PSEA IMPLEMENTATION

QUICK REFERENCE
HANDBOOK
AUTHORS

Corinne Davey and Lucy Heaven Taylor, GCPS Consulting UK, 2017

ACKNOWLEDGEMENTS

CHS Alliance would like to thank the following people and organisations for generously sharing
their knowledge and expertise:

Sanat K. Bhowmik, Director, COAST

Hannah Clare, Global Safeguarding Co-ordinator, Oxfam GB
Mariama Deschamps, Plan International
Kennedy Dhanabalan, EFICOR
Susan Grant, Save the Children International
Prem Livingstone, EFICOR
Anastasia Maylinda, YAKKUM Emergency Unit (YEU)
Gabriella Prandini, Humanitarian Response Advisor, GOAL Ethiopia
Lemma Tesafaye, Head of MEAL, Women Support Association
Tracy Van Gough, Sightsavers
Antony Wesonga, Refugee Consortium of Kenya

We would like to express our appreciation to the UK Department for International

Development, whose funding has made this project possible.

Supported by
 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

GLOSSARY

Allegation – an assertion of facts that one Complaint mechanism or procedure –

intends to prove at trial or during an internal processes that allow individuals to report
investigation procedure. concerns such as breaches of organisational
policies or codes of conduct. Elements
Beneficiary – someone in receipt of
of a complaints mechanism may include
assistance. Alternatively referred to as a
suggestion boxes, whistleblowing policies
member of the affected population, person
and designated focal points.
we seek to assist, person affected by crisis or
rights holders. Confidentiality – an ethical principle that
restricts access to and dissemination of
Case management – following the
information. In investigations on sexual
appropriate policies and procedures to
exploitation, abuse, fraud and corruption, it
determine the outcome of a report of SEA.
requires that information is available only to
Child – any individual under the age of 18, a limited number of authorised people for
irrespective of local country definitions of the purpose of concluding the investigation.
when a child reaches adulthood. Confidentiality helps create an environment in
which witnesses are more willing to recount
Child protection – preventing and responding
their versions of events and builds trust in the
to violence, exploitation and abuse against
system and in the organisation.
children – including [but not limited to]
commercial sexual exploitation, trafficking, Feedback – the information sent to an
child labour and harmful traditional practices1. entity (individual or a group) about its prior
behaviour so that the entity may adjust its
Code of conduct – a set of standards about
current and future behaviour to achieve the
behaviour that staff of an organisation are
desired result.
obliged to adhere to.
Focal point – a person designated to receive
Complaint – specific grievance of anyone
complaints of cases of sexual exploitation
who has been negatively affected by an
and abuse.
organisation’s action or who believes
that an organisation has failed to meet Investigation of sexual exploitation or abuse
a stated commitment. – an internal administrative procedure, in
which an organisation attempts to establish
Complainant – the person making the
whether there has been a breach of SEA
complaint, including the alleged survivor
policy by a staff member or members.
of the sexual exploitation and abuse or
another person who becomes aware of PSEA (Protection from sexual Exploitation
the wrongdoing. and Abuse) – the term used by the UN and
NGO community to refer to measures taken
to protect vulnerable people from sexual
exploitation and abuse by their own staff
and associated personnel.

1
UNICEF Child Protection Information Sheet What is Child Protection?

1
Report – where an individual or individuals Survivor or victim – the person who is, or has
report a concern regarding SEA. been, sexually exploited or abused. The term
‘survivor’ implies strength, resilience and the
Safeguarding – the responsibility that
capacity to survive. This document mostly
organisations have to make sure their staff,
uses the term ‘victim’, to mean the victim of
operations, and programmes do no harm to
the alleged perpetrator’s actions. However
children and vulnerable adults, and that they
this is not intended to negate that person’s
do not expose them to the risk of harm and
dignity and agency as an individual.
abuse2. PSEA and child protection come under
this umbrella term. Generally the term does Whistleblowing policy – an organisational
not include sexual harassment of staff by staff, policy which encourages staff members to
which is usually covered by organisation’s report concerns or suspicions of misconduct
bullying and harassment policy. by colleagues. Whistleblowers are protected
from any negative consequences of reporting
Sexual abuse – an actual or threatened
these concerns.
physical intrusion of a sexual nature,
whether by force or under unequal or
coercive conditions.
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.

2
Adapted from Keeping Children Safe www.keepingchildrensafe.org.uk
3
United Nations Secretariat, 9 October 2003, Secretary General’s Bulletin on Special Measures for Protection from Sexual
Abuse and Sexual Exploitation, 2003/13 (ST/SGB/2003/13), United Nations.
4
ibid

2
CONTENTS
INTRODUCTION 4

PSEA HANDBOOK AT A GLANCE 7

DEVELOPING AND IMPLEMENTING PSEA POLICY AND PROCEDURES 8

ASSIGNING SPECIFIC RESPONSIBILITIES FOR PSEA 12

ENSURING STAFF, VOLUNTEERS AND ASSOCIATES UNDERSTAND

AND WORK TO PSEA REQUIREMENTS 15

ENGAGING COMMUNITIES AND PEOPLE AFFECTED BY CRISIS 18

IMPLEMENTING PSEA REQUIREMENTS WITH PARTNERS,

SUPPLIERS AND CONTRACTORS 21

DESIGNING SAFE PROGRAMMES AND PROJECTS 24

DEVELOPING AND IMPLEMENTING A COMPREHENSIVE

COMPLAINTS MECHANISM 27

RESPONDING TO REPORTS OF SEA 31

3
INTRODUCTION

Background
PSEA (Protection from Sexual Exploitation and Abuse) is a term used by the UN and NGO
community to refer to measures taken to protect vulnerable people from sexual exploitation
and abuse our by own staff and associated personnel.
The contexts we work in bring us into contact with vulnerable people. As NGO workers, we
have access to goods and services that put us in a position of power over the community.
Unfortunately, a minority of people use this imbalance of power to exploit and abuse
vulnerable members of the community.
The humanitarian and development community is committed to preventing sexual exploitation
and abuse in our work. However the issue is a complex one and sometimes it can seem hard to
know where to start.

International standards on PSEA

The most widely used standards with regard to PSEA are the IASC (Inter-Agency Standing
Committee) Minimum Operating Standards for Protection from Sexual Exploitation and Abuse
for UN and non-UN staff. The eight areas covered by the Minimum Operating Standards are:

Minimum Operating Standard Chapter in PSEA Handbook

1. Effective policy development and Developing and implementing PSEA policy
implementation and procedures
2. Cooperative arrangements Implementing PSEA requirements with
partners, suppliers and contractors
3. A
 dedicated department/focal point is Assigning specific responsibilities for PSEA
committed to PSEA
4. Effective and comprehensive Engaging communities and people affected
communication from headquarters to the by crisis
field on expectations regarding raising
beneficiary awareness on PSEA
5. Effective community based complaints Developing and implementing a
mechanisms, including victim assistance. comprehensive complaints mechanism
6. Effective recruitment and performance Developing and implementing PSEA policy
management and procedures
Ensuring staff, volunteers and associates
understand and work to PSEA requirements
7. Effective and comprehensive mechanisms Ensuring staff, volunteers and associates
are established to ensure awareness-raising understand and work to PSEA requirements
on SEA amongst personnel
8. Internal complaints and investigation Responding to reports of SEA
procedures in place

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEA is also mainstreamed in the Core Humanitarian Standard. It is particularly referenced in

the following Key Actions and Organisational Responsibilities:
Key Action 3.6: Identify and act upon potential or actual unwanted negative effects in a timely
and systematic manner, including areas of … sexual exploitation and abuse by staff.
Organisational Responsibility 5.6: Communities and people affected by crisis are fully aware of
the expected behaviour of humanitarian staff, including organisational commitments made on
the prevention of sexual exploitation and abuse.
Organisational Responsibility 8.7: A code of conduct is in place that establishes, at a minimum,
the obligation of staff not to exploit, abuse or otherwise discriminate against people.
Other than these specific references, other elements of the CHS also contribute to PSEA:

Commitment Key Actions or Organisational Contribution to PSEA

Responsibilities
Communities and people Design and implement Safe programming –
affected by crisis receive appropriate programmes minimising the opportunities
assistance appropriate to based on an impartial for SEA in communities and
their needs. assessment of needs and risks, by humanitarian staff
and an understanding of the
vulnerabilities and capacities
of different groups.
Communities and people Design programmes that Safe programming – ensuring
affected by crisis have address constraints so that the the programme Do(es) No
access to the humanitarian proposed action is realistic and Harm
assistance they need at the safe for communities.
right time.
Communities and people Provide information to Engaging communities
affected by crisis know their communities and people and beneficiaries on PSEA
rights and entitlements, have affected by crisis about the so they understand PSEA
access to information and organisation, the principles commitments and build
participate in decisions that it adheres to, how it expects confidence in communicating
affect them. its staff to behave, the with the organisation on
programmes it is implementing PSEA and particularly making
and what they intend to deliver. a report
Policies for information-
sharing are in place, and
promote a culture of open
communication.
Communities and people Manage the risk of corruption Ensuring staff and volunteers
affected by crisis can expect and take appropriate action if understand and work to PSEA
that the organisations it is identified. requirements – corruption
assisting them are managing Policies and processes and misuse of resources
resources effectively, governing the use and may be linked to SEA e.g.
efficiently and ethically. management of resources are resources are withheld or
in place. used specifically to sexually
exploit beneficiaries

5
Purpose of the handbook Further support
The purpose of this handbook is to Tools and resources that support you to
demonstrate how we can implement practical implement the steps in each chapter can be
measures to prevent sexual exploitation and found on the CHS Alliance website at http://
abuse. The Handbook takes the key areas www.chsalliance.org/what-we-do/psea/psea-
from the above standards and provides handbook.
examples of how this can look in practice. It
also provides a real-life case study for each of If you are interested in understanding
the areas covered, so you can learn from the better how well you are implementing PSEA
work of other NGOs. measures, the CHS Alliance can advise on
approaches to organisational assessment.
CHS Alliance members are required to carry
How to use this handbook out a self-assessment against the Core
Humanitarian Standard every two years,
This handbook is designed for you to dip into
and to report progress annually against an
when you are developing PSEA measures, to
action plan derived from the findings. The
provide guidance and ideas. Each chapter
CHS Alliance extracts a detailed PSEA score
takes a key element in implementing PSEA,
from the self-assessments and progress
and discusses what needs to be in place. It
reports, giving a comprehensive picture of the
then takes you through a step by step guide of
different elements contributing to effective
how to implement these measures, followed
work on PSEA in an organisation. The score
by a good practice example.
is fed back to the individual organisations, as
well as providing a way of tracking progress
on PSEA across the sector. Organisations with
gaps on this can access free, unlimited remote
support from the CHS Alliance as they work
to improve.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

PSEA HANDBOOK AT A GLANCE

PSEA policy •A
 PSEA policy describes standard of behaviour for organisation’s staff and
and procedures representatives, specifically forbidding sexual exploitation and abuse
•P
 rocedures which describe how the policy is implemented throughout the
organisation
•A
 n implementation plan for PSEA which is reviewed and updated regularly
Assigning specific • S enior management takes responsibility for ensuring PSEA measures are
responsibilities implemented
for PSEA •O  rganisations assign focal points for PSEA
• PSEA responsibilities are reflected in role and job descriptions
Ensuring staff, •A  ll sign the organisation’s code of conduct which includes PSEA
volunteers •A  ll receive induction and (where relevant) annual refresher training on PSEA
and associates • S taff aware of their obligation to report SEA/misconduct and are protected
meet PSEA from retaliation
requirements
• S upervision and performance appraisals include adherence to code of
conduct and participation in PSEA trainings
Engaging • Communities fully aware of the expected behaviour of the organisation’s staff
communities •C  ommunities know how to complain if these commitments are not met
and beneficiaries •A  ppropriate awareness - raising tools and approaches are used with
on PSEA communities
Implementing • Partners,
 suppliers and contractors are assessed for contact with
PSEA beneficiaries, and capacity to implement PSEA measures
requirements • Clauses on PSEA are included in all contract agreements
with partners, • PSEA training is delivered to partners, suppliers and contractors
suppliers and •P SEA measures, and SEA cases, in partner, supplier and contractor
contractors organisations are monitored
Designing safe •P otential risks of sexual exploitation and abuse presented by programmes
programmes and are identified and addressed
projects • Project plans include activities on PSEA awareness and sensitivity
•B udgets include funding lines for capacity building and communications on
PSEA
Developing and •A documented complaints handling process for communities and people
implementing a affected by crisis
comprehensive •A n organisational culture in which complaints are taken seriously and acted upon
complaints •C ommunities are made aware of what behaviour they can expect from
mechanism organisation staff
•C omplaints channels that are designed to proactively enable reports of SEA
• A fast-track process for dealing with complaints about SEA
•A referral process for complaints which do not fall within the scope of your
organisation’s policy
Responding to •W  ritten procedures on responding to reports or concerns relating to SEA
reports of SEA • Investigations are undertaken in line with the relevant standards and
guidance
• Investigations are undertaken by experienced and qualified professionals
• S ubstantiated complaints result in either disciplinary action or contractual
consequences

7
DEVELOPING AND IMPLEMENTING PSEA
POLICY AND PROCEDURES

What should be in place

• A PSEA, or similar, policy which describes 2. If you are working with children and plan
the standard of behaviour expected of the on developing a child safeguarding policy to
organisation’s staff and representatives, and prevent harm to children, you can develop
which specifically forbids sexual exploitation one policy that covers PSEA and child
and abuse. safeguarding – but make sure that your
policy covers SEA of both adults
• Procedures which describe how the policy is
and children.
implemented throughout the organisation.
• An implementation plan, identifying gaps 3. Check your PSEA policy:
in implementing PSEA and actions to
• Identifies the organisation’s commitment
address the gaps, which is reviewed and
to the Secretary General’s Bulletin on
updated regularly.
Special Measures for protection from
sexual exploitation and sexual abuse (ST/
SGB/2003/13).
How to do it
• Recognises the rights of all beneficiaries
1. Develop a PSEA policy. You can develop
to be protected from sexual
your policy by:
exploitation and abuse.
• Running a consultation with staff, raising
• Applies to all staff, volunteers and
awareness on what PSEA means and
associates at all times.
asking for their inputs on what the policy
should say; or • Identifies and manages risk.
• Using an example of a PSEA policy • Includes the organisation’s Code of
from elsewhere and adapt to suit your Conduct.
organisation and the context in which
• Integrates PSEA measures into all areas of
you work. You should involve staff by
the organization.
circulating the draft and asking for
comment before finalising.
4. Develop PSEA procedures, or refer to
relevant organisational procedures/
guidelines which include PSEA measures.
The procedures should include:

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

Procedure PSEA measures

Recruitment • Job adverts include PSEA commitments
• Gaps in employment history checked during interview
• Questions related to PSEA asked during interview
• At least two references taken from previous employers which
include questions on candidate’s conduct, behaviour
• Criminal records check is conducted, where possible
• New employees sign contracts which include PSEA and the
organisation’s code of conduct
Induction/training • Induction includes at least a briefing on PSEA
• All staff receive a half day training on PSEA – recognising and
responding to risks and concerns
• Annual refresher training opportunities provided
Performance • Performance management discussions include understanding of
management PSEA and an opportunity to raise concerns
• Where performance management includes working to values or
competencies, these include PSEA
Whistleblowing • A policy or procedure which encourages people to report on
concerns without fear of reprisals
Discipline and grievance • SEA is explicitly stated as grounds for discipline which may result
in termination
Programming guidelines • Programming guidelines include identifying and mitigating risks
in programmes to make them safer
Partnership • All contracts with partners/suppliers/contractors include clauses
arrangements on PSEA
• Capacity building for partners includes capacity to implement
PSEA measures
• Partner monitoring includes PSEA measures and SEA reports
Complaints/ reporting • Complaints mechanism developed to receive and respond to
reports of SEA

5. Develop a PSEA implementation or 7. R

 eview the PSEA policy and procedures
work plan which identifies the gaps in every two years to ensure they are fit for
the organisation in implementing PSEA purpose.
measures, and states what action will be
taken to address the gaps, by whom
and when.

6. Monitor the implementation plan on

a quarterly basis to ensure that the
organisation is making steady progress
towards fully implementing PSEA policy
and procedures.

9
 Good practice example

Developing and implementing What EFICOR did

an anti-harassment policy EFICOR adopted a consultative process in
in India developing the policy. The initial draft of the
policy was developed by EFICOR’s Planning,
Action, Coordination Team (PACT) during
The programme their annual meeting and agreed by the
Board of Trustees. EFICOR used a policy from
EFICOR is a national organisation engaged in
another organisation to help inform the draft.
development, advocacy, disaster response
All staff were then consulted on this draft;
and training. EFICOR support some 38 projects
discussions focused on potential challenges in
across India, focusing primarily on disaster
implementing the policy and other concerns
management, climate change, health and
staff had. The results of this consultation
urban poverty. They work with a range of
were used to produce a final draft of the
communities and people including those with
policy which was signed off by the Board. The
disabilities. Their staff are spread across the
policy is accompanied by a set of procedures
projects, with a number of them based in fairly
which describes what needs to be done for
remote communities.
recruitment, induction/training, reporting
concerns and disciplinary actions relating to
sexual harassment. All staff were required to
sign the policy upon its introduction during
their annual staff retreat. The process of
developing, consulting and signing off the
policy took a year and a half.
Key procedures that EFICOR have
Information on how to make a complaint relating to implemented to support the policy are:
the policy
• Recruitment – EFICOR ask candidates to
complete application forms and declare they
are free from convictions relating to abuse
The issue of children. Candidates are asked about any
EFICOR had been working with a child gaps in their employment history during the
protection policy and a gender policy. In interview. They are required to provide two
2010 the Supreme Court in India issued a references; EFICOR also contacts the previous
recommendation that organisations introduce employer to check whether there are concerns
anti-harassment policies and procedures. over the candidate’s behaviour. Background
EFICOR took this opportunity to introduce checks are done on successful candidates.
a new anti-harassment policy, which
• Induction/training – all new employees
replaced their gender policy, to cover sexual
receive a briefing on the policy and are
harassment, abuse and exploitation both
asked to sign it. Staff have the opportunity
within and outside the workplace.
to discuss the values they work to during
the annual staff retreat.
• Performance appraisal – this triggers a
renewal of contract which is accompanied
by a letter reminding staff of the policies
they must work to.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

Lessons learnt
• Check what national legislation or policy
exists that supports PSEA, anti-harassment
etc. and use this as a foundation for your
organisation’s policy and measures.
Information on the anti-harassment policy being • The Board of Trustees plays a vital
delivered during a maternal health project role in leading the development and
implementation of the policy. Having
What happened as a result Board members who have a good
EFICOR’s leadership has been instrumental in understanding of the issue and/or the
developing and implementing the policy and legal implications of not having a policy is
models the behaviour expected of staff. The particularly useful.
Board monitor the progress in implementing • If using a policy from another
the policy. organisation, it must be adapted to suit
the context and organisation. Cultural
Due to the process of developing the policy, practices with regard to issues such as
and the reminders and discussions that take child care need to be well understood.
place each year, staff understand the policy
• Always consult staff in the development of
well and “hold one another accountable”.
the policy – it creates ownership, buy-in
The policy is going to be translated into local
and awareness.
languages to ensure all stakeholders fully
understand. • There needs to be a balance between
focusing on SEA for women and SEA for
men – it is not just an issue which impacts
on women.
• Larger, more well resourced, organisations
may be able to implement a policy within
existing funding. Smaller organisations
may need support and some additional
funding may be required.

11
ASSIGNING SPECIFIC RESPONSIBILITIES FOR PSEA

What should be in place

• Senior management takes responsibility for 3. Identify staff members who can serve as
ensuring PSEA measures are implemented. focal points on PSEA. These staff members
should be relatively senior and/or hold
• Organisations assign focal points for
roles which already implement PSEA
PSEA, who coordinate the development
measures, such as human resources staff.
and implementation of PSEA policy and
procedures. 4. Be clear on the role the focal points will
play. The role will need to include:
• PSEA responsibilities are reflected in role
and job descriptions. • Awareness raising/training for staff,
stakeholders and communities
• Documenting who has signed the PSEA
How to do it policy and code of conduct and who has
1. At least once every three months, received training on PSEA
include an item on PSEA on your Senior
• Receiving reports on PSEA and
Management Team meeting agenda.
coordinating the response
Discuss progress and challenges with
implementing the PSEA policy and 5. Identify PSEA responsibilities for other staff.
implementation plan. These are typically:
2. Present a progress report on implementing
the PSEA policy to your Board at least once
a year.

Role Responsibility
All staff • Adhere to the PSEA policy and code of conduct, report concerns.
All Managers • Ensure all new employees receive the PSEA policy training as part
of their induction.
• Ensure PSEA measures are implemented within their area of
responsibility.
• Follow up, and address, SEA issues appropriately.
HR staff • Implement the necessary measures when recruiting new staff and
volunteers.
• Ensure all new employees receive a copy of the PSEA policy and code
of conduct, prior to, or at the time of, issuing an employment contract.
Signed copies must be place in their personnel file.
Programme staff • Ensure that communities are aware of the PSEA Policy and how to
report concerns.

6. Write PSEA responsibilities into job

descriptions and include it in performance
management/appraisal discussions.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

Good practice example

Assigning responsibilities What RCK did

for PSEA in a refugee RCK decided to assign focal point
responsibilities to key staff in the organisation.
programme in Kenya The national focal point role was assigned
to the HR/admin officer in Nairobi. RCK
The programme recognised that the HR/admin officer is an
important role for PSEA. The HR/admin officer
The Refugee Consortium of Kenya (RCK)
had the necessary authority to recommend or
promotes and protects the rights and dignity of
take decisions in relation to staff, and she was
refugees, asylum seekers, internally displaced
able to work professionally, be objective and
people and other forced migrants in Kenya and
manage information confidentially.
the wider East African region. The organisation
was established in response to an increasingly RCK also recognised, however, that this role did
complex and deteriorating refugee situation in not have contact with the refugee communities
Kenya and the region. where abuse might be taking place. They
RCK provides legal aid services and needed to assign focal point roles to project
psychosocial counseling; advocates for policy managers who worked in the camps and the
change and raises awareness on the rights of urban communities in which RCK operated.
refugees. The organisation works in Nairobi and
The focal points have been given a number
urban centres and in camps hosting refugees.
of responsibilities for PSEA. The HR/admin
officer is responsible for:
• Delivering induction/training to staff on PSEA.
• Reporting concerns or issues with PSEA
implementation to the Senior Management
Team.
• Receiving reports and coordinating the
response to any reports that arise.
The project managers are responsible for:
• Holding monthly staff meetings during
which they discuss PSEA.
Workshop on PSEA code of conduct • Holding quarterly meetings with refugees
during which they discuss PSEA.
The issue • Receiving reports from refugees.
RCK had introduced some PSEA measures in
2004. In 2010 RCK began work with UNHCR
and, as a requirement of the partnership, had to
include PSEA commitments in all contracts and
demonstrate that the organisation was actively
implementing PSEA measures across the
organisation. RCK needed key people within the
organisation to support PSEA implementation.

13
The senior management team hold a monthly
review of concerns or issues that have arisen What happened as a result
with PSEA implementation, and report as
RCK have been able to demonstrate that PSEA
necessary to their Board of Trustees.
measures are being implemented throughout
Key staff have received introductory training the organisation. All staff are trained and
on PSEA and participated in events on have the opportunity to discuss PSEA on a
investigations. regular basis so awareness on PSEA and code
of conduct is high. Coordination on PSEA
across the organisation is strong - particularly
between the focal points. Lines of reporting
are very clear, refugees know who has
responsibility for receiving and responding
to reports and the team can manage issues
professionally.
RCK has also been able to identify where their
gaps may be. For example, they are exploring
different avenues for encouraging reports on
PSEA to build refugee confidence in reporting.
Further training will be needed for key staff to
Excerpt from booklet produced by RCK to support
manage cases and conduct investigations.
monthly discussions with children on SEA

Lessons learnt
• Need to commit to being accountable on
PSEA – having funds to implement PSEA
measures is not enough.
• Include a proportion of costs for
implementing PSEA measures in all
project proposals.
• Ensure job descriptions reflect
responsibilities, and that time is allocated
for PSEA work.
• Make sure focal points have a good
relationship with the communities you
are supporting – it is difficult for people
to report if they do not know the focal
point, or if they do not trust them.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

ENSURING STAFF, VOLUNTEERS AND

ASSOCIATES UNDERSTAND AND WORK
TO PSEA REQUIREMENTS

What should be in place

• All staff, volunteers and associated 3. Staff should be briefed on their obligations in
personnel sign the organisation’s code of terms of PSEA when joining the organisation.
conduct, or equivalent, which includes PSEA. It is not enough just to sign the code of
conduct – they need to be made aware of its
• All staff, volunteers and associates receive
contents. Inductions should include
induction and (where relevant) annual
refresher training on PSEA. • What is expected of them in terms of
their conduct.
• Staff members are aware of their obligation
to report SEA/misconduct and are aware • What are the implications of breaching
that there is a policy for protection from the code of conduct.
retaliation (often called a whistleblower
• How to report any concerns they might
policy’) in place.
have regarding SEA.
• Supervision and performance appraisals
4. Regular refresher training should be held on
include adherence to code of conduct and
PSEA, covering the above points.
participation in trainings (or similar) that
include PSEA. 5. Awareness raising materials can also be used
to remind staff of the code of conduct. These
could be in the form of posters or leaflets
How to do it displayed in the office and distributed to staff.
1. All staff, volunteers, and associated 6. Procedures such as performance review,
personnel should sign a copy of the annual appraisal and so on could include
organisation’s Code of Conduct (or a section on adherence to the code of
equivalent) when joining the organisation. conduct, and participation in training.
This can be annexed to their contract. Note
7. Staff should be performance managed
that, as an organisational policy, the Code of
on whether they are implementing their
Conduct still applies even to staff who have
role and responsibility for PSEA effectively
for any reasons not signed it.
(see the chapter on Assigning specific
2. Contractors, suppliers and other personnel responsibilities for PSEA).
associated with the organisation should
8. Senior managers should be performance-
also be made aware of the code of conduct.
managed on whether they are creating
See the chapter on Implementing PSEA
an environment to help prevent sexual
requirements with partners, suppliers
exploitation and abuse – for example
and contractors.
ensuring that inductions and training are
taking place, communicating to staff that
they will take any complaint or concerns
seriously, and following up any SEA
issues appropriately and according to the
organisation’s procedures.

15
 Good practice example

Communicating principles What YEU did

and values to YEU staff in YEU set up a series of procedures to
Indonesia ensure that PSEA became part of regular
management processes. This includes:
• Inductions on the organisation’s principles
The programme and code of conduct, which includes PSEA.
YEU is the Emergency Unit of YAKKUM - the
• Quarterly management meetings to
Christian Foundation for Public Health, based
address pressing issues of PSEA, review
in Indonesia. YEU provides humanitarian
PSEA policy, etc.
assistance across Indonesia and the East
Asia region. • Annual all-staff meetings in order to refresh
staff on organisational values and norms,
The issue including PSEA – and share experience of
dealing with PSEA issues from the field.
YEU has an organisational code of conduct,
which covers issues of PSEA. The code of • Displaying agreements with communities on
conduct has been part of all staff contracts the walls of field offices, which include code
since 2011. However, the challenge was to Of conduct and remind staff of the specific
raise staff awareness on PSEA, so it became a behaviour that is expected of them.
‘living’ part of their work – not just something
that they signed with their contract, then
forgot about.

YEU public health programme in Mentawari Island

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

• Implementing 360° feedback for staff

performance (where both managers
What happened as a result
and subordinates can feed back on staff YEU report that the results have been very
performance), which includes breaches of positive – staff are more aware of PSEA issues
the code of conduct. as a result of rolling out these procedures.
• Including PSEA in other associated policies, In addition, working on PSEA has been helpful
such as the communication policy, the for acceptance in the community. YEU are a
information disclosure policy etc – so it is Christian organisation working in a majority
visible across the organisation. Muslim country. Introducing PSEA has
shown the community that YEU are really
thinking about how they can work together
respectfully, and has helped to develop trust.

Lessons learnt
• Be aware of staff turnover, or whenever
there is mobilisation of volunteers,
especially for short-term assistance. You
will need to re-introduce PSEA for each
specific context.
• PSEA is relevant for all staff – from senior
staff to security, drivers, gardeners. There
is no excuse.
• In smaller offices, sometimes managers
have to ‘switch roles’ if there is a PSEA
issue. Make sure they have additional
training on how to deal with it.
• For Christian and other faith-based
YEU Code of Conduct displayed on the office wall organisations, it is helpful to include PSEA
in communications about organisational
values and principles.
• Think about how to roll PSEA out to
partners – not just other NGOs, but
hospitals and others.
• Be aware that zero complaints/reports
does not mean an absence of cases, but
seek to review the enabling environment
for the delivery of complaints/reports.

17
ENGAGING COMMUNITIES AND PEOPLE
AFFECTED BY CRISIS

What should be in place

• Communities we work with are fully 4. Develop your communication materials.
aware of the expected behavior of the There are many different ways to
organisation’s staff, including organisational communicate messages, and a mixture of
commitments made on the prevention of different types can be used. Here are some
sexual exploitation and abuse. suggestions:
• Communities we work with know how to • Posters
complain if these commitments are not met.
• Leaflets
• Appropriate awareness-raising tools and
• Acting out plays
approaches are used with communities,
which are relevant to age, language and • Radio programmes
capacity.
• Focus group discussions
5. Involve the community throughout the
How to do it process of developing your key messages
1. Pull out the key messages from your communication materials. This will help
organisation’s policies on PSEA that ensure that your messages are appropriate,
communities need to know. What should sensitive and likely to get the right message
communities expect from the organisation across.
and its staff in terms of PSEA? What is
6. Always make sure that the community
unacceptable conduct?
members know how to complain if they
2. Profile the community you are think SEA is taking place. Include clear
communicating with. Different groups (such information on how to contact your
as mothers with young children, older organisation with a complaint, for example
men or women with disabilities) will have by including your phone number on a
different communication needs. poster. (See Developing and implementing
a comprehensive complaints Mechanism)
3. Consider how to communicate these key
messages in a way that is relevant and
accessible to the community or community
group. Consider the following points:
• Is this group literate?
• If so, what languages do they speak?
• If your messages are translated, it helps
to have them proof-read by another party
to make sure the message is correct and
appropriate.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

Code of Conduct
Good practice example

Involving the community in The issue

Roll o
PSEA messages in Ethiopia GOAL Ethiopia has a code of conduct that
addresses PSEA, but found that the reality
was, staff were signing it then filing it away
The programme
 Conducted 12 FGDs with community m
GOAL implement a wide-scale humanitarian
programme in Ethiopia, providing
without really being aware of its contents.
GOAL decided that they would look at ways
that they could bring the code of conduct to
Zones to obtain feedback on CoC design
programmes including emergency seeds,
water and sanitation, and community-based
their staff and to the communities they were
working with.

culturally appropriate
management of malnutrition. They have a
large number of staff across many regions,
What GOAL did
most of them Ethiopian nationals.
First of all, GOAL decided to identify the key
messages in the code of conduct. They asked
team members to help define the four top
priority messages from the code of conduct.
They did this by conducting a country-wide
survey.
Working with the monitoring and evaluation
team, the humanitarian programme manager
selected one office in each region of the
country. They then held a meeting with staff
in that office, and put a piece of flipchart
paper on the wall for each of the points in the
code of conduct. Staff were asked to mark
what they thought were the top four most
important points. In addition, the GOAL team
surveyed staff in the country office. They put
out the flipcharts on a wall in the office, and
left them for a week. Staff could mark the
flipcharts whenever they wanted, for example
when they were going for lunch. All the
responses were then added to a database, and
the overall top four priorities were calculated.
The four key priority messages were:
Testing the designs with the community • Do not accept bribes.
• Do not abuse children.
• Do not exclude different groups in
the community.
• Do not sexually exploit people.

19
Next, GOAL’s media officer came up with some
designs and images that he felt matched the
What happened as a result
four key points. The images were then taken As a result of the measures taken, GOAL
out to communities, and were discussed with began to receive feedback from the
a wide group of people – different tribes and community, which was dealt with through
clans, beneficiaries and non-beneficiaries. the appropriate channels. The fact that
At this stage, the designs did not have any PSEA was chosen as one of the four key
writing on, as the team wanted to see if the messages shows that GOAL staff in Ethiopia
communities understood the messages that the take it very seriously, and communicating
images were trying to convey. this to the community demonstrates GOAL’s
commitment on this.
There was a lot of feedback, which was all
fed back to the country office. Some couldn’t
be taken into account, but most could. Text
was also added to the images in the different Lessons learnt
local languages spoken where GOAL works.
The images were then made into posters and • Ensure you have the participation and buy-
displayed wherever possible – at the country in of key staff to roll the message out to
office, in warehouses, in field offices, and so on. communities. It is often assumed that this
trickles down from senior management –
it does not.
• Do not be afraid to approach donors to
fund your PSEA activities.
• No need to create extra meetings for
community feedback – add it on the
meetings that are already planned.

Some of the original designs….

…and the finished version

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

IMPLEMENTING PSEA REQUIREMENTS WITH

PARTNERS, SUPPLIERS AND CONTRACTORS

What should be in place

• Partners, suppliers and contractors are 3. Develop contracts for organisations/
assessed for their contact with beneficiaries, companies which include PSEA
and capacity to implement PSEA measures. requirements and commitments (if
necessary) to supporting the organisation/
• Clauses on PSEA are included in all contract
company to meet requirements.
agreements.
4. Ensure that staff of organisations/companies
• PSEA training is delivered to partners,
working directly with beneficiaries sign onto
suppliers and contractors (particularly
a code of conduct, either yours or the that
where these organisations will have contact
of the organisation’s/company’s (if it is of an
with beneficiaries).
acceptable standard).
• PSEA measures, and SEA cases, in partner,
5. Decide on the best approach for training the
supplier and contractor organisations are
organisations/companies on PSEA, based on
monitored.
the context and resources available.
6. Deliver a short briefing to all organisations/
How to do it companies on PSEA.
1. Assess all partners, suppliers and
7. Include the organisation/company staff
contractors before the contracting
in staff training events if they are directly
arrangements are agreed:
implementing activities or have significant
• Will the organisation/company be working contact with beneficiaries.
directly with beneficiaries?
8. Agree with organisations/companies how to
• Will the services they deliver bring them exchange information on PSEA. This should
into contact with beneficiaries? include:
(If yes, the partner, supplier or contractor will • Progress with implementing PSEA measures
need to have a PSEA policy and code of conduct to be included in reports on progress with
or sign onto your policy and code of conduct) projects or services (where appropriate).
•W
 hat is the status of the organisation/ • Concerns or cases which arise regarding
company PSEA measures? the organisation/company will need to be
reported to your organisation.
• Do they have a PSEA policy and code of
conduct? Partners are commonly defined as those organisations
• How well has the policy been implemented which are contracted to deliver programmes and projects,
or providing funding.
throughout the organisation? Suppliers are commonly defined as organisations or
companies that have been contracted to provide goods,
(The responses to these questions will help you equipment and other supplies that are being used by
decide what support to provide to the partner/ the organisation generally, including for the delivery of
supplier/contractor) programmes and projects.
Contractors are commonly defined as organisations or
companies that have been contracted to deliver specific
services, such as construction work.

21
 Good practice example

Implementing measures to has a policy and code of conduct, how it

recruits and inducts staff, the partner’s
prevent sexual exploitation reporting/complaints mechanisms, how child
and abuse (and other harm) safeguarding measures are embedded in its
operations and programme interventions, and
of children with partners, its arrangements for monitoring the measures
suppliers and contractors that prevent harm. Plan International will
not go ahead with the partnership if they
consider that the organisation presents
The programme a significant risk for children which it
is unwilling to address. Increasingly,
Plan International is a global international
however, all organisations with whom Plan
development and humanitarian organisation
International partners are actively interested
focused on children’s rights and equality for
in strengthening their organisational capacity
girls. Plan International has programmes in
to prevent harm to children and welcome
over 70 countries and works extensively with
support from Plan International to do so.
national and local partners.
All agreements made with partners,
suppliers and contractors include a clause
The issue on preventing harm to children As Plan
As an organisation focused on children International is committed to safeguarding
and adolescent girls, Plan International children generally, the requirements for
has had policies and procedures in place partners, suppliers and contractors includes
for preventing harm (including sexual informing Plan International if any of their
exploitation and abuse) to children for more staff members is being investigated for
than 15 years. The growing scale of Plan harm to children, including SEA, regardless
International’s partnerships, the types of of whether they are working directly with
organisation partnered with, and the use children through the partnership or not.
of suppliers and contractors for its work,
The commitments described in the partnership
meant that Plan International must ensure
contract, informed by the assessment, might
that these organisations are able to work to
include support to the partner for developing
international standards for child safeguarding,
a policy, shared training, linked reporting/
which include preventing sexual abuse and
complaints mechanisms and exchanging
exploitation of children.
outcomes from the monitoring of the
measures for preventing harm to children.
What Plan International did Plan International is now supporting its
Plan International’s Child Protection national and local partners to support
(Safeguarding) Policy outlines minimum smaller civil society organisations (CSOs)
standards for engaging with partners, to put minimum (suitable) standards in
suppliers and contractors. The minimum place for preventing harm to children. Plan
standards require Plan’s offices to assess all International helps the national or local
partners’ capacity to implement measures partner to run workshops with the civil
to prevent harm to children. The assessment society organisations to raise awareness on
informs the overall decision of whether or not the importance of measures to prevent harm,
to work with the partner. The assessment is and to agree on the measures that the civil
based on ten key questions – if the partner society organisations will adopt.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

What happened as a result

Plan International’s approach to
Lessons learnt
implementing these measures with • Resources are required for supporting partners,
partners, suppliers and contractors suppliers and contractors to have the necessary
has progressed from one based on measures in place Costs for preventing harm
contractual compliance to an approach should be built into all relevant project and
which contributes to improved outcomes programme budgets – this is easier to do
for children’s safety more generally, such where the costs can be included in capacity
as increased awareness in communities, building plans for partners (which donors tend
changes to local laws and a range of to favour).
organisations with appropriate policies
and procedures. This has arisen from the • A large number of partners, suppliers and
way in which Plan International looks at contractors work with more than one
the risks involved (not only considering organisation – are the other organisations
the actual contact that organisations also supporting them on measures to prevent
have with beneficiaries, but also how harm? This is worth finding out to avoid
robust partners are in developing and duplication of effort and save resources.
implementing measures to prevent • Sharing, and maximising, capacity building
harm generally), and the investment of partners between organisations would be
Plan International has made in building valuable e.g. if one organisation is delivering
capacity of partners, contractors, and capacity building interventions for partners, if
suppliers (where necessary). possible, extend the invite to partners of other
organisations working in the same location.
• In countries where the governments have
legislated on SEA or harassment, use this as
a driver for ensuring that partners, suppliers
and contractors have the necessary measures
in place.

23
DESIGNING SAFE PROGRAMMES AND PROJECTS

What should be in place

• Potential risks of sexual exploitation and 4. Design programmes/projects to address any
abuse presented by programmes and risks identified – ensure all those involved
projects are identified and addressed. in the delivery of goods and services
are safe; include costs for prevention,
• Project plans include activities on PSEA
awareness raising, training on SEA and
awareness and sensitivity.
response in programme/project budgets.
• Budgets include funding lines for capacity
5. Incorporate awareness raising and
building and communications on PSEA.
communications on PSEA into programme/
project activities.
How to do it 6. Monitor, with the communities you are
1. Assess the context in which the programme working with, whether the programme/
is to take place – identify the general risks project is safe – ask specific questions
and issues related to sexual exploitation about whether harm or abuse has arisen
and abuse in communities. Communities because of the delivery of goods and
experiencing abuse and exploitation services, whether that has been reported,
are also more vulnerable to it being and what would help to prevent this arising
perpetrated by staff and associated in future.
personnel, and those contracted to deliver
7. Adapt, or redesign, any programme/project
programmes.
that is presenting a risk of SEA by staff or
2. Map the patterns of behaviour within associated personnel.
families and communities when designing
8. Identify and document existing local and
programmes and projects - who fetches
national child protection mechanisms and
water, who manages household income.
related support services for referral.
These patterns of behavior might make
certain family members more vulnerable to
SEA, such as adolescent girls whilst fetching
water from remote water points.
3. Identify how the programme/project might
exacerbate the risk of SEA by staff and
associated personnel - will certain groups
within the community not be receiving
goods and services? Are the goods and
services likely to be inadequate for the
beneficiary population, or delivered
unpredictably? Beneficiaries who
desperately need goods and services will be
more vulnerable to exploitation.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

Good practice example

Supporting organisational • Programmes and projects delivered by ‘safe’

staff, partners and other stakeholders.
change to ensure • Programmes and projects deliver on the
programmes and projects rights and needs identified with beneficiaries
are safe (within Save the Children’s remit) to achieve
positive outcomes - minimising opportunities
for exploitation within communities, and
The programme from humanitarian workers.
Save the Children is an international NGO • Programmes and projects do no harm
focused on creating, and supporting, to children or other beneficiaries – they
opportunities to give children a healthy start in are designed, implemented, monitored
life, to enable children to learn and to protect and evaluated using a risk management
children from harm. Save the Children work approach, identifying and minimising risk.
globally, reaching around 62 million children
either working directly and through partners.
Save the Children works in both development
What Save the Children did
and humanitarian contexts, including those Save the Children developed a structured
which are particularly fragile and complex. approach to ensuring programmes and
projects are safe. The initiative was led by
Save the Children’s global child safeguarding
The issue team who:
Save the Children has been implementing
• Assessed how different departments
PSEA measures throughout the organisation
and teams in the organisation support
for more than a decade, as part of their
or contribute to designing and delivering
commitment to safeguard children
programmes, and the standards they work to.
(implemented through their Child
Safeguarding Policy) but also as part of their • Adapted existing standards and processes
commitment to prevent sexual exploitation to ensure safety is embedded into
and abuse of adult beneficiaries. Save the department/team work on programming.
Children has played a significant role in
• Developed guidance and tools on safe
supporting the sector on PSEA, working
programming which enable staff to
with the IASC PSEA Task Team, contributing
assess and minimise risk and to design
to the To Serve With Pride film used widely
programmes to achieve positive outcomes
for training staff and others on PSEA and
in safer environments.
providing technical input at CHS Alliance PSEA
events and conferences. • Built capacity of staff and partners on safe
programming.
Save the Children has recently introduced
key initiatives across the organisation to
realise ambitions to be a high performing
organisation. One of these initiatives is
to strengthen organisational approaches
and practices for safe programming. Safe
programming in Save the Children refers to:

25
What happened as a result
The initial work on assessing how different Lessons learnt
departments and teams contribute to
designing and delivering programmes • Safe programming cuts across different
highlighted how the organisation needs to functions, teams or departments – make
work together across functions: sure they all understand how to integrate
safe programming into their work.
• Programme staff design programmes and
projects – and need to understand how to • Assessing and minimising risks is key to
make them safe. ensuring programmes are as safe as possible
– at the very least a rapid risk assessment
• The risk management team provides tools can be conducted at the beginning of an
and guidance on risk assessing programmes emergency response, but a more thorough
and projects, and these need to include risks risk assessment will be needed once the
associated with safe programming. programme or project is underway.
• Award management staff provide guidance • Projects and programmes should not be
and tools on agreeing to a programme/ ‘signed off’ by management without a
project proposal and ‘signing it off’ – the good risk assessment.
guidance and tools need to to ensure the
• All stakeholders involved in the project
proposal includes a comprehensive risk
need to understand safe programming
assessment for safe programming.
and be able to deliver their part of the
• Procurement staff are responsible for programme safely.
obtaining supplies for the programme/ • It is unlikely that you will be able to
project – they need to ensure that the mitigate all risks – minimise them but
supplies are ‘fit for purpose’. be aware of the risks the programme or
• Technical experts on child safeguarding project is carrying.
(and PSEA) need to be able to provide • Regular monitoring of the programme
advice on how to design and deliver or project is vital – make sure that
safer programmes. monitoring looks for unintended negative
• Monitoring and evaluation staff have an consequences, which should then be
important role to play in monitoring whether addressed immediately.
the project is being implemented safely.
Save the Children developed overall guidance
on child safe programming. In addition, a key
part of the work was to advise departments
and teams what changes they needed to
make in their guidance, tools and approaches
to support safe programming. They also
supported the leadership in creating an
organisational culture for safe programming.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

DEVELOPING AND IMPLEMENTING A

COMPREHENSIVE COMPLAINTS MECHANISM

What should be in place How to do it

• A documented complaints handling 1. If your organisation does not already have
process for communities and people a complaints mechanism in place, you
affected by crisis. will need to develop one. Resources are
widely available to help you to develop a
• An organisational culture in which all
complaints policy, and set up a safe, secure
complaints, including SEA are taken
and accessible complaints mechanism.
seriously and acted upon.
Below are the key considerations for
• Communities are made aware of what developing a complaints mechanism.
behaviour they can expect from organisation
2. Reports on SEA should be referred directly
staff, and of organisational commitments
to a named senior manager within the
made on protection from sexual exploitation
organisation. Staff should understand the
and abuse – and how to complain if these
importance of following this procedure.
commitments are not met (see Engaging
They should be clear that they should not
communities and beneficiaries on SEA).
try to investigate themselves, and that
• Complaints channels that are designed to they should not discuss the complaint with
proactively enable reports of SEA. anyone else. They must also understand
their own responsibility to report any
• A fast-track process for dealing with
concerns they might have regarding
complaints about SEA.
colleagues or partners and SEA.
• A referral process for complaints which
do not fall within the scope of your
organisation’s policy.

Key considerations for developing a complaints mechanism

Consult with communities and people affected by crisis on the design, implementation and
monitoring of complaints-handling processes.
Get senior management support for the mechanism – from the start.
Ensure that staff members understand the rationale for the complaints mechanism
and the importance of maintaining confidentiality, and can receive and deal with
complaints confidently.
Communicate with communities so that they understand how they can raise a complaint and
what they can complain about.
Have more than one channel through which communities can make complaints to your
organisation. Possible channels could include SMS, email, letter, telephone hotline,
information desk, complaints box or face-to-face meeting, amongst others. Consider how
the safe and private these channels will be for someone complaining about SEA.
Ensure that the mechanism can manage complaints in a confidential and timely manner
which ensures the safety of all involved.

27
3. SEA is by its nature a sensitive issue. 6. If you open up the possibility of SEA
Consider carefully whether you have reports with the community, it is absolutely
developed communication channels that vital that you follow them up. Raising
proactively enable reports about SEA. concerns of SEA can be distressing for the
When consulting the community about complainant, and we have a responsibility
your complaints mechanism, be sure to to take it seriously. Not following up such
consult diverse groups on how they might serious concerns could lead to a breakdown
feel comfortable in reporting SEA. Look of trust between your organisation and the
also at how you can use existing activities community who have raised the concerns.
to pick up concerns regarding SEA – such (See Responding to reports of SEA.)
as work with women’s groups, or outreach
work on gender-based violence.
4. Organisations are increasingly developing
joint complaints mechanisms, some
focusing on SEA. Find out if there is a
joint complaints mechanism in your area
of operation, and consider whether you
would like to participate. Participating in
a joint complaints mechanism will usually
mean agreeing to common standards and
procedures for dealing with SEA for all
members.
5. Monitor and review your PSEA complaints
mechanisms on an ongoing basis to check:
• Is the mechanism receiving complaints?
What kind of complaints are they
receiving? If your complaints channels
are not picking up reports of SEA, explore
the possible reasons for this
• Is the mechanism appropriate? Does the
community feel comfortable using it?
• Does the mechanism put users at further
risk?
• Who is using the mechanism? Is it
reaching all community groups, including
the most vulnerable?
• Are complaints, including reports of SEA,
being followed up appropriately within
your organisation?

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

Good practice example

PSEA complaints What CCSDPT did

mechanisms on the First of all, CCSDPT developed an inter-agency
Thai-Burma border protocol for dealing with complaints of SEA.
The protocol included:
• The channels through which complaints
The programme might be received.
The Committee for the Coordination of
• Assigning Focal Points to deal with and refer
Services to Displaced Persons in Thailand
incoming complaints.
(CCSPDT) is a network of NGOs and
community-based organisations working with • Clear guidance on management
displaced people in camps along the Thai- responsibilities for dealing with complaints
Burma border. once they were received.
• Procedures for investigating complaints
The issue of SEA.
CCSDPT wanted to provide an environment • How to refer complaints made about
where refugees, particularly those most another network member.
vulnerable in their communities, knew they
• Support to survivors of SEA.
were able to access services free from abuse
and exploitation. • Establishing a steering committee to ensure
complaints were being dealt with according
to the protocol.

CCSDPT member agency staff at work

29
Member agencies then implemented a
widespread roll-out of PSEA measures to
What happened as a result
the camps. Entry points for complaints Cases of PSEA began to reported to CCSDPT,
were designed, including through existing and were dealt with according to the
structures such as community-based protocol. Three years after the mechanisms
organisations, the sexual and gender-based were introduced, an assessment found that
violence committees, complaints boxes, or the community perceived that SEA had
reporting directly to the agency. significantly reduced.
From the Compendium of Practices on
Community-Based Complaints Mechanisms,
IASC, 2012

Lessons learnt
• Consult with beneficiaries and CBOs on
your complaints mechanism from the
design stage onwards, otherwise it can
affect use and sustainability.
• Consult with vulnerable groups, such as
new arrivals to the camp, single women
and children on reporting mechanisms.
The CCSDPT Protocols
• Consider different community languages
Awareness raising was then conducted and customs from the start.
through community-based organisation
• Consider how to ensure the momentum
representatives. This included PSEA
on PSEA is maintained once dedicated
messaging in local language on caps and bags,
resources are no longer available.
and through theatre and radio broadcasts.

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 CHS ALLIANCE / PSEA IMPLEMENTATION QUICK REFERENCE HANDBOOK

RESPONDING TO REPORTS OF SEA

What should be in place

• Written procedures on responding to • More information is needed to determine
reports or concerns relating to SEA if SEA took place, which may require an
Investigations are undertaken in line with investigation.
the relevant standards and guidance.
Remember if a report has been raised through
• Investigations are undertaken by your complaints mechanism, you will need
experienced and qualified professionals, to respond to the complainant to let them
who are trained on sensitive investigations know you have processed the complaint
such as allegations of SEA. and resolved the issue. For confidentiality
reasons, more detailed information is not
• Substantiated complaints result in
usually provided.
either disciplinary action or contractual
consequences. 3. If an investigation is required, it is advised
that it is undertaken by experienced and
qualified professionals, who are trained on
How to do it sensitive investigations such as allegations
1. Make sure your organisation has policies of SEA. If there is no-one within your
and procedures in place for responding to organisation with these qualifications and
reports or concerns relating to SEA. Tools training, you should consider accessing
and resources are widely available to help external resources to help you. Contact
you with this. CHS Alliance for further information.
2. When you receive a report, or hear of a It is extremely important that reports
concern about SEA, there may be several relating to SEA are investigated properly.
different actions the organisation might If you do not follow due process, it can
take. These could include: make it harder for you to discipline or
dismiss a staff member. Staff members who
• The report or concern does not actually
have been the subject of concerns may
represent a breach of policy – no
move on to work for other organisations
actions taken.
without the issue having been addressed.
• The report or concern results in Staff members who are the subject of an
immediate dismissal according to your allegation are entitled to a fair process to
organisation’s disciplinary procedures determine what actually happened, rather
– for example, if there is already clear than being subject to gossip and rumours.
evidence that SEA took place, or the staff
4. Once the SEA case has been resolved, there
member does not deny it.
are several issues you will need to consider:
• If the report involves a criminal act, it
• Confidentiality will still need to be
must be referred to the local authorities
maintained. The issue should not be
if it relates to a child under the age of 18,
discussed with anyone other than on
it may be referred to the local authorities
a need-to-know basis.
if it involves an adult, s/he agrees to a
referral and if this does not represent • All paperwork relating to the case will
a protection risk to anyone involved. need to be kept securely.

31
 • Your organisation will need to have a
policy on what goes on the personnel file
of the staff member against whom the
complaint was made – whether it was
upheld or not.
• If a staff member was found to have
breached the Code of Conduct, be clear
on what can be included legally in
their references.
5. A
 case of SEA can have an impact on staff
morale. By the time a complaint is made,
there might already have been months
of rumours and concerns circulating
in the affected office, and in the wider
community. Staff may then feel excluded
by the investigation, as confidentiality
requirements mean they can know nothing
about it. They may feel let down by the
conclusion. The organisation may well
have to invest time in restoring staff and
community morale, by listening to their
concerns and reassuring them that due
process has been undertaken, whilst
explaining why some aspects of the case
need to remain confidential.

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Good practice example

Oxfam GB’s case

management procedures
The programme
Oxfam Great Britain is one of the 18 Oxfam
affiliates that make up the confederation of
Oxfam International. Oxfam’s aims are:
• to prevent and relieve poverty and to
protect vulnerable people, including
through humanitarian intervention.
• to advance sustainable development.
• to promote human rights, equality and
diversity, in particular where to do so
contributes to the prevention and relief
of poverty.
Oxfam GB achieves this through working in
three interconnected ways, on humanitarian,
development and advocacy programmes.
Oxfam PSEA poster
Their work focuses on active citizenship,
advancing gender justice, life saving Oxfam recognises that if you invite people to
programmes, sustainable food and financing report concerns of sexual exploitation and
for development. They currently work in 51 abuse, it is vital that you have the procedures
countries globally. in place to follow them up appropriately. Not
doing so is likely to cause additional risk and
distress to complainants, and also greatly risks
The issue your relationship of trust with your staff and
Oxfam has long recognised the importance of the communities you are working with.
preventing sexual exploitation and abuse, and
has been putting measures in place for over
ten years. Work has been done to implement
What Oxfam did
stringent policies, and make staff aware of Oxfam established various entry points for
their responsibilities. Additionally, Oxfam reporting SEA (and other serious misconduct),
has invested in making the communities they including reporting to line managers or other
work with aware of their rights in terms of appropriate senior staff members; a network
assistance, and have put measures in place of safeguarding focal points; a whistleblower
to enable them to give feedback and make hotline and community-based complaints
complaints. mechanisms.
Oxfam also developed a system for dealing
with SEA reports when they enter the
organisation. The steps are as follows:
1. Refer safeguarding/SEA reports to Oxfam’s
safeguarding team.

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2. Assign responsibility for the case to the
relevant staff member. This could be the What happened as a result
country director, or somebody more senior
Oxfam’s measures have resulted in an
according to what is appropriate in each
increase in reports of SEA, which are handled
case. This person will be the decision
according to the procedures outlined above.
maker for this case.
The safeguarding team found that most reports
3. Convene a case conference. This usually
were made to an individual. This would either
consists of:
be someone the complainants knew in person,
• head of global safeguarding such as a trusted manager or a focal point, or
because they had seen someone’s name and
• Decision maker (see above)
picture on a document or website. Very often,
• Person who received the report reports would come about after a safeguarding
(such as the focal point, or manager) workshop – participants might approach the
trainer afterwards with specific issues. Reports
• HR manager
are less likely to come in through an impersonal
4. C
 onduct and sign off on risk assessment. channel, like the whistleblowing e-mail
Sign off must be given jointly by the head of address – although its important to have these
global safeguarding and the decision maker. channels, so that people have different options
through which they can raise a concern.
5. D
 ecide on next steps to take and write
a terms of reference if necessary. In 2015/16, Oxfam handled 64 reports of
sexual exploitation and abuse (this includes
6. W
 hen case is concluded, refer to HR
reports from all areas of their work, including
policy and procedure to conclude case
their UK-based shops). Oxfam sees this as
as appropriate (for example, disciplinary
a sign that they are improving visibility of
action, notes on file, etc, depending on the
this important issue and giving victims more
outcome of the investigation).
confidence to report incidents.
Disciplinary action does not necessarily mean
dismissal – it could be a written warning, a
meeting with the manager, a note on the file
etc. However it usually results in one of these
two outcomes, due to the seriousness of SEA.
It does not matter who fulfils roles in case
management, as long as:
• The decision maker is a senior staff member
(country director or equivalent).
• The investigators (if an investigation is
required) are not the same people as the
decision makers.
• Everyone involved has an understanding
of PSEA issues and procedures – not just
the investigators. It is worth providing
additional training on PSEA and case
management to everyone with decision-
making responsibility.

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Lessons learnt
• Staff involved in responding to reports • If you are smaller NGO, there is plenty of
need to have the right understanding of, help out there for you. Borrow someone
and attitude towards, sexual violence. else’s policies. Ask larger or international
• You can access experts at a national partners for help - capacity building
level, in wider civil society – people with should be part of their responsibility.
experience in the police, legal professions, • You are not on your own. If in doubt,
or in fraud can all potentially make good ask an NGO with expertise to help! The
SEA investigators or advisors – although CHS Alliance can also provide you with
they must be well managed and must guidance and support.
have the right attitude towards sexual
violence (as above).
• The more self-reflective your organisation
is, more you will succeed. Responding
to SEA will not work as a ‘box ticking’
exercise.
• There will be staff who do not respect
case management procedure: for example
not referring reports, try to investigate
themselves, or trying to get confidential
information from the case management
team – these should be treated as
disciplinary matters.

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NOTES

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