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Safeguarding

The Welsh Government is working to ensure that safeguarding is a central consideration in the systems, policy and advice being developed to support the arrival of people from Ukraine. We know this is also a priority for local authorities and relevant safeguarding partners.

We have a shared duty of care to ensure that people arriving in Wales from Ukraine are protected from the risk of abuse, harm or neglect. We also have responsibilities to safeguard people in households where people from Ukraine will live.

There are a number of different ways in which people from Ukraine and people in Wales will come to be living in a single household. This guidance is about the individual UK Government sponsoring scheme via Homes for Ukraine. It will be reviewed and updated regularly.

Overall, local authorities are required to carry out their existing statutory safeguarding functions in relation to this individual sponsoring scheme, as they would for any other population in Wales. Advice on identifying and responding to safeguarding concerns about children or adults at risk (as defined in the Social Services and Well-being (Wales) Act 2014) is explained in the Wales Safeguarding Procedures).

Additional advice and guidance

A range of UK Government security checks are carried out on people from Ukraine applying for a Visa. These checks must be passed in order for a Visa to be issued.

The same level and type of checks will be carried out by the UK Government on people from Wales aged over 18, applying to become hosts.

Local authorities should work with their statutory safeguarding partners, such as the police, to establish whether there is any information held my agencies to suggest that individuals in the host address are not suitable to act as hosts. In this way decisions that some individuals cannot act as hosts can be made by the local authority in advance of the Disclosure and Barring Service (DBS) checking process.

Local authorities will be expected to facilitate DBS checks on people from Wales applying to become hosts. Wherever possible, these should be completed before any people from Ukraine start living in a host’s household. However, this may not always be achievable.

If a match is made which involves a person from Ukraine who is a child (i.e., under 18), an Enhanced DBS check will be undertaken on all members of the host household who are aged 16+.  The enhanced check (including a check of the children’s barred list) is needed due to the level of safeguarding risk within households where the sponsor and/or other individuals aged 16+ may provide care or supervision of a child guest under the scheme on more than 3 occasions in a 30-day period, or overnight, bringing the sponsors and other adults into regulated activity (SVGA 2006, Sch4, Part1). This includes a check of the children’s barred list. However, this does not apply if the child from Ukraine is related to the host sponsor. In this instance only a Basic DBS check is required.

If your local authority decides that an adult from Ukraine requires additional support, due to age, illness or because they are disabled and it is proposed that an adult (16+) member of the sponsoring household provides them with this support, then you may ask for an Enhanced DBS check (including a check of the adults’ barred list) to be undertaken on any members of the sponsor’s household who is proposed to provide that support. Existing guidance regarding Regulated Activity with Adults and Regulated Activity with Children can support the assessment of the eligibility of individuals for this level of check.

In all other cases, including where there is a family relationship between the sponsor and the people from Ukraine, a Basic DBS check should be undertaken on all members of the host household who are aged 16+.

DBS checks and associated costs can be paid for from the £10,500 tariff UK Government is providing to local authorities via the Welsh Government for each person from the Ukraine hosted in the UK.

Further information on DBS checks is set out in the Welsh Government’s letter to local authority Chief Executives and other statutory partners dated 1 April 2022.

We will be providing further specific advice in relation to what local authorities can do if safeguarding checks reveal a potential host to be unsuitable as a result of a safeguarding concern.

Information for hosts and people from the Ukraine

In undertaking safeguarding checks, local authorities are asked to request that hosts complete the online safeguarding training module.

The Welsh Government has published a guide for sponsors that includes information for hosts on the need to report any safeguarding concerns and how to do so.

Via the Welsh Government’s Sanctuary website, people from Ukraine arriving in Wales will receive information about life in Wales including about how to report any safeguarding concerns and that it is appropriate to do so. It currently contains initial information for people from Ukraine which will be added to over time.

A Helpline which is open 9am-5pm, 7 days a week, has been established for both hosts and people from Ukraine. Freephone with the UK: 0808 175 1508. From outside the UK: +44(0)20 4542 5671.

We will expect Helpline staff to complete the online safeguarding training module.

We will provide guidance to the Helpline service on responding to and reporting any safeguarding concerns shared with Helpline staff.

Safeguarding home visits to host households

Following the placement of people from Ukraine in to host households and to confirm that there are no safeguarding or wellbeing concerns about people from Ukraine or people already residing in the host household, we will work with local authorities to agree at what points and at what frequency in-person visits should be made. As a guide, it is suggested that a home visit is scheduled for the first week of placement and then the third week of placement. If no concerns are established following the first home visit, then no further visits need be made. Local authorities will need to decide whether additional visits are necessary on a case by case basis. Local authorities are recommended to provide information about their services, to host households.

Unless specific safeguarding and/or care and support needs are identified then home visits will not need to be undertaken by qualified staff/social workers. However, staff undertaking home visits should have undertaken relevant safeguarding training. As a minimum, this online safeguarding training should be completed.

Corporate safeguarding: emergency/temporary accommodation and longer term housing for people from Ukraine

We will work with local authorities to ensure that decisions about the suitability of emergency / temporary accommodation and longer term housing for people from Ukraine, include safeguarding considerations.

Responding to safeguarding concerns

We will work with local authorities to understand and, where possible, assist with any emerging, additional demands on social services as a result of these arrangements and what further support may be required, including access to interpretation / translation services.

We will be providing further specific advice in relation to what local authorities can do if safeguarding concerns emerge during a hosting arrangement.

Peer support

The Welsh Government will work with the Wales Strategic Migration Partnership and the Welsh Local Government Authority (WLGA) to establish whether a community of practice-type arrangement would be helpful for local authority staff in their work to support people from Ukraine.

Modern slavery

Modern slavery is an umbrella term that covers human trafficking, slavery, and forced labour. The main legislation is the Modern Slavery Act 2015. Whilst modern slavery is a reserved matter, the Welsh Government works with partners in Wales, the Home Office, and other governmental and non-governmental agencies to tackle this crime and support victims and survivors.

Modern slavery takes place internationally, including across communities in Wales. There were 479 Welsh referrals for suspected victims of modern slavery in 2021. Over half of those referred were children. In Wales, around half of referrals are for non-UK nationals from countries such as Albania, Sudan, and Eritrea.

The Welsh Government recognises Ukrainian refugees are at risk of modern slavery. This includes Ukrainians who are internally displaced, those who have travelled to neighbouring countries, and those who have arrived or are currently transiting to the UK. We have raised these concerns with the UK Government, are monitoring the situation closely, and are engaging with relevant partner agencies concerning these issues.

Local Authority staff engaging with Ukrainians should have awareness of modern slavery. There are many free resources on modern slavery, including e-learning courses for First Responders and on child victims of modern slavery. The Home Office has produced a Modern Slavery Awareness Booklet.

Accessible and multilingual information and resources on modern slavery are also available at online sources including:

Ukrainian refugees are at risk of the 4 main types of modern slavery as identified by the Home Office:

  • Labour exploitation: where victims are forced to work in a highly exploitative situation in which they cannot freely leave for other employment or exercise choice.
  • Criminal exploitation: where victims are exploited and coerced to commit a crime for someone else’s gain. An example of criminal exploitation is the transportation and cultivation of drugs
  • Sexual exploitation: where victims are coerced into sex work or sexually abusive situations. This includes child sexual exploitation.
  • Domestic servitude:which typically involves victims working in a private family home where they are ill-treated, humiliated, subjected to unbearable conditions or working hours or made to work for little or no pay.

Local Authorities in England and Wales are required to follow the Statutory Guidance for England and Wales under section 49 of the Modern Slavery Act 2015. Local Authorities in Wales should also follow the Wales Modern Slavery Safeguarding Pathway.

There are many different signs of modern slavery that depend on the type of exploitation. Unseen UK, who run the Modern Slavery and Exploitation Helpline have produced information on signs of modern slavery to look out for.

Read Information about reporting modern slavery. In Wales, a Multi-Agency Risk Assessment Conference (MARAC) approach is adopted to refer adult victims into support and appropriate MARAC guidance should be followed. Complete the online form to make a National Referral Mechanism (NRM) referral.

Informed consent is required for an adult to be referred into the NRM. Where an adult does not consent to be referred, a Duty to Notify referral should be completed using the same online form.

Following referral to the NRM, a decision should be made within five days by the Home Office competent authority on whether there are reasonable grounds to suspect the person referred is a victim of modern slavery. This is called a Reasonable Grounds (RG) decision. Following a positive RG decision, the potential victim will enter a recovery period until a Conclusive Grounds (CG) decision is made.

Adults and their dependents should receive support through the recovery period. This includes financial support, medical support, accommodation, translation and interpretation services, and access to legal representation. Bawso are the Modern Slavery Victim Care and Coordination (MSVCC) service provider in Wales.

Children who are suspected victims of modern slavery must always be referred to the NRM and do not have to provide consent. In addition, children should also be referred to the Independent Child Trafficking Guardianship (ICTG) service. The ICTG service, operated by Barnardo’s, operates nationally in Wales. This service provides various practical, psychological, and emotional specialist services to children. Children can be referred using this online form. This is in addition to NRM and safeguarding referrals which must also be made.

The Gangmasters and Labour Abuse Authority (GLAA) have produced ‘Know Your Rights’ posters about exploitation in English and Ukrainian.

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