Safeguarding Against Exploitation, Sexual Abuse, Child Abuse
and Child Neglect Guidelines
PurposeThis document describes IIE's commitment to prevent Exploitation, Sexual Abuse, Child Abuse and ChildNeglect (“Guidelines”). This document expands on IIE’s Worldwide Code of Conduct (“Code”) andcomplements IIE’s Combatting Trafficking in Persons and Safeguarding Against Exploitation, SexualAbuse, Child Abuse, and Child Neglect Compliance Plan. This document not only describes IIE’ssafeguarding commitments, but also informs IIE Covered Individuals of their safeguarding
responsibilities.
Scope
This document applies to all IIE employees, interns, volunteers, trustees, and representatives, as well as
IIE contractors, suppliers, consultants, sub-contractors, sub-recipients and their employees, andrepresentatives engaged by IIE, working for IIE or on IIE’s behalf in any capacity, including for theperformance of programs sponsored by the U.S. federal government, foreign governments,
corporations, and foundations (“Covered Individuals”).
Definitions and Acronyms:
TermInternational Institute of Education, Inc.
Child, Children, Minor or Minors
Child Abuse
Child Neglect

Emotional Child Abuse or Ill Treatment

Exploitation

Definition“IIE” or “our” or “we” or “us”
Anyone under the age of 18 regardless of the age ofmajority or age of consent in the local context or country.
Emotional, physical, sexual, or any other ill-treatment
carried out against a child by an adult.
The failure to meet a child’s basic physical and/or
psychological needs either intentionally or throughcarelessness within activities supported by IIE that are
responsible for the care of a child in the absence of thechild’s parent, guardian, or caregiver.
Injury to a child’s emotional, intellectual, mental, or
psychological development caused by acts, threats of acts
or coercive tactics.
Any actual or attempted abuse of a position ofvulnerability, power differential, or trust for the benefitof the individual leveraging their position, power,privilege, or wealth (through enticement, manipulation,coercion, or trickery). When carried out for a sexual
purpose this constitutes sexual exploitation.

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Term
Physical Child Abuse

Prohibited Activities

Safeguarding

Sexual Abuse

Sexual Exploitation and Abuse (SEA)

Definition
Acts or failures to act resulting in unintended ordeliberate injury (not necessarily visible), or unnecessaryor unjustified pain or suffering which causes injury, harm,or risk of harm to a child’s health or welfare, or death.
Child Abuse, Child Neglect, Emotional Abuse or Ill
Treatment, Exploitation, Physical Child Abuse, Sexual
Abuse, and/or Sexual Exploitation and Abuse, as definedin this Policy.
Protecting people’s physical and mental health, wellbeing
and human rights, and enabling them to live free fromharm, abuse, and harassment.
Any actual or threatened physical intrusion of a sexual
nature toward another person whether by force or underunequal or coercive conditions. When carried out against
a child by an adult, such conduct is considered sexual
abuse even in the absence of force or unequal or coercive
conditions. All sexual activity with a child is sexual abuse.
A form of sexual harassment that explicitly involves apower dynamic between the perpetrator and the target;
when there is a potential threat/harm if an individual
does not consent, or if there is a potential benefit toconsenting.

Our Commitment and Shared Responsibilities
IIE has a zero-tolerance approach to any form of Prohibited Activities by any Covered Individual withaccess to or contact with program beneficiaries. IIE strictly prohibits all Covered Individuals fromengaging in any form of Prohibited Activities with program beneficiaries. All Covered Individuals mustfully comply with local and international child welfare legislation and U.S. child protection laws, orinternational standards, whichever affords greater protection.
IIE is also committed to transparency in our approach to prevent and respond to any safeguarding
violations within our organization or with third parties, consistent with our federal and international
disclosure obligations, and to the extent applicable comply with the standards, laws, statutes,
regulations and codes, including:-UN Inter-Agency Standing Committee’s Six Core Principles Relating to Sexual Exploitation andAbuse (IASC Six Core Principles);Keeping Children Safe Standards, available athttps://www.keepingchildrensafe.global/accountability/
US Trafficking Victims Protection Act 2000;
USAID ADS 303 Mandatory Standard Provision, Trafficking in Persons;Page 2 of 8

-USAID ADS 303 Mandatory Standard Provision, Safeguarding Against Exploitation, Sexual Abuse,
Child Abuse, and Child Neglect; andInternational Labor Standards on Child Labor and Forced Labor.

Implementation – Awareness, Prevention, Reporting, and Responding
IIE is committed to preventing Prohibited Activities, by creating an environment where any issue orconcern regarding the protection and safety of beneficiaries is reported and addressed appropriately
and timely. IIE is committed to safeguarding program beneficiaries through the following means:
Awareness: Provide information so that all Covered Individuals are aware of the guidelines in thisdocument, their responsibilities towards the safeguarding of program beneficiaries, and the ways theycan report their concerns.
For IIE employees (including temporary employees, interns), volunteers and members of the Board ofTrustees and Officers, the IIE Worldwide Code of Conduct contains principles, guidelines, andrequirements that reflect the highest ethical standards. The Code informs IIE employees of the U.S.
Government’s and IIE’s commitment to safeguarding against Prohibited Activities outlined in theseGuidelines. Upon beginning work with IIE, all new IIE employees are required to read and sign the IIE’s
Worldwide Code of Conduct. IIE employees are also required to read and certify their compliance withthe Code of Conduct annually.
Prevention: Minimize the risks of any form of Prohibited Activities by Covered Individuals, throughawareness and prevention activities, including, but not limited to conducting relevant vetting andbackground checks.
For IIE employees, IIE provides periodic mandatory training in Ethics and Compliance. In addition, IIE
holds periodic training activities with IIE employees in IIE’s regional and international offices in order toreview the requirements of specific awards, including safeguarding against Prohibited Activities.
Reporting: Provide information so that all Covered Individuals are aware of how to report suspicions orconcerns regarding potential allegations of Prohibited Activities.
Covered Individuals are required to immediately report any instances of suspected Prohibited Activities
involving program beneficiaries served by IIE programs or with whom Covered Individuals come incontact during the implementation of those programs.
IIE’s Worldwide Code of Conduct requires IIE employees to promptly report all violations of the Code,including any known or suspected cases of Prohibited Activities. It contains procedures for raisingcompliance questions, concerns, and violations without fear of retaliation including through ananonymous hotline. For more information, please see Code of Conduct Section 8. Raising Questions andReporting Violations.

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IIE requires all IIE employees to report known or suspected cases involving Prohibited Activities to their
immediate managers, Grants and Contracts, Human Resources, or the Legal Department, or through thehotline if an IIE employee prefers to report anonymously. IIE requires all Covered Individuals who are
not IIE employees to report known or suspected cases of Prohibited Activities to the point of contact aslisted in the terms and condition of their award/contract.
IIE maintains a Hotline for individuals, including program beneficiaries who prefer not to discuss theirconcerns in a face-to-face setting. Individuals can contact the Hotline through a toll-free telephone
number (for domestic offices) or via a website. The Hotline is available 24 hours per day, seven days perweek:U.S. Hotline Number:

1-800-461-9330

Web Hotline (including for Individuals based Overseas): www.convercent.com/report
Upon receipt of credible information of any known or suspected cases involving Prohibited Activities, IIE
will report the matter to the respective sponsor, appropriate agency or entity as applicable, in a timely
manner and cooperate in any investigation. A violation of these Guidelines or of the Code of Conduct
may result in disciplinary action, including termination of employment, contract or Board membership,and, where appropriate, reporting to relevant government officials.
Responding: IIE commits to take appropriate and prompt action to address all reports of Prohibited
Activities, to help safeguard the safety and well-being of the program beneficiaries involved.
Non-Retaliation
Covered Individuals are reminded that IIE prohibits any form of retaliation against any individual formaking a good faith complaint or providing information about suspected conduct that violates
applicable law, IIE’s Worldwide Code of Conduct, or any IIE policy. If a Covered Individual believes thatthey have been retaliated against in violation of IIE’s Worldwide Code of Conduct, that person shouldreport the violation immediately to their Supervisor, Grants and Contracts, Human Resources or theLegal Department, or through the hotline.
Violations of the principles found in these Guidelines, IIE’s Worldwide Code of Conduct or IIE’s U.S.
Employment Handbook or the applicable country specific HR Guides (“HR Guides”) may lead to serious
consequences up to and including termination of employment, contract or Board membership, and,
where appropriate, reporting to relevant government officials.
Investigation and Remedies
IIE will promptly investigate all reports or complaints of Prohibited Activities in accordance with theprocesses set out in IIE’s U.S. Employment Handbook or the applicable HR Guides.

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In investigating and responding to the alleged violations, IIE will take a “survivor-centered approach”.
Such an approach ensures the survivor’s dignity, experiences, considerations, needs, and resiliencies areplaced at the center of the process1.
IIE will investigate all reports of suspected Prohibited Activities in a confidential and timely manner andtake appropriate action, including but not limited to notifying, as applicable, local law enforcement,social services or child protection authorities, so long as such notification does not put the child orvulnerable adult at risk of further harm. Responding to alleged violations involving children requires
taking into consideration a “best interest of the child determination”. This determination considers thebest possible outcome for a vulnerable child who has been exposed to violence, abuse, exploitation, orneglect.
Any complaint of abuse made by a program beneficiary, including children, will be promptly investigatedby IIE regardless of whether or not the allegations have been verified.
Pursuant to an investigation by IIE, any employee (including temporary employee or intern), volunteer
or trustee found to have engaged in any form of Prohibited Activities will be dismissed immediatelyfrom further engagement with IIE. Any person providing services pursuant to a contract with IIE found tohave engaged in any form of Prohibited Activities will have their contract with IIE terminatedimmediately. Based on the nature of alleged violations and its findings, IIE may be required to reportcredible allegations to law enforcement agencies.

Implementation - Child Safeguarding
IIE is committed to safeguarding children, which is the process of preventing and protecting children
from intentional or unintentional acts that lead to the risk of or actual harm by IIE Covered Individuals,
who are provided access or contact with children through IIE’s program implementation and operations.
This includes IIE’s direct program implementation, work through third parties and management ofchildren’s personal data. The following are examples of prohibited behavior and practice, which are nottolerated by IIE, and best practices in safeguarding children:
1. IIE strictly prohibits any sexual activity with an individual under the age of 18, regardless of thelegal age of consent / majority within the state or country in which the child lives, and/or thelocation where the offense occurs. In locations where a child cannot legally give informed
consent to sexual activity, such activity with or without their consent will be treated as a serious
infraction and will result in disciplinary action being taken, including termination, and thepursuit of any other available legal remedy. Occurrences of “consensual” sexual activity with achild over the legal age of consent within the state or country in which the child lives and/or
where the offense occurs, but below 18 years old, will be treated as an act of sexual exploitation
1

IASC Definition & Principles of a Victim / Survivor Centered Approachhttps://interagencystandingcommittee.org/iasc-champion-protection-sexual-exploitation-and-abuse-and-sexualharassment/iasc-definition-principles-victimsurvivor-centered-approach-0

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2.
3.

4.
5.

6.
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8.

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& abuse. This is a serious infraction and will result in disciplinary action being taken, including
termination, and the pursuit of any other available legal remedy.
Two-adult rule: During activities or service where children are involved, two or more adults
should be involved to supervise the activity, whenever feasible.
No child shall be alone with a Covered Individual (in-person or virtual), unless absolutely
necessary and with parental/legal guardian and supervisor consent. Where one-to-one
interactions are absolutely necessary, interactions should be held in a public area, in a room
where the interaction may be observed or in a room with the door open.
No Covered Individual may stay alone overnight with a child program beneficiary at anylocation.
Communication outside the role of a professional or volunteer relationship is strictly prohibited.
Covered Individuals who use any form of electronic communications to communicate withChildren may only do so for activities involving IIE business and to the extent possible andapplicable, should use an IIE address or site.
No Covered Individual may discriminate against, exclude, or favor a particular child.
All program design processes for which IIE engagement with a minor is possible will include
assessment and integration of applicable child safeguarding risk mitigation measures.
Any IIE agreement (sub-award, consultant agreement, contractor agreement) with anotherentity will include language on minimum child safeguarding standards to ensure compliancewith the requirements in this document.
Engagement with children and their parent/guardian for the purposes of advertising, program
promotion, publicity, marketing, education, information and trade materials must be done withassent and informed consent and must not exploit the child or guardian, nor increase theirvulnerability or place them at risk. Child participation in IIE programs will not be limited orrestricted irrespective of the child’s assent or their parent/guardian’s consent to the use of thematerial for advertising, marketing, or program promotion.

Implementation – Safeguarding Program Beneficiaries
IIE is committed to safeguarding program beneficiaries. This includes IIE’s direct program
implementation, work through third parties and management of personal data. The following areexamples of prohibited behavior and practices, which are not tolerated by IIE, and best practices insafeguarding:
1. IIE strictly prohibits any sexual or romantic relations between Covered Individuals and program
beneficiaries (of any age).
2. IIE strictly prohibits any abuse of program beneficiaries, including, but not limited to, physical,sexual, psychological, financial, discrimination, and neglect.
3. IIE strictly prohibits any form of coercion of program beneficiaries.
4. IIE strictly prohibits any sexual exploitation and abuse (SEA) of program beneficiaries. SEA canhappen in any setting, in-person or virtual. As listed in U.S. Employment Handbook, some of theexamples of SEA include (but are not limited to):Page 6 of 8•Making inappropriate or derogatory remarks, jokes, or comments, especially thoseabout someone’s appearance, body, style, etc. whether in person or via email, text message, oron social media.
•Making vulgar or inappropriate gestures.

•media.

Sending unwanted sexual advances in person or via email, text message, or on social•
Displaying or sending sexually suggesting, pornographic material, cartoons, or graphics
on computers, emails, cellphones, etc.
•Unwelcome and/or inappropriate touching, including sexual assault.

•

Physical contact in a sexual manner by force or coercion.

•Quid pro quo situations, where preferential treatment in employment, promotions,payment, acceptance in IIE’s programs etc. are offered in exchange for accepting sexual advances.
•Threats that a person accepts sexual advances as a condition to continue participation in
IIE’s run programs or to avoid loss of benefits.

Agreements with Third Parties, Agents, Subawardees and Subcontractors-Flow-down of Prohibited Activity Requirements

IIE requires subawardee and subcontractor awareness of and compliance with Prohibited Activity
requirements by including the applicable provisions in their agreements, whenever required by US laws
and regulations or other sponsor requirements.
-Subawardee and Subcontractor Monitoring and Management

IIE has a robust subawardee and subcontractor monitoring and management program. IIE employees
who engage third parties as suppliers, consultants, independent contractors, or vendors must use
reasonable care to engage third parties who will act in a manner consistent with IIE’s principles.
Responsibility determinations or pre-award questionnaires (risk assessments) are conducted for all
subawardees and programmatic contractors under USG contracts, cooperative agreements, and grants.
Based on the results of the risk assessment, IIE may require special award conditions, monitoring, andaudit plans for the subawardee or programmatic contractors under USG contracts. The appropriate
regulations related to the USG agency and award type must be flowed-down to all subawardees andsubcontractors.

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APPENDIX

A. Internal and External References
IIE’s Worldwide Code of Conduct
IIE Privacy Statement
NYC Stop Sexual Harassment Act Notice
IIE’s U.S. Employment Handbook
IIE’s Combating Trafficking in Persons Plan
USAID’s Mandatory Provision M.27 SAFEGUARDING AGAINST EXPLOITATION, SEXUAL ABUSE, CHILD
ABUSE, AND CHILD NEGLECT
UN’s Inter-Agency Standing Committee (IASC) Six Core Principles
UN’s Inter-Agency Standing Committee (IASC) Definition & Principles of a Victim/Survivor CenteredApproach

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