Safeguarding and Student Welfare Policy

LOPEX UNICONS LTD (trading as UNICONS) is committed to safeguarding and promoting the welfare of all students who interact with its services, with particular attention to those who are under 18 years of age or who are vulnerable adults. This policy applies to every person acting on behalf of UNICONS, including employees, contractors, volunteers, recruitment agents, education counsellors, and any third-party partner operating within the UNICONS platform or under a UNICONS service agreement.

The purpose of this policy is to:

• Establish clear standards and expectations for safeguarding practice across all UNICONS operations;
• Ensure that all personnel understand their responsibilities and feel confident in responding appropriately to concerns;
• Protect children and vulnerable adults from abuse, neglect, exploitation, and harm;
• Comply with applicable legislation, including the Children Act 1989, the Children Act 2004, the Safeguarding Vulnerable Groups Act 2006, the Care Act 2014, and statutory guidance such as *Working Together to Safeguard Children* (HM Government, updated 2023).

This policy applies regardless of the medium through which UNICONS delivers services, including face-to-face consultations, digital interactions, telephone communications, and online platform activity.

For the purposes of this policy, the following definitions apply:

Child: Any person under the age of 18 years, as defined by the Children Act 1989.

Vulnerable Adult: A person aged 18 or over who, by reason of mental or physical disability, illness, age, or other circumstance, is in need of care and support, and may be unable to protect themselves from abuse, exploitation, or neglect.

Harm: Includes physical abuse, emotional abuse, sexual abuse, neglect, financial exploitation, and modern slavery or trafficking.

Physical Abuse: Inflicting physical pain, injury, or suffering, including hitting, burning, restraining, or any form of non-accidental physical harm.

Emotional Abuse: Persistent or severe emotional ill-treatment that adversely affects emotional development, including humiliation, threats, coercion, or deprivation of basic emotional needs.

Sexual Abuse: Involvement in sexual activity without informed consent, or any sexual activity with a child regardless of apparent consent.

Neglect: Persistent failure to meet basic physical, emotional, or educational needs in a way that is likely to cause serious harm.

Financial Exploitation: The improper use of a person's funds, property, or resources, including through deception, coercion, or undue influence.

Grooming: Actions taken by an individual to build trust with a child or vulnerable adult — and potentially those around them — with the intent to facilitate abuse, exploitation, or harm.

UNICONS maintains a Designated Safeguarding Lead (DSL) who holds ultimate responsibility for safeguarding across the organisation. The DSL is a senior member of the management team trained to at least Level 3 safeguarding standard.

Role and responsibilities of the DSL:

• Act as the central point of contact for all safeguarding concerns raised internally;
• Assess and manage safeguarding referrals, deciding whether and when to escalate to statutory agencies;
• Liaise with Local Authority Designated Officers (LADOs), children's social care, the police, and other relevant bodies as appropriate;
• Maintain confidential records of all safeguarding concerns and actions taken;
• Ensure all staff and partners receive adequate safeguarding training and understand the reporting procedure;
• Review this policy annually and update it in line with legislative or guidance changes;
• Represent UNICONS in multi-agency safeguarding meetings as required.

Contact details for the DSL:

Any safeguarding concern should be reported to the Designated Safeguarding Lead at: - Email: enquiry@unicons.co.uk (marked: SAFEGUARDING — CONFIDENTIAL) - Address: LOPEX UNICONS LTD, 214 High Street, Second Floor, Hounslow, TW3 1HB, London, United Kingdom

In the absence of the DSL, the Deputy DSL (as designated by UNICONS management) assumes all DSL responsibilities. Contact the main office number to be directed appropriately.

Every individual who works for or with UNICONS — whether employed, contracted, or acting as an agent or counsellor — has a personal, non-delegable obligation to:

• Act in the best interests of students at all times;
• Maintain appropriate professional boundaries with students, particularly with those who are under 18 or vulnerable;
• Report any safeguarding concern promptly to the DSL — staff must not attempt to investigate concerns themselves, as this may compromise statutory investigations and cause further harm to the student;
• Not make promises of confidentiality that conflict with safeguarding obligations — all personnel must communicate clearly to students that information indicating risk of harm cannot be kept secret;
• Avoid conduct that could itself constitute abuse or exploitation, including but not limited to inappropriate physical contact, inappropriate communications, financial pressure, or sharing of personal contact details outside professional channels;
• Cooperate fully with any investigation conducted by the DSL, statutory agencies, or regulatory bodies;
• Complete all required safeguarding training as directed by UNICONS.

No concern about potential harm to a child or vulnerable adult should be dismissed or left unreported on the grounds that the person raising it is uncertain or that the concern seems minor. All concerns should be reported and assessed by the DSL.

Personnel should be alert to the following signs and indicators, which may suggest that a student is experiencing harm or is at risk:

Behavioural changes: - Unexplained withdrawal, anxiety, depression, or significant change in demeanour; - Sudden reluctance to communicate or engage with UNICONS staff; - Reports of being monitored, controlled, or unable to speak freely; - Expression of fear, hopelessness, or references to self-harm.

Financial exploitation indicators: - Reports that another person is controlling their finances or application payments; - Pressure to pay fees through informal channels or to individuals rather than through official platforms; - Evidence that a third party is retaining or demanding possession of the student's documents (passport, visa, offer letter).

Coercion and grooming indicators: - Evidence that a student's choices are being made by another person without genuine consent; - An adult accompanying the student who speaks on their behalf, answers all questions, and restricts direct communication; - Gifts, favours, or privileges from an agent or third party that appear designed to secure compliance or access; - Students who appear to be in a relationship of dependency, fear, or undue influence with a third party involved in their application.

Modern slavery and trafficking indicators: - Student appears not to know their own address or travel arrangements; - Student's documents are held by another person; - Student appears to be under the control of someone who has organised their travel and application.

If any of these indicators are observed, personnel must report immediately to the DSL without delay and without attempting to investigate independently.

UNICONS operates a clear and accessible reporting procedure to ensure that all safeguarding concerns are handled promptly and appropriately.

Step 1 — Immediate safety. If a student is in immediate danger, the reporting individual must call 999 (UK emergency services) immediately. Safeguarding procedures do not replace or delay emergency response.

Step 2 — Internal report to the DSL. Any concern that does not require immediate emergency response must be reported to the DSL within 24 hours of the concern arising. Reports should be made in writing where possible, setting out: - The identity of the student concerned (name, date of birth if known, contact details); - The nature of the concern, including any specific incidents, observations, or disclosures; - Any action already taken; - The name and contact details of the reporting individual.

Step 3 — DSL assessment. The DSL will assess the concern and determine the appropriate response within one working day of receipt of the report. The DSL may seek advice from the Local Authority (Children's Services or Adult Safeguarding team) without necessarily naming the individual at this stage.

Step 4 — Statutory referral. If the DSL determines that a child is at risk of significant harm, or that a vulnerable adult is at risk of abuse or neglect, the DSL will make a formal referral to the relevant Local Authority and/or the police without delay.

Step 5 — Record and monitor. All reports, assessments, decisions, and outcomes are recorded securely on a confidential safeguarding log maintained by the DSL. Records are retained in line with the Data Retention and Deletion Policy.

Where a concern relates to the conduct of a member of UNICONS staff, the DSL will follow the organisation's disciplinary procedure in parallel with any statutory referral.

UNICONS respects the privacy of all students and handles personal data in accordance with the UK GDPR and the Data Protection Act 2018. However, confidentiality is not absolute in a safeguarding context.

The principle that applies is as follows: the safety and welfare of a child or vulnerable adult takes precedence over any obligation of confidentiality. Accordingly:

• Where a student discloses information that gives rise to a safeguarding concern, that information will be shared with the DSL and, where necessary, with statutory agencies, regardless of any request for confidentiality made by the student;
• All personnel must communicate this limitation clearly if a student begins to disclose information that may engage safeguarding concerns — staff should not promise to keep information secret before hearing what the student has to say;
• Information will be shared on a need-to-know basis only. It will not be shared more widely than is necessary to protect the individual or enable a proper assessment by statutory agencies;
• Where information is shared with external agencies, UNICONS will keep a record of what was shared, with whom, when, and why.

The legal basis for sharing information without consent in a safeguarding context is vital interests (UK GDPR Article 6(1)(d)) and substantial public interest (UK GDPR Article 9(2)(g)), supported by Schedule 1 of the Data Protection Act 2018.

UNICONS is committed to ensuring that all individuals who work in roles involving contact with children or vulnerable adults are subject to robust pre-employment and pre-engagement checks.

For employees and contractors in regulated activity: - An enhanced Disclosure and Barring Service (DBS) check is required before the individual commences any role involving contact with children or vulnerable adults; - Where an individual has lived or worked outside the UK in the last five years, an equivalent overseas check is required, or a risk assessment is conducted in its absence; - Two professional references are required and will be checked before appointment; - Gaps in employment history will be explored and satisfactorily explained before appointment.

For agents and counsellors: - All agents and counsellors operating on the UNICONS platform must confirm compliance with applicable local safeguarding laws; - UNICONS reserves the right to require agents and counsellors to provide evidence of relevant checks, particularly where they work regularly with minors; - UNICONS will not onboard or continue to engage any agent or counsellor who has been found to have harmed, exploited, or abused any student.

DBS records are checked at onboarding and thereafter in line with the DBS update service or at intervals determined by the DSL, not exceeding three years for regulated activity roles.

UNICONS provides a digital platform through which students interact with the organisation and its partners. Where that platform is accessed by students who are under 18 years of age, UNICONS takes additional measures to protect their online safety.

These measures include:

• Age verification at registration: Students who are identified as under 18 at the time of registration are flagged in the system, and parental or guardian consent is obtained before services are provided;
• Restricted communications: Direct messaging between agents or counsellors and students under 18 must take place only through the UNICONS platform, not through personal social media, instant messaging apps, or unofficial channels;
• Content standards: No personnel may share inappropriate content with any student via the UNICONS platform or any UNICONS-associated communication channel;
• Monitoring: UNICONS reserves the right to audit platform communications to ensure compliance with this policy;
• Reporting tools: Students are provided with accessible means to report online concerns, including concerns about the behaviour of platform users.

All personnel are reminded that communications with students — particularly those who are under 18 — must be professional, relevant to the student's application or educational journey, and conducted through official channels only.

UNICONS works with universities, colleges, and other educational institutions as part of its service delivery model. As a condition of partnership, all partner institutions are expected to:

• Maintain their own safeguarding policy that is compliant with applicable legislation and sector-specific guidance;
• Designate a senior individual with safeguarding responsibility who can act as a point of contact for UNICONS in relation to shared students;
• Notify UNICONS promptly where a safeguarding concern arises in relation to a student referred through UNICONS;
• Cooperate with any safeguarding investigation in which UNICONS is involved as a relevant party;
• Ensure that their own agents, representatives, and staff dealing with UNICONS-referred students are trained in safeguarding and aware of reporting obligations.

UNICONS will review partner institution safeguarding arrangements during the due diligence process at onboarding and may conduct periodic audits or request updated policies. Failure to maintain adequate safeguarding practices is grounds for suspension or termination of the partnership agreement.

All personnel within the scope of this policy are required to complete safeguarding training appropriate to their role.

Minimum requirements:

• All staff and platform users: Safeguarding awareness training (Level 1) completed within four weeks of joining UNICONS and refreshed annually;
• Staff with regular student contact: Safeguarding training at Level 2, covering recognition of abuse and the reporting process, refreshed annually;
• DSL and Deputy DSL: Advanced safeguarding training (Level 3 or equivalent) refreshed at least every two years, plus attendance at relevant multi-agency or sector training events.

Training completion is recorded by UNICONS' HR and compliance function. Personnel who do not complete required training within the specified timeframe may have their access to student-facing functions suspended pending completion.

UNICONS reviews training content annually to ensure it remains aligned with current statutory guidance, platform capabilities, and the specific risks encountered in international student recruitment.

This policy is reviewed and updated at least annually by the DSL, in consultation with senior management, to ensure it remains compliant with legislation, statutory guidance, and best practice.

The policy may be updated more frequently in response to significant legislative changes, statutory guidance updates, or a serious safeguarding incident. All updates are communicated to relevant personnel promptly.

Escalation contacts:

Approved by: Director, LOPEX UNICONS LTD Effective date: 1 September 2025 Next review date: 1 September 2026