Wednesday, September 20

Laws & Licensing

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Child Sexual Exploitation – Awareness

The sexual exploitation of children should not be considered to be a single act but an ongoing, often lengthy, process.  As a process, the opportunities to interrupt the same can be numerous.  Are you aware?

Regrettably, Child Sexual Exploitation (CSE) is not a new phenomenon, nor are the perpetrators limited to TV or Radio personalities of the 70s and 80s or any socioeconomic or racial profile or group.

The NPCC (National Police Chiefs’ Council) defines CSE as:

“Sexual exploitation of children and young people under 18 involves exploitative situations, contexts and relationships where the young person (or third person/s) receive ‘something’ (e.g. food, accommodation, drugs, alcohol, cigarettes, affection, gifts, money) as a result of them performing, and/or others performing on them sexual activities.”

Statistics show that 90% of offenders are male and 70% of that total are White.  The average age of an offender is 26.  The same data shows 80% of victims are female and 90% of that total white.  The average age of a victim is between 14 to 15 years.[1]

So, have you taken reasonable steps to detect and/or deter CSE in your business?

Responsible operators are aware of the benefits of good training. Customer experiences are improved, efficiencies are gained and regulatory interventions are reduced; these are just a few of the benefits.

Modern induction training often covers a range of subjects from drug policies and under age challenges to food hygiene and customer service. Does your induction training package include CSE training and if not, why not?

Grooming of victims takes place in all types of licensed premises and is not limited to any single sector.  Grooming can take any form including proxy purchases of alcohol from a pub or off licence, buying meals for vulnerable persons they are grooming, through to the renting of rooms in hotels to facilitate an assault.

We spoke to Christopher Grunert, a Partner at the solicitors firm John Gaunt & Partners, who specialise in advising the leisure industry.

We asked him, are there a list of ‘red flags’ an Operator can look out for?

“… Every business attempts to be distinct and promote their points of difference between themselves and their competitors, in the case of CSE risks this is also true.  Every business must assess their own distinct operation, no two business are identical.  For a business such as a hotel, a list of potential ‘red flags’ could include:

  • Guests refusing to provide credit card details and paying in cash, refusing to provide any form of identification,
  • Guests who live locally seeking to rent a room without explanation
  • Teenagers loitering near premises,
  • Guests requesting isolated rooms and/or appearing secretive,
  • Unexplained visitors to a guest’s bedroom from within the hotel or from the street,
  • Guests declining housekeeping,
  • Bedding being removed from the room,
  • Rooms with significant numbers of condoms or wrappers
  • Signs of drug or alcohol misuse.

[1] NPCC Regional Problem Profiles 2016

But, this is not a definitive list.  The danger, when preparing a training programme, is it to focus too much on creating a check list.  It may be preferably to engage with staff in manageable groups which facilitate discussion and ask them to come up with a list of ‘red flags’. To make staff ‘Aware’ of the possibility and how this should be tackled.

The existence of any number of these flags does not necessarily mean that CSE is occurring at your premises, but they should prompt your staff to look more closely at the situation. If they see something they should be trained to say something.

The aim of the training should be to raise awareness, not to give a definitive list.  Staff should be encouraged to report concerns and have a clear method for doing so.  The reporting policy can be more formal…

Through Police campaigns such as “Operation Make Safe”, enforcement authorities are increasingly testing that businesses in their communities reflect their core principles of:

  • Prepare: Provide strong local leadership and effective systems in partnership to tackle Child Sexual Exploitation.
  • Prevent: Raise awareness of Child Sexual Exploitation among the business community to prevent incidents / repeat incidents of Child Sexual Exploitation within their premises/environment.
  • Protect: Establish working practices that enable the safeguarding of vulnerable young people and support to victims.
  • Pursue: Establish a framework for a flow of intelligence and information to assist agencies to disrupt, arrest and prosecute offenders.

Staff training would clearly be in keeping with these principals.

CSE training should form part of any induction training programme within the hospitality sector, again we asked Christopher Grunert for any advice he may have for businesses creating a framework for CSE issues.

….I would suggest that the way forward for Operators is to be alert and be open to the possibility of their premises may be used for CSE activities and to ensure:

  • Staff are trained to be alert to the signs of such use.
  • Such training, as with other training, should be recorded and regular refresher training undertaken. We can assist with content, if required.
  • Hotels and premises providing accommodation need to be particularly alert to the possibility of CSE activity. For such premises, the authorities increasingly expect such policies to be in place and regularly reviewed.
  • Incident records should be maintained and periodically reviewed.
  • Protocols should be in place (and understood) as to how when and where to report potential or actual suspicious activities. Information is better the fresher it is, systems facilitate the information reaching the relevant authorities as quickly as possible.
  • Consider a way to share such reports within your locality with other businesses who may be affected.”
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