VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR

VICTIM/SURVIVOR-CENTREDAPPROACH TO PROTECTIONFROM SEXUAL EXPLOITATION,
ABUSE AND HARASSMENT
IN THE AID SECTOR
FOUNDATIONAL PAPER

CHS ALLIANCE

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORACKNOWLEDGEMENTS
This foundational paper has been developed in the context of a project focusing on Closing
the Accountability Gap to Better Protect Victims/Survivors of SEAH in the Aid Sector,
supported by the Dutch Ministry of Foreign Affairs.

With special thanks to colleagues at The Organisation for Economic Co-operation andDevelopment (OECD), The Safeguarding Resource and Support Hub (RSH), the Dutch
Ministry of Foreign Affairs and colleagues at the CHS Alliance.
Written by: Lucy Heaven Taylor and Martina Brostrom
Design and lay out: GoAgency.co.uk

CHS Alliance
NGO Humanitarian Hub, La Voie-Creuse 16, 1202 Geneva, Switzerland info@chsalliance.org
www.chsalliance.org +41 (0)22 788 16 41.
© All rights reserved. The copyright for this material lies with the CHS Alliance. It may
be reproduced for educational purposes, including training, research and programme
activities, provided that the CHS Alliance is acknowledged and details of such use areprovided to the Alliance prior to use. For elements of this report to be quoted in otherpublications, translated, or adapted for use, prior written permission must be obtained
from the copyright owner by emailing info@chsalliance.org.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORCHS ALLIANCE

CONTENTS
04 ↗

EXECUTIVE SUMMARY

07 ↗

INTRODUCTION

09 ↗

METHODOLOGY

13 ↗

VICTIMISATION TO REDRESS: KEY STAGES
0. VICTIMISATION

15

1. DISCLOSURE

18

2. REPORTING MECHANISMS

25

3.	REPORT HANDLING AND CASE
MANAGEMENT

34

4. REFERRAL TO SUPPORT SERVICES

42

5. INVESTIGATION

46

6. ORGANISATIONAL DECISION-MAKING 52

14 ↗

VICTIM/SURVIVOR-CENTREDAPPROACH: DEFINITIONS

7. REDRESS AND COMPENSATION

60 ↗

CONCLUSION

12 ↗

PURPOSE AND AUDIENCEWHAT THIS PAPER DOES NOT COVER

61 ↗

VICTIM/SURVIVOR-CENTRED
FRAMEWORK

65 ↗

GLOSSARY

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOREXECUTIVE SUMMARY
Sexual exploitation, abuse and harassment(SEAH) are among the most egregious failures ofaccountability in the aid sector. Rooted in genderand power inequality, SEAH is the abuse of powerby aid actors (aid organisation staff and associatedpersonnel) towards the communities they serve.
Since 2018, there has been an increasein the social and political will to tackle
SEAH in the context of humanitarian anddevelopment assistance. During this time,
the concept of victim/survivor-centred
approaches to protection from abuse,
exploitation and harassment (PSEAH)
has emerged as a key priority. Suchan approach may contribute to better
processes and outcomes for victims/
survivors, help overcome barriers, deliveraccountability and rebuild public trust in
the aid system.
The current PSEAH practice that has
emerged from compliance processes hasoften been developed with the needsof the organisation – rather than theperspective of the victim/survivor – as astarting point. And while definitions of a
victim/survivor-centred approach exist in
the sector, there are few articulations ofwhat this might look like in practice.

A multi-year project by the CHS Alliance,
funded by the Dutch Ministry of Foreign
Affairs, listened to victims/survivors of
SEAH in order to design accountability
mechanisms that work for them. The
first phase of this project focused onundertaking a country review, including
participatory action research (seeglossary), which forms the basis of thisfoundational paper.
This paper takes an holistic and innovative
approach, one that is focused on thevictim/survivor’s viewpoint and journey,from violation to redress. From this, it
sets out what a Victim/Survivor-Centred
Framework for addressing SEAH mightlook like in a humanitarian or development
organisation, and how it can be
operationalised by aid actors.

This paper takes anholistic and innovative
approach, one that is
focused on the victim/
survivor’s viewpoint andjourney, from violation
to redress.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORFINDINGSThis foundational paper found that while disclosure canbe a critical pathway to accessing support, protection
and healing for a victim/survivor of SEAH, there are many
barriers to reporting. At the individual level, these barriers
include fear of negative social reactions, fear of not being
believed, fear of losing control and concern that power,
autonomy and opportunity will be taken away after
disclosure. Barriers to reporting were found to intersectwith race, ethnicity, age, sexual orientation, disability, classand gender.
The aid sector has developed numerous
reporting mechanisms to enable andhandle reports of SEAH. Their limitations
include underuse, accessibility, language
barriers and concerns around anonymity
and privacy. Furthermore, thesemechanisms place the responsibility toreport SEAH on communities and victims/
survivors, rather than the organisation,
which has a duty to proactively detectand analyse risk and identify where
power is being abused. Current reporting
mechanisms do not reflect the SEAH
reporting preferences of victims/survivors;
they urgently need to be tailored to thosemost at risk of SEAH and extended toinclude more appropriate modalities forreporting.
A victim/survivor-centred and traumainformed approach (see glossary) requiresorganisations to seek consent fromsurvivors to follow up on SEAH reports.
This is to prevent re-traumatisation, enable
the safety of the victim/survivor anduphold their rights and dignity. However,

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this can conflict with organisations’mandatory reporting requirements, as well
as local laws, which sometimes require
the mandatory reporting to authorities
of some types of SEAH. Furthermore, it
can come into conflict with organisations’accountabilities and responsibilities for
misconduct of their employees, and theirlegal and procedural obligations to act
to prevent potential further harm beingcaused. When victims/survivors do notconsent to reports being followed up, theorganisation must make decisions thatbalance a victim/survivor-centred approachwith their responsibility to prevent andrespond to harm caused by staff andassociated personnel.
Survivors are often left on their own
to navigate and cope with the adverse
cultural, psychosocial, security and legal
consequences that follow disclosureand reporting. This leads to increased
trauma for victims/survivors and further
erodes community trust in the PSEAH
process. Victim/survivor-centred casemanagement requires that actors involved
with victims/survivors of SEAH refrainfrom making assumptions about needs,
and instead respect the voice and choicesof victims/survivors. Victims/survivors
should be accompanied at their own
pace. Key to taking a trauma-informed
approach is being culturally humble andnot limiting support to western notionsof psychotherapy. Lack of locally-available
and appropriate support services canmake it difficult to meet the holistic needsof victims and to provide appropriate
psychosocial, legal and medical support tovictims/survivors.

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There is little or no guidance available on
making management decisions around
SEAH cases. Another challenge lies inliaising with the often-multiple agencies
and entities involved in a case while
ensuring data protection and security.
The outcome is frequently an unsafe,
disjointed experience for the victim/
survivor. Poor and unethical practices inwhich whistleblowers are encouraged
to report SEAH but are then retaliatedagainst when they do, have been
documented across the sector. When
SEAH perpetrations are brushed under
the carpet, victims/survivors’ safety andhealing is compromised and perpetrators
emboldened to commit further harm.
Reparation and redress comprise one of
the least understood and least addressed
areas of PSEAH practice. Reparation
measures for victims of SEAH engaged bysome government agencies and religious
institutions are yet to be realised by theaid sector. Victims/survivors have a right toreparations, and organisations have a legal
and administrative responsibility to deliverand enforce them. However, it is practically
impossible for victims/survivors of SEAH
to exercise this right. Additionally, there
is a lack of integration of local practices
for redress, such as common law andrestorative justice approaches.

There is much scope in the aid sector forlearning how to apply victim/survivorcentred approaches throughout the PSEAH
process, from violation to redress. This
foundational paper has identified, andreferences, a wealth of guidance and goodpractice on various aspects of a victim/
survivor-centred approach, both within
and outside the aid sector. A victim/
survivor-centred approach to PSEAH isnecessarily holistic and demand-driven. It
requires well-coordinated multidisciplinary
teams working closely in the interests ofthe victim/survivor.
The Victim/Survivor-Centred Frameworkin this document builds on existing
multidisciplinary research, good
multisectoral practice and findings fromfield research undertaken in the context
of the Closing the Accountability Gap toBetter Protect Victims/Survivors of SEAH
in the Aid Sector project. It proposes aninnovative approach for how organisations
can be safer for – and more accountable to– victims/survivors of SEAH.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORCHS ALLIANCE

INTRODUCTION
Sexual exploitation, abuse and harassment(SEAH) are among the most egregious failures ofaccountability in the aid sector. Rooted in genderand power inequality, SEAH is the abuse of powerby aid actors (aid organisation staff and associatedpersonnel) towards the communities they serve.
SEAH damages the lives of individuals, erodes theconfidence and trust of affected communities andundermines the collective integrity of theaid sector.

SEAH occurs where vulnerabilities exist,
where the need for aid is acute, where
there is a high presence of aid actors
and where social safety structures
and accountability systems are weakor dysfunctional. SEAH is the complex
outcome of the interplay of sex, power,
privilege and inequality arising from local,
systemic and structural factors.

Originally, the term SEAH was used to referto such abuse and harassment perpetrated
against people in communities being
assisted by aid actors. It is now also used
to refer to workplace sexual exploitation,
abuse and harassment within the aid
sector.1

SEAH is defined as follows:
Sexual abuse – an actual or threatened physical intrusion of a sexual nature, whether by force
or under unequal or coercive conditions.2
Sexual exploitation – any actual or attempted abuse 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 another.3
Sexual harassment – a continuum of unacceptable and unwelcome behaviours and practices ofa sexual nature that may include (among others) sexual suggestions or demands, requests forsexual favours and sexual, verbal or physical conduct or gestures that are or might reasonably
be perceived as offensive or humiliating.4 Sexual harassment has widely been understoodto relate to the workplace, but is also included in the spectrum of behaviours that are notacceptable conduct by staff, be it in the workplace or with affected populations.5

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORSEAH is pervasive within the aid sector,
though insufficient data exists toadequately corroborate the scale of the
problem.57 The ability to monitor SEAH
depends on the accurate and timely
reporting of violations, and data sharing
between aid actors, service providers andother institutions – which is currently notcommon.8
There has long been a consensus that
SEAH has no place in the aid sector
and that all those that work within it,
individually and institutionally, should do
everything in their power to prevent andrespond to SEAH. This commitment isenshrined in standards such as the Core
Humanitarian Standard on Quality andAccountability (CHS)9, specifically the
PSEAH Index, the Inter-Agency Standing
Committee (IASC) Minimum OperatingStandards on Protection from Sexual
Exploitation and Abuse and the OECDDAC Recommendations on Ending Sexual
Exploitation, Abuse and Harassment10(among others).
Since 2018, there has been an increasein the social and political will to tackle
SEAH in the context of humanitarian anddevelopment assistance. During this time,
the concept of victim/survivor-centred
approaches to protection from abuse,
exploitation and harassment (PSEAH)
has emerged as a key priority. Suchan approach may contribute to better
processes and outcomes for victims/
survivors, help overcome barriers, deliveraccountability and rebuild public trust in
the aid system.
Current PSEAH practice largely centres
around reporting, investigation andtaking a decision if a violation has takenplace. Accountability for perpetrators isoften conducted with little to no focus
on accountability for victims/survivors.

Such approaches have grown out oforganisations’ own compliance processes
and are often developed with the needsof the organisation – rather than theperspective of the victim/survivor – as
the starting point. And while there aredefinitions of a victim/survivor-focused
approach in the sector, there are few
articulations of what this might look like inpractice.
The multi-year project, Closing the
Accountability Gap to Better Protect
Victims/Survivors of SEAH in the Aid Sector,
by the CHS Alliance, funded by the Dutch
Ministry of Foreign Affairs, has listened
to victims/survivors of SEAH in order todesign accountability mechanisms thatwork for them. The first phase of thisproject was a participatory action review(PAR), which forms the basis of thisfoundational paper.
This paper takes an holistic and innovative
approach, focused on the victim/
survivor’s viewpoint and journey, fromviolation to redress. From this it setsout what a Victim/Survivor-Centred
Framework for addressing SEAH mightlook like in a humanitarian or development
organisation, and how it can be
operationalised by aid actors.
The resulting Victim/Survivor-Centred
Framework – see below – is intended to be
used as the basis for further consultations
with victims/survivors of SEAH and theirintermediaries in three humanitariansettings. Meanwhile, it is hoped that
this foundational paper will inspire andinform the adaptation of existing PSEAH
principles, policies and procedures acrossthe aid sector so that, collectively, we canbetter serve victims/survivors and become
more accountable to people affected bycrises.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORCHS ALLIANCE

METHODOLOGY
The foundational paper has been informedby different data sources: participatory action
research (PAR) by communities, a multidisciplinary
literature review, consultations with experts andpolicy and guidance documents.

LITERATURE REVIEWIn August 2022, CHS Alliance performed
a limited Google Scholar search on the
topics of interest. The period covered was
2018–2022 and only articles available in
English were considered for inclusion.
Articles included covered sexual abuse andsexual violence, disclosures, complaints,
care, justice, and relevant intervention
from legal, medical, psychosocial, genderbased violence (GBV) and accountability
sectors. This initial search was followedby an analysis of the text words containedin the titles and abstracts of retrieved
papers, and of the index terms (subject
headings) used to describe the articles.
The reference list of identified reports andarticles was also searched for additional
studies.
There is very little published academic
research on SEAH committed by aid
workers. Even when examining a broadcross-section of aid workers that includes
office-based staff, peacekeepers andvolunteers, research is limited andfragmented and there is not enoughmaterial on which to base an approach.

Consequently, the term victim/survivor has
been expanded and generalised to include
those who have experienced SEAH outsideof the aid sector (for instance, when theperpetrator was not an aid worker). This
paper has summarised good practiceas outlined by feminists, criminologists,
police agencies, NGOs/INGOs, healthcare
providers, councillors, social workers,
victim advocates, therapists, educators,
specialist trauma practitioners,
psychiatrists, psychologists and legislators.

POLICY AND GUIDANCE DOCUMENTS
The websites of key IASC members
were searched for guidance and policy
documents on victim/survivor-centred
approaches to PSEA/PSEAH, as well as
those of international non-governmentalorganisations (INGOs). This research
was complemented by key documents
identified by stakeholders that have been
influential in shaping PSEAH work. (Thisfoundational paper highlights a selectionof these; the non-inclusion of a policyor resource is not an indication that it isneither useful nor valuable).

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EXPERT INPUTSCOMMUNITY RESEARCH

Requests were made to more than 200
PSEAH focal points in the CHS Alliance
PSEAH Community of Practice (CoP) for
documentation on victim/survivor-centred
approaches and good practice PSEAH
policies and documents. Also consideredwere notes from a virtual discussion on
victim/survivor-centred approaches to
PSEAH with 30 experts from CHS Alliance
PSEAH CoP on 20 September 2022.

Findings from participatory action
research (PAR) in the Occupied Palestinian
Territories (OPT), Bangladesh (Cox’s
Bazar), and Ethiopia were considered
and incorporated – research that wasundertaken in the context of the CHS
Alliance’s Closing the Accountability Gap toBetter Protect Victims/Survivors of SEAH in
the Aid Sector project.

Limitations

1
2
3
4

The review only included studies and reports in English. A broader scope could havepotentially been more inclusive of different regional and cultural contexts and captured
research from more diverse scholars.
Articles in the desk review generally do not consider the full spectrum of SEAH and moststudies are concerned with sexual assault and less with sexual exploitation and harassment.
The scope of this review could not be limited to the aid sector, and had to include thebroader existing literature on SEAH and extend its application to the aid sector.

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It is recognised that victims/survivors are not an homogeneous group and that the individual
experience of SEAH can be internalised and lived in different ways. The intersectionality ofgender, race and characteristics shape experiences of victimisation and PSEAH. The desk
review aimed to be inclusive, since “one survivor does not speak for all”, and tried to capture
a diversity of experiences for men, members of the lesbian, gay, bisexual, transgender andqueer/questioning, intersex and other gender and sexuality identities (LGBTQI+) community,
adolescents, minorities, migrant women, etc.

 hile this foundational paper focuses on victims/survivors whose diverse needs andWinterests are often overlooked, it is important not to render the perpetrators invisible. A
number of key factors contribute to the perpetuation of SEAH, including co-workers whoenable such behaviour and managers that turn a blind eye or cover up for the actions ofothers. While this focus is important, this paper does not attempt to analyse the root causesof SEAH or the factors that contribute to its continuance.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORCHS ALLIANCE

VICTIM/SURVIVOR-CENTREDAPPROACH: DEFINITIONSEXISTING DEFINITIONS OF A VICTIM/SURVIVOR-CENTRED APPROACH
Definitions of a victim/survivor-centred approach
exist in the aid sector, and tend to place thevictim/survivor’s well-being, agency and choiceat the centre of practices. The exception is forvictims/survivors who are children under theage of 18 years, for whom decisions are made byothers in their best interest. All definitions areuseful, but for ease of reference this foundational
paper uses the definition currently used by the
CHS Alliance:• Victim/survivor-centred approach: anapproach in which the victim/survivor’s
wishes, safety and well-being remain apriority in all matters and procedures.11
Note that a victim/survivor-centred, or
survivor-focused, approach differs froma victim/survivor-led approach.
• Victim/survivor-led approach: An
approach that equips and empowers
survivors to take a leadership role intheir own life12
Where such an approach exists in theaid sector, it tends to focus on a victim/
survivor-centred approach, rather than a
victim/survivor-led approach in which thevictim/survivor is the lead decision-maker.
This can sometimes be because a victim/
survivor-led approach is incompatible
with organisational accountabilities andresponsibilities on harm prevention. For
example, if the perpetrator is a memberof staff (or associated personnel) of anorganisation, the organisation may belegally and procedurally obliged to follow

due process not always compatible withvictim/survivor-led decision-making.
While definitions of victim/survivorcentred approaches are available, thereis less documentation that unpacks whata victim/survivor-centred approach
looks like in practice when the victim/
survivor reports abuse to humanitarian ordevelopment organisations. In 2022, the
IASC initiated work to develop a common
definition for a victim/survivor-centred
approach to PSEAH.13
There is useful guidance available fromthe field of gender-based violence (andwhich will be discussed below), but suchguidance is not specific to practices
for addressing SEAH perpetrated byaid organisation staff and associatedpersonnel, which come with additional
considerations related to local
employment law, human resources policies
and other “duty of care” policies andprocedures.

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORPURPOSE AND AUDIENCEThis foundational paper builds on existing
definitions in the sector to propose
a victim/survivor-centred approach
for addressing and redressing SEAH
perpetrated by aid sector staff andassociated personnel. It is hoped that the
paper will enhance the current knowledge
base and PSEAH practice in the sector byproviding recommendations for each stepof the PSEAH process.
The primary audience for this paper
is humanitarian and development
policy leaders in local and internationalorganisations who are responsible fordeveloping PSEAH policies, procedures,
guidelines and protocols. It is also

0.

REPORTINGMECHANISMSDISCLOSURE

3.

REPORT HANDLINGAND CASE
MANAGEMENT

This paper follows the likely “journey”
of a victim/survivor of SEAH, from SEAH
violation by staff or associated personnelof an aid organisation, through to contact
with the organisation itself and beyond.
The paper is structured around thefollowing stages, acknowledging thatfor the victim/survivor, the journey isunique and cannot be categorised into a
regimented series of steps:14

2.

1.

VICTIMISATION

aimed at PSEAH practitioners involvedin the provision of services and support
to victims/survivors of PSEAH during
disclosure, reporting, investigations,case management, decision-making andredress.

4.

5.

REFERRALTO SUPPORTSERVICESINVESTIGATION

7.

6.

ORGANISATIONALDECISION-MAKING

REDRESS AND
COMPENSATION

Each stage articulates a definition, outlines contributing factors and existing practice andprovided a simplified overview of how the organisation may be interacting with the victim/
survivor (see Table 1, below). In each stage, victim/survivor-centred approaches are considered.
Recommendations from these sections then form a proposal for a victim/survivor-centred PSEAH
approach in the Victim/Survivor-Centred Framework.

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Stage

Victimisation

As experienced by victim/survivor

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Action by the organisation

SEAH is perpetrated against the victim/
survivor. This could be a one-off
incident, or something happening overa longer period of time.

Disclosure

The victim/survivor discloses SEAH to
the organisation or a third party.

If the disclosure is made to a staff
member, they refer it to the relevant
person or department.

Reporting
Re mechanisms

The victim/survivor or a third party
may report SEAH concerns through areporting mechanism

The organisation receives the report.

Report handling andcase management
Reporthandling

The victim/survivor is contacted by theorganisation (if their identity is known).

The organisation:• documents the report or disclosure;• decides how to follow up on the report;•	initiates its case management
procedures if a case is opened.

Referral toReferral
support toservices

The victim/survivor accesses support
services as necessary. This may takeplace immediately, or later, and may last
any length of time as per the survivor’s
needs.

The organisation assists the survivor toaccess support services. If the survivor isa child, referrals will be made in the bestinterests of the child.

The victim/survivor is contacted by
the organisation to inform them of apotential investigation, and ask theirconsent.

The organisation undertakes aninvestigation, if appropriate.

and case

Investigation

The survivor may participate in theinvestigation by providing interview
testimony.

Organisational
decision-making

The victim/survivor is informed thatthe investigation is complete. Detailsof what is shared vary depending onorganisational policy.

The organisation makes decisions on next
steps, for example:• If disciplinary procedures are required;•	If any other stakeholders need to be
informed of the case;•	If any learning can be fed back into theorganisation.

Redress andcompensation

The victim/survivor may receive
compensation from the organisation.
They may also be supported to seek
redress.

The organisation makes a decision onwhether redress and/or compensation
are provided to the survivor, and if so,
what form these will take.

If not, the victim/survivor may decide
to seek redress for themselves, forexample through a legal process or acustomary practice.

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WHAT THIS PAPER DOESNOT COVER
Prevention of SEAH
The sector has frameworks and approaches
for SEAH prevention and these frameworks
form the foundation of any organisation’s
work preventing SEAH. This paper focuseson how SEAH is addressed and redressed
when prevention has failed. Strengthening
accountability mechanisms for SEAH will
indirectly contribute to prevention.
Debate around standards and principles
The paper recognises that there areprohibitions in many of the sector’s
PSEAH standards, including in the Six
Core Principles,15 and a debate as to how
appropriate these are for the aid-related
contexts. However, this discussion will not
be addressed in detail here.

Child-specific approaches
This paper will consider issues as theyspecifically relate to children but will not go
into detail. CHS Alliance recommends thatorganisations engage specific expertise for
SEAH cases involving children.

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0.
VICTIMISATION

015

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As experienced by the victim/survivor
SEAH is perpetrated against the victim/
survivor. This could be a one off incident,
or something that happens over an
extended length of time.

Action by the organisation

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The starting point for a victim/survivor-centred approach is an understandingof victimisation and its impact on the victim/survivor of SEAH.
Victims/survivors are not an homogeneousgroup or category of people16 – womenare not the only victims of SEAH andevery individual is unique.17 Victimisation
is a complex process, involving several
stages that impact people in different
ways. Individuals may experience andexpress different feelings at different
points, and these may impact their choices
and actions. Being a victim/survivor is alifechanging and unwanted experience,and one that requires all actors involved
with victims/survivors of SEAH to refrainfrom making assumptions about needs andinstead respect the voice and choices ofvictims/survivors.

The impactof victimisation isparticularly profound for
already-vulnerable populations
including people living in poverty
who have little power, young
people, disabled people, those
who are socially isolated
and those identifying as
LGBTQI+.

The victimisation process starts with the
SEAH incident itself – this is also referred
to as primary victimisation. Next comesthe victim/survivor’s reaction, includingchanges in self-perception and any
informal and/or formal response they may
wish to make. The third phase is that ofinteraction between the victim/survivor
and others – and where this is a negative
experience for the victim/survivor, it isreferred to as secondary victimisation.18

CONSEQUENCES AND IMPACT OF
VICTIMISATIONSEAH is known to cause psychological,
health, social and even economic harmfor victims/survivors. It may also increase
vulnerability to further sexual violence.19
SEAH may impact victims/survivors’
overall quality of life and the effect can belong-lasting, spanning decades and evengenerations. The impact of victimisation
is particularly profound for alreadyvulnerable populations including people
living in poverty who have little power,
young people, disabled people, those whoare socially isolated and those identifying
as LGBTQI+.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR© Unsplash: Levi Meir Clancy

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Health impact

Social impact

Physical injuries are not always present
or apparent when it comes to SEAH.
If present, they tend to appear on theclothed parts of the body. Physicalreactions can include insomnia, lethargy,changes in appetite, headaches, and also
unwanted pregnancy and gynaecologicalcomplications.20 Physical reactions cancontinue long after the violation.

SEAH can have emotional effects andinfluence social relationships with friends,
family and colleagues. It not uncommon
for victims/survivors to experiencestigma and discrimination from partners,
family and community members. This isparticularly true in communities where
chastity, family honour and patriarchal
norms dominate.23

Psychological impact

Economic impact

SEAH can have wide-ranging emotionaland mental health consequences. Fear,shock, powerlessness, guilt or self-blame
are common. Victims/survivors may
also have been demeaned during theviolation. The mental effects of sexualassault are particularly challenging andunpredictable.21 Depression, anxiety, posttraumatic stress disorder (PTSD), acutestress disorder (ASD), substance abuse andsuicide may also occur.22

Victims/survivors of SEAH may incur
unforeseen medical, legal and logisticalexpenses. This could also include loss of
income (from being absent, unperforming,
job loss, etc.) or costs associated withraising children born from the abuse,
etc.24 In addition, there are financial costs
to organisations and society, including
support, assistance, medical services
and possible routes to justice for victims/
survivors.25 Financial costs can last alifetime and, in cases of child abuse, theeconomic impact can be passed down
for generations and affect the wholecommunity.26

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1.
DISCLOSURE

CHS ALLIANCE

As experienced by the victim/survivor

Action by the organisation

The victim/survivor discloses SEAH to theorganisation, or a third party.

If the disclosure is made to astaff member, they refer it to therelevant person or department.

Disclosure can be the first step towards accessing support, protection,and healing for a victim/survivor of SEAH, and towards preventing it
happening to others.27 However, disclosing a SEAH incident is difficult andmay take time.28 Victims/survivors may disclose to obtain help, supportand understanding and/or to stop the violation.29,30 Disclosure can also bea political act to bring attention to a problem. Disclosures can be formal
or informal. It is essential to recognise that disclosing SEAH is not always
the best option for the victim/survivor and that non-disclosure is also a
choice.31 The decision to disclose, to not disclose or to limit disclosure
should rest with the victim/survivor. Disclosures among children canoccur through discovery/detection of signs of abuse, be accidental(unintentionally disclosed) or be purposefully disclosed.32
FACTORS THAT MAY HELP OR HINDERDISCLOSURE
Various factors influence disclosure
by adults, including the nature of theviolation and the relationship to theperpetrator,33 whether alcohol and drugs
were involved, prior experience of sexual
abuse, shame and cultural factors. In
addition, perceptions of service providers
and fear of losing access to aid have also
been documented.34 Barriers for victims/
survivors to disclose SEAH are “unique,compounded, and cumulative” andintersect with race, age, class and gender,among other characteristics. Specificbarriers have been noted among women ofminority, religious and ethnic groups; thosewith disabilities, members of the LGBTQI+
community, children, the elderly andmen. 35,36,37,38

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Victims/survivors tend to perceive formal
support systems, such as religious, medical
and legal sources, more negatively thaninformal supporters39 and most victims/
survivors disclose informally to a friend,family member, partner, etc. Mental healthprofessionals and crisis advocates tend to
be more positively perceived by victims/
survivors,40 and studies suggest thatwomen friends tend to be seen as the bestsource for disclosure.41

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Community research from refugee camps
in Cox’s Bazar found many barriers toreporting to formal responders. Women
who experience SEAH tend to avoid
reporting due to social stigma anddiscriminatory cultural norms within the
Rohingya community, and inadequate
institutional measures taken after
reporting. Research among adolescent
girls found that factors such as inadequate
security, a sense of impunity among
perpetrators and an inaccessibility to(or lack of) justice for survivors of sexualand gender-based violence (SGBV) in thecamps all increase the incidence of sexual
harassment, abuse and exploitation.
Inaccessibility of formal and informal
justice systems and a reliance on camp
governance mechanisms make reporting
instances of both GBV and SEAH nearly
impossible for many women and girls.42

Negative social reactions and victim/
survivor-perceived negative social
reactions to disclosures have provenharmful to victims/survivors,44,45 withan even greater impact on sexual andracial minorities46 arising from limited
knowledge and inadequate understandingof victimisation.
Negative social reactions/interactions
broadly fall into two categories (i) turning
against the victim/survivor (such as victimblaming; treating differently/stigmatising
behaviour; reactions that ignore the wishesof the survivor and infantilises them);and (ii) unsupportive acknowledgement(egocentric, distraction, efforts to help
without prioritising the needs of thevictim/survivor).47 These are listed in Box 1.

The ways that victims/survivors aretreated by the person they disclose to(and the victim/survivor’s perception andexperience of that support) impacts theirmental health and recovery.43

Box 1: Negative social reactions to disclosure
Victim-blaming: victim is at fault, irresponsible, not cautious enough or could have done
more to prevent the victimisation.
Stigmatising: rejecting, avoiding, or acting as if the victim is damaged or different.
Egocentricism: the victim’s needs become secondary, and they feel compelled to reassure
the disclosure recipient as they exhibit distress as well as wanting to seek revenge.
Distraction: discouraging the victim from thinking and talking about their distress.
Taking control: decision-making power and autonomy is taken away from victim, tellingothers of the victim’s experience or minimising the experience and infantilising the victim.
Source: Ullman, S. E. (2000)

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORCHS ALLIANCE© Unsplash: Dev Asangbam

Two distinct positive social reactions/interaction to disclosure have been
documented to have positive mental
health impact, including less severe
PTSD, anxiety and depression.48 Theseare emotional support reactions (such ascommunicating that the victim/survivor is
not to blame or at fault, is a good person
and is loved, along with compassion, belief
and understanding, empathetic listening)
and tangible aid/information support
reactions (such as helping victims/survivors
explore options and access services,
providing transport without coercion, etc.).
Emotional support and tangible aid
are generally perceived as positive byvictims/survivors, although their impact
on mitigating negative mental healthreactions arising from an incident of SEAH
is mixed.49 A recent meta-analysis of social
reactions to victims/survivors’ disclosure

confirmed these findings, establishing thatnegative social reactions (both received
and perceived) are harmful to victims/
survivors’ mental health. It identified that
positive received support may be helpful
but not especially protective.50
A systematic review of 13 studies focusing
on disclosures of sexual victimisation
among sexual and gender minority (SGM)
people identified that impacts of negativesocial reactions appear to be even more
harmful among these populations thanothers. Whereas positive reactions arehelpful to recovery. It also identified
that bisexual women were more likely todisclose to formal (e.g., police, healthcare
providers) and informal (e.g., friends,
family members) sources than other
women. It also found that SGM victims/
survivors disclose to mental healthprofessionals at particularly high rates.

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Digitalisation and implications for SEAH
disclosures
Social media platforms, forums and apps
have emerged as a channel for disclosing
SEAH and uniting victims/survivors. As with
face-to-face disclosures, online disclosures
are not just associated with positive
outcomes but also risks and barriers.51/52
Online disclosures may offer victims/
survivors more control over their narrative,
as well as anonymity, privacy, convenienceand even empowerment, communityand validation.53 Beyond disclosures,
digital tools and platforms can be used
to facilitate access to support for victims/
survivors in a discrete way – yet thedigital divide54 may limit this approach.
However, digital disclosures may bemisused and lead to unwanted attention
beyond victims/survivors’ intent, andrisk undermining “victim’s credibility andveracity of accounts”.55
Third-party mechanisms to handle
disclosures
These are mechanisms through which
disclosures and reports are made to andreviewed by third-party providers. Then,with victims/survivors’ consent, they arethen referred to relevant authorities,
services, or employers, as appropriate.
Examples include Sawa56 in the OPT and
Loop57 globally. These can be used either
for general complaints and feedback, or
specific to SEAH and SGBV. Disclosuresand reports may be made anonymously.
These third-party mechanisms offer
victims/survivors the opportunity todisclose without engaging directly with theorganisation responsible for the person
accused of perpetrating SEAH.

Many employers also use casemanagement software such as Ethicspoint
or Safecall. This includes telephone
hotlines staffed by call handlers in
multiple languages. Most of these systems
provide the opportunity to discloseanonymously. A report generates a
temporary email address that cannot be
traced to the person reporting, whichallows the employer to interact withthe reporting person anonymously – orthe reporting person can choose not to
reply. Humanitarian and development
organisations often also use otherreporting channels, including communitybased complaints mechanisms for making
disclosures or raising concerns directlywith the organisation. These are covered in
the next section of this report.
Although third party providers claimthat call handlers are trained to receive
sensitive disclosures, it is difficult to be
sure that all services are appropriate
for handling serious or complex SEAH
disclosures. Even with these mechanisms
in place, organisations cannot control or
predict how a victim/survivor might makea disclosure.

A SELECTION OF SECTOR BESTPRACTICEThis report found a multitude of resources
available on good practice in receiving
SEAH and GBV disclosures. For example,
the How to support survivors of genderbased violence when a GBV actor is notavailable in your area guide58 provides“dos and don’ts” for receiving a disclosure,
together with examples of what to say, andis available in multiple languages. This toolis aimed at those receiving disclosures of
GBV in the community, but the guidance isapplicable for those receiving disclosuresof SEAH. Some of the key points fromguidance on receiving disclosures include:

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR

What to do

What not to do• Allow the SEAH victim/survivor to leadthe conversation• Do not overreact – stay calm

CHS ALLIANCE• Listen more than speak• Do not force help on someone by being
intrusive or pushy• Make comforting and supportive
statements• Do not doubt or contradict whatsomeone tells you• If appropriate, ask who, when, where andwhat• Do not pressure the person to share
more information than they are
comfortable with

• Do not ask why• Repeat/check your understanding of thesituation• Ask the person what they would like you
to do with the information they havedisclosedChild-focused organisations often include
guidance on how to handle disclosuresfrom children in their safeguarding
policies.59 For example, the Save theChildren and Able Child Africa Disabilityinclusive child safeguarding toolkit contains
detailed advice on enabling and responding
to disclosure by children living withdisabilities, noting that there are manydifferent types of disability that children
may be experiencing and that common
means of disclosing may not be suitable
for all. The guidance also reminds us that,regardless of the means of disclosure, therecipient should ask themselves: “would I
respond in this way if I were dealing with

• Do not offer your own advice or opinion• Do not make false promises or overstep
your rolea child without disabilities?”. If the answer
is “no”, practitioners should demonstratethat the child with disabilities has beentreated equitably and that assumptions,discrimination or unconscious bias relating
to a child’s disability have not affected the
response.
All these guidelines emphasise theimportance of handling disclosures
sensitively to avoid re-traumatising thevictim/survivor. However, guidance is only
useful if rolled out to those who might findthemselves in the position of receiving a
disclosure.

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WHAT WOULD A VICTIM/SURVIVORCENTRED APPROACH LOOK LIKE?
Aid actors tend to trigger SEAH protection
following disclosure of SEAH. Researchunderlines the role and responsibilitiesof these responders and the importanceof victim/survivor’s perceptions of social
reactions. Evidence on SEAH disclosures
also highlights the important role of social
supporters in mitigating harm towards
victims/survivors.
It is known that harm to victims/survivors
results from negative interactions of bothinformal and formal supporters, withformal supporters being generally morenegatively perceived by victims/survivors.
Formal supporters must, therefore, bemore mindful how they listen and react todisclosures. Intervention efforts to mitigate
negative social reactions in disclosures andpromote/provide positive social support tovictims/survivors are needed and should
be prioritised by PSEAH actors. This will
require interventions and the identificationof formal professionals and informal
support networks with whom SEAH
victims/survivors interact.

Staff who are likely to comeinto contact with members of
the community should have aminimum basic training on how
to receive a disclosure.

The inconclusive evidence on theperceived benefits of positive social
reactions associated with victims/
survivors’ disclosure means it is critical that
disclosures are never forced or encouraged
by PSEAH actors in the belief that it iscathartic and/or healing for the victim/
survivor. Furthermore, organisations must
not transfer organisational responsibilities
of preventing SEAH to individuals, but must
always be respectful of victims/survivor’s
rights, risks and circumstances when it
comes to disclosures.
Staff who are likely to come into contact
with members of the community shouldhave a minimum basic training on how toreceive a disclosure. This should include
how to respond in a way that prevents
further traumatisation.
Third-party mechanisms to handle
disclosures that are external to theorganisation should be considered andcan offer an opportunity for anonymous
disclosure, or for the victim/survivor
to decide whether their disclosure isshared with the organisation. However,any mechanisms used should be quality
assured to check they are capable ofhandling serious and complex SEAH
disclosures.

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2.
REPORTINGMECHANISMS

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As experienced by the victim/survivor

Action by the organisation

The victim/survivor or a third party may
The organisation receives
report SEAH concerns through a reporting the reportmechanism.

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026

This section covers reporting mechanisms (or reporting channels) createdby organisations to directly receive reports or concerns relating to SEAH.
There are several means by which a SEAH
report or concern might come to anorganisation, for example:• Direct reporting by the victim/survivor,
through formal or informal channels.
• Disclosure by the victim/survivor to athird party, who then reports to theorganisation.
• Third party observes incident, or isconcerned about something they haveheard or witnessed, and then reports tothe organisation.
For reports to be appropriately received
and dealt with, there need to be twoelements in place – a means by which
reports can be made and a system forhandling reports once they are received.
Community-based complaints
mechanisms
A commonly-used term in thehumanitarian sector is “communitybased complaints mechanism” (CBCM).
A CBCM is a mechanism for enablingfeedback, reports and complaints from
communities. It is developed by consultingwith communities on what channels theywould like to safely provide feedback ormake complaints or reports. The channels
used depend on the results of community
consultations, but can include hot desks(for example during distributions),
community committees, focal points,
complaints’ boxes and dedicatedWhatsApp numbers. The term CBCM also
includes procedures for responding toreports, which will be covered in the next
section.
Not all CBCMs are appropriate for SEAH,
as they may not be confidential or havestaff trained to handle SEAH cases, orprocedures for referral.60 Some CBCMs arefor general complaints, but can also handle
reports relating to SEAH as they also havethe above components. Some CBCMs are
set up to specifically elicit and respond to
SEAH.
Other related terms include “complaints
and feedback mechanisms” (CFMS) and“complaints and response mechanisms”(CRMs). While these may have differing
purposes and applications, they generally
refer to the means by which reports areenabled and handled in organisations andthe same principles apply as for CBCMs
in terms of their suitability to receive andhandle SEAH reports.

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CBCMs combine formal and informal
community structures and have an
important role to play for communities
which have difficulty in accessing formal
systems that can administer investigations
and justice. The challenges with CBCMs
include becoming outdated, noncoherent and hard to operationalise
due to challenges around interagency
coordination. Research has found that,as currently implemented, they are notadequate (because of concerns aroundconfidentiality and stigma) for SEAH
complaints which require a more sensitive
and tailored approach.
Hotlines
Hotline services (telephone and online)
inform and assist victims/survivors of
SEAH. The privacy and anonymity they
offer makes them a common voluntaryintervention for disclosures andpsychosocial support. Hotlines can also
be used as an intake channel for reporting
an SEAH violation and be a pathway tosupport services, linked and integrated
with various forms of assistance. Hotlines
are also used for reporting by nonvictims/survivors. Anonymised data fromhotlines can be used to collect sensitive
data on victims/survivors’ experiences
without secondary victimisation and so
guide institutional practices and systemic
improvements.
Types of hotline services used in thehumanitarian sector vary and include:• Single agency hotlines, often “low tech”,
using a local provider. These can utilise
SMS as well as voice calls, and arestaffed either by third-party providers or
the organisation’s staff.
• Hotlines that are part of a casemanagement package, such as Safecall
or Ethicspoint (see previous section).
• Inter-agency hotlines that are shared byorganisations, such as via the in-country
PSEAH Network.

CHS ALLIANCE

Interagency hotlines are increasingly
used, particularly in humanitarian
responses, in recognition of the fact thatpeople reporting may not know whichorganisation a perpetrator works for andshould be given a shared channel thoughwhich to report. Interagency hotlines
usually comprise of:• A local hotline staffed by trained
personnel.
• Awareness raising in the community on
what the hotline is for, and what number
to call.
• A process to share reports that comeinto the hotline with the relevant
agency.
• An agreement from members to commit
to protocols to investigate reports to anagreed set of standards.
Hotlines have been used as a mechanism
to support victims/survivors of sexual
abuse since the 1970s.62 They are usedinternationally to support victims/survivorsof SEAH. Telephone hotlines tend to be theprincipal mechanism for victim/survivor
assistance as compared to online chatand text,63 although data suggest that thelatter has gained in prominence in recent
years64 – in particular among children andadolescents for their first disclosure.65
Victims/survivors use hotlines differently
and at different times. Some use them toreport the victimisation, others only after
they feel let down by the institutions towhich they have reported. Hotlines arealso used for reporting by non-victims.
Victims/survivors may initiate contact
with the hotline after a few days but mostcommonly this contact is not immediateand only occurs a few years later. Given
limited data, it is impossible to say whether
this is also the case in emergency settings.

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The media (including social media)
In recent years the media has emerged astrusted conduit for reporting SEAH. Media
reports have uncovered and documented
atrocious abuses of power against
some of the world’s most vulnerable
populations and shed a light on SEAH
within aid organisations themselves.
First-time reporters, along with victims/
survivors who have filed complaints
within aid organisations, have bravely
shared their stories with journalists. Being
believed and taken seriously, alongside
the uncompromising independence,
impartiality and respect of anonymity andconfidentiality on the part of journalists,
has allowed SEAH victims/survivors to
entrust them with their stories. Journalists
have also challenged organisations to beaccountable vis-a-vis their own policies.
Still, ethical questions arise in theaftermath of such disclosures. Given
the role of the media rarely reaches
beyond the telling stories in the absenceof support systems to which the victim/
survivor can turn, questions around how
to accommodate victims/survivors’ safety
persist. The media can be an importantpartner in shedding light on abuse within
the aid sector, acting as a watchdog andspurring action by aid sector. They canbe better capacitated to understand andadhere to ethical reporting standards
and become more familiar with referral
pathways, where they exist.
Trusted intermediaries, community
entry points
Research has identified the important role
informal reporting channels play whenit comes reporting incidences of SEAH.66
When victims/survivors do break theirsilence, they share their grievances andseek support and relief through trusted

intermediaries/community entry points.
These reporting channels are often
selected by the victim/survivor because
they are trusted by the communityand perceived to offer support and/or
accountability. Such intermediaries may
include a range of actors that exist in
the community, including communitybased women’s groups, religious leaders,
community elders, community leaders,midwives and camp authorities.67 Theiradvantage is that they are independentand not controlled by organisations.
However, their capacity for PSEAH may
be limited.
PSEAH Focal Points
Many organisations have PSEAH focal
points, or personnel in similar roles, toreplicate the “trusted intermediary”
approach. Focal points are usually staff
members in existing substantive roles,
with their focal point duties comprising
just 10-20% of their role. They are notnecessarily PSEAH experts but work in
related roles, such as gender or GBV
advisors, human resources, etc. Their roles
include championing and promoting PSEAH
in their location and receiving and referring
SEAH reports. PSEAH focal points are notgenerally trained or expected to participate
in SEAH investigations.68 Limits to the roleof focal points include their sometimes
short-term or rotating assignments and thelimited time they have as a consequence
to build trust and implement PSEAH
measures. In contrast they are sometimes
embedded in organisations and are
therefore seen as part of the system andnot adequately independent, making themsubject to trust issues.

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WHAT ARE THE CHALLENGES?
The diverse emotions experienced by avictim/survivor following victimisation
and/or disclosure play a significant rolein the under-reporting of SEAH. Shame,
guilt, embarrassment but also fear of
retaliation, fear of stigma, fear of not
being believed and lack of trust contributeto the underreporting of SEAH within
and outside of the aid sector.69/70 The aid
sector is, in part, accountable for thissituation as their response to victims/
survivors has often been found to be
woefully inadequate. Over time, lack ofprivacy, lack of confidentiality, negative
experiences, stories of retaliation, statutesof limitations, slow processes with nofeedback and impunity for perpetrators
have all contributed to a general mistrustof formal reporting mechanisms thatthe aid sector should repair to regain
victims/survivors’ trust. Aid actors have
unethically called on victims/survivors toreport abuse without having the adequate
protection and support services in placewhen they do. Strengthening reporting
mechanisms to better serve victims/
survivors necessitates a critical review ofexisting mechanisms and improvement inpractices.
© Unsplash: Debbie Molle

CHS ALLIANCE

Confidentiality in reporting
Anonymity and confidentiality concerns area key barrier to SEAH reporting. Ensuringconfidentiality in reporting is best practiceand among the standards of the CHS
PSEAH Index.71 While commonly cited inorganisational policies, confidentiality is far
from obvious and cannot be assumed if not
explicitly safeguarded. Field research from
Bangladesh and the OPT has identified
confidentiality concerns associated with
common reporting mechanisms.72 This
includes the placement of complaints
boxes in public spaces where privacy andanonymity cannot be assured and no selfreporting options available to community
members, thus requiring many people
to be involved in reporting – each one
increasing the likelihood of confidentiality
breaches and complaints becoming
known to the community. These findings
have been documented in other low- andmiddle-income countries.73
Confidentiality is sometimes misused asa justification by aid organisations to not
publicise numbers and outcomes of SEAH
reports, denying feedback and reviews by
victims/survivors about their case and as apretext for non-disclosure agreements.74

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Use of reporting mechanisms
With respect to hotlines, research has also
found that men and women experience
different trust concerns when it comes toreporting their experiences, with womenprincipally fearing “not being believed”
and men fearing “being judged”.75 An
exploratory case study from a US sexualassault hotline found that men withlong-term psychological distress weremore likely to use and favour hotlines toalternative services on the basis that they
better accommodate their stigma andprivacy concerns.76 Hotlines have reported
having high attrition rates among staff,
necessitating regular identification andtraining of new personnel.77
Experience from PSEAH practitioners
indicates that victims/survivors are more
likely to report SEAH to trusted staff
members rather than through a moreimpersonal reporting channel. PSEAHrelated activities, such as awarenesstraining, can also result in disclosures
as victims/survivors observe that theorganisation has policies and procedures
on PSEAH and the trainer may be seen as atrusted interlocuter.78

Even when reporting channels are in place,experience has shown that this does not
result in uptake. The Reuters/HumanitarianNews report79 on widespread SEAH in
the Ebola response in the Democratic
Republic of the Congo (DRC) demonstrated
that, even in a response with multiple
humanitarian actors all stating thatthey had a complaints mechanism inplace, victims/survivors chose not to
use them. More than 40 humanitarianorganisations were operational in the
response, with most stating that they
had complaints mechanisms in place.80
UNICEF told journalists that they had
introduced 22 ways to file complaints inthe DRC, including a confidential hotline
and complaints’ boxes. However, whenjournalists surveyed 34 of the maininternational organisations and a handfulof local NGOs involved, most of the 24 thatprovided data indicated they had received
no complaints during the near two-year
outbreak.
Interviewees told journalists: “Mostwomen interviewed were unaware of
hotlines and other ways to report abuse”,
and a victim/survivor stated: “Why would
you even ask if I reported it?... I was
terrified. I felt disgusting. I haven’t eventold my mother about this”.
Language

The humanitarian
sector’s use of language
and terminology canfrequently be inaccessible
to the communities withwhich they are working.

The humanitarian sector’s approach tolanguage is a significant challenge inaddressing SEAH. This is both with respect
to the language and terminology usedin work on PSEAH, and the complexityof language in disclosure and discussing
sensitive issues related to SEAH.

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The humanitarian sector’s use of language
and terminology can frequently beinaccessible to the communities withwhich they are working. Resources
on awareness raising are often in thelanguages spoken by the sector rather
than the communities it serves, and theterminology is impenetrable and difficult
to translate. As the CHS Alliance report
Closing the Accountability Gap found:“While Rohingya womenthemselves are clear on what
constitutes SEAH, the sector’s own
definitions and use of language
around the subject mean thatthey are not communicating
effectively with the community.
Organisations perceived that
Rohingya women’s lack ofunderstanding of what the sector
defines as SEAH, and what they
can report, was the problem,
rather than addressing their(the organisations’) own use oflanguage and communication.”81
This inhibits the sector’s ability tocommunicate with communities onwhat they should expect from staff
and associated personnel in termsof conduct and how to report if they
have any concerns or are aware of any
violations. Sometimes staff working for theorganisation do not themselves understandwhat is expected of them.82

CHS ALLIANCE

One of the many challenges facingorganisations in their efforts to preventand respond to SEAH is the linguistic
and cultural differences inherent in
humanitarian contexts. As a sector,
humanitarian actors are accustomed tolooking at factors such as poverty, gender,
age and disability as common drivers ofvulnerability. Yet language and culture arealso intertwined with vulnerability. For
example, speakers of minority languages
often experience multiple layers of
disadvantage when they seek information.
Compounding this is the complexity of
discussing sensitive and often culturallytaboo issues. Often, colloquialisms may
be used to discuss issues round SGBV and
SEAH, or there may simply not be thelanguage at all – for example, in some
cultures there are no terms for sexual
violence perpetrated against men.83
Humanitarian organisations’responsibility to identify SEAH
The humanitarian sector’s focus onreporting mechanisms is predicated on
victims/survivors highlighting that SEAH
is brought to the organisation’s attention.
This burden of responsibility should not be
placed on victims/survivors, or membersof the community. The sector needs tobe more proactive in firstly assuming that
SEAH will be occurring in humanitariansituations where there is extreme
vulnerability and power imbalances and,secondly, assessing when, where and how
it is occurring. Not enough is done to takeresponsibility for analysing SEAH risk andproactively identifying where violations are
occurring.

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Communities andpeople affected bycrisis should have accessto safe and responsive
mechanisms to handle
complaints.

A SELECTION OF SECTOR BESTPRACTICE
The humanitarian sector has embedded
the need for reporting mechanisms in thestandards that guide its practice. In termsof guidance on implementing reporting
mechanisms, many tools and resources
developed by different organisations canbe found on the CHS Alliance website.84
Core Humanitarian Standard on Quality
and Accountability (CHS) Commitment
5 contains clear commitments on safe,
appropriate reporting mechanisms for all
kinds of feedback and complaints.
Commitment: Communities and people
affected by crisis have access to safeand responsive mechanisms to handle
complaints.
Quality Criterion: Complaints arewelcomed and addressed.

Key actions
5.1 Consult with communities andpeople affected by crisis on the design,
implementation and monitoring ofcomplaints-handling processes.
5.2 Welcome and accept complaints andcommunicate how the mechanism can beaccessed and the scope of issues it canaddress.
5.3 Manage complaints in a timely, fair
and appropriate manner that prioritises
the safety of the complainant and thoseaffected at all stages.

Organisational responsibilities
5.4 The complaints-handling process
for communities and people affected bycrisis is documented and in place. The
process should cover programming, sexual
exploitation and abuse and other abusesof power.
5.5 An organisational culture in which
complaints are taken seriously and acted
upon according to defined policies andprocesses has been established.
5.6 Communities and people affectedby crisis are fully aware of the expectedbehaviour of humanitarian staff, includingorganisational commitments made on
the prevention of sexual exploitation andabuse.
5.7 Complaints that do not fall within thescope of the organisation are referred to arelevant party in a manner consistent withgood practice.85
Principles for a survivor-centred reporting
mechanism can be found in the Aga Khan
Foundation’s Guidelines on Developing
Survivor-Focused Community-BasedComplaints Mechanisms in Consultation
with Communities:• Confidentiality is prioritised at all times.
• Procedures are designed in a way that
reduces the risk of re-traumatising thesurvivor.
• Support services (such as medical,
protection and psychosocial support) aremapped in advance of developing the
CBCM.
• Channels are provided to safely report
safeguarding concerns, designed inconsultation with the community andrelevant local safe-guarding expertise.
• The survivor is supported to accessthese services (if they wish to do so)
immediately after the concern is raised(and not pending the outcome of aninvestigation or any other processes).

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORThe Guidelines also provide guidance on
consulting with communities in developing
appropriate, survivor-centred reporting
mechanisms.86
There are fewer resources when it comesto mechanisms specifically designed toaddress reports of SEAH. The exception
is the comprehensive PSEA Best Practice
Guide on Inter-Agency CBCMs,87 produced
by IOM, Save the Children and UNHCR. The
guidance is a 135-page manual that covers
everything from securing management
support to developing the mechanism andhandling reports that come through on
SEAH. The guide is focused on interagency
complaints mechanisms rather thanCBCMs for single agencies.
Shorter guidance can be found in a rangeof tools produced by the sector, such as
the chapter on PSEAH CBCMs in the CHS
Alliance PSEA Implementation Handbook,88
resources on the Inter-Agency Standing
Committee Accountability and Inclusion
PSEA portal89 and protocols developed bynational hubs of the Safeguarding Resourceand Support Hub,90 which are aimed atsmaller or less-well-resourced NGOs a
nd CSOs.

CHS ALLIANCE

WHAT WOULD A VICTIM/SURVIVORCENTRED APPROACH LOOK LIKE?
Where reporting mechanisms are used,
they should be safe and appropriate as
articulated in the CHS. In order to be
victim/survivor-centred, the following
should be ensured (as a minimum):• Confidentiality is prioritised at all times.
• Procedures are designed in a way that
reduces the risk of re-traumatising thevictim/survivor.
• Support services (such as medical,
protection and psychosocial support)
are mapped in advance of developing
reporting mechanisms and awarenessraising on PSEAH.
• Channels are provided to safely report
safeguarding concerns, designed inconsultation with the community andrelevant local safe-guarding expertise.
• The survivor is supported to accessthese services (if they wish) as soon as
the concern is raised (and not pending
the outcome of an investigation or any
other processes).91

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3.
REPORT HANDLINGAND CASE
MANAGEMENTAs experienced by the victim/survivor

Action by the organisation

The victim/survivor is contacted by theorganisation (if their identity is known).

The organisation

CHS ALLIANCE• documents the report or disclosure;• decides how to follow up on thereport;• initiates its case management
procedures if a case is opened.

Once a report of SEAH enters an organisation it is the organisation’s
responsibility to follow it up. Even if there is insufficient information totake further steps, the report must be logged and filed and relevant actions
taken, such as:• Informing stakeholders where appropriate, such as the human resources
department.
• Checking for similar reports to identify a pattern.
• Conducting awareness-raising activities in the location (if known) to see
if any other reports have been made.
Case management is a structured method
for providing help to a victim/survivor. It
involves one organisation that provides,
or has access to, psychosocial support orsocial services, taking responsibility formaking sure that victims/survivors are
informed of all the options available tothem. They also ensure that any issues
or problems facing a victim/survivor andtheir family are identified and followed
up in a coordinated way, providing thevictim/survivor with emotional support
throughout the process.92
Case management refers to the tasks thattake place once an SEAH case is known tothe organisation. It includes interaction
with the victim/survivor, documentationof information relevant to the case and

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decisions made, arranging support services
for the victim/survivor if appropriate (seesection 4, below, on referral to support
services), interacting with relevant
authorities if safe to do so and continuing
to provide long-term support to the victim/
survivor. Case management is usually led
by an individual or team with an overview
of everything that is happening in relation
to the specific case.
The way in which a case is managed canmake all the difference for the victim/
survivor’s well-being, protection and safety.
Empowering survivors after incidents ofsexual violence, can facilitate healing,
and render the process of reporting andseeking help less traumatising.93

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WHAT ARE THE CHALLENGES?
Examples of SEAH reports being
mishandled are easier to find than
good practice in the sector. The CHS
Alliance report Closing the Accountability
Gap found that victims/survivors areencouraged to come forward to discloseand report SEAH, but their complaints are
not adequately followed up. There arealso serious confidentiality and anonymity
concerns. Survivors are often left on theirown to navigate and cope with the adverse
cultural, psychosocial, security and legal
consequences that follow a disclosure andcomplaint.94
PSEAH practice is distinct from GBVpractice, and different approaches andprocesses are sometimes required. While
GBV practice addresses gender-based
violence perpetrated in the community,and how to prevent and respond to thesecases, PSEAH focuses on sexual harms
caused by abuse of power perpetrated
by an organisation’s staff and associatedpersonnel. This brings with it some
additional implications.

A victim/survivor-centred approachrequires that consent is sought from thevictim/survivor before following up on
an SEAH case. This is for many reasons.
Disregarding consent can result in retraumatisation. It may also represent arisk to the victim/survivor, for example, ifthey are of a sexual orientation, gender
identity and (gender) expression that is
criminalised in their location, or the SEAH
would criminalise them or stigmatise themin any way.
However, many organisations (particularly
UN agencies) have mandatory reporting
requirements for concerns of SEAH toensure that SEAH is being addressed. Thismeans that if a victim/survivor discloses
SEAH to a staff member, that staff member
must report it to the organisation.
Additionally, in some countries there
can be a legal requirement to report
some forms of SEAH to the authorities.
Furthermore, when the perpetratorof SEAH is an employee (or associatedpersonnel) of an organisation, thatorganisation is accountable for harmcaused and has legal and procedural
obligations to act on violations and prevent
potential further harm. This can come into
conflict with a victim/survivor-centred andtrauma-informed approach, which requirethat organisations seek consent fromsurvivors to follow up on SEAH reports.95
Some organisations misuse victim/
survivor-centred approaches – andtheir principle of consent for the victim/
survivor – to justify not responding toreports. In their article ‘Post #aidtoo: are
we setting ourselves up to fail?’,96 theauthors argue that: “rather than trying
to shut down investigations entirely asa means to ‘protect’ survivors from retraumatisation, we should be insisting on
professionally-led investigations by traumainformed investigators and demandingthat organisations take seriously their
obligations to stop harm through a safe
process”.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORA SELECTION OF SECTOR GOOD
PRACTICE
There are several comprehensive
resources available in the sector for casemanagement of GBV and protection
cases in the wider community. These casemanagement resources are useful for
PSEAH practitioners but require adaptation
when the perpetrator is a member ofstaff or associated personnel of theorganisation, as discussed above.
For example, the GBV Information
Management Systems Steering
Committee has produced guidance on
Interagency Gender-based Violence CaseManagement97 that describes a victim/
survivor-centred case management
approach that aims to create a supportive
environment in which each victim/
survivor’s rights are respected and inwhich the person is treated with dignity
and respect. A victim/survivor-centred
approach recognises that every survivor:• Has equal rights to care and support.
• Is different and unique.
• W ill react differently to their experienceof GBV.
• H
 as different strengths, capacities,
resources and needs.
• H as the right, appropriate to her/his
age and circumstances, to decide whoshould know about what has happened
to her/him and what should happen
next.
• S hould be believed and treated withrespect, kindness and empathy.

CHS ALLIANCE

Similar principles can also be found inother guidance such as the Murad Code98
and the International Protocol on theInvestigation and Documentation on Sexual
Violence in Conflict.99
The Interagency Gender-based Violence
Case Management guidance also contains
chapters on LGBTQI+ victims/survivors,
victims/survivors with disabilities andmale victims/survivors. The Alliance forChild Protection in Humanitarian Action
has produced guidance and a Standard
Operating Procedure template for casemanagement in child protection cases.100
This guidance emphasises that it isimportant to consider these (and other)groups when developing case management
and report handling procedures to ensurethat the systems are safe, appropriate,
accessible and respectful for thesedifferent groups.
Specific to PSEAH, the Safeguarding
Resource and Support Hub has
produced training and guidance on casemanagement. The interagency network
Bond has a template for receiving andreferring cases as they come into theorganisation.101

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORThe Global Interagency Security Forumguide, Managing Sexual Violence against
Aid Workers, also provides useful
victim/survivor-centred guidance thatis applicable to managing any case of
SEAH, not only where the victim/survivor
is a member of staff. For example, theguidance contains examples of how to
be transparent with victims/survivors,
respect their wishes and seek their consent
when undertaking actions. In the eventof an incident of sexual violence, theorganisation should immediately:• Ensure the victim/survivor’s and teammembers’ security and safety.
• Offer to arrange emergency medical careconfidentially, with the victim/survivor’s
consent.
• Offer to arrange transport to a safe
location if danger is imminent or if thevictim/survivor wishes to move.
• Ensure the victim/survivor knows thatthe organisation believes their accountof what happened.
• Assure the victim/survivor that theirneeds will be met to the greatest extent
possible and that the organisation isthere to provide guidance and support
and not to decide on their behalf.
© Unsplash: Levi Morsy Ansuqg• Offer to put the victim/survivor in touchwith friends and family, if desired.
• Find out from the victim/survivor whomthey would like their victim/survivor
supporter to be and offer a trained
supporter from within the organisation,
if this is an option the survivor is open to
considering.
• Offer other support as may be needed
and guidance on next steps.
• Provide advice to the survivor on options
for preserving physical evidence andsupport the survivor in this if they wish
to preserve evidence.
• Follow the appropriate reporting
protocol while maintaining
confidentiality and limited information
on a need-to-know basis.
• Inform the victim/survivor of thereporting protocol.
• Start a confidential log of allcommunications and decisions for the
response process with the survivor’s
consent.102
Many humanitarian organisations also havetheir own internal report handling and casemanagement procedures, based on theirpolicies and relevant labour law.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR

WHAT WOULD A VICTIM/SURVIVORCENTRED APPROACH LOOK LIKE?
Reporting mechanisms should not be
the default methodology for learning
about cases of SEAH in humanitarianorganisations. However, if used, theyshould be designed in a way that istrauma-informed so that it does not cause
further harm to victims/survivors and isaccessible to as many different groups
in the community as possible, including
the most at risk and marginalised. It is
important that report-handling and casemanagement systems take local law andpractice into account.
Reporting mechanisms and casemanagement should be developed using
principles that recognise victims/survivors
as individuals, with individual reactions,needs and wishes. Victims/survivors should
be recognised as experts in their own
situation. Case-management and reportshandling systems should take into accountthe specific needs of vulnerable of at-risk
groups, such as children, LGBTQI+ people,
people living with disabilities and malesurvivors.

It is important tobe honest with victim/
survivor about what will
happen if they wish toproceed with a reportof SEAH.

CHS ALLIANCE

The victim/survivor’s consent should besought before proceeding with a SEAH
report.103 If the victim/survivor does notconsent, this should be balanced against
the risk that the perpetrator may poseto the people with whom they come into
contact – while acknowledging that it isnever the victim/survivor’s responsibility
to prevent a perpetrator from causing
further harm. Alternative actions may beconsidered, such as closely monitoring thestaff member against whom the reporthas been made, moving them to a rolethat does not bring them into contact withvulnerable or at-risk communities andindividuals and conducting awarenessraising activities to see if any further
reports are made. This should be donein a way that does not pre-suppose thatthe staff member is a perpetrator andinfringe on their right to due process. Any
decisions around this should be thoroughly
risk-assessed and signed off by theorganisation’s senior management.
It is important to be honest with victim/
survivor about what will happen if theywish to proceed with a report of SEAH.
The case management and investigation
process should be outlined, including thepotential outcomes of the case – and thelimitations on what may be possible interms of the disciplinary procedure of theperpetrator. The victim/survivor should be
able to make an informed decision on what
they consent to in the process.
Consent does not end with receiving thereport – the victim/survivor’s consent
should also be sought for actions once thereport has been received, where possible.

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Preserving
victims/survivors’
confidentiality andprivacy is critical, as is
the security of digital
information related tothe allegations.

Humanitarian organisations should
allow anonymous reports and shouldhave no statute of limitations on making
reports of SEAH. Organisations should
welcome information regarding possible
harm caused by their organisation inorder to address the issue. Constraints
or parameters on reporting gives theimpression that redress is within the giftof the organisation only under certain
circumstances.
Preserving victims/survivors’ confidentiality
and privacy is critical, as is the securityof digital information related to theallegations. Pseudonym and data
codification protects the victim/survivor’s
anonymity and mitigates attrition due
to pressure on victims/survivors, theirfamilies and witnesses in the form of
blackmail, threats and bribes, all of which
are commonly reported.104
A victim/survivor-centred approachmeans providing the victim/survivor withsupport for as long as it is needed. This
does not always fit with the timelines ofan organisation’s case management andinvestigation procedures, but rather can
be a long-term commitment, in somecases many years. Support should not end
with the conclusion of an investigation or
disciplinary outcomes, but rather needs toinform how an organisation better ensuresprotection against SEAH in the future andcontinued support for victims/survivors of
SEAH for as long as they need it.

Trauma-informed care, treatment andsupportSEAH treatment, care and support
interventions include individual andcommunity-level interventions. Individualinterventions seek to directly benefit
the individual and ameliorate/alleviate
the consequences of victimisation.
Such interventions include counselling,clinical care and sexual and reproductive
healthcare services, etc. Community
interventions are system-oriented andconcerned with improving informal andformal responses to victims/survivors.105
Victim/survivor services can be helpful
in supporting and preparing the victim
before reporting. Those involved inproviding services to victims/survivors of
SEAH should be compassionate, express
validation and help connect the victim/
survivor to the required support services.
Trauma-informed care (TIC) is an evidencebased approach which has gained
prominence in social and behavioural
work and health. It focuses aroundresponding to the wishes and needs ofvictims/survivors and seeks to avoid retraumatising them, instead promoting theirhealth and healing, meeting justice needs
and providing support. It emphasises that
all interactions, decisions and services
should be prioritised and organised for thewell-being of the victim.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORSEAH victims/survivors who present fortreatment and care should be met withcompassion and be listened to carefully in a
non-judgemental way. Any victim/survivor
should receive a medical examination
subject to their consent only. Their accountof the incident (time, nature, what, where,whom) needs to be carefully documented
and their protection and safety needs
appropriately addressed and coordinated.
The role of the medical examiner is to
examine, measure and manage any physicalinjuries, take early evidence (mouth, genital,
urine, tampons, temporary wound dressing,etc.), screen for sexually-transmitted
infections and offer HIV screening andpost-exposure prophylaxis (PEP) and, if thevictim/survivor is a woman, offer pregnancy
prevention. LGBTQI+ victims/survivors
and children will require additional andspecialised support. 106

CHS ALLIANCE

While effective in some settings, theseapproaches might not always be culturally
appropriate. Key to taking a traumainformed approach is being culturally
humble and flexible. It requires moving
beyond western notions of therapy toincorporate elements of religious, spiritualand cultural practices, such as prayer. Suchsupport may tap into the victim/survivor’s
strength and resilience and offer a moreculturally appropriate path to healing.108/109
When victims/survivors come fromcollectivistic cultures, communities andsocial networks may have an importantrole to play in the recovery process.100

Many victims/survivors of SEAH present
with trauma, which is complex and can belong lasting. Therefore, it is important tounderstand the trauma experienced by the
SEAH victims/survivors. This has implications
for victims/survivors’ healing and redressand should be addressed. Best practicetreatment approaches for working withvictims/survivors of SEAH to address theirtrauma and mental health consequences
include cognitive behavioural approaches,
emotion-based approaches, eye movement
desensitisation and reprocessing (EMDR),
art-based approaches and mindfulness
approaches.107

Key to taking a
trauma- informed
approach is being
culturally humble
and flexible.

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4.
REFERRALTO SUPPORTSERVICES

CHS ALLIANCE

As experienced by the victim/survivor

Action by the organisation

The victim/survivor accesses any support
services they might wish to use. This may
take place immediately, or later, and maylast any amount of time as per the victim/
survivor’s needs,

The organisation supports thevictim/survivor to access any
support services they may wish to use.
If the victim/survivor is a child, referrals
will be made in the best interestsof the child.

Good practice in dealing with SEAH cases includes enabling the victim/
survivor to access support services, should they choose to do so. If thevictim/survivor is a child under the age of 18 years, referral will be made by
the organisation (if it is safe and appropriate to do so). Services can include
medical, psychosocial and legal support. Referrals can also be made tolaw enforcement, should the victim/survivor choose this pathway. These
referrals are part of due process in dealing with reports of SEAH and areseparate from the organisation’s own internal procedures to address
the report.
Many organisations work to advocate
for and provide support to victim/
survivor support services, usually in theirprotection, gender or GBV programming.
PSEAH practice focuses on leveraging,coordinating and extending existing safe,
appropriate services that can be accessedby and for victims/survivors when SEAH
occurs.

WHAT ARE THE CHALLENGES?
There is a difference between “allowing”
victims/survivors to access services andproactively enabling them to do so. Equally,
there is a difference between passive andactive referrals. Victims/survivors may needsupport in accessing services and may
want to do so outside of the timeframeof the organisation’s case management of
the investigation. Importantly, the victims/

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survivors needs may evolve over time,from needing support to deal with theimpact of the victimisation to more diverse
support needs emerging as the SEAH
complaints process is underway.
Some organisations have agreementswith staff welfare providers that offer
psychosocial support services. These aresometimes used as providers in SEAH
cases. It is important to assess whether
these providers are fit for purpose
for SEAH cases. Sometimes budget
constraints mean that the use of these
services is encouraged over external,
potentially more tailored and appropriate,
psychosocial services that meet individual
victim/survivor’s needs. The providers
too might be seen as associated withthe organisation, in which case victims/
survivors may not want to use them.

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The biggest challenge to providing support
services to victims/survivors is the lackof adequate services in many locations,particularly GBV support services. CHS
Alliance’s Closing the Accountability Gap
to Better Protect Victims/survivors against
SEAH in the aid sector project found that alack of appropriate services was identified
as a barrier in all three research locations– for example in OPT there is a lack ofeffective sexual and reproductive health,rights and well-being services for SEAH
survivors. For instance, research found that
there is no available STI testing or HIV PEP.
There is a lack of awareness of harmful
practices that violate the fundamental
rights of the survivors, such as virginity
tests in the Gaza Strip. There is also a lackof formal and safe abortion services for
pregnancies resulting from SEAH and alack of access to quality mental healthservices.111

A SELECTION OF SECTOR GOOD
PRACTICE
There are tools for mapping safe,
appropriate support services, such as thosedeveloped by Girls Education Challenge112
and the Safeguarding Resource andSupport Hub.113 These tools guideorganisations to map services available inareas local to their programmes and offices(services usually include psychosocial
support, medical services and legal
services). These tools suggest mapping
both official services, as provided bygovernment, but also services provided byNGOs and CSOs. Some mapping tools also
include the wider mapping of local laws
and practices that apply to SEAH.

The tools go beyond simply listing theservices, but include assessment criteria,such as:• Who the service is aimed at (e.g., adults,
children)?
• Is the service safe for victims/survivors,
including victims/survivors of different
sexual orientations, gender identities,
etc., and other potential at-risk
categories?
• Is the service accessible for people livingwith disabilities?
• Does the service include traditional
practices, where they are preferred?
• Are staff in this service appropriately
trained?
Existing mappings are also available, bothglobally and locally. For example, the No
More Global Directory114 provides links to
GBV services in every country in the world
and the PSEA Networks often conduct andshare their service mappings.
The UNICEF Technical Note to support the
UN Protocol on Provision of Assistanceto Victims of SEA addresses how toproactively enable a victim/survivor toaccess services, while respecting theirwishes and choices, along with how towork in the best interests of children. It
includes the following principles:• If the victim/survivor is an adult, explain
the risks associated with this [referral]
option (such as retaliation, harassment,etc.) so they can make an informed
decision on how they want to proceed
and whether they want to receive
services from that organisation, being
fully aware of the risks.
• If the victim/survivor is a child,depending on their age and level ofunderstanding they should be consulted
on their preference.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR• For young children (under the age of 12
years), always consult the trusted adultthey identify and take into account theirbest interests when making a decisionon their behalf.
• Services should not be provided by aservice provider from the organisationthat employs the perpetrator if there isany possibility of the child victim coming
into contact with the perpetrator.
• Explain the availability of other service
options and offer support to the victim
to access these (either in anotherlocation or via another service provider),depending on the severity of the risks.

CHS ALLIANCE

WHAT WOULD A VICTIM/SURVIVORCENTRED APPROACH LOOK LIKE?
Organisations should undertake
comprehensive support service mapping
before an SEAH case is reported. Services
should be safe for victims/survivors,
particularly those who may be at increased
risk due to their sexual orientation orgender identity expression, or othercharacteristics such as belonging to amarginalised community or being inconflict with the law. They should also take
local custom and context into account andbe accessible for victims/survivors livingwith disabilities.
Referral to support services should involve
proactively assisting the victim/survivor
to access services, should they wish to.
This should take place at the victim/
survivor’s pace, even if this does not fit
with organisational case management andinvestigation timeframes.

Referral tosupport services
should involve
proactively assisting thevictim/survivor to accessservices, should theywish to.

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5.
INVESTIGATIONAs experienced by the victim/survivor

Action by the organisation

The victim/survivor is contacted by the
The organisation undertakes anorganisation to inform them of a potential investigation, if appropriate
investigation, and ask their consent

CHS ALLIANCE

The victim/survivor may participate in
the investigation by providing interview
testimony

As discussed in the previous section, PSEAH practice differs from GBV
programming in that the organisation is accountable for the actions of theperpetrator. Part of this can include undertaking an investigation.
Organisational SEAH cases do not always
result in an investigation. An investigation
is not always necessary to hold theperpetrator to account, or to provide
redress to the victim/survivor. In somecases, it will be clear that a violation has
occurred, so an investigation will not benecessary. In some cases, reports will bereferred directly to law enforcement.
An investigation will usually only take placewhen:• The report represents a potential breachof organisational PSEAH policy.
• Further information is required todetermine whether policy was breached.
A SEAH investigation is a workplaceadministrative investigation, defined as a“factfinding process involving searching
for, gathering and examining information
to establish facts”.115 A good-practice
SEAH administrative investigation process
follows six steps: 1) investigation planning;2) studying background materials andgathering evidence; 3) updating theinvestigation plan; 4) conducting
interviews; 5) analysis and report writing;and, 6) conclusion and returning ofevidence.116 Throughout this process andat any given point, victims/survivors should

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be kept informed and be able to easily
track the progress of their case.
If the report alleges criminal activity,
it should be referred to the relevant
local authorities. However, in somecircumstances the organisation may decide
not to refer to local authorities if it is not
safe for the victim/survivor.
If well implemented, the SEAH
investigation can be expected to: (i)contribute to the recovery and restorationof dignity of victim/survivor; (ii) holdperpetrators to account; (iii) mitigate
further SEAH perpetrations; and, (iv)strengthen prevention systems by learningfrom every case. However, the risks of
not conducting an appropriate, safe
investigation are high.
In organisations such as UN bodies
where functional and absolute politicalimmunities can be (wrongfully) leveraged
for escaping criminal investigations,or in countries where local laws suchas debauchery laws can deter victims/
survivors of SEAH from filing criminal
complaints, administrative investigations
may be the only conduit for victims/
survivors of SEAH to have their cases
investigated and redressed.

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR© iStock: PeopleImages

WHAT ARE THE CHALLENGES?
Investigations may be seen as the default
response to SEAH cases partly becauseof donor requirements. This can be
debilitating, as organisations – particularly
those that are less-well-resourced– can see
it as an insurmountable barrier to dealing
with SEAH. This can lead to inertia, whereorganisations do not feel they are able toaddress SEAH and therefore do not follow
up on reports and concerns. There is alsoa real challenge around organisations
investigating themselves – often without
any oversight mechanism.

Capacity building
should include
training on victim/
survivor responses andperpetrator dynamics
and patterns

Organisations’ accountability for harmcaused by staff or associated personnel
sometimes conflicts with a victim/
survivor-centred approach when it
comes to investigations. This is because
organisations’ responsibility to investigate
if a staff member caused harm can be hardto honour if a victim/survivor does notconsent to an investigation.
Furthermore, taking a victim/survivor’s
wishes into account can lead to otherissues with an investigation. For example,
the victim/survivor’s wishes may be for theorganisation to dismiss the perpetrator,or they may prefer local restorative justicepractices to an investigation. However,
the organisation is required to follow due
process as required by its own policies
and employment law, and this may be inconflict with the victim/survivor’s wishes.
There is an acknowledged capacity gap inthe sector for trained, skilled investigators– especially women investigators117.
Research by the Safeguarding Resourceand Support Hub’s Country Safeguarding
Assessments118 found investigation capacity
was one of the biggest gaps in countries
assessed. Capacity building should
include training on victim responses andperpetrator dynamics and patterns, rapemyths, representations and traumatisation,with an understanding how these play out
in diverse local contexts.

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When investigations do take place, thequality is variable. The CHS Alliance
Closing the Accountability Gap research
project found evidence of investigators
visiting and conducting investigations at
victims/survivors’ shelters, in full view ofcommunity members, allowing people toassume and speculate about what had
happened.119
Investigations are the area of PSEAH
practice that require the most specificskills, yet it is here that the capacity
gaps in the sector are the greatest. If
not conducted appropriately, the risks ofre-traumatisation and the compromised
safety of victims/survivors in theinvestigation process are high.
Some organisations, particularly UN
agencies, still use the evidentiary standardof “beyond reasonable doubt”, throughwhich is almost impossible to substantiate
in the absence of a confession by theperpetrator(s) and/or video materials
documenting the abuse. Where a “beyond
reasonable doubt” evidentiary standard
is applied, even DNA evidence will not
suffice unless accompanied by a physicalinjury obtained by a third party which
can exclude a consensual act. “Beyond
reasonable doubt” is not an appropriate
evidentiary threshold to use in the context
of administrative SEAH investigations.120
Instead “ balance of probabilities” should
apply. Criticism has been levelled at aid
actors for applying “beyond reasonable
doubt” or the lesser standard of“overwhelming evidence” as unreasonably
high evidentiary thresholds and for being
slow to adopt good practice guidance. It
has been suggested that a reason for this
could be “reputational”, with aid actors
wanting to keep the numbers of reported
and substantiated SEAH allegations low.121

CHS ALLIANCEA SELECTION OF SECTOR GOOD
PRACTICE
Guidance on how to conduct workplaceadministrative investigations into SEAH isavailable in the sector, including the recent
CHS Alliance Sexual Exploitation, Abuse
and Harassment (SEAH) Investigation
Guide.122 CHS Alliance Investigation
Qualification Training Scheme (IQTS)123 isa 4-tiered training scheme that has beendeveloped to build professional skills in
SEAH investigations. This guidance departs
from looking at SEAH as a compliance issue
and instead applies policy and procedure
in a way that mitigates further trauma to
the victim/survivor and considers theirbest interests when decisions are made.
Consideration also needs to be given toinvestigations being impartial and withoutbias – to all involved, including the alleged
perpetrator.
Sector guidance generally follows similar
principles and approaches, most basedon the original ICVA Building Safer
Organisations Guidelines on Receiving andInvestigating Allegations of Abuse andExploitation by Humanitarian Workers.124

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Principles for an SEAH Investigation

Approaches for an SEAH investigation• Confidentiality Investigations must
uphold confidentiality at all times.
Information relating to the case should
be shared only on a limited, need-toknow basis.

The following good practice approaches
can help mitigate further harm to thevictim/survivor during an investigation.

• Commitment to safety, health andwelfare This should include a victim/
survivor-centred approach.
• Good planning and reviewing
Investigations should be thoroughly
planned, including risk assessment.
Planning and risk assessments should be
reviewed and updated throughout theinvestigation process.
• Timeliness Investigations should becompleted on a timely basis, to avoid
further distress to victims/survivors.
• Thoroughness Investigations should be
conducted as thoroughly as possible,
exploring any new information or
disclosures that may arise.
• Professionalism Investigators should beappropriately skilled and trained, and all
staff involved should have a knowledgeof PSEAH principles and approaches.
• Independence The outcomes of theinvestigation should be developed asa result of information collected, andshould not be influenced by otherparties in the investigation.

The investigation team should compriseof a minimum of two people with therelevant skills and contextual knowledge
for conducting a SEAH investigation.
This team should be separate from theindividual or team who will decide theoutcome of the investigation, to ensuretransparency. If the victim/survivor isinterviewed, the interview should be
conducted in a manner which avoids retraumatisation. Many SEAH investigations
use the PEACE model,125 as well as specifictechniques to allow free narrative andavoid judgemental questioning.126 Moredetailed information on conducting an
investigation can be found in the CHS
Alliance Sexual Exploitation, Abuse andHarassment (SEAH) Investigation Guide.
Some organisations offer the victim/
survivor the opportunity to beaccompanied by an independent support
person. This should be someone who is
not involved in the investigation in any
way, and who can help the victim/survivor
navigate the investigation process, andadvocate for their rights and best interests.

• Respect for all involved This should
include a non-judgemental approach.
• Working in partnership Investigations
involve a range of stakeholders whoshould work together for the bestinterests of the victim/survivor.
• Adherence to the law Investigations
should always follow the relevant labour
law of the country where they take place(unless adherence to the law represents
a risk to the victim/survivor).

Offer the victim/
survivor theopportunity to beaccompanied by anindependent support
person.

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WHAT WOULD A VICTIM/SURVIVORCENTRED APPROACH LOOK LIKE?
Using a victim/survivor-centred approachmeans the organisation should consider
whether an investigation is necessary, or
whether there are other, less resourceintense, ways in which the SEAH case canbe resolved that do not risk re-traumatising
the survivor (while ensuring that thealleged perpetrator presents no risk to
those with whom they come into contact).
If an investigation is required, ensure thatthe victim/survivor provides consent,
based on an informed choice where theimplications and potential outcomes of aninvestigation are made clear to them. If thevictim/survivor does not consent, consider
other options for resolving the case.
If it is decided that an investigation isnecessary, consider whether victims/
survivors need to participate – e.g., is their
original report sufficient? Are there other
witnesses that could provide information?
If the decision is made to go ahead withan investigation, this should be done with
PSEAH expert advice, be proceeded bya clear risk assessment127 to ensure thatthe victim/survivor is not exposed to any
further risk or harm and that identified
risks are mitigated. The decision toproceed with an investigation should besigned off confidentially at a senior level ofthe organisation.
When conducting investigations, follow
victim/survivor-focused principles anduse safe and appropriate investigation
protocols. Use only investigators with skills
and experience in interviewing victims/
survivors of SEAH. Review all organisational
procedures to ensure they are traumainformed.

CHS ALLIANCE

The purpose of an investigation is notto judge the victim/survivor but rather
to collect information that upholds ordisproves the allegation. When due
process is followed, it eliminates, as far
as possible, judgements about any of the
stakeholders involved, including the victim/
survivor. An investigation report should
clearly demonstrate to anyone who reads
it how the conclusions were reached on a
factual basis.
Where possible, use “balance of
probability” as the evidentiary threshold.
When SEAH is hard to determine, consider
methodologies such as: nalysing patterns of behaviour of the• A
person against whom the allegation has
been made. Consider whether there is apattern of behaviour that adds credibility
to individual testimony and builds a
coherent picture.
 eighing the credibility of testimony• W
of individual victims/survivors, where
due process allows. Consider whether
the victim/survivor’s testimony issufficient to stand alone in upholding theallegation, on the balance of probability.
Allow the victim/survivor to beaccompanied by a support person
throughout their interaction with theorganisation. This support person should
be unconnected with the organisation andchosen by the victim/survivor.

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6.
ORGANISATIONALDECISION-MAKINGCHS ALLIANCE

As experienced by the victim/survivor

Action by the organisation

The victim/survivor is informed thatthe investigation is complete. Detailsof what is shared vary depending onorganisational policy.

The organisation makes decisions
on next steps to take, for example• If disciplinary procedures are required;• If any other stakeholders need to be
informed of the case;• If any learning can be fed back into theorganisation.

Reports of, and investigations into, SEAH provide information but do not
replace a decision-making process. At various points during a SEAH case,decisions need to be made, often at senior levels of the organisation. These
decisions include• Whether to follow-up on a SEAH report.
• What form that follow-up will take.
• Whether there will be any disciplinary outcomes for staff and what they
may be.
• What actions will be taken (if any) if an investigation is inconclusive.
• What (if any) changes are made to the organisation following learningfrom the case.
These decisions can have enormous
impact on victims/survivors, both incurrent and future cases. However,stakeholders’ experience and cases in the
public domain show that this is the point
at which many organisations fail to act in
the best interests of the victim/survivor,
despite having all the relevant polices
and processes on paper, and making
public commitments to a “zero tolerance
approach”.

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WHAT ARE THE CHALLENGES?
There are many examples of poor
decision-making in SEAH cases in the
sector. Perhaps the most well-known is
the Oxfam GB SEAH case in Haiti, thatwas reported in the media in 2018. In thiscase, the organisation actually had policies
and procedures in place that were able
to detect, if not prevent, the SEAH being
perpetrated by their staff. Where the casewas mishandled was around decisions toignore previous concerns raised about
the perpetrators, not informing theCharity Commission (the UK regulatory
body that governs NGOs) and allowing
the perpetrator to resign rather than facedisciplinary action.128

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Decision-making that is motivated by
the need to protect the organisation,
hide institutional weaknesses or to avoid
tackling difficult and complex situations
is invariably to the detriment of victims/
survivors.

A SELECTION OF SECTOR GOOD
PRACTICE
While there is a wealth of resourceson policies and procedures for PSEAH
available in the sector, there is very little
on decision-making on SEAH cases. As
decisions are made within organisations
and rarely make the public domain, it isdifficult to know how much consistency
and due process exists.
Sharing data on SEAH cases at least allows
some insight into how cases are dealt
with. This data sometimes includes (verybrief) information on the outcome of thecases (e.g., dismissal, report not upheld,etc.). However not all organisations publish
case data and, when they do, they do nottake a common or comparable approachto collecting and reporting information
on cases. Organisations use very different
reporting systems and so information
is not available or useful for analyses tobetter understand the extent of SEAH
in aid work.129 CHS Alliance has recently
produced guidance on sharing data in thehope of resolving this situation, but theresults are yet to be seen.130

WHAT WOULD A VICTIM/SURVIVORCENTRED APPROACH LOOK LIKE?
Decisions should be made in the bestinterests of the victim/survivor, rather thanthe organisation. Disciplinary outcomesfor perpetrators should be consistent, andanonymised data on cases shared in the
public domain, so organisations can beheld to account.
Whistleblowers should not be retaliatedagainst for exposing SEAH cases orreporting malpractice or negligence indealing with SEAH cases by organisations.
All organisations should have at aminimum a whistleblower protection
policy (a “disclosure of malpractice in theworkplace” policy) in place, which is also
upheld in practice.

Decisions should
be made in the bestinterests of the victim/
survivor, rather than theorganisation

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7.
REDRESS AND
COMPENSATIONCHS ALLIANCE

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056

As experienced by the victim/survivor

Action by the organisation

The victim/survivor may receive
compensation from the organisation.
They may also be supported to seek
redress.

The organisation decides whether
redress and/or compensation
are to be provided to the victim/survivor,
and if so, what form these will takeIf not, the victim/survivor may decide toseek redress for themselves, for example
through a legal process or a customary
practice .

One of the most under-resourced and little-discussed areas of work on
PSEAH in the sector is redress and compensation, yet this is the area thatis often of the most significance to victims/survivors.131 Victims/survivors
have a right to justice in the outcomes of SEAH cases, of accountability fromorganisations, and compensation for the harms caused to them. Victims/
survivors’ right to reparation has been recognised under international
human rights law and reflected in several UN Security Council resolutions132
and treaties, such as Article 75 of the Rome Statute of the International
Criminal Court (ICC).133
WHAT ARE THE CHALLENGES?
The needs of victims/survivors are highly
subjective when it comes to justice,and they vary across time and context.
Commonly they involve restitution of rights
and dignity, holding the perpetrator toaccount, and compensating the victim/
survivor for the harm committed. In
addition, there should be guarantees
of non-repetition. Although victims/
survivors’ rights to justice are recognised
in international laws, conventions andtreaties, they remain intangible.134
Historically they have been limited topaternity and custodial complaints andpayments arising out of individual SEAH
cases among peacekeepers, with justice forlarge-scale sexual violence being resolved

through the ICC (though cases of this typeare rare). No action or frameworks exist
when it comes to duty-of-care obligations
owed to people affected by crisis, or
reparations for victims/survivors of SEAH.
SEAH victims/survivors that come forward
do not get the justice outcomes they
deserve, and barriers to justice are many.
Victims have limited information and voicein administrative proceedings and lack themeans to hold organisations accountable.
For organisations themselves, reputationalrisks and priorities take priority overindividual (victim/survivor) concerns andthere is a lack of organisational procedures
for redress. At systemic level, althoughneeded,135,136 there is no oversight entity tohold aid actors to account.137,138

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Criminal accountability
Across countries, SEAH crimes are difficult
to prosecute and can put the victim/
survivor at risk, especially when the victim/
survivor is vulnerable. For people affectedby crises, accessing justice in humanitariansettings is even less likely. Barriers toformal justice systems include: lack ofhost state capacity, lack of knowledge of
local laws, financial and language barriers,transport barriers, fear of reprisals and lackof protections.139,140,141,142
While greater collaboration between
aid actors and criminal authorities isrequired for satisfactory redress forvictims/survivors, it is fraught withchallenges. Aid organisations and theirstaff are subject to national criminal law
and SEAH perpetrations can and should
be prosecuted by the host state undersuch national laws.143 Host states also
have protection obligations.144 Despite
this being standard accountability
requirement145 it rarely happens,146 andhost states frequently “delegate their
responsibilities to UNHCR, which in turn© Unsplash: Ninno JackJR

CHS ALLIANCE

delegates responsibilities to NGOs andother partners”.147 The consequence is
a complex web of informal and formal
justice mechanisms for victims/survivors tonavigate.148
Ethical and practical tensions arise whenorganisations put self-interest and dutyof-care obligations towards the alleged
perpetrator above the justice needs ofthe victims/survivors and the upholding of
national legal requirements in the country
where the SEAH takes place. The common
outcome is that substantiated cases arehandled discretely, with perpetrators beingtransferred, dismissed or repatriated.
Within the UN, perpetrators are also
wrongfully able to leverage politicalimmunity to escape private lawsuits innational courts and no alternative modesof settlement exist for victims/survivors toclaim compensation and redress.149,150
Project Soteria151 was developed
to strengthen the capacity of law
enforcement to investigate, prosecute andarrest those who abuse aid recipients.

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Reparation and compensation
Reparation measures for SEAH victims/
survivors, as employed by somegovernment agencies and religious
institutions,152 are yet to be realised for theaid sector.
Related Personnel,153 and the Interagency
Task Force Victim Assistance Guide
underscore the need for victims/
survivors’ assistance and support; andthat perpetrators should be held legallyand financially accountable. In reality,
this is unlikely to happen as it depends
on the individual responsibility of
perpetrators rather than organisations’legal obligations. Furthermore, the existing
aforementioned frameworks are explicit
about not awarding compensation forvictims/survivors, prioritising individual
and not organisational accountability: “TheStrategy shall in no way diminish or replace
the individual responsibility for acts ofsexual exploitation and abuse, which rests
with the perpetrators. The Strategy is notintended as means for compensation.”154
In 2016 the UN created a Trust Fund insupport of Victims of Sexual Exploitation
and Abuse.155 The Trust Fund makes
grants to UN and non-UN entities andorganisations that provide victim assistanceand support services but does notcompensate individual victims/survivors.
The trust has been criticised on grounds ofaccessibility, as it requires demonstrationof evidence/proof which “due to thedeficient investigations is often lacking”.156
Today no mechanism exists in the aid
sector through which victims/survivors canclaim reparation for SEAH.

Trust funds tend to be implemented as ameans of reparation because of challenges
in achieving compensation throughnational courts.157 For example, in Japan,
through a Women Support Women Fund,
victims/survivors can borrow up to 200,000
yen (approximately US$ 2,000) to use legal
services to prosecute the perpetrator.
The potential for leveraging tort law
frameworks remains interesting but
unexplored.158 In essence, this means
holding organisations liable for harmful
acts of their employees (e.g., SEAH) against
affected people or colleagues and thenclaiming vicarious liability (i.e., that theorganisation was negligent and failed toprevent or mitigate SEAH). This might beeasier for aid worker victims/survivors thancrisis-affected people who are inherently
disadvantaged in terms of producing
evidence, and would require legal aid to
structure such a legal case.
Contextually-appropriate practices
A common challenge in the area of redressis the lack of culturally-appropriate,
contextualised approaches. Althoughinternational organisations claim that
their safeguarding systems are culturally
sensitive, they are usually built according
to these organisations’ experiences, andthey induce local organisations to apply
them following a top-down approach.159
There is a lack of integration of local
practices for redress with organisational
approaches, such as common law andrestorative justice practices160 that may be
preferred by victims/survivors as pathways
to redress. Issues can arise when thesepractices are in conflict with organisations’policies or labour law. Sometimes, enablingthese processes can conflict with theorganisation’s duty of care to the alleged
perpetrator, who is their staff member.

VICTIM/SURVIVOR-CENTRED APPROACH TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORA SELECTION OF SECTOR GOOD
PRACTICE
There is very little good practice available
on redress and compensation in the sector.
The IASC Victim Assistance protocol, withaccompanying technical note and training,
outlines a common set of norms andstandards based on existing frameworks
to strengthen a coordinated, system-wide
approach to the provision of assistanceand support, which prioritises the rights
and dignity of victims/survivors of sexual
exploitation and abuse.161 However, it
does not address the wider issues aroundcultural practices for redress and financial
compensation.

WHAT WOULD A VICTIM/SURVIVORCENTRED APPROACH LOOK LIKE?
Victims/survivors have a right toreparation, but this right is practically
impossible to exercise. Aid actors havean administrative and legal obligation
to ensure redress for victims/survivorsof SEAH, but no redress and reparations
mechanism for victims/survivors of
SEAH exist in the aid sector. Aid actors
thus neglect and ignore their legal andadministrative obligations to provide
justice to victims/survivors, focusing on
perpetration (reporting and investigations)at the expense of the victims/survivors’
justice rights.
SEAH is deemed a criminal act in mostnational legislation, and taking a SEAH
complaint through the justice system
can be both financially and emotionallytaxing for victims/survivors. Legal aid could
be facilitated through aid organisations
to avoid victims/survivors’ experiences
going unrecorded and without remedy
and justice. Legal insurance, legal aid
and funding for legal aid can likely
support victims/survivors in their criminal
accountability pursuits but this will not
solve the problem. Aid actors must commit
to action redress for victims/survivors.

CHS ALLIANCE

Common justifications for not doing so
include that it would be inappropriate
to use public funds to settle claims.162
This however cannot be a justification
for doing nothing at all. The aid sector
must agree on a framework for redress,
including reparations, compensation andrestitution, and ensure due diligencethrough independent oversight. Such an
endeavour must involve victims/survivors
in its design, implementation, monitoringand evaluation. This is probably the mostmeaningful contribution that can be madein terms of ensuring accountability for SEAH
and to ensure individual, organisational andcollective accountability in the aid sector.
Donors could reinforce this by including
measures for accountability and redressin their compliance requirements fororganisations seeking funds.
Where possible, organisations should be ledby the victim/survivor’s wishes for redress –for example, legal recourse or common law
or restorative justice practices.
Organisations could look to their existing
compensation policies for harms other than
SEAH, for example, road traffic accidents
where the organisation is at fault. These
policies should at a minimum form part ofpractice on compensation cases of SEAH.
Specifically, organisations should consider
financial compensation as is usual in otherworkplace malpractice cases.

The aid sector
must agree on aframework for redress,
including reparations,compensation andrestitution, and ensure
due diligence throughindependent oversight.

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORCONCLUSION
An accountability chain is never stronger than its weakest link – from the person entrustedwith the first disclosure to the person who takes the first report; and from the persons
involved in providing care and support to those managing the case, those investigating
the case and writing the report and the final person who decides on redress and provides
reparation. All must all be better informed, capacitated and sensitised to the experiencethrough which a SEAH victim/survivor undergoes.
This paper has tried to expose the concerns, challenges, gaps and barriers in the aid sector’s
response to SEAH. Coupled with the vulnerabilities inherent in the SEAH experience, it
is argued that it is the role of aid actors to anticipate, accommodate and mitigate suchchallenges and vulnerabilities by taking a victim/survivor-centred approach to SEAH. This
paper has summarised good practice as used by feminists, criminologists, police agencies,
NGOs/INGOs, healthcare providers, councillors, social workers, victim advocates, therapists,
educators, specialist trauma practitioners, psychiatrists, psychologists and legislators. A
summary of what a victim/survivor-centred approach could look like based on this goodpractice follows.
This global framework will serve to guide the remainder of the project entitled Closing the
Accountability Gap to Better Protect Victims/Survivors of SEAH in the Aid Sector and will be
adapted at the end of the project (as required) according to the lessons learned from thepilot interventions in three humanitarian contexts and then finally turned into a replicableand scalable guideline.

© Unsplash: Tim Mossholder

VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORCHS ALLIANCE

Stage

As experienced by victim/survivor

Disclosure

Organisations are aware and prepared to receive disclosures made to anyone in the organisation through any means, not just designated staff and reporting
channels.
Staff who are likely to come into contact with members of the community have (at a minimum) basic training on how to receive a disclosure. This should
include how to respond in a way that prevents further traumatisation.
All staff and associated personnel know how to confidentially refer any disclosures made to them to the designated team or staff member.
Victims/survivors are not influenced to disclose, for the interests of others or perceived benefit to the victim/survivor – for example to prevent theperpetrator from abusing others, or because of a belief that the process might be “cathartic” for the victim/survivor.

Reportingmechanisms

Organisations recognise that the burden of reporting SEAH should not be placed on victims/survivors and communities. They are more proactive in analysing
SEAH risk and proactively identifying where perpetration is occurring.
Organisations recognise the role that trusted intermediaries play in reporting SEAH, both within and external to the organisation (for example members of
the community, or GBV actors) and, where appropriate, work with them on receiving and referring disclosures safely and confidentially.
Organisations have trained PSEAH focal points in place that replicate this “trusted intermediary” approach.
Organisations have reporting channels in place that have been designed in consultation with different groups in communities and are safe, accessible,
appropriate and confidential – but the organisation does not rely solely on these channels to bring SEAH to their attention.
For organisations with more resources, “third party” mechanisms to handle disclosures are considered that are external to the organisation and can offer
an opportunity to disclose anonymously, or for the victim/survivor to decide whether their disclosure is shared with the organisation. Any mechanisms used
are quality assured to check they are capable to handling serious and complex SEAH disclosures. These “third party” mechanisms should not replace staff
training on receiving disclosures (see Disclosure).

Report handling andcase management

Victims/survivors are treated as unique individuals who are experts in their situation.
Report handling and case management systems are designed with vulnerable and at-risk groups in mind, such as children, people of different sexual
orientation or gender identify expression, people living with disabilities and male survivors.
Case management teams (or individuals in less-resourced organisations) are appointed to coordinate consistent support and decision-making on the case.
The victim/survivor’s consent is sought by the organisation before following up on a SEAH report or disclosure.
When victims/survivors do not consent, the organisation balances its decision-making with the risk that the perpetrator may pose to those they come into
contact with and considers alternative actions where possible.
The survivor is supported to access services, should they wish to do so, as soon as the organisation receives a report. Treatment, care and support for
victims/survivors of SEAH should be multidisciplinary and trauma informed and generally include access to medical and psychosocial support.
Organisations are honest with victims/survivors about what will happen if they wish to proceed with a report of SEAH. The case management andinvestigation processes are outlined, including the potential outcomes of the case – and the limitations on what may be possible in terms of disciplinary
procedures for the perpetrator. The victim/survivor is able to make an informed decision on what they consent to in the process.
Organisations allow anonymous reports and have no statute of limitations on making reports of SEAH.
Victims/survivors are provided with support for as long as needed, at the pace of the victim/survivor.
Pseudonyms and data codification are used to preserve the anonymity and confidentiality of the victim/survivor.

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Stage

As experienced by victim/survivor

Referral tosupport services

Comprehensive support-service mapping is undertaken before the organisation receives a SEAH report. Services are identified that are safe for victims/
survivors, particularly those who may be at increased risk. Services that are mapped take local context and custom into account. Support service mappings
are shared between organisations.
Victims/survivors are proactively assisted to access services, where desired. This should take place at the victim/survivor’s pace, even if this does not fit withorganisational case management and investigation timeframes.
Cases involving children aged under 18 years are always referred to appropriate services when it is safe to do so.

Investigation

Organisations consider whether an investigation is necessary, or whether there are other ways in which the SEAH case can be resolved that do not risk retraumatising the survivor, but can still ensure that the alleged perpetrator does not present a risk of harm to those with whom they come into contact.
If an investigation is required, the victim/survivor provides consent based on an informed choice where the implications and potential outcomes of aninvestigation are made clear to them. If the victim/survivor does not consent, other options for resolving the case are considered (see above).
When organisations decide an investigation is necessary, they consider whether victims/survivors need to participate, or whether the investigation can be
conducted using other approaches.
When conducting investigations, organisations follow principles, use investigators trained and experienced in victim/survivor-centred approaches and use
safe and appropriate investigation protocols.
Organisations review all investigation and case management process to ensure they are trauma-informed.
Investigations are transparent and impartial and do not judge the victim/survivor.
Where possible, “balance of probability” is used as the evidentiary threshold.
Victims/survivors are accompanied by a support person throughout their interaction with the organisation, if they wish to be. This support person should be
unconnected with the organisation, and chosen by the victim/survivor.

Organisational
decision making

Decisions are made in the best interests of the victim/survivor, rather than the organisation.

Redress &compensation

Organisations are aware of and committed to their administrative and legal obligation to ensure redress for victims/survivors of SEAH.

Disciplinary outcomes for perpetrators are consistent and anonymised data on cases shared in the public domain so organisations can be held to account.
Whistleblowers are not retaliated against for exposing SEAH cases or reporting malpractice or negligence in dealing with SEAH cases by organisations. All
organisations should have (at a minimum) a whistleblower protection policy (disclosure of malpractice in the workplace policy) in place, which is also upheldin practice.

Where possible, organisations support the victim/survivor’s wishes for redress – for example legal recourse, or common law or restorative justice practices.
Where the SEAH is a criminal act, legal aid is facilitated for victims/survivors if they wish to pursue legal recourse.
Organisations look to their existing compensation policies for harms other than SEAH, for example road traffic accidents where the organisation is at fault, toinform practice on compensation cases of SEAH. Specifically, organisations consider financial compensation as is usual in other workplace malpractice cases.

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Glossary
Accountability to Affected People – theprocess of using power responsibly. It
involves taking account of, and being held
accountable to those who are primarily
affected by the exercise of such power
Affected people – the individuals, groups
and communities that are affected by ahumanitarian crisis. This can also be used
to refer to populations affected by issuesof development.
Associated personnel – includes (but is
not limited to) consultants, volunteers,
contractors, programme visitors including
journalists, celebrities and politicians
engaged with work on behalf of the aidorganisation in question.
At-risk adults
1. Any person aged 18 years andolder who may be at risk of abuse or
exploitation due to their dependenceor reliance on others for services, basic
needs or protection, and according tocontext, for example, in humanitariansituations.
2. An adult may also be at risk/vulnerable
when in a relationship (social- or workrelated) with another who seeks tomisuse their position of authority ortrust to control, coerce, manipulate or
dominate them.
3. An adult may also be at risk if theirdecision-making capacity is impaired and/or they do not have the support to makethe decision. Being at risk is not a “fixed”
characteristic but can change becauseof a range of factors, or over time. For
example, a person living with a disability
may not be at risk in their regularenvironment but may become so if they
are displaced and are separated fromtheir usual coping mechanisms.
Child – any individual under the age of18 years, irrespective of local country
definitions of when a child reaches
adulthood.
Child protection – preventing andresponding to violence, exploitation andabuse against children – including (but notlimited to] commercial sexual exploitation,
trafficking, child labour and harmful
traditional practices.
Civil society organisations – nongovernmental, non-profit organisations

that operate independently of
government and business. They are
typically run by citizens who arecommitted to addressing social, economic
and political issues in their community.
CSOs can include charitable organisations,advocacy groups, community-basedorganisations and professional
associations.
Code of conduct – a set of standards
about behaviour to which staff andvolunteers of an organisation are obliged
to adhere.
Community-based complaints
mechanism – a system blending
both formal and informal community
structures, built on engagement with thecommunity where individuals are able andencouraged to safely report grievances– including SEAH incidents – and thosereports are referred to the appropriate
entities for follow-up.
Community-based women networks –groups of women who come together tosupport one another and address issues
that affect them within their community.
These networks often focus on issues
such as gender equality, women’s
rights and economic empowerment for
women. They may provide resources,
education and advocacy for women in thecommunity, and often work in partnershipwith other organisations to achieve theirgoals.
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.
Complainant – the person making thecomplaint, including the alleged victim/
survivor of the sexual exploitation, abuseor harassment, or another person who
becomes aware of the wrongdoing.
Complaint mechanism or procedure– processes that allow individuals toreport concerns such as breaches oforganisational policies or codes ofconduct.
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 for the purpose of concluding theinvestigation. Confidentiality helps create
an environment in which witnesses are
more willing to recount their versions ofevents and builds trust in the system andin the organisation.
Core Humanitarian Standard on Quality
and Accountability – sets out Nine
Commitments that organisations can –and should – make to people affectedby crises or situations of vulnerability todeliver quality, effective and accountablesupport and assistance. As a core
standard, the CHS describes the essential
elements of principled, accountable andhigh-quality support and assistance.
Focal point – a person designated toreceive reports of cases of SEAH andsupport the organisation in implementing
PSEAH.
Gender-based violence (GBV) – refers to
any form of violence that is directed at anindividual based on their gender. This can
include physical, sexual, emotional andpsychological violence.
International non-governmentalorganisations (INGOs) - non-profit
organisations that operate on a global
scale, with offices and operations in
multiple countries. They are typicallyfocused on addressing global issues suchas humanitarian action, development,
human rights and environmental
protection.
Investigation of sexual exploitation,
abuse or harassment – an internal
administrative procedure by which
an organisation attempts to establish
whether there has been a breach of SEAH
policies by a staff members or associatedpersonnel.
Participatory action research – a methodof enquiry in which community members
actively participate in the research
process. It is an approach that emphasises
collaboration and empowerment, with thegoal of addressing issues and promoting
positive change in the community. It
often involves a cyclical process of datacollection and analysis, reflection andaction planning, with the aim of creatingknowledge that is relevant and useful tothe community.

VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORPSEAH (Protection from Sexual
Exploitation and Abuse and Sexual
Harassment) – the term used by thoseworking in the international humanitarianand development sector to refer tomeasures taken to protect people fromsexual exploitation, abuse and harassmentby their own staff and associatedpersonnel.
Redress – refers to the process of making
amends or providing compensation forharm or injury that has been suffered.
Redress refers to actions taken toaddress violations or abuses that haveoccurred and to provide justice forvictims/survivors. This can include legal
or administrative action, as well as
reparations for harm suffered.
Referral pathway – the various supportand referral services available to victims/
survivors of SEAH.
Report – where an individual orindividuals report a concern regarding
SEAH.
Reparations - refers to the process ofproviding compensation for harm or
injury that has been suffered as a resultof human rights violations. It can include
a range of measures such as monetarycompensation, restitution, rehabilitation
or a formal apology. Reparations aim toaddress the harm caused by the violations
and to bring closure to the victims/
survivors while helping them to move
forward with their lives.
Restitution – refers to the act of returning
something that was taken or lost to its
rightful owner or to compensate forthe loss. It is a form of redress for aharm or injury that has been suffered.
Restitution is considered as one of themost important steps in the process of
reparations and it is a way to repair theharm that has been done and to restore
the dignity of the victims/survivors.
Safeguarding – the responsibility oforganisations to make sure their staff,
operations and programmes do noharm to children and adults at-risk nor
expose them to abuse or exploitation.
This term covers physical, emotionaland sexual harassment, exploitation andabuse by staff and associated personnel,
as well as safeguarding risks caused byprogramme design and implementation.
Many organisations now also use thisterm to cover harm caused to staff in theworkplace.
SEAH – the term used to refer tosexual exploitation, abuse and sexual
harassment.
Sexual abuse – an actual or threatened
physical intrusion of a sexual nature,whether by force or under unequal or
coercive conditions.
Sexual and gender-based violence(SGBV) – refers to any form of violence
that is directed at an individual based on
their gender or sexual identity. This can
include physical, sexual, emotional andpsychological violence. SGBV can takemany forms, including rape, domestic
violence and sexual harassment. It canalso include harmful traditional practices
such as female genital mutilation,
child marriage and forced marriage. It
disproportionately affects women andgirls, but men and boys can also beaffected
Sexual exploitation – any actual orattempted abuse of a position ofvulnerability, differential power or trust
for sexual purposes, including, but notlimited to, profiting monetarily, socially or
politically from the sexual exploitation ofanother.
Sexual harassment – a continuum of
unacceptable and unwelcome behaviours
and practices of a sexual nature that may
include, but are not limited to, sexualsuggestions or demands, requests forsexual favours and sexual, verbal or
physical conduct or gestures that are(or might reasonably be perceived as
being) offensive or humiliating. Sexual
harassment has widely been understoodto relate to the workplace but is also
included in the spectrum of behaviours
that are not acceptable conduct by staff,
be it in the workplace or with affected
populations.
Sexual misconduct – includes sexual
harassment, sexual exploitation andsexual abuse.
Victim/survivor – the person who is, or
has been, sexually exploited, abused or
harassed. The term “survivor” implies
strength, resilience and the capacity to

CHS ALLIANCE

survive. The term “victim” has protective
implications, as it implies the victim of an
injustice which we should seek to redress.
Therefore, this resource uses both terms.
People who have experienced SEAH may
choose different terms to describe theirexperience.
Trauma-informed approach – a wayof understanding and responding toindividuals who have experienced
trauma. It involves recognising theimpact of trauma on individuals and their
behaviour, and making adjustments inpolicies and practices to better support
them. This approach emphasises safety,
trustworthiness, choice, collaborationand empowerment. It also includes
understanding the prevalence of trauma
and its effects, and creating a traumasensitive environment.
Victim/survivor-centred approach – anapproach in which the victim/survivor’s
wishes, safety and well-being remain apriority in all matters and procedures.
Violence against women (VAW) – refers
to any form of violence that is directed
specifically at women and girls, based on
their gender. VAW is a violation of humanrights and can have long-lasting physicaland emotional consequences for victims/
survivors. It is a serious problem that
affects women of all ages, backgrounds
and cultures
Whistleblower protection policy(or disclosure of malpractice in theworkplace policy) – a policy thatencourages staff members to reportconcerns, the disclosure of which are
typically in the public interest, particularly
in countries where whistleblowing ispart of national legislation. Concerns
are typically those regarding a criminal
offence, health and safety, damage to theenvironment or miscarriage of justice.
Reporting on PSEAH can fall within an
organisation’s whistleblower protection
policy. Whistleblowers are often protectedby law and cannot be treated unfairly or
lose their job because they report theseconcerns.

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORENDNOTES
1
CHS Alliance (2020) PSEAH Implementation
Quick Reference Handbook. Available at: https://www.chsalliance.org/get-support/resource/pseah-implementation-quick-referencehandbook/United Nations Secretariat (9 October 2003)
Secretary General’s Bulletin on Special Measuresfor Protection from Sexual Abuse and Sexual
Exploitation, 2003/13 (ST/SGB/2003/13), New
York: United Nations.

2

3

Ibid

Endorsed in the UN General Assembly
Resolution A/RES/73/148 on 17th December
2018.

4

CHS Alliance (2020) PSEAH Implementation
Quick Reference Handbook. Available at: https://www.chsalliance.org/get-support/resource/pseah-implementation-quick-referencehandbook/
5

IDC (2018). Sexual exploitation and abusein the aid sector inquiry. House of CommonsInternational Development Commitment

6

Naik, Asmita (2022) Tackling sexual exploitation
and abuse by aid workers: what has changed 20
years on? ODI Humanitarian Practice Network,
Issue 14, Article 4. Available at: https://odihpn.
org/publication/tackling-sexual-exploitation-andabuse-by-aid-workers-what-has-changed-20years-on/

7

Birchall, J. (2020). NGO collection and reportingof data on sexual exploitation, abuse andharassment. K4D Helpdesk Report 778. Brighton,
UK: Institute of Development Studies. Available
at: https://opendocs.ids.ac.uk/opendocs/
handle/20.500.12413/15287?show=full

8

See: https://corehumanitarianstandard.org/
the-standard

910
https://www.oecd.org/dac/genderdevelopment/dac-recommendation-on-endingsexual-exploitation-abuse-and-harassment.htm

inter-agency-standing-committee/iasc-six-coreprinciples-relating-sexual-exploitation-andabuse-201916
United Nations Office of the HighCommissioner (OHCHR) (2019) Protection of
victim of sexual violence: Lessons learned,
Workshop report
17

Ibid

Singh, S. B. (2014) Victimization and Victim
Impact Statements: An Analysis of theConsequences on Victims of Crime and the Aimsof the South African Victim Charter. International
Journal of Social Studies, 118

McMillan, L., & Thomas, M. (2009). Police
interviews of rape victims: tensions andcontradictions. In M. Horvath, & J. Brown (Eds.),
Rape: Challenging Contemporary Thinking Willan
Publishing.
19

20
World Health Organization (2002) Vaginal
bleeding, fibroids, chronic pelvic pain, andurinary tract infections; and sexually transmitted
diseases (STDs) including HIV/AIDS. Available
at: http://apps.who.int/iris/bitstream/
handle/10665/77434/WHO_RHR_12.37_eng.pdf
21
Bartol, C. R., & Bartol, A. M. (2008). Criminal
behavior: A psychosocial approach. Upper Saddle
River, NJ: Pearson Prentice Hall
22
Long, L., & Butler, B. (2018). Sexual assault. The
Obstetrician & Gynaecologist, 20(2)Macy, R. J., Giattina, M. C., Montijo, N. J., &Ermentrout, D. M. (2010). Domestic violenceand sexual assault agency directors’ perspectives
on services that help survivors. Violence Against
Women, 16(10)CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
23

IASC) Principals (2015) Protection from Sexual
exploitation and Abuse Statement by the InterAgency Standing Committee. Note that several
definitions are currently in circulation for the
IASC. This definition is currently being updated
and a new version will be available soon.

24
Singh, S. B. (2014) Victimization and Victim
Impact Statements: An Analysis of theConsequences on Victims of Crime and the Aimsof the South African Victim Charter. International
Journal of Social Studies, 1

Countryman-Roswurm, K. (2015). Rise,
unite, support: Doing “no harm” in the antitrafficking movement. Slavery Today Journal: A
Multidisciplinary Journal of Human Trafficking
Solutions, 2, 1. URL via Safeguarding Resourceand Support Hub Tipsheet Engaging Survivorsof SEAH

Crowell, N. A., & Burgess, A. W. (Eds.). (1996).
Understanding violence against women.
American Psychological Association. https://doi.
org/10.1037/10204-000

11

12

A victim/survivor-centred approach places therights, needs, safety, dignity and well-being of thevictim/survivor at the centre of all preventativeand responsive measures concerning sexual
exploitation, sexual abuse and sexual harassment.
13

14
The extent to which these stages areappropriate for different communities, culturalcontexts and settings will be examined throughpilot projects in three humanitarian settings.
15
IASC (2019) IASC Six Core Principles Relating
to Sexual Exploitation and Abuse. Available at:https://interagencystandingcommittee.org/

25

Ibid

26

27
Carson, K. W., Babad, S., Brown, E. J., &Nikulina, V. (2021). Why do women talk about
it? Reasons for disclosure of sexual victimization
and associated symptomology. Violence against
women, 27
28
Ahrens CE, Stansell J, Jennings A.(2010) To
tell or not to tell: the impact of disclosure on
sexual assault survivors’ recovery. Violence Vict.
2010;25(5). doi: 10.1891/0886-6708.25.5.631.
PMID: 21061869.
29
Ahrens, C. E., Campbell, R., Ternier-Thames,
N. K., Wasco, S. M., & Sefl, T. (2007). Deciding
whom to tell: Expectations and outcomes of rape
survivors’ first disclosures. Psychology of Women
Quarterly, 31(1)30Campbell, R., Dworkin, E., & Cabral, G.
(2009). An ecological model of the impactof sexual assault on women’s mental health.
Trauma, violence & abuse, 10(3). https://doi.
org/10.1177/1524838009334456; Ullman, S. E.
(2000). Psychometric Characteristics of the Social
Reactions Questionnaire: A Measure of Reactions
to Sexual Assault Victims. Psychology of Women
Quarterly, 24(3)31Weiss, K. G. (2011). Neutralizing sexual
victimization: A typology of victims’ non-reporting
accounts. Theoretical Criminology, 15(4).https://doi.org/10.1177/1362480610391527
32
Ettinger T. R. (2022). Children’s needs during
disclosures of abuse. SN social sciences, 2(7),101. https://link.springer.com/article/10.1007/
s43545-022-00397-6
33
Campbell, R., Ahrens, C. E., Sefl, T., Wasco,
S. M., & Barnes, H. E. (2001). Social reactions
to rape victims: healing and hurtful effects on
psychological and physical health outcomes.
Violence and victims, 16(3).
34
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
35
Gjika, A. and Marganski, A. J. (2020) “Silent
Voices, Hidden Stories: A Review of Sexual
Assault (Non)Disclosure Literature, Emerging
Issues, and Call to Action”, International Journalfor Crime, Justice and Social Democracy, 9(4). doi:
10.5204/ijcjsd.v9i4.1439.
36
Curry, M. A., Renker, P., Robinson-Whelen, S.,
Hughes, R. B., Swank, P., Oschwald, M., & Powers,
L. E. (2011). Facilitators and barriers to disclosing
abuse among women with disabilities. Violenceand victims, 26(4)37
Easton, S. D., Saltzman, L. Y., & Willis, D. G.
(2014). “Would you tell under circumstances
like that?”: Barriers to disclosure of child sexual
abuse for men. Psychology of Men & Masculinity,
15(4), 460.
38
Bryant-Davis, T., Chung, H., & Tillman, S.
(2009). From the margins to the center. Trauma,
Violence, & Abuse, 10(4).
39Golding, J. M., Siege, J. M., Sorenson, S. B.,
Burnam, M. A., & Stein, J. A. (1989). Social
support sources following sexual assault. Journalof Community Psychology, 17(1).
40

Ibid

Ahrens, C. E., Cabral, G., & Abeling, S. (2009).
Healing or hurtful: Sexual assault survivors’interpretations of social reactions from support
providers. Psychology of Women Quarterly,
33(1). https://doi.org/10.1111/j.14716402.2008.01476.x; Dworkin, E. R., Ojalehto, H.,
Bedard-Gilligan, M. A., Cadigan, J. M., & Kaysen,
D. (2018). Social support predicts reductions
in PTSD symptoms when substances are notused to cope: A longitudinal study of sexualassault survivors. Journal of affective disorders,
229; Filipas, H. H., & Ullman, S. E. (2001). Social
reactions to sexual assault victims from various
support sources. Violence and victims, 16(6)41VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR

42
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/

Dworkin, E. R., Brill, C. D., & Ullman, S.
E. (2019). Social reactions to disclosure ofinterpersonal violence and psychopathology:
A systematic review and meta-analysis. Clinicalpsychology review, 72, 101750.
43

Ullman, S. E. (2010). Social reactions and theireffects on survivors. In S. E. Ullman, Talking about
sexual assault: Society’s response to survivors.
American Psychological Association. Ullman, S. E.
(2000). Psychometric Characteristics of the Social
Reactions Questionnaire: A Measure of Reactions
to Sexual Assault Victims. Psychology of Women
Quarterly, 24(3)4445
Borja, S. E., Callahan, J. L., & Rambo, P. L.
(2009). Understanding negative outcomes
following traumatic exposure: The roles ofneuroticism and social support. PsychologicalTrauma: Theory, Research, Practice, andPolicy, 1(2), 118; Campbell, R., Ahrens, C. E.,
Sefl, T., Wasco, S. M., & Barnes, H. E. (2001).
Social reactions to rape victims: healing andhurtful effects on psychological and physicalhealth outcomes. Violence and victims, 16(3);Jacques-Tiura, A. J., Tkatch, R., Abbey, A., &Wegner, R. (2010). Disclosure of sexual assault:
Characteristics and implications for posttraumaticstress symptoms among African American
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impact of social support and negative disclosure
reactions on sexual assault victims: A crosssectional and longitudinal investigation. Journalof Trauma & Dissociation, 11(2); Sigurvinsdottir,
R., & Ullman, S. E. (2016). Sexual orientation,
race, and trauma as predictors of sexual assault
recovery. Journal of family violence, 31(7);46Sigurvinsdottir, R., & Ullman, S. E. (2016).
Sexual orientation, race, and trauma as predictorsof sexual assault recovery. Journal of family
violence, 31(7)Relyea, M., & Ullman, S. (2015). Unsupported
or Turned Against: Understanding How Two
Types of Negative Social Reactions to Sexual
Assault Relate to Post-Assault Outcomes.
Psychology of women quarterly, 39(1), https://doi.org/10.1177/0361684313512610
47

Dworkin, E. R., Brill, C. D., & Ullman, S.
E. (2019). Social reactions to disclosure ofinterpersonal violence and psychopathology:
A systematic review and meta-analysis. Clinicalpsychology review, 72, 101750.

for Crime, Justice and Social Democracy, 9(4). doi:
10.5204/ijcjsd.v9i4.1439.
53

Ibid

Regnedda, M., & Muschert, G. W. (2013). The
Digital Divide. The Internet and social inequalities
in international perspective. New York, 10,9780203069769
54

55

Ibid

56

See: https://sawa.ps/en/

57

See: https://www.talktoloop.org/

See: https://gbvguidelines.org/en/
pocketguide/58

59
For example, the British Council Guidance on
Handling a Disclosure form a Child. Available
at: https://www.britishcouncil.org/education/accreditation/information-centres/care-children
60
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
61

Ibid

62
Galleguillos, S., & Pugliese, K. (2022). The
United Nations victim approach revisited: areview of the literature on sexual assault andgender-based violence hotlines. Violence against
women, 10778012221086001
63
Macy, R. J., Giattina, M., Sangster, T. H., Crosby,
C., & Montijo, N. J. (2009). Domestic violenceand sexual assault services: Inside the black box.
Aggression and Violent Behavior, 14(5)64McDonnell, K., Nagaraj, N., Mead, K.,
Bingenheimer, J., Stevens, H., Gianattasio, K., &Wood, S. (2018). An Evaluation of the National
Domestic Violence Hotline and loveisrespect.
65
Feeney, H. (2019). “ Need to talk”: A latentclass analysis of sexual victimization disclosure toa national sexual assault online hotline (Doctoral
dissertation, Michigan State University). Available
at: https://www.proquest.com/openview/b5e461
37b7624d4d09e376e9b0e65216/1?pq-origsite=gscholar&cbl=18750&diss=y66
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
67

48

Ibid

Resource and Support Hub (2022) PSEAH Focal
Point Role and Responsibilities. Available at:https://safeguardingsupporthub.org/documents/
pseah-focal-point-role-and-responsibilities
68

Aziz, Z. (2017). Due Diligence andAccountability for Online Violence Against
Women.

Birchall, J. (2020). NGO collection and reportingof data on sexual exploitation, abuse andharassment. K4D Helpdesk Report 778. Brighton,
UK: Institute of Development Studies. Available
at: https://opendocs.ids.ac.uk/opendocs/
handle/20.500.12413/15287?show=full

52
Gjika, A. and Marganski, A. J. (2020) “Silent
Voices, Hidden Stories: A Review of Sexual
Assault (Non)Disclosure Literature, Emerging
Issues, and Call to Action”, International Journal

70
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closing-

49

Ibid

50

Ibid

51

69

CHS ALLIANCE

the-accountability-gap-country-assessmentreport-phase-1/
71
CHS Alliance (2020) PSEAH Index. Available
at: https://www.chsalliance.org/get-support/
resource/pseah-index/
72
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
73
Semler, M. (2019). Factors Influencing
Misconduct Reporting in Kachin, Myanmar.
Available at : https://oxfamilibrary.
openrepository.com/bitstream/
handle/10546/620893/cs-misconduct-reportingkachin-myanmar-121119-en.pdf?sequence=1
74
CHS Alliance (2020) Non-disclosure agreements– CHS Alliance Guidance Note. Available at:https://www.chsalliance.org/get-support/
resource/non-disclosure-agreements-guidancenote/
75
Young, S. M., Pruett, J. A., & Colvin, M. L.
(2018). Comparing help-seeking behavior of maleand female survivors of sexual assault: A content
analysis of a hotline. Sexual Abuse, 30(4).
76Colvin, M. L., Pruett, J. A., Young, S. M., &Holosko, M. J. (2017). An exploratory case studyof a sexual assault telephone hotline: Training
and practice implications. Violence against
women, 23(8)77
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
78

CHS Alliance PSEAH community of PracticeFlummerfelt, R., Peyton, N. ‘More than 50
women accuse aid workers of sex abuse inCongo Ebola crisis’, The New Humanitarian 29
September 2020. Available at: https://www.
thenewhumanitarian.org/2020/09/29/exclusivemore-50-women-accuse-aid-workers-sex-abusecongo-ebola-crisis. Retrieved 30 September
2022.
79

80

CHS Alliance PSEAH community of Practice

CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
81

82

Ibid

Resource and Support Hub (2021) Contextual
communications for safeguarding (video).
Available at: https://safeguardingsupporthub.
org/webinars/contextual-communicationssafeguarding
83

84
See: https://www.chsalliance.org/get-support/
resources/accountability/
85
See: https://corehumanitarianstandard.org/
language-versions
86

From Aga Khan Foundation (2021) Developing

066

067

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VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTORENDNOTES
survivor-focused CBCMs in Consultation with
Communities

at: https://www.bond.org.uk/resources/
safeguarding-policy-templates

87
IASC, IOM, Save the Children, UNHCR (2016)
Best Practice Guide on inter-agency CBCMs
https://psea.interagencystandingcommittee.
org/resources/best-practice-guide-inter-agencycbcms

102

CHS Alliance (2020) PSEAH Implementation
Quick Reference Handbook. Available at: https://www.chsalliance.org/get-support/resource/pseah-implementation-quick-referencehandbook/88

89
See: https://psea.
interagencystandingcommittee.org/
90
Garwin, A (2021) How to Design andManage Community-based Complaints
Mechanisms (CBCM) Available at: https://
safeguardingsupporthub.org/documents/
how-design-and-manage-community-basedcomplaints-mechanisms-cbcm

From Aga Khan Foundation (2021) Developing
survivor-focused CBCMs in Consultation with
Communities

91

92
GBV IMS Steering Committee (2017)
Interagency Gender-based Violence CaseManagement. Available at: https://reliefweb.
int/report/world/interagency-gender-basedviolence-case-management-guidelines93
EISF (2017) Managing Sexual Violence against
Aid Workers. Available at: https://gisf.ngo/wpcontent/uploads/2019/03/Managing-SexualViolence-against-Aid-Workers.pdf
94
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
95

Olusese, A., & Hingley, C. (2019)96

Bys & Clare, Humanitarian Exchange (2022)

GBV IMS Steering Committee (2017)
Interagency Gender-based Violence CaseManagement. Available at: https://reliefweb.
int/report/world/interagency-gender-basedviolence-case-management-guidelines
97

98

Murad Code 2022

99
Golding, J. M., Siege, J. M., Sorenson, S. B.,
Burnam, M. A., & Stein, J. A. (1989). Social
support sources following sexual assault. Journalof Community Psychology, 17(1), 92-107; UK
Foreign Office (2017) International Protocol on
the Documentation and Investigation of Sexual
Violence in Conflict. Available at: https://www.
un.org/sexualviolenceinconflict/wp-content/
uploads/2019/06/report/international-protocolon-the-documentation-and-investigationof-sexual-violence-in-conflict/International_
Protocol_2017_2nd_Edition.pdf

Alliance for Child Protection in Humanitarian
Action (2022) Standard Operating Procedures(SOPs) Template. Available at: https://www.
alliancecpha.org/en/technical-materials/
standard-operating-procedures-sops-template

100

Bond (2018) Safeguarding policy templates:
Dealing with Safeguarding Reports. Available

101

EISF (2017) Managing Sexual Violence against
Aid Workers. Available at: https://gisf.ngo/wpcontent/uploads/2019/03/Managing-SexualViolence-against-Aid-Workers.pdf
Bufacchi, V. (2018). Victims, Their Stories, and
Our Rights. Metaphilosophy, 49

103

104
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/

Crowell, N. A., & Burgess, A. W. (Eds.).
(1996). Understanding violence against women.
American Psychological Association. https://doi.
org/10.1037/10204-000

105Long, L., & Butler, B. (2018). Sexual assault.
The Obstetrician & Gynaecologist, 20(2)106

Riddle, A. M. (2018). Best-Practice Treatment
Approaches for Working with Survivors of Sexual
Assault.

107

Sweeney, A., Perôt, C., Callard, F., Adenden, V.,
Mantovani, N., & Goldsmith, L. (2019). Out of thesilence: towards grassroots and trauma-informed
support for people who have experienced
sexual violence and abuse. Epidemiology andpsychiatric sciences, 28(6) UK Parliament(2019) The Independent Inquiry into Child
Sexual Abuse. Available at: https://www.iicsa.
org.uk/investigations-research/investigations/
reparations-for-victims-and-survivors-of-childsexual-abuse

108

Bach, M. H., Beck Hansen, N., Ahrens, C.,
Nielsen, C. R., Walshe, C., & Hansen, M. (2021).
Underserved survivors of sexual assault: asystematic scoping review. European journal of
psychotraumatology, 12(1), 1895516.

109

Akinsulure-Smith A. M., (2014) Displaced
African Female Survivors of Conflict-Related
Sexual Violence: Challenges for Mental Health
Providers. Violence Against Women. Jun;20(6).
doi: 10.1177/1077801214540537. Epub 2014 Jul
10. PMID: 25011674.

110

CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/
111

Girls Education Challenge (2021)
Protection is Possible. Available at: https://
safeguardingsupporthub.org/documents/
protection-possible
112

Resource and Support Hub (2021) Mapping
local services for safeguarding. Available at:https://safeguardingsupporthub.org/documents/
mapping-local-services-safeguarding

113

114

See: https://nomoredirectory.org/

115
CHS Alliance (2022) Sexual Exploitation, Abuse
and Harassment (SEAH) Investigation Guide.
Available at: https://www.chsalliance.org/getsupport/resource/sexual-exploitation-abuse-andharassment-seah-investigation-guide/

CHS Alliance investigation training IQTS 1 and2. For more information, visit: https://www.
chsalliance.org/get-support/training/investigatorqualification-training-scheme/

116

Aranburu, X. A (2010). Sexual Violence Beyond
Reasonable Doubt: Using Pattern Evidence andAnalysis for International Cases. Law Social
Inquiry 35 (4)117Country Assessments found at https://
safeguardingsupporthub.org/

118

119
CHS Alliance (2022) ‘Closing the Accountability
Gap to Better Protect Victims/Survivors of SEAH in
the Aid Sector’ Project. Available at: https://www.
chsalliance.org/get-support/resource/closingthe-accountability-gap-country-assessmentreport-phase-1/

Aranburu, Xabier Agirre. 2010. “Sexual
Violence Beyond Reasonable Doubt: Using
Pattern Evidence and Analysis for International
Cases.” Law Social Inquiry 35 (4)

120

121
CHS Alliance (2022) Sexual Exploitation, Abuse
and Harassment (SEAH) Investigation Guide.
Available at: https://www.chsalliance.org/getsupport/resource/sexual-exploitation-abuse-andharassment-seah-investigation-guide/
122

Ibid

CHS Alliance investigation training IQTS 1 and2. For more information, visit: https://www.
chsalliance.org/get-support/training/investigatorqualification-training-scheme/

123

124
ICVA Network (2007) Building Safer
Organisations Handbook. Available at: https://www.icvanetwork.org/resource/building-saferorganisations-bso-handbook/

The acronym - P.E.A.C.E - summarises andassists remembrance of the five stages ofmanaging the interview process: Preparation
and Planning, Engage and Explain, Account,
Clarification, Challenge and Closure Evaluation.

125

126
CHS Alliance (2022) Sexual Exploitation, Abuse
and Harassment (SEAH) Investigation Guide.
Available at: https://www.chsalliance.org/getsupport/resource/sexual-exploitation-abuse-andharassment-seah-investigation-guide/

CHS Alliance, Risk Assessment Tool. Available
at: https://d1h79zlghft2zs.cloudfront.net/
uploads/2022/04/IQTS-Risk_Assessment-Tool.pdf

127

UK Charity Commission Inquiry Report (20919)
Summary Findings and Conclusions: Oxfam

128

CHS Alliance/GCPS (2021) Increasing
Transparency on Sexual Exploitation and Abuse in
the Aid Sector

129

130
CHS Alliance (2022) Harmonised SEAH Data
Collection and Reporting Template. Available
at: https://www.chsalliance.org/get-support/
resource/harmonised-seah-data-collection-andreporting-template/

Daly, K. (2014). Reconceptualizing sexual
victimization and justice. Justice for victims:
Perspectives on rights, transition andreconciliation, 1.

131

UN Security Resolution (S/RES/1325), (S/RES/1888), (S/RES/1889), (S/RES/1960) (S/
RES/2106), (S/RES/2122),( (S/RES/2242)

132

VICTIM/SURVIVOR-CENTRED APPROACHES TO PROTECTION FROMSEXUAL EXPLOITATION, ABUSE AND HARASSMENT IN THE AID SECTOR

Leyh, B. M., & Fraser, J. (2019). Transformative
reparations: changing the game or more of thesame?. Cambridge International Law Journal, 8(1)133

Ferstman, C. (2020). Reparation for sexual
exploitation and abuse in the (post) conflict
context: The need to address abuses bypeacekeepers and humanitarian aid workers. In
Reparations for victims of genocide, war crimes
and crimes against humanity

134

Hilhorst D (2018) Aid agencies can’t police
themselves. It’s time for a change. The New
Humanitarian. Available at: https://www.
thenewhumanitarian.org/opinion/2018/02/22/
aid-agencies-can-t-police-themselves-it-s-timechange

135

Hilhorst D., Naik A., Cunningham A., (2018)
International Ombuds for Humanitarian andDevelopment Aid Scoping Study International
Ombuds for Humanitarian and Development
Aid Scoping Study Available at: https://www.
academia.edu/79944668/International_
Ombuds_for_Humanitarian_and_Development_
Aid_Scoping_Study

136

137

Aids Free World (2018) Code Blue Campaign

Naik (2021): How to adopt a survivor-centred
approach to sexual abuse. Available at: https://www.devex.com/news/opinion-how-to-adopta-survivor-centered-approach-to-sexualabuse-99820

138

Purkey, A. L. (2011). Whose Right to What
Justice-The Administration of Justice in RefugeeCamps. New Eng. J. Int’l & Comp. L., 17

139

Farmer, A. (2006). Refugee responses, statelike behavior, and accountability for human rights
violations: a case study of sexual violence inGuinea’s refugee camps. Yale Hum. Rts. & Dev.
LJ, 9, 44.

140

Le Sage, A. (2005). Stateless justice in Somalia:
Formal and informal rule of law initiatives.

141

García-Moreno, C., Pallitto, C., Devries, K.,
Stöckl, H., Watts, C., & Abrahams, N. (2013).
Global and regional estimates of violenceagainst women: prevalence and health effects of
intimate partner violence and non-partner sexual
violence. World Health Organization.

142

The only exception regards peacekeeping
operations where “status of forces agreements”
specify that it is the country contributing thepeacekeeping troops (and not the country
where such peacekeepers are deployed)that is responsible for ensuring perpetrator
accountability and prosecutions, including for
SEAH.

143

Schaaf, M., Boydell, V., Sheff, M. C., Kay, C.,
Torabi, F., & Khosla, R. (2020). Accountability
strategies for sexual and reproductive health andreproductive rights in humanitarian settings: a
scoping review. Conflict and health, 14(1)144

CHS Guidance Notes and indicators (2015).
Available at: https://corehumanitarianstandard.
org/resources/chs-guidance-notes-and-indicators

145

UK Parliament (2019) The Independent Inquiry
into Child Sexual Abuse. Available at: https://www.iicsa.org.uk/investigations-research/
investigations/reparations-for-victims-andsurvivors-of-child-sexual-abuse

146

Schaaf, M., Boydell, V., Sheff, M. C., Kay, C.,
Torabi, F., & Khosla, R. (2020). Accountability
strategies for sexual and reproductive health andreproductive rights in humanitarian settings: a
scoping review. Conflict and health, 14(1)

147

148

Ibid

Ferstman, C. (2020). Reparation for sexual
exploitation and abuse in the (post) conflict
context: The need to address abuses bypeacekeepers and humanitarian aid workers. In
Reparations for victims of genocide, war crimes
and crimes against humanity

149

United Nations (1946) Convention On The
Privileges And Immunities Of The United Nations.
Available at: https://www.un.org/en/ethics/
assets/pdfs/Convention%20of%20PrivilegesImmunities%20of%20the%20UN.pdf

150

See: https://www.interpol.int/en/How-wework/Capacity-building/Capacity-buildingprojects/Project-Soteria

151

For example, in Canada, see Buti, A. 2001,‘Canadian Residential Schools: The demands
for reparations’, The Flinders Journal of Law
Reform, 5, 2; or in the United States see Smith,A. (2006) Boarding School Abuses, Human Rights
and Reparations, Journal of Religion & Abuse,
8:2, DOI: 10.1300/J154v08n02_02; or in the
UK see UK Parliament (2019) The Independent
Inquiry into Child Sexual Abuse. Available at:https://www.iicsa.org.uk/investigations-research/
investigations/reparations-for-victims-andsurvivors-of-child-sexual-abuse

152

153
United Nations (2008) United Nations
Comprehensive Strategy on Assistance andSupport to Victims of Sexual Exploitation andAbuse by United Nations Staff and Related
Personnel resolution/adopted by the General
Assembly Available at: https://digitallibrary.
un.org/record/614563?ln=en

CHS ALLIANCE

154
United Nations (2019) United Nations
Comprehensive Strategy on Assistance andSupport to Victims of Sexual Exploitation andAbuse by United Nations Staff and Related
Personnel: resolution/adopted by the General
Assembly. Annex, paragraph 3, ( A/RES/62/214)

UN Secretary-General (2022) Special measuresfor protection from sexual exploitation and abuse(A/69/779). Available at: https://documents-ddsny.un.org/doc/UNDOC/GEN/N22/259/23/PDF/
N2225923.pdf?OpenElement

155

Ferstman, C. (2020). Reparation for sexual
exploitation and abuse in the (post) conflict
context: The need to address abuses bypeacekeepers and humanitarian aid workers. In
Reparations for victims of genocide, war crimes
and crimes against humanity

156

157

Ibid

Tort law is principally used to compensate
a victim/survivor for harm or injury arisingout neglect or are intentially inflicted by adefendant’s conduct. This may include a whole
range of damages to person and property notlimited to battery, road accidents, diffamation,
trespassing, trespassing or damage to cattle, etc.
Tort law also serves the purpose of deterring
persons from acting in ways that may cause injury
to others.

158

Abu Assab.N & NasserEdin.N (2021)
Organisational Safeguarding Best Practices andProcedures: A Toolkit Towards Transnational
Intersectional Feminist Accountability
Frameworks to Respond to Exploitation, Assault,
Abuse, Harassment and Bullying. Women’s
International League for Peace and Freedom
Centre for Transnational Development andCollaboration. https://safeguardingsupporthub.
org/documents/organisational-safeguardingbest-practices-and-procedures-toolkit-towardstransnational

159

McGlynn, C. (2011). Feminism, rape and thesearch for justice. Oxford Journal of Legal Studies,
31(4)

160

See: https://psea.
interagencystandingcommittee.org/victimsurvivor-centred-assistance (retrieved 30-9-22)

161

Naik (2021): How to adopt a survivor-centred
approach to sexual abuse. Available at: https://www.devex.com/news/opinion-how-to-adopta-survivor-centered-approach-to-sexualabuse-99820

162

068

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resource/closing-the-accountability-gapcountry-assessment-report-phase-1/
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