Introduction

Contents
Glossary

PSEAH
handbook
at a glance

Developing andimplementing
PSEAH policy
and procedures

Ensuring staff
and volunteers
work to PSEAH
requirements

Engaging
communities andpeople affectedby crisis

Implementing
requirements withpartners, suppliersand contractors
Designing safe
programmes
and projects

Sexualmisconduct inthe workplace

REVISED 2020

Assigning
specific
responsibilities
for PSEAH

PSEAH IMPLEMENTATIONQUICK REFERENCE
HANDBOOK

Developing andimplementing
a complaints
mechanism

Responding
to reportsof SEAH

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOKCorinne Davey and Lucy Heaven Taylor, GCPS Consulting UK, 2017

Affected populations – the individuals,
groups, and communities that are affectedby a humanitarian crisis. This can also be used
to refer to populations affected by issuesof development.

Revised in 2020 by Lucy Heaven Taylor

Developing andimplementing
a complaints
mechanism

Bond Safeguarding templates undated
CBM Safeguarding Policy 2018
3
UNICEF Child Protection Information Sheet What is Child Protection?
4
IASC Best Practice Guide to Inter-Agency Community-Based Complaints Mechanisms 2016
1
2

1

Responding
to reportsof SEAH

Alina Potts, Harriet Kolli, Elizabeth Hedge and Chelsea Ullman. Empowered Aid: Participatory Action Research with Refugee
Women & Girls to Better Prevent Sexual Exploitation and Abuse--Uganda Results Report. Washington, DC: The George
Washington University and Uganda: IRC

Complaint mechanism or procedure –processes that allow individuals to reportconcerns such as breaches of organisational
policies or codes of conduct.

Sexualmisconduct inthe workplace

Case studies on pages 37-39 adapted with permission from:
Alina Potts, Loujine Fattal, Elizabeth Hedge,Farah Hallak, and Amelia Reese. (2020). Empowered Aid:Participatory Action
Research with Refugee Women & Girls to Better Prevent Sexual Exploitation and Abuse—Lebanon Result sReport.
Washington, DC: The George Washington University and Lebanon: CARE International.

Being at risk is not a ‘fixed’ characteristic but
rather changes due to a range of factors, andcan change over time. For example, a person
living with a disability may not be at risk intheir own usual environment but may become
so if they are displaced and away from theirusual coping mechanisms.

Complainant – the person making thecomplaint, including the alleged victim/
survivor of the sexual exploitation, abuse or
harassment, or another person who becomesaware of the wrongdoing.

Designing safe
programmes
and projects

Supported by

3. An adult may also be at risk if theirdecision-making capacity is impaired
and/or they do not have the support tomake a decision2.

Complaint – specific grievance of anyone
who has been negatively affected by anorganisation’s action or who believes thatan organisation has failed to meet a statedcommitment.

Implementing
requirements withpartners, suppliersand contractors

We would like to express our appreciation to the UK Foreign, Commonwealthand Development Office, whose funding has made this project possible.

2. An adult may also be at risk/ vulnerable
when in a relationship (social or work) withanother who seeks to misuse their positionof authority or trust to control, coerce,
manipulate or dominate them.

Community-based Complaints Mechanism– a system blending both formal and informal
community structures, built on engagementwith the community where individuals
are able and encouraged to safely reportgrievances – including SEA incidents – andthose reports are referred to the appropriate
entities for follow up4.

Engaging
communities andpeople affectedby crisis

Sanat K. Bhowmik, Director, COAST
Lilian Bogonko, Action Aid
Hannah Clare, Global Safeguarding Co-ordinator, Oxfam GB
Mariama Deschamps, Plan International
Kennedy Dhanabalan, EFICOR
Susan Grant, Save the Children International
Prem Livingstone, EFICOR
Anastasia Maylinda, YAKKUM Emergency Unit (YEU)
Alina Potts, Global Women’s Institute (GWI) at the George Washington University
Gabriella Prandini, Humanitarian Response Advisor, GOAL Ethiopia
Margaret Rooney, Trócaire
Lemma Tesafaye, Head of MEAL, Women Support Association
Tracy Vaughan Gough, Sightsavers
Antony Wesonga, Refugee Consortium of Kenya

At-risk adults –1. Any person aged 18 years and older who
may be at risk of abuse or exploitation due
to their dependence or reliance on othersfor services, basic needs or protection,
and according to context, for example, inhumanitarian situations.

Code of conduct – a set of standards about
behaviour that staff and volunteers of anorganisation are obliged to adhere to.

Ensuring staff
and volunteers
work to PSEAH
requirements

CHS Alliance would like to thank the following people and organisations for generously sharing
their knowledge and expertise:Child protection – preventing and responding
to violence, exploitation and abuse againstchildren – including [but not limited to]commercial sexual exploitation, trafficking,child labour and harmful traditional practices3.

Assigning
specific
responsibilities
for PSEAHACKNOWLEDGEMENTS

Associated personnel – Associated personnel
whilst engaged with work or visits related
to [NGO], including but not limited to
the following: consultants; volunteers;
contractors; programme visitors including
journalists, celebrities and politicians1.

Child – any individual under the age of 18,
irrespective of local country definitions ofwhen a child reaches adulthood.

Developing andimplementing
PSEAH policy
and procedures

GLOSSARY

PSEAH
handbook
at a glance

AUTHORSIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

Developing andimplementing
a complaints
mechanism

Protection from Sexual exploitation and Abuse Statement by the Inter-Agency Standing Committee(IASC) Principals 2015

3

Responding
to reportsof SEAH

2

9

Sexualmisconduct inthe workplace

6

Designing safe
programmes
and projects

Bond www.bond.org.uk
United Nations Secretariat, 9 October 2003, Secretary General’s Bulletin on Special Measures for Protection from Sexual
Abuse and Sexual Exploitation, 2003/13 (ST/SGB/2003/13), United Nations.
7
ibid
8
Endorsed in the UN General Assembly Resolution A/RES/73/148 on 17th December 2018
5

Whistleblower Protection policy (orDisclosure of Malpractice in the Workplacepolicy) – a policy which encourages staff
members to report concerns, the disclosureof which are typically in the public interest,
particularly in countries where whistleblowing
is part of national legislation. Concerns are
typically those regarding a criminal offence,
health and safety, damage to the environment
or miscarriage of justice. Reporting on PSEAH
can fall within an organisation’s Whistleblower
Protection policy. Whistleblowers are often
protected by law and cannot be treatedunfairly or lose their job because they reportthese concerns.

Implementing
requirements withpartners, suppliersand contractors

Report – where an individual or individuals
report a concern regarding SEAH.

Sexual harassment – a continuum of
unacceptable and unwelcome behaviours andpractices of a sexual nature that may include,
but are not limited to, sexual suggestions or
demands, requests for sexual favours andsexual, verbal or physical conduct or gestures,that are or might reasonably be perceived as
offensive or humiliating8. Sexual harassment
has widely been understood to relate to theworkplace (see ‘Workplace sexual misconduct’
below), but is also included in the spectrumof behaviours that are not acceptable conduct
by our staff, be it in the workplace or withaffected populations.

Victim/Survivor-centred approach – anapproach in which the victim/survivor’s
wishes, safety, and well-being remain apriority in all matters and procedures9.

Engaging
communities andpeople affectedby crisis

Referral pathway – the various support andreferral services available to victims/survivorsof SEAH.

Sexual exploitation – any actual or attemptedabuse of a position of vulnerability, differential
power or trust for sexual purposes, including,but not limited to, profiting monetarily,socially or politically from the sexual
exploitation of another7.

Survivor or victim – the person who is, or
has been, sexually exploited or abused. The
term ‘survivor’ implies strength, resilienceand the capacity to survive. The term ‘victim’
has protective implications, as it implies thevictim of an injustice which we should seek
to redress. Therefore, this resource uses bothterms. People who have experienced SEAH
may choose different terms to describe
their experience.

Ensuring staff
and volunteers
work to PSEAH
requirements

PSEAH (Protection from Sexual Exploitation
and Abuse and Sexual Harassment) –the term used by those working in theinternational humanitarian and development
sector to refer to measures taken to protect
people from sexual exploitation, abuse andharassment by their own staff and associatedpersonnel.

Sexual abuse – an actual or threatened
physical intrusion of a sexual nature, whether
by force or under unequal or coercive
conditions6.

Speak Up policy – an organisational policy
which encourages staff members to reportconcerns or suspicions of misconduct
by colleagues. Those making reports areprotected from any negative consequencesof reporting these concerns.

Assigning
specific
responsibilities
for PSEAH

Investigation of sexual exploitation, abuseor harassment – an internal administrative
procedure, in which an organisation attempts
to establish whether there has been a breachof SEAH policy(ies) by a staff member ormembers.

SEAH – the term used to refer to sexual
exploitation, abuse and sexual harassment.

Sexual misconduct – includes sexual
harassment, sexual exploitation andsexual abuse.

Developing andimplementing
PSEAH policy
and procedures

Focal point – a person designated to receive
reports of cases of sexual exploitation, abuseand harassment, and support the organisationin implementing PSEAH.

Safeguarding – the responsibility oforganisations to make sure their staff,
operations, and programmes do no harm tochildren and adults at-risk nor expose themto abuse or exploitation5. This term covers
physical, emotional and sexual harassment,
exploitation and abuse by staff andassociated personnel, as well as safeguarding
risks caused by programme design andimplementation. Many organisations now
also use this term to cover harm caused tostaff in the workplace.

PSEAH
handbook
at a glance

Confidentiality – an ethical principle that
restricts access to and dissemination of
information. In investigations on sexual
exploitation, abuse, fraud and corruption,
it requires that information is available only
to a limited number of authorised people forthe purpose of concluding the investigation.
Confidentiality helps create an environment
in which witnesses are more willing to recounttheir versions of events and builds trust in
the system and in the organisation.

Introduction

Glossary

Contents

PSEAH
handbook
at a glance

CONTENTSDEVELOPING AND IMPLEMENTING PSEAH POLICY AND PROCEDURES

14ASSIGNING SPECIFIC RESPONSIBILITIES FOR PSEAH

19

ENSURING STAFF, VOLUNTEERS AND ASSOCIATES UNDERSTAND
AND WORK TO PSEAH REQUIREMENTS

23

ENGAGING COMMUNITIES AND PEOPLE AFFECTED BY CRISIS

27

IMPLEMENTING PSEAH REQUIREMENTS WITH PARTNERS,SUPPLIERS AND CONTRACTORS

31

DESIGNING SAFE PROGRAMMES AND PROJECTS35

SEXUAL MISCONDUCT IN THE WORKPLACE40

DEVELOPING AND IMPLEMENTING A COMMUNITY-BASEDCOMPLAINTS MECHANISM44

RESPONDING TO REPORTS OF SEAH

49

Designing safe
programmes
and projects

12

Implementing
requirements withpartners, suppliersand contractors

PSEAH HANDBOOK AT A GLANCE

Engaging
communities andpeople affectedby crisis

6

Ensuring staff
and volunteers
work to PSEAH
requirements

INTRODUCTION

Assigning
specific
responsibilities
for PSEAH

1

Developing andimplementing
PSEAH policy
and procedures

GLOSSARY

Sexualmisconduct inthe workplace
Developing andimplementing
a complaints
mechanism5

Responding
to reportsof SEAH

4

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

The purpose of this handbook is to demonstrate how aid workers and organisations canimplement practical measures to prevent sexual exploitation, abuse and harassment, in linewith the Core Humanitarian Standard PSEAH Index. The Handbook takes the key areas from the
PSEAH Index and provides examples of how this can look in practice. It also provides a real-lifecase study for each of the areas covered, so you can learn from the work of other NGOs.

This Handbook was update in 2020 to reflect new learning and practices in PSEAH.

CHS Indicator

Specific PSEAH Requirement

Chapter in PSEAH
Handbook

1.2. Programmes areappropriately designed andimplemented based on an
impartial assessment of needs
and risks and an understanding of
the vulnerabilities and capacities
of different groups.

Programmes need to be designed Designing safe
and implemented based onprogrammes andan assessment of SEAH risks
projects
and understanding of SEAH
vulnerabilities of different groups.

Sexualmisconduct inthe workplace

The primary audience for this Handbook is smaller and/or national NGOs who may have fewer
resources to implement PSEAH. However, it can be used by any organisation or institution
involved in the delivery of humanitarian and development assistance.

The CHS is a broad quality and accountability framework describing the essential elements
of principled, accountable and high-quality aid. Protection from sexual exploitation, abuse,and harassment is incorporated throughout the Standard. The Standard is a verifiable
standard, meaning organisations can measure and improve their performance against it.
One of the verification tools is the PSEAH index, which is an amalgamation of the CHS
indicators that specifically relate to PSEAH and include specific PSEAH requirements.
These are outlined below:

Designing safe
programmes
and projects

Purpose of the handbook

The most widely used standards with regard to PSEAH are the Core Humanitarian Standard
and the IASC (Inter-Agency Standing Committee) Minimum Operating Standards forProtection from Sexual Exploitation and Abuse for UN and non-UN staff.

Implementing
requirements withpartners, suppliersand contractors

The humanitarian and development community is committed to preventing sexual exploitation,
abuse and harassment in our work. However, the issue is a complex and sometimes it can seem
hard to know where to start.

International standards on PSEAHEngaging
communities andpeople affectedby crisis

In recent times, the sector has become more aware of the issues of abuse of power within
the workplace, as well as in the work we do with affected populations. The humanitarianand development community has had policies and measures in place for many years that aredesigned to create safe and productive workplaces which are free of abuse such as bullying,
discrimination and sexual harassment. (In a number of countries this is mandated by national
legislation.) Since 2018, agencies have now been examining and strengthening these policies,
as well as analysing in more detail the issues of gender, diversity and power imbalance that are
the root causes of these abuses of power.

CHS Alliance uses the term SEAH to refer to the spectrum of behaviours that are notacceptable conduct by our staff, be it with affected populations or in the workplace. Some of
the Learning Examples in this Handbook use the term PSEA, as this was the term used by thatorganisation at the time of writing to refer to sexual misconduct against affected populations.
All chapters in this Handbook focus on SEAH against affected populations, except the chapter
on sexual misconduct in the workplace.

Ensuring staff
and volunteers
work to PSEAH
requirements

The contexts we work in bring us into contact with at-risk children and adults in thecommunities with which we work. As aid workers, we have access to goods and services that
put us in a position of power over these communities and individuals. Unfortunately, a minorityof people use this power imbalance to exploit, abuse and harass others. The humanitarian anddevelopment community has developed standards and approaches to prevent and respond tosuch abuses of power.

This handbook is designed to provide guidance and ideas when you are developing PSEAH
measures. Each chapter takes a key element in implementing PSEAH and discusses what needs
to be in place. It then takes you through a step by step guide of how to implement thesemeasures, followed by a Learning Example.

Assigning
specific
responsibilities
for PSEAH

PSEAH (Protection from Sexual Exploitation and Abuse and Sexual Harassment) is a term
used by those working in the international humanitarian and development sector to refer tomeasures taken to protect people from sexual exploitation, abuse and harassment by theirown staff and associated personnel. We also now use it to mean protecting staff and associatedpersonnel from sexual harassment or misconduct within the workplace.

How to use this handbook

Developing andimplementing
PSEAH policy
and procedures

Background

PSEAH
handbook
at a glance

INTRODUCTION

2.1. Programmes are designed
Programmes need to take into
Designing safe
taking into account constraints
account organisational andprogrammes andso that the proposed action iscontextual constraints so that the projects
realistic and safe for communities. proposed action is safe in relation
to PSEAH for communities.

Developing andimplementing
a complaints
mechanism7

Responding
to reportsof SEAH

6

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

5.3. Complaints are managed
in a timely, fair and appropriatemanner. Complaints handlingmechanisms prioritises the safetyof the complainant and thoseaffected at all stages.

Complaints or reports relating to
SEAH need to be managed in atimely, fair, appropriate and safemanner.

Responding toreports of SEAH

3.7. Policies, strategies andguidance are designed toprevent programmes having
any negative effects such as, forexample, exploitation, abuse or
discrimination by staff against
communities and people affectedby crisis, and to strengthen local
capacities.

The organisation needs to havedocumented policy, strategies
and guidance in place to prevent
SEAH.

Developing andimplementing
PSEAH policy andprocedures

5.4. The complaints-handlingprocess for communities andpeople affected by crisis is
documented and in place. The
process covers programming,
sexual exploitation and abuse,and other abuses of power.

The organisation needs to have a
documented complaints-handlingand investigations processthat addresses SEAH, is victim/
survivor-centred, and sets out
mandatory reporting obligations
relating to SEAH.

Developing andimplementing
a Communitybased Complaints
Mechanism
Responding toreports of SEAH

5.5. An organisational culture
in which complaints are taken
seriously and acted upon
according to defined policies andprocesses has been established.

The organisation needs to havean organisational culture thattakes SEAH complaints seriously
and acts upon them according to
its PSEAH Policy and processes.

3.8. Systems are in place
to safeguard any personal
information collected from
communities and people affectedby crisis that could put themat risk.

The organisation needs to havesystems in place to safeguard
personal information relating to
SEAH incidents that could put
affected people at risk.

Responding toreports of SEAH

Ensuring staff,
volunteers
and associates
understand andwork to PSEAH
requirements
Responding toreports of SEAH

4.1. Information is provided tocommunities and people affectedby crisis about the organisation,
the principles it adheres to, theexpected behaviours of staff, andits programmes and deliverables

Information provided tocommunities needs to cover
the organisation’s commitment
and expected staff behaviours in
relation to PSEAH.

Engaging
communities andpeople affected bycrisis

5.6. Communities and people
affected by crisis are fully awareof the expected behaviour ofhumanitarian staff, includingorganisational commitments
made on the prevention of sexual
exploitation and abuse.

The organisation needs toensure that affected people
are fully aware of the expectedbehaviour of staff in regard to
PSEAH, and organisational PSEAH
commitments.

Engaging
communities andpeople affected bycrisis

5.7. Complaints that do not
fall within the scope of theorganisation are referred toa relevant party in a mannerconsistent with good practice.

The organisation needs to refer
Responding to
SEAH complaints/reports that do reports of SEAH
not fall within the scope of theorganisation to a relevant party
in a manner consistent with goodpractice.

6.1. The roles, responsibilities,
capacities and interests ofdifferent stakeholders are
identified.

The roles, responsibilities andcapacities of partners and otherstakeholders to prevent SEAH
need to be identified.

Implementing PSEAH
requirements withpartners, suppliersand contractors

6.4. Information is shared withpartners, coordination groups
and other relevant actors throughappropriate communication
channels.

Information relating to PSEAH
needs to be shared with partners,
coordination groups and otherrelevant actors.

Implementing PSEAH
requirements withpartners, suppliersand contractors

4.5. Policies for informationThe organisation needs to have
Engaging
sharing are in place and promote an information sharing policy that communities anda culture of open communication. addresses PSEAH.
people affected bycrisisCommunities and affected people
need to be consulted on how thecomplaints handling process willaccommodate SEAH.

Developing andimplementing
a Communitybased Complaints
Mechanism

5.2. Complaints are welcomed andaccepted, and it is communicated
how the mechanism can beaccessed and the scope of issues it
can address.

Complaints handling mechanism
needs to welcome and accept
reports relating to SEAH, andcommunities need to know how
and what to report.

Developing andimplementing
a Communitybased Complaints
Mechanism9

Responding
to reportsof SEAH

8

5.1. Communities and people
affected by crisis are consulted on
the a. design, b. implementation,and c. monitoring of complaints
handling processes.

Developing andimplementing
a complaints
mechanism

Developing andimplementing
a Communitybased Complaints
Mechanism
Responding toreports of SEAH

Sexualmisconduct inthe workplace

Programmes need to identify
and act upon potential or actual
unintended negative effects
relating to SEAH.

Designing safe
programmes
and projects

3.6. Programmes identify andact upon potential or actual
unintended negative effects ina timely and systematic manner,
including in the areas of people’ssafety, security, dignity and rights,
sexual exploitation and abuse bystaff, culture, gender, social andpolitical relationships, livelihoods,
the local economy, and theenvironment.

Implementing
requirements withpartners, suppliersand contractors

Chapter in PSEAH
Handbook

Engaging
communities andpeople affectedby crisis

Specific PSEAH Requirement

Ensuring staff
and volunteers
work to PSEAH
requirements

CHS Indicator

Assigning
specific
responsibilities
for PSEAH

Chapter in PSEAH
Handbook

Developing andimplementing
PSEAH policy
and proceduresSpecific PSEAH Requirement

PSEAH
handbook
at a glance

CHS IndicatorIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

The organisation needs to haveclear and consistent agreementswith its partners specificallyaddressing PSEAH obligations.

Implementing PSEAH
requirements withpartners, suppliersand contractors

8.1. Staff work according to
the mandate and values of theorganisation and to the agreed
objectives and performancestandards.
8.2. Staff adhere to the policies
that are relevant to them andunderstand the consequences of
not adhering to them.

Chapter in PSEAH Handbook

1. Effective policy development andimplementation

Developing and implementing PSEAH policy
and procedures

Recruitment, screening and staff Developing andperformance processes need to
implementing
promote safeguarding from SEAH PSEAH policy andprocedures

2. Cooperative arrangements

Implementing PSEAH requirements withpartners, suppliers and contractors

3. A dedicated department/focal point iscommitted to PSEA

Assigning specific responsibilities for PSEAH

Staff need to adhere to PSEAH
policies, including mandatory
obligation to report andunderstand the consequences of
not adhering to them.

4. Effective and comprehensive
communication from headquarters to thefield on expectations regarding raising
beneficiary awareness on PSEA

Engaging communities and people affectedby crisis

5. Effective community-based complaints
mechanisms, including victim assistance.

Developing and implementing acomprehensive complaints mechanism

6. Effective recruitment and performance
management

Developing and implementing PSEAH policy
and procedures
Ensuring staff, volunteers and associates
understand and work to PSEAH requirements

Assigning specificresponsibilities for
PSEAH
Ensuring staff,
volunteers
and associates
understand andwork to PSEAH
requirements
Developing andimplementing
PSEAH policy andprocedures

8.9. Policies are in place for the
security and wellbeing of staff.

The organisation needs tohave policies in place for thesafeguarding of staff to protect
them from sexual exploitation,
abuse and harassment,
and retaliation, including a
Whistleblower Protection policy.

Sexual Misconduct in
the Workplace

8. Internal complaints and investigation
procedures are in place

Further support
Tools and resources that support you to implement the steps in each chapter can be found on
the CHS Alliance website at www.chsalliance.org.

Responding toreports of SEAH

Note the PSEAH Index – with the specific requirements to fulfil the indicators – is documented
in full detail in the CHS Alliance Verification Framework10.

If you are interested in understanding better how well you are implementing PSEAH measures,
the CHS Alliance can advise on how you can access the CHS verification options; selfassessment, or independent verification and certification (the latter two are carried out by
independent HQAI auditors).
CHS Alliance encourages organisations to assess themselves using one of these options. From
this assessment you can derive a PSEAH index score giving a comprehensive picture of thedifferent elements contributing to effective work on PSEAH in an organisation. This not only
enables your own organisation to improve, it also provides valuable data to track progress on
PSEAH across the sector. CHS Alliance member organisations are able to access support fromthe CHS Alliance as they work to improve.

Developing andimplementing
a complaints
mechanism

https://www.chsalliance.org/get-support/resource/chs-verification-framework/

10

11

Responding
to reportsof SEAH

10

Responding to reports of SEAH

Sexualmisconduct inthe workplace

9.5. The risk of corruption is
Serious misconduct needs to be
managed, and appropriate action taken seriously and acted upon.
is taken when corruption cases
are identified.

7. Effective and comprehensive mechanisms Ensuring staff, volunteers and associates
are established to ensure awareness-raising understand and work to PSEAH requirements
on SEA amongst personnel

Designing safe
programmes
and projects

The organisation needs to have acode of conduct that includes theobligation of staff and associatedindividuals and entities, not tosexually exploit, abuse or harass
people and to comply with
reporting obligations.

Implementing
requirements withpartners, suppliersand contractors

8.7. A code of conduct is in placethat establishes, at a minimum,
the obligation of staff not to
exploit, abuse or otherwise
discriminate against people.

Engaging
communities andpeople affectedby crisis

Minimum Operating Standard

Ensuring staff
and volunteers
work to PSEAH
requirements

6.6. Work with partners isgoverned by clear and consistentagreements that respect eachpartners mandate, obligations
and independence, andrecognises their respective
constraints and commitments.

The IASC is a committee of UN agencies and NGOs involved in the delivery of humanitarianassistance. They developed the PSEA Minimum Operating Standards to support agencies
in implementing PSEA measures. The eight areas covered by the IASC Minimum OperatingStandards are:

Assigning
specific
responsibilities
for PSEAH

Chapter in PSEAH
Handbook

Developing andimplementing
PSEAH policy
and proceduresSpecific PSEAH Requirement

PSEAH
handbook
at a glance

CHS IndicatorIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEAH
handbook
at a glance

PSEAH HANDBOOK AT A GLANCE• A PSEAH, or similar, policy• A Whistleblower Protection policy• Procedures which describe how the policy is implemented throughout
the organisation• An implementation plan

Designing safe
programmes
and projects• Potential risks of sexual exploitation, abuse and harassment presented byprogrammes and projects are identified and addressed• Programme designs respond to or are adapted to mitigate risks of SEAH
• Project plans include activities on PSEAH awareness and sensitivity• Budgets include funding lines for capacity building and communications
on PSEAH

Developing andimplementing
a complaints
mechanism• Partners, suppliers and contractors are assessed for their contact withchildren, at-risk adults and affected populations, and capacity to implement
PSEAH measures• Clauses on PSEAH are included in all contract agreements• Where required, PSEAH training is delivered to partners, suppliers andcontractors• PSEAH measures, and SEAH cases, in partner, supplier and contractor
organisations are monitored

Sexualmisconduct inthe workplace

Implementing
PSEAH
requirementswith partners,
suppliers andcontractors

Designing safe
programmes
and projects• Communities that aid organisations work with are fully aware of the expectedbehavior of the organisation’s staff, including organisational commitments
made on the prevention of sexual exploitation, abuse and harassment• Communities that aid organisations work with know how to complain if thesecommitments are not met• Appropriate awareness-raising tools and approaches are used with
communities, which are relevant to age, language and capacity• Written procedures on responding to reports or concerns relating to SEAH,
which are victim/survivor-centred and ensure confidentiality• A mapping of referral pathways for victims/survivors of SEAH
• Investigations are undertaken in line with the relevant standards andguidance• Investigations are undertaken by experienced and qualified professionals• Substantiated complaints result in consistent disciplinary action

Implementing
requirements withpartners, suppliersand contractors

Engaging
communities
and affected
populations
on PSEAH

Responding toreports of PSEAHEngaging
communities andpeople affectedby crisis• All staff, volunteers and associated personnel sign the organisation’s codeof conduct• All staff, volunteers and associates receive induction and (where relevant)annual refresher training on PSEAH• Staff members are aware of their obligation to report SEAH/misconduct andare aware that there is a policy for protection from retaliation• Supervision and performance appraisals include discussions on the level ofunderstanding of PSEAH, adherence to code of conduct and participation intrainings (or similar) that include PSEAH

Developing and• A confidential, victim/survivor-centred report handling protocol
implementing• Designated staff with responsibility for receiving and managing reports
a Community• Appropriate, accessible and confidential reporting channels that have been
based Complaints
designed in consultation with the community , including channels that are
Mechanism
designed to proactively enable reports of SEAH
• A referral process for reports which do not fall within the scope of the CBCM

Ensuring staff
and volunteers
work to PSEAH
requirements

13

Responding
to reportsof SEAH

12

Ensuring staff,
volunteers
and associates
meet PSEAH
requirements• Clear commitments to an organisational culture that recognises issues ofgender, power and privilege, encourages diversity and speaking up• A PSEAH policy or policies that describe prohibited behaviours in theworkplace and outlines the organisation’s commitment to preventing andresponding to workplace sexual harassment• Procedures which describe how the policy is implemented throughout theorganisation• Formal and informal opportunities to speak up on sexual misconduct

Assigning
specific
responsibilities
for PSEAH

Assigning specific • The Board has accountability for PSEAH as part of its role
responsibilities• Senior management takes responsibility for ensuring PSEAH measuresfor PSEAH
are implemented• The Board and leadership teams are responsible for creating anorganisational culture which supports PSEAH• Organisations assign focal points for PSEAH• PSEAH responsibilities are reflected in role and job descriptions

Sexualmisconduct inthe workplace

Developing andimplementing
PSEAH policy
and procedures

PSEAH Policies
and Procedures

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

Recruitment, screening and staff performance
processes need to promote safeguardingfrom SEAH.

8.7. A code of conduct is in place that
establishes, at a minimum, the obligationof staff not to exploit, abuse or otherwise
discriminate against people.

The organisation needs to have a code of
conduct that includes the obligation of staff
and associated individuals and entities, not tosexually exploit, abuse or harass people andto comply with reporting obligations.

What should be in place– The policy should reflect where possible the organisation’s values and state how thesevalues are intended to create safe, equitable and inclusive organisations• A Whistleblower Protection policy that protects staff who report SEAH in good faith throughthe organisation’s whistleblowing/Speak Up mechanisms.
• Procedures which describe how the policy is implemented throughout the organisation.

6. Develop PSEAH procedures or refer torelevant organisational procedures/
guidelines which include PSEAH measures.
The procedures should include:– Identifies the organisation’scommitment to the IASC Six Core
Principles Relating to Sexual
Exploitation and Abuse– Recognises the rights of all children,
adults at-risk, affected populations
and staff and associated personnel tobe protected from sexual exploitation,
abuse and harassment– Applies to all staff, volunteers andassociates at all times– Identifies and manages risk

Sexualmisconduct inthe workplace• An implementation plan, identifying gaps in implementing PSEAH and actions to address thegaps, which is reviewed and updated regularly.

– Reflects organisational values which
are explicit on e.g. non-discrimination,
diversity and inclusivity, recognising
power and privilege

Designing safe
programmes
and projects– The policy should be victim/survivor-focused (i.e. the victim/survivor’s wishes, safety,
and well-being remain a priority in all matters and procedures).

2. Check your PSEAH policy:

5. If your organisation conducts online
activities, ensure you have an Online
Safeguarding policy or equivalent.

Implementing
requirements withpartners, suppliersand contractors• A PSEAH, or similar, policy (such as a Safeguarding Policy) which describes the standard of
behaviour expected of the organisation’s staff and representatives, and which specificallyprohibits sexual exploitation, abuse and harassment:– Using an example of a PSEAH policy
from elsewhere and adapt to suit yourorganisation and the context in which
you work. You should involve staff by
circulating the draft and asking forcomment before finalising.

4. If your organisation gathers content
from affected populations for research orcommunications materials, ensure you havepolicies and procedures in place to prevent
SEAH that might arise from inappropriate
use of content and safely store dataon individuals.

Engaging
communities andpeople affectedby crisis8.1. Staff work according to the mandate andvalues of the organisation and to the agreed
objectives and performance standards.

– Running a consultation with staff,
raising awareness on what PSEAH
means and asking for their inputs onwhat the policy should say (ensure theconsultation is run with groups of staff
from different intersecting identities
e.g. older and younger female staff,
staff identifying as LGBTQ+); or

3. Organisations which have alreadydeveloped a policy and procedure forsexual harassment in the workplace(often linked to policies on discriminationand other workplace issues such as
bullying) should check that policy meetsthe requisite standards.

Ensuring staff
and volunteers
work to PSEAH
requirements

The organisation needs to have documented
policy, strategies and guidance in place toprevent SEAH.

1. Develop a PSEAH policy. You can develop
your policy by:

Assigning
specific
responsibilities
for PSEAH

Specific PSEAH Requirement

3.7. Policies, strategies and guidance aredesigned to prevent programmes having
any negative effects such as, for example,
exploitation, abuse or discrimination by staff
against communities and people affected bycrisis, and to strengthen local capacities.

How to do it

Developing andimplementing
PSEAH policy
and procedures

CHS Indicator

PSEAH
handbook
at a glance

DEVELOPING AND IMPLEMENTING PSEAH
POLICY AND PROCEDURES– Includes the organisation’s code of
conduct– Integrates PSEAH measures into allareas of the organisation.

Developing andimplementing
a complaints
mechanism

15

Responding
to reportsof SEAH

14

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOKPSEAH measures

Recruitment

EFICOR is a national organisation engaged indevelopment, advocacy, disaster response andtraining. EFICOR supports some 38 projects
across India, focusing primarily on disastermanagement, climate change, health andurban poverty. They work with a range ofcommunities and people including those withdisabilities. Their staff are spread across the
projects, with a number of them based in fairly
remote communities.

Developing andimplementing
a complaints
mechanism• Induction/training – all new employees
receive a briefing on the policy and areasked to sign it. Staff have the opportunity
to discuss the values they work to during
the annual staff retreat.

Sexualmisconduct inthe workplace

EFICOR had been working with a childprotection policy and a gender policy. In
2010 the Supreme Court in India issued arecommendation that organisations introduce
anti-harassment policies and procedures.
EFICOR took this opportunity to introduce
a new anti-harassment policy, which
replaced their gender policy, to cover sexual
harassment, abuse and exploitation bothwithin and outside the workplace.

• Recruitment – EFICOR ask candidates tocomplete application forms and declare they
are free from convictions relating to abuseof children. Candidates are asked about any
gaps in their employment history during theinterview. They are required to provide two
references; EFICOR also contacts the previous
employer to check whether there are concerns
over the candidate’s behaviour. Backgroundchecks are done on successful candidates.

Designing safe
programmes
and projects

The issue

Key procedures that EFICOR have
implemented to support the policy are:

Implementing
requirements withpartners, suppliersand contractors

Information on how to make a complaint relating to
the policy

Action, Coordination Team (PACT) during
their annual meeting and agreed by the
Board of Trustees. EFICOR used a policy fromanother organisation to help inform the draft.
All staff were then consulted on this draft;
discussions focused on potential challenges in
implementing the policy and other concerns
staff had. The results of this consultation
were used to produce a final draft of thepolicy which was signed off by the Board. The
policy is accompanied by a set of procedures
which describes what needs to be done forrecruitment, induction/training, reporting
concerns and disciplinary actions relating tosexual harassment. All staff were required tosign the policy upon its introduction during
their annual staff retreat. The process ofdeveloping, consulting and signing off thepolicy took a year and a half.

Engaging
communities andpeople affectedby crisis

9. Review the PSEAH policy and procedures
every two years to ensure they are fit
for purpose.

The programme

Ensuring staff
and volunteers
work to PSEAH
requirements• Performance appraisal – this triggers arenewal of contract which is accompanied
by a letter reminding staff of the policies
they must work to.
17

Responding
to reportsof SEAH

16

8. Monitor the implementation plan
on a quarterly basis to ensure that theorganisation is making steady progress
towards fully implementing PSEAH policy
and procedures.

Developing and implementing What EFICOR did
an anti-harassment policy
EFICOR adopted a consultative process indeveloping the policy. The initial draft of thein India
policy was developed by EFICOR’s Planning,

Assigning
specific
responsibilities
for PSEAH

7. Develop a PSEAH implementation
or work plan which identifies the gaps
in the organisation in implementing
PSEAH measures, and states what action
will be taken to address the gaps, by whom
and when.

Good
Learning
practice
ExampleexampleDeveloping andimplementing
PSEAH policy
and procedures• Job adverts include PSEAH commitments• Gaps in employment history checked during interview• Questions related to PSEAH asked during interview• At least two references taken, preferable verbally, from previous employers
which include questions on candidate’s conduct, behaviour• Criminal records check is conducted, where possible• Consider a self-declaration form, where staff declare that they have noprevious convictions or dismissals that prevent them from working withchildren or at-risk adults• New employees sign contracts which include PSEAH and the organisation’scode of conduct• Consider becoming a signatory to the Inter-Agency Misconduct Disclosure
Scheme. This is an interagency scheme that commits to systematically asking
for, and responding to requests for checks with previous employers
on SEAH issues
Induction/• Induction includes at least a briefing on PSEAH
training• All staff receive a half day training on PSEAH – recognising and responding torisks and concerns• Annual refresher training opportunities provided
Performance• Performance management discussions include understanding of PSEAH andmanagement
an opportunity to raise concerns• Where performance management includes working to values orcompetencies, these include PSEAH
Whistleblowing • A policy or procedure which encourages people to report on concerns
without fear of reprisals
Discipline and • SEAH is explicitly stated as grounds for discipline which may result ingrievance
termination of employment
Programming• Programming guidelines include identifying and mitigating risks of sexual
guidelines
exploitation, abuse and harassment in programmes to make them safer
Risk Register• SEAH risks are included in the organisation’s Risk Register• SEAH is treated as a separate risk category• Major SEAH risks have an assigned owner• All contracts with partners/suppliers/contractors include clauses on PSEAH
Partnershiparrangements • Capacity building for partners includes capacity to implement PSEAH measures• Partner monitoring includes PSEAH measures and SEAH reports
Complaints/• Complaints/reporting mechanism developed to receive and respond toreportingreports of SEAH

PSEAH
handbook
at a glance

Procedure

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

What happened as a result• There needs to be a balance between
focusing on SEA for women and SEA
for men – it is not just an issue which
impacts on women.

What should be in place

How to do it• The Board (or equivalent governancestructure) has accountability for PSEAH
as part of its role.

1. Ensure that maintaining an organisational
culture which supports PSEAH is built
into job descriptions and performance
management for senior leadership staff.

• Senior management takes responsibility forensuring PSEAH measures are implemented.
• The Board (and leadership teams are
responsible for creating an organisational
culture which supports PSEAH. An
organisational culture which supports
PSEAH is one in which:– staff understand the organisation’sshared values which help to prevent
SEAH– staff have the opportunity to discussand challenge attitudes, behaviours
and practice that underpin SEAH
– senior leadership model theorganisation’s shared values which
help to prevent SEAH

3. Present a progress report on implementing
the PSEAH policy to your Board at least
annually.
4. Identify staff members who can serve as
focal points on PSEAH. These staff members
should be relatively senior and/or hold roles
which already implement PSEAH measures,such as human resources staff. Focal points
should ideally reflect the diversity of staff
who may wish to report sexual harassment,
exploitation or abuse, and be ‘trusted’.

• Organisations assign focal points for
PSEAH, who support the development
and implementation of PSEA policy
and procedures.

Developing andimplementing
a complaints
mechanism• PSEAH responsibilities are reflected in roleand job descriptions.

19

Responding
to reportsof SEAH

18

Sexualmisconduct inthe workplace– the organisation’s policies andpractices address issues of gender,
diversity and empowerment.

2. At least once every three months,
include an item on PSEAH on your Senior
Management Team meeting agenda.
Discuss progress and challenges with
implementing the PSEAH policy andimplementation plan and how theorganisational culture is either driving or
hindering progress with implementation.

Designing safe
programmes
and projects• Larger, more well resourced,
organisations may be able toimplement a policy within existingfunding. Smaller organisations mayneed support and some additional
funding may be required.

Staff need to adhere to PSEAH policies,
including mandatory obligation to reportand understand the consequences of notadhering to them.

Implementing
requirements withpartners, suppliersand contractors• Always consult staff in the developmentof the policy – it creates ownership,
buy-in and awareness.

8.2. Staff adhere to the policies that are
relevant to them and understand theconsequences of not adhering to them.

Engaging
communities andpeople affectedby crisis

Due to the process of developing thepolicy, and the reminders and discussions
that take place each year, staff understandthe policy well and “hold one anotheraccountable”. The policy is going to betranslated into local languages to ensure
all stakeholders fully understand.

• If using a policy from anotherorganisation, it must be adapted to suitthe context and organisation. Cultural
practices with regard to issues such as
childcare need to be well understood.

Specific PSEAH Requirement

Ensuring staff
and volunteers
work to PSEAH
requirements

EFICOR’s leadership has been instrumental indeveloping and implementing the policy andmodels the behaviour expected of staff. The
Board monitor the progress in implementing
the policy.

• Check what national legislation orpolicy exists that supports PSEA, anduse this as a foundation for yourorganisation’s policy and measures.

CHS Indicator

Assigning
specific
responsibilities
for PSEAH

Information on the anti-harassment policy being
delivered during a maternal health project• The Board of Trustees and seniorleadership teams plays a vital rolein leading the development andimplementation of the policy. They
need to model behaviours and createa culture for preventing and responding
to harm and abuse within and outside
the organisation.

Developing andimplementing
PSEAH policy
and procedures

Learnings

PSEAH
handbook
at a glance

ASSIGNING SPECIFIC RESPONSIBILITIES FOR PSEAHIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK• Awareness raising/training for staff, stakeholders and communities• Receiving reports on PSEAH and referring to the correct team or staff member forfollow up.

The programme

Board• Ensuring that PSEAH policies, procedures and approaches are in placeand being implemented• Foster and maintain an organisational culture which supports PSEAH• Accountability for serious SEAH incidents• Foster and maintain an organisational culture which supports PSEAH• Ensure all new employees receive the PSEAH policy training as part oftheir induction.
• Ensure PSEAH measures are implemented within their area of
responsibility and risk assessments conducted on systems, processes
and activities.
• Follow up, and address, SEAH issues appropriately and consistently

HR staff• Implement the necessary measures when recruiting new staff
and volunteers• Ensure all new employees receive a copy of the PSEAH policy andcode of conduct, prior to, or at the time of, issuing an employment
contract. Signed copies must be place in their personnel file.
• Serve as focal points (where appropriate) or be identified as therelevant personnel for addressing sexual misconduct within theworkplace and SEAH of communities by staff

Programme staff• Receiving reports and coordinating the
response to any reports that arise.
The project managers are responsible for:
Workshop on PSEA code of conduct• Holding monthly staff meetings during
which they discuss PSEA

The issue• Holding quarterly meetings with refugees
during which they discuss PSEARCK had introduced some PSEA measures in• Receiving reports from refugees.
2004. In 2010 RCK began work with UNHCR
and, as a requirement of the partnership, had toinclude PSEA commitments in all contracts anddemonstrate that the organisation was actively
implementing PSEA measures across theorganisation. RCK needed key people within theorganisation to support PSEA implementation.

Developing andimplementing
a complaints
mechanism

7. Write PSEAH responsibilities into job descriptions and include it in performance
management/appraisal discussions.

• Reporting concerns or issues withPSEA implementation to the Senior
Management Team

Sexualmisconduct inthe workplace• Ensure that communities are aware of the PSEAH Policy and how toreport concerns• Serve as focal points (where appropriate) for SEAH of affected
populations e.g. as a trusted person to whom affected populations
can report SEAH
• Conduct SEAH risk assessments of all programmes• Ensure safe programming/ Design safe programmes• Delivering induction/training to staff
on PSEA

Designing safe
programmes
and projects

All Managers

Implementing
requirements withpartners, suppliersand contractors• Adhere to the PSEAH policy and code of conduct, report concerns

RCK also recognised, however, that thisrole did not have contact with the refugeecommunities where abuse might be taking
place. They needed to assign focal point
RCK provides legal aid services androles to project managers who worked in thepsychosocial counseling; advocates for policy
camps and the urban communities in whichchange and raises awareness on the rights ofrefugees. The organisation works in Nairobi and RCK operated.
urban centres and in camps hosting refugees.
The focal points have been given a numberof responsibilities for PSEA. The HR/admin
officer is responsible for:Engaging
communities andpeople affectedby crisis

All staff

The national focal point role was assigned
to the HR/admin officer in Nairobi. RCK
recognised that the HR/admin officer is an
important role for PSEA. The HR/admin officer
had the necessary authority to recommend or
take decisions in relation to staff, and she wasable to work professionally, be objective andmanage information confidentially.

Ensuring staff
and volunteers
work to PSEAH
requirements

Responsibility

RCK decided to assign focal point
responsibilities to key staff in the organisation.

Assigning
specific
responsibilities
for PSEAH

Role

The Refugee Consortium of Kenya (RCK)promotes and protects the rights and dignity of
refugees, asylum seekers, internally displaced
people and other forced migrants in Kenya andthe wider East African region. The organisation
was established in response to an increasingly
complex and deteriorating refugee situation in
Kenya and the region.

What RCK did

Developing andimplementing
PSEAH policy
and procedures• Supporting teams and departments to conduct risk assessments on their departmental
systems and processes to ensure that PSEAH measures are integrated effectively

6. Identify PSEAH responsibilities for other staff. These are typically:

21

Responding
to reportsof SEAH

20

Learning Example

Assigning responsibilities
for PSEA in a refugeeprogramme in Kenya• Documenting who has signed the PSEAH policy and code of conduct and who hasreceived training on PSEAH

PSEAH
handbook
at a glance

5. Be clear on the role the focal points will play. The role will need to include:Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK• Need to commit to being accountable on
PSEA – having funds to implement PSEA
measures is not enough.

How to do it• All staff, volunteers and associated personnel
sign the organisation’s code of conduct, or
equivalent, which includes PSEAH.

1. All staff, volunteers, and associatedpersonnel should sign a copy of theorganisation’s code of conduct (orequivalent) when joining the organisation.
This can be annexed to their contract and,
where necessary by employment law, forma part of the contract. Note that, as anorganisational policy, the Code of Conduct
still applies even to staff who have for any
reasons not signed it.

• All staff, volunteers and associates receive
induction and (where relevant) annual
refresher training on PSEAH which includes
the organisation’s values and how they help
prevent SEAH.
• Staff members are aware of their obligation
to report SEAH/misconduct and are awarethat there is a policy for protection from
retaliation (often called a Speak Up orWhistleblower Protection policy) in place.
• Supervision and performance appraisals
include discussions on the level ofunderstanding of PSEAH, adherence tocode of conduct and participation intrainings (or similar) that include PSEAH.

2. Contractors, suppliers and other personnel
associated with the organisation should
also be made aware of the code of conduct.
See the chapter on Implementing PSEAH
requirements with partners, suppliersand contractors.

23

Responding
to reportsof SEAH

22

What should be in place

Developing andimplementing
a complaints
mechanism• Make sure focal points have a good
relationship with the communities you
are supporting – it is difficult for people toreport if they do not know the focal point,
or if they do not trust them.

Staff need to adhere to PSEAH policies,
including mandatory obligation to reportand understand the consequences of notadhering to them.

Sexualmisconduct inthe workplace• Ensure job descriptions reflect
responsibilities, and that time is allocatedfor PSEA work.

8.2. Staff adhere to the policies that are
relevant to them and understand theconsequences of not adhering to them.

Designing safe
programmes
and projects• Include a proportion of costs for
implementing PSEA measures in all
project proposals.

The organisation needs to have anorganisational culture that takes SEAH
complaints seriously and acts upon themaccording to its PSEAH Policy and processes.

Implementing
requirements withpartners, suppliersand contractors

Learnings

5.5. An organisational culture in which
complaints are taken seriously and acted
upon according to defined policies andprocesses has been established.

Engaging
communities andpeople affectedby crisis

Excerpt from booklet produced by RCK to supportmonthly discussions with children on SEAHRCK has also been able to identify where theirgaps may be. For example, they are exploring
different avenues for encouraging reports on
PSEA to build refugee confidence in reporting.
Further training will be needed for key staff tomanage cases and conduct investigations.

Specific PSEAH Requirement

Ensuring staff
and volunteers
work to PSEAH
requirements

Lines of reporting are very clear; refugees
know who has responsibility for receiving
and responding to reports and the team canmanage issues professionally.

CHS Indicator

Assigning
specific
responsibilities
for PSEAHRCK have been able to demonstrate that PSEA
measures are being implemented throughout
the organisation. All staff are trained andhave the opportunity to discuss PSEA on aregular basis so awareness on PSEA and codeof conduct is high. Coordination on PSEA
across the organisation is strong – particularly
between the focal points.

Developing andimplementing
PSEAH policy
and procedures

Key staff have received introductory training
on PSEA and participated in events on
investigations.

What happened as a result

PSEAH
handbook
at a glance

The senior management team hold a monthly
review of concerns or issues that have arisenwith PSEA implementation, and report asnecessary to their Board of Trustees.

ENSURING STAFF, VOLUNTEERS AND
ASSOCIATES UNDERSTAND AND WORKTO PSEAH REQUIREMENTS

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK• Inductions on the organisation’s principles
and code of conduct, which includes PSEAYEU is the Emergency Unit of YAKKUM – theChristian Foundation for Public Health, basedin Indonesia. YEU provides humanitarianassistance across Indonesia and the East
Asia region.

The issue
YEU has an organisational code of conduct,
which covers issues of PSEA. The code of
conduct has been part of all staff contracts
since 2011. However, the challenge was toraise staff awareness on PSEA, so it became a‘living’ part of their work – not just somethingthat they signed with their contract, thenforgot about.

• Quarterly management meetings toaddress pressing issues of PSEA, review
PSEA policy, etc• Annual all-staff meetings in order to refresh
staff on organisational values and norms,
including PSEA – and share experience of
dealing with PSEA issues from the field• Displaying agreements with communities on
the walls of field offices, which include codeof conduct and remind staff of the specificbehaviour that is expected of them

Implementing
requirements withpartners, suppliersand contractors

5. Awareness raising materials can also be
used to remind staff of the code of conduct.
These could be in the form of posters
or leaflets displayed in the office anddistributed to staff.

The programme

YEU set up a series of procedures toensure that PSEA became part of regularmanagement processes. This includes:

Engaging
communities andpeople affectedby crisis

4. Regular refresher training should be held
on PSEAH, covering the above points.

What YEU did

Ensuring staff
and volunteers
work to PSEAH
requirements

8. Senior managers should be performancemanaged on whether they are creating aculture and environment to help prevent
sexual harassment, exploitation and abuse– for example modeling the organisation’svalues, ensuring that inductions andtraining are taking place, communicating– What are the implications of breaching
to staff that they will take any complaint
the code of conduct?
or concerns seriously, and following up any– How to report any concerns they might
SEAH issues appropriately and according
have regarding SEAH (and that staff
to the organisation’s procedures.
should not attempt to investigate orresolve situations themselves).
– What role they play on PSEAH in theirteam or department (their specificresponsibilities for integrating PSEAH
measures in their work)

Communicating principles
and values to YEU staff
in Indonesia

Assigning
specific
responsibilities
for PSEAH– What is expected of them in terms of
their own behaviour and conduct

7. Staff should be performance managed onwhether they are implementing their roleand responsibility for PSEAH effectively(see the chapter on Assigning specificresponsibilities for PSEAH).

Learning Example

Developing andimplementing
PSEAH policy
and procedures– The organisational values, culture andcontribution these make to PSEAH

6. Procedures such as performance review,
annual appraisal and so on could include
a section on adherence to the code of
conduct, and participation in training.

PSEAH
handbook
at a glance

3. Staff should be briefed on their obligationsin terms of PSEAH when joining theorganisation. It is not enough just to sign
the code of conduct – they need to bemade aware of its contents. Inductions
should include:

Designing safe
programmes
and projects
Sexualmisconduct inthe workplace
Developing andimplementing
a complaints
mechanism

YEU public health programme in Mentawari Island
25

Responding
to reportsof SEAH

24

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEAH
handbook
at a glance

What happened as a result
YEU report that the results have been very
positive – staff are more aware of PSEA issues
as a result of rolling out these procedures.

CHS Indicator

Specific PSEAH Requirement• Including PSEA in other associated policies,
such as the communication policy, theinformation disclosure policy etc – so it isvisible across the organisation.

In addition, working on PSEA has been
helpful for acceptance in the community.
YEU are a Christian organisation working ina majority Muslim country. Introducing PSEA
has shown the community that YEU are reallythinking about how they can work together
respectfully, and has helped to develop trust.

4.1. Information is provided to communities
and people affected by crisis about theorganisation, the principles it adheres to,
the expected behaviours of staff, and its
programmes and deliverables.

Information provided to communities needs
to cover the organisation’s commitment
and expected staff behaviours in relation to
PSEAH.

4.5. Policies for information-sharing are
in place, and promote a culture of open
communication.

The organisation needs to have an
information sharing policy that addresses
PSEAH.

5.6. Communities and people affectedby crisis are fully aware of the expectedbehaviour of humanitarian staff, includingorganisational commitments made on theprevention of sexual exploitation and abuse.

The organisation needs to ensure that
affected people are fully aware of the
expected behaviour of staff in regard
to PSEAH, and organisational PSEAH
commitments.

What should be in place

How to do it• Think about how to roll PSEA out topartners – not just other NGOs, but
hospitals and others.

– communication needs to understand
SEAH and how they want to report it.

27

Responding
to reportsof SEAH

26– different risks of SEAH,

Developing andimplementing
a complaints
mechanism• Be aware that zero complaints/reports
does not mean an absence of cases, but
seek to review the enabling environment
for the delivery of complaints/reports.

Sexualmisconduct inthe workplace• For all organisations, it is useful tolink PSEA to organisational values andprinciples. For Christian and other faithbased organisations, PSEA can be linked
to faith teachings.

Designing safe
programmes
and projects

YEU Code of Conduct displayed on the office wall

Implementing
requirements withpartners, suppliersand contractors• In smaller offices, sometimes managers
have to ‘switch roles’ if there is a PSEA
issue. Make sure they have additional
training on how to deal with it.

• Communities that aid organisations
1. Pull out the key messages from yourwork with are fully aware of the expectedorganisation’s policies on PSEAH thatbehavior of the organisation’s staff, including
communities need to know. What shouldorganisational commitments made on thecommunities expect from the organisation
prevention of sexual exploitation, abuse
and its staff in terms of sexual exploitation,and harassment.
and abuse and harassment? What is
unacceptable conduct? How can they
• Communities that aid organisations work
report any concerns?
with know how to complain if these
2. Profile the community you arecommitments are not met.
communicating with and the different• Appropriate awareness-raising tools andidentities within community groups,
approaches are used with communities,
such as different genders, ages, whether
which are relevant to age, language
they are living with disability, or any
and capacity.
other contextually relevant or potentiallymarginalised diversity. Be aware ofdifferent intersecting identities and how
they impact on:

Engaging
communities andpeople affectedby crisis• PSEA is relevant for all staff – fromsenior staff to security, drivers,
gardeners. There is no excuse.

Ensuring staff
and volunteers
work to PSEAH
requirements• Be aware of staff turnover, or whenever
there is mobilisation of volunteers,
especially for short-term assistance.
You will need to re-introduce PSEA foreach specific context.

Assigning
specific
responsibilities
for PSEAH

Learnings

Developing andimplementing
PSEAH policy
and procedures• Implementing 360° feedback for staff
performance (where both managers
and subordinates can feed back on staff
performance), which includes breachesof the code of conduct

ENGAGING COMMUNITIES AND PEOPLE
AFFECTED BY CRISISIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK– What languages do they speak?

– Do certain members in the community
have more power than others?

The programme

The issue

Roll out c

GOAL Ethiopia has a code of conduct that
addresses PSEA, but found that the reality
was, staff were signing it then filing it away
without really being aware of its contents.
GOAL decided that they would look at waysthat they could bring the code of conduct totheir staff and to the communities they were
working with.

 Conducted 12 FGDs with community mem
Zones to obtain feedback on CoC design andculturally appropriate
What GOAL did
GOAL implement a wide-scale humanitarian
programme in Ethiopia, providing
programmes including emergency seeds,
water and sanitation, and community-based
management of malnutrition. They have alarge number of staff across many regions,most of them Ethiopian nationals.

4. Develop your communication materials.
There are many different ways tocommunicate messages, and a mixtureof different types can be used. Here aresome suggestions:– Leaflets– Acting out plays– Radio programmes• Do not accept bribes• Do not abuse children

Developing andimplementing
a complaints
mechanism• Do not exclude different groups in thecommunity• Do not sexually exploit people.

29

Responding
to reportsof SEAH

28

Sexualmisconduct inthe workplace

Testing the designs with the community

Designing safe
programmes
and projects– Focus group discussions.

Implementing
requirements withpartners, suppliersand contractors– Posters

Working with the monitoring and evaluation
team, the humanitarian programme manager
selected one office in each region of thecountry. They then held a meeting with staff
in that office, and put a piece of flipchart
paper on the wall for each of the points in thecode of conduct. Staff were asked to markwhat they thought were the top four mostimportant points. In addition, the GOAL teamsurveyed staff in the country office. They put
out the flipcharts on a wall in the office, andleft them for a week. Staff could mark the
flipcharts whenever they wanted, for example
when they were going for lunch. All the
responses were then added to a database, andthe overall top four priorities were calculated.
The four key priority messages were:Engaging
communities andpeople affectedby crisisFirst of all, GOAL decided to identify the
key messages in the code of conduct.
They asked team members to help define
the four top priority messages from the codeof conduct. They did this by conducting
a country-wide survey.

Ensuring staff
and volunteers
work to PSEAH
requirements– How will that impact oncommunicating SEAH and encouraging
reporting e.g. can SEAH be discussed
openly with communities, with young
women in communities?

6. Always make sure that the different
community members have a mechanism
to report SEAH that works for them andthat everyone knows how to report throughthese mechanisms. See Developing
and Implementing a Community-based
Reporting Mechanism.

Involving the community in
PSEA messages in Ethiopia

Assigning
specific
responsibilities
for PSEAH– If your messages are translated,it helps to have them proof-readby another party to make sure themessage is correct and appropriate

Code of Conduct
Learning Example

Developing andimplementing
PSEAH policy
and procedures– Is everyone within this group literate?

5. Involve the different groups within
the community throughout the processof developing your key messages
communication materials. This will help
ensure that your messages are appropriate,sensitive and likely to get the rightmessage across.

PSEAH
handbook
at a glance

3. Consider how to communicate thesekey messages in a way that is relevant
and accessible to the different identities
within community groups. Consider thefollowing points:

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK• Do not be afraid to approach donors
to fund your PSEA activities.

6.4. Information is shared with partners,
Information relating to PSEAH needs to becoordination groups and other relevant actors shared with partners, coordination groups
through appropriate communication channels. and other relevant actors.
6.6. Work with partners is governed by clear
The organisation needs to have clear andand consistent agreements that respectconsistent agreements with its partners
each partner’s mandate, obligations andspecifically addressing PSEAH obligations.
independence, and recognises their respective
constraints and commitments.

What should be in place• Partners, suppliers and contractors areassessed for their contact with children,
at-risk adults and affected populations, andcapacity to implement PSEAH measures.
• Clauses on PSEAH are included in allcontract agreements.
• Where required, PSEAH training is delivered
to partners, suppliers and contractors(particularly where these organisations will
have contact with affected populations).
• PSEAH measures, and SEAH cases,in partner, supplier and contractor
organisations are monitored.

1. Assess all partners, suppliers andcontractors before the contracting
arrangements are agreed:– How well have the policies and values
been implemented throughout theorganisation?
(The responses to these questions
will help you decide what support
to provide to the partner/supplier/contractor)– Recognise that many partners
already have good practice in PSEAH– even if they do not use terms such
as PSEAH or safeguarding to describe
it. Be prepared to learn fromtheir experience.
2. Develop contracts for organisations/companies which include PSEAH
requirements and commitments (ifnecessary) to support the organisation/company to meet requirements.
31

Responding
to reportsof SEAH

30– Do they have a PSEAH policy and codeof conduct?

Developing andimplementing
a complaints
mechanism…and the finished version– Will the organisation/company
be working directly with children,
at-risk adults and affected populations(as these groups may be at mostrisk of sexual exploitation, abuseand harassment)?

– What is the status of the organisation/company PSEAH measures?

Sexualmisconduct inthe workplace

How to do it– For partners: what are the values thatyour organisations share? How dothese contribute to PSEAH?

Designing safe
programmes
and projects

Some of the original designs….

The roles, responsibilities and capacities ofpartners and other stakeholders to prevent
SEAH need to be identified.

Implementing
requirements withpartners, suppliersand contractors• No need to create extra meetings forcommunity feedback – add it on themeetings that are already planned.

6.1. The roles, responsibilities, capacities
and interests of different stakeholders are
identified.

Engaging
communities andpeople affectedby crisis• Ensure you have the participation andbuy-in of key staff to roll the message
out to communities. It is often assumed
that this trickles down from senior
management – it does not.

Specific PSEAH Requirement

Ensuring staff
and volunteers
work to PSEAH
requirements

Learnings

CHS Indicator

Assigning
specific
responsibilities
for PSEAH

As a result of the measures taken, GOAL
began to receive feedback from thecommunity, which was dealt with throughthe appropriate channels. The fact that
PSEA was chosen as one of the four key
messages shows that GOAL staff in Ethiopia
take it very seriously, and communicating
this to the community demonstrates GOAL’s
commitment on this.

Developing andimplementing
PSEAH policy
and procedures

There was a lot of feedback, which was all
fed back to the country office. Some couldn’t
be taken into account, but most could. Text
was also added to the images in the different
local languages spoken where GOAL works.
The images were then made into posters anddisplayed wherever possible – at the country
office, in warehouses, in field offices, and so on.

What happened as a result

PSEAH
handbook
at a glance

Next, GOAL’s media officer came up withsome designs and images that he felt matched
the four key points. The images were thentaken out to communities, and were discussedwith a wide group of people – different tribes
and clans, beneficiaries and non-beneficiaries.
At this stage, the designs did not have any
writing on, as the team wanted to see if thecommunities understood the messages thatthe images were trying to convey.

IMPLEMENTING PSEAH REQUIREMENTS WITHPARTNERS, SUPPLIERS AND CONTRACTORSIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

Partners are commonly defined as those organisations
which are contracted to deliver programmes andprojects, or providing funding.
Suppliers are commonly defined as organisations orcompanies that have been contracted to provide goods,
equipment and other supplies that are being used by
the organisation generally, including for the delivery of
programmes and projects.

Plan International is a global international
development and humanitarian organisation
focused on children’s rights and equality forgirls. Plan International has programmes inover 70 countries and works extensively withnational and local partners.

Responding
to reportsof SEAH

33

Developing andimplementing
a complaints
mechanism

32

Plan International is now supporting its
national and local partners to support
smaller civil society organisations (CSOs)
to put minimum (suitable) standards inplace for preventing harm to children. Plan
International helps the national or local
partner to run workshops with the civil society
organisations to raise awareness on theimportance of measures to prevent harm, andto agree on the measures that the civil society
organisations will adopt.

Sexualmisconduct inthe workplace

Plan International’s Safeguarding Policy
outlines minimum standards for engaging
with partners, suppliers and contractors. The
minimum standards require Plan’s offices toassess all partners’ capacity to implement
measures to prevent harm to children. The
assessment informs the overall decision ofwhether or not to work with the partner. The
assessment is based on ten key questions – if
the partner has a policy and code of conduct,

Designing safe
programmes
and projects

What Plan International did

Implementing
requirements withpartners, suppliersand contractors

All agreements made with partners, suppliersand contractors include a clause on preventing
harm to children. As Plan International is
The issuecommitted to safeguarding children generally,
As an organisation focused on children andthe requirements for partners, suppliers
adolescent girls, Plan International has had
and contractors includes informing Plan
policies and procedures in place for preventing
International if any of their staff members
harm (including sexual exploitation and abuse)is being investigated for harm to children,
to children for more than 15 years. The growing
including SEA, regardless of whether they are
scale of Plan International’s partnerships, theworking directly with children through thetypes of organisation partnered with, and thepartnership or not.
use of suppliers and contractors for its work,
The commitments described in the partnershipmeant that Plan International must ensure
contract, informed by the assessment, mightthat these organisations are able to work to
include support to the partner for developing
international standards for child safeguarding,a policy, shared training, linked reporting/which include preventing sexual abuse andcomplaints mechanisms and exchanging
exploitation of children.
outcomes from the monitoring of the measuresfor preventing harm to children.

Engaging
communities andpeople affectedby crisis

Contractors are commonly defined as organisations orcompanies that have been contracted to deliver specificservices, such as construction work.

The programme

how it recruits and inducts staff, the partner’sreporting/complaints mechanisms, how childsafeguarding measures are embedded in its
operations and programme interventions, andits arrangements for monitoring the measuresthat prevent harm. Plan International will
not go ahead with the partnership if they
consider that the organisation presents
a significant risk for children which itis unwilling to address. Increasingly,
however, all organisations with whom Plan
International partners are actively interested
in strengthening their organisational capacity
to prevent harm to children and welcome
support from Plan International to do so.

Ensuring staff
and volunteers
work to PSEAH
requirements

6. Include the organisation/company staff
in staff training events if they are directly
implementing activities or have significant
contact with children, at-risk adults andaffected populations.

– What are the obligations for reporting
concerns or cases which arise
regarding the organisation/company
to your organisation.

Implementing measures toprevent sexual exploitation
and abuse (and other harm)of children with partners,
suppliers and contractors

Assigning
specific
responsibilities
for PSEAH

5. Deliver a short briefing to all organisations/companies on PSEAH.

– Progress with implementing PSEAH
measures to be included in reports
on progress with projects or services(where appropriate)

Learning Example

Developing andimplementing
PSEAH policy
and procedures

4. Decide on the best approach for training
the organisations/companies on PSEAH,
based on the context and resources
available.

7. Agree with organisations/companies how
to exchange information on PSEAH. Thisshould include:

PSEAH
handbook
at a glance

3. Ensure that staff and volunteersof organisations/companies working
directly with children, at-risk adults andaffected populations sign onto a codeof conduct, either yours or that of theorganisation’s/company’s (if it is of an
acceptable standard).

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEAH
handbook
at a glance

DESIGNING SAFE PROGRAMMES AND PROJECTS
Learnings• Resources are required for supporting
partners, suppliers and contractors tohave the necessary measures in place
Costs for preventing harm should be built
into all relevant project and programmebudgets – this is easier to do where thecosts can be included in capacity building
plans for partners (which donors tend
to favour).

2.1. Programmes are designed taking into
account constraints so that the proposed
action is realistic and safe for communities.

Programmes need to take into accountorganisational and contextual constraints sothat the proposed action is safe in relation to
PSEAH for communities.

What should be in place• Potential risks of sexual exploitation, abuseand harassment presented by programmes
and projects are identified and addressed.
• Programme designs respond to or are
adapted to mitigate risks of SEAH.
• Project plans include activities on PSEAH
awareness and sensitivity.
• Budgets include funding lines for capacity
building and communications on PSEAH.

How to do it

3. Identify how the programme/projectmight exacerbate the risk of SEAH – willcertain groups within the community not
be receiving goods and services that puts
them more at risk of exploitation? Does the
programme/project design exacerbate SEAH
risks, for example water points are isolated
or toilets not lit or separated by gender?

Responding
to reportsof SEAH

35

Developing andimplementing
a complaints
mechanism

4. If your programme is operating or ismanaged remotely, consider the specificrisks associated with this. What contact doyour organisation, partners, and associatedpersonnel have with affected populations?
Is it face to face, or online? Consider how
you will monitor in-person contact withaffected populations by partners andassociated personnel, if your organisation
does not have direct oversight of this. If
contact is online, ensure you have specific
PSEAH measures in place for this.

Sexualmisconduct inthe workplace

1. Assess the context in which the programmeis to take place – identify the general risks
and issues related to sexual exploitation,
abuse and harassment in communities
and the different intersecting identities of
those who appear most at risk of sexual
exploitation, abuse and harassment.
Communities, and particular members
within communities, experiencing abuse,
exploitation and harassment are more at
risk of it being perpetrated by staff andassociated personnel, and those contracted
to deliver programmes.

2. Map the patterns of behaviour withinfamilies and communities when designing
programmes and projects – who fetches
water, who manages household income.
These patterns of behavior might makecertain family members with particularintersecting identities more vulnerable
to SEAH, such as adolescent girls whilst
fetching water from remote water points.

Designing safe
programmes
and projects

34

Programmes need to be designed andimplemented based on an assessmentof SEAH risks and understanding of SEAH
vulnerabilities of different groups.

Implementing
requirements withpartners, suppliersand contractors• In countries where the governments havelegislated on SEA or harassment, use thisas a driver for ensuring that partners,
suppliers and contractors have thenecessary measures in place.

1.2. Programmes are appropriately designed
and implemented based on an impartial
assessment of needs and risks and anunderstanding of the vulnerabilities andcapacities of different groups.

Engaging
communities andpeople affectedby crisis• Sharing, and maximising, capacity buildingof partners between organisations would
be valuable e.g. if one organisation isdelivering capacity building interventions
for partners, if possible, extend the invite
to partners of other organisations working
in the same location.

Specific PSEAH Requirement

Ensuring staff
and volunteers
work to PSEAH
requirements• A large number of partners, suppliersand contractors work with more than
one organisation – are the otherorganisations also supporting them on
measures to prevent harm? This is worth
finding out to avoid duplication of effort
and save resources.

CHS Indicator

Assigning
specific
responsibilities
for PSEAH

Plan International’s approach to
implementing these measures with partners,
suppliers and contractors has progressedfrom one based on contractual complianceto an approach which contributes toimproved outcomes for children’s safety
more generally, such as increased awarenessin communities, changes to local laws anda range of organisations with appropriate
policies and procedures. This has arisen fromthe way in which Plan International looks at
the risks involved (not only considering theactual contact that organisations have with
beneficiaries, but also how robust partners
are in developing and implementing
measures to prevent harm generally), andthe investment Plan International has madein building capacity of partners, contractors,
and suppliers (where necessary).

Developing andimplementing
PSEAH policy
and procedures

What happened as a result

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

The programme

The issue

37

Responding
to reportsof SEAH

36

Developing andimplementing
a complaints
mechanism

In Lebanon, GWI partnered with CARE
International. Together they undertook

Participatory action research is a methodthat proactively acknowleges and addresses
power imbalance between the affected
population and researchers/humanitarians.
It enables people to take an active role inasking and answering questions about theirown lives.

Sexualmisconduct inthe workplace

For this phase of the project, GWI undertook
research in Lebanon and Uganda.

In Uganda, GWI partnered with IRC. Here, they
undertook participatory action research witha group of 29 South Sudanese refugee womenin refugee settlements in northern Uganda. As
with Lebanon, they also undertook interviews
and focus group discussions with the wider
community. In Uganda, the research focusedon increased risk of SEA for women and girls in
food, fuel and firewood, shelter and WASH aid
delivery processes.

Designing safe
programmes
and projects

What GWI did

participatory action research with a coregroup of 26 Syrian refugee women and girls
in northern Lebanon. They also undertook
interviews and focus group discussions
with the wider community. The research
focused on how food, cash, shelter and water,
sanitation and hygiene (WASH) aid delivery
processes may increase risk of SEA for refugee
women and girls.

Implementing
requirements withpartners, suppliersand contractors

While existing SEA response mechanisms
are important in creating accountability inthe humanitarian sector, much of the focus
on addressing SEA has been on reporting
mechanisms and actions against perpetrators.
More focus needs to be been given to
pro-active measures to prevent abuse andexploitation from occurring in the first place.
There has been little examination of theprocesses through which humanitarian aid
is delivered and how these processes might
increase the risks of SEA. GWI believe that
more consideration is needed to create aid
delivery models that actively work to reduce
power imbalance, and give women and girls asustained voice in how aid is delivered.

A risk mapping of a distribution site in Lebanon
created by women and girls © The Global Women’s
Institute at the George Washington University.

Engaging
communities andpeople affectedby crisis

Empowered Aid is a multi-year, multi-country
participatory action research project led by the
Global Women’s Institute (GWI), part of the
George Washington University. The research
examines the mechanisms through whichhumanitarian aid is delivered, and how theseprocesses might inadvertently increase the risksof SEA within affected populations, in order toaddress them. Its goal is to support the creation
or adaptation of aid delivery models that actively
work to reduce power disparities and give
women and girls—as those most affected by SEA
and other forms of gender-based violence—asustained voice in how aid is delivered.

Ensuring staff
and volunteers
work to PSEAH
requirements

10. Identify and document existing local andnational child protection mechanisms andrelated support services for referral.

Participatory research
to better prevent sexual
exploitation and abuse

Assigning
specific
responsibilities
for PSEAH

7. Incorporate awareness raising andcommunications on PSEAH into
programme/project activities.

9. Adapt, or redesign, any programme/projectthat is presenting a risk of SEAH.

Learning Example

Developing andimplementing
PSEAH policy
and procedures

6. Design programmes/projects to addressrisks identified, and ensure the mitigation
measures work across different groups;
include costs for prevention, awarenessraising, training on SEAH and response
in programme/project budgets.

8. Monitor, with the communities you areworking with, whether the programme/
project is safe – ask specific questions
about whether harm or abuse has arisen
because of the delivery of goods andservices, whether that has been reported,
and what would help to prevent thisarising in future. Conduct the monitoringwith community members with different
intersecting identities. Do not rely only on
those with power within communities tofeed back that the programme is safe.

PSEAH
handbook
at a glance

5. For online programme activities, assess
all the ways in which contact takes place.
Is it one-on-one contact (for example formonitoring surveys), as part of a group(for example community consultations,focus group discussions), or on social
media platforms (for example connecting
people around an advocacy campaign?)
Any online contact should have PSEAH
measures in place to the same level asin person contact.

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEAH
handbook
at a glance

The research found that SEA by aid and non-aid
actors was pervasive in all types of aid explored.
Distribution mechanisms were failing to create
an environment in which women and girls wereactively protected from SEA.

•

SEA was most frequently mentioned inrelation to interactions at the point of
distribution; and also mentioned acrossall other points of the distribution cycle
including transporting items home,findingout about aid, during registration/verification exercises, and safely storing ormaintaining aid.

•

SEA was mentioned in relation to all pointsof the distribution cycle, including: findingout about aid, registration/verification, atthe point of distribution (which received
the most mentions), traveling to/from
distribution sites (especially when carrying
heavy or bulky aid, such as food, home),
and safely storing aid.

•

Women and girls were acknowledged
as those most vulnerable to SEA by allparticipants. Adolescent girls— especiallythose without parents—and widows werenoted as especially at risk.1

Recommendations• Aid distribution systems must be
adapted to more fully meet womenand girls’ needs for shelter materials,
cash assistance, WASH and food items
in ways that minimize opportunities for
exploitation and abuse by aid as well as
non-aid actors. The most important way
to do that is to ensure women & girls arepart of program design.
• Increase access to GBV services—suchas healthcare, psychosocial support,
and case management—while ensuring
access to such services is not contingent
on reporting specific instances of abuse,in recognition of the powerful deterrent
this can be.

Implementing
requirements withpartners, suppliersand contractors• Recognize women and girls as experts
in contextual safeguarding and actively
engage them in mechanisms designed
to improve aid processes and protect
against SEA.
• Specifically, senior management
and safeguarding leads must takeresponsibility to reflect on theirorganization’s role in creating a‘conducive context’ for abuse.

Sexualmisconduct inthe workplace

Women discuss a community risk map they havecreated in Uganda © The Global Women’s Instituteat the George Washington University.

Designing safe
programmes
and projects

Women and girls were acknowledged
as those most vulnerable to SEA by allparticipants. Adolescent girls— especiallythose without parents—and widows
were noted as especially at risk, as well as
women and girls who are a family provider
or caretaker (head of household) and those
who lack income (either themselves orfrom a spouse)•

Engaging
communities andpeople affectedby crisis

SEA and GBV was most noted in relation to
shelter aid and cash distributions, followed
by WASH and food.

SEA was most noted in relation to food
distributions, followed by shelter; whileother forms of GBV were most frequently
described in relation to accessing WASH
(water points, latrines, sanitary materials)
and fuel and firewood.

Ensuring staff
and volunteers
work to PSEAH
requirements••

Recommendations emerging from this research
are listed below. The next phase of the projectwill put this information to use in demonstrating
how contextual safeguarding approaches canbe applied to aid distribution systems, and will
include producing a ‘toolkit’ of resources thatcan be further adapted to fit other contexts.

Assigning
specific
responsibilities
for PSEAHIn Lebanon, the following key takeaways wereidentified:

Although the context was different, the key
takeaways from Uganda were similar:

Developing andimplementing
PSEAH policy
and procedures

What happened as a result

Developing andimplementing
a complaints
mechanism

39

Responding
to reportsof SEAH

38

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

8.9. Policies are in place for the security andwellbeing of staff.

The organisation needs to have policies inplace for the safeguarding of staff to protect
them from sexual exploitation, abuse andharassment, and retaliation, including a
Whistleblower Protection policy.

What should be in place

3. Develop leadership behaviours which are
explicit on fostering and maintaining anorganisational culture which prevents andresponds effectively to sexual misconduct
in the workplace. See Assigning SpecificResponsibilities for PSEAH.

How to do it

41

Responding
to reportsof SEAH

40

Developing andimplementing
a complaints
mechanism

1. Be explicit on how the organisation’svalues contribute to creating anorganisational culture which preventsand responds to sexual misconduct inthe workplace. See Assigning SpecificResponsibilities for PSEAH.

5. Ensure that accessible mechanisms are inplace to allow staff to safely, confidently andconfidentially report sexual misconduct. Thisshould include a Speak Up mechanism anda Whistleblower Protection policy.

Sexualmisconduct inthe workplace• Formal and informal opportunities to
speak up on sexual misconduct which
include reporting to managers, focal points
or other trusted representatives within
the workplace.

– Ensure a Whistleblower Protection
policy is in place. See Developing
and implementing PSEAH policies
and Procedures.

Designing safe
programmes
and projects• Procedures which describe how the policy isimplemented throughout the organisation.

4. Ensure relevant policies include definitionsof types of workplace misconduct, including
sexual misconduct, and be clear on what is
unacceptable. Sexual misconduct includes
sexual harassment, but also other types of
misconduct such as sexual exploitation andsexual assault, as well as accessing and/or
sending images of abuse through laptops,
mobile phones, etc.

– Communicate with staff so thatthey understand how they can raise
a complaint or make a report, andwhat these can cover

Implementing
requirements withpartners, suppliersand contractors• A PSEAH policy or policies which prevent
different forms of workplace sexual
misconduct, that describe prohibited
behaviours in the workplace (linked whereappropriate to discrimination and protectedcharacteristics e.g. ethnicity, disability) andoutlines the organisation’s commitment topreventing and responding to workplacesexual harassment.

– Ensure that staff members
understand the rationale for thereporting mechanisms introduced,
the importance of maintaining
confidentiality if they receive
disclosures, and that those withspecific responsibilities canreceive and deal with complaints
and reports confidently

Engaging
communities andpeople affectedby crisis

2. Develop a diversity and inclusion strategy
which articulates how the organisation is
encouraging diversity, recognising power
and privilege and working towards a saferorganisation for all different groups of staff
and associated personnel.

– Ensure that the mechanism canmanage complaints and reports in aconfidential and timely manner which
ensures the safety of all involved

Ensuring staff
and volunteers
work to PSEAH
requirements• Clear commitments to an organisational
culture that recognises issues of gender,
power and privilege, encourages diversity
and speaking up. These commitments
are often best articulated through theorganisation’s values.

– Consult with different groups of staff
on proposed channels for reporting
workplace sexual misconduct

Assigning
specific
responsibilities
for PSEAH

Specific PSEAH Requirement– Get senior management support forthe mechanism from the start

6. Create ‘safe spaces’ for different groupsof staff to discuss issues that affect them,for example women’s groups (for older
and younger female staff), groups of staff
identifying as LGBTQ+, groups of staff fromdifferent communities. These can bein-person or online.

Developing andimplementing
PSEAH policy
and procedures

CHS Indicator

Here are some key considerations fordeveloping a Speak Up mechanism:

PSEAH
handbook
at a glance

SEXUAL MISCONDUCT IN THE WORKPLACEIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEAH
handbook
at a glance

Learning Example

The programme

ActionAid brought in an expert in Feminist
Leadership to guide them through theprocess. A staff member in senior leadershipwas charged to take the work forward. The
organisation realised it needed to identify
some ‘guiding stars’ – an articulation of whatkind of behaviours it wanted to see in its staff.
Hence the Feminist Leadership Priniciples
were born. They are:1. Self-awareness9. Courage
Taking initiative, learning from mistakes andnot fearing failure.
10. Zero tolerance
Calling out any form of discrimination andabuse of power and ensuring our own
conduct is free from any kind of harassmentand exploitation.

Back in 2004, ActionAid started addressing
the challenges that women were facing in theorganisation. Spaces were created to identify
what the issuues were and the best approachfor dealing with them.

Checking our own and institutional privilege
and power based on advantages we havesuch as gender, class, race, ability and otherfactors.
4. Inclusion

What happened as a result

Through a series of conversations over time,
ActionAid realised that in order to address
the issues facing women in the workplace,it needed to really examine how power andleadership worked within the organisaion.

Building diverse teams and responding todifferent barriers to participation.

The roll-out was not without its challenges.
Feminism as a term was resisted by somestaff, both male and female. The organisation
also had to challenge its assumptions onwhat difficulties people were facing in theorganisation – the dynamics were not justmale to female.

6. Responsible and transparent use of power
Being clear, timely and transparent in making
decisions.
7. Accountable collaboration
Ensuring collective goals are clearly definedand mutually owned. Holding ourselves andothers accountable for achieving them.

• The journey varies from office to office. It
is not an overnight process, but a series of
conversations over time.

To address this, safe spaces were provided for
discussion on what it was that ActionAid wasdoing, and why. These discussions gave staff
a chance to talk through their concerns in an
open and honest way.
Now, the Feminist Leadership Principles are
known across the whole organisation, andare a ‘common language’ in all 45 countries
where ActionAid works. They make it clear
to staff what is expected of them in terms of
43

Responding
to reportsof SEAH

42

Creating a space for others to lead.

• However – it can’t be just one team that
implements it. It has to be taken up by
the whole organisation.

Developing andimplementing
a complaints
mechanism

Feminist leadership came after numerous
conversations looking for the best approachto deal with women’s rights issues in theorganization and eventually to deal with theissues of power that had been identified.
Feminist Leadership became a natural choice.
It took a lot of conversations to get buy-in
because of the label “feminist”, but eventuallywith persistence and courage under thefounder’s belt, the principles were arrived at.

5. Sharing power• Feminist Leadership should be housed ina team that has access to all aspects of
the organisation.

Sexualmisconduct inthe workplace

3. Dismantling bias

• Feminist Leadership Principles are not justfor larger NGOs! In fact it can be easierin smaller NGOs. It does not requireresources – as long as there is leadershipfrom the top and the organisation is able
to have a critical mass of champions intheir staff to support it, it can be achieved.

Designing safe
programmes
and projects

The issue

Learnings

Implementing
requirements withpartners, suppliersand contractors

ActionAid decided that implementation of
the Feminist Leadership Principles needed tobe housed somewhere where it made sense.
They decided on the Human Resources andOrganisational Development department,
as this department worked across the wholeorganisation. Although leadership on the rollout came from the top, ActionAid decided tofocus on individuals – how they could change
their behaiviour to achieve a critical mass ofchange in the organisation.

That’s not to say it is easy. ActionAid works inmany different locations with their own culturesand political environments, and there is a long
way to go to embed and internalise the Principles.
But now that everyone knows them, it becomeseasier to indentify negative behaviour.

Engaging
communities andpeople affectedby crisis

ActionAid’s work falls into four broad areas:
women, politics and economics, land and climate, 2. Self-care and caring for othersand emergencies. They have a particular focus
Taking care of our own emotional and physicalon women’s rights, which is a thread that runs
well-being and encouraging and supporting
through all their work.
others to do the same.

Seeking, giving and valuing constructive
feedback as an opportunity for two-way
learning.

conduct – and they are everyone’s business.
They give people an opportunity to call out
the conduct of others and say ‘that’s not how
we do things’.

Ensuring staff
and volunteers
work to PSEAH
requirements

Working towards accepting our vulnerabilities,
as well as recognising and valuing our own
strengths and those of others.

8. Respectful feedback

Assigning
specific
responsibilities
for PSEAH

ActionAid is a global federation working for aworld free from poverty and injustice. They workwith people living in poverty and exclusion, civilsociety organisations, social movements andsupporters. They deliver grassroots programmes,
provide emergency relief and campaign for things
such as women’s economic rights, tax justice andclimate justice.

What ActionAid did

Developing andimplementing
PSEAH policy
and procedures

Feminist Leadership
Principles

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOKSpecific PSEAH Requirement

The organisation needs to have a documented
complaints-handling and investigations
process that addresses SEAH, is victim/
survivor-centred, and sets out mandatory
reporting obligations relating to SEAH.

What should be in place

How to do it• A confidential, victim/survivor-centred
report handling protocol.

1. If your organisation does not already havea CBCM (Community-Based Complaints
Mechanism) in place, you will need todevelop one. Resources are widely available
to help you to develop a CBCM, and set up
a safe, confidential, secure and accessible
mechanisms which work for different
groups within communities.

• Designated, trained staff with responsibility
for receiving and managing reports.

• A referral process for reports which do not
fall within the scope of the CBCM.

45

Responding
to reportsof SEAH

44

2. Define the purpose and scope of yourmechanism. Will it receive all types ofcomplaints and feedback, or just reportsof SEAH? Will it be part of a Joint InterAgency CBCM?

Developing andimplementing
a complaints
mechanism• Appropriate, accessible and confidential
reporting channels that have been designed
in consultation with the community,
including channels that are designed toproactively enable reports of SEAH.

Sexualmisconduct inthe workplace

5.4. The complaints-handling process forcommunities and people affected by crisis is
documented and in place. The process covers
programming, sexual exploitation and abuse,and other abuses of power.

Designing safe
programmes
and projects

Complaints handling mechanism needs towelcome and accept reports relating to
SEAH, and communities need to know how
and what to report.

Implementing
requirements withpartners, suppliersand contractors

5.2. Complaints are welcomed and accepted,
and it is communicated how the mechanism
can be accessed and the scope of issues it canaddressEngaging
communities andpeople affectedby crisis

Communities and affected people need
to be consulted on how the complaints
handling process will accommodate SEAH

Ensuring staff
and volunteers
work to PSEAH
requirements

5.1. Communities and people affectedby crisis are consulted on the a. design,b. implementation, and c. monitoring ofcomplaints handling processes.

Assigning
specific
responsibilities
for PSEAH

3.6. Programmes identify and act upon
Programmes need to identify and act upon
potential or actual unintended negative
potential or actual unintended negative
effects in a timely and systematic manner,
effects relating to SEAH.
including in the areas of people’s safety,
security, dignity and rights, sexual exploitation
and abuse by staff and others delivering
assistance, culture, gender, social and political
relationships, livelihoods, the local economy,
and the environment.

Developing andimplementing
PSEAH policy
and procedures

CHS Indicator

themselves, and that they must not discuss
Organisations are increasingly developing
the report with anyone else outside of thejoint Inter-Agency CBCMs, some focusing
reporting chain. They must also understandon SEAH. Find out if there is a joint Intertheir own responsibility to report any
Agency CBCMs in your area of operation,
concerns they might have regarding
and consider whether you would like tocolleagues or partners and SEAH.
participate. Participating in a joint complaints
mechanism will usually mean agreeing to
6. Once the internal reports handlingcommon standards and procedures for
protocols are in place, develop yourdealing with SEAH for all members.
reporting channels for the community.
Consult with communities on what existing
3. If not in place already, ensure you havestructures they have for reporting concerns,
an internal protocol for receiving reports
and how they would like to report toof SEAH which is confidential and victim/
the organisation. Ensure that different
survivor-centred (i.e. prioritises the wishes,groups in the community are consulted,
safety, and well-being of the victim/
including people of different genders,survivor). Assign staff responsibilities forages, those living with disability, or any
reports handling, such as: who will haveother contextually relevant or potentially
immediate responsibility for reports as theymarginalised groups.
come into the organisation, how they will
be assessed for follow up, and who they
7. Have more than one reporting channel forwill then be referred to on what basis.
your CBCM. Possible channels could include
See Responding to Reports of SEAH.
SMS, email, letter, telephone hotline,
information desk, or face-to-face meeting,
4. Ensure your internal protocol foramongst others – depending on what is
responding to reports includes what to do
identified by your community consultation.
with reports that are outside the scope of
the CBCM, for example:
Consider how safe and confidential thesechannels will be for someone reporting– Reports relating to other organisations.
SEAH, the power dynamics and risk of
How will these be referred?
retaliation, literacy levels and language– Reports relating to SEAH not caused bybarriers, access to phone data, how
the organisation’s staff or programmes.
confident they would be to use them.
Ensure a referral mapping is in place –8. Communicate with communities so
see belowthat they understand how they can raise– Reports that allege criminal incidents.
a complaint or make a report, and what
The organisation will need tothese can cover.
determine on a case-by-case basis
9. SEAH is by its nature a sensitive issue.
whether referral to the authorities is
Consider carefully whether you havesafe and appropriate for all concerned,
developed communication channels thatwith the best interests of victim/
proactively enable reports about SEAH.
survivors as a priority.
When consulting the community or staff
5. Raise staff awareness on the protocols. For
about your reporting mechanisms for SEAH,
staff with specific roles, ensure training
be sure to consult diverse groups on how
is provided. For all staff, be clear thatthey might feel comfortable in reporting
any reports they receive on SEAH should
SEAH. Look also at how you can use existing
be referred directly to a named senioractivities to pick up concerns regarding
manager within the organisation. Staff
SEAH – such as trainings on SEAH, work
should understand the importance ofwith women’s groups, or outreach work on
following this procedure. They should be
gender-based violence.
clear that they must not try to investigate

PSEAH
handbook
at a glance

DEVELOPING AND IMPLEMENTING
A COMMUNITY-BASED COMPLAINTS MECHANISM

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOKPSEA complaints
mechanisms on theThai-Burma border

What CCSDPT did

The programme• The channels through which reports might
be received– Do the mechanisms put users atfurther risk?

The issue• Procedures for investigating reports of SEA• How to refer reports made about anothernetwork member• Support to victims/survivors of SEA• Establishing a steering committee to ensure
reports were being dealt with according to
the protocol.

Implementing
requirements withpartners, suppliersand contractors
Designing safe
programmes
and projects

11. When you open up the possibility of
SEAH reports, it is absolutely vital thatyou follow them up. Raising concerns of
SEAH can be distressing for the person
reporting, and we have a responsibility
to take it seriously. Not following upsuch serious concerns could lead toa breakdown of trust between yourorganisation and staff or the community
who have raised the concerns. See
Responding to reports of SEAH.

CCSDPT wanted to provide an environment
where refugees, particularly those mostvulnerable in their communities, knew they
were able to access services free from abuseand exploitation.

• Clear guidance on management
responsibilities for dealing with reports once
they were received

Engaging
communities andpeople affectedby crisis– Are reports of SEAH, being followed
up appropriately within yourorganisation?

• Assigning Focal Points to deal with and referincoming reports

Ensuring staff
and volunteers
work to PSEAH
requirements– Are the mechanisms appropriate forstaff and communities? Do both staff
and the community feel comfortableusing it?

The Committee for the Co-ordination ofServices to Displaced Persons in Thailand(CCSPDT) is a network of NGOs andcommunity-based organisations working
with displaced people in camps along theThai-Burma border.

First of all, CCSDPT developed an inter-agency
protocol for dealing with reports of SEA. The
protocol included:

Assigning
specific
responsibilities
for PSEAH– Who is making reports e.g. are certain
groups of staff reporting more thanothers?

Learning Example

Developing andimplementing
PSEAH policy
and procedures– Are the mechanisms receiving
reports? What kind of reports are theyreceiving? If your channels are notpicking up reports of SEAH, explore thepossible reasons for thisPSEAH
handbook
at a glance

10. Monitor and review your mechanisms forenabling SEAH reports on an ongoing basis
to check:

Sexualmisconduct inthe workplace
Developing andimplementing
a complaints
mechanism

CCSDPT member agency staff at work
47

Responding
to reportsof SEAH

46

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEAH
handbook
at a glance

RESPONDING TO REPORTS OF SEAH
What happened as a result

From the Compendium of Practices on
Community-Based Complaints Mechanisms,
IASC, 2012.

• Consider different community languages
and customs from the start.
• Consider how to ensure the momentum
on PSEA is maintained once dedicatedresources are no longer available.

The organisation needs to have systems inplace to safeguard personal information
relating to SEAH incidents that could put
affected people at risk.
Complaints or reports relating to SEAH need
to be managed in a timely, fair, appropriate
and safe manner.
The organisation needs to have a documented
complaints-handling and investigations
process that addresses SEAH, is victim/
survivor-centred, and sets out mandatory
reporting obligations relating to SEAH.
The organisation needs to have anorganisational culture that takes SEAH
complaints seriously and acts upon themaccording to its PSEAH Policy and processes.
The organisation needs to refer SEAH
complaints/reports that do not fall within thescope of the organisation to a relevant party
in a manner consistent with good practice.
Serious misconduct needs to be taken
seriously and acted upon

• A mapping of referral pathways forvictims/survivors of SEAH.

48• Substantiated complaints result in consistentdisciplinary action.

49

Responding
to reportsof SEAH• Investigations are undertaken in line withthe relevant standards and guidance.

• Investigations are undertaken byexperienced and qualified professionals,
who are trained on sensitive investigations
such as allegations of SEAH.

Developing andimplementing
a complaints
mechanism• Written procedures on responding
to reports or concerns relating to SEAH,
which are victim/survivor-centred andensure confidentiality.

Sexualmisconduct inthe workplace

What should be in place

Designing safe
programmes
and projects

Awareness raising was then conducted
through community-based organisation
representatives. This included PSEA messaging
in local language on caps and bags, andthrough theatre and radio broadcasts.

Programmes need to identify and act upon
potential or actual unintended negative
effects relating to SEAH.

Implementing
requirements withpartners, suppliersand contractors

The CCSDPT Protocols• Consult with vulnerable groups, such as
new arrivals to the camp, single womenand children on reporting mechanisms.

3.6. Programmes identify and act upon
potential or actual unintended negative
effects in a timely and systematic manner,
including in the areas of people’s safety,
security, dignity and rights, sexual exploitation
and abuse by staff culture, gender, social andpolitical relationships, livelihoods, the local
economy, and the environment.
3.8. Systems are in place to safeguard
any personal information collected from
communities and people affected by crisis
that could put them at risk.
5.3. Complaints are managed in a timely, fair
and appropriate manner. Complaints handlingmechanisms prioritises the safety of thecomplainant and those affected at all stages.
5.4. The complaints-handling process forcommunities and people affected by crisis is
documented and in place. The process covers
programming, sexual exploitation and abuse,and other abuses of power.
5.5. An organisational culture in which
complaints are taken seriously and acted
upon according to defined policies andprocesses has been established.
5.7. Complaints that do not fall within thescope of the organisation are referred to arelevant party in a manner consistent withgood practice.
9.5. The risk of corruption is managed, andappropriate action is taken when corruption
cases are identified.

Engaging
communities andpeople affectedby crisis• Consult with beneficiaries and CBOs on
your complaints mechanism from thedesign stage onwards, otherwise it canaffect use and sustainability.

Specific PSEAH Requirement

Ensuring staff
and volunteers
work to PSEAH
requirements

Learnings

CHS Indicator

Assigning
specific
responsibilities
for PSEAH

Cases of SEA began to be reported to
CCSDPT, and were dealt with according to theprotocol. Three years after the mechanisms
were introduced, an assessment found thatthe community perceived that SEA had
significantly reduced.

Developing andimplementing
PSEAH policy
and procedures

Member agencies then implemented
a widespread roll-out of PSEA measures
to the camps. Entry points for reports
were designed, including through existing
structures such as community-basedorganisations, the sexual and gender-based
violence committees, complaints boxes,
or reporting directly to the agency.

Introduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

5. If an investigation is required, it is advisedthat it is undertaken by experienced andqualified professionals, who are trained onsensitive investigations such as allegationsof SEAH. If there is no-one within yourorganisation with these qualifications andtraining, you should consider accessing
external resources to help you. Contact
CHS Alliance for further information.

Trócaire put the following procedures in place
for responding to complaints and reports of SEA:
All safeguarding complaints arising in country
programmes are referred to the Safeguarding
Case Management Committee. Members of
Safeguarding Case Management Committee(SCMC) are Head of Region/Unit, Country
Director (overseas cases) and the Head ofSafeguarding.
The Safeguarding Case Management Committee
conduct an initial review of the case and makerecommendations for next steps. Considerations
are based on who is the alleged Subject of theComplaint in the first instance:
a. Trócaire staff or representative (Trócaire’s
policies apply)
b. Partner staff (Partnership Agreement
applies)c. Other organisations (other arrangements
may / may not apply e.g. consortia)

Responding
to reportsof SEAH

51

Developing andimplementing
a complaints
mechanism

The Safeguarding Case Management
Committee advise the Leadership Committee(Chief Executive Officer and Divisional Director)
that a complaint has been received, the initialassessment and proposed next steps.

Sexualmisconduct inthe workplace

50

Trócaire does not tolerate exploitative or
abusive behaviour by anyone associatedwith the implementation of Trócaire’s
work. Trócaire also requires that partnerorganisations share their safeguarding
commitment and have in place policies andsystems to both prevent and respond toabuse and exploitation by their organisational
representatives.

What Trócaire did

Designing safe
programmes
and projects

4. Even if there is not sufficient information tofollow up on a report or concern, it should
be recorded anyway. It may be useful in
identifying a pattern of harm.

Trócaire’s Vision, Mission and Values statethat they believe in the intrinsic dignity of
every person, celebrate difference and aim
to create relationships of mutual respect
wherein the rights and dignity of every person
are respected. Trócaire’s work is inspired
and informed by Catholic Social Teaching,
one of the fundamental principles of whichis the dignity of each individual. The right tofreedom from all forms of exploitation andabuse is implicit in this principle. Underpinned
by Trócaire’s organisational value ofaccountability, it is their policy to safeguard all
individuals involved in Trócaire’s work against
risks of exploitation and abuse.

As Trócaire works in partnership it was
important that their mechanisms not only
cater for complaints relating to Trócaire but
also those relating to partners they work with.

Implementing
requirements withpartners, suppliersand contractors

Your funder, and some statutory bodies may
require that they are informed of reportsof SEAH that come into your organisation.
Check your funder and legal requirements.

Trócaire is the overseas humanitarian anddevelopment agency of the Catholic Church
in Ireland. Trócaire works with local partnerorganisations in over 20 countries. Since
1973, Trócaire has been challenging injusticeand providing support to people living with its
effects.

Trócaire believes that it is important to create
safe environments, to reduce the potential
for things to go wrong. However, when
there is a complaint, it is important thatthe organisation’s response is appropriate,
professional and limits any further possible
stress or impact. Mechanisms and aproaches
need to be developed to achieve this.

Engaging
communities andpeople affectedby crisis

You should have a contact list ready forwhen an incident occurs, so you can access 6. A case of SEAH can have an impact on
staff morale. By the time a report is made,support for the victim/survivor (if they are
there might already have been months
under 18 years old), or if the victim/survivorof rumours and concerns circulating
is an adult, support them to make decisions
in the affected office, and in the wider
on which services to access should they
community. Staff may then feel excluded
want to.
by the investigation, as confidentiality
3. When your organisation receives a report,
requirements mean they can know nothingor hears of a concern about SEAH, it should
about it. They may feel let down by thebe handled immediately through yourconclusion. The organisation may wellreport handling procedures. Regardless of
have to invest time in restoring staff andwhat the outcome of the report or concern
community morale, by listening to theirmight be, the first priority is always theconcerns and reassuring them that due
safety and well-being of the victim/survivor.
process has been undertaken, whilst
Support should be provided immediately
explaining why some aspects of the casewhen a concern is raised – and for as longneed to remain confidential.
as the victim/survivor requires it.

The programme

The issue

Ensuring staff
and volunteers
work to PSEAH
requirements

It is extremely important that reports
relating to SEAH are investigated properly.
If you do not follow due process, it canmake it harder for you to discipline or
dismiss a staff member. Staff members who
have been the subject of concerns may
move on to work for other organisations
without the issue having been addressed.
Staff members who are the subject of anallegation are entitled to a fair process todetermine what actually happened, rather
than being subject to gossip and rumours.

Developing SEA casemanagement practices
in Trócaire

Assigning
specific
responsibilities
for PSEAH

2. Undertake a mapping of reporting andreferral pathways. This means identifying
the formal authorities to whom reports
should be made if the incident is criminal
in nature, as well as formal and informal
support services available in your areafor victims/survivors of SEAH. You should
assess all of these pathways to ensure they
are safe, accessible and relevant. If there
are other organisations working on PSEAH,
gender and GBV issues in your area, check
whether mappings have already been
undertaken, or explore opportunities forjoint mapping.

Learning Example

Developing andimplementing
PSEAH policy
and procedures

1. Make sure your organisation has
confidential, victim/survivor-centred
policies and procedures in place forresponding to reports or concerns relating
to SEAH. There are templates and resources
available to help you with this.

PSEAH
handbook
at a glance

How to do itIntroduction

Glossary

Contents

CHS ALLIANCE / PSEAH IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEAH
handbook
at a glance

For complaints relating to a Trócaire staff
member a representative from the Human
Resources Department joins the Safeguarding
Case Management Committee.
•

While it is important to have accessible
and safe channels in place for people toraise concerns; safeguarding concerns
can emerge via other means – e.g. talking
to a trusted person, during training as
participants reflect on safeguarding or
during monitoring visits.
• No two cases are the same but being
prepared is essential
Every case is different. This can dependon the nature of the complaint, whoreports it, the local context and otherfactors. However, having systems in place
to respond to cases with clear decisionmaking processes as well as advanceknowledge of the context is critical.
• The need to continue to review, learn andupdate practiceDesigning safe
programmes
and projects

Trócaire can never say that their work in
relation to safeguarding is done. There isalways learning from implementation andin keeping up to date with best practicewithin and beyond our sector. Trócairecontinue to strive to ensure that oursafeguarding policies and practices are
relevant.

Implementing
requirements withpartners, suppliersand contractors
Sexualmisconduct inthe workplace
Developing andimplementing
a complaints
mechanism

In addition to case management procedures,
Trócaire has the following processes in place:• Confidentiality for all involved in
the investigation process – includes
confidentiality agreements forinvestigators.
• Guidelines for support to survivors
involved in a safeguarding concern –considerations for a survivor centred
approach as well as considerations forothers involved in the process.
• Filing, storage and retention ofsafeguarding case records – includes
secure restricted access filing system andprotocols for sharing information.

• Not all complaints come via establishedcomplaints mechanisms

Engaging
communities andpeople affectedby crisis•

Where Trócaire receives a complaint directly
about a partner staff the initial assessment
will consider the following:a. Why was the complaint forwarded toTrócaire and not the partner?
b. Are there protection concerns?
c. Does the partner have robust systems
in place consistent with managing thecomplaint themselves?
d. Does the partner require support inorder to manage this complaint?
e. Should Trócaire request an external
investigation or oversight?

Learnings

Ensuring staff
and volunteers
work to PSEAH
requirements•

Trócaire Partnership Agreements include
a requirement for partners to inform
Trócaire of Safeguarding allegations. When
this occurs Trócaire will require partners
to complete ‘Template for Reporting a
Safeguarding Concern’. Trócaire will review
this document and seek clarification to ensurethat appropriate steps were taken. Trócaire
offer support if appropriate (e.g. managing
investigation, lessons learnt sessions).

Assigning
specific
responsibilities
for PSEAH•

Investigations conducted by Trócaire
are informed by CHS Alliance Guidelines
for Investigations. It is our preference
to have an external investigator either
fully conduct the investigation or be partof the investigation. Trócaire will only
conduct the investigation in instanceswhere it is not possible to engage asuitably qualified investigator (none
immediately available, access or security
issues in country).
When investigations are complete a
disciplinary process may be instigated inline with Trócaire’s policies.
Findings are reviewed to assess if otheractions are required (e.g. review ofpolicies, practices, training etc)
A lessons learnt session is conductedby the Safeguarding Case Management
Committee.

Partners

Developing andimplementing
PSEAH policy
and procedures

In all instances SCMC will consider:•
If there is sufficient evidence to form
a complaint or if further informationis required? Steps to gathering further
information are considered to ensurethat any action does not jeopardisea potential investigation or present a
protection risk for anyone concerned.
•
Does the complaint allege a criminal
offence? Understanding the local context
is essential for decision making. Each
Trócaire office has in place a ‘Context
Mapping Document’ which outlines key
legislation on child protection, assault
and employment rights, reality of
implementation of this legislation andin-country support networks. Using thisas a reference the SCMC can make an
informed decision of whether:a. There is a possible criminal offence &when Trócaire are required to reportb. Risks and protection concernsc. Support networks to refer parties to

Safeguarding week in Myanmar © Trocaire
53

Responding
to reportsof SEAH

52

www.chsalliance.org