Introduction

The PRA and all those involved with pony racing can be justifiably proud of the progress pony racing has made since the first races in Great Britain in 2004 and the establishment of the PRA in 2007. Over the last fifteen years, pony racing has become one of the fastest growing equestrian sports, allowing 9-16 years olds to experience the thrill of racing at British racecourses.
That being so, not only does pony racing bring joy to a great number of children, the sport has become very important as a training ground for tomorrow’s jockeys, with a significant number of jockeys licensed by the British Horseracing Authority having started their careers in pony racing.
The PRA is committed to continuing to provide an environment where all children who are involved in pony racing have a positive and fulfilling experience, where they can achieve their best, and where they can enjoy their participation in the sport to its fullest. To that end, the PRA (as the governing body of the sport) has a particular duty to protect children from any harm that might arise from their participation in pony racing. However, this duty is not confined to the PRA. It is shared by everyone in pony racing.
To accompany the introduction of this Safeguarding Policy, the PRA has put in place practical measures, tailored to the requirements of pony racing, that seek to minimise the risk of harm and enable the PRA to respond as appropriate to suspicions and concerns whenever and wherever they might arise. This Safeguarding Policy will be supported by the introduction of PRA Safeguarding Regulations, enabling the PRA to support the aims of this Safeguarding Policy (including by taking disciplinary action if necessary).
This Safeguarding Policy addresses the following:
1. Key principles
2. Who is covered by this Safeguarding Policy?
3. The PRA Safeguarding Code of Conduct
4. Parental responsibility and the supervision of children
5. Harm and abuse
6. Safeguarding concerns – reporting and responding
7. Useful contact details and sources of further information
In developing this Safeguarding Policy and its related procedures, the PRA has worked alongside a number of stakeholders in pony racing, including the British Horseracing Authority, the Pony Club, and the PRA’s shareholders, being the Racecourse Association, The Jockey Club, the Point-to-Point Secretaries Association and the Master of Foxhounds Association.
I know all those involved with pony racing will welcome the introduction of these safeguarding measures, which represent another significant milestone in the development of pony racing in Great Britain, and will support its long term development for many years to come.
Clarissa Daly
PRA Chief Executive
1st December 2019

1. Key principles

The following key principles will guide the PRA’s approach to safeguarding and child protection within pony racing:
• The PRA will challenge any conduct within pony racing that is, or might be, harmful to children.
• The PRA will take all allegations of abuse seriously and respond swiftly and appropriately.
• The PRA will seek to support all of those involved in any cases of abuse, in particular any affected children, their families, and those who report concerns to the PRA. The level of support will be appropriate to the circumstances of each individual case, and the circumstances of each affected individual.
• Where a child is being abused (or at risk of being abused), the most appropriate body to address such concerns will typically be the social care team at the relevant local authority. In an emergency, or if it is suspected a crime has been committed, the police will typically be the most appropriate body to which concerns should first be reported. However, in its capacity as the governing body of racing, the PRA also has a legitimate and very important role to play.
• The PRA will work in partnership with the police, local authorities, and any other appropriate authorities in accordance with their procedures, and in order to enable them to carry out their duties to investigate concerns and protect children.

2. Who is covered by this Safeguarding Policy?

2.1 This Safeguarding Policy and its supporting documentation and procedures are designed to promote the interests of children who are engaged in any pony racing activities overseen by the PRA, in particular by protecting them from harm.
2.2 Children are of course at the heart of pony racing and this Safeguarding Policy therefore applies to everyone engaged in activities overseen by the PRA, including all of the following:
• Officials
• Jockey coaches
• PRA members
• PRA employees
• PRA Board members
• PRA appointed volunteers, associates and representatives
• Parents/carers
• Spectators
• Those who are not performing roles overseen by the PRA but who are otherwise involved in pony racing activities overseen by the PRA. Examples may include (but not be limited to) racecourse officials/staff, and service providers such as veterinarians, medical staff, physiotherapists, nutritionists, farriers etc.

3. The PRA Safeguarding Code of Conduct

3.1 This section of the PRA Safeguarding Policy sets out certain expectations of behaviour for all those within pony racing when dealing with children. The PRA will use this Code of Conduct to help inform and guide its response to any concerns in relation to the treatment of children.
3.2 It is expected that all those involved with children in pony racing activities will:
• Be familiar with the PRA Safeguarding Policy.
• Promote the best interests of children within pony racing, and prioritise their safety and wellbeing at all times.
• Not behave in any way that is harmful, or might be harmful, to any child, including (without limitation) engaging in any behaviour that involves or could be construed as abusive or neglectful (see section 5 below).
• Take appropriate action in the event of concerns about the wellbeing of any child, in particular by reporting such concerns to the police and/or other appropriate authorities and/or the PRA (see section 6 below).
• Ensure that any physical contact with children is limited to that which is appropriate and necessary. Private or unobserved situations should be avoided where possible.
• Ensure that any relevant parents/carers are included in correspondence with children, or if that is not practicable for any reason, that they are made aware of correspondence with children in relation to pony racing activities (including any text messages, emails and any private correspondence carried out via social media).
• Enjoy positive and appropriate relationships with children, based on openness, honesty, mutual trust, care and respect, including by:
o ensuring that children are treated fairly and feel valued;
o acting as a role model, displaying appropriately high standards of personal behaviour and conduct at all times;
o not exerting undue influence on children, and being aware of physical and emotional limits they might have;
o never humiliating or intimidating children; and
o never, while in contact with children, engaging or encouraging any behaviour that might be unlawful.
3.3 Breaches of this Code of Conduct will not necessarily result in liability for disciplinary action under the PRA Safeguarding Regulations (although may do so in serious, multiple and/or repeated cases) – guidance as to future conduct might be appropriate instead.

4. Parental/carer responsibility and the supervision of children

4.1 Parents/carers play a crucial role in pony racing, and should be assured that children’s wellbeing is at the heart of pony racing and everything the PRA does.
4.2 It is a central tenet of the PRA’s Regulations that parents/carers are ultimately responsible for their children, including in respect of their wellbeing and safety.
4.3 Parents/carers should, in accordance with the Code of Conduct:
4.3.1 Take the time to talk to their child about what they want to achieve from participation in pony racing, and the importance of good etiquette, sportsmanship, and abiding by the rules.
4.3.2 Behave positively while supporting their child, and remember that how parents/carers behave can affect not just their child but other children too.
4.3.3 Accept the decisions of PRA Officials made in respect of their child.
4.4 In circumstances where children are accompanied by adults other than their parents/carers while undertaking pony racing activities – for example during the course walk prior to a race – they should be accompanied by an adult who has adequate awareness of safeguarding matters (e.g. an adult who has undergone appropriate safeguarding training), or there should be more than one responsible adult accompanying them.
4.5 All training organised or overseen by the PRA is undertaken by, or alongside, experienced Pony Club Instructors and/or British Horseracing Authority accredited Jockey Coaches, who are subject to appropriate criminal record checks and safeguarding training as required by the Pony Club and British Horseracing Authority respectively.

5. Harm and abuse

5.1 ‘Harm’ is not a narrow concept, and can mean different things in different contexts. In a broad sense, however, the PRA considers ‘harm’ (in the context of this Safeguarding Policy) to be the consequence of any form of ill-treatment that adversely affects physical or mental health, or the intellectual, emotional, social or behavioural development of a child.
5.2 More specifically, although not exclusively, ‘harm’ can result from ‘abuse’, which can be considered as conduct falling into one or more of the following four categories.
• Sexual abuse
Sexual abuse occurs when a child is forced, persuaded or encouraged to take part in sexual activities. Such abuse does not have to involve physical contact and can take place online.
• Physical abuse
Physical abuse is causing physical harm to a child, including by causing injuries such as bruises, broken bones, burns or cuts.
• Emotional abuse
Emotional abuse is the emotional mistreatment of a child. It can also be considered as psychological abuse and can seriously damage mental health and wellbeing. Emotional abuse can involve scaring or humiliating a child. Such abuse does not have to take place in person and can take place online.
• Neglect
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of their health or development e.g. by not meeting their essential needs for food, warmth and care, or failing to adequately supervise them.
5.3 While all forms of abuse are to be taken seriously, any abuse that is motivated by, or involves reference (explicit or implicit) to, ethnic origin, nationality, colour, race, religion or belief, gender, gender reassignment, sexual orientation or disability, will be treated as a particularly serious matter.
5.4 Some common signs of child abuse in children include:
o unexplained changes in behaviour or personality;
o becoming withdrawn;
o seeming anxious;
o becoming uncharacteristically aggressive;
o lacking social skills and having few friends, if any;
o poor bonding or relationship with a parent/carer;
o knowledge of adult issues inappropriate for their age;
o running away or going missing; and
o always choosing to wear clothes which cover their body.
Note: In the event a child displays one or more of these signs, it should not lead to an automatic conclusion that they are suffering from abuse. However, the display of one or more of these indicators may – in the context of the circumstances relating to the individual child – prompt concern that warrants further attention. The above list is not intended to be exhaustive, and you might also notice some concerning behaviour from adults who you know have children in their care, which makes you concerned for the child/children’s safety and wellbeing.

6. Safeguarding concerns – reporting and responding

6.1 Where there are concerns in relation to the safety and/or wellbeing of a child, it is important that those concerns are reported to the appropriate authorities in order that appropriate action may be taken to protect that child. In emergencies or serious cases, this means reporting to the police or local child protection authorities. The PRA’s core aims in relation to safeguarding, as a sports governing body, are to (i) seek to prevent harm to children in pony racing, and (ii) take appropriate action against those who harm, or pose a risk of harm, to children within pony racing. It is for those reasons that the PRA also wishes to receive reports of concerns, and it is appropriate that it does so.
6.2 In all cases of concerns reported directly to the PRA, the PRA will consider how best to respond, but all concerns that warrant and/or require referral to police and/or local child protection authorities will be shared with those authorities (if not already reported directly to those authorities), who will be best placed to manage such cases. The PRA will then liaise with those authorities in relation to any action the PRA may propose to take, and support those authorities as may be necessary or appropriate. If an individual has made a report about someone in pony racing to the police and/or local child protection authorities, but does not wish to report it directly to the PRA for any reason, then the PRA should instead be informed on a ‘no names’ basis that a report has been made, and to which force/authority it has been made (the PRA can then liaise with that force/authority to determine whether any action by the PRA is appropriate).
Making a report to the PRA
6.3 The PRA wants to be presented with any relevant information, from any source, where there is reason to believe that an individual involved in pony racing has presented or presents a risk of harm to any child.
6.4 It is not the responsibility of those reporting concerns to the PRA to determine if a child has been abused or is otherwise at risk of harm. In the first instance all concerns should be reported directly to the PRA and any other appropriate bodies (for example the police if criminal activity is suspected or in an emergency).
6.5 Reports can be made to the PRA to the PRA Chief Executive, Clarissa Daly, at clarissa@ponyracingauthority.co.uk, or on 01584 823783, and/or to the PRA Chief Steward, Caroline Hutsby, at caroline@ponyracingauthority.co.uk, or on 01789 8406311. Alternatively, if the report concerns one of those individuals (or the maker of the report would rather report the concern to someone else for any reason), the report should be made instead to a member of the PRA’s Board (see https://www.ponyracingauthority.co.uk/the-board/).
6.6 When reporting an incident or concern to the PRA, the person making the report should:
• provide his/her name and contact details;
• provide the affected child’s name, age and gender;
• provide the name of the affected child’s parent(s)/carer(s) and their contact details (stating whether or not the parent(s)/carer(s) are aware of the concern);
• state whether he/she is reporting his/her own concerns or concerns that have been raised by someone else;
• provide details of the incident or concern, including the name(s) of any person(s) involved, and the name(s) of any potential witness(es) (focus should be on the facts rather than opinion i.e. what exactly has been observed, seen, heard, or disclosed); and
• state whether or not the incident has been reported to any other body, e.g. the police or relevant local authority.
6.7 All reports received by the PRA will be treated in confidence and will be shared only with individuals within the PRA, or with those from whom the PRA may seek advice on confidential terms (such as lawyers and safeguarding professionals), on a strictly ‘need to know’ basis. The details of the report may also be shared with other bodies (again on a ‘need to know’ basis and to the extent appropriate) where that is in the interests of preventing harm to any child or other person. The PRA’s approach to information sharing is set out below.
The PRA’s response to reports of safeguarding concerns
6.8 All reports received by the PRA will in the first instance be considered by the PRA Chief Executive and/or the PRA Chief Steward, both of whom are trained to consider and respond to the report of a safeguarding concern. The PRA’s initial response to a safeguarding report will depend on the nature of the concern and its specific facts (but, as above, will always include referral to the police and/or social services where warranted and/or required).
6.9 Any investigations under the PRA Safeguarding Regulations will be undertaken by the PRA and/or by an expert investigator appointed by the PRA from the National Safeguarding Panel, a specialist body administered by Sport Resolutions (UK).
6.10 Where (in a particular case) it is determined by the PRA (whether as the result of a report or otherwise) that a person poses a risk of harm to any child, the matter will be dealt with in accordance with the PRA Safeguarding Regulations. This may result in a temporary suspension order until the matter is determined (which is a neutral act that is not indicative of a person’s guilt) and, should it be found that wrongdoing has occurred, disciplinary orders up to and including a lifetime ban from pony racing.
6.11 Where (in a particular case) it is determined by the PRA that no relevant person poses a foreseeable risk of harm to any child but an understandable concern was raised, it might be the case that the PRA or others give guidance to any relevant individual in relation to his or her future conduct (for example for less serious or inadvertent breaches of the PRA Safeguarding Code of Conduct).
6.12 The PRA may, without prejudice to its own ability to progress the matter under the PRA Safeguarding Regulations, refer any safeguarding matter to another organisation within equine sport (e.g. the BHA or the Pony Club) if it is satisfied that that is appropriate in all the circumstances of the case.

6.13 In circumstances where a concern arises relating to the poor behaviour of a child towards another child (or other children), the PRA’s initial response will (as in any case) depend on the nature of the concern and its specific facts. However, children in particular might not realise that certain behaviour is unacceptable. In general terms therefore, the PRA will seek to discuss the issue with the child and/or parents/carers concerned, in order to manage the behaviour and seek to ensure it is not repeated. This will be done calmly, with an explanation provided as to why the child’s behaviour has been unacceptable (with reference to the PRA Safeguarding Code of Conduct), and guidance offered as to what they can do to improve it. In any case where one child has abused another, the PRA will take expert advice and respond as appropriate.

Summary flowchart outlining the progress of reports received by the PRA

The PRA’s approach to information sharing
6.14 The PRA recognises that information sharing is vital to safeguarding and promoting the wellbeing of children. The PRA also recognises that decisions about how much information to share, with whom and when, can have a profound impact on individuals’ lives.
6.15 In respect of its response to receipt of information relating to safeguarding , the PRA adopts the following principles of information sharing in relation to safeguarding (adapted from HM Government’s ‘Golden Rules’ concerning information sharing, contained within the ‘Advice for practitioners providing safeguarding services to children, young people, parents and carers’ government advice document):
• Data protection legislation, human rights law and the law relating to confidentiality are not barriers to justified information sharing, but provide a framework to ensure that personal information about living individuals is shared appropriately.
• The PRA will be open and honest with individuals (and/or their family where appropriate) from the outset about why, what, how and with whom information will, or could, be shared and seek their agreement, unless it is unsafe or inappropriate to do so.
• Where there is any doubt as to the appropriateness of information sharing, the PRA will seek to provide guidance to those who wish to provide information to it, and where necessary seek advice from other practitioners and experts in relation to information sharing (in each case without disclosing concerned individuals’ identities if possible).
• The PRA will share information to the extent it is necessary, proportionate, and relevant, and will do so in a manner that adequate, accurate, timely and secure.
• The PRA will keep an adequate record of its decision-making in relation to information sharing.
6.16 The PRA processes personal data received in reports and otherwise collected as part of its safeguarding investigations in accordance with applicable data protection law, for the purposes of meeting its safeguarding responsibilities as set out in this policy.

7. Useful contact details and sources of further information

Industry bodies
British Horseracing Authority
Matt Mancini, BHA Lead Safeguarding Manager
Tel: 07826 552393 Email: mmancini@britishhorseracing.com
Racing Welfare
24 Hour Helpline – 0800 6300 443
Text – 0786 0079 043
www.support.racingwelfare.co.uk/app/ask
www.support.racingwelfare.co.uk/app/chat/chat_launch
External and statutory bodies
NSPCC Helpline
Tel: 0808 800 5000
Email: help@nspcc.org.uk
Child Protection in Sport Unit
Email: cpsu@nspcc.org.uk
Childline
Freephone: 0800 1111
www.childline.org.uk/get-support/1-2-1-counsellor-chat/