Organizational and Control Model for Sports Activities

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ASSOCIAZIONE SPORTIVA DILETTANTISTICA BOMBOKLAT SURF SCHOOL
Registered Office: Via E. Mattei 21/D - 20007 Cornaredo (MI) Tax Code/VAT: 07603170965

This organizational and control model for sports activities is drafted by the Association in accordance with paragraph 2 of Article 16 of Legislative Decree No. 39 of February 28, 2021, and based on the guidelines published by ACSI.

It applies to anyone participating in the Association's activities in any capacity or role, regardless of the sport practiced. It is valid for four years from the date of approval and must be updated whenever necessary to incorporate any changes or additions to the Fundamental Principles issued by CONI, any further provisions from the CONI National Council, and recommendations from the CONI Permanent Safeguarding Policy Observatory.

The aim of this model is to promote an inclusive culture and environment that ensures dignity and respect for the rights of all members, particularly minors, guaranteeing equality and fairness, while valuing diversity and protecting the physical, psychological, and moral integrity of all members.

This model is published on the Association’s website homepage, displayed at the Association's headquarters, and communicated to the National Safeguarding Policy Manager as outlined in Art. 4 of the ACSI SAFEGUARDING REGULATIONS, along with the appointment of the person responsible for preventing abuse, violence, and discrimination.

This model integrates the Regulation for the protection of members from abuse and discriminatory behavior of the Association to which Bomboklat is affiliated.

Rights and Duties

All members are entitled to the following fundamental rights:

  1. To be treated with dignity and respect in every relationship, context, and situation within the association;
  2. To be protected from any form of abuse, harassment, gender-based violence, and all other forms of discrimination, regardless of ethnicity, personal beliefs, disability, age, gender identity, sexual orientation, language, political opinion, religion, economic status, birth, physical, intellectual, relational, or athletic condition;
  3. To have their health and physical-mental well-being prioritized over any sports result.

Anyone participating in sports activities, in any capacity and function, directly or indirectly, must comply with all provisions protecting these rights.

Coaches, managers, members, and all other affiliates must be familiar with this model, the Code of Conduct for the protection of minors, the prevention of harassment, gender-based violence, and all other forms of discrimination, as well as the ACSI Regulation for the protection of members from abuse and discriminatory conduct.

Everyone involved in association life, in any capacity, must respect the fundamental principles of non-discrimination and non-violence in competitions, training, shared spaces (e.g., locker rooms), and in interactions with athletes, members, coaches, and staff of their own and other associations/sports clubs.

Privacy Protection

All students (or those exercising parental authority), coaches, managers, collaborators, and members of the Association must be provided with the privacy notice regarding personal data processing pursuant to Article 13 of EU Regulation 679/2016 (GDPR) at the time of registration/membership, and in any case whenever personal data is collected.

Collected data must be managed and processed in accordance with the procedures described in the Regulation, and only based on the necessity for the execution of the contract to which the data subjects are parties, the fulfillment of a legal obligation, or based on the consent provided.

With specific written consent obtained at the time of registration or membership, the Association may publish on its communication channels photographs of members taken during training and competitions. However, it is not permitted to produce or publish images that could cause embarrassment or danger to the members.

Documentation, whether in paper or digital format, collected by the Association containing personal data of members, suppliers, or any other subject must be stored securely, ensuring it is inaccessible to unauthorized individuals. In case of loss, deletion, accidental disclosure, data breach, etc., prompt notification must be given to the data subject and simultaneously to the Data Controller. Notification must also be made to the Data Protection Authority if the data breach poses a risk to the rights and freedoms of natural persons.

All individuals authorized to process personal data must be adequately trained and must implement all necessary behaviors and procedures to protect the personal data of the data subjects, especially those falling into special categories of personal data.

Inclusiveness

The Association guarantees all its students and members of other amateur sports associations and clubs equal rights and opportunities, regardless of ethnicity, personal beliefs, disability, age, gender identity, sexual orientation, language, political opinion, religion, economic condition, birth, physical, intellectual, relational, or sports-related status.

The Association commits, including through agreements, conventions, and collaborations with other amateur associations or clubs, to guarantee the right to sport for students with physical or intellectual-relational disabilities.

The Association also commits to ensuring the right to sport for economically or socially disadvantaged athletes by promoting their participation in association activities, including through membership fee discounts and/or agreements, conventions, and collaborations with third-sector entities operating in the local area and neighboring municipalities.

Reporting and Addressing Harmful Behaviors

Reporting Harmful Behaviors

In the event of alleged harmful behavior by members or third parties against other members, especially minors, it must be promptly reported to the Officer for the Prevention of Abuse, Violence, and Discrimination via verbal communication or email to: samu.laquintana@gmail.com

Only the Officer will have access to this email address.

The email address must be made known to all members and published on the Association's official website, social media, and displayed prominently in the office. It must also be indicated in the Association membership form, of which a copy is given to the member.

If a report involves a minor as the alleged victim, the parents or legal guardians must be informed, provided this does not pose a risk to the minor's safety.

Reports of such harmful behavior must also be submitted to the Safeguarding Office at the following link: https://acsi.safeguarding.openblow.it

In the case of serious harmful behavior, the Association must notify the authorities of the facts in its possession.

The Association must implement appropriate measures to prevent any form of secondary victimization of members who in good faith:

  1. filed a report or complaint;
  2. expressed the intention to file a report or complaint;
  3. assisted or supported another member in filing a report or complaint;
  4. testified or were heard in proceedings regarding abuse, violence, or discrimination;
  5. undertook any other action or initiative related to safeguarding policies.
Disciplinary System and Sanctioning Mechanisms

By way of example and not limitation, sanctionable behaviors may include:

  1. Negligent failure to implement the measures set out in the Model and its supporting documents (e.g., Code of Conduct for the protection of minors and the prevention of harassment, gender‑based violence, or any other form of discrimination);
  2. Willful violation of the measures in this Model and its supporting documents, thereby undermining the relationship of trust with the Association and being clearly aimed at committing an offense;
  3. Violation of measures put in place to protect the whistleblower;
  4. Submission, with intent or gross negligence, of reports that prove unfounded;
  5. Failure to fulfill information obligations toward the Association;
  6. Breach of provisions regarding information, training, and dissemination to the recipients of this Model;
  7. Retaliatory or discriminatory acts, direct or indirect, against the whistleblower for reasons linked to the report;
  8. Failure to apply this disciplinary system.

Sanctions vary according to the legal relationship with the offender, the seriousness of the violation, the role and responsibility of the offender, the degree of negligence or intent, any recurrence, position held, seriousness of risk created, extent of damage, and any aggravating or mitigating circumstances.

This sanctioning system must be made known to all Recipients of the Model by means deemed most appropriate by the Association.

Sanctions for Paid Collaborators

Conduct by paid collaborators that violates this Model—including information obligations—and its supporting documents constitutes disciplinary misconduct.

The following sanctions may be imposed on paid collaborators, proportionate to the nature and seriousness of the violation:

  • Verbal warning for minor offenses;
  • Written warning in case of recurrence;
  • Fine not exceeding five hours’ pay;
  • Suspension without pay for up to 15 days;
  • Contract termination and, for member‑collaborators, expulsion from the Association.

Specifically:

  1. Verbal warning for negligent, internally irrelevant breaches of procedures or the Code of Conduct.
  2. Written warning for recurring breaches or negligent misconduct with external relevance.
  3. Fine (≤ 5 hours’ pay) for further recurrences or, given rank or aggravating factors, for misconduct undermining the Model, including:
    • Failure to inform the Safeguarding Officer; filing grossly negligent false reports;
    • Violating whistleblower‑protection measures; repeated non‑compliance when dealing with public or sports authorities.
  4. Suspension (≤ 15 days) for repeated fined misconduct or deliberate false reports/retaliation.
  5. Dismissal without notice for fraudulent circumvention of the Model or obstruction of internal controls (removal, destruction, or alteration of documents, denial of access, etc.).

Sanctions for Volunteers

The following sanctions may be imposed on volunteers, proportionate to the seriousness of the violation:

  1. Verbal warning for minor misconduct;
  2. Written warning for recurrence (see above);
  3. Removal from training and competition facilities for up to 15 days;
  4. Removal for up to one year;
  5. Termination of volunteer relationship and, if a member, expulsion.

Sanctions for Other Participants

Where applicable, the above provisions extend to all persons who frequent areas where the Association’s sports activities take place.

Training, Information Obligations, and Other Measures

The Association must publish this Model and the name of the Officer for the Prevention of Abuse, Violence, and Discrimination at its headquarters and facilities under its management or use, as well as on the home page of its official website.

Upon adoption of this Model and whenever it is amended, the Association must notify all members, associates, and volunteers by email. The Association must inform each member—or, where applicable, those exercising parental authority or those entrusted with athlete care—about this Model and the Officer’s name and contact details.

The Association must immediately communicate any relevant information to the Officer, to the Safeguarding Office of the competent sports federation, and, where applicable, to the Federal Prosecutor’s Office. The Association must disseminate suitable information to its members to prevent and combat abuse, violence, and discrimination, and to raise awareness of members’ rights, duties, and protections.

The Association must adopt adequate measures to distribute or provide access to informational materials aimed at raising awareness of and preventing eating disorders among athletes.

The Association must provide appropriate information to members—or, where applicable, to those exercising parental authority or entrusted with athlete care—regarding specific measures adopted to prevent and combat abuse, violence, and discrimination during sporting events.

The Association must inform members—or, where applicable, those exercising parental authority or entrusted with athlete care—of any other Safeguarding policies adopted by its affiliated sports federations.

Every six months, the Association, including through agreements with the EPS or Federation to which it is affiliated, organizes specific training programs to educate its members on fundamental principles and adopted prevention policies. Participation is mandatory for members and anyone involved in Association activities and must be evidenced by specific certificates.

Useful Websites
  • battiamoilsilenzio.gov.it

    Website of the technical working group set up by the Department for Sport to co‑create and promote a safeguarding policy for young female and male athletes.

  • savethechildren.it

    Save the Children page on abuse in sport involving minors: best practices for prevention.

  • sportesalute.eu

    Page dedicated to sports inclusion on the Sport e Salute website.

Related Documents
  • Attachment to:

    BOMBOKLAT SURF SCHOOL AMATEUR SPORTS ASSOCIATION
    Registered Office: Via E. Mattei 21/D – 20007 Cornaredo (MI) – VAT/Tax ID 07603170965
    Code of Conduct for the Protection of Minors and for the Prevention of Harassment,
    Gender‑Based Violence and Any Other Form of Discrimination

    The recipients of this Code are instructors, coaches, managers, collaborators of any title, level or qualification, employees and volunteers. They are responsible for the development of young students and members and for creating a positive, safe and stimulating environment for sporting practice. They must therefore set a good example and be role models for all students affiliated with the Association.

    Everyone listed above who has direct contact with minor students and members must respect this Code, which they fully accept after reading it. Any alleged breach must be reported to the Association’s Safeguarding Officer and dealt with as set out in the organisational and control model. Measures and sanctions are indicated therein.

    The Association is committed to guaranteeing a safe, respectful and inclusive environment for all members, including minors and vulnerable adults. This Code establishes the expectations and responsibilities for everyone involved in the Association’s activities.

    Every student and member has the fundamental right to be treated with respect and dignity and to be protected from any form of abuse, harassment, gender‑based violence and discrimination, as provided by Legislative Decree 198/2006, irrespective of race, beliefs, disability, age, gender identity, sexual orientation, language, political opinion, religion, financial status, place of birth, physical, intellectual, relational or sporting characteristics.

    No discrimination of any kind is tolerated, whether based on race, colour, sex, sexual orientation, language, religion, political opinion, nationality, social origin, economic means, birth or any other personal circumstance.

    The Association expressly prohibits, repudiates and sanctions any form of:

    • Psychological abuse – any intentional, unwanted act such as isolation, coercion, verbal aggression, intimidation, or other behaviour that can harm a person’s identity, dignity or self‑esteem, or disturb their tranquillity, including via digital means.
    • Physical abuse – any deliberate act (beating, punching, kicking, throwing objects, etc.) that can cause real or potential harm to health or development, including forcing inappropriate physical activity.
    • Sexual harassment – any unwanted verbal, non‑verbal or physical conduct of a sexual nature that causes serious discomfort, distress or offence.
    • Sexual abuse – any sexual behaviour, with or without physical contact, that is unwanted or where consent is forced, manipulated, absent or denied.
    • Gender‑based violence – psychological, physical or sexual violence, including stalking or gender discrimination.
    • Bullying and cyber‑bullying – offensive or aggressive conduct on‑ or offline intended to dominate or intimidate others, causing discomfort, insecurity or isolation.
    • Hazing – humiliating and/or dangerous initiation of new members by senior members.
    • Religious abuse – limiting or conditioning the right to freely practice one’s faith.
    • Neglect – failure to meet essential physical, medical, educational or emotional needs.
    • Other discriminatory behaviour – any conduct producing discrimination based on ethnicity, colour, physical traits, gender, socio‑economic status, sporting ability, religion, beliefs, disability, age or sexual orientation.

    GENERAL CONDUCT RULES

    Students, members and everyone taking part in sporting activity MUST NOT:

    • Discriminate or display inappropriate attitudes based on race, colour, sex, sexual orientation, language, religion, political opinion, nationality, social origin, economic means or birth;
    • Physically assault or psychologically abuse another person;
    • Display behaviour that could negatively affect others’ psychological development;
    • Set a negative example, especially for minors;
    • Engage in sexual, exploitative or abusive relations with minors;
    • Act in abusive ways;
    • Use offensive or abusive language or suggestions;
    • Behave inappropriately or provocatively from a sexual standpoint;
    • Contact minor members through private online tools outside institutional channels;
    • Tolerate or partake in illegal or abusive behaviour;
    • Invite minors to non‑institutional social events without parental consent;
    • Shame, humiliate or belittle others or commit emotional abuse;
    • Discriminate or favour some individuals while excluding others.

    DUTIES OF STUDENTS

    The following duties apply to students and course participants:

    • Show loyalty, honesty and fairness in all sporting activities and respect other students;
    • Avoid inappropriate or suggestive language, even jokingly;
    • Communicate feelings of anxiety, fear or discomfort about themselves or others to coaches;
    • Prevent and report situations that may put others in subjection, danger or fear;
    • Respect and safeguard the dignity, health and wellbeing of all participants;
    • Recognise and respect the educational role of coaches;
    • Help create a healthy, safe and inclusive environment;
    • Promote a healthy balance between personal life and sport, valuing social aspects;
    • Maintain balanced relations with parents or guardians;
    • Collaborate in preventing and combating abuse and discrimination;
    • Not share private photos or videos;
    • Promptly report potential risks to the Safeguarding Officer.

    DUTIES OF ADMINISTRATORS AND COACHES

    The following duties apply to administrators and coaches:

    • Actively prevent and combat abuse, violence and discrimination;
    • Avoid misuse of their position of trust or influence, especially with minors;
    • Contribute to the harmonious development of students, particularly minors;
    • Limit physical contact with minors to the minimum necessary;
    • Promote respectful relations among students and prevent manipulative situations;
    • Avoid creating intimate situations with minors;
    • Ensure logistic solutions on trips to prevent discomfort or inappropriate behaviour, involving guardians in decisions;
    • Share educational goals with minors and involve guardians in choices;
    • Avoid intimate communications with minors, including via social networks;
    • Immediately cease contact if their conduct causes anxiety or discomfort and alert the Safeguarding Officer;
    • Use professional expertise when planning dietary regimes;
    • Report signs of eating disorders among students;
    • Declare any conflicts of interest;
    • Promote sporting values;
    • Stay informed on safeguarding policies and modern training methods;
    • Use or share images of minors only for educational purposes with proper authorisation;
    • Promptly report risks to the Safeguarding Officer.

    SPECIFIC RULES WHEN WORKING WITH MINORS

    When working with minors, it is necessary to:

    • Organise activities to minimise risk;
    • Remain visible to other adults whenever possible;
    • Use images of minors only for educational purposes with guardian authorisation;
    • Avoid intimate situations with minors;
    • Share educational goals with minors involving their guardians;
    • Avoid intimate communications with minors, including on social networks;
    • Cease contact and inform the Safeguarding Officer if anxiety or discomfort arises;
    • Promote an open culture allowing discussion of concerns;
    • Maintain balanced relationships with guardians;
    • Value minors’ abilities and discuss their rights and safety strategies;
    • Keep high personal and professional standards;
    • Treat minors fairly, honestly and with respect;
    • Encourage minors’ active participation to develop self‑protection skills.

    SIGNS OF DISTRESS AND DISCOMFORT

    Examples of distress signals include:

    • ⚠️Sudden unexplained behaviour changes (isolation, depression, fear, mood swings, reluctance to train or compete) possibly with performance drops;
    • ⚠️Eating disorders;
    • ⚠️Physical signs or behavioural changes indicating distress;
    • ⚠️Unexplained bruises, cuts or burns, especially on unusual body parts;
    • ⚠️An implausible explanation for an injury;
    • ⚠️A child stating they have been abused;
    • ⚠️Distrust toward coaches or other adults who should be trusted;
    • ⚠️Neglect and frequent loss of personal belongings.

    Note: the presence of one or more signals is not by itself proof of abuse; developmental stages such as adolescence may show similar behaviour.

    SELECTION PROCEDURES FOR SPORTS OPERATORS

    When the Association establishes any form of work relationship with operators having direct, regular contact with minors, it must first obtain a criminal record certificate and child‑protection clearance in accordance with current legislation.

    PROCEDURES IN CASE OF POSSIBLE CONCERNING BEHAVIOUR

    Everyone must watch for situations that may pose risks and report any concern, suspicion or certainty of abuse, maltreatment, violence or discrimination to one of the following:

    If minors are involved, distress signals may be promptly shared with parents or guardians unless they are implicated or unable to handle the situation, in which case consult the Safeguarding Officer.

    INFORMATION, COMMUNICATION AND PRIVACY

    All members are informed of the Association’s Safeguarding Officer contacts and the national ACSI Safeguarding Office email. We communicate clearly, openly and respectfully with participants, parents and colleagues, providing copies of the Code of Conduct and the reporting form.

    We respect members’ privacy and keep personal or sensitive information confidential.