Safeguarding

SAN MARINO FOOTBALL FEDERATION 05/08/2024

Introduction:

The Child Safeguarding Policy presented herein has been developed by the San Marino Football Federation (“FSGC”), as evidence of its commitment to ensuring that football in San Marino is safe and enjoyable for all minors participating in it, regardless of their age, ability, or level of involvement. This policy is based on five overarching objectives or areas of action aimed at preventing the risk of harm to children in football and ensuring an appropriate response whenever such situations arise.

5 Objectives:

• Goal 1: Establish the foundations for safeguarding
• Goal 2: Ensure organisational preparedness and prevention
• Goal 3: Raise awareness
• Goal 4: Work with relevant authorities and report concerns
• Goal 5: Measure success in safeguarding

GOAL 1

1.1 Responsibility

1.1.1. Safeguarding children is everyone’s responsibility. The purpose of this Policy is to promote, in the best interests of children, the creation of an environment that supports, safeguards, and protects them.
1.1.2. All individuals involved, at any level, in any capacity and with any role, in the organisation and delivery of activities and events within the youth sector of the San Marino Academy and its affiliated clubs, whether they are federation staff, registered members of affiliated clubs, or parents, must acknowledge and be aware of their duties regarding child safeguarding and must act in a way that actively promotes the welfare of children and young people and addresses their specific needs. It is everyone’s responsibility to adopt appropriate and targeted actions and measures to implement this Policy.
1.1.3. Given the shared and collective responsibility for safeguarding children, FSGC and San Marino Academy will actively encourage and support affiliated clubs in developing procedures and establishing internal organisational structures based on the principles and requirements of this Policy.

1.2 Definition of “Child Safeguarding”

1.2.1 For the purposes of this Policy, “child safeguarding” is defined as the set of behavioural standards and procedures aimed at ensuring that football is a safe, positive, and enjoyable experience for all children and young people. It must also ensure that minors are protected from any potential risks or abuse when involved, in any capacity, in football and youth football activities.
1.2.2 Child safeguarding includes awareness-raising and preventive actions to reduce the risk of harm or abuse, as well as reporting and response measures to ensure effective intervention following any report of abuse, while supporting, safeguarding, and protecting the child involved. This reflects the need to promote the best interests of children and to comply with both international standards and national legislation, particularly with regard to potential breaches of criminal law.

1.3 What is meant by “harm” and “abuse”?

1.3.1 All individuals referred to in section 1.1.2 must be aware that abuse, harm, and child safeguarding concerns are rarely subject to a single, clear-cut classification. In most cases, different forms of abuse or harm overlap and occur simultaneously.
1.3.2 Harm may occur in different ways and generally involves a compromise to a child’s safety and well-being. This may result from the deliberate actions of an individual, but it may also stem from inadequate or deficient training, leaving that person without the knowledge and skills necessary to fulfil their responsibilities.
1.3.3 Abuse means any act that causes physical or psychological harm to a child, directly or indirectly inflicts damage, or hinders the child’s prospects for healthy and safe development into adulthood.
1.3.4 Children may suffer abuse or maltreatment from individuals known to them, within the home environment or within institutions and organisations. Alternatively, abuse and maltreatment may be perpetrated by strangers (e.g. online). Abuse and maltreatment may be committed by adults or by other minors.
1.3.5 Abuse may take various forms: physical, emotional/psychological, or sexual abuse; it may also take the form of neglect, lack of care, or violence, as outlined above.
1.3.6 Although child safeguarding concerns generally involve adults, minors themselves may also commit acts of abuse or maltreatment. This usually occurs when a child is in a position of power or influence (for example, because they are older or hold a position of authority, such as being the team captain). This phenomenon is commonly referred to as bullying.

1.4 Specific Child Safeguarding Risks in Football

1.4.1 There are several situations specific to football in which harm or abuse may occur.
1.4.2 PHYSICAL INJURIES: Every sport carries a risk of physical injury, and football is no exception. However, an excessive desire to achieve success and secure victory may place undue pressure on children and young people, pushing them beyond what would be appropriate and reasonably expected given their age and ability. This may result in injuries or medical conditions developing or becoming more severe.
1.4.3 PERFORMANCE PRESSURE: Winning is an important part of football. However, placing excessive pressure on players in an effort to achieve success or gain recognition can be harmful from a psychological, emotional, and physical perspective.
1.4.4 PERSONAL CARE: Changing rooms, shower facilities, and situations involving close physical contact (e.g. physiotherapy and medical treatment) may create opportunities for bullying, inappropriate photography, unauthorised or inappropriate filming, or may otherwise facilitate abuse, particularly sexual abuse.
1.4.5 TOURS, TRAVEL, AND OVERNIGHT STAYS: Travel and trips involving overnight stays present a number of potential risks, including inadequate supervision, children going missing or becoming separated from the group, access to alcohol or inappropriate content available on television or online, issues relating to social media use, and the possibility of abuse occurring, particularly sexual abuse.
1.4.6 STAFF AND PERSONAL RELATIONSHIPS: The relationships that develop within a team environment between players and coaches or other staff members (such as team officials, physiotherapists, and doctors) are an important and positive aspect of football. Many children and young people develop close and trusting relationships with their coaches, who often play a significant role in the lives of young athletes, particularly where those athletes do not have healthy and positive relationships with other adults. While many coaches build positive relationships in the best interests of the children entrusted to their care, there may be cases where the authority held by such individuals and the trust placed in them become potentially harmful to children and young people and may give rise to abuse.

1.5 Links with National Legislation and Policies: this Policy establishes the minimum requirements and standards for child safeguarding. All actions undertaken in this area must be carried out in full compliance with the applicable laws and regulations in force.

1.6 Activities Outside Football: this Policy focuses on situations that arise (and may involve children) during FSGC–San Marino Academy activities organised directly or delivered by affiliated clubs. However, inappropriate or harmful behaviour occurring outside football activities, whether on an individual basis or within a group, may also breach the principles set out in this Policy and conflict with the values promoted by football. It is therefore important to remain vigilant regarding potentially harmful situations that may have a negative impact on football and on the participation of children and young people in the game, referring such matters, where necessary, to the appropriate organisations or institutions responsible for addressing them.

1.7 Key Principles Underpinning the Policy

1.7.1 Football must be a safe, positive, and enjoyable experience for all players.
1.7.2 All players have an equal right to safeguarding, protection, the promotion of their well-being, and participation in activities, regardless of their age, gender, sexual orientation, ethnicity, social background, religion, level of ability, or disability.
1.7.3 All actions undertaken in the area of child safeguarding must be guided by the best interests of children and young people.
1.7.4 Everyone has a responsibility for safeguarding and protecting children. Children themselves can also play an important role by making an active contribution to their own protection and that of other children and young people, although ultimate responsibility remains with adults.
1.7.5 Safeguarding measures must be inclusive and non-discriminatory, recognising that some children (for example, those with disabilities) may be at greater risk of abuse.
1.7.6 Transparency and openness are essential in relation to child safeguarding. Abuse and harm may occur more frequently when staff, volunteers, sports personnel, children, young people, and families are not adequately trained, informed, and prepared.
1.7.7 Child safeguarding and protection must be addressed with seriousness and professionalism. Where necessary, safeguarding measures must extend to referring cases to law enforcement authorities and child protection agencies/organisations.
1.7.8 Child safeguarding is a shared responsibility and must be addressed collaboratively with all potentially involved stakeholders, including organisations, agencies, associations, and government bodies.
1.7.9 The confidentiality of the personal data of all individuals involved must be maintained (including the identity of the person reporting the abuse, the child victim, and the alleged perpetrator). Subject to compliance with all applicable data protection and legal requirements, such information must not be disclosed unless disclosure is necessary to ensure the protection of the child (for example, where a criminal offence may have been committed).
1.7.10 All actions undertaken must be carried out within a framework of legality and in compliance with all applicable laws and regulations.

GOAL 2

2.1 Adoption of the Policy

2.1.1 FSGC and San Marino Academy, as the bodies responsible for organising activities for children and young people and therefore also responsible for their safeguarding, have adopted this Policy together with other safeguarding tools, including guidelines and codes of conduct.
2.1.2 All FSGC-affiliated clubs involved in youth football activities, their registered members, FSGC–San Marino Academy staff and collaborators, and all individuals engaged in any capacity and in any role within activities directly or indirectly organised for their youth sectors, undertake to adopt and comply with this Policy.
2.1.3 Affiliated clubs are encouraged to implement all safeguarding tools made available to them, adapting procedures and content to their specific local circumstances and operational realities.

2.2 Appointment of the Child Safeguarding Officer

2.2.1 FSGC shall appoint a Child Safeguarding Officer (also referred to as the Child Safeguarding Focal Point) at national level to ensure compliance with this Policy and the provisions contained therein. This individual will work closely with affiliated clubs and any third parties involved (agencies, associations, public bodies, etc.). The name and contact details of the Child Safeguarding Focal Point are available on a dedicated page of the FSGC website.
2.2.2 All affiliated clubs will be encouraged to appoint their own internal Child Safeguarding Officer (also referred to as the Child Safeguarding Focal Point) to act as a liaison with FSGC and to serve as the first point of contact for the receipt and initial assessment of reports and concerns.
2.2.3 The role of the Child Safeguarding Officer is to receive reports and provide initial guidance regarding the appropriate response and procedures to be followed in accordance with the established processes, as well as to monitor the correct implementation of this Policy and related safeguarding tools [See the Guidelines on the Roles and Responsibilities of the Child Safeguarding Officer].
2.2.4 It is recommended that the role of Child Safeguarding Officer be assigned to individuals who have received appropriate training in child safeguarding and protection, taking into account their skills, expertise in youth football, relevant experience, and personal aptitude. Within affiliated clubs, the role may be undertaken by any individual capable of performing it effectively and efficiently, having regard to their relationships with sports personnel and young players. [See the Guidelines on the Roles and Responsibilities of the Child Safeguarding Officer]

2.3 Recruitment and Selection Process for Sports Personnel

2.3.1 Safer recruitment and selection procedures will be introduced for sports personnel, whether employed by the Youth and School Sector (SGS) or forming part of the staff of affiliated clubs, in order to ensure that candidates are suitable to work within youth football activities and have direct contact with minors.
2.3.2 The selection procedures must include the collection of documentation and self-declarations, as well as pre- and post-selection checks and verification processes [See the Guidelines for Safe Recruitment].
2.3.3 To prevent unsuitable individuals from working with children and young people, no sports personnel may be engaged in activities until all required checks have been completed and all necessary documentation has been obtained. The process will conclude with a training and information session covering child-safeguarding matters. During the training period, activities may be carried out only under the supervision of another authorised individual.
2.3.4 Documentation relating to the recruitment and selection process must be properly retained so that both the information concerning selected candidates and the records of the recruitment process itself can be consulted when necessary. Such information must be archived and stored in compliance with the applicable legislation concerning privacy and the protection of personal data.

2.4 Codes of Conduct

2.4.1 Clear Codes of Conduct shall apply to all activities involving minors. These shall set out the standards of behaviour to be observed and the procedures to be followed in order to safeguard children in all situations and contexts related to football and the participation of children and young people in sporting activities [Please refer to the dedicated section for the provisions of the Child Safeguarding Codes of Conduct].
2.4.2 All individuals involved, in any capacity and in any role, in the organisation and delivery of FSGC–San Marino Academy activities shall be required to read and sign the Codes of Conduct, which will be attached to any collaboration agreements or registration/membership forms.
2.4.3 FSGC encourages affiliated clubs to adopt and sign the Codes of Conduct as a key tool for child safeguarding and as a demonstration of commitment by all personnel working in this area.
2.4.4 Any breach of the Codes of Conduct must be promptly reported to the person responsible for child safeguarding (the Child Safeguarding Officer). Such reports must include all information necessary to facilitate the effective assessment and resolution of the matter.
2.4.5 In the event of a report concerning a suspected breach of a Code of Conduct, the investigation of the facts must be carried out by an individual possessing the necessary knowledge and expertise.
2.4.6 As organisations committed to child safeguarding, FSGC and San Marino Academy shall take all necessary measures to prevent breaches of the Codes of Conduct by their staff and collaborators. Where breaches occur, appropriate action shall be taken to bring the conduct to an end and to sanction those responsible. Likewise, FSGC shall support affiliated clubs in the proper implementation and enforcement of the Codes of Conduct.
2.4.7 In cases of alleged breaches, consideration should be given to suspending the individual concerned from activities pending the outcome of the investigation.
2.4.8 The Codes of Conduct may contain specific disciplinary measures applicable in the event of a breach. Such measures and sanctions may range from a verbal warning to suspension or termination of the collaboration relationship and may be accompanied by additional training and awareness-raising measures.
2.4.9 Any sanctions imposed for breaches of the Codes of Conduct shall be in addition to any sanctions imposed by the competent authorities where the conduct concerned has civil or criminal implications.

2.5 Supervision and Deployment of Sports Personnel in Activities

2.5.1 As a general principle, activities involving minors should not be conducted by a single member of sports personnel. Whenever an activity involves children or young people, at least two adults should be present. Recognising that compliance with this requirement may sometimes be challenging, activities involving children and young people must always take place in open and freely accessible environments where observation of the activity is readily possible. Group activities should always be preferred over one-to-one activities involving a single child and an adult.
2.5.2 The number of sports personnel involved must always be sufficient to ensure adequate supervision of participants, taking into account the context, age, and abilities of the children and young people involved. During the planning and organisation stages, the number of minors and sports personnel participating must always be considered as part of the risk assessment for the activity or event.
2.5.3 FSGC and San Marino Academy recommend the following adult-to-child ratios:
1 adult for every 10 children aged 13–18;
1 adult for every 8 children aged 9–12;
1 adult for every 6 children aged 5–8; and
1 adult for every 3 children aged 4 or under.
2.5.4 If there are insufficient adults to achieve the required level of supervision, the activity should be modified accordingly or cancelled.
2.5.5 In the case of medical assistance (e.g. medical examinations, post-injury treatment, or physiotherapy), minors are entitled to have a peer or an adult of their choosing present alongside the doctor or healthcare professional providing the treatment or assistance.
2.5.6 Specific requirements apply to the collection of anti-doping samples from minors and must always be respected throughout the procedure. Athletes aged 14 or over, and in all cases their parents, guardians, or legal representatives, must be informed of their selection for doping control in the presence of an adult. They may choose to be accompanied by a sports official throughout the sample collection process. Such a person may be replaced by another witness who must be present during the doping control procedure.
2.5.7 Children and young people should not receive personal care (e.g. assistance while showering) from sports personnel. If they are unable to carry out such activities independently, a parent, guardian, or another person authorised by them (preferably of the same sex as the child) should always provide the necessary assistance.
2.5.8 Changing rooms, shower facilities, and similar areas must be supervised, as must access to those facilities, in a manner that protects the privacy of minors. Only adults responsible for the supervision of children and young people should be permitted access to changing room areas. Clear procedures governing access to such areas must be established and communicated.
2.5.9 Where activities involve overnight stays (for example during away trips or tournaments), a minor must never be assigned to share a room with a member of sports personnel, except in exceptional and justified circumstances with the prior consent of the parents or guardians, or where there is a family relationship between the minor and the adult concerned.
2.5.10 Clear procedures must be established to deal with situations involving a missing, unaccounted-for, or separated child, as well as circumstances where a parent or guardian fails to collect a minor at the end of an activity and cannot be contacted or is unable to do so.
2.5.11 Where a minor travels unaccompanied or with a person other than their parent or guardian in order to participate in activities, written authorisation signed by the parent or guardian must be obtained, authorising both the travel arrangements and the care of the minor by the designated individual.

2.6 Visitors and Spectators

2.6.1 FSGC, as well as all affiliated clubs, undertakes, during activities and competitions that allow public access to the venue hosting the event, to share the principles of this Policy with visitors and spectators, who must acknowledge and accept its provisions.
2.6.2 Visitors and spectators (including journalists and media or communications personnel) must never be left alone with children or young people. The presence of a supervising adult is always required, unless the adult concerned is a relative of the minor.
2.6.3 The safety and well-being of children must not be compromised through interactions with external individuals such as visitors or spectators. Private information, including contact details or home addresses of minors, must not be disclosed to such persons.

2.7 Video/Photographic Material and Online Safety

2.7.1 FSGC – San Marino Academy and its affiliated clubs, through their online presence, including official websites and social media channels, share activities, initiatives, and achievements by publishing information and images of children and young people in compliance with applicable legislation. All necessary authorizations must be obtained in advance, paying particular attention to the individual providing the content, the platform or channel through which it is published, and the permissions under which such images or testimonials are disseminated. These checks must also extend to offline channels, such as printed posters and promotional or informational materials.
2.7.2 Where photographic or video material depicting a minor is acquired and/or retained, it is always necessary to obtain the appropriate consent form signed by the parents or legal guardians, ensuring that the signatures are valid, in order to store and/or use the material concerned.
2.7.3 Consent granted to FSGC–San Marino Academy (or affiliated clubs) for the use of athletes’ images does not extend to, nor authorize, the use of such images by other individuals involved, including club officials, coaches, players, or team escorts.
2.7.4 Images that may be considered offensive or that could place a child in an embarrassing or exploitative situation (for example, images where the child is not fully clothed) must never be acquired, published, shared, or distributed. In any event, a minor aged 14 or over who feels offended by the publication of material relating to them, or their parents, guardians, or legal representatives, may submit a request to the person responsible for the publication and/or sharing of the content for the obscuring, removal, or blocking of any personal data relating to the minor that has been published online, as further detailed in the relevant privacy notices and in accordance with applicable legislation. In the event of continued inaction, the right to initiate a formal reporting procedure shall remain unaffected.
2.7.5 Any project involving the use of media or new technologies must be preceded by a risk assessment relating to the safety of minors and by a review of the measures to be implemented to mitigate such risks. The safeguarding of children must always be considered the primary concern, as further detailed in Article 3.2.
2.7.6 FSGC shall provide guidance on the appropriate use of technology (including the Internet, mobile phones, social media, and similar tools) in relation to child safeguarding and the implementation of this Policy.
2.7.7 Where minors have unrestricted internet access within facilities hosting SGS activities or events, appropriate measures must be in place to prevent access to unsuitable or offensive material. Websites that promote child abuse or contain images or information potentially harmful to minors must be blocked on devices provided by FSGC or affiliated clubs and used by sports personnel.
2.7.8 Where FSGC–San Marino Academy or affiliated clubs use WhatsApp groups (or similar platforms) as a communication channel for sharing photographs and/or information, specific rules governing their use must be established, including moderation procedures designed to protect children and young people.
2.7.9 Should offensive material or unsolicited inappropriate messages be received online, the relevant Child Safeguarding Officer must be informed so that the matter can be reported and, where appropriate, referred to specialists for resolution.

2.8 Collaborations, Partnerships, and Sponsorships

2.8.1 Particular attention must be paid to child safeguarding in all relationships established for the organisation and delivery of activities, whether with associations, agencies, organisations, or companies. Agreements entered into with such parties must include specific provisions relating to child safeguarding and this Policy.
2.8.2 Should any concerns arise regarding the reliability of third parties involved in activities with respect to child safeguarding, all necessary measures must be taken to investigate and resolve any issues identified, including, where appropriate, in cooperation with the parties concerned.

GOAL 3

3.1 Awareness and Training

3.1.1 All individuals involved in FSGC–San Marino Academy activities as sports personnel, whether they are FSGC–San Marino Academy collaborators or members of affiliated clubs’ staff, as well as communities, families, children, and young people, must be informed about the contents of this Policy and enabled to recognise and report situations involving breaches of the Codes of Conduct or instances of abuse.
3.1.2 FSGC–San Marino Academy shall develop and make available training resources dedicated to child safeguarding (both online and offline) in support of sports personnel and affiliated clubs.
3.1.3 Particular attention shall be devoted to initiatives aimed at increasing the awareness of children and young people regarding the issues addressed in this Policy and the ways in which they can contribute to making sport and football participation safe. To this end, materials and resources specifically designed for minors, using age-appropriate language and formats, shall be produced.
3.1.4 Depending on the role and responsibilities carried out within FSGC–San Marino Academy activities, tailored training materials and resources may be provided.
3.1.5 FSGC–San Marino Academy shall ensure the continuous updating of child safeguarding materials and documentation through a variety of methods and tools.
3.1.6 Alongside the commitment of FSGC–San Marino Academy to provide support and training on the matters covered by this Policy, all adults have both the right and the responsibility to request clarification, guidance, and advice regarding these issues and the other safeguarding tools in place. Child Safeguarding Officers shall serve as the primary point of contact for such requests.
3.1.7 Records of all webinars and training activities, including the relevant programmes and schedules, should be maintained so that all content remains accessible and available to authorised individuals at all times.

3.2 Risk Assessment

3.2.1 Risk assessment is an essential tool within any child safeguarding process. Its importance lies in its ability to provide the foundation for all preventive actions aimed at ensuring that activities can be conducted safely by identifying and minimising, through targeted measures, potential risks and safeguarding concerns affecting children and young people.
3.2.2 Responsibility for carrying out risk assessments rests with the individual responsible for the organisation and delivery of the activity. [See the Tools Section for the Risk Assessment Template].
3.2.3 Where, following a risk assessment, it is concluded that sufficient safeguards cannot be provided for an activity or event, and where appropriate preventive measures cannot reasonably be implemented, the activity or event must be postponed, redesigned, or cancelled.
3.2.4 Emergency contact details and medical information forms for players must be collected before they participate in any activities. Such information must be made available to those responsible for child safeguarding during activities and events where it is necessary for risk prevention or for the management of emergencies or other safeguarding concerns.
3.2.5 Risk management measures must be reviewed and updated continuously, both during and after activities or events, so that the actions taken and solutions identified can be documented and used to inform future activities and events.

3.3 Establishing a Safe Reporting Channel

3.3.1 A clear and accessible procedure must be established and communicated for reporting breaches of the Codes of Conduct, safeguarding concerns, or instances of abuse. This procedure must be available to all individuals involved, whether they are victims, witnesses, or persons who have become aware of the facts.
3.3.2 A process map illustrating the reporting and case-management procedure must be made known to all relevant stakeholders. The primary point of reference for all safeguarding processes shall always be the Child Safeguarding Officer, whether appointed at local or national level.
3.3.3 The process map detailing reporting procedures and the individuals responsible for handling reports must be discussed with any relevant third parties (institutions, associations, public bodies, etc.) that may have a role in managing reports and safeguarding cases (e.g. law enforcement authorities) [see also Goal 4].
3.3.4 The reporting platform available on the FSGC website (www.fsgc.sm) shall enable reports concerning breaches of the Codes of Conduct, misconduct, maltreatment, or abuse to be submitted, including anonymously. Reports may be submitted directly to FSGC or to San Marino Academy.
3.3.5 FSGC–San Marino Academy guarantees the strict confidentiality of the reporting process and of any documentation accessed or processed during the implementation of the required procedures.
3.3.6 Where the facts reported cannot be substantiated, no disciplinary action may be taken against the individual who submitted the report solely because it proved to be unfounded, unless that person’s conduct constitutes a separate harmful or improper act.
3.3.7 All documents and records obtained as a result of, or in connection with, a report must be retained in accordance with the applicable legislation and handled with the utmost discretion by the appointed Child Safeguarding Officers.
3.3.8 All reports must be formally acknowledged and addressed. Appropriate responses must also be provided to all reports and complaints in accordance with the provisions of this Policy [see also Goal 4].

GOAL 4

4.1 Building Links with Other Child Safeguarding Stakeholders

4.1.1 Effective collaborative relationships must be established with law enforcement authorities, agencies, and organisations involved in child safeguarding in order to facilitate the referral of safeguarding concerns and to benefit from specialist advice and support whenever such intervention becomes necessary.
4.1.2 Relevant local contacts should be identified in advance in order to facilitate referral procedures for cases requiring intervention or management by competent authorities or specialist agencies.
4.1.3 Child Safeguarding Officers are required to continue their professional development by participating in meetings, workshops, and training courses delivered by external bodies, associations, agencies, and organisations, with the aim of further enhancing their knowledge and expertise in child safeguarding matters.

4.2 Reports and Follow-up Measures

4.2.1 All reports, investigations, and the management of child safeguarding concerns must comply with the regulations adopted by FSGC–San Marino Academy, as well as with applicable legislation in force. Where consideration is given to referring a child to an external party for protection and support purposes, the legal framework and the child’s best interests must always be taken into account.
4.2.2 Accordingly, professionals such as doctors or psychologists may be involved in the reporting and support process, and their intervention must be duly recorded.
4.2.3 Referrals to local child protection authorities and law enforcement agencies must be made in accordance with the procedures and formats established by the applicable legislation.

GOAL 5

5.1 Ultimate responsibility for the implementation of the Policy and the Codes of Conduct rests with FSGC–San Marino Academy.
5.2 At least once a year, FSGC shall carry out an evaluation of the Policy and the Codes of Conduct, as well as their implementation across the territory and within affiliated clubs.
5.3 Based on this evaluation, an annual action plan should be developed to address any gaps in implementation, reduce risks, and resolve identified issues. This plan will involve the Child Safeguarding Focal Point, grassroots and youth sector managers, and any other relevant stakeholders.
5.4 On a periodic basis, FSGC will request affiliated clubs to provide an assessment of the situation within their organisations, in order to produce a consolidated national report.
5.5 This Child Safeguarding Policy is a living document that will be continuously updated and reviewed.
5.6 Periodically, FSGC may request an external evaluation of the implementation of the Policy and related procedures.

FINAL PROVISIONS

This Policy is adopted by FSGC and San Marino Academy on 05/08/2024 following approval by the FSGC Federal Council, and enters into force on the same date. FSGC–San Marino Academy may adopt guidelines or other documents deemed necessary for the implementation of this Policy.