CHARTERED INSTITUTE FOR SECURITIES & INVESTMENT FUTURE FOUNDATION

(CISI Future Foundation or ‘the Charity’)

Policies

  • Safeguarding Policy
  • Speak Up & Listen Up Policy
  • Privacy Notice
  • Equal Opportunities Policy

SAFEGUARDING POLICY

  1. Introduction

    The Charity’s objects are to advance knowledge and improve skills in financial capacities and capabilities, in particular but not exclusively through the provision of grants and promotion of research and dissemination of such research.

    The Charity will work in partnership with organisations and charities that fulfil its charitable objectives. The Charity itself will not have direct regular contact with children or vulnerable people, therefore, when identifying potential partners the Charity will check their safeguarding policies, records and practice. Safeguarding is defined as the range of measures in place to protect people in the Charity or those it comes into contact with from abuse or maltreatment of any kind.

    1. The Charity is committed to ensuring that it provides a safe and trusted environment which safeguards and promotes the welfare and wellbeing of anyone who comes into contact with the Charity, including its consultants, employees, Trustees and other volunteers, partners, donors and beneficiaries, and other stakeholders.
    2. The Trustees recognise that they are ultimately responsible for ensuring that those benefiting from, or working with, the Charity, are not harmed through contact with it and are treated in a safe, respectful, and appropriate manner. This responsibility relates in particular to young people (i.e. those under 18 years of age) and vulnerable persons including the elderly and adults at risk.

  2. Scope

    1. This safeguarding policy (the Policy) applies to all consultants, employees, Trustees and other volunteers, as well as any other person associated with the Charity.
    2. This Policy aims to deter, minimise and remove opportunities for the abuse of those who come into contact with the Charity and its work, in particular children, young people and adults at risk; and provide consultants, employees, Trustees and other volunteers with the overarching principles that guide the Charity’s approach to safeguarding.
    3. The Chairperson of the Charity, and the *Designated Safeguarding Lead (DSL) Trustee are required to undergo a Disclosure and Barring Service (DBS check).
    4. The Charity has an administrative services level agreement (SLA) in place with the Chartered Institute for Securities & Investment (CISI).

  3. Other policies

    1. This Policy should be read in conjunction with any other applicable operational policies, which may be adopted by the Charity from time to time.
    2. The Charity’s policies are located on the CISI’s local network.

  4. Summary of Key Safeguarding Responsibilities

    1. The Charity acknowledges the importance of the Charity Commission’s guidance on safeguarding and the following safeguarding requirements:
      1. providing a safe and trusted environment which safeguards consultants, employees, Trustees and other volunteers and any other person associated with the Charity,
      2. setting an organisational culture that prioritises safeguarding, so that it is safe for those affected to come forward and report incidents and concerns with the assurance they will be handled sensitively and properly;
      3. having adequate safeguarding policies, procedures and measures to protect people; and
      4. providing clarity as to how incidents and allegations will be handled should they arise, including reporting to the relevant authorities, such as the Charity Commission.
    2. The Trustees recognise that it is their responsibility to set the overarching principles and governance strategies that guide the Charity’s approach to safeguarding.

  5. Policy Statement

    1. Safeguarding and promoting well-being and welfare means protecting the rights of persons to live in safety, free from abuse and neglect.
    2. The Charity believes that all persons, without exception, have the right to protection from bullying, harassment (including sexual harassment), physical or emotional abuse and exploitation and takes a zero-tolerance approach to these behaviours. Discrimination, prejudice or oppressive behaviour or language in relation to any of the following are not acceptable: race, colour, sex, gender, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status.
    3. The Charity acknowledges that safeguarding does not encompass only the prevention of physical abuse but also the protection of people from harm generally, including neglect, emotional abuse, exploitation and the consequences of the misuse of personal data.

  6. Partner Organisations

    1. As part of its due diligence in relation to potential partner organisations with which the Charity may fund or partner, the Charity will seek confirmation that such organisations have in place adequate safeguarding arrangements, including appropriate policies and mechanisms to provide assurance on compliance.
    2. All partners working with the Charity are required to comply with this Policy.
    3. The Charity is committed to supporting Grantees in safeguarding issues but may refuse / withdraw funding in the most serious cases of failure of safeguarding.

  7. Procedures

    1. The Trustees will ensure there are adequate Safeguarding, Confidentiality and Speak Up and Listen Up policies and procedures in place for the Charity and its work and will review these, along with their application, regularly.
    2. If a consultant, employee, Trustee or other volunteers have or are made aware of a safeguarding concern, this should be raised with the Chairperson of the Charity, or the DSL, who will follow the Charity’s reporting procedure to make a formal record and obtain advice on the action required.
    3. The Charity’s **Manager is delegated responsibility for the day to day implementation of this policy, together with the DSL who will review the policy and report to the Board of Trustees annually.
    4. Where applicable, in relation to the Charity’s grant making activities, the Charity will:
      1. include in its standard grant Terms and Conditions a requirement to confirm that the grant recipient have in place adequate safeguarding arrangements, including appropriate policies and mechanisms to provide assurance on compliance; and
      2. establish and enforce clear lines of responsibility and reporting between the grant recipient and the Charity.

  8. Serious Incident Reporting

    1. The Charity will respond to all suspicions, allegations and safeguarding incidents swiftly and appropriately and take professional advice where appropriate. This may include reporting to the appropriate entities, including police forces, any relevant national authorities and the Charity Commission for England and Wales (Charity Commission).
    2. The Trustees acknowledge the Charity Commission’s guidance on how to report a serious incident and in the safeguarding context, their duty to make a serious incident report to the Charity Commission in the event:
      1. of an incident where someone has been, or has alleged to have been, abused or mistreated and this is connected with the Charity’s activities;
      2. a beneficiary(ies) has been, or is alleged to have been, abused or mistreated while under the Charity’s supervision, or by someone connected with the Charity, for example, a Trustee; and/or
      3. the Charity’s procedures or policies relating to safeguarding matters have been breached and this has placed beneficiaries at risk.

  9. Implementation of Policy

    1. This Policy will be provided to all consultants, employees, Trustees and other volunteers as part of their induction and they will be required to confirm by email that they have read and understood the policy. Training will be provided annually on this Policy to Trustees.
    2. Failure to comply with this Policy will be considered as gross misconduct and potentially grounds for removal.

  10. Monitoring and Review

    1. This Policy will be reviewed at least annually by the Trustees or more frequently should circumstances dictate or when relevant legislation changes.

*Designated Safeguarding Lead: Responsible for the implementation of the Safeguarding and Speak Up & Listen Up policies and reviewing the policies on an annual basis

**Manager: Responsible for administration matters concerning routine meetings, Board papers for discussion, expenses and travel, authorising Level 2 to commit to spend payments, and any ad hoc tasks bestowed by the Board.

Last reviewed by the Board: 22/04/2024

SPEAK UP & LISTEN UP POLICY

  1. Introduction

    The Speak Up & Listen Up Policy (the Policy) sets out the framework for dealing with concerns of illegal and improper conduct.

    The Charity is committed to the highest standards of transparency, probity, integrity and accountability.

    This Policy is intended to provide a means of raising concerns about standards, conduct, financial irregularity or possible unlawful action, in a way that will ensure confidentiality and protect those raising such concerns in the reasonable belief that it is in the public interest to do so from being victimised, discriminated against or disadvantaged.

    This Policy is intended to ensure that the Charity complies with its duty under the Public Interest Disclosure Act 1998.

  2. Scope

    This policy applies to the Trustees as well as any other person associated with the Charity.

    This Policy applies to, but is not limited to, concerns about any of the following:
    • Conduct which is an offence or breach of the law
    • Alleged miscarriage of justice
    • Serious Health and Safety risks
    • The unauthorised use of public funds
    • Possible fraud and corruption
    • Sexual, physical or verbal abuse, or bullying, or harassment, or intimidation of employees, or customers or service users
    • Abuse of authority
    • Other unethical conduct
    This Policy should be read in conjunction with any other applicable operational policies, which may be adopted by the Charity from time to time.

    The Charity’s policies are located on the Chartered Institute for Securities & Investment (‘CISI’) local network.

  3. Reporting

    Contact Details for Reporting (in writing):

    Nick Swales (Chairperson) or Debbie Clarke (*Designated Safeguarding Lead)
    CISI Future Foundation
    20 Fenchurch Street
    London
    EC3M 3BY

    The Charity recognises that the decision to raise a concern can be difficult. However, those who speak up in the reasonable belief that it is in the public interest to do without fear of victimisation or discrimination because they are doing their duty either to the Charity and/or to those for whom the Charity are providing a service for.

    The Charity will take appropriate action to protect anyone who speaks up in the reasonable belief that it is in the public interest to do so from any reprisals, harassment or victimisation.

  4. Confidentiality

    All concerns will be treated in confidence and every effort will be made not to reveal the identity of the individual who raised the concern unless the individual requests otherwise. However, this may not always be possible if the matter is subsequently dealt with through other Charity policies.

    Similarly, if the concern results in court proceedings, then the individual may have to give evidence in open court if the case is to be successful.

    The Charity will not, without the individual’s consent, disclose the identity of said individual to anyone other than a person involved in the investigation/concern.

  5. Anonymous Concerns

    This Policy encourages those who speak up to put their name to a concern wherever possible as anonymous concerns may often be difficult to substantiate/prove. Concerns made anonymously are much less powerful but anonymous concerns will be considered at the discretion of the Charity Chairperson / Board of Trustees.

    In exercising discretion to accept an anonymous concern the factors to be taken into account:
    • The seriousness of the issue raised
    • The credibility of the concern; and
    • Whether the concern can realistically be investigated from factors or sources other than the complainant

  6. Untrue Concerns

    No action will be taken against an individual who speaks up and raises a concern in the reasonable belief that it is in the public interest to do so even if the concern is not substantiated by an investigation. However, action may be taken against an individual who speaks up and raises a concern without reasonable belief that it is in the public interest to do so (e.g. raising a concern frivolously, maliciously or for personal gain where there is no element of public interest).

  7. Procedure for Raising a Concern

    It is preferable for concerns to be made to the Charity Chairperson. However, this may depend on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if the individual who speaks up believes that the Chairperson is involved it would be inappropriate to raise it directly with them. The individual may then raise the concern directly with the Designated Safeguarding Lead (DSL).

    If either of the above are notified of a concern, they will consider the concern and may discuss it with the other Trustees. The Chairperson (or either/or both) of the above, after consideration, will discuss the concern with the individual who spoke up to determine if they wish to proceed with the concern and an investigation.

  8. Concerns

    Whether a written or oral report is made it is important that relevant information is provided including:

    • The name of the person raising the concern and a contact point (if not anonymous).
    • The background and history of the concern (giving relevant dates and names and positions of those who may be in a position to have contributed to the concern);
    • The specific reason for the concern. Although someone raising a concern will not be expected to prove the truth of any concerns, they will need to provide information to the person they have reported to, to establish that there are reasonable grounds for the concern.
    Someone raising a concern may be accompanied by another person of their choosing during any meetings or interviews in connection with the concern. However, if the matter is subsequently dealt with through another policy, the right to be accompanied will at that stage be in accordance with the relevant policy.

  9. Action on receipt of a concern

    The Chairperson and/or the DSL will record details of the concern, gathering as much information as possible, (within 5 working days of receipt of the concern) including:
    • The record of the concern:
    • The acknowledgement of the concern;
    • Any documents supplied by the individual speaking up
    The Chairperson and/or the DSL will ask the individual speaking up for their preferred means of communication and contact details and use these for all communications with the individual in order to preserve confidentiality.

    If the concern relates to fraud, potential fraud or other financial irregularity the Chairperson and/or the DSL will be informed within 5 working days of receipt of the concern. The Chairperson and/or the DSL will determine whether the concern should be investigated and the method of investigation.

    If the concern discloses evidence of a suspected criminal offence, it will immediately be reported to the Board of Trustees and a decision will be made as to whether to inform the Police. If the concern involves suspected harm to children and/or vulnerable adults, the Safeguarding Policy should be referred to.

  10. Timetable

    An acknowledgement of the concern in writing within 10 working days with:
    • An indication of how the Charity propose to deal with the matter
    • An estimate of how long it will take to provide a final response
    • An indication of whether any initial enquiries have been made
    • Information on support mechanisms for the individual speaking up
    • Indication whether further investigations will take place and if not, why not
    The Chairperson and/or the DSL will aim to keep the individual speaking up informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent them giving specific details of the investigation or any action taken as a result.

    Where the concern has been made anonymously the Charity will be unable to communicate what action has been taken.

  11. Support

    The Charity will take steps to minimise any difficulties which may be experienced as a result of raising a concern. For instance, if the individual speaking up is required to give evidence in criminal or disciplinary proceedings the Charity will arrange for them to receive advice about the procedure and advise on the support mechanisms that are available.

    The Charity accepts that those speaking up need to be assured that the matter has been properly addressed. Thus, subject to legal and/or confidentiality constraints, we will inform those raising concerns of the outcome of any investigation.

  12. Responsibility for the Policy

    The **Manager and the DSL have overall responsibility for the operation of this Policy and for determining the administrative processes to be followed and the format of the records to be kept.

  13. Monitoring

    A Register will record the following details:
    • The name and status (e.g. supplier) of the individual speaking up
    • The date on which the concern was received
    • The nature of the concern
    • Details of the person who received the concern
    • Whether the concern is to be investigated and, if yes, by whom
    • The outcome of the investigation
    • Any other relevant details
    The Register will be confidential and only available for inspection by the Board of Trustees.

    The Manager will report annually to the Board of Trustees on the operation of the Policy and on any concerns raised during the period covered by the report. The report will be in a form which does not identify those speaking up.
*Designated Safeguarding Lead: Responsible for the implementation of the Safeguarding and Speak Up & Listen Up policies and reviewing the policies on an annual basis

**Manager: Responsible for administration matters concerning routine meetings, Board papers for discussion, expenses and travel, authorising Level 2 to commit to spend payments, and any ad hoc tasks bestowed by the Board.

Last reviewed by the Board: 22/04/2024

PRIVACY NOTICE

  1. Who we are

    The Charity is registered in England and Wales (number 1201304) and is a company limited by guarantee and registered in England and Wales (number 13918024).

    The Charity’s objectives are:
    The advancement of education for the public benefit by advancing knowledge and improving skills in financial capacities and capabilities, in particular but not exclusively through the provision of grants and promotion of research and dissemination of such research.

    The Charity is also affiliated with the Chartered Institute for Securities & Investment (‘CISI’), headquartered at 20 Fenchurch Street, London, EC3M 3BY.

    CISI is the leading professional body for securities, investment, wealth and financial planning professionals. Formed in 1992 by London Stock Exchange practitioners, it has a global community in over 100 countries. Each year more than 40,000 CISI exams are sat in 80 countries, 15,000 outside the UK.

  2. Your data privacy

    The Charity is a data controller and committed to protecting the rights of individuals in line with data protection legislation.

    This Privacy Notice was created in view of the requirements of the UK General Data Protection Regulation (‘UK GDPR’) and all other relevant privacy legislation. We may change this policy from time to time to reflect changes in the law or in the provision of our services.

    The Charity has an appointed *Data Protection Representative who can be contacted by email via futurefoundation@cisi.org.

  3. What information we may collect about you

    We process a limited amount of personal information which is outlined below.

    TypeDescription
    Personal and ContactName, date of birth, gender, your address, and contact details for your Directors and/or Trustees and/or senior management
    IdentificationCopies of photographic legal identification documents for your Directors and/or Trustees and/or senior management to support grant applications.
    Socio-EconomicDetails of any financial interest held by your Directors and/or Trustees and/or senior management that may present a Conflict of Interest with your grant application.
    National IdentifierA reference given to your Directors and/or Trustees and/or senior management by a regulated body to identify who you are, such as a Charity number.

  4. Why we collect personal information

    In order to fulfill our legal and regulatory obligations, and for us to conduct appropriate due diligence for recipients of our grants, we require you to provide personal information to allow us to:
    • Verify the identities of your Directors and/or Trustees and/or senior management;
    • Identify and query any Conflicts of Interest there may be in your grant application;
    • Provide updates relating to your grant applications;
    • Provide granted funds upon the success of an application.
    Failure to provide required information may mean that we cannot appropriately scrutinise your grant application and may result in your application being rejected.

  5. Where we collect personal information from

    We may collect information about you from these sources:

    Data you give to us:
    • When you make contact with us by email;
    • When you talk to us on the phone
    • When you complete a grant application form;
    • In surveys.
    Data that is publicly available:
    • Data relating to your entity that is available on Companies House or the Register of Charities;
    • Information that is available through your entity’s website;
    • Information that is made available through social media;
    • Information that has been published in physical or digital media.

  6. How we use your personal information

    We may use personal information to:
    • To validate your registered entity;
    • To evaluate your registered entity in the interest of due diligence;
    • To validate the information provided by you about your registered entity;
    • To validate the information provided by you about your registered entity’s Directors and/or Trustees and/or senior management;
    • To contact you to query, progress, and deliver a decision upon your grant application.

  7. Our legal bases for using your personal information

    • Where it is in our legitimate interests to do so;
    • To comply with our legal obligations;
    • With your consent.

  8. Who we share your personal information with

    • CISI, acting as a data processor, in order to process grant applications and respond to any queries that you may raise;
    • Companies you ask us to share your data with;
    • Any relevant Regulator, where there is a lawful basis to do so.

  9. International data transfers

    The Charity operates internationally, therefore we may transfer information to countries outside the United Kingdom for the purposes described in this policy where necessary, relevant and proportionate.

    Where we are required to do so in order to fulfil our objectives, we will ensure that such transfers are conducted in a lawful and transparent manner and that such transfers are essential for provision of our services and fulfilment of our objectives.

  10. Marketing

    We may, with your consent, publish case studies with limited personal data of your Directors and/or Trustees and/or senior management on our website and/or the CISI’s website and social media presence in describing the awarding of grants to your firm.

    In addition to UK data privacy laws, marketing communications are additionally subject to the Privacy and Electronic Communications Regulations (PECR).

  11. How long we keep your personal information

    We will keep your personal information for the duration of the application process and thereafter. Following the outcome of your grant application, we may keep your data for one of these reasons:
    • To respond to any questions or complaints;
    • To maintain records according to rules and regulations that apply to us.
    We may keep your data if we cannot delete it for legal or regulatory reasons, and we may also keep it for statistical purposes. If we do, we will make sure that your privacy is protected and your data is only used for those purposes.

  12. Information security

    All systems and services upon which personal data is stored are owned and operated by CISI, and subject to strict access controls.

    We have ensured that there are appropriate technical and organisational measures to safeguard the personal information we collect in connection with our services.

  13. Your rights under data protection laws

    As a data subject you have certain rights under data protection laws:
    • The right to be informed
    • The right to request access to your personal information
    • The right to have your personal information corrected
    • The right to object to certain processing of your personal information
    • The right to restrict processing of your personal information
    • The right to have your personal information erased
    • The right to move, copy or transfer your personal information
    • Rights in relation to automated decision-making.
    Please note that under certain circumstances, your right to have your personal information erased may be limited.

    We ask that you keep us informed if your personal information changes during your relationship with us.

  14. How to get a copy of your personal information

    You can access the personal information we hold on you by emailing futurefoundation@cisi.org or by writing to us at this address:

    Data Protection Representative
    CISI Future Foundation
    20 Fenchurch Street
    London
    EC3M 3BY

    If you have any queries about the Charity and Data Protection, please feel free to contact the Data Protection Representative.

    You also have the right to contact the Information Commissioner’s Office (see ico.co.uk).
*Data Protection Representative: Responsible as the point of contact for internal and external queries relating to data protection and for facilitating any and all necessary compliance with data protection legislation.

Last reviewed by the Board: 22/04/2024

EQUAL OPPORTUNITIES POLICY

  1. Introduction

    The Charity is committed to promoting equality, diversity, and inclusion in all aspects of its operations and activities. We believe that everyone should have an equal opportunity to contribute, succeed, and thrive, regardless of their background, identity, or circumstances. This Equal Opportunities Policy (this Policy) outlines our commitment to fostering an inclusive environment where all individuals are treated with respect and dignity.

    This Policy should be read in conjunction with any other applicable operational policies, which may be adopted by the Charity from time to time.

  2. Aims and Objectives

    This Policy aims to:
    1. Eliminate discrimination, harassment, and victimization.
    2. Promote an inclusive and diverse culture that values the contributions of all individuals.
    3. Provide fair and equal opportunities for recruitment, training, development, and advancement.
    4. Ensure that decisions regarding employment, projects, and funding are based on merit and skills.
    5. Create an environment where all individuals can work and engage free from discrimination, bullying, and harassment.

  3. Responsibilities

    1. The Board of Trustees will be responsible for overseeing the implementation of this policy and ensuring its effectiveness.
    2. This Policy applies to all consultants, employees, Trustees, and other volunteers of the Charity.
    3. All consultants, employees, Trustees, and other volunteers of the Charity have a duty to promote and implement equal opportunities in their areas of responsibility.

  4. Implementation

    1. Recruitment and Selection: We will ensure that our recruitment and selection processes are fair and transparent, focusing on the skills and qualifications required for the role.
    2. Training and Development: We will provide equal access to training and development opportunities for all individuals, regardless of their background.
    3. Promotion and Advancement: Opportunities for promotion and advancement will be based on merit and potential, with no discrimination.
    4. Harassment and Bullying: We have zero tolerance for harassment and bullying and reports of such should be made according to the Charity’s ‘Speak Up & Listen Up Policy’.

  5. Reporting and Monitoring

    1. We encourage individuals to report any instances of discrimination, harassment, or unequal treatment. Complaints will be taken seriously, investigated promptly, and appropriate action will be taken in line with the Charity’s ‘Speak Up & Listen Up Policy’ and/or ‘Disciplinary Policy’.
    2. We will regularly review and monitor the effectiveness of this policy to ensure its continuous improvement.

  6. Communication

    We may use personal information to:
    1. This policy will be communicated to all consultants, employees, Trustees, and other volunteers of the Charity. It will also be made available to the public on our website.
    2. We will promote awareness and understanding of this policy through training, workshops, and other appropriate means.

  7. Conclusion

    The CISI Future Foundation is dedicated to providing equal opportunities for all individuals, promoting diversity, and fostering an inclusive environment. We believe that by upholding these principles, we can contribute to a fairer and more just society and empower individuals to reach their full potential.


Last reviewed by the Board: 22/04/2024