Commitment 1.5:
We advance the safeguarding of those who are vulnerable to sexual exploitation, abuse and harassment. 

Compliance Indicators

Compliance with the Commitments will be assessed against the following Compliance Indicators. All of the applicable Compliance Indicators must be met by every ACFID Member to be considered compliant with the Code. Each of the Compliance Indicators has one or more compliance Verifiers. Verifiers are the description of evidence that is required to substantiate compliance with each Compliance Indicator. Guidance is also provided.

1.5.1 Members demonstrate their organisational commitment to the prevention of sexual exploitation, abuse and harassment.

Policy document that:  

  • describes the standards of behaviour for governing body members, staff, contractors, volunteers, visitors to projects and partners.  
  • specifically prohibits sexual exploitation, abuse and harassment. 
  • outlines how the policy is implemented throughout the organisation. 
  • specifies the agency’s reporting responsibilities where an incident is identified, including processes for reporting to local enforcement authorities, subject to the wishes and welfare of the complainant/survivor. 

Appointment of a prevention of sexual exploitation, abuse and harassment focal person. 

Good Practice Indicators

The following Good Practice Indicators describe a higher standard of practice than that set out in the Compliance Indicators. While Members do not need to meet the Good Practice Indicators to be considered compliant with the Code, they will self-assess against these indicators once every three years. This provides a clear pathway for Members to strengthen and improve practice over time.

  • Members limit the use of non-disclosure agreements in grievance processes. 
  • Members display statements about their commitments to PSEAH and their complaints process in public places such as at head office and country offices and at project sites (in local language). 
  • Members work with partners and communities to challenge attitudes which permit or excuse sexual exploitation, abuse and harassment, or other sex-based misconduct. 
  • Members participate in the Misconduct Disclosure Scheme. 

Good Practice Guidance

Here are some practical suggestions for your organisation to further deepen and improve practice over time.

Policy

  • Refer to ACFID’s Guidance Note on developing a PSEAH Policy in the Resources Section
  • If your organisation receives DFAT funding, ensure your policy and practices comply with DFAT’s minimum standards.
  • Consult with your staff, partners and primary stakeholders to inform the development of your policy and complaints mechanisms and about how you can promote PSEAH within your organisation and within their contexts.
  • Design and print easily readable versions of your PSEAH policy and your complaints process and display these in your work place including in public areas such as at reception, in the kitchen or bathrooms where people will frequently see them.
  • Translate your policy into the languages of the countries and communities where you work and ensure your in-country offices and partners do the same and display them in their workplace as described above. Consider placing signage/posters with appropriate language and terminology in public areas, such as community halls, notice boards or at project sites.
  • Create occasions/space where governing body members and staff can meet and openly discuss the organisation’s position on PSEAH to assist staff in understanding the commitment of the leadership and building a culture where it becomes normal to discuss risks associated with PSEAH and how the organisation will prevent these.

Organisational

  • Undertake a power analysis and gender analysis of your programs and organisation to identify gaps, barriers and strengths for PSEA.
  • Create your own PSEAH or safeguarding policy and Code of Conduct and support local staff and partners to do the same.
  • Ensure that your approach to PSEAH places the protection, voice and wishes of the survivor/victim at the centre of your management, reporting and responses.
  • Educate staff and other stakeholders about how to reduce risk and ensure organisational activities protect both adults and children.  This should include discussions about power imbalances, gender norms, local status and workplace cultures and how they impact on work and personal relationships.
  • Work with staff to support and understand healthy sexual relationships that are not exploitative. Understanding and analysing the power dynamics and the nature of vulnerability and exploitation is a challenging concept with different cultural interpretations. All staff will need support to understand and assess this well.
  • Clearly define the role of your PSEAH focal person to be responsible for promoting PSEAH throughout your organisation, coordinating staff training, monitoring your compliance to relevant internal and external policies, coordinating policy reviews and to serve as the central contact point for both internal and external queries.
  • Establish a PSEAH group or community of practice within your organisation and task them with researching and keeping up to date with current and emerging research, new recommended practices and resources.
  • Ensure that your PSEAH focal person and community of practice is well supported within your organisation and resourced with time and funds if required. This could involve ensuring they have enough time separate to their normal roles, funding key staff to attend external PSEAH meetings or conferences, getting together with PSEAH focal people from other organisations and sharing good practices.
  • Undertake research to identify a range of external bodies and support systems available and ensure staff, partners and primary stakeholders are aware of these.
  • Undertake research to identify all applicable laws and mandatory reporting requirements/entities in all locations where you work and ensure these are referenced in your PSEAH policy and procedures.

Recruitment

  • Have a strong policy and clear, well-known complaints process in your organisation – this will assist in building a culture that does not tolerate SEAH and will assist in deterring people who may target organisations that have weak or inconsistently applied procedures.
  • Promote a commitment to PSEAH on your website, in promotional materials and in all job advertisements.
  • Assess all positions for the level for risk in relation to vulnerable people. Applicants to positions working directly with vulnerable people should be subject to the highest level of screening.
  • Confirm the identity and work history of applicants.
  • Require a minimum of two verbal reference checks for all preferred candidates and include targeted questions about the applicant’s attitudes and behaviour towards women, children and other vulnerable groups as relevant to the context.
  • Ask targeted questions of applicants during interviews that explore their attitudes towards PSEAH.
  • Check appropriate professional registers.
  • Require all appointees to read and sign your PSEAH policy, code of conduct and complaints policy.
  • Check criminal and police records for all your preferred candidates. If staff, volunteers or consultants are Australian residents, use the police check from the Australian Federal Police.
  • Include PSEAH in all job descriptions and performance appraisal processes. See Good Practice Guidance for Compliance Indicator 9.3.1.

Reporting

  • Develop clear criteria to inform your triage system so that no single staff member is responsible for making subjective judgements about the seriousness of an incident. The triage system should signal to the staff person responsible whether an incident should be classified as serious and the relevant reporting responsibilities.
  • Establish clear reporting and investigation procedures for sexual exploitation, abuse and harassment, to report suspected or known instances of abuse to relevant authorities. These should include clear guidance on internal and external reporting requirements for your organisation in Australia and in field offices.
  • Ensure your approach to addressing incidents of sexual misconduct include reparations for victims/survivors such as access to medical, psychosocial and legal services and other forms of support.
  • Report suspected or known instances of sexual exploitation and abuse to relevant local and Australian authorities unless this is at odds with the wishes or welfare of the complainant/survivor.
  • Report safeguarding incidents and their response to senior management and governing bodies.

Partners

  • Work with your partners to understand the implications for PSEAH in local contexts and a shared understanding of the gender and power inequities and their impact on PSEAH.
  • Develop a shared understanding with your partners of appropriate behaviours and incident reporting processes.
  • Work with partners and field managers to support and understand healthy sexual relationships that are not exploitative. Understanding and analysing the power dynamics and the nature of vulnerability and exploitation is a challenging concept with different cultural interpretations. All staff will need support to understand and assess this well.
  • Develop communications to ensure that partners and communities where you work are aware of what behaviours are inappropriate and how to report, investigate, document and manage sexual misconduct incidents.
  • Where possible, participate in existing in-country NGO forums, working groups and Cluster Systems to develop and share training and knowledge on local PSEAH activities, including reporting systems and referral pathways.

Programs

  • Ensure individual, organisational and external risk factors for sexual exploitation, abuse and harassment of adults are incorporated into risk assessment processes for all programs and initiatives.
  • Integrate PSEAH into your project cycle management guidelines and tools such as proposal and project design templates, appraisal templates, and progress and monitoring report templates to ensure PSEAH issues are considered at each stage of the project cycle.
  • Consider how to strengthen protective factors and minimise risk factors for SEAH when designing and implementing activities.
  • Establish review mechanisms that minimise the possibility of program activities exposing vulnerable people to greater risk.
  • If undertaking humanitarian responses, provide additional information and training for staff and partners on the additional risks of vulnerability and exploitation. This should include scenarios to enable them to recognise and assess vulnerability and whether a situation could be exploitative, and establish mechanisms to monitor compliance.
  • Provide opportunities for primary stakeholders, especially vulnerable women and other groups to share their views, experiences and ideas to inform and set the direction for your initiatives and projects.
  • Provide opportunities for primary stakeholders especially vulnerable women and other groups to provide both positive and negative feedback on the outcomes of projects on their lives.
  • Ensure that translators and interpreters are trained on the organisation’s Code of Conduct and the PSEAH Policy and agreed shared language on terms related to PSEAH. Actively recruit women translators wherever possible.
  • Provide training for field staff and volunteers to identify risks, potential or actual abuse of power or breaches of safeguarding policies and to report it safely.
  • Establish appropriate and safe systems and mechanisms for field staff to report concerns confidentially.
  • Build networks with other organisations working in your sector or program area and ensure that SEAH is regularly discussed and concerns are shared between organisations.

Communications

  • Ensure that all communications materials do not provide any identifying information about survivors of SEAH.
  • Develop communications materials about PSEA and complaints processes for communities in appropriate language and media.
  • Ensure communications materials are designed in collaboration with community members who are most vulnerable to exploitation and abuse to ensure their relevance.
  • Ensure materials show clear messaging about standards and expectations of behavior, and ways in which concerns can be reported.
  • Field-test materials with community groups – including groups of women and girls – and adapt according to their feedback.
  • Distribute materials through all program activities and use as discussion starters with sex-disaggregated groups in program activities.

ACFID Resources

EWB Australia’s Preventing Sexual Exploitation, Abuse, and Harassment policy (PSEAH)

Engineers without Borders Australia (EWBA)'s PSEAH policy is an example of preventing and managing SEAH incidents and reports across the organisation. This is relevant to new members, emerging and small organisations looking to develop their own PSEAH policy as it covers all requirements.

Guidance for the Development of a Prevention of Sexual Exploitation, Abuse and Harassment policy

This guidance will assist ACFID’s members to develop a prevention of sexual exploitation, abuse and harassment (PSEAH) policy to satisfy the ACFID Code of Conduct’s Commitment 1.5 and its associated Compliance Indicators.

Preventing Sexual Misconduct and Safeguarding Human Rights | ACFID Conference 2018

This resource details ACFID's commissioned review into the international aid sector’s approach to safeguarding. These are the highlights from the session at the ACFID Conference 2018, which explores challenges and showcases examples of good practice and leadership from our sector and beyond

Prevention of Sexual Exploitation, Abuse and Harassment (PSEAH) | ACFID Code of Conduct Topic Guide

This ACFID resource outlines all the requirements in the ACFID Code of Conduct related to the prevention of sexual exploitation, abuse and harassment. It is suitable for all organisations to strengthen their compliance with the Code.

Prevention of Sexual Exploitation, Abuse, and Harassment (PSEAH) Policy (AVI)

This example of AVI's PSEAH policy demonstrates the organisation's respect for the dignity and basic human rights of people within Australia and throughout the world. This example is suitable for all organisations. This is relevant to the Code because it outlines how the policy is implemented throughout the organisation.

Safeguarding Policy (WWF-Australia)

This policy articulates WWF-Australia’s commitment to provide a safe and trusted environment that safeguards staff,volunteers, contractors, partners, communities, children and vulnerable adults. This example is suitable for all organisations as it describes the standards of behaviour for organisation’s staff, representatives and partners; outlines how the policy is implemented throughout the organisation; specifies the agency’s reporting responsibilities and procedures; and ensures a ...

Safeguarding with Partners’ learning event summary

This resource is documents an ACFID learning even on policy implementation, including with partners in-country. This is suitable for all organisations. This is relevant to the Code because all ACFID members require a policy that prohibits sexual exploitation and abuse, describes behavioural standards, and specifies reporting responsibilities.

Other Resources

DFAT Violence against women guidance note

This DFAT Guidance Note addresses the protection and wellbeing needs of the children and young people (including young women). This is suitable for signatory organisations providing violence prevention programming for young women. This is relevant to the Code in demonstrating organisational commitment to the prevention of sexual exploitation, abuse and harassment.  

Language in PSEA – a webinar

This webinar by Translators Without Borders alongside the IOM explores and highlights the importance of language in PSEA.  It draws on examples in Cox's Bazar, Niger, Myanmar and Mozambique. It highlights critical applications of awareness-raising, local reporting mechanisms, translators, communications so that we can reach the most marginalised speakers.

Managing complaints package

This resource is about creating accountable spaces. This is suitable for new applicants, emerging to medium organisations who want to develop or update an effective complaint management mechanism. This resource is available as a guide, an e-learning module, or an interactive toolkit.

Managing Sexual Violence against Aid Workers: prevention, preparedness, response and aftercare

This Guidance aims to support aid agencies in preventing, being prepared for and responding to incidents of sexual violence against their staff. It is intended as a good practice guide to help strengthen existing processes and support organisations as they set up their own protocols.

Prevention of Sexual Exploitation and Abuse (PSEA) Policy

Fundamental to the operation of AVI is respect for the dignity and basic human rights of people within Australia and throughout the world. Every person who represents AVI is expected to reflect these values in their professional conduct, regardless of who they are dealing with, or where they are working.

Rules on sexual conduct for humanitarian workers

Translators without Borders has worked with the Inter-Agency Standing Committee (IASC) to help prevent sexual exploitation and abuse in humanitarian contexts. This library is a link to plain language versions of the principles in over 50 languages. This suitable for all organisations developing localised information for primary stakeholders. This resource also supports Commitments for racial justice and locally-led development.

Sexual Exploitation, Abuse and Harassment (SEAH) Investigation Guide

This guide provides best practice guidance, tools, and steps for conducting survivor-centered SEAH investigations in the humanitarian and development sector. This is suitable for all organisations tin improving effective safeguarding and complaints mechanisms. This resource is also available in Ukrainian, Polish, Urdu, Arablic, French, Spanish, and Bengali (scroll down the web page).

Taking a victim/survivor-centred approach to protection from sexual abuse, exploitation and harassment in the aid sector

This resource maps the journey of a victim/survivor from violation to redress, exploring the challenges, existing best practice, and what a victim/survivor-centred approach could look like at each stage. This is suitable for all organisations who aspire to deliver victim/survivor-centred approaches in addressing complaints.
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