Safeguarding and Working with Minors Policy

1. Purpose

AWARE Community Foundation ("AWARE") delivers betting education and integrity support to athletes, including high-school and club teams whose members are under 18. This policy sets out how AWARE keeps athletes safe, how it keeps its own people accountable, and how it keeps gambling-industry funding away from young people. It applies from the day it is adopted and must be fully in force before the first program session in 2027.

AWARE has no staff and has delivered no programs as of the date of adoption. Several requirements below therefore describe systems that must be built before delivery begins. Section 17 lists what must be in place first.

2. Scope

This policy applies to everyone who acts for AWARE, paid or unpaid:

• directors, including the founder and interim chair;
• staff, once hired;
• Athlete Educator Corps educators (current and retired athletes trained and paid to deliver sessions);
• contractors, including the independent evaluator and any research staff;
• volunteers and anyone else who attends a session on AWARE's behalf.

In this policy, "AWARE personnel" means all of these people. A "minor" is anyone under 18. A "session" means any program delivery, briefing, research activity or event where athletes are present, in person or online.

3. Commitments

AWARE commits to:

1. Adopt and comply with the Universal Code of Conduct to Prevent and Address Maltreatment in Sport (UCCMS), in its current version, as a condition of every role covered by this policy. The mechanism by which AWARE adopts the UCCMS (directly, or through a sport organization), and the version in force, are confirmed with the Abuse-Free Sport program, subject to legal advice, and recorded by the board before AWARE's first session.
2. Never be alone with a minor.
3. Never deliver a session to under-18 athletes except at the invitation of, and with staff present from, the school or club responsible for them.
4. Keep every gambling-industry funder out of youth sessions and youth materials, completely.
5. Report every concern about a child's safety as Alberta law requires, and never investigate it ourselves.
6. Look after the wellbeing of our own educators, especially those with lived experience of gambling harm.

4. Roles

• Safeguarding Lead. Designated by the board. The Safeguarding Lead is a non-founding director designated by board resolution, until an Executive Director is hired and takes over the role. The Safeguarding Lead keeps screening and training records, receives incident reports, makes or supports required reports to authorities, and reports to the board.
• Independent safeguarding director. Once the independent majority of the board is seated, one independent director will be named as the safeguarding contact for any concern involving the founder, a director or the Safeguarding Lead. Until then, concerns about any of these people go to the two non-founding directors, with the Foundation's external legal counsel as external reviewer where needed. The founder will not be the sole recipient of any safeguarding concern about the founder.
• Session lead. The AWARE educator responsible for a given session. The session lead completes the Session Safeguarding Checklist (Appendix A).

Note: Policy 04 (Whistleblower and Complaints) currently routes reports to the Chair. Safeguarding concerns are handled under this policy instead, so that they do not go to the founder alone.

5. Screening

No one may have contact with minors on AWARE's behalf until all of the following are complete and recorded by the Safeguarding Lead:

1. Application and declaration. A written application and a signed declaration disclosing any criminal charges or convictions, any past or current sanction or investigation under a safe sport, maltreatment or integrity code, and any current commercial arrangement with a gambling operator (see section 12).
2. Interview. A structured interview that includes safeguarding scenarios and boundaries with young athletes.
3. References. At least two references, at least one from someone who has supervised the applicant working with young people or in sport.
4. Police information check including a vulnerable sector check. Obtained through the applicant's local police service before any contact with minors. A check that discloses relevant information is reviewed by the Safeguarding Lead and the independent safeguarding director (or, until one is seated, the two non-founding directors), who decide whether the person may proceed. Alberta police services issue the vulnerable sector component only where the role involves a position of trust over vulnerable persons; the exact check type and process are confirmed with the issuing police service, subject to legal advice, and recorded by the board before AWARE's first session.
5. Safe sport sanctions check. A check of any publicly available sanction registry maintained under the UCCMS framework, where one exists. Registry availability is confirmed and recorded by the board before AWARE's first session.

Renewal. Police information checks with vulnerable sector component are renewed every three years, and sooner if AWARE becomes aware of new information. Every person signs an annual declaration in between. Three years is the maximum interval; where a sport or school partner AWARE serves requires more frequent checks, AWARE follows the stricter requirement.

Schools and school authorities may impose their own volunteer or visitor screening. AWARE personnel will comply with any host's additional requirements.

6. Training

Before first contact with athletes, and refreshed as set out below, every person covered by this policy completes:

• Safe sport training. A recognized UCCMS-aligned course such as the Coaching Association of Canada's Safe Sport Training module or Respect in Sport for Activity Leaders. Refreshed every two years.
• AWARE safeguarding orientation. This policy, the Rule of Two, disclosure handling, Alberta's duty to report, youth content rules, and the referral pathways in section 14.
• Funder-separation briefing. What may and may not appear in a youth session (section 9).
• Educators only: AWARE curriculum certification, including how to respond when an athlete discloses a gambling problem, harassment or an approach to fix or share inside information.

Training completion is recorded by the Safeguarding Lead. Training records are retained under the Data Governance and Privacy Policy.

7. Rule of Two and open, observable settings

AWARE follows the Rule of Two as it is used in Canadian sport: no AWARE personnel will be alone, out of sight or out of earshot with a minor athlete, in person or online.

• Every session is held in an open, observable setting: a classroom, team room or gym, with doors open or windows unobstructed where practical.
• A one-on-one conversation with a minor that begins after a session (for example, an athlete who stays behind to ask a question) must take place in view and within earshot of the team's coach, a teacher or a second screened adult.
• AWARE personnel never transport a minor, never meet a minor off-site, and never visit a minor at home.
• Online sessions with minors use the school's or club's own platform or an AWARE organizational account, with a school or club adult present on the call. No private breakout rooms with a single minor.
• Medical emergencies are the only exception. Any departure from this section is reported to the Safeguarding Lead the same day.

8. Sessions with under-18 teams

AWARE delivers to under-18 athletes only under these conditions:

1. By invitation. The request comes from the school, school authority or club through its authorized adult (athletic director, head coach, principal or club official). AWARE does not approach minors directly, and does not accept a booking made by an athlete under 18.
2. Host adult present throughout. A team coach or school staff member is present for the whole session. AWARE never runs a youth session alone. If no host adult is present, the session does not start.
3. Parent/guardian notice. The host sends a notice to parents and guardians at least 7 days before the session, using or adapting the template in Appendix B.
4. Consent model. AWARE's default is notice with the right to opt out: education sessions run as part of normal team activity, and any parent or guardian may withdraw their child without explanation. The host school or club decides whether its own rules require active (opt-in) consent, and AWARE will follow the stricter rule. Research and evaluation activity with minors always requires active parental consent and the athlete's own assent (see the Data Governance and Privacy Policy). AWARE confirms each host's consent requirement at the time of booking and records it on the Session Safeguarding Checklist.
5. Two AWARE personnel where possible. Where only one AWARE educator attends, the host adult satisfies the Rule of Two. The session lead confirms this on the checklist.
6. No photography or recording of minors by AWARE, unless the host has collected releases under its own policy and minors are not identifiable.

9. Content rules for youth sessions

These rules apply to every session, handout, slide, video and digital resource used with or provided to under-18 athletes.

Purpose. For minors, AWARE teaches risk, not technique. Content explains why the odds favour the house, how betting harm develops, what harassment looks like and how to report it, and why inside information and approaches must be reported.

Prohibited in youth sessions and materials:

• anything that promotes, normalizes or glamorizes gambling, or presents betting as a skill to be improved;
• exercises framed as betting practice, such as calculating stakes, finding "value", comparing sportsbook prices or building a bet. Probability and house-edge examples may be used only to show why the bettor loses over time;
• the name, logo, mark, colours, slogan, promo code, bonus offer, app, website or advertising of any gambling operator, including AWARE's funders;
• the "AWARE Founding Partner" mark, any partner mark, or any acknowledgment of a funder;
• gambling-company merchandise, prizes or giveaways, worn or distributed by AWARE personnel;
• real-money or simulated wagering, including "free play" demonstrations;
• live screenshots of operator apps (generic, unbranded mock-ups only).

Required: age-appropriate language; a help slide or card with the referral contacts in section 14; and a statement that it is illegal for people under 18 to gamble in Alberta, online or in person.

The curriculum lead reviews all youth materials against this section before use and records the review. Funders have no role in this review and see youth materials only after they are finalized, if at all.

10. Educator dress and conduct

AWARE personnel wear neutral or AWARE-branded clothing only. No operator, sponsor or betting-brand clothing at any session. Personnel do not discuss their own betting activity in a way that could be seen as encouragement, do not use alcohol or cannabis before or during sessions, and use respectful, inclusive language consistent with the UCCMS.

11. Communication and social media

• AWARE personnel do not send private direct messages to minors on any platform, and do not accept or send friend or follow requests to minors from personal accounts.
• Communication about a youth session goes to the host coach or school staff member, not to athletes.
• Where AWARE needs to reach athletes (for example, sharing a resource), it uses official channels: the team's group channel run by the host, or an AWARE organizational account, with the host adult included.
• If a minor contacts an AWARE educator privately, the educator replies once, briefly, directing the athlete to the coach and to the help contacts in section 14, copies or informs the host adult, and logs the contact with the Safeguarding Lead. If the message contains a safeguarding concern, section 13 applies.
• With adult athletes, educators use professional, transparent communication and keep records of substantive contact.
• No AWARE personnel may post images, names or stories of athletes met through AWARE without written consent (and parental consent for minors).

12. Athlete Educator Corps: lived experience, wellbeing and independence

Some Corps educators will have lived experience of gambling harm, their own or a family member's. That experience is valuable, and it carries risk to the educator and to the audience.

Support and supervision.

• Each educator has a named supervisor and a debrief after every session for at least the first 10 sessions, then at regular intervals.
• Educators with lived experience of gambling harm are offered access to confidential counselling paid for by AWARE, through a provider with no link to any funder. The provider and budget are confirmed and recorded by the board before AWARE's first session.
• Educators may decline any session, audience or topic without penalty.

Disclosure boundaries.

• Educators decide what, if anything, to share about their own experience. AWARE never requires personal disclosure and never markets an educator's story.
• Personal stories in youth sessions must not include detail about how to bet, wins, amounts staked, or methods of hiding gambling.
• An educator's personal experience is not shared with funders in any form.

Fitness to deliver.

• An educator who is currently experiencing gambling harm, or is in early recovery, agrees a plan with the supervisor about whether and when to deliver. The test is the educator's wellbeing and the audience's safety, not punishment.
• An educator may be stood down from delivery temporarily, and is paid for any sessions already scheduled at the time.

Independence from operators. No Corps educator may hold an endorsement, ambassador, affiliate, content or advertising arrangement with any gambling operator, directly or indirectly, while in the Corps. Educators declare such arrangements on application and annually. AWARE never supplies educators or athletes as marketing talent. This rule exists to keep AWARE clear of any arrangement that could fall within AGLC's restriction on athletes in operator advertising; it is not based on any review or approval by AGLC.

13. Duty to report and responding to concerns

Alberta law. Under Alberta's Child, Youth and Family Enhancement Act, any person who has reasonable and probable grounds to believe that a child is in need of intervention must report it promptly to a director under the Act (Child Intervention Services) or to the police (section 4). The duty applies to every individual personally, even if the information was received in confidence, and it is not discharged by telling a supervisor. This summary does not replace the Act; AWARE's training on the duty to report is kept current with the Act, subject to legal advice.

How to report.

• Immediate danger: call 911.
• Otherwise: the Alberta Child Abuse Hotline, 1-800-387-KIDS (5437), available 24 hours, or local police.
• Then inform the Safeguarding Lead the same day.

AWARE never investigates. AWARE personnel listen, reassure, record and report. They do not question the athlete beyond what is needed to understand immediate safety, do not confront an alleged person, do not promise confidentiality, and do not contact the alleged person's employer, team or family.

Responding to a disclosure in the moment.

1. Stay calm, listen, and believe the person is telling you something important.
2. Tell them you cannot keep it secret if someone is at risk, and explain who you will tell.
3. Write down what was said in their words, the date, time and who was present, as soon as possible.
4. Report as required, then inform the Safeguarding Lead.

14. Disclosures by athletes and referral pathways

Athletes may disclose things during or after a session. AWARE responds as follows. Where the athlete is a minor and the disclosure suggests a child may be in need of intervention, section 13 applies first.

AWARE does not share any disclosure with a funder in any form. Disclosures are shared with a coach or institution only if the athlete asks, or if someone is at risk of harm, consistent with AWARE's published privacy commitments.

15. Incident recording and escalation

• Every incident, concern, disclosure, departure from the Rule of Two or breach of content rules is recorded on an incident form within 24 hours and sent to the Safeguarding Lead, using the incident form approved by the board before AWARE's first session.
• Records are factual, stored securely with access limited to the Safeguarding Lead and the independent safeguarding director, and retained under the Data Governance and Privacy Policy.
• The Safeguarding Lead decides on next steps, including notifying the host school or club, reporting to authorities if not yet done, and whether the person involved should be stood down pending the outcome of any external process.
• Concerns about AWARE personnel go to the independent safeguarding director (or, until one is seated, the two non-founding directors). Where a concern involves a person covered by the UCCMS framework, AWARE will refer it to the appropriate independent mechanism. The mechanism with jurisdiction over AWARE personnel is confirmed, subject to legal advice, and recorded by the board before AWARE's first session.
• The board receives an anonymized safeguarding report at every meeting: number and type of incidents, actions taken, and training and screening status.

16. Breaches of this policy

A breach of this policy by AWARE personnel may lead to removal from sessions, suspension, termination of employment or contract, removal from the Corps, or a request to resign as a director, depending on severity. Criminal matters go to police. Where a funder breaches the content rules in section 9 (for example, by seeking youth visibility), AWARE treats it as a breach of the funding agreement. Serious breaches are disclosed in AWARE's annual report without identifying any athlete.

17. Before first delivery

The following must be complete before any session with athletes in 2027:

1. Safeguarding Lead designated and trained.
2. Interim independent safeguarding arrangement in place (the two non-founding directors, with the Foundation's external legal counsel as external reviewer), pending the independent director.
3. Screening, training and declaration records system in place.
4. Incident form and secure storage set up.
5. Parent/guardian notice template approved (Appendix B).
6. Youth materials reviewed against section 9.
7. Legal review of sections 5, 8 and 13 completed.

18. Review

The board reviews this policy at least annually, and after any serious incident or change in law, sport policy or UCCMS requirements.

Appendix A: Session Safeguarding Checklist

Completed by the session lead for every session; initial each item. Under-18 items are mandatory for any group that includes a minor.

Before the session

• Booking came from an authorized adult at the school or club (not from an athlete)
• All AWARE personnel attending have current screening, safe sport training and annual declaration on file
• Host confirms a coach or staff member will be present for the whole session
• Parent/guardian notice sent by host at least 7 days before (under-18)
• Any opt-outs received and the host has arranged supervision for those athletes
• Materials are the approved youth version; no funder names, logos, marks or promo codes
• Help contacts card or slide included

At the session

• Host adult present at start; session does not begin without them
• Room is open and observable; online sessions on host or AWARE organizational platform
• No operator or sponsor clothing or merchandise
• No photography or recording of minors
• Any one-on-one conversation held in view and earshot of the host adult

After the session

• No personal contact details exchanged with minors
• Any disclosure recorded and reported (section 13 or 14) and Safeguarding Lead informed
• Any departure from this checklist reported to the Safeguarding Lead the same day
• Checklist signed and filed

Session date: ________ Host organization: ________ Host adult present: ________ Session lead: ________ Signature: ________

Appendix B: Parent/Guardian Notice Template

To be sent by the school or club, on its letterhead or channel, at least 7 days before the session.

Subject: Sports betting education session for [team name] on [date]

Dear parent or guardian,

On [date], [team name] will take part in a [60-minute] education session delivered by AWARE Community Foundation, an independent Alberta non-profit company. The session is part of [school or club]'s athlete development program. [Coach or staff name] will be present throughout.

What the session covers. Why sports betting favours the house over time; how athletes can be targeted by bettors online and how to report it; why betting on your own sport or sharing inside information breaks the rules; and where to get help. The session teaches about risk. It does not teach betting, and it reminds athletes that people under 18 cannot legally gamble in Alberta.

What it does not include. No gambling company names, logos, apps, promotions or merchandise. AWARE does not collect personal information from athletes at this session. No photographs or recordings of athletes will be taken by AWARE.

Safeguarding. AWARE educators are screened (including a police vulnerable sector check), trained in safe sport, and are never alone with an athlete.

Your choice. If you do not want your child to take part, please tell [contact name] at [contact] by [date]. You do not need to give a reason. [If the school or club requires opt-in consent: Please return the attached consent form by [date].]

Help is available any time.

• Addiction Helpline (Recovery Alberta): 1-866-332-2322
• Kids Help Phone: 1-800-668-6868 or text CONNECT to 686868
• Abuse-Free Sport Helpline: 1-888-837-7678
• 988 Suicide Crisis Helpline: call or text 988

Questions about the session can go to [school or club contact] or to AWARE at info@awarecf.com.

[Name, title, school or club]

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