Protection from Sexual Exploitation and

Abuse (PSEA) Policy

January 2019

Contents
Safeguarding Framework ....................................................................................................... 2
Policy Introduction...................................................................................................................2
Accountability Statement .................................................................................................. 2
Policy Approach ......................................................................................................................3
Framework Principles ........................................................................................................... 3
Policy Implementation ............................................................................................................ 4
Policy Map ............................................................................................................................4
Governance .........................................................................................................................4
Responsibilities ......................................................................................................................4
EngenderHealth’s Obligations ........................................................................................... 5
Staff Responsibility ................................................................................................................ 6
Manager Responsibility ....................................................................................................... 6
Safeguarding Committee .................................................................................................. 6
Confidentiality of Complaint .............................................................................................. 6
Whistle-Blowing.....................................................................................................................7
Prohibited Retaliation .......................................................................................................... 7
PSEA Commitments ............................................................................................................. 8
Consequences .....................................................................................................................9
PSEA Reporting Procedures ................................................................................................ 9
Support for Survivors ..........................................................................................................10
Definitions ............................................................................................................................10
Policy Review .........................................................................................................................13

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Safeguarding Framework
This document is part of EngenderHealth’s Safeguarding Framework that consists of
this policy, procedures and resources.

Policy Introduction
EngenderHealth has a zero tolerance for sexual exploitation and abuse.
EngenderHealth will not tolerate its staff, associates, partners or any other
representatives associated with the delivery of its work to engage in any form of sexual
exploitation or abuse. Vulnerable adults, women and children are particularly at risk
of sexual exploitation and abuse. EngenderHealth is committed to protecting all
communities that the organisation works with from sexual exploitation and abuse at
all times. Please see definitions for a full outline who is included in the community.

The purpose of the PSEA Framework, including the policy, procedures and resources,
is to establish an outline of the importance of the framework and clear procedures.
The PSEA Framework also affirms EngenderHealth’s commitment to the United Nations
Secretary General’s Bulletin on Special Measures for protection from sexual
exploitation and abuse (ST/SGB/2003/13).

This policy ensures that all EngenderHealth staff, associates, and partners are aware
of their role and responsibilities in keeping communities and stakeholders safe from
any form of sexual exploitation or abuse. The policy clarifies definitions and
responsibilities regarding prohibited behaviour and the associated PSEA procedures
outline the reporting and investigation processes.

Accountability Statement
EngenderHealth takes this policy very seriously, and the mandate prohibiting any form
of sexual exploitation and abuse comes from EngenderHealth’s Executive Team (ET)
and Board of Directors.

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The PSEA policy applies to all EngenderHealth staff, associates, and partners who must
comply with its requirements and understand the sanctions that may be applied for
breaches of the policy. Where required by law or local practices, EngenderHealth or
Country Offices may enhance the standards as set out in this policy. This commitment
will be evidenced through signing the policy and the Code of Conduct. Training in
this policy is mandatory for all EngenderHealth staff, associates, and partners.

The Board of EngenderHealth is ultimately accountable for this policy. The CEO, ET
and directors of EngenderHealth are responsible for its implementation. It is the
responsibility of all representatives of EngenderHealth to raise any concerns regarding
sexual exploitation and abuse. EngenderHealth takes all concerns and complaints
seriously and will initiate a comprehensive investigation of complaints that are in
violation of this policy and take disciplinary and possibly legal action as warranted.

Policy Approach
This policy details how EngenderHealth achieves its obligations and applies to all staff,
associates and partners regardless of their location.

Framework Principles
This policy and the entire Safeguarding Framework are guided by the following
principles:

Safeguarding

EngenderHealth is committed to all community members as outlined in the definitions

as having the right to safeguarding and protection from sexual exploitation and
abuse irrespective of ability, ethnicity, faith, gender, sexuality, and culture. A key
principle within this is that all processes are survivor led. EngenderHealth commits to
survivors leading the complaint process where it is possible and appropriate to do so.

Shared Responsibility

For the PSEA policies and practices to be effective in reducing the risks to beneficiaries
and communities, all at EngenderHealth must share the responsibility for
implementation and improvement. As such, a failure at one level of the organization
constitutes a failure at all levels of the organization.

Effective Communication

EngenderHealth effectively communicates with all staff, associates, and partners in

simple and accessible language to create a positive and accessible culture where
responsibilities for PSEA are clear.

Continuous Improvement

EngenderHealth provides assessment, reflection and feedback mechanisms to inform

the organisation of any improvements that can be made to policies and practices.

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These mechanisms include quarterly incident reviews, regular safeguarding audits, as
well as regular policy review and refresher training.

Dignity and Respect

EngenderHealth creates a work environment where the principles of dignity and

respect for all staff, associates, and partners, in all locations are at the heart of what
the organisation does. Included in this are the principles of being non-judgemental
when hearing the concerns and complaints of survivors of sexual exploitation and
abuse.

Zero Tolerance

EngenderHealth has zero tolerance for any forms of sexual exploitation and abuse.

Confidential

EngenderHealth Is committed to confidentiality and information will not be shared

outside of the Safeguarding Committee unless it is absolutely necessary, and the
safety of the person involved is a concern.

Policy Implementation
Policy Map
This policy will guide EngenderHealth staff through the definitions of sexual exploitation
and abuse as well as governance and responsibilities. The associated procedures
and resources will provide information on how to report any complaints, the format of
the reporting, and how these complaints will be managed.

Governance
The Chief Executive Officer (CEO), together with the Board of Directors, has ultimate
responsibility for this policy and the PSEA Framework and its proper management,
using a systematic approach. As such, the CEO and the Board of Directors will receive
a summary of any reported sexual exploitation and abuse incidents and follow-up
measures taken at each Executive Team meeting and Board meeting, respectively.

Responsibilities
EngenderHealth is committed to following through on the following measures in order
to ensure that the organisation is observing its PSEA commitments:

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 Risk
Assessment

Implement Safe
and Review Recruitment

Safeguarding
Management
Training

PSEA

Safe
Reporting
Program
Procedures
Design

On-Line Comms
Protection Guidelines

These commitments are fully outlined in the Safeguarding Policy.

EngenderHealth’s Obligations
EngenderHealth believes that all people have a right to live their lives free from sexual
exploitation and abuse and will not tolerate its staff, associate, or partners engaging
in any sort of behaviour that puts beneficiaries or communities at risk. To that end,
EngenderHealth commits to:

1. Creating a safe culture for both those it serves and those who work for and
represent the organisation.
2. Following through on any complaints and concerns in a timely manner through
its Safeguarding Committee and taking each complaint seriously.
3. Sensitising staff, associates, and partners, around how to make a complaint.
4. Ensuring zero tolerance towards sexual exploitation and abuse.
5. Building a culture of dignity, honor and respect where all those who work with
and are served by EngenderHealth feel empowered to report complaints.
6. Educating staff, associates, and partners that sexual exploitation and abuse
constitute gross misconduct and are grounds for termination of employment
and possibly legal action.
7. Providing information on how to report complaints and the investigation
procedure.
8. Ensuring that all staff, associates, and partners have access to the PSEA policy
and procedures as well as all other related safeguarding policies.

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 9. Providing training to all staff, associates, and partners on PSEA.

Staff Responsibility
All staff, associates, and partners are required to adhere to this policy at all times and
are obliged to report any suspicions of sexual exploitation and abuse of others. All
staff, associates, and partners are required to sign the associated Code of Conduct
and an acknowledgement of having read and understood the policy.

Manager Responsibility
All Managers and Directors hold overall accountability for this Policy and its
Implementation. Managers also have a responsibility to support and develop systems
that maintain an environment where all parties involved with EngenderHealth
understand how to behave, how to raise complaints and concerns, and what action
will be taken.

Safeguarding Committee
A Safeguarding Committee has been established at the HQ level as well as in each
field location. The Safeguarding Committee is comprised of 5 members:

1. One woman in a Senior Management Role

3. Three members will be from across different departments in the country program.

4. A fifth member who is an external expert in harassment, sexual exploitation or

abuse.

All Safeguarding Committees will ensure that there is diversity and equal gender
representation on the committee.

The Safeguarding Committee will be responsible for informing and training all staff in
safeguarding, PSEA and harassment policies and procedures. They will also be
responsible for receiving and investigating any safeguarding complaints, including
PSEA.

The Safeguarding Committees will be trained in all of the Safeguarding policies as well
as reporting and investigations. The Safeguarding Committee will also be provided
with specialised psychological first aid training so that they are able to offer
appropriate support as required.

Confidentiality of Complaint
EngenderHealth will protect the confidentiality of sexual exploitation and abuse
allegations to the greatest extent possible in order to protect the integrity of the
investigation and prevent embarrassment, further discrimination or harassment, or
retaliation.

Confidential or sensitive information obtained by any staff member during the

course of an investigation shall not be disclosed to others unless required by law.
Concerns of individuals regarding confidentiality of information provided by them
will be handled as sensitively as possible, and information shall not unnecessarily
be disclosed to others.

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EngenderHealth cannot guarantee, however, complete confidentiality, because
the organisation cannot conduct an effective investigation without revealing
certain information to the alleged perpetrator and potential witnesses.
EngenderHealth will share information about allegations of sexual exploitation,
abuse and harassment only with those who need to know about it. Records
relating to sexual exploitation, abuse and harassment complaints will also be kept
confidential on the same basis.

Whistle-Blowing
As referred to in EngenderHealth’s whistle-blowing policy, all disclosures will be treated
in confidence. EngenderHealth maintains a third-party secure reporting system
through EthicsPoint to ensure that all staff, partners, and vendors have recourse in the
event of possible misconduct. Reports may be submitted anonymously for
investigation via www.ethicspoint.com or by calling the US hotline at 1-866-739-4117
or the country number found at the same webpage.

Prohibited Retaliation
EngenderHealth maintains a zero-tolerance policy for retaliation against anyone for
reporting sexual exploitation or abuse, assisting in making a complaint, or
participating in an investigation.

Any staff, associate, or partner who makes a good-faith complaint of sexual

exploitation or abuse, assists, testifies, or participates in any investigation or
proceeding or who reasonably opposes such conduct in the workplace will not be
adversely affected in the terms and conditions of his or her employment and will not
be discriminated against or discharged for engaging in such activity.

Retaliation not only affects the recipient, but also can spread rapidly throughout
EngenderHealth. It destroys faith in EngenderHealth’s leadership and can damage
employee morale.

Complaints of retaliation will be promptly investigated. If retaliation is substantiated,

appropriate disciplinary action, including possible dismissal, will be taken.

Examples of retaliation:

Some examples of retaliation include but are not limited to the following:

● Termination, demotion, disadvantageous transfers or assignments, refusals to

promote, threats, reprimands, or negative evaluations.
● Co-worker hostility or retaliatory harassment, which includes intimidation,
gossip, rumors, insults, or otherwise offensive conduct that would subject a
person to ridicule or humiliation.
● Any action or combination of actions that is reasonably likely to materially and
adversely affect an employee’s job performance or opportunity for
advancement.

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PSEA Commitments
All EngenderHealth staff, associates, and partners are expected to conduct
themselves in accordance with the PSEA policy. Following are the core commitments
relating to sexual exploitation and abuse that all staff, associates, and partners are
expected to follow. The following behaviours are prohibited:

Sexual Activity with Children and Vulnerable Adults

Sexual activity with children (persons under the age of 18) is prohibited regardless of
the age of majority or age of consent locally. Mistaken belief in the age of the child
is not a defence.

Sexual activity with vulnerable adults, as outlined in the definitions, is also prohibited.

Child Marriage
Any staff, associates, or partners who engage in child marriage (marriage to anyone
under the age of 18) will be in violation of the PSEA policy. As per the definition of
child marriage, anyone under the age of 18 is not able to give or withhold consent
and is considered a form of sexual violence. Any staff married to a child under the
age of 18 as per the custom or law of their country, before the EngenderHealth PSEA
policy came into force will not be subject to disciplinary action. EngenderHealth,
however, prohibits any such relationship from occurring once the PSEA policy came
into effect.

Sexual Activity with EngenderHealth Beneficiaries

Sexual activity with any beneficiary is prohibited due to inherently unequal power
imbalances. An EngenderHealth beneficiary is defined as anyone who receives
services or support from EngenderHealth or an EngenderHealth partner.

Grooming and/or Coercion

Any grooming and/or coercion of a child or vulnerable adult for the purposes of
obtaining sex is prohibited.

Sexual Exploitation
Any form of sexual exploitation is prohibited including:
- Buying Sex
Exchange of money, material assistance, employment, goods or services for
sex, including sexual favours or other forms of humiliating, degrading or
exploitive behaviour is prohibited.

- Profiting from Sexual Exploitation

Any monetary, social or political gain from sexual exploitation is prohibited.

Sexual Harassment
Any act of sexual harassment including unwelcome sexual advances or requests for
sexual favours is prohibited both under the PSEA policy and the Anti-Harassment
policy.

Sexual Violence

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Any acts of sexual violence as outlined in the definitions in prohibited. This includes,
but is not limited to, sexual violence including intercourse, sexual touching, and threats
of sexual violence.

Physical/Emotional Abuse
As outlined in both the Child Safeguarding and the Adult Safeguarding policies, any
physical or emotional abuse is prohibited.

This list may be expanded at any time and details will be communicated with staff,
associates and partners through the Safeguarding Committee. Additional prohibited
behaviours related to abuse can be found in the Child Safeguarding and Adult
Safeguarding policies.

Consequences
Any staff, associate, or partner who is in violation of the PSEA policy will face
disciplinary procedures, which may result in disciplinary action, termination of
employment or contract and/or referral to the appropriate law enforcement agency
or legal authority.

Communication and Training

It is EngenderHealth’s responsibility to ensure that all staff, associates and partners are
aware and fully compliant with the PSEA policy. In order to take the steps to prevent
any forms of sexual exploitation or abuse, EngenderHealth will ensure that:

1. Training is provided for all staff who has a specific responsibility for
implementing this Policy and associated Procedure or who may be involved in
dealing with complaints, which arise.
2. Awareness raising training is provided to all staff, associates, and partners on
PSEA. The training will equip staff, associates, and partners to develop
awareness as well as an understanding of when and how to report any
concerns.
3. Proactive steps are taken to communicate the zero-tolerance message.
4. All staff is informed of and trained in the policy and procedure.
5. All staff is aware of the definitions under this policy.
6. All staff is aware of reporting procedures.
7. All staff has signed and acknowledged that they have read and understood
the policy.

PSEA Reporting Procedures

The associated procedures document outlines how to report any incidents of sexual
exploitation or abuse.

Failure to Report
The Code of Conduct as well as the InterAgency Standing Committee (IASC) 1 Core
Principles on PSEA state that it is the duty and the responsibility of all staff, associates,

1 https://interagencystandingcommittee.org/

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and partners to report any PSEA concerns. Failure to report may lead to disciplinary
action.

Support for Survivors

Support will be offered to survivors regardless of the outcome of any investigations.
This support can include specialist psychosocial counselling and/or access to other
specialist support as needed.

Definitions
Child and vulnerable adults
A child is any individual under the age of 18, irrespective of local country definitions
of when a child reaches adulthood. 2

Vulnerable adults are defined as:

• Those aged over 18 years and who identify themselves as unable to take care of
themselves/ protect themselves from harm or exploitation; or
• Who, due to their gender, mental or physical health, disability, ethnicity, religious
identity, sexual orientation, economic or social status, or as a result of disasters and
conflicts, are deemed to be at risk.

Physical Abuse
Physical abuse occurs when a person purposefully injures or threatens to injure a child
or vulnerable adult. This may take the form of slapping, punching, shaking, kicking,
burning, shoving or grabbing. The injury may take the form of bruises, cuts, burns or
fractures.

Child Emotional Abuse

Emotional abuse is inappropriate verbal or symbolic acts toward a child or a pattern
of failure over time to provide a child with adequate non-physical nurture and
emotional availability. Such acts have a high probability of damaging a child’s self-
esteem or social competence. 3

Neglect
Neglect is the failure to provide a child or vulnerable adult with the conditions that
are culturally accepted as being essential for their physical and emotional
development and well-being.

Vulnerable Adult Abuse

A Vulnerable Adult is defined as someone “who is or may be in need of community
care services by reason of mental or other disability, age or illness; and who is or may
be unable to take care of him or herself, or unable to protect him or herself against
significant harm or exploitation”. Vulnerable Adult Abuse can take many forms

2 Definition of child from the InterAgency Standing Committee (IASC) Guidelines to

implement Minimum Operating Standards for Protection from Sexual Exploitation and Abuse
by UN and non-UN Personnel, March 2013.
3 CARE International PSEA Policy 2017

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including: physical, sexual, psychological, financial/ material, discriminatory,
domestic abuse and self-neglect.4

Sexual Abuse
The term “sexual abuse” means the actual or threatened physical intrusion of a sexual
nature, whether by force or under unequal or coercive conditions. 5

Child Sexual Abuse

Child sexual abuse is the involvement of a child in sexual activity that s/he does not
fully comprehend, give informed consent to, or for which s/he is not developmentally
prepared and cannot give consent, or that violates the laws or social taboos of
society. It is evidenced by an activity between a child and an adult or another child
who by age or development is in a relationship of responsibility, trust or power, the
activity being intended to gratify or satisfy the needs of the other person. It may
include, but is not limited to, the inducement or coercion of a child to engage in any
unlawful sexual activity, the exploitative use of a child in prostitution or other lawful
sexual practices or the exploitative use of pornographic performances and materials. 6

Grooming
Grooming is behavior that an offender uses to procure sexual activity from a child. It
can include building trust with children and/or their carers to gain access to children
to sexually abuse them.

Online Grooming
Grooming may be in person as above, or online where the groomer sends electronic
messages with the goal of engaging the child in sexual activity.

Coercion
Coercion covers a whole spectrum of degrees of force. Apart from physical force, it
may involve psychological intimidation, blackmail or other threats. For instance,
threats of being dismissed from a job or of not obtaining a job that is sought. It may
also occur when a person is unable to give consent. For example, while drunk,
drugged, asleep or mentally incapable of understanding the situation. 7

Sexual Exploitation
The term “sexual exploitation” means 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.8

Modern Slavery
Slavery is a situation where a person exercises (perceived) power of ownership over
another person. Related terms include forced labour, which covers work or services

4 Department of Health and Social Care No Secrets: guidance on protecting vulnerable

adults in care
5 1 Secretary-General’s Bulletin: Special Measures for Protection from Sexual Exploitation and

Sexual Abuse (2003)

6 United Nations Secretary General’s Bulletin: Special measures for protection from sexual

exploitation and sexual abuse (ST/SGB/2003/13).

7 World Health Organization World Report on Violence and Health (2002)
8 Ibid.

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that people are not doing voluntarily but under threat of punishment; human
trafficking, which involves deceptive recruitment and coercion; and bonded labour,
which is demanded in repayment of a debt or loan. Modern slavery encompasses a
spectrum of labour exploitation, ranging from the mistreatment of vulnerable workers
to human trafficking to child labour and forced sexual exploitation. 9

Sexual Violence
Sexual violence is 10:
• Any sexual act or attempt to obtain a sexual act
• Unwanted sexual comments or advances or acts to traffic that are directed
against a person’s sexuality using coercion by anyone, regardless of their
relationship to the victim, in any setting, including at home and at work.
Three types of sexual violence are commonly distinguished: sexual violence
involving intercourse (i.e. rape), contact sexual violence (i.e. unwanted
touching, but excluding intercourse) and noncontact sexual violence (i.e.
threatened sexual violence, exhibitionism and verbal sexual harassment). While
coerced sex may result in sexual gratification for the perpetrator, its underlying
purpose is to express power and dominance over the other person. 11

Child Marriage
The custom of marrying young children, particularly girls, is a form of sexual violence
as children are unable to give or withhold consent.

Sexual Harassment
Sexual harassment includes ‘unwelcome sexual advances, requests for sexual
favors, and other conduct that creates a coercive, hostile, intimidating, or
offensive work environment’. 12 The harassment of a sexual nature may be
directed to a person of the same or opposite sex.

The key elements are that the behaviour is uninvited, unreciprocated and unwelcome
and causes the person involved to feel threatened, humiliated or embarrassed. The
behaviour may also be determined to be sexual violence and harassment if:

● Submission to such conduct is explicitly or implicitly made a term or condition

of employment.
● Submission to or rejection of this conduct is used as a basis for an employment
decision affecting the staff.
● Such conduct has the purpose or effect of substantially interfering with an
individual’s work performance or creating an intimidating, hostile, or offensive
work environment.

Please refer to EngenderHealth’s Anti-Harassment policy & procedure for more

information.

9 Oxfam PSEA Policy 2018

10 World Health Organization definition 2012
11 World Health Organization Global Status Report on Violence Prevention (2014)
12SEXUAL HARASSMENT IN THE HUMANITARIAN CONTEXT Dr. Linda Wagener, Senior Consulting
Psychologist, Headington Institute April 25, 2012

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Communities
The communities that EngenderHealth works with includes, but isn’t limited to, health
service providers at facilities, outreach facilities, frontline health workers, any other
service providers, women, men, girls, boys, people with special needs, vulnerable
adults and marginalised groups.

EngenderHealth staff refers to individuals who receive a regular salary for work in any
part of EngenderHealth Inc., including all Country Offices, Field Offices, Headquarters
and any other location where EngenderHealth operates.

EngenderHealth associates refers to a range of paid and non-paid individuals who

have committed to work with or support EngenderHealth. It includes volunteers,
interns, and consultants and contractors.

EngenderHealth managers refers to EngenderHealth staff who have responsibility for

line managing or supervising the work of EngenderHealth staff or EngenderHealth
associates.

EngenderHealth partners refers to staff and/or representatives of partner organizations

and local governments when operating in partnership agreement with
EngenderHealth.

Policy Review
To meet with sector best practice, EngenderHealth agrees to review this policy and
the entire PSEA Framework every two years, as a minimum. It is the responsibility of the
Chief of Governance and Operations to complete this review, in collaboration with
any key internal stakeholders or external third-party providers.

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