Child Protection Policy

Purpose and scope

Shotocup is committed to protecting children from abuse, neglect, exploitation and avoidable harm. The welfare of a child takes priority over results, rankings, event schedules, sponsorship and the reputation of an individual, club or organisation. This approach reflects the purposes and welfare principle of the Bermuda Children Act 1998. (Sections 5 and 6.)

This policy covers everyone under 18 involved in activities organised or controlled by Shotocup, including tournaments, workshops, demonstrations and awards events. It applies to directors, organisers, coaches, referees, judges, volunteers, contractors, medical personnel, photographers, participating clubs, parents, athletes and spectators. A child remains protected even when entered in an adult division. (Section 2.)

The policy covers event preparation, registration, competition, warm-up and changing areas, official communications, media, and any transport or accommodation arranged by Shotocup. Clubs must cooperate with these requirements whenever participating in a Shotocup activity.

Immediate action and reporting contacts

Protect the child. Report required information or reasonable suspicions directly to the Director of Child and Family Services without delay. Do not wait for proof, parental consent, an internal investigation or permission from a senior organiser. (Section 20.)

If DCFS cannot be reached, contact police promptly for assistance and continue efforts to report directly to DCFS. Record attempts and confirm receipt. Contacting a club, federation, event organiser or police does not replace the report to the Director required by section 20.

Policy owner: Shotocup Director. The safeguarding lead and deputy must be appointed before activities involving children begin. Official event inboxes and registration forms must not be presented as emergency reporting services.

This draft uses the supplied Act and the official consolidated text checked on 11 October 2026. Legal citations identify statutory provisions; event safeguards are Shotocup requirements. Complete the approval fields and obtain Bermuda legal review before adoption.

01Recognising harm and understanding the duty

A child is a person under 18 for the purposes relevant to this policy. Significant harm includes ill-treatment or impairment of health or development, with specific circumstances listed in section 3. Ill-treatment includes sexual abuse and non-physical harm. The following summary does not replace those statutory conditions. (Sections 2 and 3.)

• Physical harm and sexual abuse, including specified substantial risks and failures to supervise or protect a child. (Section 3(a) to (d).)
• Unmet medical needs, serious emotional harm, or serious developmental impairment where the conditions concerning necessary help and parental provision or consent in the Act are met. (Section 3(e) to (h).)
• Harm or substantial risks associated with repeated domestic violence, serious neglect, inadequate basic care or supervision, and parental substance abuse or other injurious behaviour, subject to the particular statutory conditions. (Section 3(i) to (l).)
• Abandonment, dangerous behaviour and other circumstances listed in section 3(m) to (q). Staff should seek immediate DCFS advice where the application of these provisions is uncertain.

Warning signs in sport may include unexplained injuries, fear of a particular adult, sexualised contact or messages, humiliating treatment, unsafe training, concealed injuries, repeated exclusion, or a child saying they do not feel safe. Grooming, online exploitation, bullying and harmful behaviour between children must be taken seriously. Indicators require attention; they are not proof of abuse.

Disability, neurodivergence, poverty, culture or communication differences must not be treated as evidence of abuse or as reasons to dismiss a disclosure. Offer accessible reporting, communication assistance and reasonable adjustments. Consider the child’s views and any risks affecting siblings or other athletes.

02Who must act

Section 20(1) requires every person with information indicating that a child is suffering or has suffered significant harm to report it immediately to the Director. Section 20(2) requires people performing professional or official duties concerning a child to report reasonable suspicions arising in those duties; the listed roles include youth or recreational leaders and health professionals.

As an internal standard, all Shotocup personnel must act on reasonable safeguarding concerns and report directly to DCFS when the section 20 threshold is met. Where uncertain, seek DCFS advice promptly. A person’s paid or volunteer status, seniority or club affiliation must never be used as a reason to ignore a concern.

Shotocup’s Director provides resources and appoints a trained lead and deputy. The lead coordinates advice, records and follow-up; the deputy covers absence or conflicts. Event officials may stop an unsafe activity. Clubs and parents must follow the supervision plan. Every reporting person remains responsible for making their required report; telling the lead does not transfer that duty.

03Responding to concerns and disclosures

3AMake the child safe

Stop the activity where necessary and call 911 for immediate danger or urgent medical care. Provide first aid within competence. Keep the child with suitable support in a safe place and seek DCFS or police direction about any unsafe collection or return home. Do not confront an alleged abuser. Staff must not assume powers to detain or remove a child; the Act assigns specific protective powers to courts, the Director and police. (Sections 39 to 41.)

3BListen without investigating

Remain calm, allow the child to speak and take the account seriously. Explain that they did the right thing by telling someone and are not to blame. Say that information may need to be shared with people who can help keep them safe. Do not promise secrecy or a particular outcome.

Ask only minimal, non-leading questions needed to understand the concern and immediate safety. Do not suggest answers, require repeated accounts, test the child’s story, question other children as an investigation, or arrange mediation with the alleged abuser. Respect privacy without isolating the child with an unfamiliar adult.

3CReport without delay

Call DCFS using the contacts on page 1. Give the child’s name, age and location if known, the nature of the concern, the information supporting it, immediate risks, the alleged person’s access to children, and any other children potentially affected. Identify what is observed, reported by someone else or uncertain. Missing details must not delay the call. (Section 20(1) and (2).)

Do not wait for an event to finish, a club head to agree, an incident form to be completed or proof to be obtained. Section 3 includes specified substantial risks; action must not wait for an injury. Ask for the recipient’s name, a reference where available, instructions and a secure route for any written follow-up. Record failed contact attempts and confirm receipt.

If a child withdraws or changes their account, record and report the change without deleting the original. Withdrawal does not automatically end the concern. Section 20A provides that child sexual-offence investigations or proceedings may continue after withdrawal of a statement or complaint.

3DRecord notify and follow up

As soon as immediate safety and reporting allow, normally the same working day, complete Appendix B. Record exact words where possible, times, observations, questions asked and actions taken. Inform the safeguarding lead or an uninvolved deputy without delaying the external report and protect the reporter’s identity.

Agree a safety and follow-up plan with DCFS or police. If no response is received and risk remains, contact DCFS again and request supervisory review; use 911 for immediate danger. Report new information and concerns even where a previous report has been made.

Ordinarily involve a safe parent or carer and explain action to the child. First seek DCFS or police advice if doing so could increase danger, alert an alleged abuser or affect an enquiry. Follow any lawful instruction not to notify others, and document the reason for notification or non-notification. (Section 42(8).)

04Athlete welfare and conduct at events

4ASafe participation

Before each event, the event director must approve a written risk assessment covering the venue, staffing, activities, medical arrangements, access control, weather where relevant, and the needs of participating children. Publish the applicable rules for each discipline and brief officials and coaches. Rules for one martial art must not be assumed to apply to another.

• Use divisions, permitted techniques, contact levels and protective equipment appropriate to the published rules and the child’s age, size, ability and experience. Do not combine divisions or arrange demonstrations in a way that creates an unsafe mismatch.
• Inspect mats, equipment, barriers and warm-up areas. Control the storage and handling of training weapons. Keep spectators out of competition and preparation areas unless authorised.
• Provide adequate qualified officials and suitable first-aid or medical cover for the activity. Confirm emergency access, venue address, communications and transport arrangements before participation begins. Pause activity if required safety cover is unavailable.
• Respect a child’s request to stop. No coach, official or parent may pressure a child to compete while injured, distressed or medically unfit. A safeguarding complaint or safety withdrawal must not result in intimidation or retaliatory selection decisions.

For suspected concussion, remove the athlete from participation immediately, obtain medical assessment and do not permit return that day. Later return requires clearance and the applicable return-to-sport process, with any stricter event restrictions observed. Coaches and parents cannot override a medical stoppage. This event rule follows CDC HEADS UP guidance listed in Appendix C; it is not a deadline prescribed by the Children Act.

4BRespectful coaching and appropriate contact

Explain the purpose of any physical correction or assistance and seek the child’s agreement. Contact must be necessary, appropriate to the activity and visible to others. Respect refusal and offer another way to explain a technique. Medical assessment belongs with qualified personnel using suitable privacy and safeguarding arrangements.

Shotocup prohibits corporal punishment, hazing, sexualised conduct, discriminatory abuse, humiliation, threats, deliberate excessive contact and exercise used to punish or degrade. Deliberate dehydration, starvation, forced rapid weight loss and pressure to conceal injuries are prohibited. Section 19 separately creates an offence for specified wilful mistreatment or neglect by a person with care and control of, or parental responsibility for, a child.

4CParents spectators and children

Parents, coaches and spectators must support respectful participation, follow barriers and access rules, and avoid threatening officials or athletes. Children must not bully, harass, sexually harm or deliberately injure others. Intervene promptly, separate children safely where needed, and support both the affected child and any child alleged to have caused harm. Do not dismiss harmful conduct as ordinary sporting rivalry.

The event director may pause participation, restrict access or remove a person from an event to protect children. Such action must be proportionate, documented and coordinated with police where necessary. Sporting sanctions and safeguarding reports are separate processes.

05Supervision privacy and safe movement

5ARegistration and handover

Collect the child’s age, emergency contacts, authorised responsible adult and essential medical or accessibility information through secure registration. Confirm appropriate parental authority and participation consent, taking account of relevant court orders. Section 4 defines parental responsibility; an event waiver does not remove safeguarding duties or the duty to report.

Explain who supervises each child from arrival to departure. A parent or a formally nominated club adult must remain responsible unless Shotocup expressly accepts a defined supervision role. Record any handover. Shotocup remains responsible for the safety of activities and areas it controls and must act on concerns wherever they arise.

Set staffing levels through the event risk assessment, considering age, disability, venue layout, activity and movement between areas. Assign adults to each child-supervision area, plan breaks and cover, and use an observable setting with another screened adult available. Junior helpers under 18 must not have sole responsibility for children. These are event safeguards, not statutory ratios under this Act.

5BChanging toilets and weigh ins

Arrange private changing and toilet facilities with clear access rules. Adults must not change or shower alongside unrelated children. No photography, filming or phone-camera use is permitted in changing rooms, toilets or weigh-in areas. Monitor entrances without compromising privacy; explain and record any necessary adult entry.

Where a weigh-in is required, use an approved private procedure, minimal authorised personnel and suitable clothing. Never require a child to be naked or in underwear for a Shotocup weigh-in. Offer an appropriate support person and respect the child’s dignity. Do not announce a child’s weight publicly or permit unnecessary touching. Explain the procedure before arrival and resolve any rules conflict safely in advance.

Avoid secluded one-to-one contact. Where a private discussion or personal assistance is necessary, keep another suitable adult aware and available, take the child’s preferences into account, and record unusual arrangements. Personal care must be planned with the family and suitable personnel; no improvised intimate assistance by an unfamiliar volunteer.

5CMissing children and collection

Notify the event lead immediately if a child is missing. Coordinate a prompt search while maintaining supervision of other children. Contact police immediately where danger, abduction or urgent vulnerability is suspected; do not impose a waiting period. Keep sensitive details off public announcements and social media. Verify identity and authority before reunification and record the outcome.

If a child is uncollected, keep them safely supervised, contact the approved adult and escalate to DCFS or police when safety cannot be assured. Do not leave the child alone or send them with an unauthorised person.

5DTravel and accommodation where arranged

Shotocup-arranged transport or overnight stays require a separate written plan, suitable screened adults, permissions, emergency contacts and clear sleeping and supervision arrangements. Avoid one adult alone in a vehicle with an unrelated child and prohibit adult staff sharing bedrooms with unrelated children. Document any unavoidable emergency variation and notify a safe parent and the lead. Identify club-arranged responsibilities clearly before travel.

06Photography communications and confidentiality

6AImages livestreams and public results

Tell families before registration how official photographs, video, livestreams and athlete results will be used. Obtain appropriate parent or guardian permission for planned promotional images and consider the child’s wishes. Offer a clear way to decline optional publicity without excluding the child from participation. Explain public-event filming limits honestly and agree practical protections in advance.

Appoint and identify authorised media personnel, define where they may film, and brief them on restrictions. Never publish humiliating, sexualised or distressing images of children or footage of private medical care. Photographers must not arrange private contact with a child. Report suspicious filming promptly; staff must not seize or search devices on their own authority.

Publish only the athlete information needed for the stated competition or ranking purpose, with a documented lawful basis and suitable notice. Avoid publishing full dates of birth, addresses, emergency contacts, private medical details or children’s travel and accommodation arrangements. Use age divisions rather than precise ages where sufficient and consider individual protection needs before displaying names or images.

Section 85 restricts publication identifying a child or specified relatives in proceedings covered by the Act. Event publicity, social media and results systems must respect those restrictions. Parental permission does not override a statutory prohibition.

6BContact with children

Use approved Shotocup accounts and communication channels. Keep messages related to the activity and include a parent, guardian or another authorised adult where appropriate. Prohibit secret messaging, disappearing messages, sexualised content, personal social-media relationships and requests for intimate images. Make a safe alternative communication plan if involving a particular adult could put the child at risk.

Preserve relevant messages and report concerns. Do not download, forward or create extra copies of suspected child sexual abuse material; seek police instructions about safe evidence handling. Do not investigate online allegations yourself.

6CSharing and storing safeguarding information

Explain that safeguarding confidentiality has legal limits. Section 20(3) applies reporting duties despite confidentiality or privilege, apart from solicitor-client privilege. A child’s or parent’s permission is not a condition of a required report. Give DCFS the concern and its supporting information and comply with lawful requests.

Section 20(6) protects the reporter’s identity from disclosure. Restrict access to reporter details and seek DCFS or legal advice before responding to any request that may reveal them. Section 20(4) provides protection from civil action unless information is reported falsely and maliciously; section 20(5) creates offences for specified breaches.

Keep safeguarding records in a secure, restricted system separate from public brackets and general event files. Record facts, sources, exact words and actions; preserve originals and make corrections through dated additions. Share only with authorised people for a proper purpose. Do not circulate reports through club group chats or upload identifiable information to unapproved AI tools.

Apply an approved retention schedule that reflects legal, insurance and organisational requirements. Suspend deletion for investigations, complaints, claims or preservation requests. Management must confirm the schedule before adoption; this policy does not assign a statutory retention period to the Children Act.

07Recruitment screening and training

7AAppoint suitable people

Before appointing someone to a child-facing role, verify identity, relevant qualifications, experience and references. Use appropriate criminal-record checks and safeguarding questions and assess any relevant history fairly. A black belt, referee licence, club recommendation or personal friendship does not replace safeguarding screening.

Seek relevant Child Abuse Register information through the authorised process with the individual’s written consent. Section 23(4) permits disclosure by the Minister in specified circumstances, including work with children and relevant employment. Information received must remain confidential; the Register is not an unrestricted public list. (Section 23(1), (4) and (5).)

Section 21A disqualifies persons on the Register from employment in professions listed in section 20(2), restricts their involvement in institutions caring for children, and prohibits a person in a listed profession from knowingly employing a registered person. Apply these statutory restrictions where relevant. As a Shotocup rule, a person barred from child-related work must not be assigned a child-facing role.

Do not allow unsupervised child contact while required checks are incomplete. Issue access credentials by role and restrict contractors, visitors and unscreened personnel to authorised areas. Junior helpers remain children under this policy and need suitable adult supervision.

7BConfirm participating club arrangements

Each participating club must nominate a responsible adult, confirm its supervision arrangements, ensure its representatives accept this policy and identify any known restrictions that affect their eligibility to work with children. Shotocup must assess suitability for roles it appoints and must not rely solely on a club’s assurance where concerns exist.

Staff, officials and volunteers must disclose relevant changes affecting suitability, including restrictions or relevant charges and findings. The lead must assess risk promptly with appropriate advice. An allegation is not a finding of guilt, but protective restrictions may be needed while it is examined.

7CBrief train and supervise

Provide safeguarding induction before child-facing duties, annual refreshers for regular personnel and an event-specific briefing for everyone assigned a role. Cover recognition, immediate reporting, appropriate contact, missing children, photography, changing facilities, whistleblowing and records. Give officials clear authority to stop unsafe participation.

The safeguarding lead and deputy must receive training suitable for their responsibilities. Record attendance, outstanding checks and policy acknowledgements. These briefing and refresher intervals are Shotocup standards, not training deadlines stated in the Act.

Provide accessible reporting information to children and families at registration and at the venue. Tell children they can speak to any official or trusted adult and can say no to contact that makes them uncomfortable. Ensure a concern can be raised privately and without needing to approach the person complained about.

08Allegations cooperation and follow up

8AConcerns about adults in positions of trust

Use the same reporting threshold for a coach, referee, volunteer, club leader, sponsor, director or family member as for anyone else. Notify DCFS immediately where required and police when urgent protection or suspected crime requires assistance. A club disciplinary process or federation complaint must not delay external reporting.

If the safeguarding lead is involved, notify the deputy or an uninvolved director. If Shotocup’s Director or several senior people are implicated, bypass them and report directly to DCFS and, where appropriate, police. Management must arrange an uninvolved person or independent adviser to manage the organisational response.

Take proportionate protective steps, such as suspension from child contact, withdrawal of event access or restricted record access, without prejudging the allegation. Record the reasons. Coordinate with investigating authorities before alerting the subject or interviewing witnesses. Preserve accreditation logs, reports and relevant media without circulating them.

Do not use mediation, resignation, private settlements or confidentiality agreements to suppress a required report. Support the child and their safe family, and provide a fair process for the person accused. No one may retaliate against a child, parent, volunteer or official for honestly raising a concern. Record and address lower-level boundary concerns even when section 20 is not engaged; review patterns together.

8BCooperate with DCFS and police

The Director of Child and Family Services has investigation and enquiry duties under sections 20(7) and 42. Verify the identity and authority of visiting officers promptly. Comply with lawful requirements to grant access to a child, provide relevant information or facilities, be absent during an enquiry, or avoid obstruction, including not alerting others. (Section 42(8).)

Failure without reasonable excuse to comply with a requirement under section 42(8) is an offence under section 42A. Seek advice promptly about disputed requests without using consultation to delay or obstruct lawful action. Shotocup must not run a parallel abuse investigation.

8CSupport review and accountability

Record the agreed safety plan, agency contacts, follow-up owner and review date. Check that referrals were received and actions completed. Support safe continued participation where appropriate, or arrange a safe pause without blame. Consider any other children who may be affected and report new information promptly.

After each event, review incidents, supervision gaps and corrective actions without unnecessarily identifying children. The policy owner must review this policy annually and after serious incidents, material legal changes or identified failures. Verify reporting contacts before events and whenever a change becomes known.

Policy breaches may lead to training, supervision, removal of credentials, suspension, exclusion or contractual action, following a fair process. These measures do not replace reports to DCFS, police or an applicable professional or sporting regulator. Ordinary scoring disputes follow event appeal rules, while a safeguarding concern must receive an immediate safety response.

AAppendix A · Event safeguarding plan

Complete and approve before activities involving children begin. Keep direct contacts available at event control and brief personnel on where to find help.

DCFS: (441) 278-9111 | DCFS main: (441) 296-7575 | Emergency: 911 | Police: 211

Do not start an affected activity until material safeguarding or safety gaps have been resolved. Keep any detailed medical, custody or individual protection information in restricted records rather than on this general plan.

BAppendix B · Child protection concern record

RESTRICTED ACCESS | Make the child safe and report first. Do not delay a call to complete this form. Attach additional secure pages where necessary.

Record the child’s exact words, observations, information sources and any questions asked. Keep facts and accounts separate from interpretation.

Protect the reporter’s identity under section 20(6). Keep this record restricted; do not circulate through club groups or general event files. Preserve the original account and add subsequent information as dated entries.

CAppendix C · References and approval

All legislative section references are to the Bermuda Children Act 1998 (1998:38), as amended. The supplied edition was checked against the official consolidated text on 11 October 2026. Relevant later provisions include sections 20A and 21A, the change to section 23(4), the revised section 42 and section 42A.

• Bermuda Laws Online - Children Act 1998 consolidated text
• Government of Bermuda - child abuse reporting number
• Government of Bermuda - Department of Child and Family Services
• Bermuda Police Service - emergency and non-emergency contacts
• CDC HEADS UP - Responding to a Sports-related Concussion

The CDC source supports the concussion safeguard only and is not Bermuda legislation. Staffing arrangements, privacy rules for weigh-ins, training intervals and event checks in this policy are Shotocup standards rather than requirements attributed to the Children Act.

Before adoption, complete the roles below, obtain Bermuda legal review, agree the records-retention schedule and brief participating clubs and personnel. Before each event, complete Appendix A, confirm reporting routes and medical cover, and publish the child-friendly reporting arrangements.

Retain acknowledgement of this policy from personnel and participating club representatives. Provide its relevant conduct and reporting requirements to parents, athletes and spectators.