Comprehensive child protection policy

EF High School Exchange Year has a zero-tolerance policy for any type of inappropriate behaviours, sexual abuse, physical abuse, neglect, emotional maltreatment or harassment toward students or other minors. Any suspected child abuse and/or neglect concerns will be immediately reported to the appropriate authorities.


Child Sexual Abuse Facts *

  • One in ten children will be the victim of sexual abuse before their 18th birthday.
  • 93% of abused children know, and perhaps even greatly trust, their abuser.
  • Child sexual abuse thrives in an environment of denial and fear.
  • The sexual abuse of a child often has lasting negative consequences for the child, the child’s family and community.
  • Childhood sexual abuse is never the fault of the child.



  1. Child Protection or Child Safeguarding: Individual, institutional and societal measures to protect the health, well-being and human rights of young people to live free from abuse, harm and neglect.
  2. Minor or Youth: Minor is generally legally defined as a person under the age of 18. However, in order to protect all students, EF HSEY will follow the same reporting procedures for 18-year-old students as for legal minors.
  3. Mandated Reporter: A person who, because of his or her profession or position, is legally required to report any suspicion of child abuse or neglect to the relevant authorities. The official designation of which professions are considered mandated reporters can vary. However, in most cases the definition includes anyone who works closely with a vulnerable population, such as children or the elderly.
  4. Code of Conduct: Short document that outlines the actions a group will take to protect children at a particular institution.
  5. Physical Abuse: Any intentional act causing injury or trauma to another person by way of bodily contact.
  6. Child Sexual Abuse: Any sexual act between an adult and a minor, or between two minors when one exerts power over the other.” It is important to understand that “child sexual abuse takes many forms, and they aren’t just physical.
  7. Consent: Consent is an agreement between participants to engage in sexual activity. It is an ongoing process of discussing boundaries and comfort. Consent cannot be given by individuals who are underage, intoxicated, under the influence of drugs, asleep or unconscious, or in unequal power dynamics.
  8. Child Neglect: The ongoing failure to meet a child's basic needs.
  9. Emotional Abuse: Continual emotional mistreatment of a child which can involve deliberately trying to scare, humiliate, manipulate, isolate, or ignore a child.
  10. Harassment: Any repeated or continuing uninvited contact that serves no useful purpose beyond creating alarm, annoyance, or emotional distress.
  11. Grooming: A deliberate process by which offenders gradually initiate and maintain sexual relationships with victims in secrecy.
  12. Commercial exploitation: Range of crimes and activities involving the sexual abuse or exploitation of a child for the financial benefit of any person or in exchange for anything of value (including monetary and non-monetary benefits) given or received by any person.

Training & Education

EF HSEY provides information on the topic of child sexual abuse prevention and response. We believe that knowledge is the first step in prevention.


Training for Students

According to the US Department of State Regulations for high school exchange programmes, “all sponsors must provide exchange students, prior to their departure from their home countries...age and language appropriate information on how to identify and report sexual abuse or exploitation.”


It is imperative that students feel confident coming forward if they have any concerns and know that at EF HSEY, student safety comes first. Before beginning their programme, students receive information on how to identify and report sexual abuse or exploitation as part of their pre-departure orientation materials.


In our safety training, students learn what are appropriate vs inappropriate interactions between adults and youth and between youth. The Compliance and Programme Support Team maintain records of students who have completed training. Prior to the programme, and while on exchange, students learn that they are encouraged to come forward with any concerns, that they will be listened to, and that they will never be in trouble for coming forward.


Additionally, students and their families will receive EF HSEY’s Comprehensive Child Protection Policy including the EF HSEY Code of Conduct.


Training for Staff

All EF HSEY staff who have direct contact and communication with students will receive annual training on child sexual abuse prevention and EF HSEY’s prevention policies and procedures.


The Programme Support Team specialises in student support and is in communication with students throughout their exchange. This team receives extensive training on child sexual abuse prevention and crisis response annually.

Screening & Hiring Practices

At EF HSEY, the safety and wellbeing of student participants is always a priority. Staff and host families undergo a screening process prior to onboarding or contracting and during annual renewal. Screening includes, but is not limited to, criminal background checks, references, and interviews. All families must report any concerns of student safety and welfare directly to EF HSEY. All families must acknowledge and sign EF HSEY’s Comprehensive Child Protection Policy including the EF HSEY Code of Conduct as part of contracting or onboarding.


Monitoring for Child Protection

  • EF HSEY will regularly screen and monitor participants through periodic in-person host family home visits and at least one in person visit per semester. Visits are both unscheduled and scheduled throughout the year.
  • Staff maintain ongoing communication with students and host families and provide a monthly recorded documentation of this communication to EF HSEY. These “Exchange Journey Updates” are reviewed by the Programme Support Team to assess student safety, wellness, and overall programme satisfaction.
  • The Programme Support Team is in communication with and available for students 24 hours a day, 7 days a week.
  • The Programme Support Team also conducts student surveys throughout the year as another means to assess for student safety and wellness and overall programme satisfaction.
  • Staff and host families are required to renew the criminal background check annually.

Adult to Youth Interaction

It is the responsibility of adults to set and protect appropriate boundaries with youth. Acknowledging the existence of child sexual abuse, sexual harassment, and grooming behaviours, helps to actively identify situations that could foster an abusive situation during a student’s programme year and take immediate steps to promote student safety.


Healthy Communication

EF HSEY’s Communications Policy defines healthy communication practices with minors as it relates to adult/youth cell phone communication, email expectations, and group messages. It is inappropriate for an adult to:

  • Comment on a child/student’s body or appearance inappropriately
  • Excessively text or message a child/student
  • Discuss sex, sexual experiences, or sexual relationships
  • Discuss intimacies of their marriage or adult relationships
  • Discuss sexually provocative jokes
  • Threaten a child/student to keep secrets from a trusted adult or EF
  • Shame a child/student to keep secrets from a trusted adult or EF
  • Isolate a child/student from forming healthy relationships with your peers
  • Communicate with a child/student in any way that makes them feel uncomfortable


Healthy Boundaries

It is important to always maintain healthy physical boundaries with students/children. Examples of appropriate physical contact include high five, fist bumps and side hugs.

It is inappropriate for an adult to:

  • Insist on hugging, kissing, wrestling, or massaging a child/student
  • Touch a child/student sexually in any way or in any personal areas
  • Walk in on a child/student unannounced in the bathroom or bedroom
  • Show a child/student pornography or other images containing nudity, or leave these images out in the open
  • Film or photograph a child/student inappropriately or without their consent
  • Display any sort of nudity or invite a child/student to display any sort of nudity
  • Provide drugs or alcohol to a child/student
  • Give gifts that are exclusive, excessive, or to be kept private
  • Physically interact with a child/student in any way that makes them feel uncomfortable

Youth to Youth Interaction

In the Safety training, students learn what are appropriate vs inappropriate interactions between adults and youth and between youth. Students and their families acknowledge and sign EF HSEY’s Comprehensive Child Protection Policy including the EF HSEY Code of Conduct prior to their programme.


Just as students are trained on their personal safety, they are also trained on respecting and protecting the safety of others. Students are trained on appropriate/inappropriate sexual behaviours, sexual harassment, consent, age of consent, sexting laws, safety on social media, and safety from drugs and alcohol.

Responding Procedure

At EF HSEY it is imperative that we work to create an environment where students feel confident coming forward if they feel unsafe or uncomfortable. Students are provided information on appropriate vs. inappropriate interactions between adults and youth, as well as between youth. Students are encouraged to raise any concerns of their safety and wellbeing and are ensured that they will not get in trouble for doing so.


Decide to Respond

When deciding how to respond to suspected, disclosed, or witnessed abuse EF HSEY encourages employees to follow the steps outlined in Darkness to Light’s Responsible Reaction Decision Tree that is found in the appendix.


React Responsibly

How we respond to concerns of abuse or other inappropriate behaviours can have a lasting impact on the child. When a child discloses:

  1. Express empathy: “I’m so sorry this happened to you.”
  2. Praise the child for telling: “I’m so proud of you for telling me,” or “you are so brave for telling me.”
  3. Believe: “I believe you. This is not your fault.”
  4. Accept the child’s feelings: “It’s ok to be scared/sad/mad.”
  5. Support the child: “I am here for you.”
  6. Don’t investigate: Ask only open-ended questions. Let the authorities do the investigation. Minimise the amount of times the child has to repeat the allegations.
  7. Tell the child what you will do. “We are going to talk to specialists who keep kids safe.”


It is not supportive or helpful to deny the concerns occurred, to blame the child for what happened, to question the validity of the concerns, to over protect the child, to emphasise the child as a victim, or to respond overly emotionally. It is also important to minimise the number of times the youth will need to repeat the allegations- to avoid secondary traumatisation.

Reporting Procedure

EF HSEY has a zero-tolerance policy for any type of sexual abuse, physical abuse, neglect, emotional maltreatment or harassment toward student participants or other minors and we immediately report concerns to the appropriate authorities. EF HSEY will report any allegations of inappropriate behaviour involving any minor, regardless of whether the minor is a programme participant.


File a Report

All EF HSEY staff must report to the appropriate local authorities and/or child protective services when they have received information that gives them any reasonable, good faith belief that a child’s health or well-being has been or may be endangered by abuse or neglect. This includes good faith suspicions of abuse or neglect regardless of whether or not a staff member has proof or can otherwise substantiate the suspicions. Once the report has been filed, further investigation into the concerns will be conducted by the authorities and other experts in this field.


Removing the student from harm’s way

If there is a concern for student safety, EF HSEY will take all reasonable and immediate steps to help protect the student’s wellbeing, which may include immediately removing the student from any potentially unsafe environment. Our student safety motto is to “act first, ask questions later.” At EF HSEY we have set escalation and reporting policies to quickly bring the student into a safe environment and to immediately involve the authorities.


Incident Investigation

At EF HSEY, staff, and host families are required to follow the mandated reporter guidelines of their state as well as report any knowledge or suspicions of inappropriate or unsafe behaviours to EF HSEY. EF HSEY will involve the appropriate authorities (child protective services, law enforcement, and child advocacy centres) to investigate the allegations or suspicions. A report will also be filed with the US Department of State, as they oversee J1 high school exchange programmes.

Review Process & Improvement

EF HSEY is committed to the prevention of child sexual abuse. EF HSEY will continually review our policies, procedures, screening, and support to provide as safe and as healthy of a programme as possible for students, staff, and host families