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1. Policy Statement

WingsWay Training Institute is committed to maintaining a safe, respectful, inclusive, and professionally managed environment for all learners, staff members, trainers, invigilators, visitors, and corporate stakeholders.

As an authorized training and examination centre operating in partnership with international awarding organizations—including CIPS (Chartered Institute of Procurement & Supply), IFPSM, IATA Training, CILT International, and CPD-SO accredited frameworks—WingsWay upholds a duty of care to ensure learner welfare, dignity, equality, and protection. Beyond general wellbeing, this policy sets out explicit, actionable, and incremental provisions to safeguard ‘vulnerable adults’ from abuse, exploitation, coercion, neglect, or discrimination across all physical and digital learning environments.

2. Definition & Specificity of 'Vulnerable Adults'

In alignment with CIPS guidelines and international safeguarding standards, a ‘Vulnerable Adult’ (or Adult at Risk) is defined as any person aged 18 or over who:

  • Has care and support needs (whether or not the local authority or institution is meeting any of those needs).
  • Is experiencing, or is at risk of experiencing, abuse, neglect, exploitation, or discrimination.
  • Is unable to protect themselves against significant harm, abuse, or exploitation as a result of those care and support needs.

In an educational and professional training context, vulnerability may be permanent or temporary, and may arise from factors including but not limited to:

  • Physical, sensory, cognitive, or learning disabilities, or neurodivergence.
  • Mental health conditions, severe stress, or emotional distress.
  • Communication impairments, language barriers, or digital exclusion.
  • Socio-economic vulnerability, displacement, or sudden life crises.
  • Disproportions in power dynamics within academic, workplace, or examination settings.

3. Scope of Policy

This policy applies universally across all WingsWay operations, including:

  • All enrolled learners, corporate clients, candidates, and exam examinees.
  • Trainers, assessors, invigilators, consultants, administrative staff, and management.
  • In-person classroom facilities, examination venues, and corporate client sites.
  • Virtual learning environments (VLEs), digital platforms, web conferencing, and official communication channels.

4. Specific Safeguarding Risks & Preventative Actions

WingsWay identifies specific safeguarding risks associated with vulnerable adult learners and mandates explicit operational risk mitigations:

4.1 Physical, Emotional, & Financial Abuse

  • Risk Identification: Coercion, intimidation, improper financial demands, or abusive conduct by staff, peers, or external parties.
  • Preventative Action: Zero-tolerance policy for coercion or exploitation; transparent fee structures; strict professional boundaries enforced between staff and learners.

4.2 Bullying, Harassment, & Online Exploitation

  • Risk Identification: Discriminatory remarks, cyberbullying, unauthorized recording, harassment in virtual breakout rooms, or digital exclusion.
  • Preventative Action: Virtual learning platforms are actively moderated by trainers; unauthorized session recording or screen-capturing is prohibited; strict digital conduct guidelines are enforced.

4.3 Academic Misconduct & Coercive Pressure

  • Risk Identification: Vulnerable learners being targeted, manipulated, or pressured into academic collusion or exam malpractice.
  • Preventative Action: Proactive academic integrity support; confidential guidance on assessments; clear separation between support resources and disciplinary panels.

4.4 Physical Safety & Accessibility Barriers

  • Risk Identification: Inaccessible facilities, inadequate emergency evacuation, or unsafe assessment environments for learners with physical impairments.
  • Preventative Action: Routine facility accessibility checks; individual emergency evacuation plans; Seamless integration with the Reasonable Adjustments Policy.

5. Institutional Safeguarding Governance

WingsWay maintains dedicated internal roles to manage safeguarding responsibilities effectively:

  • Designated Safeguarding Lead (DSL): Designated Safeguarding Lead (DSL) — Shakir Kantawala (Co founder & Managing Partner). The DSL holds overall institutional responsibility for receiving safeguarding reports, initiating risk assessments, and coordinating interventions.
  • Deputy Safeguarding Officer: Deputy Safeguarding Officer — Senior Academic Manager / Head of Faculty. Supports operational safeguarding, oversees online learning safety, and manages initial
    welfare referrals.
  • Duty of All Staff: All Staff & Invigilators — Obligated to uphold professional boundaries, identify signs of vulnerability or distress, and report any safeguarding concerns immediately.

6. Reporting, Investigation, & Escalation Procedure

WingsWay enforces a clear procedural workflow for handling safeguarding allegations or disclosures involving vulnerable adults:

  • Stage 1: Immediate Disclosure / Referral — Any learner or staff member who suspects, witnesses, or receives a disclosure of abuse, neglect, or harassment must report the issue to the Designated Safeguarding Lead within 24 hours.
  • Stage 2: Initial Risk Assessment — The DSL conducts an immediate risk assessment to ensure the victim’s immediate safety. All details are logged securely and confidentially.
  • Stage 3: Formal Investigation — A confidential internal investigation is conducted. The vulnerable adult is provided with support and guidance throughout the process without fear of retaliation.
  • Stage 4: Escalation & External Reporting — Where allegations are substantiated, disciplinary action, suspension, or termination of access will be enacted. If a law is broken or required by regulatory bodies (e.g., CIPS, KHDA, UAE Legal Authorities), the DSL will escalate the matter to external authorities immediately.

7. Online Learning & Digital Safeguarding

  • Active Platform Moderation: Trainers must maintain professional standards during virtual sessions and actively monitor chat and breakout rooms for signs of inappropriate conduct or harassment.
  • Professional Digital Boundaries: Unsanctioned one-on-one digital interactions between staff and vulnerable learners outside official learning management channels are prohibited.
  • Immediate Mitigation: Participants engaging in abusive or disruptive behavior during online training will be removed immediately from the session and flagged to the DSL.

8. Policy Review & Governance Alignment

This policy is reviewed annually by Institute Management to maintain alignment with: