TABLE OF CONTENT
Page
1. Introduction

3

2. Definitions

3

3. Scope of Application

7

4. Commitment Statement8

5. Codes of Behaviour

9

6. Reporting Concerns

11Child Safeguarding Reporting Flowchart

12Child Safeguarding Incident Reporting Form

14

Responding to a Child’s Disclosure

15

7. Recruitment Procedures

17

8. Enforcement17

9. Appendices

18

APPENDICESAPPENDIX 1: AFC Child Safeguarding Recruitment Guide

19

APPENDIX 2: AFC Child Safeguarding Guidelines to Reduce and Mitigate Risk

23

1.

Use of Dressing Rooms and Shared Facilities23

2.

Use of Social Media24

3.

Use of Children’s Images and/or Audio-Visual Recordings

25

4.

Transporting of Children

27

5.

Travel and Overnight Stays with Children

28

6.

AFC Child Safeguarding Risk Assessment Tool

29

APPENDIX 3: Policy Guidance for AFC Member Associations and Regional
Associations33

2

1. Introduction
As defined in the United Nations Convention on the Rights of the Child (1989), every Childhas “the right to live free from violence, exploitation and abuse”.
The AFC champions the rights of all Children to be safe from abuse while participating in
AFC programmes and activities.
This Policy is part of the AFC’s overall commitment to safeguard Children within the AFC
football ecosystem and will be supplemented with further guidance, templates, knowledgesharing and training to support Employees, Representatives, Member Associations andRegional Associations together with regional and community organisations.
The purpose of this Policy is to outline the responsibilities and obligations of Employees
and Representatives with regard to Child Safeguarding, including through adherence tothe following principles:
1. Act in the Child’s best interests by promoting and prioritising the safety andwellbeing of Children;
2. Value, respect and listen to Children, allowing them the right to participate andfreely express their opinions in matters affecting them;
3. Ensure all Children are never subjected to any form of discrimination concerning
race, skin colour, gender, disability, language, physical appearance, religion,
political opinion, wealth, birth or any other status, sexual orientation, or ethnic,
national, or social origin; and4. Uphold and promote a culture of Child Safeguarding regardless of function, levelor position.
The Policy is an evolving document that will be updated as needed to reflect legislativeand best practice changes, in addition to feedback and consultation relating to thepractical experience of the persons and/or organisations within the AFC football ecosystem.

2. Definitions
In this Policy, capitalised terms shall have the following meanings, unless the context
specifically indicates otherwise:
Term

Definition

Bullying

Bullying involves the inappropriate use of power by one or more persons
over another less powerful person or group and can be by an adult,
another Child or by a group. Bullying is typically a pattern of inappropriate

3behaviour repeated over time. Bullying may take many forms that are often
interrelated and can include:• verbal bullying including name calling, demeaning actions and threats;• physical bullying including hitting, punching, kicking, scratching,tripping and spitting;• social bullying including ignoring, excluding, ostracising and, alienating;and/or• psychological bullying including spreading rumours, stalking, dirty looks,
hiding or damaging possessions.
For the avoidance of doubt, bullying also includes cyber bullying, which
can also have lasting and damaging consequences. Cyber bullying is
usually done via the internet, social media, SMS, MMS, email or other
online platform(s).
ChildChild Abuse

A person who is under the age of 18 years. The term “Children” shall be
construed accordingly.
Child Abuse is the mistreatment of a Child by an adult that has harmed, isharming or is likely to harm, endanger or put at risk that Child’s physicalor emotional health, development or wellbeing.
For the avoidance of doubt, this includes, but is not limited to:
●
●
●
●
●
●

Child
Safeguarding

Emotional or
Psychological
Abuse

Emotional or Psychological Abuse;
Bullying;
Grooming;
Sexual Abuse;
Neglect; and/or
Physical Abuse.

Child Safeguarding is the set of actions an organisation can take to keepChildren safe from harm. It is a broad term encompassing, amongst otherthings, the prevention of Child Abuse.
Emotional or Psychological Abuse occurs when a Child does not receive
the support or attention they need for healthy emotional, psychologicaland social development.
Such abuse may involve repeated rejection or threats to a Child. Constantcriticism, teasing, ignoring, threatening, yelling, scapegoating, ridiculingand rejection or continuous apathy are all examples of emotional abuse.
These behaviours can result or have the potential to result in significant
damage to the Child’s physical, intellectual or emotional wellbeing anddevelopment.
4

Employee(s)Football
Association
Member
Association
Grooming

All persons engaged in full or part-time service with the AFC under acontract of employment (whether on a permanent, fixed term or otherbasis). This includes, without limitation the AFC General Secretary, AFC
Deputy General Secretaries, AFC Directors, Heads of Department/Unit andall other AFC staff members.

The controlling body for football within a country or territory recognisedby the AFC.

A Football Association which is a member of the AFC.
Grooming is a term used to describe what happens when a perpetrator ofabuse builds a relationship with a Child with an intent to abuse them atsome stage. There is no set pattern in relation to the Grooming of a Child.
For some perpetrators, there will be a lengthy period of time before theabuse begins.
The Child may be given special attention and/or be treated favourably andwhat starts as an apparently normal interaction, such as tickling, or
physically embracing a Child, can develop into sexualised behaviours
including Sexual Abuse of a Child.
Grooming can take place in any setting where a relationship is formed,
such as leisure, music, sports and religious activities, or in internet chatrooms, in social media or by other technological channels.

Neglect

Neglect is the failure to provide the Child with basic needs including but
not limited to food, clothing, shelter, adequate supervision, clean water,
medical attention or supervision to the extent that the Child’s health anddevelopment is, or is likely to be harmed.
Categories of Neglect include physical neglect, medical neglect,
abandonment or desertion, emotional neglect and educational neglect.
The issue of neglect must be considered within the context of resources
reasonably available at the time.

PhysicalAbuse

Physical Abuse occurs when a person subjects a Child to non-accidental
injury and/or physically aggressive acts. The abuser may inflict an injury
intentionally or inadvertently as a result of physical punishment or theaggressive treatment of a Child. Physically abusive behaviour includes, but
is not limited to:

5

●
●

shoving, hitting, kicking, slapping, shaking, throwing, punching,biting, burning; and/or
excessive and/or physically harmful overtraining.

It also includes giving Children unlawful or harmful substances such as
drugs, alcohol, poison, tobacco or e-cigarettes.
PolicyThis AFC Child Safeguarding Policy.

Regional
Association

A group of Member Associations recognised by the AFC that belong to
the same geographic zone.

Representative (s)All persons who are elected, appointed, authorised and/or assigned by the
AFC to carry out a function and/or who otherwise represent the AFC in an
official capacity. This includes, without limitation, the AFC President, themembers of the AFC Executive Committee and other AFC Committees, allpersons appointed to exercise an official function for, or on behalf of, theAFC at any match, competition, function, course or other events organisedby the AFC, and any volunteers engaged by the AFC in connection with
its events and competitions.
This definition shall also extend to contractors, consultants, service
providers and others who may be temporarily engaged in the performanceof work or services for the AFC.

Sexual Abuse

Sexual Abuse occurs when a person involves a Child in any sexual activity.
Perpetrators of sexual abuse take advantage of their power, authority,
influence, or position over the Child for their own or the benefit of others.
Such actions constituting Sexual Abuse shall include without limitation:
●
●
●
●
●

Unacceptable
Behaviourmaking sexual comments to a Child;engaging Children to participate in sexual conversations face toface, over the internet or on social media;
kissing or touching any intimate part of a Child’s body includinga Child’s genitals, bottom or breasts;
oral or penetrative sex or other forms of sexual intercourse or
conduct with a Child; and/or
encouraging a Child to view pornographic magazines, websites
and videos.

Any behaviour or conduct which breaches this Policy or which is otherwiseinconsistent with this Policy. Examples of Unacceptable Behaviour are
outlined in Article 5.3.3.

6

For purposes of this Policy and provided the context so permits:
(a)
(b)
(c)

the singular shall include the plural and vice-versa;
the feminine gender shall include the masculine and vice-versa; andreference to natural persons shall include any legal person or corporation.

3. Scope of Application
3.1

Employees and Representatives

3.1.1 All Employees and Representatives are bound by this Policy.
3.1.2 As underlined in the definition of “Representatives”, the AFC also expects its
contractors, consultants, service providers and others who may be temporarily
engaged in the performance of work or services for the AFC to follow the Policy inconnection with their work for the AFC. Any failure by a contractor, consultant,service provider or others engaged by the AFC to abide by this Policy may result inthe termination of their relationship with the AFC.
3.1.3 The AFC expects all persons who are subject to and bound by this Policy to adhere
to the principles contained herein. Failure to do so may result in disciplinary and/or
other action being taken against the relevant individual. In appropriate cases, action
may also be taken under the AFC Disciplinary and Ethics Code.
3.1.4 This Policy will continue to apply to a person, even after they have ceased any
involvement (subject to this Policy’s terms) with the AFC, if disciplinary action
against that person has commenced.
3.2

Member Associations and Regional Associations

3.2.1 Member Associations and Regional Associations are encouraged to develop andimplement effective policies and best practices aimed at ensuring the protection
and safeguarding of Children at various levels of football within their respective
jurisdictions.
3.2.2 The Policy Guidance for AFC Member Associations and Regional Associations as
set out in Appendix 3 of this Policy shall serve to provide general guidance toassist Member Associations and Regional Associations in the development andimplementation of their Child Safeguarding policies and practices.

74. Commitment Statement
4.1

This Policy serves to uphold the AFC’s core values and recognise that the welfare
and interests of Children are paramount in the AFC’s programmes and activities.
It aims to ensure that all Children:● have a positive and enjoyable experience of football with the AFC in a safe andChild-centred/friendly environment; and● are protected from abuse whilst participating in AFC programmes and activities.

4.2

The AFC acknowledges that Children, including Children with impairments,
disabilities and/or those from ethnic minority communities, can be particularly
vulnerable to Child Abuse and we accept the responsibility to take reasonable andappropriate steps through the provision of the required manpower and resources
to ensure their safety and wellbeing during AFC programmes and activities.

4.3

The AFC commits to the following:
4.3.1 Recognising and communicating to all Employees and Representatives
through this Policy (and other means, where appropriate) that Children havethe right to be protected from all forms of Child Abuse.
4.3.2 Establishing an AFC Child Safeguarding team to oversee the implementationand development of Child Safeguarding best practices within the AFC andto liaise with Member Associations and Regional Associations in respect toChild Safeguarding matters and best practices.
4.3.3 Requiring Employees and Representatives to adhere to this Policy.
4.3.4 Ensuring that all allegations of Child Abuse are responded to promptly, ina confidential manner and through established reporting lines in accordancewith this Policy.
4.3.5 Raising awareness and influencing others on the importance of
safeguarding Children by using our policies and procedures to uphold ourcommitment and values.
4.3.6 Providing effective management for Employees and Representatives
through supervision, support, training and quality assurance measures.
4.3.7 Ensuring appropriate action is taken in the event of incidents or concernsof Child Abuse and that support is provided to the individual(s) who raiseor disclose concerns.
4.3.8 Ensuring that confidential, detailed and accurate records of all safeguarding
concerns are maintained and securely stored.
4.3.9 Reducing the risk of employing and engaging unsuitable individuals byrecruiting and selecting Employee and Representatives safely and ensuring
appropriate probity and reference checks are completed.
4.3.10 Sharing information about Child Safeguarding and good practice withChildren and their parents.
84.3.11 Ensuring that Children and their parents know where to go for help if they
have a concern.
4.3.12 Ensuring everyone within the AFC understands their roles andresponsibilities in respect of Child Safeguarding and are provided withappropriate learning opportunities to recognise, identify and respond tosigns of Child Abuse.
4.3.13 Reviewing this Policy and Child Safeguarding procedures periodically.
4.3.14 Striving to ensure that adequate resources are allocated to allow for thedevelopment and implementation of this Policy.
4.3.15 Developing opportunities for regular discussions at all levels to support aculture of openness, continuous improvement and accountability for Child
protection and Child wellbeing.
4.3.16 Encouraging policy development and implementation amongst Member
Associations and Regional Associations.
4.3.17 Promoting Child Safeguarding across the Asian football ecosystem.
4.3.18 Advocating and promoting Child rights, and empowering and engaging
Children in support of this Policy and its objectives.

5. Codes of Behaviour
5.1This section outlines the required level(s) of professional conduct that Employees andRepresentatives must observe when working with or in the presence of Children
during any AFC programme or activity or otherwise in an AFC context. This serves tosupplement the AFC’s expectations as set out in the AFC Code of Conduct and
Employee Handbook.

5.2

These requirements play an important role in setting out the AFC’s expectations of:
5.2.1 Personal and professional boundaries;
5.2.2 Ethical behaviour; and5.2.3 Appropriate and inappropriate behaviour when working with or in thepresence of Children during any AFC programme or activity or otherwise in
an AFC context.

5.3 The requirements are as follows:
5.3.1 Core Values
The standards of behaviour which Employees and Representatives are expected toobserve when working with or in the presence of Children during any AFC
programme or activity or otherwise in an AFC context are based on the following
core values:

9

a)
b)
c)
d)
e)

to act in accordance with the vision, mission and values of the AFC;
to display respect and courtesy towards Children;
to prevent discrimination and harassment;
to prioritise the safety and wellbeing of Children; andto report any Unacceptable Behaviour to help prevent the abuse of Children
in the AFC community.

5.3.2 General Rules of Behaviour
When working with or in the presence of Children during any AFC programme oractivity or otherwise in an AFC context, Employees and Representatives shall not:a)use, possess or be under the influence of any illegal drug(s);b)
use or be under the influence of alcohol;c)be incapacitated by any other legal drug such as prescription or over-thecounter drugs; and/ord)supply alcohol or drugs (including tobacco/e-cigarettes) to a Childparticipating in any AFC programmes/activities.
It is strongly recommended that Employees and Representatives familiarise
themselves with and adhere to the Child Safeguarding Guidelines to Reduce and
Mitigate Risk as set out under Appendix 2 of this Policy.
5.3.3 Unacceptable Behaviour
Employees and Representatives must not engage in any conduct that constitutes
or may constitute Unacceptable Behaviour when working with or in the presenceof Children during any AFC programme or activity or otherwise in an AFC context.
Without limitation, the following shall constitute Unacceptable Behaviour for the
purposes of this Policy:

a)
b)

c)

d)

any form of Child Abuse (which, for the avoidance of doubt, includes PhysicalAbuse, Emotional or Psychological Abuse, Bullying, Grooming, Sexual Abuse
and Neglect) or similar conduct;any conduct that involves inappropriate or sexual handling of a Child, otherthan as part of delivering medical or allied health services, questioning or
discussing sexual preference, experience or knowledge with a Child;any suggestive conduct including undressing in front of Children (including
in dressing rooms, accommodation settings and bathroom areas which are inuse by a Child);
showing a Child any offensive written material or images, whether in hard
copy or electronic form (e.g., any form of pornography including via social
media platforms);

10

e)

f)
g)

taking or displaying photographs of a Child that are inappropriate, covert,
and/or any photographs taken without the consent of the Child’s parent orlegal guardian;contacting a Child for non-work-related matters; and/or
engaging in any form of communication and/or activity with a Child outside
the scope of any AFC programme or activity or for non-work-related matters.

6. Reporting Concerns
6.1

Employees and Representatives must report any Child Safeguarding concerns or
suspicions (i.e., regarding any Unacceptable Behaviour by any person) in a timely
manner to the AFC Child Safeguarding team and, where necessary, external
agencies, so that appropriate action can be taken to manage and address suchconcerns.

6.2

Employees or Representatives who fail to report any concern or suspicion of
Unacceptable Behaviour shall be in breach of this Policy, and such omission may
result in disciplinary and/or other action being taken against such individuals.

6.3

The AFC Child Safeguarding Reporting Flowchart as appended under Article 6.6
below sets out the process to be followed when managing a reported concern or
suspicion that has been reported to the AFC Child Safeguarding team.

6.4

All concerns or suspicions of Child Abuse or Neglect involving any Employee orRepresentative within any AFC programme or activity or otherwise in an AFC
context may be reported to the AFC Child Safeguarding team at safeguarding@theafc.com. All reports shall be submitted with the AFC Child Safeguarding Incident
Reporting Form as set out under Article 6.6 below.

6.5

For the avoidance of doubt, concerns and suspicions of Unacceptable Behaviour by
third parties (i.e., not Employees or Representatives) shall still be reported to the
AFC Child Safeguarding team and, where appropriate, directly to the local
authorities.

11Child Safeguarding Reporting Flowchart

12

Notes:When identifying appropriate action(s) and next steps, due regard must be accorded to thecategory of suspicion or concern reported. In so determining, the AFC Child Safeguarding
team may assess the same based on the following levels of risk:
Levels of Risk
Low Risk
Moderate Risk
High Risk

Description
No harm or impact to Child
Slight harm or impact to Child, withability to mitigate any harm or impact
sustained
Significant harm and impact to Childrequiring urgent/immediate intervention

The description of risks as outlined above is not intended to be exhaustive. Risks that do
not fall within these categories may be identified during the process of verification andassessment.

13

6.6

Child Safeguarding Incident Reporting FormYour information

Name
Contact number
Email
Name of organisation (ifnot AFC)

Your role

Personal information of the Child
Name
GenderMale

FemaleNon-binary

◻

◻

◻

Date of birth
Another description (please state)◻

Contact information – parent/carerName(s)Address
Contact number(s)EmailIncident details*
Date and time of incident
Please tick
I am reporting my own
one:concerns◻

◻

I am responding to concerns raised by someone else – please fill in
their details:

Name of person raisingRole within football orconcern
relationship to the childContact number(s)EmailDetails of the incident or concerns (include other relevant information, such as description of any injuries and/or disclosure madeby a child)* Attach a separate sheet if more space is required (e.g. multiple witnesses)
Child’s account of the incident (if disclosed by the child to you)

Please provide the names of any witness to the incident

Name of witness (pleaseindicate if a child)Role within football (Coach,
Official, Player)

Contact number(s)EmailDetails of any person involved in this incident or alleged to have caused the incident/injury

14

Name

Role within football (Coach,
Official, Player)

Contact number(s)EmailPlease provide details of any action taken to date (Contacted AFC, removal of persons involved in incident, police contacted *Seenext section)

Has the incident been reported to any external agencies?

◻ No

◻

Yes – please provide
further details:

Name of organisation/agency
Contact person
Contact number(s)EmailAgreed action or advice given

Declaration
Your signature
Print name
Date

Contact your Safeguarding Officer in line with the AFC’s reporting procedures
Safeguarding Officer’s
name
Date reported

6.7

Responding to a Child’s Disclosure of Abuse

The AFC recognises that Children may disclose their experiences of Child Abuse to
Employees and Representatives. Employees and Representatives shall observe the following
guidance notes when handling such matters. It should be noted that Employees andRepresentatives should, if the circumstances allow, contact the AFC Child Safeguarding
team before initiating any conversations, but it is acknowledged that the Child’s interests
must come first and a conversation should not be rejected.

15

LISTEN

REASSURE

RESPECT

Move to a suitable environment free of distractions.
Be calm and patient – allow the Child to be heard.
Let the Child use their own words – avoid asking questions.
Avoid ‘quizzing’ the Child about details of the abuse.
Don’t be afraid of saying the ‘wrong’ thing. Listening supportively is more
important than what you say.

Reassure the Child that it is OK they have told you what has been happening.
Address any concerns about the Child’s safety.
Reassure the Child that he or she is not at fault, and not the cause of any distress
you may feel.

Respect that the Child may only reveal some details.
Acknowledge the Child’s bravery and strength.
Avoid making promises you can’t keep – manage the Child’s expectations.
Explain to the Child that you will need to report their experience to someone else
who can help.

Do
Let the Child tell you in their own words.
Reassure them that ‘It is OK’ they told you.
Tell them ‘It is a brave thing to speak about
this’.
Do tell the Child ‘What happened is not theirfault’.

Don’t
Don’t panic and say, ‘That didn’t happen’or ‘I doubt that is true’.
Don’t ‘quiz’ the Child about the details ofabuse.
Don’t make promises you can’t keep (e.g.,‘You don’t have to go home’).

Employees should take notes either during the conversation (if over the phone) or immediately
after (if face-to-face). Document what was said ‘in the Child’s own words’. Employees and7. Representatives
Recruitment
to Reduce
Risk of shared
Harmandtonoted whenshall Procedures
ensure the confidentialityof all information
responding to any disclosure of abuse.

167. Recruitment Procedures
7.1

The AFC is committed to ensure that recruitment and screening practices that
reduce the risk of Child Abuse are observed when recruiting for Child-facing roles.
For the purposes of this Policy, the AFC defines a ‘Child-facing role’ as one wherea person is:● working directly with Children on a regular basis (not incidentally or one-off);
and/or● providing assistance, programmes or services to Children on behalf of the AFC.

7.2

The AFC Human Resources Department (where appropriate, in consultation with
the AFC Child Safeguarding team) will assist Heads of Departments/Units and the
AFC Management when recruiting for Child-facing roles, taking into consideration
the provisions of the Child Safeguarding Recruitment Guide as set out under
Appendix 1.

8. Enforcement
This AFC Child Safeguarding Policy has been adopted on 11 January 2022 and comes
into force with immediate effect.

179. Appendices1) AFC Child Safeguarding Recruitment Guide
2) AFC Child Safeguarding Guidelines to Reduce and Mitigate Risk
1.

Use of Dressing Rooms and Shared Facilities2.

Use of Social Media3.

Use of Children’s Images and/or Audio-Visual Recordings

4.

Transporting of Children

5.

Travel and Overnight Stays with Children

6.

AFC Child Safeguarding Risk Assessment Tool

3) Policy Guidance for AFC Member Associations and Regional Associations

18

APPENDIX 1:
AFC CHILD SAFEGUARDING RECRUITMENT GUIDE
1.

Recruitment checklist

The implementation of robust recruitment procedures will help the AFC ensure that thebest applicants are employed in Child-facing roles to reduce the risk of employment or
engagement of unsuitable individuals. From advertising, through to conducting interviews
and background checks on applicants, it is important that each step is considered andapplied where necessary.
This checklist and guide will assist any Employee involved in the recruitment of Childfacing roles to observe and undertake certain steps in the recruitment process. It includes
objectives and examples for:⬜ Selection criteria in job descriptions.
⬜ Advertising with a Child-safe intent.
⬜ Interviews including behavioural-based questions and questions about motives
for wanting to work with Children.
⬜ Pre-employment screening including police/probity checks, identity checks(including international police record checks where necessary) and qualification
checks.
⬜ Reference checks over the telephone with recent managers/supervisors.
⬜ Probation periods and performance reviews.

*AFC departments shall adopt this checklist entirely and use all relevant components as
referred to below alongside existing recruitment procedures.
A. Selection criteria in job descriptions
Developing the job description and appropriate selection criteria for the position isa vital first step in reducing the risk of employing someone who poses a risk toChildren. It will also ensure that all applicants have the specific knowledge andskills required for the position. Roles involving interaction with Children should
explicitly include reference to safeguarding job descriptions. If the role is identified
as Child-facing, hiring departments must clearly indicate the same in the job
description to the Human Resource department.

19

Examples of appropriate selection criteria language may include:● “Must have experience working with Children”; and/or● “Must be able to demonstrate an understanding of appropriate professional

standards when working with Children”.
Remember to ensure that the selection criteria provides for the safety of all Children.
Your applicants should have the opportunity to indicate their understanding of, or
any experience they have, in working with Children with diverse needs and/or
backgrounds. For example:● Children living with a disability● Children from a diverse range of cultural/linguistic backgrounds
B. Advertising with a Child Safe intent
When recruiting, advertising provides a good opportunity to demonstrate the AFC’scommitment to Child Safeguarding in addition to deterring potential candidates
who may be seeking an opportunity to harm Children. Roles involving interaction
with Children should explicitly include a reference to Child Safeguarding principles
and values in the advertisements.
It is imperative that the AFC promotes the safety, participation and empowermentof all Children.
A suggested statement may be:‘The AFC promotes the safety, wellbeing and inclusion of all Children. Applicants
are encouraged to elaborate on experience they may have working with Children
safely.’C. Interviews
The interview process is a critical step in selecting the right people for the AFC’s
Child-facing roles and in identifying any person who may pose a risk to Children.
An open-ended style of behavioural-based questioning will give insight into theapplicant’s values, attitudes and understanding of professional boundaries andaccountability. Some useful questions may include:● Tell us about why you want to work with Children?
● How would the Children you have worked with previously describe you?
● Describe a time when you had to manage a Child whose behaviour you
found challenging?
● Tell us about a time when you had to comfort a distressed Child?
● What boundaries are important when working with Children?
20

● If you were concerned about the actions or behaviour of a co-worker
towards Children, how would you respond?
● How would you involve Children in their own protection as part of ourprogrammes?
Interview panel members should be instructed to take note of their own thoughts
and feelings when interacting with the applicant. Always ask for more information
if the applicant does not provide sufficient information in his or her responses.
Furthermore, take notice of any warning signs (often referred to as ‘red flags’) suchas:
● Unexplained lengthy gaps in employment history● The applicant says they do not value or ‘need’ supervision● The applicant objects or criticises the need for a code of conduct● The applicant is evasive or inconsistent in his or her answer
D. Pre-employment screening
Screening applicants (including for paid and volunteer positions) is an essential toolfor helping prevent people who may abuse Children from being employed by theAFC. Police/probity checks from countries the applicant has recently worked in can
provide insight into any prior criminal convictions. At the very least, a selfdeclaration form (or national equivalent) should be signed when a reliable criminal
record check is not available. This can include broader questions about whether theindividual has ever been subject to a disciplinary investigation. All such checks must
be completed before the individual starts working in his/her role.
Additional checks will confirm the identity of the applicant and that theirapplication and responses have been truthful.
● Have you checked the identity of the applicant (for example, that theirdriver’s licence/passport has the same name they have provided you)?
● Did you see a certified copy of the applicant’s qualifications (if required)?
E. Reference checks
The AFC aims to require each applicant to provide the contact details of at least
two referees as this can provide insight into the applicant’s character and skills. All
reference checks will be undertaken as preferred over the phone by the AFC.
Managers, particularly the most recent, are likely to provide you with the mostaccurate reference.
*Where possible, referees that can provide insights into the applicant’s
experience working with Children should be contacted as first preference.
21

When speaking with referees, always seek to establish the referee’s relationship withthe applicant, including:● How long the applicant and referee worked together● The specifics of the position● The applicant’s perceived strengths and weaknesses● Whether the referee would hire the person again, particularly in a role
working with Children● Whether they have any concerns about the applicant working with Children
Additionally, ask referees directly about any concerns they may have about theapplicant working with Children. To help introduce this difficult topic, you could
say you have some specific questions about Child safety because your organisation
takes Child safety seriously.
Ask behaviour-based questions like:● What did the applicant do when (for example, they had to comfort a
distressed Child)?
● Do you have any concerns about the applicant’s attitude towards people
from culturally and/or linguistically diverse backgrounds/people with adisability?
F. Probation
Probation periods can help the AFC assess any new worker’s performance andsuitability for the job before confirming their permanent employment. The lengthof probation periods can vary and are usually between three (3) and six (6)months.
The AFC will consider whether the person should receive closer supervision and/or
additional training throughout the probation period. A probation period can offer
an opportunity to set goals with inexperienced workers and identify training,supervision and other support needs.
Induction and performance review in relation to Policy awareness is recommended
at bi-annual intervals for all employees.
G. Contacting the AFC Child Safeguarding team for further information
The AFC Child Safeguarding team can assist you with any questions or further
information if needed.

22

APPENDIX 2:
AFC Child Safeguarding Guidelines to Reduce and
Mitigate Risk
The AFC is committed to ensuring that Children participating or involved in AFC
programmes and activities are protected from Child Abuse. Football, like many sports, has
potential areas of risk which require attention. The following are examples of risks andencouraged behavioural actions to reduce and mitigate any Unacceptable Behaviour inrelation to such risks:

1. Use of Dressing Rooms and Shared Facilities
It is important to monitor and maintain the safety of Children when utilising certain
facilities during AFC programmes and activities, including dressing rooms and sharedfacilities.
Children can be vulnerable to abuse in dressing rooms due to common activities ofdressing/undressing, use of shower areas and toilets and because they are less supervisedthan at many other times (for example, whilst on the pitch).
The risk of Child-to-Child inappropriate conduct, such as Bullying or sexual harassment,
may be prevalent when coaches or Employees are not supervising Children. This isespecially true in dressing rooms.
To reduce the risk of misconduct or Child Abuse in dressing rooms and shared facilities
it is recommended that:● An Employee or Representative assist or supervise all operational affairs of theChild/Children involved in the AFC programme or activity.
● Where facilities are used by both adults and Children at the same time, there must beaccess to separate changing, showering and toilet areas.
● Under no circumstances should adults undress in front of Children in dressing rooms.
● Adults must not change or shower at the same time as Children using the same facilities.
● For mixed-gender activities, separate dressing rooms must be available for boys andgirls. If only one dressing room is available, the boys and girls must use these dressing
rooms alternately at different time slots.
● If a Child feels uncomfortable changing or showering in the dressing rooms, then nopressure should be placed on him/her to do so. Instead, he/she should be encouraged
to do so at home/hotel or official accommodation.

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● If Children living with a disability need to use facilities, make sure they are accessible,
and the Child and his/her carer participate in deciding if and how they should be
assisted.
● The use of mobile phones and/or photographic equipment with video recording
capabilities by Employees, Representatives or any other persons including Children
themselves is prohibited when Children are utilising the dressing rooms to dress or
shower.
● Where no dressing room facilities are available, Children and their parents or guardiansshould be made aware of this prior to the game and advised to make alternative
arrangements and take appropriate additional clothing.
● Parents should be excluded from entering the dressing room unless it is absolutely
necessary (e.g., injured Child and/or distressed Child). In such circumstances, preferably
only a parent of the same sex as the Child may enter the dressing room. At least one
member of the coaching staff of the same sex as the Child involved should be present
with the parent when other Children are in the dressing room, especially if a parent of
the same sex as the Child is not available to accompany the Child.
● Except for Employees or Representatives that are authorised to assist the Children in
dressing rooms or any facilities as required, all other Employees, Representatives andany other persons, especially those of the opposite sex, should not be in the dressing
room when Children are utilising such facilities to change or shower.

2. Use of Social Media
Misuse of information, communication and technology can put Children at considerable
risk of:● Inappropriate access to, use or sharing of personal details (e.g. names, email
addresses or phone numbers);● Unwanted contact from adults with wrongful intent;● Being sent offensive or otherwise inappropriate material;● Online Bullying; and/or● Grooming for Sexual Abuse.
All Employees and Representatives who work with Children should ensure that their social
media accounts are set up as securely as possible. Each website, app or device will requirea slightly different configuration to set it up correctly.
There are, however, some key principles which apply to all forms of social media:● Employees and Representatives shall not post any inappropriate photo, image oraudio/video footage of a Child whether involved in AFC programmes, or activities
or otherwise.
● Never give out your password, pin or login details to any other person. These details
should be kept private at all times. You should also ensure that you log out after

24

●

●

●

●

●

●

use and don’t leave your social media accounts open on a shared device as otherpeople (including Children) could post in your name.
Employees and Representatives should not be ‘friends’ or ‘connected’ with juniorplayers/officials on personal social media platforms. Private chat functions within
online platforms are often unmoderated and can leave adults open to accusationsof improper use.
If you need to communicate with Children associated with AFC programmes or
activities, do so through official AFC communication (i.e., an AFC email account)or an AFC-appointed personnel or by group text message; approved apps/sites
and/or phone calls to parents/carers; or via a post on an AFC approved platform,
on a closed club or governing body page rather than via your personal profile.
Remember that what you post online can be easily misinterpreted. When things are
typed instead of said face to face it is often difficult to know the true meaning of
the words and people can easily take offence to a post that was shared without
intending to upset. This is especially true when online abbreviations, hashtags or
emojis are used in place of words so before you post, consider how someone elsemight read your post.
Never post or share messages, images and/or audio-visual recordings which are
unlawful or illegal including content that may be deemed abusive, discriminatory
or sexually explicit.
Employees and Representatives are personally responsible for content they publish
on social media and must be aware that what they publish can affect their own
image and the image of the AFC.
Be sure your online postings about the AFC or its activities are accurate and not
misleading. It is advisable to refer any queries to the AFC Communications team at
media@the-afc.com*Any online Grooming or inappropriate conduct towards Children via an electronic
service is illegal and will be immediately reported to the AFC Child Safeguarding team
and/or Legal and/or local authorities.
The use of social media shall at all times be in accordance with the AFC’s Social Media
Policy.

3. Use of Children’s Images and/or Audio-Visual Recordings
The guidelines below set out the recommended best practices in order to reduce the riskof inappropriate use of Children’s images and/or audio-visual recordings.
● All photographers should be authorised and easily identified with a clear
identification bib/tag/lanyard or badge.
● Consider using models or illustrations for promotional/advertising purposes whereappropriate.
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● Unsupervised access or one-to-one photography or video sessions with Children
under 18 should not be allowed. At least one AFC Employee, Representative and/or
the Child’s parent or legal guardian should attend any one-to-one photography orvideo session if requested by the AFC.
● Obtain written permission from the Child's parent/guardian prior to taking imagesof a Child.
● If there is a large event with many Children involved (e.g. Grassroots/Community
events), seek consent with information and registration documents prior to theevent. Additionally, it is recommended that event coordinators set up signage thatindicates “Photography of today’s event will occur. If you do not consent to yourChild’s image being captured and used, please speak to the event management
team via (insert location/contact details)”. This is an informed consent practice.
● For non-competition events, if an image is used, avoid naming or identifying theChild. If this is not possible, do not use both a first name and surname. Thisintentionally makes it harder to find a Child online if only the first name is provided.
● Avoid displaying personal information such as a Child’s full name, residential
address, email address or telephone numbers if images are being posted on websites
or distributed in publications.
● Do not display information about hobbies, likes/dislikes, school, etc. as thisinformation has the potential to be used as Grooming tools by online predators orother inappropriate persons.
● Photography or filming should not be permitted in changing areas, bathrooms or
sleeping areas.
● Only use appropriate images of the Child relevant to football or approved activities.
Ensure that the Child is suitably clothed.
● Reduce the ability for direct copying of pictures from a website to another source(i.e. disable the 'right mouse click' function).
● Clearly outline in a written contract to photographers who are engaged to takephotos and who will retain the images taken, include arrangements made fornegatives, digital files and proofs, and outline any restrictions for use and sale. It
is important to note that certain use of camera devices and/or sharing of images
are inappropriate and not permitted, including images or photos that are:o indecent, inappropriate or suggestive;o taken in changing rooms, toilets or other designated private areas;o for the purposes of voyeurism or in an otherwise provocative or sexual manner;
and/oro used for commercial purposes without the consent of the subject (the person's
image or likeness is used to endorse a product).
•

Employees and Representatives access to photo/image gallery (including images
and digital footage of Children). Protocols when accessing the AFC photo/image
gallery shall include without limitation:26

o Employees and Representatives must have a work-related reason for accessing
the gallery;o Photos/images of Children must not be sent to any person unless it relates towork;o Hard copies of images should be kept in a locked area (e.g. lockable drawer orfiling cabinet);o Electronic images should be in a protected folder with restricted access;o Images should not be stored on unencrypted portable equipment such as
laptops, memory sticks or mobile phones; ando If personal equipment is used to take/download photos and recordings ofChildren for work purposes, images must be deleted once the project/work iscompleted.
Any concerns or complaints of inappropriate image use must be raised with the AFC’s Child
Safeguarding team.

4. Transporting of Children
At certain times during AFC programmes and activities, you or an AFC Employee and/or
Representative, may be required to travel to various locations with a Child. Employees areallowed to drive a Child (or group of Children) to locations under the condition that theguidelines set out below are observed at all times:
Prior to traveling:● Ensure that the Child’s parent or legal guardian has expressly consented for the Childto travel for the purposes of an AFC programme, event and/or activity requiring avehicle.
● Ensure you hold a valid and current driving licence.
● Ensure you are not under the influence of alcohol or illicit drugs.
● Ensure you inform your manager of the intended travel, the location and when you
will leave and return from your trip.
During travel:● Whenever possible, travel in a group with another worker or more than one Child.
● Ensure all Children are seated in the back seat of the car and fitted with seat belts
before leaving. A worker is not allowed to drive a Child anywhere without a fitted seatbelt or with a Child in the front seat (unless all rear seats are filled).
● Ensure all Children alight the car on the sidewalk side of the road.
● Take the most direct and convenient route without any unnecessary detours (e.g. do
not run errands, take the scenic route, stop unnecessarily, etc.).
● Do not detour Children to any secluded areas for any reason.

27

● Do not leave a Child at a destination unaccompanied by another worker/adult without
prior arrangement.
Once you arrive/return:● Always advise your manager/supervisor of your arrival/return (via call, SMS, email, etc.).
During youth events and competitions, safe use of buses and minivan vehicles should
include:● Always having a minimum of three (3) players (Children) in each vehicle.
● Whenever possible, having a team official (or responsible adult) accompany the groupin each vehicle.
● Seat players (Children) in the rear of the vehicle rather than the seats directly behindthe driver.

5. Travel and Overnight Stays with Children
Overnight stays in hotels, camps, and/or competition events are to occur only with thewritten authorisation from the management of the relevant AFC department. Written
approval from the parents/guardians of the Child/Children involved must be obtained. Thisapproval needs to be prior to the event and in writing. Employees and Representatives
attending an overnight stay involving Children must be appropriately screened inaccordance with the guidelines set out under the AFC Child Safeguarding Recruitment
Guide.
Attendance by Children at formal events such as an awards event or regional conferenceis only permitted when a parent or legal guardian travels and attends the event with theirChild or where express consent is provided by a parent or legal guardian to that effect.
Practices and behaviour by all persons involved during an overnight stay must be consistent
with the practices and behaviour expected during the delivery of our programmes/activities.
The AFC acknowledges that Children may attend overnight stays in hotels, camps, and/or
competition venues throughout the region and requires several risk management standards
be in place. Standards of conduct that must be observed by all persons involved during anovernight stay include:●

providing Children with privacy when in restrooms and changing areas;●

observing appropriate dress standards when Children are present – such as no
exposure to any adult nudity, showering or undressing;●not providing Children access to areas where they can be exposed topornographic material (for example, through movies, television, the Internet,
magazines, or literature);●

not leaving Children under the supervision or protection of unauthorised persons
such as hotel staff, unauthorised parties or friends;

28

●providing sleeping arrangements that do not compromise the safety of Children
such as unsupervised sleeping arrangements or an adult sleeping in the same
bed as a Child. Having adults sleep in rooms adjacent to a Child’s room (or as
close as possible) affords easy monitoring of Children’s rooms;●

the right of Children to contact their parent/guardian, or others, if they feelunsafe, uncomfortable or distressed during the stay;●

subject to the AFC’s direction regarding the use of mobile devices during AFC
events and activities, not removing a Child’s access to their mobile phone orability to be contactable whilst away from their families/guardians; and●an expectation that parents/guardians can, if they wish, make contact with theChild.

6. AFC Child Safeguarding Risk Assessment Tool
This risk assessment tool provides some examples of potential risks of harm that may
occur during an AFC programme or activity when working or volunteering withChildren. Some examples of risk and how they can be mitigated are provided in thetemplates below (organisational-level risk assessment and activity-by-activity risk
assessment).
The examples do not cover every potential risk and this assessment should be adapted
accordingly and reviewed regularly before the implementation of new programmes andactivities to ensure the best possible plan has been put in place.
This assessment should be adapted to fit with the way your team works withChildren.
A. Risk assessment template (organisational level)
Terms used:• Potential risk of harm to Children - identified risks to Children participating

in football.
• Likelihood of harm happening - the likelihood of the risk occurring: Low,

Medium or High.
• Required policy, activity or guideline needed in response- which policy, activity or guideline is required to address the risk?
• Responsibility – who is responsible for reducing the risk?

29

Potential risk toChildren

Likelihoodof harm:(low, med,
high)Required policy,
procedure, guidelineor activity

Who is responsible
for managing thisarea of risk?
(depending on theevent)

Further action(if needed)
Examplesbelow

AFC EMPLOYEES & REPRESENTATIVES
Recruiting
inappropriate people
to work withChildrenLack of Child
Safeguarding
training for
employees, officials,
volunteers,
contractors
Other adults who
may have access toChildren – e.g.,security, medical• Safe Recruitment

High• Child Safeguarding

training and induction• Child Safeguarding

training and induction

Medium• Child Safeguarding

PolicyHigh• Child Safeguarding
training• Child Safeguarding
PolicyRecruiting managers,
Human Resources, Child
Safeguarding team

Background andreference checks.

Child Safeguarding
team, Human Resourcesand department
superiors

Child Safeguarding teamand relevant
departments involved

Identify who thesegroups of adults
are and thereafter
assess the risks anddevelop any
necessary guidance
that are context
specific. Implement
steps to mitigate
risks as referred tounder this Policy as
a first step ofaction.

Child Safeguarding
team, Competitions andEvents team and anyother departments
involved in such an area

Clarify
responsibilities
before a match /training session. To
ensure the rightsignages are inplace and to
additionally brief
all Employees
and/orRepresentatives.

Security and Events
team

Plan ahead tocreate the safest
possible
environment, whichshall include CCTV
and guards on site.

FACILITIES AND ACCOMMODATION
Unauthorised accessto Children’s
activity areas(changingrooms, bathrooms)

Children and adults
sharing the sameaccommodation or
facilities

High

High

•

Child Safeguarding
Policy• Child Safeguarding
Policy30

TRANSPORT AND TRAVELTransportingChildren between
venues/training
without approval

Unvetted drivers
employed totransport Children

Unregulated
travelling and trips
away

High

•

Child Safeguarding
PolicySecurity and Events
team

Low
(If it is in a
bus/minivan)

MediumHigh• Child Safeguarding

Policy• Safe recruitment• Child Safeguarding

Policy• Parental consent forms

Security and Events
team

Security and Events
team

Plan ahead tocreate thesafest possible
environment
which could
includeensuring thatsuch vehicle isa van or a bus
with many
people pervehicle,indirectlyreducing therisk of any
form of abuse
and to always
ensure an AFC
Representative
and/or
Employee ispresent.

Plan ahead tocreate the safest
possible
environment.
Extensive earlyplanning required.
Ensure there is achecklist for trips
away and ensure
there are enoughtrained and vetted
adults to supervise.
To obtain parental
consent.

COMMUNICATION AND SOCIAL MEDIA
Inappropriate use ofsocial media andcommunication by
under-18 players• Player’s Code of Conduct

Low(to be developed)• Social Media guidance

for under-18 players

Child Safeguarding teamand Grassroots
department

To encourage AFC
Employees/Representatives to reportsuch matters to the
AFC Child
Safeguarding teamif such links or
pages are foundonline.
AFC Child
Safeguarding team
to conduct random
checks on theirsocial media.
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Inappropriate use ofsocial media andcommunication by
adults with Children(under 18 years old)

• Child Safeguarding

PolicyMedium• Guidance ofChild Safeguarding teamand Communications
teamcommunication withChildren under 18

To encourage AFC
Employees/Representatives to reportsuch matters to the
AFC Child
Safeguarding teamif such links or
pages are foundonline.
AFC Child
Safeguarding team
to conduct random
checks on theirsocial media.

COMPLAINTS AND DISCIPLINE
Concern about
behaviour of an
adult towards aChild or group ofChildren•High

Clear Reporting
Guidelines as
outlined in the Child
Safeguarding Policy

Child Safeguarding
team, Legal and Human
Resources

Report concern
to Safeguarding
Officer.
Immediate actionneeded.

B. Risk assessment template (activity level): to be completed at the start of every
new project/activity
What contact
will you havewith Children
through thiswork project?

What potential
risks to Children
can you
identify?

What steps will you
take to mitigate theserisks?

Will the contact beface to face
and/or online/digital?
• What activities willChildren be
involved in?
• Will the Children be
photographed, filmedor asked to share
their stories?
• Will parents/carers
be present
or arestaff/volunteers
acting in loco-• Are there any risks
inherent inthese activities?
• Who will bepresent?
• Will these people
be MA staff/
volunteers or third
parties?
• What will theenvironment be
like?
• What physical oremotional issues may
arise?

• What have/will you include
in your safeguarding
planning?
• Who is your designatedsafeguarding contact for thisactivity?
• What support will beavailable for the Children
present?
• How will concerns be
managed should they arise?
• What safeguarding
information will everyone
involved receive at the startof the activity?

Who isresponsible
for ensuring
these steps
are taken?

Pleaseconfirm datewhen theaction wascompletedparentis?

Please confirm that this risk assessment has been copied to the AFC’s
Safeguarding Officer or focal pointYour name and role:______________________

32

Appendix 3:
Policy Guidance for AFC Member Associations andRegional Associations
Note: This document should only be used as guidance. Member Associations and Regional
Associations will have to take into account their own local laws, procedures and practices
when devising policies and procedures.
The AFC, as the governing body of football in Asia, emphasises the importance of each
Member Association and Regional Association having policies, procedures and guidelines
to ensure that these organisations are safe for Children. The AFC has developed this policy
guidance summary to assist its Member Associations and Regional Associations indeveloping and implementing their Child Safeguarding policies and best practices.
Member Associations and Regional Associations are encouraged to appoint a suitable anddedicated Child Safeguarding focal point within their organisation, who should be provided
with the necessary support, training and resources to facilitate Child Safeguarding
initiatives, including the development of a safeguarding policy. The Child Safeguarding
focal point will act as a point of reference and as a coordinator. A vital role of the Child
Safeguarding focal point is to work closely with key internal and external partners todevelop and implement safeguarding procedures, especially procedures for responding tosuspected cases of abuse. This person will also liaise with the AFC on relevant topics.
Member Associations and Regional Associations should ensure that the following key areas
are met when developing a Child Safeguarding policy:● Strive to ensure that the policy is adhered to by its members, affiliates andstakeholders and their staff and officials;● Advocate and promote Child rights, empowering and engaging Children in supportof the policy;● Proactively share resources and experience in the development of Child
Safeguarding initiatives in football as they are identified;● Develop opportunities for regular discussion at all levels to support a culture ofcontinuous improvement and accountability in respect of Child protection. For
example, in team meetings or regular forums, include Child Safeguarding as aregular agenda item; and● Strive to ensure that adequate resources are allocated to allow effective
implementation of the policy.
Member Associations and Regional Associations are encouraged to have in place thefollowing:
1. A Code of Conduct (that identifies clear professional standards of conduct whenworking with, or in the presence of Children).
33

2. Clear procedures for responding to allegations of Child Abuse, which includes theimplementation of local laws and internal processes.
3. Sound recruitment screening processes for Employees/volunteers who are
engaged to work with Children (including criminal record checks andbackground/reference checks).

Your organisation’s Child Safeguarding policy should:
•
•
•
•
•
•
•

Demonstrate your organisation’s commitment to the safety and wellbeing ofChildren.
Identify to leaders, staff and volunteers the actions required and both individualand collective responsibilities to prevent harm and keep Children safe.
Promote and protect the rights of Children.
Clarify the roles and responsibilities in relation to recognising and responding toChild Abuse.
Refer to relevant legislative requirements and to the organisation’s other policies,
procedures and guidelines for keeping Children safe.
Be specific to the size, nature and risks of your organisation and the services/programmes it provides to Children.
Be easy for people to access and understand.

In developing a Child Safeguarding policy or any best practices, each Member Association
and Regional Association shall be solely responsible for all matters concerning thedevelopment, implementation and enforcement of their respective policies and practices.

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