The Berlitz School Estate - A Guide to Site Management

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1 Inspection report Organisation name Berlitz (UK) Ltd, London Inspection date 5-7 February 2014 Section standard Met Not met Management: The management of the provision will operate to the benefit of its students, in accordance with its publicity and in accordance with the Declaration of legal and regulatory compliance. Resources and environment: The learning resources and environment will support and enhance the studies of students enrolled with the provider, and will offer an appropriate professional environment for staff. Teaching and learning: Teachers will have appropriate qualifications and will be given sufficient support to ensure that their teaching meets the needs of their students. Programmes of learning will be managed for the benefit of students. The teaching observed will meet the requirements of the Scheme. Welfare and student services: The needs of students for security, pastoral care, information and leisure activities will be met; any accommodation provided will be suitable; the management of the accommodation systems will work to the benefit of students. Care of under 18s section Met Not met There will be appropriate provision for the safeguarding of students under the age of 18 within the organisation and in any leisure activities or accommodation provided. Recommendation We recommend continued accreditation. Publishable statement The British Council inspected and accredited Berlitz (UK) Ltd, London in February The Accreditation Scheme assesses the standards of management, resources and premises, teaching and welfare and accredits organisations which meet the overall standard in each area inspected (see for details). This private language school offers courses in general and professional English for adults and under-18s. The inspection report stated that the organisation met the standards of the Scheme. Report expires 31 March 2018

2 Organisation profile Inspection history First inspection 2009 Last full inspection 2009 Subsequent spot check (if applicable) 2010 Subsequent supplementary check (if applicable) 2012 Subsequent interim visit (if applicable) Current accreditation status Other related schools / centres /affiliates Other related non-accredited activities (in brief) at this centre Private Sector Date of foundation 1901 Ownership Other accreditation/inspection Dates/details Accredited Berlitz Windsor (directly owned and managed by Berlitz), Berlitz franchised schools in Birmingham, Brighton, Edinburgh, Manchester and Oxford, and about 550 directly owned Berlitz schools around the world. At Berlitz London, foreign language instruction, Global Leadership Training, and Berlitz Virtual Classroom (online and phone lessons).` Berlitz International Inc (USA), owned by Benesse Group in Japan. Premises profile Address of main site Details of any additional sites in use at the time of the inspection (location/normal use of site/when used/number of rooms used) Details of any additional sites not in use at the time of the inspection Inspectors note of sites inspected High Holborn, London WC1V 7JH TI Centre, 233 High Holborn, London WC1V 7DN High Holborn is the main site. It occupies the whole of the second floor of an eight-floor office block dating from the 1930s and consists of 20 small and medium-sized classrooms suitable for one-to-one lessons and small groups. There are also five offices, a teachers' room, a student common room, a small self-study room and a large reception area. A second premises, the TI (Total Immersion) Centre, opened in July 2012 at 233 High Holborn. These premises are on the fourth floor and were spot-checked in They provide 12 classrooms, a teachers' room, an admin office, a student common room and kitchenette and a reception area. Both premises, which are leased, are appropriately decorated and equipped. Student profile At inspection In peak week (organisation s estimate) Of all international students, approximate percentage on ELT/ESOL courses peak week in July ELT/ESOL Students (eligible courses) At inspection In peak week Total ELT/ESOL student numbers (FT + PT) Full-time ELT (15+ hours per week) 18 years and over Full-time ELT (15+ hours per week) aged years 1 1 Full-time ELT (15+ hours per week) aged under Part-time ELT aged 18 years and over 3 3 Part-time ELT aged years 0 0 Part-time ELT aged under 16 years 0 0 Minimum age (including closed group or vacation) 4 (on exception - separate arrangements made for u18s) Advertised minimum 18 for most 4 (on exception - separate arrangements made for u18s) Advertised minimum 18.

3 courses. Typical age range Typical length of stay 2-3 weeks 2-3 weeks Predominant nationalities Russian, Ukrainian, Qatari, Spanish, Russian, Ukrainian, Qatari, Spanish Argentinian Number on PBS Tier 4 General student visas 0 0 Number on PBS Tier 4 child visas 0 0 Number on student visitor visas 7 16 Number on child visitor visas 3 3 Staff profile At inspection In peak week (organisation s estimate) Total number of teachers on eligible ELT courses Number teaching ELT under 10 hours/week 7 Number teaching ELT hours/week 5 Number teaching ELT 20 hours and over/week 10 Total number of administrative/ancillary staff 9 Academic staff qualifications to teach ELT/TESOL Profile at inspection Professional qualifications Total number of teachers Diploma-level ELT/TESOL qualification (TEFLQ) - Certificate-level ELT/TESOL qualification (TEFLI) 20 Holding specialist qualifications only (specify) - YL initiated - Qualified teacher status only (QTS) - Rationale(s) required for teachers without appropriate ELT/TESOL qualifications 2 Total 22 These figures exclude the academic manager(s) Two teachers employed during the week of the inspection were not working during the inspection. Course profile Eligible activities Year round Vacation Other - General ELT for adults (18+) General ELT for juniors (under 18) English for academic purposes (excludes IELTS preparation) English for specific purposes (includes English for Executives) Teacher development (excludes award-bearing courses) ESOL skills for life/for citizenship Run n Run n Run n

4 Other Most ELT courses run are one-to-one (70-80%). There are also various group and combination (group and one-toone) courses available, including closed group courses. Some of the latter include under 18s. Junior courses are run exceptionally, separate from the adult courses, and with separate arrangements made. Examination preparation is available on request. Accommodation profile Number of students in each at the time of inspection (all ELT/ESOL students) Types of accommodation Adults Under 18s Arranged by provider/agency Homestay Private home Home tuition Residential Hotel/guesthouse 2 Independent self-catering e.g. flats, bedsits, student houses Arranged by student/family/guardian Staying with own family Students own arrangements 31 3 Introduction Berlitz London is a well-established school teaching English and foreign languages to individuals and small groups. Most of its students are paid for by their companies, take very intensive short courses which are wholly or partly taught on a one-to-one basis, have come to London specifically to attend the course, and arrange their own accommodation. Occasionally the school accepts under 18s: either children studying with a parent or yearolds in closed groups from corporate clients, but these are exceptional. Typical students are executives in their 30s and 40s. Foreign language teaching has declined since the last inspection and now accounts for only about 20% of the school s business. The school is owned by Berlitz International Inc. of Princeton, New Jersey, which in turn is owned by the Japanese Benesse Group. The Berlitz corporation is an international language teaching, translation and publishing company, with about 500 directly owned schools worldwide and many franchises. The directly owned schools in the UK, Berlitz London and Windsor, report to the Berlitz regional director based in Brussels, and use common procedures and systems. London and Windsor each have separate accreditations. There are also five independently owned franchised UK schools, licenced to use the Berlitz name, method and materials. The Berlitz method, essentially a direct method, uses an approach not at variance with mainstream language teaching methodology widely used today. Berlitz produces its own teaching and learning materials which form a core part of the design of almost all its English and foreign language courses. A number of changes have been made to the senior general and academic management of the school in the last year. This inspection was originally due to take place in April 2013, and has been postponed several times. The present language centre director (LCD), who was recruited externally, has been in post since early December This inspection took three days. The inspectors had meetings with the LCD, the director of studies (DoS), the assistant director of studies (ADoS), the study abroad/homestay coordinator, the office coordinator, and the consumer sales manager, and met other key members of staff. They interviewed groups of students and teachers and observed lessons by all but one of the teachers. One inspector visited one of the homestays organised by the school. Supplementary documentation was submitted and assessed after the inspection, on the invitation of the committee, concerning the newly-introduced Care of under 18s section.

5 Management Legal and statutory regulations Criteria M1 Declaration of compliance M1 The items sampled were satisfactory. Staff management M2 Management structure M3 Duties specified M4 Communication channels M5 Human resources policies M6 Qualifications verified M7 Induction procedures M8 Monitoring staff performance M9 Professional development M2 This is generally clear, but the role of the DoS, which includes both Berlitz London and Berlitz Windsor, needs clarification. M3 There are job descriptions for all staff which, the inspectors were told, are reviewed every four years. However, the descriptions are not dated so it is not clear when the reviews took place. M4 Channels of communication appear effective at all levels. There are weekly staff meetings, s and a friendly atmosphere. Staff particularly praised the availability and openness of the new LCD. M5 There are well-developed human resource policies operating throughout the Berlitz group. M6 There is a procedure for investigating and verifying the qualifications and experience of all prospective employees. In the staff files sampled, although a few documents were missing, they were generally well-organised and up to date. They include a cover-sheet and, among other documents, certified copies of qualifications, ID and CVs, initial Berlitz training records and feedback and a signed code of corporate conduct. The inspector also took the opportunity to check the files of the teachers at Berlitz Windsor, files which were not available in Windsor at the recent interim inspection as they are held at present in London. Although there were a few minor omissions they were generally satisfactory. M7 There is a set induction procedure following a checklist and including health and safety which is signed off when complete. Staff receive a copy. M9 There is a CPD policy and evidence of its implementation. Internal teacher training workshops, which are paid, take place, and there are regular observations with feedback and encouragement to attend external workshops. Administrative staff are given training to meet their needs. Student administration M10 Administrative staff and resources M11 Information on course choice M12 Enrolment procedures M13 Student records M14 Student attendance policy M15 Conditions and procedures

6 M13 There is an effective system to maintain up-to-date records of students local and emergency or next-of-kin contact details. However, some of these records are kept by the study abroad/homestay coordinator in his office offsite and therefore might not be accessible at all times to staff at the school responding to an emergency. Quality assurance M16 Action plan M17 Continuing improvement M18 Student feedback and action M19 Staff feedback and action M20 Complaints M16 The November 2010 spot check detailed how most of the points raised in the 2009 inspection had been addressed. The new LCD had reviewed the points and. A few points continue to require action but these are commented on under the relevant criteria. M18 Students are given a brief, well-designed first impressions questionnaire, the results of which are shared with their teachers. The questionnaire, however, does not ask about accommodation in those instances where it is arranged by the school. At the end of their course, students are invited by to complete an online customer satisfaction survey, sent to them by an independent company. This recently introduced system is achieving a return of only about 30%, which calls into question its effectiveness. Publicity M21 Accessible accurate language M22 Realistic expectations M23 Course description M24 Course information M25 Cost M26 Accommodation M27 Leisure programme M28 Staff qualifications M29 Accreditation M22 Publicity is generally accurate and raises realistic expectations. However, the claim that At the end of your course you will be presented with your Berlitz Diploma showing the Berlitz level you achieved should be reworded since there is no formal assessment of a student s English language level at the end of the course. M23 The course descriptions are generally accurate although course titles vary from one medium to another. M24 The minimum enrolment age(s) for different courses are not clearly stated. Total tuition time in number of hours per week is now given (unlike in 2009) but is inaccurately stated, as the figure includes a five minute break in each 45-minute lesson. Thus, for instance, the taught hours for the 25-lesson course are given as 18¾ hours whereas they should be 16hrs 40mins. M26 Publicity does not make clear that the school may use accommodation agencies. M27 The school offers no organised leisure programme although it provides help and advice to individual s queries. M28 The claim, You can be assured of a dedicated teaching team of the highest quality and experience cannot be substantiated. (The description of staff qualifications and experience was also raised as a point to be addressed at the last inspection.) M29 This criterion is generally met, but the brochure mentions eberlitz Online Learning, which is not eligible for accreditation.

7 Management summary The provision meets the section standard. The management of the school is responsive to its students needs and operates efficiently to their benefit. Although some details of publicity require attention, it is generally accurate and raises realistic expectations. Resources and environment Premises and facilities R1 Adequate space R2 Condition of premises R3 Classrooms and learning areas R4 Student relaxation facilities R5 Signage and display R6 Staff room(s) R2 Both the main school and the TI Centre are well maintained, smartly decorated and appropriately furnished for adult executive students. R3 In the main school, the sound insulation between rooms is in some cases poor; this was commented on both by teachers and students. R4 At both centres there are very pleasantly comfortable areas for students to relax in, with free tea and coffee. R6 Both centres have staff rooms, appropriately furnished and equipped with learning resources, work spaces and relaxation facilities for teachers. Learning resources R7 Learning materials R8 Resources for teachers R9 Educational technology R10 Self-access facilities R11 Library/self-access guidance R12 Review and development R7 Students are provided with Berlitz paper, audio and online learning materials appropriate to their level, and with supplementary and specialist materials in support, including ESP materials. There is also a Berlitz magazine of articles taken from various magazines published by Time Inc. Students are provided with access to Berlitz online materials for a year after their course. All learning materials are included in the price. The centrally-produced Berlitz materials are in American English, a fact that the students the inspectors spoke to regarded, if anything, as an advantage as they complement the British English of their teachers. R9 There is satisfactory provision of educational technology in the main school. At the TI Centre, the technology available includes ipads in each classroom linked to a large screen. Teachers have received training in its use. R10 Although students have good access to computers and the internet in both centres, including to Berlitz s own online materials, there are no dedicated self-access or library facilities in either centre. R12 The Berlitz core materials, produced at ten levels, are periodically reviewed and updated centrally in response to feedback from teachers and students. Resources and environment summary The provision meets the section standard. The school s premises provide comfortable and appropriate learning environments for the executive students the school enrols, and the learning materials and resources support and enhance their studies. The premises and resources also provide a pleasant and supportive professional environment for the staff.

8 Teaching and learning Academic staff profile T1 General education (and rationales) T2 ELT/TESOL teacher qualifications T3 Rationales for teachers T4 Profile of academic manager(s) T5 Rationale for academic manager(s) T1 Seven of the 22 teachers scheduled to teach in the week of the inspection did not have a level 6 qualification. At the 2010 spot check this weakness was also raised: there were six. Although rationales were provided for them, this high proportion of teachers without a level 6 qualification does not meet the Scheme s requirement. T2 Two teachers did not have ELT qualifications that met Scheme requirements. T3 Rationales were provided for the two teachers, and were accepted within the context of this inspection. T4 The DoS is appropriately qualified and experienced, He is on a 0.4 part-time contract and conducts observations and supports the full-time ADoS. The latter, who has a certificate-level ELT qualification, has worked for Berlitz for more than 20 years and has been in post in London since Academic management T6 Deployment of teachers T7 Timetabling T8 Cover for absent teachers T9 Continuous enrolment T10 Support for teachers T11 Observation and monitoring T6 Teachers are allocated with care to students on the basis of a needs analysis which is usually conducted before the student arrives. T7 In theory there is a sound procedure for timetabling students, teachers and rooms, but it is sometimes difficult to follow in practice because of the Berlitz cancellation policy. That policy, common to all Berlitz schools, allows oneto-one students to cancel their classes without penalty by noon of the preceding day. Teachers may therefore find themselves without work at short notice. To rectify this, the school can allocate them to another student, but in the process will reduce the second teacher s timetable. In a spirit of give and take, staff agree that this practice is the fairest solution available. However, it does mean that students need to check who is teaching them each day and that the continuity of teacher and teaching may be disrupted. The cancellation policy may be appropriate in overseas schools where students need to cancel lessons at short notice due to changes in their work schedule. In this school it causes difficulties with timetabling and has a negative impact on continuity. T9 In publicity and briefings by sales persons, it is not always made clear to new students joining a group course that the class may have already started and that therefore they may join a course some way through the book assigned for that Berlitz level. T10 New teachers have training and an initial qualification in the Berlitz materials and approach and all teachers have access to the online Berlitz training modules. There are also periodic in-house training sessions, with notes and hand-outs circulated to teachers who cannot attend. Course design and implementation T12 Principled course structure T13 Review of course design

9 T14 Course outlines T15 Study and learning strategies T16 Linguistic benefit from UK T13 Course design is managed by Berlitz centrally and periodically reviewed in response to feedback from students and teachers. T16 Most students are in the UK for a relatively short time. Within that context, the provision meets this criterion s requirements although a more systematic approach would further benefit the students. Learner management T17 Placement and level T18 Monitoring students progress T19 Examination guidance T20 Assessment criteria T21 Academic reports T22 Information on UK education T22 The school is not one selected by students who aim to enter UK mainstream education. Classroom observation record Number of teachers seen 19 Number of observations 19 Parts of programme(s) observed Small groups and one-to-one. Of the 22 teachers timetabled during the week, two were not working on site during the inspection days and one was not seen because her teaching timetable did not coincide with the scheduled observations. Classroom observation T23 Linguistic systems of English T24 Appropriate language T25 Planning content T26 Coherent and relevant activities T27 Classroom management T28 Teaching techniques T29 Student engagement T30 Sensitivity and learning atmosphere T23 Most teachers showed a good awareness of the linguistic systems of English and modelled well. Where rules were given, they were given in accessible language. Explanations of vocabulary items were more variable, and students in some lessons would have benefited if a dictionary had been consulted. T25 In a minority of lessons, the content was too book-bound and did not take the needs of the student into account, or was not sufficiently challenging. However, in most lessons, teachers were skilful in adapting course materials to engage with their students experiences and learning objectives.

10 T27 The quality of board-work was variable. In one or two one-to-one lessons, a more collaborative approach with student and teacher sitting together rather than student sitting and teacher standing by the board would have probably been more appropriate. However, in the great majority of lessons the classroom environment and resources were well managed, and at the TI Centre the inspectors observed some excellent use of the ipads and screens. T28 A range of appropriate techniques was observed, including role-play, effective elicitation, careful phrasing of questions to maximize student talking time and the sensitive repetition of a task until the student had achieved the desired learning outcome to his/her own satisfaction. In a small number of lessons there was not enough checking of students understanding by teachers, or of listening carefully to what the student was really trying to say. There were also one or two instances of unprepared reading aloud, for instance of dialogues, by students. Feedback to students, with encouragement and correction, was generally handled well. Self-correction was successfully encouraged and there was some effective correction and practice of pronunciation. T30 In all the lessons observed, there was good rapport between students and teachers and a positive learning atmosphere. Classroom observation summary The teaching observed met the requirements of the Scheme, and ranged from satisfactory to very good. Most teachers were sensitive to their students needs and were able to adapt the teaching materials successfully to students lives and learning objectives. However, a few teachers relied too heavily on the course book and did not personalise the materials sufficiently. In most cases, teaching techniques were appropriate and classroom resources were used well. Students received positive feedback, encouragement and correction and in almost all cases were clearly enjoying and fully engaged in their lessons. Teaching and learning summary The provision meets the section standard. Although a rather high proportion of the teachers do not have a Level 6 qualification, their ELT/TESOL qualifications and experience are appropriate for the courses being delivered, and they are given sufficient support to ensure their teaching meets the needs of their students. Courses are effectively designed to match the individual requirements and objectives of the students. The teaching observed met the requirements of the Scheme. Welfare and student services Care of students W1 Safety and security onsite W2 Pastoral care W3 Personal problems W4 Dealing with abusive behaviour W5 Emergency contact number W6 Transport and transfers W7 Advice W8 Medical and dental treatment W1 Both premises are secure. At the main school a security officer on the ground floor checks all visitors before they are allowed to go up to the school. At the TI Centre there is a video entry system operated by the Berlitz receptionist. Students are informed of fire safety procedures on arrival; information is also included in the student handbook. Students receive sensible advice on safeguarding their own property. W2 Staff are told to seek help at the reception desk if they have personal problems and are passed on to other members of staff if necessary. Students commented that they were well supported by both administrative staff and their teachers. There is an informal understanding that spare classrooms may be used for religious observance. W3 At the time of the inspection, no one person was identified as having overall responsibility for dealing with personal problems. A revised student handbook was provided after the inspection. This makes clear that the centre director is responsible for welfare issues. W4 Appropriate policies and procedures are in place for both students and staff. The policy relating to students is set out in the student handbook. Staff who feel they are the victims of bullying or harassment can report incidents using a free Berlitz telephone helpline, available to all Berlitz employees worldwide. Details of this service are

11 included in the staff handbook and are displayed in the staff room. W7 All required information is in the student handbook. At the time of the inspection the handbook included information about London and Windsor. It was suggested that references to Windsor should be removed to avoid confusion. The revised student handbook has information about London only. W8 The student handbook has information about the local NHS walk-in centre, NHS Direct, health insurance, registration with a GP, and dental and optician services in the UK. Staff provide further information and support on request. Accommodation profile on the accommodation seen by the inspectors Most students make their own accommodation arrangements. At the time of the inspection no students were in accommodation arranged by the school. The school has a register of six host families and has no plans to recruit new hosts. All hosts are well known to the school and have accepted students for many years, some for over twenty years. The school accepts groups of corporate clients on short courses. Two accommodation agencies, both registered with the British Council, provide homestay accommodation for these groups. The school s accommodation service is managed by the former centre director who works from home. under criteria W9-W21 relate to the six hosts on the school s homestay register. One of these hosts was visited. She was friendly, welcoming and showed a great interest in her students. The house was located in a pleasant area of north London with good local facilities and easy transport links to the school. The provision easily met the requirements of the Scheme. Accommodation: all types W9 Services and facilities W10 Accommodation inspected first W11 Accommodation re-inspected W12 Accommodation registers W13 Information W14 Student feedback W15 Meals in homestay/residences W9 The services and facilities required are set out in the homestay policy document. W10 The homestay providers have all worked with the school for many years. All were inspected before students were placed. It was noted that there are no plans to recruit more hosts. W11 Hosts are revisited annually, most recently in September W13 Homestay information is sent to the student with the course confirmation. Detailed host profiles, including photographs of the house and student room, are provided. W14 Students are asked by staff about their satisfaction with their homestays, but the first impressions questionnaire does not include any questions on accommodation. The student handbook does not make clear who students should contact if they have problems with accommodation. Both these points were raised in the reports following the last full inspection and the spot check in 2010 and remain to be addressed. Any complaints are dealt with satisfactorily through the school s action request procedure. Accommodation: homestay W16 No more than four students W17 Rules, terms and conditions W18 Shared bedrooms W19 Students first language W20 Language of communication

12 W21 Adult to welcome W17 Rules, terms and conditions are clearly set out for the guidance of hosts. Annual gas safety certificates are required and copies are kept on file. However, hosts are not informed of the legal requirement to carry out a basic fire risk assessment. Accommodation: residential W22 Cleaning W23 Health None. Accommodation: other W24 Information and support W25 Other accommodation W24 Students very rarely enter into contracts with private landlords. Advice is available on request. W25 The school maintains a list of local hotels and apartment hotels which it recommends to students. Students benefit from preferential rates if they book through the school. Leisure opportunities W26 Events and activities W27 Leisure programmes W28 Health and safety W29 Responsible person W26 Some tourist information is available in reception, including leaflets about weekend excursions aimed at overseas students. Administrative staff and teachers give suggestions on how students can make the most of London. The school has season tickets to a London football club; students can use these on request. W27 The school does not advertise or organise a leisure programme, apart from an informal early-evening weekly pub visit for students and staff. Welfare and student services summary The provision meets the section standard. Premises are safe and secure and students are well cared for. Homestay provided by the school is of a good standard and is generally well-managed, although some improvements are required. The school does not offer a leisure programme. Care of under 18s C1 Safeguarding policy C2 Guidance and training C3 Publicity

13 C4 Recruitment materials C5 Suitability checks C6 Safety and supervision C7 Accommodation C8 Contact arrangements

14 C1 A safeguarding policy for under 18s is in place. Following the inspection, a more detailed document was produced. This includes a code of conduct for staff and group leaders accompanying corporate closed groups which may include 16 and 17 years olds. It also includes the school s safer recruitment policy and guidelines on dealing with any allegations which may arise. A parental information and consent form sets out rules for under 18s who attend courses with their parents. The centre director is named as the person with overall responsibility for the safeguarding of under 18s. C2 The centre director has had Level 1 safeguarding training. In-house training on safeguarding procedures for under 18s is planned for February A new Information for group leaders document provided after the inspection sets out the duties and responsibilities of group leaders for any 16 and 17 year olds in their care. C3 The school does not advertise courses for under 18s. C4 Applicants are informed of the checks which may be made. C5 All members of staff have signed declarations of suitability for working with under 18s. Suitability checks are being carried out on staff who have substantial access to under 18s. Inspectors noted that most teachers assigned to under 18s had undergone suitability checks with previous employers and had relevant experience of this age group. C6 In the case of under 18s accompanied by parents, the parent assumes full responsibility for their child or children outside lesson times. At the time of the inspection no rules were provided for 16 and 17 year olds attending corporate closed group courses, apart from curfew times imposed by the homestay accommodation agencies. The revised student handbook includes behaviour guidelines for under 18s, as well as details of the support available from the school, for example a welfare tutorial on arrival. C7 In the case of under 18s accompanied by parents, no accommodation is provided by the school. In the case of 16 and 17 year olds attending corporate closed group courses, appropriate homestay accommodation is provided by two accommodation agencies, both registered with the British Council. Care of under 18s summary The provision meets the section standard. The school has a detailed safeguarding policy for under 18s. Under 18s receive appropriate guidance and support. Group leaders accompanying corporate closed groups which may include under 18s are made aware of their duties and responsibilities in ensuring the safety and welfare of the under 18s in their care. Systems for ensuring the safety and well-being of under 18s accompanied by their parents are in place and are fully implemented. Suitability checks have not yet been carried out for all staff who have substantial access to under 18s.

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