TABLE OF CONTENTS
1.1 Chennaiyin F.C. Sports Private Limited (“Company” / “We” / ”Our”) owns the football team, Chennaiyin F.C. (“Club”). The Club has teams in various age categories and the Company also engages in grassroots development activities (“Programs”).
1.2 The Company is committed to ensuring and protecting the integrity of the sport of football and promoting the safety and well-being of all its members and players representing the Club. This Code of Conduct (the “Code of Conduct”), which inter alia includes the Child Protection and Welfare Policy, is adopted and implemented as a part of all Programs, including the youth teams representing the Club, run under the auspices of the Company. It is clarified that this Code of Conduct is designed solely to function as a supplementary framework to support and enhance the protections afforded under Protection of Children from Sexual Offences Act 2012 (“POCSO”). This Code of Conduct is neither intended to replace nor supersede the mandates of POCSO. In the event of any inconsistency or conflict between the provisions of this Code of Conduct and those outlined in POCSO, the provisions of POCSO shall govern and take precedence. At all times, for all events under the purview of POCSO, the first point of complaint / reporting of an offense shall be made as per the provisions of POCSO. In the event an offense falls outside the purview of POCSO, however is addressed under this Code of Conduct or is otherwise brought to the attention of the Club, the Club reserves the right to take any action it considers appropriate at its sole discretion. This discretionary authority allows the Club to respond effectively to any conduct that may compromise the welfare and safety of children, ensuring a comprehensive approach to child protection beyond statutory requirements.
1.1 The purpose of this Code of Conduct is to:
1.1.1 create an environment within the Program that is both ‘child safe’ and ‘child friendly’ when it comes to protection against all types of abuse and the safety of the environment;
1.1.2 ensure prevention of abuse;
1.1.3 address issues relating to recruitment and training of personnel who work with children in the Programs;
1.1.4 provide guidelines for appropriate and inappropriate behaviour/attitude;
1.1.5 provide guidelines for communications;
1.1.6 aid in recognising, reporting and reacting to allegations of abuse; and
1.1.7 enlist the ramifications of misconduct for those who disregard or fail to follow the Code of Conduct.
1.2 This Code of Conduct encompasses:
1.2.1 health and safety measures to be put in place;
1.2.2 disciplinary measures to be imposed;
1.2.3 physical harm;
1.2.4 working with information about children,
1.2.5 proper recruitment and managerial procedures, and
1.2.6 the extent of measures put in place in the event of misconduct.
1.3 This Code of Conduct prevents and prohibits:
a. Abuse, within the context of this Code of Conduct, is the mistreatment of a child by an adult that has harmed, is harming or is likely to harm, endanger or put at risk that Child’s physical or emotional health, development or wellbeing.
b. Abuse may take several forms. Abuse includes physical harm, emotional or psychological harm or sexual molestation or exploitation.
c. Types of Abuse:
(i) neglect;
(ii) harassment;
(iii) inappropriate gestures;
(iv) emotional abuse;
(v) bullying;
(vi) physical abuse; and
(vii) sexual abuse.
d. Occurrence of Abuse:
Abuse against another may take place anywhere, and that includes on the field and/or in the locker room areas. Coaches/ staff members may unintentionally be engaged in abusive behaviors. Some signs of abuse include:
(i) unexplained bruising or injuries;
(ii) sudden changes in behavior;
(iii) something someone has said;
(iv) a change in the participant/player that is observed over a long period of time (eg. losing weight, eating excessively, becoming increasingly unhygienic).
a. Bullying is the use of aggressive behavior with the intention of hurting another person either physically or emotionally. We acknowledge and endorse the identification of bullying as a category of abuse. Bullying of any kind is not acceptable at the Company. If bullying does occur, a player, coach, referee, parent and/or guardian should be able to report incidents and also know that incidents will be dealt with promptly.
b. Types of bullying:
(i) Verbal: name-calling, sarcasm, spreading rumors and teasing;
(ii) Emotional: being unfriendly, excluding, tormenting;
(iii) Physical: pushing, kicking, hitting, punching or any use of violence;
(iv) Racist/ Casteist: racial/cast related taunts or gestures;
(v) Sexual: unwanted physical contact or sexually abusive comments;
(vi) Cyber-bullying: threats by e-mail (other internet chatrooms), text message and/or calls or the misuse of associated technology, such as cameras – both still and videos.
a. Grooming is when an individual builds an emotional connection with a child to gain their trust for the purposes of abuse or exploitation.
b. Grooming may include:
(i) offering advice or understanding;
(ii) buying gifts;
(iii) giving a child individual attention;
(iv) using professional position or reputation;
(v) taking someone on non-Company related trips, outings, or holidays;
(vi) using secrets and intimidation to control children.
a. Neglect takes place if an adult with responsibility for the care or supervision of a child fails to meet the child’s basic physical and/or psychological needs, e.g. food warmth, clothing, emotional needs such as attention or supervision and in case of a parent or legal guardian parental affection, which is likely to result in the serious impairment of the child’s health or development.
b. Indicators of neglect may include:
(i) Failure by parents or carers to meet the basic essential needs e.g. adequate food, clothes, warmth, hygiene and medical care;
(ii) A child seen to be listless, apathetic and irresponsive with no apparent medical cause;
(iii) Failure of child to grow within normal expected pattern, with accompanying weight loss;
(iv) Child thrives away from home environment;
(v) Child frequently absent from school;
(vi) Child left with adults who are intoxicated or violent; and/or
(vii) Child abandoned or left alone for excessive periods.
a. Actions, behaviors, or practices that fall below the expected standards of care and may result in harm or risk of harm to a child. Poor practices may include inadequate supervision, failure to follow child protection policies and procedures, lack of awareness or understanding of child welfare issues, and failure to respond appropriately to concerns raised about a child’s welfare. Identifying and addressing poor practices is essential to maintaining a safe and nurturing environment for children.
1.5 Further, the Company is issuing and adopting this Code of Conduct to provide for an effective means to uphold both the spirit as well as the laws of the game of football and to ensure that all participants and the members of the Programs (including but not limited to players, parents/legal guardians of children, coaches, physiotherapists, team officials, referees) conduct themselves in an appropriate manner and restrain from conducting themselves in a manner that may be construed as a violation of this Code of Conduct.
1.6 This Code of Conduct shall apply to all persons managing, delivering or engaging with the Club in any and/or all its Programs, including but not limited to players, coaches, parents/legal guardians, all the other employees of the Club (such as physiotherapist, analysts, medical personnel, scouts, groundskeeper, facility managers, administrators, directors, security personnel etc.), and third parties (including but not limited to commercial partners, license holders, contractors, consultants and the employees of such third parties).
1.7 Where the Company enters a commercial or contractual relationship with third parties (including but not limited to commercial partners, license holders, contractors, and consultants), those organizations and/or individuals are also required to uphold the requirements, principles, procedures and/or protocols presented in this Code of Conduct.
1.8 This Code of Conduct shall be integrated with other existing policies of the Club to ensure a cohesive approach to safeguarding children.
1.9 This Code of Conduct shall align with the Club’s core values of respect, fairness and inclusivity. This alignment shall reinforce the Club’s stance against all forms of discrimination and its dedication to fostering a culture of respect and equality.
1.10 All players, coaches, parents/legal guardians, all the other employees of the Club (such as physiotherapist, analysts, medical personnel, scouts, groundskeeper, facility managers, administrators, directors, security personnel etc.) shall receive training on this Code of Conduct and its links to the other existing policies of the Club. This training shall emphasize the importance of understanding and adhering to all relevant policies to ensure the safety and wellbeing of children.
1.11 All Programs (matches, training sessions, workshops) shall be conducted in the true spirit of the game of football and all persons to whom this code is applicable, coaches, captains, players, referees, parents / guardians, shall ensure adherence to this Code of Conduct.
1.12 No player or official shall, during the performance of obligations at the Programs, whether on or off the field of play, engage in conduct unbecoming to the game of football.
1.13 All members, players, parents, team officials etc. agree to protect the spirit of the game of football. The Spirit of the Game involves respect for:
1.13.1 Your opponents;
1.13.2 Your own captain and team;
1.13.3 The role of the referees; and
1.13.4 The game’s traditional values.
1.14 All members, players, parents, team officials etc. shall take utmost care and precautions for the safety and security of the participants of the Programs. Any incidents regarding the conduct of an individual must be reported to the Child Welfare Officer immediately.
1.15 All matters pertaining to improper conduct of this nature shall be dealt by the Management Committee/Disciplinary Committee fairly and expeditiously.
2.1 The Company has a duty to safeguard and promote the welfare of children and to protect them from abuse, and to ensure that the sport of football is played with the spirit of the game.
2.2 The workforce of the Company which includes but is not limited to the players, coaches, parents/legal guardians, and employees shall have the collective responsibility to ensure the safety and welfare of all children engaging in activities provided by the Club. This includes taking the appropriate steps set out in this Code of Conduct where there is suspicions and/or allegations of abuse and/or bullying.
2.3 Where appropriate, the Company shall consult with children and their parents and/or legal guardians to understand their needs, concerns and/or wishes so that these may help shape the Club’s policy, procedure and practice.
2.4 The legislation, rules, regulations and/or guidelines relevant to this Code of Conduct includes but is not limited to the following:
2.4.1 The Juvenile Justice (Care and Protection) Act, 2000;
2.4.2 The Protection of Children from Sexual Offences Act, 2012;
2.4.3 The Prohibition of Child Marriage Act, 2006;
2.4.4 The Child Labour (Prohibition and Regulation) Act, 1986;
2.4.5 National Charter for Children, 2003;
2.4.6 Tamil Nadu State Policy for Children, 2021;
2.4.7 Asian Football Confederation (“AFC”) Child Safeguarding Policy, 2022;
2.4.8 All the rules, regulations and/or guidelines of the All India Football Federation (“AIFF”);
2.4.9 All the rules, regulations and/or guidelines of the Fédération Internationale de Football Association (“FIFA”);
2.4.10 All relevant legislations, rules, regulations and/or guidelines that involves child protection and welfare, and the integrity of football; and
2.4.11 Any and all amendments to the legislations, rules, regulations and/or guidelines hereinabove.
2.5 All employees of the Company are required, should they be a party to a criminal investigation whilst employed, to inform a member of the HR team of the Company as soon as reasonably practicable after such an incident. Failure to do so will result in a breach of this Code of Conduct which may lead to a disciplinary action.
3.1 All players, either through their parents or by themselves, are automatically bound by or required to comply with all of the provisions of the Code of Conduct.
3.2 All players and their parents agree:
3.2.1 that it is their personal responsibility to familiarize themselves with all of the requirements of the Code of Conduct, including what conduct constitutes an offence under this Code of Conduct;
3.2.2 to submit to the exclusive jurisdiction of Management Committee/Disciplinary Committee to hear and determine charges brought pursuant to the Code of Conduct;
3.2.3 not to bring any proceedings, with respect to the violation of the Code of Conduct in any court or other forum.
3.3 Football is a game that owes much of its unique appeal to the fact that it should be played not only within its laws, but also within the spirit of the game. Any action that is seen to abuse this spirit causes injury to the game itself. If any player commits any of the following acts prohibited under this Code of Conduct, he/she shall be deemed to have acted in violation of this Code of Conduct and committed an offence under this Code of Conduct. Thereafter, the Management Committee/ Disciplinary Committee shall have the right to institute appropriate proceedings, through the parents of the players, as per the procedure mentioned in the organization of the Committee document.
3.4 Players shall not abuse football equipment or clothing, ground equipment or fixtures and fittings during coaching/training and/or matches.
3.5 Players and team officials must at all times accept the referee’s decision. Players must not show dissent at the referee’s decision or react in a provocative or disapproving manner towards a referee’s decision during a match such as:
3.5.1 excessive, obvious disappointment with a referee’s decision;
3.5.2 an obvious delay in resuming play;
3.5.3 arguing or entering into a prolonged discussion or argument with the referee about his decision;
3.5.4 shall not intimidate, assault or attempt to intimidate or assault the referee.
3.6 Players shall not use crude or abusive language nor make gestures that are obscene, offensive or insulting during a match;
3.7 Players shall refrain from excessively audible or repetitious swearing;
3.8 Players shall refrain from excessive appealing during a match;
3.9 Players shall refrain from inappropriate and deliberate physical contact between Players in the course of play during a match;
3.10 Players shall refrain from charging or advancing towards the referee in an aggressive manner;
3.11 Players shall refrain from deliberate and malicious distraction or obstruction on the field of play during a match;
3.12 Players shall refrain from throwing a ball (or any other item of football equipment such as a water bottle) at or near another player, official, referee or any other third person in an inappropriate and/or dangerous manner;
3.13 Players shall refrain from using language or gesture(s) that is seriously obscene, seriously offensive or of a seriously insulting nature to another player, official, referee or any other third person;
3.14 Players shall refrain from any attempt to manipulate a match for inappropriate strategic or tactical reasons;
3.15 Players shall refrain from intimidating a referee whether by language or conduct (including gestures) during a match including appealing in an aggressive or threatening manner;
3.16 Players shall refrain from threat of assault on another player, official or any other person (including a spectator) during a match;
3.17 Player shall not conduct himself or behave in any manner that is contrary to the spirit of the game or bring the game into disrepute;
3.18 Players shall refrain from any act of violence at all times;
3.19 Players shall neither make racially abusive comments nor indulge in racially abusive actions against fellow players, officials, members and supporters;
3.20 Players shall not deliberately distract any other player;
3.21 Players shall not indulge into any act of violence on the field of play;
3.22 Players shall report punctually for both, training and matches;
3.23 Players must wear all protective gear / equipment required in all matches for their safety;
3.24 Players must remove any jewellery which they are wearing during the match or the training session;
3.25 No alcohol shall be consumed by players or match officials during the hours of play;
3.26 Players shall adhere to the dressing requirements and present oneself for play in a suitable manner;
3.27 Players shall comply with the conditions of entry of each tournament with regard to clothing and advertising regulations;
3.28 Players shall not engage, directly or indirectly, in match fixing or betting as set out in Appendix A of this Code of Conduct;
3.29 Players shall follow the general responsibilities and procedures laid out in Appendix B.
4.1 Referees shall not make or cause to be made any public announcement or media comment which is detrimental to:
4.1.1 the game of football in general; or
4.1.2 any particular match between teams representing the Club in which any such referee is involved; or
4.1.3 the Programs;
4.2 Referees shall not disclose or comment upon any alleged breach of this Code of Conduct or any hearing, report or decision arising from any such alleged breach unless such disclosure is required under the provisions of this Code of Conduct and/or the applicable law.
4.3 Referees shall not engage, directly or indirectly, in match fixing or betting as set out in Appendix A of this Code of Conduct;
4.4 Referees shall not use or in any way be concerned in the use or distribution of illegal drugs;
4.5 Referees shall at all times observe and comply with the provisions of any regulation of Programs which applies to referees including but not limited to the operational rules of the Programs.
4.6 Referees shall not engage in any conduct which is prejudicial to the interests of the game of football and/or the Programs.
4.7 Referees shall not indulge in any form of abuse and/or bullying.
4.8 Referees shall follow the general responsibilities and procedures laid out in Appendix B.
5.1 Parents / guardians shall encourage their children to learn the laws of the game of football and to play within the spirit of those laws and to ensure compliance of the Code of Conduct.
5.2 Parents / guardians should discourage unfair play and disputes with officials / coaches on and off the field of play, at all times.
5.3 Parents / guardians should guide their child to recognize good performance and not just results and should set a good example by recognizing fair play and by applauding the good performances of all.
5.4 Parents / guardians should inculcate the spirit of true sportsmanship in their children and never punish or belittle a child for losing or making mistakes.
5.5 Parents / guardians should support their child’s involvement and help them to enjoy football and to develop within it and not try to impose their expectations on the child.
5.6 Parents / guardians should and ensure that their children condemn all violence and not question the decision of an official.
5.7 Parents / guardians should never ridicule a player for making a mistake. They should respect their efforts and applaud all good play from both teams.
5.8 Parents / guardians should at all times be friendly and courteous to the opposition – players, managers, coaches, parents and supporters alike.
5.9 Parents / guardians must understand that even if the children are under the direct supervision of the managers/coaches for the Programs, the parents are still at all times responsible for the well-being, safety, security and the compliance by the children of the Code of Conduct.
5.10 Parents shall not engage, directly or indirectly, in match fixing or betting as set out in Appendix A of this Code of Conduct;
5.11 Parents / guardians shall not indulge in any form of abuse and/or bullying.
5.12 Parents / guardians shall follow the general responsibilities and procedures laid out in Appendix B.
6.1 All captains and coaches shall:
6.1.1 Instruct all players to avoid time wasting on the field of play;
6.1.2 Ensure that players conduct themselves in a manner that conforms to the traditional image of the game of football;
6.2 All other members of the Programs including captains, managers, coaches, team officials and match officials shall ensure the following:
6.2.1 shall be dressed appropriately in team uniform comprising of shirt/polo shirt/blouse or trousers/skirt;
6.2.2 Must not coach when match is on or in any manner distract opposing player or disrupt play;
6.2.3 must not delay any match on account of coaching in any form;
6.2.4 must not verbally abuse or intimidate in any form such as shouting making gesture, towards or in any other way distract any spectator, tournament official, technical official, opposing coach or opposing team official, or opposing player;
6.2.5 must not attempt to communicate in any way with opposing players or coaches or team officials;
6.2.6 must not make or attempt to make any unwelcome, abusive or intimidating physical contact in any way with any spectator, tournament official, technical official, opposing players, coaches or team officials;
6.2.7 must not bring the sport into disrepute through media comments, either pre, during, or post tournament that relate to tournament officials, technical officials, opposing coaches or team officials and or players, that are personal in nature, imply bias, or question their integrity;
6.2.8 Respect the rights, dignity and worth of each and every person, and treat each equally within the context of the sport;
6.2.9 Place well-being and safety of the children above all other consideration, including the development of performance;
6.2.10 Develop an appropriate working relationship with each player based on mutual trust and respect;
6.2.11 Not exert undue influence to obtain personal benefit or reward;
6.2.12 Recognize good performance not just match results;
6.2.13 Encourage and guide players to accept responsibility for their own behavior and performance;
6.2.14 Ensure that the activities they direct or advocate are appropriate for the age, maturity, experience and ability of the player(s);
6.2.15 Co-operate fully with other specialists e.g., other coaches/managers, officials, and medical staff;
6.2.16 Promote the positive aspects of the game i.e., sportsmanship and fair play, and never condone violations of the laws of the game, behavior contrary to the spirit of the game or relevant rules and regulations, or the use of prohibited substances or techniques;
6.2.17 Ensure that their actions serve the best interests of the players from both sides;
6.2.18 Ensure the matches / training is conducted in manner that serves the best interests of participants;
6.2.19 Instruct members, players, team officials, parents and spectators of their obligation to behave in a manner that serves the best interest of participants at all times;
6.2.20 Make every effort to remove members, players, team officials, parents and spectators from the venue of the match who are not behaving in a manner that serves the best interests of participants to ensure safety and protection of the participants at all times;
6.2.21 No alcohol shall be consumed by anyone during the hours of play.
6.3 All other members of the Programs including captains, managers, coaches, team officials and match officials shall not engage, directly or indirectly, in match fixing or betting as set out in Appendix A of this Code of Conduct;
6.4 All other members of the Programs including captains, managers, coaches, team officials and match officials shall take utmost care and precautions for the safety and security of the participants;
6.5 All other members of the Programs including captains, managers, coaches, team officials and match officials shall not indulge in any form of abuse and/or bullying.
6.6 All other members of the Programs including captains, managers, coaches, team officials and match officials shall follow the general responsibilities and procedures laid out in Appendix B.
7.1 We aim to ensure safeguarding within this Code of Conduct based on the following principles:
7.1.1 Recognizing the child’s rights and interests;
7.1.2 Zero tolerance towards abuse or harm to children;
7.1.3 Using a risk management approach to prevent the abuse or harm to children;
7.1.4 Ensuring awareness amongst all members of the Programs.
7.2 All members of the Programs working with children or who come in contact with children must adhere to this Code of Conduct, and all the laws, rules and regulations specified in Article 2.4 of this Code of Conduct.
7.3 We believe in a top-down accountability approach when it comes to safeguarding and aim at ensuring that each individual at the Company knows and understands their role, accountability and responsibility towards child safeguarding.
7.4 Reporting mechanism: The Club endeavors to train all members of the Program to recognize, investigate and immediately remove the affected child from a situation which hampers the safety or security of such child, to the best of their abilities. To ensure that concerns related to child safety are addressed promptly and comprehensively, the Club adopts a “reasonable suspicion” threshold for reporting safeguarding concerns to remove ambiguity and reduce underreporting due to perceived lack of evidence.
7.5 All members of the Program are duty bound to report any incident(s), if such members form a reasonable belief that a child is at risk or is being abused and/or neglected. All such incidents can be reported to the following Child Welfare Officer, without any fear of repercussions:
| Name and Designation: | Mr. Senthilkumaran |
| Email Address: | childsafety@chennaiyinfc.com |
| Phone No: | +91 98949 31919 |
7.6 The Child Welfare Officer shall ensure the anonymity of the person(s) reporting any activity relating to child safeguarding. Further, the Child Welfare Officer shall, on a case-to-case basis, report the incidents and/or complaints to the parent(s) and/or guardian(s), the police and the child protection unit in the relevant district. However, all incidents shall be reported to the Management Committee/ Disciplinary Committee.
7.7 Investigation Timelines: To ensure prompt and fair handling of safeguarding concerns, the following timelines shall be adhered to for responding to matters:
7.7.1 Initial Acknowledgment: Within 24 working hours of receiving a report;
7.7.2 Preliminary Assessment: Within 3 working days;
7.7.3 Full Investigation Launch: Within 5 working days;
7.7.4 Interim Safeguarding Measures: Immediately upon assessing risk;
7.7.5 Final Report Submission: Within 60 calendar days of complaint registration.
In the event of any unforeseen delay in meeting the abovementioned timelines, a justification report shall be submitted to the ISOP, which it may, at its’ sole discretion, approve or decline.
7.8 Investigation Protocols:
7.8.1 A standard case intake and tracking system shall be maintained;
7.8.2 Investigations will be trauma-informed, child-centric and confidential;
7.8.3 Children and parents shall be informed of the status and outcome of investigations at all key milestones.
7.8.4 In the event an allegation is of such serious nature that it is considered a criminal offence, the Child Welfare Officer shall inform the parent or legal guardian of the child at the earliest opportunity. Where such an allegation is against the parent or legal guardian of the child, the Child Welfare Officer shall report to the police and the child protection unit in the relevant district at the earliest opportunity.
7.8.5 The Child Welfare Officer shall always respect the right of a child to have their say when a decision that affects them is being taken and will take their views into account, acting in their best interests when a decision is made, especially when a child is at risk of harm or may have come to harm. A child’s parent or legal guardian will also be consulted, and consent shall be obtained before any action is taken unless this may put the child at increased risk of harm. Where a parent or legal guardian is unable to give consent, the Child Welfare Officer will always act in the best interests of the child.
7.8.6 The Child Welfare Officer shall maintain a report of all the incidents reported and the action taken thereunder.
7.8.7 The Child Welfare Officer shall play a proactive role in increasing awareness of respect, poor practice(s), and abuse amongst Club members.
7.9 Resolution mechanism: The Child Welfare Officer shall, while responding to an incident and/or complaint:
7.9.1 Prioritize the safety and wellbeing of the child;
7.9.2 Respond to the immediate risk or harm and mitigate potential risks and harms;
7.9.3 Ensure that individuals find it comfortable to report and/or provide evidence in different ways and mediums.
7.10 Reporting Against Senior Staff and Officers: To ensure impartiality in cases involving senior personnel:
7.10.1 Allegations against senior leadership, including the Child Welfare Officer, must be reported directly to the ISOP (as defined below in Clause 8);
7.10.2 Accused staff shall be placed on administrative leave with confidentiality and non-retaliation protections.
7.11 Child Participation in Safeguarding: To be able to adapt to changing times and needs, the Club acknowledges the importance of taking feedback from children through child-friendly mechanisms. Accordingly, the Club shall enable the following feedback structures:
7.11.1 Anonymous safeguarding satisfaction surveys conducted annually;
7.11.2 Feedback boxes shall be placed at primary training facility;
All feedback received shall be reviewed by the Child Welfare Officer and key recommendations/ feedback shall be summarized and submitted to the ISOP for their review.
7.12 The Club recognises that effective safeguarding requires strong partnerships with external statutory bodies and specialised agencies. In furtherance of the same, the Club shall proactively coordinate with external safeguarding stakeholders—including Police, child protection authorities, child helplines and mental health professionals—not only in cases of confirmed or serious abuse but also for guidance, referrals and preventive interventions. A formal protocol shall be established to ensure timely reporting, documentation and follow-up with these agencies and the Club shall maintain an updated directory of contacts.
8.1 To ensure objectivity and accountability in the enforcement of the safeguarding policy, the Company shall constitute an Independent Safeguarding Oversight Panel (“ISOP”). This panel shall function autonomously from the Club’s management and report directly to the Board of Directors of the Company.
8.2 Composition:
8.2.1 One child protection and safeguarding expert with no prior association with the Club;
8.2.2 One independent legal professional with experience in juvenile justice or child rights law;
8.2.3 One representative from a reputed child-focused NGO or government welfare body.
8.3 Functions:
8.3.1 Conduct external audits of the Club’s safeguarding compliance on a bi-annual basis;
8.3.2 Review all complaints involving serious breaches and recommend disciplinary action;
8.3.3 Produce an annual public report on child welfare practices and outcomes at the Club;
8.3.4 Evaluate effectiveness of the training modules and recommend changes;
8.3.5 Periodically assess alignment of Club policy with the applicable national and international child rights laws.
9.1 Recognizing the emotional impact of abuse, the Club shall establish a structured psychosocial support system which shall include:
9.1.1 Enable access to a certified Child Psychologist;
9.1.2 Provision of psychological first aid to any affected child within 48 hours of an incident;
9.1.3 Up to 10 free therapy sessions per child victim through a designated mental health partner;
9.1.4 Trauma-informed care training for coaches, staff and volunteers.
The Club is committed to protecting children from harm while also safeguarding the rights and reputations of individuals who may be falsely accused. Recognizing that while most allegations are made in good faith, a minority may stem from misunderstanding, external influence, or malicious intent, the Club shall adopt the following approach:
10.1 Understanding False Allegations:
10.1.1 The Club acknowledges two primary pathways through which false allegations may arise:
a. Intentional fabrication, where the child or complainant knowingly provides untruthful information; and
b. Unintentional misrepresentation, often influenced by external factors such as leading questions, suggestive environments, or errors in memory processing.
10.1.2 Allegations shall be assessed with sensitivity and neutrality. Particular attention shall be paid to:
a. The presence of fantastical or logistically implausible details;
b. Inconsistencies in the narrative across time;
c. History of suggestibility or prior false claims;
d. The context of the disclosure (e.g., custody disputes, influence of peers or adults);
e. The level of specificity and coherence in the description of events.
10.1.3 The presence of any of the above shall not in itself invalidate a claim but may prompt further, unbiased inquiry to test the reliability of the allegation without undermining the child’s voice.
10.2 Protective Measures for the Innocent:
10.2.1 The identity of any accused individual shall remain confidential during initial assessments, and no punitive or reputational consequences shall be imposed until a finding is reached.
10.2.2 Any individual found to have been wrongly accused shall be entitled to appropriate institutional support, including psychological counselling, internal mediation and a formal mechanism for reputational restoration.
10.2.3 Where feasible, the wrongly accused shall be consulted on preferred forms of reputational restoration (e.g., written clearance, internal communication, or reinstatement protocols).
10.3 Maintaining a Safe Reporting Environment:
10.3.1 The Club shall ensure that all children and stakeholders continue to operate in an environment wherein individuals feel empowered to report any concern without fear of dismissal or reprisal.
10.3.2 The investigation of false allegations shall be conducted in a manner that does not dissuade genuine disclosures or stigmatize complainants acting in good faith, even if ultimately mistaken.
10.3.3 Disciplinary action for intentionally false claims shall be considered only where evidence clearly establishes malicious intent and shall be proportionate and handled with due process.
The Club is committed to fostering a transparent, accountable and child-safe environment where all individuals—whether staff, volunteers, contractors, athletes, parents, or spectators—feel empowered to raise concerns related to misconduct, abuse, policy violations, or any other wrongdoing without fear of retaliation.
11.1 Objectives:
11.1.1 Encourage the reporting of genuine concerns regarding unethical or unlawful conduct;
11.1.2 Ensure that all disclosures are treated with seriousness, fairness and confidentiality;
11.1.3 Protect whistleblowers against any form of reprisal or detriment;
11.1.4 Establish clear, secure and accessible reporting mechanisms.
11.2 Anti-Retaliation Safeguards:
11.2.1 The Club shall adopt a zero-tolerance approach to retaliation against whistleblowers. Any form of adverse treatment—whether direct or indirect—against a person making a good-faith disclosure shall be subject to immediate investigation and may result in disciplinary action, including fines, termination or removal from position.
11.2.2 Retaliatory acts may include, but are not limited to:
a. Unwarranted demotion or changes in duties;
b. Harassment, intimidation, or social exclusion;
c. Withholding of opportunities, benefits, or access;
d. Any form of professional or personal reprisal.
11.3 Secure and Anonymous Reporting Mechanisms:
11.3.1 To ensure safe and confidential disclosures, the Club shall maintain multiple, independently monitored channels for reporting concerns:
a. Physical drop-boxes at key Club premises, to be accessed and monitored solely by the designated Child Welfare Officer;
b. Email and/or telephone helpline, accessible to whistleblowers who prefer direct but discreet reporting options.
11.3.2 Clear digital communication shall be maintained through Club platforms to:
a. Explain what constitutes reportable conduct;
b. Guide individuals on how to file a report anonymously;
c. Reiterate the Club’s non-retaliation commitment.
11.4 Whistleblower Support Measures:
11.4.1 Any individual who comes forward with a concern in good faith shall be entitled to:
a. Access to legal advisory services to understand their rights and obligations;
b. Confidential counselling or emotional support, either through the Club’s internal wellness team or partnered service providers;
c. Assistance during investigative processes, including updates and explanations of procedural steps.
11.4.2 Where necessary, temporary protective accommodations (e.g., change of role, schedule flexibility, reallocation of duties) may be made to ensure the whistleblower’s physical and psychological safety.
12.1 The Club endeavors to ensure that all recruitments including but not limited to staff, contractors, coaches, managers and other individuals who come in contact with children are suitably qualified and committed to providing a safe, enjoyable and professional environment and services while meeting the requirements under the applicable laws in force at the time.
12.2 Recruitment processes for child-related positions shall emphasize the importance of child safety and will be managed keeping child safety as priority.
12.3 The recruitment process for child-related positions shall include:
12.3.1 Through interviews to assess the candidate’s suitability for working with children.
12.3.2 Reference checks with previous employers or organizations where the candidate has worked with children.
12.3.3 Verification of qualifications and certifications relevant to the position.
12.3.4 Assessment of the candidate’s understanding of and commitment to child protection principles.
12.4 The Club shall provide training to all individuals involved in the recruitment process to ensure they are aware of and adhere to the Club’s child protection policies and procedures.
12.5 Appropriate background checks, including but not limited to police clearance certificates (where possible) and in case of foreign recruitments, “Working With Children Check” or any analogous requirements in different jurisdictions.
12.6 The Club shall regularly review its recruitment process and procedures to ensure they remain effective in safeguarding children.
12.7 The Club shall comply with any additional requirements or recommendations from relevant authorities or child protection agencies regarding safe recruitment practices.
12.8 Any concerns or allegations regarding the suitability of an individual for a child-related position shall be promptly investigated and addressed in accordance with the Club’s child protection policies and procedures.
To ensure the safety and well-being of children during Club-related travel, events, and overnight stays, the Club shall implement clear protocols governing adult-child interactions, supervision, and accommodation arrangements.
13.1 Travel and Accommodation Protocols:
13.1.1 All travel involving children shall be pre-approved by the Child Welfare Officer and accompanied by a detailed travel and safeguarding plan, including designated supervisors, emergency contacts, and consent from parents/guardians.
13.1.2 Children shall not travel alone with a single adult unless in an emergency and with documented justification. Wherever possible, the adult-child ratio as defined in Clause 13.1.4 shall be followed.
13.1.3 Accommodation shall be arranged to ensure:
a. Gender-appropriate rooming;
b. Separate sleeping arrangements for adults and children;
c. Supervising adults’ rooms located adjacent to children’s rooms, with regular night-time check-ins without intrusion of privacy.
13.1.4 Adult-Child Interaction and Supervision Ratios: The Club shall maintain clear adult-to-child supervision ratios, recommended as follows (or stricter, as per event/activity risk):
a. 1:6 for children under 10;
b. 1:8 for children aged 10–14;
c. 1:10 for children aged 15–18.
13.1.5 At least one female staff member must be present during travel or overnight stays involving girls, and similarly, efforts shall be made to accommodate other gender-specific or accessibility needs.
13.1.6 All adult-child interactions in transit or at the accommodation venue must follow established safeguarding principles, including transparency, avoidance of one-on-one unsupervised situations, and maintaining professional boundaries at all times.
13.2 Briefings and Accountability:
13.2.1 All staff and volunteers involved in travel or accommodation supervision shall receive pre-departure safeguarding briefings specific to the event.
13.2.2 Any safeguarding incident or deviation from these protocols must be immediately reported and documented, with appropriate follow-up and corrective measures.
14.1 In the event of an incident involving a child, the Club shall designate a spokesperson to communicate with the media. Only authorized spokesperson shall provide information to the media to ensure accuracy and consistency of information.
14.2 Media statements regarding incidents involving children shall prioritize the protection and privacy of the child and shall be made in consultation with the child’s parents or legal guardians.
14.3 The Club shall not disclose any information that could identify the child involved in an incident, including but not limited to their name, age, addresses, school names, or any other identifying information, without the consent of the child’s parents or legal guardians.
14.4 Any media inquiries regarding incidents involving children shall be directed to the designated spokesperson, and members of the Club shall not provide information to the media without authorization.
15.1 The Club shall obtain written consent from parents or legal guardians before capturing and using any photographs or videos of children.
15.2 The Club shall represent children in a respectful and dignified manner in all images and videos, avoiding any content that could be deemed inappropriate or exploitative.
15.3 The Club shall not include any identifying information including but not limited to their name, age, addresses, school names, or any other identifying information in captions or comments accompanying images or videos of children without the express written consent of their parents or legal guardian.
15.4 The Club shall ensure that all social media posts containing images or videos of children are set to private or restricted access to prevent unauthorized viewing or sharing.
15.5 The Club shall regularly monitor social media channels for any unauthorized use of images and/or videos of children and take immediate action including removing such content and reporting such unauthorized use to the relevant authorities.
15.6 The Club shall provide training and education to Club members and volunteers (if any) on the importance of protecting children’s privacy online and the Club’s policies regarding the use of photography and video recording in social media.
15.7 Any concerns or incidents related to the use of images or videos of children in social media shall be reported to the Child Welfare Officer, and the Child Welfare Office shall investigate such concerns or incidents and submit a comprehensive report to the Management Committee/Disciplinary Committee.
15.8 The Club shall regularly review and update the Club’s photography and video recording guidelines to ensure they remain up-to-date and effective in protecting children’s privacy and safety online.
The Club is committed to building and maintaining a safeguarding-first culture by ensuring that all individuals associated with the Club are equipped with knowledge and competencies appropriate to their roles. To this end, the Club shall implement a structured, tiered safeguarding training program that is mandatory, role-specific and continuously assessed.
16.1 Training Objectives:
16.1.1 Instill a shared understanding of child protection principles;
16.1.2 Equip individuals with practical tools to identify, respond to and report safeguarding concerns;
16.1.3 Ensure ongoing compliance with legal and regulatory frameworks;
16.1.4 Foster a proactive, informed and accountable safeguarding culture.
16.2 Training Framework and Frequency:
16.2.1 Onboarding Documentation: All Club personnel—whether staff, volunteers, contractors, or consultants—must receive all documents regarding the policies of the Club including without limitation this Code of Conduct within seven (7) days of joining.
16.2.2 Quarterly Refresher Modules: Quarterly seminars/workshops for training modules shall be conducted to introduce and/or reinforce core principles, address emerging risks (e.g., digital safety, grooming trends), and incorporate case-based learning.
16.2.3 Annual Evaluation and Certification: All personnel shall be required to complete an annual online safeguarding assessment, the successful completion of which is mandatory to retain active safeguarding certification and continued engagement with the Club.
16.2.4 Role-Based Training Tiers: The training program shall be structured across three tiers, aligned with the nature of responsibility and exposure to children or safeguarding risks:
a. Tier 1: General Awareness Training
• Stakeholders: All staff, volunteers, and ancillary personnel.
• Content: Introduction to child protection, identifying signs of abuse, Club’s Code of Conduct and internal reporting procedures.
b. Tier 2: Functional Expertise Training
• Stakeholders: Personnel involved in media, administration, logistics, and medical functions.
• Content: Safe handling of disclosures, managing image rights, maintaining professional boundaries and responding to accidental breaches.
c. Tier 3: Leadership and Decision-Making Training
• Stakeholders: Senior management, safeguarding leads, Child Welfare Officers and appointed investigators.
• Content: Legal and regulatory obligations, trauma-informed practices, oversight responsibilities, managing and documenting allegations, and responding to complex safeguarding scenarios.
16.3 Digital Safety Training:
: In light of the evolving risks in online environments, all tiers shall incorporate dedicated digital safeguarding content tailored to role exposure and responsibilities. The digital safety module shall include:
16.3.1 Understanding Online Risks: Online grooming, sextortion, cyberbullying and inappropriate contact.
16.3.2 Safe Digital Communication: Appropriate use of personal devices and Club-authorized platforms.
16.3.3 Consent and Data Privacy: Digital consent for media usage, image rights and online participation.
16.3.4 Ethical Conduct in Virtual Spaces: Case studies on digital boundaries, group chats and responsible posting.
16.3.5 Incident Reporting: Steps to report online safety violations or suspicious digital behaviour.
16.3.6 Emerging Threats: Regular updates on current digital risks and preventive strategies (e.g., AI-generated content, impersonation attempts).
16.4 Gender Sensitivity and Intersectional Safeguarding:
A module which is designed to build awareness and competence among all personnel in recognising and responding to the unique safeguarding risks experienced by children who belong to marginalised or vulnerable groups shall also form a part of the training of all stakeholders, wherein stakeholders shall learn to:
16.4.1 Identify risks commonly faced by girls (e.g., harassment, exclusion), LGBTQIA+ children (e.g., bullying, stigma) and children with disabilities (e.g., neglect, communication barriers);
16.4.2 Recognise and address unconscious bias in reporting and response processes;
16.4.3 Promote inclusive language, safe spaces, and accessible reporting mechanisms for all children, regardless of identity.
16.5 Documentation and Compliance Monitoring:
16.5.1 The Club shall maintain a centralized digital training register capturing:
• The tier-wise assignment of each individual;
• Attendance and completion records;
• Certification validity and renewal dates;
16.6 Line managers and department heads shall be accountable for ensuring that their teams remain compliant with training requirements and receive role-appropriate updates as part of performance and review cycles.
17.1 Where the Management Committee/ Disciplinary Committee determines that an offence under the Code of Conduct has been committed, an appropriate sanction shall be imposed on the relevant person i.e., player or team official, match official or the respective member.
17.2 The Management Committee/ Disciplinary Committee shall consider the term for which the relevant person shall be suspended based on the nature of offence. The Committee shall also have the right to terminate the existing right of the relevant person to participate in Programs and/or file a complaint with the local police/ relevant authorities, depending on the seriousness of the offence committed.
17.3 The decision of the Disciplinary Committee/Management Committee shall be final and binding on all the stakeholders.
18.1 This Code of Conduct may be amended from time to time by the Company with such amendments coming into effect on the date specified by Company.
18.2 The headings used for the various articles of this Code of Conduct are for the purpose of guidance only and shall not be deemed to be part of the substance of the Code of Conduct or to inform or affect in any way the language of the provisions to which they refer.
18.3 If any Article or provision of this Code of Conduct is held invalid, unenforceable or illegal for any reason, this Code of Conduct shall remain otherwise in full force apart from such Article or provision which shall be deemed deleted insofar as it is invalid, unenforceable or illegal.
Any participant or member of the Programs including but not limited to players, parents, referees, coaches, managers, captains, and team officials shall be in breach of this Code of Conduct if he is found to have engaged in any of the following conduct:
1. Responsibility of all relevant persons:
2. Reporting Misconduct
3. Recording and Disclosure
4. Information Sharing
5. Confidentiality of Complainant
| A. YOUR INFORMATION | |
|---|---|
| Name | |
| Contact number | |
| B. PERSONAL INFORMATION OF THE CHILD | |
|---|---|
| Name | |
| Date of birth (DD/MM/YYYY) | |
| Gender |
|
| C. CONTACT INFORMATION – PARENT/LEGAL GUARDIAN | |
|---|---|
| Name(s) | |
| Address | |
| Contact number(s) | |
| D. INCIDENT DETAILS | |
|---|---|
| Date and time of incident | |
| Please tick one |
|
| Name of person raising concern | |
| Role within the Club or relationship to the child | |
| Contact number(s) | |
*Attach a separate sheet if more space is required (e.g. multiple witnesses)
Please provide the names of any witness to the incident
| Name of witness (please indicate if a child) | Role within the Club (Coach, Official, Player) |
|---|---|
| Contact number(s) | |
Details of any person involved in this incident or alleged to have caused the incident/injury
| Name | Role within the Club (Coach, Official, Player) |
|---|---|
| Contact number(s) | |
*See next section
