What Changed After We Left
A side-by-side comparison of TSIS's 2018 Child Protection Policy and the 2025 Child Safety Handbook, examined alongside the documented events that occurred between them.
Tien Shan International School's child safeguarding documentation exists in two distinct versions. The first is a 5-page policy dated June 2018, which was in effect during the events of 2024. The second is a 33-page handbook dated December 2025, published after Joe and Sharon Byerly left the school and before CRU and IMB were placed on formal legal notice in February 2026.
The comparison below places the two documents side by side in seven areas, alongside the documented events from 2024–2025. In several cases, the administration's own statements at an April 7, 2025 parent meeting corroborate the gaps identified. Readers can draw their own conclusions about the relationship between what happened and what changed.
The 2025 handbook is publicly accessible and linked from the school's website. The 2018 policy was publicly available at the time of these events but has since been removed from the school's site; copies are retained in our records.
At a Glance
What existed in 2018 vs. what was added by 2025.
| Provision | 2018 Policy | 2025 Handbook |
|---|---|---|
| Standing Child Safety Team (CST) | Did not exist | Full standing committee with defined roles |
| Response Team protocol | Ad hoc "crisis team" | Formal RT with appointment process, conflict of interest rules |
| Category system (A/B/C) | Did not exist | Three-tier classification with escalation paths |
| Misconduct assessment framework | Did not exist | 8-step process with written findings, due process, appeal |
| Child Safety / Impact assessments | Did not exist | Defined assessment types aligned with CSPN |
| Whistleblower protection | One sentence | Full appendix with explicit protections |
| Anti-retaliation language | Implied in non-retaliation sentence | Retaliation explicitly defined as misconduct, "strictly forbidden" |
| Conflict of interest provisions | Did not exist | Mandatory recusal for respondents and conflicted parties |
| Reporting path if Director is involved | One sentence: "notify the Board Chair" | Defined process: CST Lead reports to Board; Board may engage independent investigator |
| External investigator provision | Did not exist | CST Lead may "engage an external, third-party investigator" |
| Board grievance process | Did not exist | Written appeal to the Board within 5–10 working days |
| CSPN affiliation | Not mentioned | CSPN membership, PET/RTT training referenced throughout |
| Code of Conduct (separate signed doc) | Combined with policy | Standalone document with 6 sections, signature required |
| Communication/social media boundaries | Did not exist | Detailed guidelines: monitored platforms, no private DMs |
| Healthy touch guidelines | Did not exist | Age-specific guidelines for elementary and secondary |
| Grooming definition | Sexual abuse only | Sexual abuse only (but added separate "inappropriate behavior" category) |
| Document length | ~5 pages (English) | 33 pages + 7 appendices |
1. Who Controls the Process
The single most important structural difference between the two documents.
Everything flows through the Director. Reports go to the Director. The Director initiates investigations. The Director determines outcomes. The Director controls confidentiality. The Director decides whether to contact parents. The Director decides whether the accused is removed from contact with children.
If the Director is involved, the only recourse: "the school Board Chair is to be notified." One sentence. No process defined.
A standing Child Safety Team maintains the safeguarding program. A Response Team is formed for each incident. The CST Lead manages the process and writes the report. The Director is informed and consulted but does not single-handedly control the response.
If the Director is the concern, the CST Lead reports to the Board, which "may contact an independent third-party investigator to initiate a formal action."
The Director at the time controlled the safeguarding response to reported grooming by a teacher. According to the Byerlys and the child safety team, when the team produced an 11-page findings report, the administration altered the findings before communicating them to the teacher. When Joe raised concerns about the Director's handling of the situation, the Director reportedly told students Joe was "delusional." Under the 2018 policy, there was no structural mechanism to prevent a Director from exercising this level of control over the process.
Notably, at the April 7, 2025 parent meeting, the Director himself acknowledged this structural failure, stating: "When I was in a conflict of interest, I was not able to carry out responsibility, and, definitely, it's on me in that time." The CST Lead similarly acknowledged: "We didn't really have rigorous guidelines when these things continue to come forward... we were operating off of our old child safety policy... it wasn't updated since 2018."
2. Whistleblower Protection
"TSIS will not retaliate against anyone for reporting any incidents of inappropriate behavior or for making a complaint under this policy, so long as it is not discovered that the complaint was made specifically to slander another's character."
One sentence. No process. No protections. No definition of retaliation.
Full Whistleblowing Policy (Appendix B) with explicit commitments to: providing clear reporting channels, investigating concerns "thoroughly and fairly," protecting whistleblowers from "retaliation, punishment, or discrimination," and keeping the reporter's identity confidential.
Retaliation is separately defined as a form of misconduct: "Retaliation against alleged victim(s), complainant(s), witnesses, or staff members is strictly forbidden... Retaliation can take many forms, including but not limited to shunning, threats, or any other intimidation."
According to Joe and Sharon Byerly, after Joe raised safeguarding concerns: he was told he was "trying to destroy the school"; his credibility was undermined with staff and students; students were told he was "delusional"; Sharon was pressured to doubt his experience; his reporting structure at IMB was changed without explanation; he was given 30 days to leave the country; and he was pressured to remove a song addressing the situation. The Byerlys characterize these actions as retaliation for their safeguarding advocacy. The 2018 policy offered one sentence addressing retaliation. The 2025 policy now names behaviors matching this description as misconduct.
3. Conflict of Interest
No conflict of interest provisions existed. No requirement for recusal. No rules about who could or could not participate in investigations or responses.
"Anyone facing an allegation (the respondent) and anyone with an apparent conflict of interest must be recused from any response actions."
Response Team members are "selected in a way that mitigates conflicts of interest."
If any CST or RT member "acts independently without collaboration, fails to carry out their responsibilities, or withholds critical information, they may be subject to removal from the team within 72 hours."
According to the Byerlys, board member Jonathan McDonald, acting in his role as a board member, influenced aspects of the child safety process and worked to discredit the child safety team. Under the 2018 policy, there were no conflict of interest provisions that would have required his recusal or limited his involvement. The 2025 version now explicitly requires recusal for anyone with a conflict of interest, and provides for removal of team members who act independently or withhold information.
4. Assessment and Response Framework
Basic investigation procedure: notify the accused, form a crisis team (if possible), investigate, report to the Director, Director decides. No categories. No structured assessment types. No flowchart. No due process for the accused beyond being informed and the investigation being "objective."
No provision for written responses, support persons, or appeals.
Three-tier category system (A/B/C) with defined escalation paths. Three assessment frameworks: Child Safety Assessment, Misconduct Assessment, and Impact Assessment. An 8-step misconduct procedure including written notification, the right to a written response, the right to a support person during interviews, written findings shared with affected parties, and a formal appeal process through the Board.
The child safety team compiled an 11-page findings document and submitted it to administration per the school's safeguarding procedures. According to the Byerlys, the administration altered the findings, weakened the conclusions, and presented violations in vague terms without a defined accountability path.
This account is corroborated by the administration's own statements at the April 7, 2025 parent meeting. The CST Lead, Sunna, acknowledged: "We didn't really have rigorous guidelines when these things continue to come forward... we were reacting without very clear, robust policy." The Director acknowledged "missteps in the process and some unclear communications." The board subcommittee conducted its own review, arriving at conclusions that differed from the original CST findings — agreeing with some findings while rejecting the grooming characterization. Under the 2018 framework, there was no established protocol governing how CST findings should be communicated, who had authority to modify them, or how disagreements between the CST and leadership should be resolved.
5. Communicating with Parents
"It is the responsibility of the Director to inform the parents and to work as quickly and sensitively as possible."
The Director controlled parent communication. No requirement for the child safety team to communicate directly with families. No exception clause defined.
"Parents of involved Students will be informed, unless doing so would increase the risk of harm."
The CST is responsible for informing "appropriate authorities (i.e., parents, sending organizations, embassies, local authorities, etc.) in a timely manner."
"When it is appropriate to reassure the community and/or counter harmful narratives, the CST will make public statements to the affected communities."
According to the Byerlys, when students disclosed that a teacher had discussed personal struggles with pornography in co-ed classroom settings, the child safety team proposed communicating transparently with affected families. The administration did not support this communication. Parents were not informed.
The extent of this information gap was confirmed at the April 7, 2025 parent meeting, where parents expressed confusion about basic facts. One parent stated: "this touching thing, I never heard of that until now." Another said: "I'm getting bits and pieces from my kids that I didn't even know... they've been having discussions in their classrooms with the teachers giving them information I didn't even know about." Multiple parents asked how they were supposed to make decisions about their children's safety without adequate information.
The 2025 version now assigns parent communication responsibility to the CST rather than the Director alone, and adds a provision for public statements to "counter harmful narratives."
6. Defining Grooming
Definition: "Befriending and establishing an emotional connection with a child and sometimes the family, to lower a child's inhibitions for sexual abuse."
Grooming was defined exclusively as a precursor to sexual abuse. No category for grooming toward emotional abuse or codependency.
Definition: "The process of intentional manipulation to build trust, gain access, and initiate or maintain sexual abuse." (Adapted from ICMEC.)
Still anchored to sexual abuse. However, the 2025 version adds a new category: "Inappropriate Behavior" — defined as interactions that "raise concerns for the child's safety or well-being but do not meet the legal definition of abuse." This category did not exist in 2018.
According to Joe Byerly's contemporaneous communications, the child safety team's findings characterized the behavior in question as grooming "most likely for emotional codependency." This finding did not cleanly fit the 2018 policy's grooming definition, which required grooming to be directed toward sexual abuse.
The process by which the definition was subsequently narrowed is documented in the transcript of the April 7, 2025 parent meeting. At that meeting, TSIS administrator Ruth presented three grooming definitions side by side to parents:
Definition 1 (described as "latest research-based"): "Building a relationship, trust, and emotional connections with the child and possibly their family or community which breaches boundaries and may lead to manipulation, exploitation, and abuse."
Definition 2 (the school's own 2018 policy): "Befriending and establishing an emotional connection with a child and sometimes a family to lower a child's inhibitions for sexual abuse."
Definition 3 (ICMEC, recommended by administration going forward): "Intentional manipulation to build trust, gain access, and initiate or maintain sexual abuse."
The administration recommended adopting Definition 3 — the ICMEC definition — which is the narrowest of the three. It requires both intentional manipulation and a connection to sexual abuse. Under this definition, the board subcommittee's conclusion followed: "there was a breach of the code of conduct, but there was no child or sexual abuse."
Notably, the board subcommittee agreed that the teacher "did engage in unhealthy touch on multiple occasions" and agreed that the teacher failed to protect students from "ridicule and humiliation." But it rejected the child safety team's grooming finding, stating that "Miss Bader's attention came from a positive place of helping students grow closer to Jesus" and that "the board rejects the notion that Miss Bader's actions resemble child grooming."
The 2025 handbook adopted the ICMEC definition recommended at this meeting. The addition of "inappropriate behavior" as a separate category provides a way to classify conduct that the broader research-based definition would call grooming but that the ICMEC definition does not.
One parent at the meeting, Zach Gallimore, identified the core tension: the investigation found grooming behaviors, but the board concluded there was no grooming intent. He noted: "On one hand, you've got kind of objective things like behaviors that can be visibly seen. On the other hand, you've got intent of the heart, which no human being can know... which is why policies are so important because we don't know people's hearts."
7. Screening and Background Checks
"Careful screening and selection of faculty and employees with regard to any history of child abuse. TSIS does not employ anyone with a prior conviction for or history of child sexual abuse."
General language. No mention of "comprehensive background checks" or "verification of multiple references."
"TSIS implements rigorous recruitment procedures, including comprehensive background checks and verification of multiple references."
Mandatory training "before beginning work" is now required. Training records are "signed and maintained."
According to the Byerlys, a staff member reported having worked at the school for months without ever receiving a background check. The 2025 version's strengthened screening language and documentation requirements address this type of gap.
What This Tells You
A school does not typically expand a 5-page policy into a 33-page handbook with seven appendices without reason.
Each major addition in the 2025 Child Safety Handbook corresponds to a documented event from 2024. In several cases, the school's own leadership has publicly acknowledged the gaps:
The Director controlled the entire process → The 2025 version created an independent CST and RT. The Director himself acknowledged at the parent meeting that he was "in a conflict of interest" and unable to carry out his responsibilities.
Those who raised concerns reported experiencing retaliation → The 2025 version added a whistleblower protection appendix defining retaliation as misconduct.
A board member reportedly interfered in the process → The 2025 version added conflict of interest provisions requiring recusal.
Findings were reportedly altered before communication → The 2025 version added a structured misconduct assessment framework. The CST Lead acknowledged at the parent meeting that the team was "reacting without very clear, robust policy."
Parents were not informed of classroom disclosures → The 2025 version assigned parent communication to the CST. At the parent meeting, parents confirmed they had received almost no information about the events affecting their children.
The behavior identified did not fit the grooming definition → The administration explicitly presented competing definitions at the parent meeting and selected the narrowest one. The 2025 version adopted that definition and added an "inappropriate behavior" category.
A staff member reported never receiving a background check → The 2025 version added "comprehensive background checks" and documentation requirements.
The school has not publicly acknowledged these events. It has not explained why the policy was rewritten. It has not addressed the events of 2024 transparently with its community.
The documents, however, speak to what the institution recognized needed to change.
In our view, the 2025 handbook is not primarily evidence that the school takes child safety seriously going forward. It is evidence that the school recognized its prior framework was insufficient. The community deserves to know why.
What Remains Unaddressed in the 2025 Policy
A longer document is not necessarily a more effective one if structural vulnerabilities remain. The 2025 handbook is a significant improvement on paper, but several weaknesses persist — some carried over from 2018, others introduced by the rewrite itself.
1. The Director Retains Decisive Control
The 2025 version creates a CST and RT, but the Director retains decisive authority over outcomes. Category C cases — the most serious, including staff misconduct — are "immediately reported to the Director." The misconduct assessment happens "in consultation with the Director" who is "included in all stages." The Director controls whether the accused is suspended. The Director initiates disciplinary actions.
The CST and RT gather information and make recommendations. The Director decides what happens with those recommendations. Under this structure, a Director who wished to soften findings, delay action, or limit transparency would have the procedural authority to do so.
What would strengthen this: Require that CST findings and recommendations be shared directly with affected parties and sending organizations before the Director acts on them. Give the CST authority to escalate to the Board independently if the Director's response is inconsistent with the findings. Remove the Director from direct control of misconduct assessments involving staff they supervise.
2. The Board Has Almost No Defined Oversight Role
The Board only appears in two contexts in the 2025 handbook: when the concern involves the Director (Section 4:2a), and in the grievance process (Appendix D, Step 8). There is no requirement for the Board to receive regular reports on child safety incidents, audit the CST's work, review the outcomes of misconduct assessments, or verify that the school's safeguarding practices match its written policies.
This means the Board can remain entirely uninformed about safeguarding concerns until someone escalates to them — a step that, as the documented events suggest, institutional dynamics can actively discourage.
What would strengthen this: Require quarterly reporting from the CST to the Board, including the number of concerns raised, their categories, outcomes, and any unresolved issues. Designate at least one Board member with a safeguarding oversight role and access to the Community Safety Drive.
3. Independent Investigation Is Discretionary
Section 4:2a says the Board "may contact an independent third-party investigator." The CST Lead "may initiate an internal inquiry or engage an external, third-party investigator." In both cases, the language is permissive ("may"), not mandatory ("shall").
For Category C cases involving school leadership, a board member, or any situation where internal investigators have personal relationships with the people involved — which describes virtually every situation in a small international school community — an independent investigation should not be optional.
What would strengthen this: Require external investigation for any Category C case involving a member of the administration or Board. Replace "may contact" with "shall engage" when the Director, a principal, or a Board member is the subject of a concern.
4. No Defined Trigger for External Reporting
The handbook references informing "appropriate authorities (i.e., parents, sending organizations, embassies, local authorities, etc.) in a timely manner," but defines no specific threshold at which reporting to law enforcement or an embassy becomes mandatory rather than discretionary. It lists external contacts in Appendix G (Kazakh child protection authorities, UNHCR, ICMEC) but does not specify when those contacts must be used.
This leaves every external reporting decision in the hands of the Director and CST, who may face institutional pressures to contain situations internally.
What would strengthen this: Define specific triggers for mandatory external reporting — for example, any allegation of physical sexual contact, any situation involving more than three independent reports of the same individual, or any case where the accused remains in contact with students after a finding of misconduct. Require written documentation of any decision not to report externally, including the reasoning, reviewed and signed by at least two members of the CST.
5. The Grooming Definition Remains Narrow
Both the 2018 and 2025 definitions anchor grooming exclusively to sexual abuse. The addition of "inappropriate behavior" as a separate category helps capture conduct that falls outside the grooming definition, but it also means that behavior which is functionally grooming — building emotional dependency, differential treatment, boundary erosion — but directed toward emotional control rather than sexual abuse is classified as a less serious category with less defined consequences.
CSPN, the network TSIS claims membership in, recognizes grooming as a process that can be directed toward multiple forms of abuse. The school's definition is narrower than the standard of the network it cites as its framework.
What would strengthen this: Broaden the grooming definition to include manipulation directed toward any form of abuse or exploitation, consistent with CSPN's framework. Alternatively, ensure that the "inappropriate behavior" category carries equivalent procedural weight and consequence pathways as formally defined grooming.
6. No Framework for Institutional Accountability
The misconduct assessment framework (Appendix D) addresses individual staff misconduct in detail. However, there is no equivalent framework for situations where the institution's own leadership fails to follow its safeguarding procedures — where findings are not communicated as written, where required notifications are not made, or where the process itself is not followed by those responsible for administering it.
A policy that holds individual staff accountable for misconduct but provides no mechanism for holding institutional leadership accountable for process failures creates an asymmetry that can undermine the entire framework.
What would strengthen this: Add an institutional review process — triggered when safeguarding procedures are not followed by leadership — led by external reviewers rather than internal staff. Require the Board to commission an independent review when a formal grievance is filed regarding the handling of a Category C case.
7. No Transparency About What Changed or Why
The 2025 handbook contains no changelog, no acknowledgment of the prior version's shortcomings, and no explanation for why the document was expanded from 5 pages to 33. The "Updated December 2025" date appears on the cover. That is the only indication that anything changed.
The school's own stated guiding principles include "truth and transparency" and "shared responsibility, accountability." A commitment to those principles would include explaining to the community what was learned, what was changed, and why.
What would strengthen this: Publish a changelog. Acknowledge the prior version's gaps. Explain what prompted the rewrite. A school that is transparent about improving its own child safety policies demonstrates that it has internalized the values it claims to hold.
Better policies are necessary. They are not sufficient. Policies protect children only when the people responsible for enforcing them are willing to do so — even when it is uncomfortable, even when it threatens the institution's reputation, and even when it means holding their own leadership accountable.
The question for the Tien Shan community is not whether the 2025 handbook is an improvement over the 2018 policy. It clearly is. The question is whether the conditions that led to the failures documented here have meaningfully changed — and what safeguards exist for the next person who raises a concern.