Safeguarding Children and Young People Policy

For this policy, a child is anyone under the age of 18. Safeguarding is everyone's responsibility. A concern does not need to be proved before it is raised.

1. Our Commitment

We aim to make every interaction with Study With FM safe, respectful and appropriate to the child's age and circumstances. Children and young people should be:

• treated with dignity, kindness and respect;
• listened to and taken seriously;
• able to ask questions or raise concerns without fear;
• protected from abuse, neglect, exploitation and inappropriate behaviour;
• given information they can understand, where possible;
• supported with consideration for disability, special educational needs and other individual circumstances; and
• treated fairly and without unlawful discrimination.

We work with parents and guardians wherever appropriate, while recognising that protecting a child may sometimes require action without first involving a parent or guardian.

2. Who We Are

Study With FM operates through separate legal entities in the United Kingdom and Nigeria. In Iran, one local contact handles initial student enquiries and referrals; the other members of our Iran-facing team are based in the United Kingdom.

United Kingdom

STUDY WITH FM LTD, trading as Study With FM Company number: 11417586 Registered office: 7 Westmoreland House, Cumberland Park, Scrubs Lane, London, England, NW10 6RE, United Kingdom

Nigeria

Study With FM Global Limited RC number: 7602429 Registered address: No. 25, Aare Avenue, New Bodija, Ibadan, Oyo State, Nigeria

Study With FM Global Limited is a separate Nigerian legal entity. Each entity must meet the safeguarding obligations applicable to the activities it carries out.

Iran

Our only contact based in Iran is Hamid Shafiee, who receives initial education enquiries, communicates primarily with parents or guardians, and passes relevant referral information to STUDY WITH FM LTD in the United Kingdom. The UK-based team handles subsequent education guidance, application coordination and related support. Other colleagues presented on the website as part of our Iran-facing team are based in the UK. The Tehran address is a contact point only, not a staffed business office or a walk-in branch.

Hamid does not collect payments from students or families, receive university commissions or handle payments between Iran and the United Kingdom. Students and families do not pay Study With FM for its Iranian student-recruitment and referral service; where applicable, Study With FM receives commissions from universities. This does not describe the pricing of separately agreed services offered in other markets.

Hamid must take any child welfare or safeguarding concern encountered during initial enquiries seriously, pass relevant information promptly to the Study With FM Safeguarding Lead or appropriate alternative contact, and take any immediate protective action required under applicable local law. Safeguarding information should be collected and shared only where necessary and through appropriate secure channels.

3. Safeguarding Contacts and Reporting Concerns

Study With FM Safeguarding Lead: Mahin Shafiei Email: coordinator@studywithfm.com UK telephone: +44 7557 271171

Mahin oversees safeguarding matters relating to Study With FM services, receives concerns, supports appropriate action and coordinates with relevant authorities and organisations when necessary.

Alternative Safeguarding Contact: Hamid Shafiee Role: Iran Enquiries Contact and IT Manager Email: studywithfm@gmail.com

Hamid has accepted the alternative safeguarding role and can access this contact address independently of Mahin. If your concern involves Mahin, contact Hamid directly rather than reporting it only to Mahin.

Nigeria Safeguarding Contact: Anthony Study With FM Nigeria team Email: studywithfm@gmail.com

Iran Safeguarding Contact: Hamid Shafiee Email: studywithfm@gmail.com

Concerns identified by Hamid during initial enquiries in Iran should normally be referred to Mahin. If a concern involves Mahin, an appropriate external safeguarding authority may also be contacted directly. No internal reporting step should delay immediate action needed to protect a child. If your concern involves Hamid, contact Mahin instead. Where the safety or independence of an internal reporting route is in doubt, contact the relevant police or child-protection authority directly. In an emergency, contact local emergency services first.

4. Scope of This Policy

This policy applies to directors, staff, contractors, representatives and others acting for Study With FM in the United Kingdom, Nigeria or Iran when their work involves children, young people or safeguarding information.

Study With FM's services may include:

• education consultations and individual guidance;
• school, university and other education applications;
• international-student and boarding-school support;
• agreed welfare check-ins or school visits;
• airport collection, arranged transport or accompaniment;
• arranging educational guardianship or, in limited cases, providing agreed guardianship support directly;
• events attended by children; and
• communication with students, parents, guardians, schools and other relevant organisations.

Hamid's Iran-based role is limited to initial enquiries, recruitment and referrals, primarily through communication with parents or guardians. He does not provide the subsequent case management, welfare visits, transport or guardianship services described above; those are handled by the UK team or relevant approved providers, according to the agreed service. Hamid must nevertheless follow appropriate safeguarding and confidentiality practices if he receives information suggesting that a child is at risk.

Study With FM does not ordinarily supervise trips or summer camps run independently by schools or other providers unless a separate arrangement expressly assigns that responsibility to us.

5. Our Safeguarding Principles

The child's welfare comes first. Decisions affecting a child should take account of their safety, wishes, feelings, age, maturity and circumstances.

Children must be heard. We take what children tell us seriously, including concerns that may initially seem uncertain or incomplete.

Parents and guardians should normally be involved. We work with them where appropriate, but not where doing so could increase risk, compromise a referral or delay necessary protection.

Concerns require action. Nobody acting for Study With FM should ignore, minimise, conceal or unnecessarily delay reporting a genuine concern.

Confidentiality has limits. We handle sensitive information carefully but cannot promise complete secrecy where disclosure may be needed to protect a child or another person.

Information sharing must be necessary and proportionate. Relevant information should be shared securely with appropriate people or bodies where there is a lawful reason to do so.

6. What Counts as a Safeguarding Concern?

A concern may involve physical, sexual or emotional abuse; neglect; domestic abuse; grooming; sexual or criminal exploitation; trafficking; online abuse; bullying or cyberbullying; harmful behaviour between children; coercion; forced marriage; female genital mutilation; so-called honour-based abuse; discriminatory abuse; radicalisation or extremist exploitation; unsafe accommodation or care; inappropriate adult–child relationships; or breaches of professional boundaries.

A child's distress, isolation or other serious welfare concern may also require safeguarding attention, even if there is no allegation of abuse. You do not need evidence that abuse has occurred to report a concern.

7. One-to-One Education Consultations

Study With FM may arrange individual consultations with a child when appropriate. A parent or guardian should ordinarily know the consultation is taking place, although they do not always need to participate throughout.

In these consultations:

• the purpose, planned time and relevant participants should be clear;
• the child's wishes, comfort and understanding should be considered;
• approved professional communication channels should be used;
• appropriate boundaries must be maintained;
• a child must not be recorded without appropriate permission; and
• any safeguarding concern must be acted on and reported appropriately.

Where parental or guardian agreement is given verbally, the agreement should be recorded, including who gave it, when and what was agreed.

8. In-Person Meetings and Welfare Visits

Study With FM does not ordinarily arrange isolated one-to-one meetings with a child without a parent, guardian or another appropriate responsible adult present.

A welfare visit may occasionally be appropriate, for example where a parent requests a check-in or a boarding student is distressed, isolated or struggling to settle. Such visits should have a clear purpose, take place in a suitable setting and respect the child's wishes and safety.

Parents or guardians and, where relevant, the school should ordinarily be informed. Agreed arrangements should be recorded, and written parental or guardian confirmation is preferred for planned unaccompanied visits. Staff must maintain professional boundaries, avoid unnecessary secrecy and report any concern arising during the visit.

9. Airport Collection, Transport and Accompaniment

Study With FM may help arrange transport for a child with a parent, guardian, school or transport provider. Our representatives do not ordinarily act as the child's driver. Where agreed, a representative may accompany an arranged driver and student, for example if the student needs additional reassurance.

Arrangements should identify the child's destination, responsible adults, provider and emergency contacts. A parent or guardian should ordinarily be informed, planned journeys should be confirmed in writing where practicable, and safe arrival or handover should be confirmed where appropriate.

Unauthorised journey changes, unsafe arrangements and breaches of professional boundaries are not acceptable. Any welfare or safeguarding incident must be documented and reported.

10. Boarding-School Visits and Student Welfare

Study With FM may visit a boarding-school student when appropriately requested or agreed with the family or school, including where the student feels lonely, distressed or unable to settle.

The school and parent or guardian should normally know about the visit. Our representatives must respect the school's safeguarding rules and should not take over responsibilities belonging to its staff or designated safeguarding lead. Significant concerns must be referred through the appropriate safeguarding route, rather than investigated independently by Study With FM.

11. Educational Guardianship

Study With FM may help families arrange educational guardianship through an external provider. In limited circumstances, we may agree to provide particular educational guardianship support ourselves.

Any direct arrangement must be recorded in a separate written agreement identifying its scope, duration, responsible people, parental authority, relevant school requirements, emergency contacts, safeguarding arrangements and limitations.

Where an external provider is involved, appropriate enquiries should be made about its suitability, safeguarding arrangements, relevant checks and any accreditation or school approval.

Educational guardianship does not automatically transfer legal parental responsibility to Study With FM or a third-party provider. Any arrangement involving legal guardianship or parental responsibility requires its own lawful basis and documentation.

12. Events

Study With FM may organise, attend or support education-related events involving children. Safeguarding arrangements should reflect the ages of participants, the venue, the activity, the adults present and foreseeable risks.

If another organisation runs the event, it may be primarily responsible for its safeguarding arrangements. Study With FM representatives must nevertheless respond appropriately to any concern they observe or receive.

13. Professional Boundaries

Everyone acting for Study With FM in contact with a child must behave professionally. They must not:

• enter into a sexual or romantic relationship with a child;
• engage in sexualised messages, comments or conduct;
• request, share or keep sexual or intimate images involving a child;
• threaten, intimidate, humiliate, manipulate or discriminate against a child;
• exploit the child or encourage secrecy about inappropriate contact;
• maintain unnecessary secret personal contact or arrange unauthorised meetings;
• use disappearing messages to conceal professional contact;
• arrange unauthorised transport or unsafe accommodation;
• supply alcohol, illegal drugs or other inappropriate substances; or
• engage in unnecessary or unsafe physical contact.

Necessary first aid, practical assistance or appropriate reassurance may sometimes involve physical contact. Any such contact must be proportionate, respectful and appropriate to the circumstances.

14. Digital Communication and Online Safety

Communication with children must remain relevant to the service and professional in tone. Staff and representatives should use approved business channels, communicate at appropriate times and involve parents or guardians where appropriate.

Unnecessary personal social-media connections, secret recordings and the misuse of disappearing messages are not acceptable. Important professional communications should be documented when appropriate, and any relevant messages should be preserved if a safeguarding concern arises.

Online abuse, grooming, coercion, bullying and worrying disclosures must be treated as seriously as concerns raised in person.

15. Photographs, Videos, Testimonials and Public Content

We may publish student photographs, videos, testimonials, success stories or case studies only where the relevant permissions have been obtained.

Where a child is identifiable, this normally requires appropriate parent or guardian consent and consideration of the child's own wishes and understanding. Permission for a quotation, photograph, video, audio recording or other promotional use should be specific to the material and intended use.

We must avoid unnecessary disclosure of identifying details, health or disability information, special educational needs, welfare matters or safeguarding concerns. A child's vulnerable circumstances must not be used for promotion simply because they make a compelling story.

Further information is available in our Privacy Policy.

16. Responding to a Disclosure or Concern

When a child says they have been harmed or feel unsafe, the person receiving the information should:

1. Listen calmly and take the child seriously.
2. Avoid blame, disbelief and unnecessary or leading questions.
3. Explain, in an age-appropriate way, that information may need to be shared to help keep them safe.
4. Never promise absolute secrecy.
5. Make a prompt, factual record, using the child's own words where important.
6. Report the concern without unnecessary delay to the appropriate safeguarding contact.
7. Seek immediate external help when the child may be in danger.

Study With FM personnel, including Hamid when receiving initial enquiries in Iran, must not try to investigate suspected abuse themselves. Their responsibility at this stage is to protect, record and refer the concern to the appropriate person or authority.

17. Immediate Danger and External Safeguarding Help

If a child is in immediate danger, contact the local emergency services. Do not wait for an internal response.

United Kingdom

• Emergency services / police: 999
• Childline (children and young people): 0800 1111
• NSPCC Helpline (adults worried about a child): 0808 800 5000

You may also contact the relevant local authority children's social care service or police. Allegations about adults working with children may need to be referred to the Local Authority Designated Officer (LADO) or another relevant authority.

Nigeria

• National emergency number: 112

Emergency-number availability and response arrangements may vary by location. Where necessary, contact the local police, emergency services, child-welfare services or appropriate state child-protection authority directly. In Oyo State, local child-protection and welfare referral services may be relevant.

Iran

• Police: 110
• State Welfare Organization Social Emergency Hotline: 123

The social emergency service can receive concerns about a child being harmed or at risk. Appropriate local protective action should not be delayed while a concern is escalated to Study With FM.

18. Information Sharing and Confidentiality

Safeguarding information should be treated as sensitive and shared only where necessary, proportionate and lawful. Data-protection obligations should not be used as a blanket reason to withhold information where disclosure is necessary and lawful to protect a child. Consent is not always the appropriate or required basis for safeguarding disclosures.

Where information is shared, the responsible person should consider the child's safety, any risk from informing a parent or guardian, the lawful basis for sharing, the minimum necessary information and an appropriate secure method. The decision, recipient and reasons should be recorded.

Where a concern arises in Iran, relevant information may need to be passed to STUDY WITH FM LTD and/or an appropriate local safeguarding authority, subject to the law and the child's safety. Cross-border handling of safeguarding information must be consistent with applicable data-protection requirements and our Privacy Policy.

19. Safeguarding Records

Safeguarding records must be factual, dated, clear, confidential and appropriately protected against unauthorised access. Depending on the circumstances, they should record the concern, what the child said, immediate risks, decisions, actions, parental involvement, information shared, referrals and follow-up.

Safeguarding records should not exist only in informal messages or WhatsApp conversations. They should be stored securely and kept separate from, or clearly distinguished within, ordinary client files, with access limited to those who need it for legitimate safeguarding purposes.

Retention requirements for safeguarding material may differ from those for ordinary client enquiries. The appropriate period depends on relevant legal, safeguarding and evidential considerations; this policy does not set an automatic fixed retention period for every safeguarding record.

20. Safer Recruitment, Vetting and Suitability

Appropriate suitability checks depend on the person's role and level of contact with children. These may include identity and reference checks, review of relevant experience and work history, lawful background or safeguarding checks, role-specific induction and reassessment when duties change.

United Kingdom

The type of Disclosure and Barring Service (DBS) check, if any, must be determined for each role under the applicable eligibility rules. Some activities involving regular teaching, care, supervision or relevant guidance to children may be regulated activity, depending on the circumstances and frequency. Since 1 September 2026, the former supervision exemption no longer applies to relevant regulated activity with children in England and Wales. This does not mean every child-facing role is eligible for the same check.

Nigeria

Study With FM Global Limited must consider suitable identity, reference, suitability and legally available background checks for relevant roles, taking account of Nigerian and applicable state requirements.

Iran

Appropriate role-specific suitability and safeguarding measures apply to our sole Iran-based contact where he encounters children or sensitive safeguarding information. Relevant local requirements must be considered; UK DBS terminology does not imply that an equivalent check exists in Iran.

21. Safeguarding Training

Relevant Study With FM personnel receive safeguarding instruction and training appropriate to their roles. This includes relevant personnel in the UK and Nigeria and Hamid in his role receiving initial enquiries and referrals in Iran.

Training should cover recognising possible abuse and neglect, responding to disclosures, reporting and escalation, emergency action, professional boundaries, one-to-one contact, online safety, information sharing, safeguarding records and allegations about adults. Completion and refresher arrangements should be documented and reviewed as responsibilities change.

22. Concerns or Allegations About Adults

Any safeguarding concern involving a director, employee, contractor or representative, including someone acting for Study With FM in Iran, must be taken seriously. This includes suspected harm, exploitation, inappropriate contact, serious boundary violations or behaviour indicating a risk to children.

Report concerns promptly to Mahin or the alternative safeguarding contact. Where a concern involves Mahin, report it to Hamid or directly to an appropriate external authority. Where a concern involves Hamid, contact Mahin or an external authority. Allegations should be handled fairly and confidentially without assuming they are either proven or unfounded.

Where necessary, an adult's contact with children may be restricted while the matter is assessed. Depending on the circumstances and applicable law, referrals may be needed to police, children's social care, the LADO, the DBS or relevant Nigerian or Iranian authorities.

23. Whistleblowing and Escalation

Staff and representatives should be able to raise genuine safeguarding concerns without improper retaliation. A concern may need to be escalated where someone believes it has been ignored, procedures have not been followed, a child remains at risk or management has failed to act appropriately.

Anyone may contact an appropriate external safeguarding authority directly where necessary. Internal reporting arrangements must never prevent urgent protective action or an appropriate independent referral.

24. Working With Schools and Other Providers

We work with schools, universities, accommodation providers, transport companies, guardianship organisations and other independent providers. Each provider remains responsible for its own legal and safeguarding duties.

When appropriate to the service and level of risk, we seek information about a provider's identity, safeguarding arrangements and contacts, staff checks, emergency plans, insurance, complaints process and relevant approvals or accreditation. We should not knowingly rely on a provider where serious safeguarding or suitability concerns remain unresolved.

We cooperate with schools' safeguarding arrangements and refer concerns to the appropriate person or authority rather than assuming responsibility for an investigation ourselves.

25. Legal and Safeguarding Framework

Study With FM's safeguarding approach takes account of relevant laws and guidance in the countries in which the service or referral activity takes place. Which legal duties apply depends on the entity, its role and the circumstances.

England

Relevant frameworks may include the Children Act 1989, Children Act 2004, Working Together to Safeguard Children 2026, the Safeguarding Vulnerable Groups Act 2006, current DBS requirements, and applicable data-protection law.

Keeping Children Safe in Education 2026 sets duties for schools and colleges; it does not automatically make Study With FM subject to every duty imposed on those institutions. Its relevant safeguarding practices may nevertheless inform how we work with them. Likewise, any specific statutory information-sharing duty applies only where the law brings a particular organisation or activity within scope.

Nigeria

Relevant protections may include the Child Rights Act 2003, Oyo State Child Rights Law 2006, the Nigeria Data Protection Act 2023 and other applicable federal or state safeguarding requirements.

Iran

Relevant protections include Iran's Law on Protection of Children and Adolescents (2020) and applicable rules on child welfare, reporting and information handling. The legal duties applying to initial referral activity in Iran depend on the actual roles and arrangements involved.

26. Review of This Policy

We review this policy periodically and when a significant change affects safeguarding law or guidance, our services, children's contact arrangements, guardianship, transport, welfare visits, staff vetting, reporting contacts, Iran-based referral arrangements or the handling of safeguarding information.

A serious incident or an identified weakness in safeguarding arrangements may also require an earlier review.

27. Contact Us

For a safeguarding concern or question about this policy, use the relevant contact below. In an immediate emergency, contact local emergency services before using an internal contact route.

Safeguarding Lead

Mahin Shafiei Email: coordinator@studywithfm.com UK telephone: +44 7557 271171

Alternative Safeguarding Contact and Iran Contact

Hamid Shafiee — Iran Enquiries Contact and IT Manager Email: studywithfm@gmail.com

Use this route if the concern involves Mahin or independent internal escalation is needed.

Nigeria Safeguarding Contact

Anthony — Study With FM Nigeria team Email: studywithfm@gmail.com

Company Details

United Kingdom: STUDY WITH FM LTD, company number 11417586, 7 Westmoreland House, Cumberland Park, Scrubs Lane, London, England, NW10 6RE, United Kingdom.

Nigeria: Study With FM Global Limited, RC number 7602429, No. 25, Aare Avenue, New Bodija, Ibadan, Oyo State, Nigeria.

Iran: Hamid Shafiee is our sole Iran-based contact in Tehran. He forwards relevant initial enquiry and referral information to STUDY WITH FM LTD in the UK and does not collect client payments. The Tehran address is a contact point, not a staffed or walk-in business office; the other Iran-facing team members work from the United Kingdom.

Privacy and data-protection enquiries: coordinator@studywithfm.com.

Related information: Privacy Policy · Terms and Conditions · Contact Us.