1. Introduction

1.1 Policy Statement

The Modern Minerva is committed to providing a safe and secure environment for all its Employees, Members, Visitors, Volunteers and particularly to Children, Aged and Vulnerable People. The Modern Minerva Client Protection Policy aims to reduce the risk of Abuse occurring, and to ensure that a caring and appropriate response is taken should Abuse occur.


1.2 Scope

This Client Protection Policy applies to:

• All service organisations or subsidiary bodies authorized by or under the control of The Modern Minerva,

• All Employees, Members, Volunteers, Contractors and Visitors within The Modern Minerva or engaged by The Modern Minerva.


1.3 Authority

This Client Protection Policy was adopted for use by Vanessa Nakoski DBA The Modern Minerva on 12/01/16. Vanessa Nakoski DBA The Modern Minerva is committed to implementing the Client Protection Policy and to training our Employees, Members, Contractors and Volunteers in its content and application.


1.4 Definitions

Abuse, can consist of one or more of but is not restricted to the following:

Elder Abuse, a single or repeated act, occurring in any relationship where there is an expectation of trust, which causes harm or distress to an older person.

Physical Abuse, any non-accidental physical injury resulting from practices such as:

  • hitting, punching, kicking (marks from belt buckles, fingers), shaking, burning (irons, cigarettes), biting, pulling out hair, alcohol and/or other drug administration.

Sexual Abuse, any assault or abuse of a sexual nature, sexual molestation, indecent exposure, sexual harassment or intimidation.


Emotional Abuse, the chronic attitude or behavior of one person which is directed at another person, or, the creation of an emotional environment which erodes a person’s self esteem and social confidence over time. Behaviors may include:

  • Insulting, bullying, devaluing, ignoring, rejecting, corrupting, isolating, terrorizing or other extreme acts in the aged or vulnerable person’s presence.

Financial Abuse may include:

  • Activities by an attorney in violation of their powers, duties and responsibilities under an Enduring Power of Attorney (EPA), 

  • Misappropriation of money, valuables or assets,

  • Forging signatures on checks,

  • Denial of access to personal assets,

  • Accessing a person’s funds electronically and/or

  • Forced or unauthorized changes to legal documents.


Financial abuse may also occur where a person takes advantage of an older person who has already lost (or is losing) capacity, by coercing or arranging for the older person to sign a document in circumstances where the older person is unable to understand the nature and effect of the document.  

Neglect, characterized by the failure to provide for basic needs. Any serious omission or commission which jeopardizes or impairs a person’s health or development.


Child, any person under the age of 18.


Leader, any person (paid or unpaid) over the age of 18 who is responsible for the control and safety of members placed in their care whilst holding a formal position in a named Organization. A leader could include but is not limited to:

  • Activity Coordinators,

  • Small group Leaders,

  • Counselors,

  • Teachers,

  • Volunteers.


Member, any person, including children, who attends or participates in the named Organization’s activities, objectives or strategic plan.


Organization, The Modern Minerva, located at 122 North Towne Court, Mount Airy, MD 21771


Volunteer, any unpaid person over the age of 16 who is invited to assist in the work or programs of The Modern Minerva.


Vulnerable Person, any person who is or may be in need of community care services by reason of mental or other disability, age or illness.


2. Policy Review

This Client Protection Policy will be reviewed annually.


3. Obligations

3.1 Responsibility

The core expectations of any responsible Organization require us to treat all people with fairness and dignity and to care for those who are less powerful and in need of nurture and protection.


3.2 Legal

All relevant organizations within The United States of America are bound by Federal and State legislation and principles established through common law. The Modern Minerva is committed to adhering to all relevant legislation.


3.3 Ethical

Some actions may not be regarded as Abuse, but are unacceptable behavior for The Modern Minerva. These include:

  • Inappropriate conversation of a sexual nature.

  • Coarse language, especially that of a sexual nature.

  • Suggestive gestures or remarks.

  • Jokes of a sexual nature.

  • Inappropriate touching.

  • Inappropriate literature (e.g. PG, M, MA, R or X rated material used with Children or Vulnerable Persons).

  • Recording or filming with or without prior consent.

  • Acts of violence committed by a Worker, Leader or Volunteer in the course of an activity.


The Modern Minerva will ensure that high standards of conduct are maintained at all times.


Each client of The Modern Minerva has the right:

  • To full and effective use of his or her personal, civil, legal and consumer rights;

  • To quality education which is appropriate to his or her needs;

  • To full information about his or her own educational progress;

  • To be treated with dignity and respect and to receive services without exploitation, abuse or neglect;

  • To receive services without discrimination or victimization, and without being obliged to feel grateful to those providing his or her instruction;

  • To personal privacy;

  • To be treated and accepted as an individual, and to have his or her individual preferences taken into account and treated with respect;

  • To continue his or her cultural religious practices and to retain the language of his or her choice, without discrimination;

  • To freedom of speech;

  • To maintain his or her personal independence, which includes a recognition of personal responsibility for his or her own actions and choices, even though some actions may involve an element of risk which the client has the right to accept, and that should then not be used to prevent or restrict those actions;

  • To have access to services and activities which are available generally in the community;

  • To have access to information about his or her rights, education, and any other information which relates to him or her personally;

  • To complain and to take action to resolve disputes;

  • To have access to advocates and to other avenues of redress; and

  • To be free from reprisals, or a well-founded fear of reprisal, in any form for taking action to enforce his or her rights.


4. Selection & Screening

4.1 Employees, Agency Staff, Contractors & Volunteers

Employees, Agency Staff, Contractors and Volunteers involved in activities or programs with children, aged and/or vulnerable people must be carefully selected and screened. Prior to commencing employment or volunteer services, the following precautions will be taken:

  • All employees and/or volunteers must complete an application form which requests details of relevant past experience, positions held, details of two referees and permission to contact them.

  • Both referees will be checked and spoken to, using an agreed set of questions which have been drafted by The Modern Minerva. The questions will seek to establish the applicant’s suitability for the role or position and the conversation will be documented and retained on file.

  • All short-listed candidates must undertake a formal interview which includes an analysis of past experience working with students, including children and vulnerable people.


5. Training

All new Workers/Employees, including Agency Staff, Contractors and Volunteers will be issued with a copy of this policy and receive formal training in;

  • The content and application of the Organisation’s Client Protection Policy,

  • Reporting procedures and the associated legal requirements.

  • Refresher training courses based on current “best practice."


6. A Safe Environment

Incidents of Abuse are unlikely to take place in front of another person and the presence of a witness can assist in clarifying questionable allegations. For these reasons, wherever possible, workers will not visit children in their homes unless a friend or relative is present or another Worker accompanies them. Workers will respect a Member’s feelings and privacy when engaging in physical contact of any kind. No Worker will be alone in a room with a Child or an Elderly or Vulnerable person while any/either is changing. All aspects of every program related to children, aged and vulnerable people will be open to observation by family, friends or guardians. Workers have the right to ask people who do not have a valid reason to be present at such activities to leave. Police may be contacted if such persons refuse to comply with any reasonable request to leave.


7. Disciplining Children

It is not the responsibility of The Modern Minerva or its Workers, Volunteers or Leaders to discipline a Child. If a Child does not abide by the rules set down by the Organisation, or becomes an obstruction to the care of other Children or Members, and may cause harm, the Child will be removed and referred back to their parent or guardian. At no time will a Leader administer any form of physical, emotional, financial or mental discipline.


8. Reporting Procedures

The Modern Minerva actively encourages the reporting of all abuse including Sexual Abuse. The Modern Minerva is committed to building an environment where either a victim or employee/volunteer feels able to report such abuse. Employees and/or volunteers must report reasonable suspicions of abuse to the senior management of The Modern Minerva. Reasonable Suspicion means fair and practical reason to believe an incident involving abuse has occurred based on either verbal communication, hearsay, rumor or observation of behavior. The details of those reporting abuse will be kept private and confidential. A documented reporting process with escalating procedures has been established by The Modern Minerva for handling allegations of abuse.


The escalating procedures will be as follows:

  • The automatic suspension from all work or other duties within The Modern Minerva of any person while under investigation by The Modern Minerva, or by the police, for committing abuse;

  • The automatic termination of their employment, or involvement with The Modern Minerva if found guilty of committing abuse, either by internal investigation or by a court.


If there is reasonable suspicion that a Member has been or is suffering abuse, the Police and the Organization’s Insurer will be contacted immediately. The phone number for The Modern Minerva is: 301-471-5114. The Police will also be notified if a Member discloses an incident of Abuse that has occurred somewhere other than The Modern Minerva premises, (e.g. an outing).


If a disclosure of abuse is made, the person who receives the disclosure will maintain appropriate pastoral care to the one making the disclosure. This will include:

  • Treating each allegation seriously and not attempting to deny the allegation or minimize its impact on the alleged victim. The matter should not be swept under the carpet.

  • Not pushing the Member to disclose details of the alleged assault or attempting to investigate the allegation.

  • Assuring the Member that they are understood: that their disclosure is being taken seriously; that what has happened is not their fault, and that they are correct in disclosing the incident.

  • Reporting the abuse to the police and The Modern Minerva's insurer.

  • Not making contact with the alleged perpetrator. If the Worker or Volunteer is already providing counsel to the alleged perpetrator, it may be advisable for another person to assume this responsibility for the duration of any investigation.

  • If the alleged assault has taken place recently, clothing worn by the Member should be, if reasonably practical, retained and handed to the police for forensic examination.

  • Maintaining confidentiality. Any disclosures by a Member, reports of suspected abuse and all details of the subsequent investigation will be documented promptly and the documents will be held in a secure location where a breach of privacy cannot occur.


9. Alcohol & Drugs

The consumption of alcohol or illegal drugs on The Modern Minerva grounds or during an activity is not to be allowed or condoned by any Worker. Any Member found to be under the influence of alcohol or illegal drugs is to be counseled and family contacted. 

Client Protection Policy