Rainbow Care & Coaching is committed to providing a safe, respectful, and professional environment for children, families, and staff. This Code of Conduct applies to everyone performing work at or on behalf of Rainbow Care & Coaching: employees, interns, ZZP’ers, volunteers, and external contractors. Section 1 · employees, interns & volunteers. Section 2 · ZZP’ers and independent contractors, without employment relationship.

Legal basis:

• Care & Youth: Jeugdwet · Wkkgz · WGBO
• Employment: Arbowet & Arbobesluit · Working Hours Act · CAO Gehandicaptenzorg · BW 7:611 & 6:248
• Privacy: AVG/GDPR · Trade Secrets Protection Act
• Safeguarding: Meldcode Domestic Violence & Child Abuse
• Integrity: Whistleblower Protection Act (2023)
• ZZP: Wet DBA

SECTION 1 · EMPLOYEES, INTERNS & VOLUNTEERS

1.1 VOG & CONTINUOUS SCREENING

A valid VOG is required before commencing work for everyone working directly with children (Art. 4.1.6 Jeugdwet):

• Employees and interns
• Volunteers with direct contact with children
• ZZP’ers and freelancers working directly with children
• Independent contractors with direct contact with children

In addition to the entry VOG, Rainbow Care & Coaching registers all relevant persons in the continuous screening system via Justis (Art. 4.1.6a Jeugdwet, in force since 1 March 2023). There is no fixed renewal interval. Justis screens automatically and continuously and notifies the organisation of any disqualifying conviction.

1.2 FOUR-EYES PRINCIPLE

Rainbow Care & Coaching applies the four-eyes principle as a standard safeguarding measure. Staff should always be visible to a second person during child contact where possible. When one-to-one contact is organisationally unavoidable, the following protocol applies:

• Notify a colleague or coordinator in advance
• Ensure visibility via window or open door where possible
• Document the contact in HiRasmus
• Report it to the coordinator afterwards

1.3 EATING, DRINKING & BREAK ENTITLEMENTS

• Eating only during breaks and only in staff/kitchen areas
• Exception outside breaks: a small snack if necessary for proper functioning, only if brief, discreet, not visible to children, and not interrupting supervision
• Eating is forbidden during therapy, group activities, or supervision
• Drinking (water, coffee, tea) only in a fully enclosed bottle, cup, or thermos, briefly and discreetly, without interrupting child supervision or interaction

1.4 PHONE USE & RIGHT TO DISCONNECT

Forbidden during working hours:

• Using personal phone visibly
• Texting, scrolling, calling, social media
• Photos/videos of clients on personal phones
• Private WhatsApp/social media contact with parents or clients

Permitted (work phone only):

• HiRasmus reporting and incident registration
• Communication with management
• Authorised photos/videos
• Microsoft Teams (internal only)

Right to disconnect: Employees are not expected to be reachable outside working hours, in accordance with the CAO Gehandicaptenzorg. Exceptions apply only to agreed on-call arrangements.

2. BOUNDARIES, INTEGRITY & GIFTS

2.1 Professional Boundaries

• Personal relationships with clients/parents are strictly forbidden
• Sharing personal phone numbers or social media is forbidden
• Providing private services (e.g., babysitting) is forbidden
• Visiting clients outside work is forbidden
• Private communication with parents via WhatsApp, calls, or social media is forbidden

2.2 Integrity & Conflicts of Interest

• Employees must avoid personal financial gain from the care relationship
• Avoid situations where private interests influence professional conduct
• Avoid external activities that conflict with the role at Rainbow Care & Coaching
• Suspected conflicts of interest must be reported to management immediately

2.3 Gifts & Treats

• Team treats (max €30 pp) require management approval
• Gifts to/from clients require written approval
• All gifts must be logged
• No cash or high-value gifts

3. RESPECT & DIGNITY

• Treat children with dignity and respect
• Use calm, supportive communication
• Maintain emotional control
• Use positive reinforcement
• Ensure safe and appropriate physical contact

Strictly forbidden: mocking, humiliation, sarcasm, shouting, rough handling

4. CONFIDENTIALITY, PRIVACY & SOCIAL MEDIA

• No photos/videos of clients on personal phones
• No sharing client information outside the organisation
• No forwarding HiRasmus content
• No storing client data on private devices
• No discussing clients with friends/family
• No WhatsApp or private email communication with clients
• No social media posts about organisation, clients, or colleagues
• Post-employment confidentiality remains under GDPR/Trade Secrets Act

5. DEVICE RULES

5.1 Work Phone

Permitted only for:

• HiRasmus reporting
• Incident reporting
• Management communication
• Work scheduling
• Authorised photos/videos
• Microsoft Teams

5.2 Personal Phone (no work phone provided)

Permitted for authorised work tasks:

• Uploading photos/videos to HiRasmus (only if authorised)
• Microsoft Teams for internal communication
• Group photos/videos for organisational social media (only with permission)

Mandatory when using media:

• Upload immediately to HiRasmus after capture
• Permanently delete before end of shift
• No backups, WhatsApp, AirDrop, or private storage

Forbidden on all devices:

• Social media (unless authorised)
• Personal calls (except emergencies)
• Private messaging during working hours
• Entertainment apps (TikTok, Instagram, etc.)

6. MELDCODE & IGJ REPORTING OBLIGATION

Under Art. 4.1.1 Jeugdwet, all employees follow the five-step Meldcode process when there are suspicions of domestic violence or child abuse:

1. Identify and map signals
2. Consult a colleague or reporting centre
3. Conversation with those involved
4. Assess the severity
5. Decide: report or arrange support

In case of acute danger: report immediately to Veilig Thuis and management.

IGJ reporting obligation (Art. 4.1.8 Jeugdwet):

Separate from the Meldcode, Rainbow Care & Coaching as an organisation has a standalone obligation to report calamities and violence within the care relationship to the IGJ. Employees must report such incidents immediately internally so the organisation can fulfil this obligation. This is a parallel, non-substitutable requirement.

7. REPORTING, GRIEVANCES & WHISTLEBLOWER PROTECTION

Employees must immediately report:

• Boundary violations
• Safety risks and privacy breaches
• Suspected child abuse
• Unethical or unprofessional conduct
• Suspected integrity violations

Internal reporting channel:

Reports may be made to management or, if preferred, to the internal confidential adviser (vertrouwenspersoon) for staff.

Employees reporting in good faith are protected under the Whistleblower Protection Act (Wet bescherming klokkenluiders, 2023). Retaliation is prohibited.

Concerns about this Code may be raised with management or the confidential adviser.

8. TRAINING & DEVELOPMENT

• Attend mandatory training
• Participate in supervision
• Maintain required certifications
• Follow all internal policies and instructions

Failure to comply may lead to disciplinary action.

9. ENFORCEMENT

Violations may result in:

• Verbal warning
• Written warning
• Mandatory retraining
• Removal from child contact
• Suspension with continued pay pending investigation (per CAO Gehandicaptenzorg)
• Termination of contract
• Legal action in severe cases

SECTION 2 · ZZP’ERS & INDEPENDENT CONTRACTORS

Important: Ensures child safety and legal compliance without creating an employment relationship. ZZP’ers remain independent contractors.

2.1 LEGAL & PROFESSIONAL STANDARDS

Under applicable law (Jeugdwet, Arbowet, AVG, Meldcode), ZZP’ers must:

• Communicate respectfully
• Protect the dignity and safety of children
• Maintain appropriate physical contact
• Behave professionally

No mocking, humiliation, or rough handling.

VOG (statutory requirement, Art. 4.1.6 Jeugdwet):

• Valid VOG required before commencing work
• Registration in continuous screening via Justis required (Art. 4.1.6a Jeugdwet)

This is a statutory requirement, not an employer instruction.

2.2 EATING & DRINKING (STATUTORY SAFETY STANDARD)

Under the statutory child safety obligation (Jeugdwet):

• No eating during child contact
• Drinks only water/coffee/tea in a closed bottle or thermos, briefly and discreetly, without interrupting supervision

2.3 PHONE & DEVICE USE (GDPR OBLIGATION)

Under the GDPR, personal phones may only be used for authorised professional tasks:

• Photos/videos for HiRasmus (only with explicit permission)
• Upload immediately to HiRasmus, then permanently delete before end of shift
• Microsoft Teams for internal communication
• Contacting centre or management for work coordination

Forbidden (GDPR obligation):

• Client communication or contact with parents
• Storing client media in iCloud, Google Photos, or private cloud
• Keeping screenshots or copies
• Sharing client media via WhatsApp, SMS, AirDrop, or social media

2.4 CONFIDENTIALITY (STATUTORY OBLIGATION)

Under the GDPR and Jeugdwet:

• Protect client information
• Follow privacy laws
• Follow the Meldcode
• Maintain confidentiality after assignments end

Breaches may lead to immediate termination of collaboration.

2.5 SAFETY REPORTING & IGJ (STATUTORY OBLIGATION)

Under the Jeugdwet and Meldcode, ZZP’ers are legally required to immediately report:

• Suspected abuse
• Safety risks
• Privacy breaches
• Boundary violations
• Behaviour endangering children

Report to management so the organisation can fulfil its IGJ reporting obligation (Art. 4.1.8 Jeugdwet).

This is a statutory obligation, not an employment instruction.

2.6 INDEPENDENCE & ASSIGNMENT CONDITIONS (WET DBA)

• ZZP’ers choose their own working methods
• ZZP’ers may accept or decline assignments
• ZZP’ers may work for other organisations
• ZZP’ers handle their own training, taxes, and insurance
• ZZP’ers are not subject to employer-style discipline

Rainbow Care & Coaching may end collaboration immediately if:

• Safety is compromised
• Confidentiality is breached
• Legal obligations are violated
• Professional standards are not met

This is termination of assignment, not a disciplinary measure.

2.7 NO EMPLOYMENT RELATIONSHIP

Nothing in this Code creates:

• Employer authority
• Employee rights
• Subordination
• Fixed schedules
• Mandatory attendance at staff meetings
• Mandatory training requirements

ZZP’ers remain independent at all times.