Vulnerable adult protection policy

The purpose of this document

This document is for those employed by the Shrimala Trust or volunteering with the Awakened Heart Sangha.

It aims to protect both vulnerable adults attending the Awakened Heart Sangha activities and those working or volunteering with the Awakened Heart Sangha.

It sets out

  • practices and procedures contributing to the prevention of abuse of vulnerable adults or those who may be at risk in certain situations.
  • a course of action to be followed if abuse is suspected.

Our values

The Awakened Heart Sangha is a Buddhist community, supported by the Shrimala Trust, a charitable company.

The Awakened Heart Sangha is a mandala of students, teachers and supporters dedicated to the Path of Awakening. The mandala is continually evolving around the core principle of Openness, Clarity and Sensitivity.

Each person in the mandala helps create and maintain that mandala for their own sake and for the sake of all beings as a vehicle to carry the transmission of the teachings and adhistana of the lineage, which is our connection with the living truth.

The Shrimala Trust aims to advance religious education in accordance with the doctrines and principles of the buddhist faith, and in particular the Kagyu-Nyingma tradition of Tibetan Buddhism. These aims are furthered through the activities of the Awakened Heart Sangha, a spiritual community in the Kagyu and Nyingma traditions of Tibetan Buddhism, formed by students of Lama Shenpen Hookham.

Awakened Heart Sangha’s activities include one to one mentoring, teaching events, workshops, and online study groups.

Occasionally its activities may involve adults who may be considered to be vulnerable.

Ensuring the sexual, physical and psychological safety of vulnerable adults involved in the Awakened Heart Sangha activities is an expression of the wisdom and compassion taught by the Buddha.

The Shrimala Trust recognizes a duty of care (Care Act 2014) to everyone who comes in contact with the charity, and is committed to promoting their well-being by whatever means and resources it has available.

Our Safeguarding team includes:

  • Stephanie Hair (a trustee, mentor and junior teacher within the AHS. Former occupation: Mental Health Nurse)
  • Jackie McGarry (a mentor within the Awakened Heart Sangha. Occupation: Mindfulness Teacher)
  • Ian McKenzie (mentor and junior teacher within the AHS. Former occupation: Consultant)
  • Pati Bielak-Smith (mentor and junior teacher within the AHS. Former occupation: Communications trainer)

Who is a ‘vulnerable adult’?

A vulnerable adult is a person aged 18 years or over who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is, or may be, unable to take care of him/herself, or unable to protect him/herself against significant harm or exploitation.

A vulnerable adult may  be a person who:

•       Has a physical or sensory disability
•       Is physically frail or has a chronic illness
•       Has a mental illness or dementia
•       Has a learning disability
•       Is old and frail
•       Misuses drugs and/or alcohol
•       Has social or emotional problems
•       Exhibits challenging behaviour

Whether or not a person is vulnerable in these cases will vary according to circumstances. Additionally, a person who does not fit any of the above categories may from time to time find themselves vulnerable or at risk in certain situations. Each case must be judged on its own merits.

What is ‘abuse’?

Abuse is the harming of a person usually by someone who is in a position of power, trust or authority over them, or who may be perceived by that person to be in a position of power, trust or authority over them. The harm may be physical, psychological or emotional, or it may exploit the vulnerability of the victim in more subtle ways.
Types of abuse

•       Bodily assaults resulting in injuries e.g. hitting, slapping, pushing,
kicking, misuse of medication, restraint or inappropriate sanctions.
•       Bodily impairment e.g. malnutrition, dehydration, failure to thrive
•       Medical/healthcare maltreatment 

•       Rape, incest, acts of indecency, sexual assault
•       Sexual harassment or sexual acts to which the vulnerable adult has not
consented, or could not consent or was pressured into consenting.
•       Sexual abuse might also include exposure to pornographic materials,
being made to witness sexual acts; also sexual harassment, with or without physical contact.

•       Threats of harm, controlling, intimidation, coercion,
harassment, verbal abuse, enforced isolation or withdrawal from
services or supportive networks.
•       Humiliation
•       Bullying, shouting or swearing

Abuse through neglect
•       Ignoring medical or physical care needs, failure to provide
access to appropriate health, social care or educational services
the withholding of the necessities of life, such as medication, adequate
nutrition and heating

Financial or material
•       Theft, fraud
•       Exploitation, pressure in connection with wills, property or inheritance
or financial transactions; the misuse or misappropriation of property,
possessions or benefits

•       Language which is racist, sexist, or based on a person’s disability, gender or sexual orientation, etc

Signs of abuse


NB Ageing processes can cause changes which are hard to distinguish from some aspects of physical assault e.g. skin bruising can occur due to blood vessels becoming fragile.
•       A history of unexplained falls or minor injuries
•       Bruising in well-protected areas, or clustered from repeated striking
•       Finger marks
•       Burns of unusual location or type
•       Injuries found at different states of healing
•       Injury shape similar to an object
•       Injuries to head/face/scalp
•       History of moving from doctor to doctor, or between social care agencies; reluctance to seek help
•       Accounts which vary with time or are inconsistent with physical evidence
•       Weight loss due to malnutrition; or rapid weight gain
•       Ulcers, bed sores and being left in wet clothing
•       Drowsiness due to too much medication; or lack of medication causing
recurring crises/hospital admissions


•       Disclosure or partial disclosure (use of phrases such as ‘It’s a secret’)
•       Medical problems, e.g. genital infections, pregnancy, difficulty walking or sitting
•       Disturbed behaviour e.g. depression, sudden withdrawal from activities, loss of previous skills, sleeplessness or nightmares, self-injury, showing fear or aggression to one particular person, inappropriately seductive behavior, loss of appetite or difficulty in keeping food down.
•       Unusual circumstances, such as, for example, two service-users found in a toilet/bathroom area, one of them distressed

Signs of psychological or emotional vulnerability

•       Isolation
•       Unkempt, unwashed appearance; smell
•       Over meticulousness
•       Inappropriate dress
•       Withdrawnness, agitation, anxiety; not wanting to be touched
•       Change in appetite
•       Insomnia or need for excessive sleep
•       Tearfulness
•       Unexplained paranoia; excessive fears
•       Low self-esteem
•       Confusion

Signs of neglect

•       Poor physical condition
•       Clothing in poor condition
•       Inadequate diet
•       Untreated injuries or medical problems
•       Failure to be given prescribed medication
•       Poor personal hygiene

Signs of financial or material vulnerability

•       Unexplained or sudden inability to pay bills
•       Unexplained or sudden withdrawal of money from accounts
•       Disparity between assets and satisfactory living conditions
•       Unusual level of interest by family members and other people in the
vulnerable person’s financial assets

Signs of discrimination

•       Lack of respect shown to an individual
•       Substandard service offered to an individual
•       Exclusion from rights afforded to others, such as health, education,
criminal justice

Other signs of abuse

•       Controlling relationships
•       Inappropriate use of restraint
•       Sensory deprivation e.g. spectacles or hearing aid
•       Denial of visitors or phone calls
•       Failure to ensure privacy or personal dignity
•       Lack of personal clothing or possessions

People who may abuse

Abuse may happen anywhere and may be carried out by anyone.

Prevention of abuse

•    Continuous training in Openness, Clarity and Sensitivity as the basis for all activities of the Awakened Heart Sangha
•       Respect for all living beings
•       Training in Nonviolent Communication available to all members
•       Vulnerable Adults policy training for all mentors, and group leaders
•       Mental Wellbeing Guidelines available to all mentors, and group leaders

Reporting suspected abuse

Is it abuse?

To gain reassurance, clarity, support or empowerment, all members of the Mahayanagana student group and the Awakened Heart Sangha mentors make themselves available to discuss the matter with whomever has a concern related to potential abuse.
Anyone who receives a report of suspected abuse has a duty to take action, i.e. refer the matter directly to the Safeguarding Team. If you are sure that crime was committed, please take immediate action.
You are encouraged to voice your concern on your own behalf, or on behalf of someone else.
The consent of the vulnerable adult must be obtained except where:
•       The vulnerable adult lacks the mental capacity to make a decision (Mental Capacity Act 2005), and a risk assessment indicates that referral would be in their best interests
•       Others may be at risk
•       A crime has been committed
Contact Safeguarding Team (any of its members) immediately.

What’s next

The Safeguarding Team will consider the following:
•       The wishes of the vulnerable adult and their right to self-determination
•       The mental capacity of the vulnerable adult
•       Known indicators of abuse
•       Definitions of abuse
•       Level of risk to the individual
•       The seriousness of the abuse
•       The effect of the abuse on the individual
•       Level of risk to others
•       The effect of the abuse on others
•       Whether a criminal offence has been committed
•       Whether other statutory obligations have been breached
Depending on the above, the Safeguarding Team may choose to inform relevant services (incl. police, local council, social services etc.), discuss the matter further within the Shrimalagana student group or among trustees, initiate Grievance Process, or other appropriate courses of action.

Grievance Process

In the spirit of reconciliation and healing, the Awakened Heart Sangha may offer emotional and spiritual support for all who have been affected by abuse that occurred within the organisation.  This would take form of the Grievance Process involving several meetings oriented around empathy, healing and restoration. This would be an expression of the Awakened Heart Sangha’s commitment to the promotion of wellbeing of all its members, and those who came into contact with it. It is an act of good and free will of all involved, and would be conducted by appropriately trained members to bring about restorative justice within the organisation.
This document is to be read in conjunction with the Awakened Heart Sangha’s Child protection policy and Child protection code of conduct.
Published 2020 by the trustees of The Shrimala Trust.