We advance the safeguarding of those who are vulnerable to sexual exploitation and abuse.
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 and abuse, through a survivor-centred approach.
Members are required to extend this compliance indicator and verifiers to partners through MOU or similar.
All members must have a policy document that:
- Describes the standards of behaviour for organisation’s staff, representatives and partners
- Specifically prohibits sexual exploitation and abuse
- 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.
Members are also required to appoint a prevention of sexual exploitation and abuse focal person.
Acts of sexual exploitation and abuse are intrinsically linked to power and gender inequity and disproportionately impact on women and girls and people with disabilities. An understanding of gender and power inequity in the contexts and relationships within which your organisation and staff work is important to effectively address this issue.
A prevention of sexual exploitation and abuse policy provides one way for your organisation to advance the safeguarding of those who are vulnerable to sexual exploitation and abuse. These people may be adversely affected by the conduct of staff or volunteers associated with your organisation or through the design and implementation of your programs and activities. They may be people in the communities in which your organisation works, or staff and volunteers in your organisation or partner organisations. A policy provides an important statement of the organisation’s and its leadership’s commitment to PSEA, and can be used to communicate this commitment to internal and external stakeholders. A policy on its own will not foster a strong and positive culture which enables safeguarding but it is an important component in achieving this.
This policy should outline your organisation’s commitment to the prevention of sexual exploitation and abuse and outline the responsibilities of staff, volunteers, partners and others in relation to prevention, reporting and responding to incidents of sexual exploitation and abuse.
Your organisation may choose to have a standalone policy or to include the prevention of sexual exploitation and abuse in a wider safeguarding policy.
Your organisation must appoint a focal person for the prevention of sexual exploitation and abuse. A sexual exploitation and abuse focal person provides a key role in raising awareness throughout your organisation and in coordinating, supporting and advising on the development and implementation of prevention of sexual exploitation and abuse policy and practices.
Members receiving funding from DFAT should also ensure their organisation’s policy and practices comply with DFAT’s Sexual Exploitation, Abuse and Harassment Policy. Examples and guidance for developing a policy on prevention of sexual exploitation and abuse is located in the Resources Section below.
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 PSEA and their complaints process in public places such as at head office and country offices and at project sites (in local language).
Good Practice Guidance
Here are some practical suggestions for your organisation to further deepen and improve practice over time.
- Refer to ACFID’s Guidance Note on developing a PSEA 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 PSEA within your organisation and within their contexts.
- Design and print easily readable versions of your PSEA 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 PSEA to assist staff in understanding the commitment of the leadership and building a culture where it becomes normal to discuss risks associated with PSEA and how the organisation will prevent these.
- Undertake a power analysis and gender analysis of your programs and organisation to identify gaps, barriers and strengths for PSEA.
- Create your own PSEA or safeguarding policy and Code of Conduct and support local staff and partners to do the same.
- Ensure that your approach to PSEA 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 PSEA focal person to be responsible for promoting PSEA 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 PSEA 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 PSEA 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 PSEA meetings or conferences, getting together with PSEA 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 PSEA policy and procedures.
- 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.
- 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.
- Work with your partners to understand the implications for PSEA in local contexts and a shared understanding of the gender and power inequities and their impact on PSEA.
- 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.
- 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 PSEA 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 PSEA issues are considered at each stage of the project cycle.
- Consider how to strengthen protective factors and minimise risk factors for SEA 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 PSEA Policy and agreed shared language on terms related to PSEA. 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 SEA is regularly discussed and concerns are shared between organisations.
- Ensure that all communications materials do not provide any identifying information about survivors of SEA.
- 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.