Purpose

Seefar is committed to ensuring the safety and protection of all individuals, including children, young people, and vulnerable adults, from abuse, neglect, and exploitation. This policy enshrines Seefar’s zero-tolerance commitment to Sexual Exploitation, Abuse, and Harassment (SEAH) and Bullying, Harassment, and Discrimination (BHD), ensuring a safe and respectful working environment for all.

The purpose of Seefar’s safeguarding policy is to:

• Ensure the safety and protection of children, young people, vulnerable adults who receive our services, including the children of adults who benefit from our services.
• Provide Seefar personnel with the overarching principles that guide our approach to safeguarding and child protection and ensure that the protection and safety of all individuals, including children, is prioritised in every area of our work. This includes that it is safe for those affected to come forward and to report incidents and concerns with the assurance that Seefar will handle these sensitively and efficiently. 

Applicability

This policy applies to all Seefar personnel, consultants, trainees, volunteers, interns, and where possible extends to and requires that all contractors, agents, sponsors, or any other person or persons associated with us (including third parties), adhere to this policy. Those responsible for Seefar legal entities have responsibility for adapting this SOP to local requirements. The policy also applies to Trustees, Board, and/or Committee members at all levels.

Definition of a Child

For the purposes of this policy, a child is defined as any person under the age of 18, irrespective of the local age of consent or majority in programme countries. Sexual relations with persons under 18 are strictly prohibited.

Background

What is Safeguarding?

Safeguarding Definition: In this policy, safeguarding refers to actions taken to protect children, young people, and vulnerable adults from harm, ensuring their health, development, and overall well-being. It encompasses preventing harm and ensuring safe and effective care for them.

Guiding Principles

Our team must maintain a focus and commitment to safeguarding the well-being of children, young individuals, and vulnerable adults. This commitment entails adhering to key principles that guide our actions in every possible instance:

1. Prioritise Safety: Give the highest precedence to ensuring the safety and well-being of children, young people, and vulnerable adults in all our endeavours.
2. Recognise and Act: Identify and promptly respond to indications of abuse, neglect, and concerns regarding safeguarding.
3. Appropriate Action: Take suitable action in response to disclosures of abuse by children or young people and allegations against personnel or other parties.
4. Risk Awareness: Maintain vigilance regarding potential risks posed by abusers or potential abusers and proactively take preventive measures.
5. Contribute to Safeguarding Processes: Contribute, as necessary, to Seefar's safeguarding and protection processes.

Safeguarding Procedures

Personnel, and where possible contractors, must report all safeguarding concerns and incidents that occur in the course of his/her work using the FOBE: HR Grievance Form available on Drive. Examples include reporting any maltreatment or abuse to children, young people and vulnerable adults.

When reporting a major concern or incident, a member of the Board and/or HR should be notified before submitting the HR Grievance Form.

Seefar’s Safeguarding Procedures include:

1.   Recruitment

When recruiting personnel whose roles involve direct contact with children, young people, and vulnerable populations, we are committed to integrating thorough screening procedures into our hiring process. This includes a careful review during the interview process and reference checks, where specific attention is given to the following aspects:

• Identification of gaps in employment history
• Examination of frequent changes in employment or address
• Inquiry into reasons for leaving employment, especially for sudden job departures
• Clarification of duties and accomplishments in relation to working with individuals, particularly children, if mentioned ambiguously in the CV
• Assessment of body language, evasion, contradictions, and discrepancies in provided answers, interpreting them sensibly.

Additionally, the selected candidate will need to present proof of identity (e.g., passport, driver’s licence) and, if feasible, secure a police clearance certificate.

2.   Training

During the onboarding process, all newly onboarded personnel are introduced to Seefar's safeguarding policy and are required to sign the code of conduct and resign it every two years. Seefar facilitates regular opportunities for addressing queries and gaining insights into safeguarding matters. Moreover, each staff member is required to complete an annual certification process, reinforcing comprehension of our safeguarding procedures and measures.

3.   Interaction Standards

At Seefar, prioritising the well-being of individuals we engage with is paramount. We establish clear and appropriate standards of conduct towards both adults and children in each pertinent project. These expected behavioural standards, provided below, are to be understood and observed with transparency and practicality. Personnel are expected to familiarise themselves with the local customs regarding physical contact, and when applicable, projects will incorporate an orientation on the expected behavioural standards for personnel.

Risk Mitigation

• Do: Avoid placing yourself in a compromising or vulnerable position, and fill out an FOBE: HR Grievance Form if a situation occurs involving a project participant, which may be subject to misinterpretation.
• Do not: Be alone with a project participant, including a child, in a closed space (if in a room make sure the door is open); show favouritism or spend excessive amounts of time with one person.
• Sexual behaviour, harassment, abuse, assault and exploitation
• Do: Report any harassment, abuse, assault, exploitation or violence that is experienced or observed without unreasonable delay using the FOBE: HR Grievance Form. It is the individual’s decision whether or not to report the incident to the police or other authorities.
• Do not: Make physical contact with beneficiaries, including children, in an inappropriate or culturally insensitive way.
• Do not: Deliberately access internet sites containing pornographic, offensive or obscene material.
• Do not: Participate in any form of sexual harassment, abuse, assault exploitation or other forms of sexual violence. Seefar has a zero tolerance policy towards these acts. Any sexual, romantic or otherwise inappropriate contact with Seefar’s project participants is strictly prohibited. The use of sex workers by Seefar personnel is also strictly prohibited.

Please see Annex 1 for a list of definitions of sexual harassment, abuse, assault, exploitation and sexual violence.  

Psycho-social behaviour

• Do: Try to be alert to physical and emotional states of the people you are working with; be aware of the power balances and avoid taking advantage of these; always report cases via the FOBE: HR Grievance Form where there is an immediate risk of harm, and, if requested, signpost to appropriate services and organisations.
• Do not: Display discriminatory, prejudicial or oppressive behaviour or language towards anyone; do not yell or call anyone names; or act in any way that intends to embarrass, shame, humiliate or degrade an individual.

Depicting Children, Young People and Vulnerable Adults 

Seefar holds a duty of care towards project participants, encompassing both adults and children, and is steadfast in prioritising their interests and well-being. Any depiction, whether in words or images, of project participants should safeguard their identity, uphold their dignity, and maintain accuracy, fairness, and balance.

Guidelines:

• Do: Obtain consent from individuals (or, in the case of children, their guardians) before pictures are taken and images used for publicity or awareness-raising purposes. Confirm consent in writing if the images will be used for publicity purposes, and file these in a secure location.
• Do: Encourage individuals to share their own accounts whenever feasible, rather than relying on others to speak on their behalf.
• Do: Present accurate and balanced portrayals of individuals in campaigns and research, emphasising their dignity and avoiding portrayal as passive victims.
• Do: Always change the names of project participants to protect their identity, unless they have explicitly stated a preference that their real name should be used, and there are no security implications.
• Do not: Disclose any personal information (e.g., location) that could jeopardise an individual on Seefar platforms or in public-facing materials.
• Do not: Manipulate images of individuals.
• Do: Ensure individuals are appropriately clothed and photos should not be sexually suggestive.
• Do: Require third parties requesting the use of Seefar images or other materials to agree to Seefar-stipulated conditions regarding the proper and specific use of the materials for the agreed purpose(s) without the rights of redistribution, reuse or syndication. This can be done through an agreed contract, terms of the contract may vary from case to case.
• Do: Accompany images with captions wherever possible.

Reporting Criminal Activity and Referring to Support Services

In reporting and addressing safeguarding concerns, the welfare and best interests of the individual take precedence.

Seefar will provide assistance to any individual involved in its project in order to protect them from further harm where it is within Seefar’s capabilities, scope and capacity to do so. This may involve referrals to relevant agencies, authorities, or donors rather than direct care provision.

• Do: Ensure individuals in Seefar projects are informed, in a suitable and understandable manner based on their age and language, about actions to take if they feel uncomfortable and need to report an incident. This is the responsibility of Seefar's in-country personnel.
• Do: Let the individual decide whether to disclose information to Seefar when reporting criminality, and let them advise how they would like Seefar to handle it.
• Do: Delete all confidential information relating to protection and safeguarding incidents every seven years unless special circumstances warrant retention. This process is monitored annually by HR.
• Do: Maintain a list of local agencies dealing with protection and support services, to whom individuals can be referred. This responsibility lies with Project Coordinators. Additionally, Project Coordinators should devise and communicate a project security plan with comprehensive incident reporting details for the respective region.

Addressing Misconduct

Seefar maintains a steadfast commitment to addressing any misconduct or violations within the organisation, ensuring a professional and accountable approach. The process for dealing with misconduct is outlined below:

1. Reporting Discrimination

All personnel and, where feasible, contractors are required to report any incidents of discrimination using the FOBE: HR Grievance Form available on Drive.

2. Reporting Major Incidents

In the event of a major incident, a member of the Board and/or HR should be informed before completing the FOBE: HR Grievance Form available on Drive.

3. Handling Misconduct

We view cases of misconduct or alleged violations as serious matters and will manage them in a professional manner under the enterprise's grievance and/or disciplinary procedures. Appropriate action will be taken following a thorough investigation.

4. Suspension and Investigation

Immediate action will be taken to remove the affected individual from the situation. If a member of the organisation is alleged to be involved in an incident, they may be suspended on full pay pending the completion of an investigation. The decision for suspension will be made by a senior manager in conjunction with HR and is not subject to challenge. Suspension is intended to maintain a fair investigative process, preserve evidence, prevent intimidation of involved parties, and mitigate potential risks.

5. Investigation Process

The investigation will be confidential, and information limited only to those who need to know. All parties are bound by confidentiality, and documentation will be securely filed. The investigation will be led by HR in close coordination with the Board. The investigation is a documented process compromising the following steps:

1. The organisation receives the allegation
2. Management makes decision on how to proceed, including any safeguarding concerns
3. Appointment of investigation team
4. Plan investigation, including a risk assessment
5. Gather and study background material and other documentary evidence
6. Draft interview questions
7. Interview parties to the allegation and any witnesses
8. Write a report including conclusions and recommendations
9. Conclude investigation

6. Disciplinary Action

Any breach of Seefar’s safeguarding policy warrants swift disciplinary action. Depending on the severity and nature of the misconduct, this may include termination of contract for consultants and contractors, ending the relationship with volunteers and interns; withdrawal of funding/support and ending the relationship with local partner organisations; legal actions, and criminal prosecution for severe violations like sexual harassment or assault.

7. Appeals Process

Adverse determinations from an investigation may be challenged through an appeals process, ensuring a fair and just resolution. All parties involved will be notified of the investigation's outcome and the organisation's decisions in a timely manner. Please see the SOP Personnel Grievances for more information on this process.

Monitoring Incidents

HR monitors all safeguarding related concerns and incidents reported via the HR Grievance Report Form. Such reports are collated and analysed by the project team and HR on a regular basis. Recommendations arising from analysis feed into an annual review of Seefar’s Safeguarding Policy.

Seefar is committed to upholding its policies and values, ensuring a safe, inclusive, and respectful environment for all individuals associated with the organisation and reserves the right to amend this policy at any time.

Annex 1

Seefar refers to the Inter Agency Standing Committee’s (IASC) definitions:

• Sexual Harassment: Unwelcome sexual advances, requests for sexual favours, and other verbal or physical conduct of a sexual nature.
• Sexual Abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.
• Sexual Assault: Any form of non-consensual sexual contact that does not result in or include penetration.
• 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. Some types of forced and/or coerced prostitution can fall under this category.
• Sexual Violence: Sexual violence is any sexual act, attempt to obtain a sexual act, unwanted sexual comments or advances, or acts to traffic a person’s sexuality, using coercion, threats of harm or physical force, by any person regardless or relationship to the victim, in any setting, including but not limited to home and work.