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Legal

Safeguarding Policy

Version 1.3In effect from 1 October 2026All policies

Version 1.3. Last updated: 1 October 2026. Review date: 3 September 2027.

1. Purpose and scope

1.1 mentorhero connects mentors with people seeking career advice and support. Most mentees are aged 18 to 30. Some are under 18, and some are adults who are vulnerable because of disability, illness, care needs or circumstances.

1.2 This policy sets out how we keep everyone safe, what we expect from the people taking part, and what happens when a concern is raised.

1.3 It applies to everyone using the platform: mentees, mentors, Business Clients, their executive sponsors and ambassadors, our own staff, and any contractor working on our behalf.

1.4 It is incorporated into the Platform Terms and Conditions and into every Partnership Agreement. Following it is not optional.

1.5 What this policy is not. mentorhero provides the platform, the rules and the safeguarding response. We do not supervise sessions live, we are not a crisis service, and we are not a substitute for a mentee's own support network or for a Business Client's own safeguarding duties towards its employees. Where a mentee is at immediate risk, the emergency services are the right route.

1.6 A Business Client remains responsible for its own people at all times. Nothing in this policy transfers to us the employment, supervision or disciplinary responsibilities that sit with an employer.

2. Our principles

2.1 The welfare of the mentee comes first. Where safeguarding and any other consideration pull in different directions, safeguarding wins.

2.2 Everyone has a part to play. Safeguarding is not only the job of the designated lead.

2.3 Concerns are acted on, not weighed up privately. If something feels wrong, report it. It is never the reporter's job to decide whether it is serious enough.

2.4 We act promptly, proportionately and without retaliation against anyone raising a concern in good faith.

2.5 We follow the Children Act 1989 and 2004, the Care Act 2014, Working Together to Safeguard Children, and the guidance of the relevant safeguarding partners.

2.6 We are a global platform. UK law and guidance set our baseline everywhere. Where local law in another country requires more, the higher standard applies. Where local law requires something different, we follow both wherever we can, and the safety of the mentee decides which comes first.

3. Who is responsible

Designated Safeguarding Lead (DSL) Leon Juice, Chief Business Officer. safeguarding@mentorhero.com

Out of hours leon@mentorhero.com

3.1 The DSL owns this policy, receives all concerns, decides on referrals, keeps the safeguarding record and reports to our board.

3.2 The DSL is contactable during UK working hours at the safeguarding address, and out of hours by email to leon@mentorhero.com. A Deputy Safeguarding Lead will be appointed as the team grows; until then, a concern that cannot wait goes to the out of hours address, and a concern about the DSL goes to the external route in 8A.

3.3 Every Business Client names an executive sponsor who is responsible for cooperating with us on any safeguarding matter involving their people.

3.4 Every mentor accepts the Mentor Terms before their profile goes live. It sets out the behaviour expected in every session.

3A. What we require from Business Clients

3A.1 Each Business Client maintains its own safeguarding policy covering its employees, and makes sure that anyone signing up as a mentor understands both that policy and this one.

3A.2 The Business Client is responsible for the suitability of its own mentors. That includes any background or suitability check, any enhanced DBS check required under section 5, and any professional registration a mentor relies on.

3A.3 The Business Client tells us immediately about anything that affects a mentor's suitability, including a safeguarding investigation, a disciplinary process, a change in DBS status, a barring decision, or the mentor leaving the business.

3A.4 The Business Client cooperates fully with any review we carry out, provides information we reasonably ask for, and does not take steps that would prejudice our review, a police investigation or a local authority referral.

3A.5 Where a concern involves one of its people, the Business Client does not contact the mentee, the mentee's family, or any other party involved, unless we agree it first.

3A.6 Press, social media and public enquiries about a safeguarding matter are referred to us. Neither of us comments publicly on a live concern.

3A.7 The Business Client holds the insurance set out in the Platform Terms and provides evidence on request.

3A.8 A failure to meet this section is a material breach under section 18 of the Platform Terms.

3A.9 The Business Client tells us, before a mentor is activated, whether that person has ever been subject to a safeguarding allegation, a barring decision, a dismissal on conduct grounds, or a professional sanction. Withholding that is a material breach, and the Business Client is responsible for anything that follows from it.

3A.10 We may require a Business Client to pause its participation, or to stand down a group of mentors, while a serious concern is reviewed. Fees continue to run during a pause of that kind, and the pause does not extend the term.

3A.11 Where a concern arises from something a Business Client did or failed to do, including an inaccurate background check confirmation or a failure to tell us about a change in a mentor's status, the Business Client meets the reasonable costs of our investigation, any independent review, any notification we have to make, and any legal or insurance costs we incur.

4. How we reduce risk by design

4.1 All sessions happen on the platform. Mentoring is virtual micro-mentoring, delivered through platform video. Contact outside the platform, including personal email, phone, social media and messaging apps, is prohibited and is a material breach.

4.2 Mentors are approved before activation. A profile goes live only once it is complete and we have approved it. Approval is at our discretion.

4.3 Mentors need 18 months of work experience to sign up. Experience alone is not enough, and we may decline anyone.

4.4 Sessions may be recorded for safeguarding, quality assurance and training. Participants are told so in the terms they accept, and are responsible for telling anyone else who may be seen or heard during a session.

4.5 We monitor platform messaging for indicators of grooming, solicitation, off-platform contact and other harm, and we act on what we find.

4.6 No personal contact details are shared through profiles or messaging. Attempts to exchange them are flagged.

5. Mentees under 18 and vulnerable adults

5.0 Mentors must be 18 or over. There is no exception to this.

5.1 We ask every mentee for their date of birth at sign-up, and we ask whether they need any additional support to take part safely.

5.2 Where a mentee is under 18, or is classed as a vulnerable adult, one of the following must apply before a session goes ahead:

(a) a parent, guardian or carer attends the session with them; or (b) the mentor holds a valid enhanced DBS check, or the equivalent check in the country where they are based, recorded with us before the booking.

5.3 The platform will not offer a booking that meets neither condition. This is enforced in the product, not left to the mentor or the mentee to police.

5.4 For a mentor who is a Business Client's employee, contractor or representative, the Business Client obtains the enhanced DBS check, sees the certificate, and confirms to us that it is valid and current. That confirmation is a warranty under clause 7.9 of the Platform Terms.

5.5 The Business Client tells us immediately if a mentor's DBS status changes, if a mentor becomes subject to a safeguarding investigation, or if a mentor leaves their business.

5.6 An accompanying adult stays present for the whole session. A session does not continue if they leave.

5.7 Mentees must be 16 or over. We cannot accept anyone under 16, in any circumstances. Where local law sets a higher minimum age for online services, that age applies instead.

5.7B Where a mentee is 16 or 17, both of the following apply, and neither replaces the other:

(a) a parent or guardian must give consent before the mentee can be matched with a mentor. A guardian can withdraw that consent at any time, which stops future sessions, and can choose to be notified about sessions; and

(b) the mentee is matched only with a mentor who holds a valid enhanced DBS check, or the equivalent check in the country where that mentor is based, recorded with us before the booking.

5.7BB Mentors choose their own age range at onboarding. Every mentor states whether they are willing to mentor 16 and 17 year olds, or 18 and over only. A mentor who has not opted in is never offered a booking with a 16 or 17 year old, whatever their background check says, and a mentor can change that choice at any time. Opting in is not enough on its own: the background check in 5.7B(b) still applies.

5.7C For a mentee aged 16 or 17, the accompanying-adult route in 5.2(a) is not an alternative to the background check. A parent, guardian or carer may attend, and is welcome to, but a 16 or 17 year old is never matched with a mentor who has not been background checked.

5.7A Where the age of majority in a mentee's country is above 18, we treat them as a minor until they reach that age.

5.8 We keep a record of which mentors hold a current enhanced DBS check and when it was confirmed. Confirmations are refreshed at least every three years, or sooner where we have reason to.

5.9 We rely on the date of birth and support needs a mentee gives us, and on the DBS confirmation a Business Client gives us. Both are provided as accurate. Where either is false or out of date, we act on it as soon as we know, but we are not responsible for the consequences of relying on information we were given in good faith.

5.10 Giving a false age to gain access to the platform is a breach of our Community Standards. Where we find it, we close the account and, where the person is a child, we follow section 8.

5.11 Where a Business Client cannot confirm a mentor's enhanced DBS check, that mentor is not matched to any mentee under 18 or any vulnerable adult. There is no discretion on this and no exception for urgency.

5A. Working across countries

5A.1 Mentors and mentees take part from many countries. Sessions regularly cross borders and time zones.

5A.2 Where a mentor is outside the UK, the equivalent of an enhanced DBS check in their country applies. Common equivalents are the Working with Children Check or National Police Check in Australia, Garda vetting in Ireland, state and FBI criminal background checks in the United States, an RCMP vulnerable sector check in Canada, and the national police certificate elsewhere. The Business Client identifies the right check, obtains it, sees it and confirms it to us. Where no equivalent exists in that country, the mentor is not matched to a minor or a vulnerable adult.

5A.3 A check obtained in one country does not clear a mentor to mentor minors in another where local law requires its own. Where both apply, both are needed.

5A.4 Where a mentor is subject to a mandatory reporting duty in their country, they follow it. Reporting to us is in addition to that duty, never instead of it.

5A.5 Referrals go to the safeguarding authority with jurisdiction over the mentee, not over the mentor. Where that is unclear or the mentee is in a country whose authorities we cannot reach, we refer in the UK, contact the relevant embassy or consular service where appropriate, and record the limits of what we could do.

5A.6 The DSL keeps a current list of referral routes for every country where we operate, and reviews it at least every 12 months.

5A.7 Our out of hours contact operates in UK time. Anyone anywhere facing an immediate risk should contact their local emergency services first.

6. What we expect in every session

6.0 Every session is 30 minutes, virtual, and arranged through mentorhero. Cameras stay on throughout. Mentors and mentees do not exchange personal contact details, connect on social media, or arrange to meet in person, and all contact stays on the platform.

6.1 Mentors give general career advice and support. They must not give mental health, medical, legal or regulated financial advice unless professionally qualified and acting within that qualification.

6.2 Mentors must not arrange to meet a mentee in person, offer money, gifts or favours, promise a job, or ask a mentee for anything.

6.3 Mentors must not discuss their own or the mentee's personal relationships, sexual matters, or anything else that has no place in a career conversation.

6.4 Photographs, screenshots and recordings by participants are prohibited.

6.5 If a session becomes uncomfortable for either person, either may end it immediately without explanation and report it afterwards.

6.6 Where a mentee discloses something that suggests they are at risk, the mentor does not investigate. They listen, do not promise confidentiality, end the session appropriately, and report it straight away.

7. Reporting a concern

Anyone with a concern reports it immediately to the DSL at safeguarding@mentorhero.com.

7.1 In-platform reporting is available on every profile and in every session, and reaches the DSL directly.

7.2 Report the same day wherever possible, and never later than 24 hours. Do not wait for proof.

7.3 A report should say what happened, when, who was involved, what was said or seen, and what the reporter did. Record the words used rather than an interpretation of them.

7.4 Anyone can report: mentee, mentor, Business Client, sponsor, ambassador, parent, carer or member of our team.

7.5 Reports made in good faith are protected. Nobody is penalised for raising something that turns out to be unfounded.

7.6 If someone is in immediate danger, call 999 first. Report to us afterwards.

8. What happens next

8.1 The DSL acknowledges the report within one working day.

8.2 We may immediately suspend a mentor, restrict platform access, or pause a mentoring relationship while we look into it. Suspension is a neutral step, not a finding.

8.3 The DSL reviews the report, gathers what is available including any recording and any messages sent during the session, and decides on the response within five working days, or sooner where the risk is high.

8.4 Where a child or vulnerable adult may be at risk, the DSL refers to the relevant local authority safeguarding team, the LADO where the concern is about someone working with children, and the police where a crime may have been committed. We do not delay a referral to complete our own review.

8.5 Where the concern involves a Business Client's mentor, we inform that client's executive sponsor in writing. Internal disciplinary action is the client's responsibility. Removal from the platform is ours.

8.6 We tell the person who raised the concern that it has been dealt with. We do not share the detail of the outcome, because it usually concerns someone else's personal data.

8.7 Outcomes may include no further action, a warning, additional conditions, suspension, permanent removal from the platform, or referral to the DBS where the legal duty to refer applies.

8A. Allegations about our own people

8A.1 An allegation about a member of the mentorhero team is reported to the DSL.

8A.1B Where the allegation is about the DSL, it does not go to the DSL. It goes directly to the Local Authority Designated Officer (LADO) for the local authority where the DSL works, and, where a crime may have been committed, to the police. Both routes are in section 11. We publish an external route rather than an internal one because the DSL is also an officer of the company, and an internal escalation would be worth little.

8A.2 The person is removed from any contact with mentees while the matter is reviewed.

8A.3 Where the allegation concerns someone working with children, we refer to the LADO within one working day, and we make a DBS referral where the legal duty applies.

8A.4 We tell any affected Business Client that a matter is being handled, without sharing detail that would identify individuals or prejudice a review.

8B. Raising a concern about how we handled something

8B.1 Anyone who believes a safeguarding concern has been handled badly, ignored, or covered up can escalate it outside mentorhero, without telling us first and without needing our permission. The routes are the LADO for the relevant local authority, the NSPCC helpline, and the police, all listed in section 11. Nothing in this policy, in any contract, or in any confidentiality obligation prevents anyone from doing so.

8B.2 Escalation can be made anonymously. Nobody is penalised for raising a concern in good faith, and any retaliation is itself a disciplinary matter.

8B.3 If someone is still not satisfied, they can go to the local authority safeguarding team, the ICO, or the police directly. Nothing in our terms prevents that, and no confidentiality obligation applies to it.

9. Records and confidentiality

9.1 Safeguarding records are kept securely, separately from ordinary account data, and are accessible only to the DSL, the Deputy and anyone with a genuine need.

9.2 Records are retained for [7] years from the date of the concern, or longer where a case is ongoing or where a statutory retention period applies.

9.3 Information is shared on a need to know basis. Safeguarding is never a reason to withhold information from a statutory authority, and data protection is never a reason to delay a referral.

9.4 Every concern is logged with the date received, who raised it, what was reported, what we did, who decided, when, and why. The log records decisions not to refer as well as referrals.

9.5 The DSL reports to our board at least quarterly on the number and type of concerns, the outcomes, and any pattern that needs a change to how we work.

9.5A Our safeguarding decisions are final as far as the platform is concerned. Removing or suspending a mentor is a safeguarding judgement, not a service failure, and it does not entitle a Business Client to a refund, a credit, an explanation of our full reasoning, or a right to appeal on that person's behalf.

9.6 We provide each Business Client with an annual safeguarding assurance statement covering our training, our review, and the number of concerns raised across the platform, in aggregate and without identifying anyone.

10. Training and review

10.1 Every member of our team completes safeguarding training on joining and refreshes it annually. The DSL and Deputy hold role-appropriate training at a higher level.

10.2 Mentors complete a safeguarding briefing during onboarding and accept the Mentor Terms before activation.

10.3 We brief every Business Client's executive sponsor on this policy at launch.

10.4 This policy is reviewed at least every 12 months, and immediately after any serious incident or relevant change in the law.

11. External contacts

  • Emergency: 999
  • NSPCC Helpline: 0808 800 5000
  • Childline: 0800 1111
  • Local authority safeguarding teams: found through the relevant council website
  • LADO: contacted through the local authority where the person works
  • Disclosure and Barring Service: 03000 200 190
  • Child Helpline International lists the service in each country at childhelplineinternational.org
  • Outside the UK: contact local emergency services first, then the national child protection or adult safeguarding authority for that country. The DSL holds the current country list.

11A. If you are under 18

Your mentor is there to talk about work and careers, nothing else. A mentor should never ask for your phone number or social media, ask you to keep secrets from your parent or guardian, say anything sexual or comment on how you look, ask you for photos, or suggest meeting in person.

If any of that happens, it is not your fault and you will not be in trouble. Tell us at safeguarding@mentorhero.com, or tell your parent or guardian, or any adult you trust. You can end a session at any moment, for any reason, and you never have to explain.

If you would rather talk to someone outside mentorhero, in the UK you can call Childline free on 0800 1111, at any time.

mentorhero Mentorhero Limited, company number 16861069, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. Safeguarding: safeguarding@mentorhero.com