken seriously and acted upon without delay.

Right to protection: Every child has the right to be protected from harm. Compass takes all reasonable measures to prevent abuse and to respond swiftly and appropriately to any suspicion or allegation.

Best interests of the child: In all Compass activities, services and decisions affecting children, the best interests of the child have priority.

Right to be heard: Compass promotes children’s right to express their views and participate in decisions that affect them, using age-appropriate and safe methods.

Mainstreaming safeguarding: Child safeguarding is integrated into project design, risk assessment, implementation, monitoring and evaluation, and is aligned with trauma-informed and child-centred approaches.

Guidance and support for staff: Compass provides clear procedures, training and supervision for staff who work directly or indirectly with children, to ensure consistent and safe practice.

3. SCREENING AND HIRING PRACTICES
Compass applies safe recruitment practices designed to minimise risks to children. These include clear role descriptions, application forms, reference checks, background checks (where legally possible) and explicit reference to child protection in all contracts and in the Compass Code of Conduct.

3.1 Applications

• All applicants (staff, volunteers, interns, long-term freelancers) complete an application form including employment history, education and relevant experience.
• All application documents contain a statement on Compass’ zero tolerance for abuse and exploitation, particularly against children and vulnerable persons.
• Any person whose role may involve direct or indirect contact with children must provide relevant background documentation as required by Austrian law (e.g. criminal record extract / „Strafregisterauszug“ or equivalent, where applicable).

3.2 Reference Checks
Compass reserves the right to:

• Contact professional referees indicated by the applicant (e.g. former supervisors, project managers).
• Contact previous employers/organisations to explore the applicant’s suitability for work involving children.
• Verify written references via phone or email.
• Conduct reasonable open-source checks (e.g. public information, professional profiles) to identify any clear safeguarding red flags.

3.3 Interviews

• Applicants are interviewed by at least two members of Compass (e.g. management plus project lead).
• Behavioural and scenario-based questions are used to assess attitudes towards children, safeguarding and professional boundaries.
• All interviews are documented using a standardised template and stored in the applicant’s file in accordance with GDPR and Austrian data protection law.

4. PRINCIPLES OF CONDUCT & PROCEDURES FOR STAFF WORKING WITH / IN CONTACT WITH CHILDREN
4.1 Compliance with the Code of Conduct and this Policy

• Before starting any tasks, all staff, volunteers, interns and long-term external collaborators must read, accept and sign the Compass Code of Conduct and this Child Protection Policy.
• Any substantial revision of the Code or this Policy is communicated to staff; updated versions must be acknowledged and re-signed.
• Signed documents are stored in the personnel file and form part of the contractual framework.
• Project partners or external experts working directly with children under Compass programmes may be asked to sign an addendum acknowledging and following Compass’ child protection standards.

4.2 Data Protection and Use of Images
Compass complies with GDPR (EU 2016/679) and Austrian data protection law in relation to children’s personal data:

Informed consent: When collecting any personal data from or about a child (e.g. photos, video, audio, questionnaires), Compass obtains written informed consent from the parent/legal guardian and, where appropriate, the assent of the child.

Purpose limitation: Data is collected and used only for the specific purpose communicated at the time (e.g. participation documentation, evaluation, dissemination). Any different or future use requires renewed consent.

Confidentiality: Staff who handle children’s personal data sign a confidentiality declaration for the relevant project or activity.

Anonymity: As a rule, children are not identified by full name in public materials. Images and case descriptions are anonymised unless explicit consent for identification is given.

Secure storage: Personal data is stored on secure systems (e.g. password-protected server / cloud solutions with access control) for clearly defined retention periods.

4.3 Behaviour Guidelines
In all interactions with children, Compass representatives must:

• Treat all children with respect, dignity and fairness.
• Maintain appropriate professional boundaries (no favouritism, no personal secrecy with individual children, no private one-to-one digital communication without transparency).
• Use age-appropriate, non-violent and non-discriminatory language.
• Avoid any behaviour that could be misinterpreted as grooming, favouritism or seeking inappropriate emotional dependence.
• Never use corporal punishment, humiliating treatment, sexualised language or gestures.
• Never engage in any form of sexual activity or romantic relationship with a person under 18, regardless of the local age of consent.
• Immediately report any concern about the safety or well-being of a child.

Specific practical rules (e.g. photography, transport, online meetings, overnight activities) may be defined in project-specific protocols and must be followed in addition to this policy.

4.4 Training on Child Protection

• Safeguarding is integrated into Compass onboarding and internal capacity-building.
• Staff whose work includes direct or regular contact with children receive specific training on:
  • children’s rights and relevant legal frameworks,
  • recognising signs of abuse,
  • boundaries and safe communication,
  • online safety,
  • internal reporting procedures.
• Training is repeated periodically and updated to reflect new risks, legislation and project experience.

5. REPORTING PROCEDURES
All Compass staff, volunteers, interns and external collaborators are obliged to raise concerns about potential or actual abuse, exploitation or breaches of this policy, whether committed by Compass staff, partners, family members or any other person.

5.1 Duty to Report
You must report if:

• you witness or hear about behaviour that may harm a child;
• a child tells you something that may indicate abuse;
• you suspect that the Code of Conduct or this Policy has been breached;
• you are unsure but worried – doubts must be reported, not hidden.

No staff member may attempt to investigate on their own or promise absolute secrecy to a child.

5.2 How to Report
Compass will adapt the following to its internal structure (names/emails can be inserted):

Complete a short written note (e.g. Child Protection Reporting Form) as soon as possible, describing:

• what you saw/heard,
• when and where,
• who was involved (names or descriptions),
• any immediate risks to the child.

Send or hand this report without delay to the designated Child Protection Officer (CPO) or, if unavailable, to the Managing Director / designated member of management:

• Child Protection Officer: Omer DUZGUN
• Email: omer.duzgun(@)compass4you.at

The CPO will:

• acknowledge receipt,
• assess the information and level of risk,
• decide on immediate protective measures (if needed),
• determine whether to:
  • consult management / HR,
  • inform parents/legal guardians (if safe to do so),
  • contact external child protection services or Austrian authorities (e.g. Kinder- und Jugendhilfe, police),
• document all steps taken.

5.3 Confidentiality and Protection of Whistleblowers

• All reports are treated with strict confidentiality and shared only on a need-to-know basis.
• Compass guarantees that no staff member will suffer negative consequences for reporting concerns in good faith, even if the concern is not confirmed.
• Deliberate, malicious or knowingly false allegations may lead to disciplinary action in line with Austrian law and employment regulations.

5.4 Disciplinary Measures
If an internal investigation indicates that this policy or the Code of Conduct has been breached, Compass may apply one or more of the following measures:

• verbal or written warning,
• temporary suspension from duties involving children,
• termination of contract or cooperation,
• reporting to relevant Austrian authorities and professional bodies where required.

6. COOPERATION WITH EXTERNAL ORGANISATIONS, NETWORKS AND AGENCIES
When cooperating with external organisations, networks or agencies, Compass will:

• Consider child safeguarding as a core element of due diligence, including a basic check of the partner’s reputation and policies regarding children’s rights and protection.
• Share this Child Protection Policy and request that partners respect comparable standards when activities involve children.
• Include a child protection clause in partnership agreements, contracts or Memoranda of Understanding, confirming zero tolerance for abuse and the obligation to report concerns.
• Refuse or terminate cooperation with any organisation that is credibly associated with child abuse, exploitation or serious safeguarding failures.
• Collaborate where appropriate with local child protection services, youth welfare offices, schools, NGOs and authorities to ensure coordinated responses in the best interests of the child.

Policy Approval
This Child Protection Policy has been prepared by the Child Protection Officer of Compass – Beratung, Begleitung und Training gemeinnützige GmbH and approved by the Management / Board of Directors. It is binding for all Compass operations and personnel and is reviewed at least annually or earlier if required by legal changes or a safeguarding incident.
Signed on behalf of Compass – Beratung, Begleitung und Training gemeinnützige GmbH
Name: Omer DUZGUN
Function: General Manager
Place/Date: Innsbruck, 2020

Contact
If you have questions about this Child Protection Policy or wish to raise a concern, please contact:

• Email: office(@)compass4you.at
• Phone: +43 676 400 47 28
• Postal Address: Compass – Beratung, Begleitung und Training gGmbH, Kaufmannstraße 38A, Innsbruck, Austria