- Purpose and Scope
- This section outlines the purpose and scope of the document, explaining its objectives and limitations.
3. STRATEGIC FOCUS
- An Organisational Culture of Zero Tolerance
- Reporting Mechanisms
- Investigations and Sanctions
- Survivor-Centred Response
- Engaging Partners
- Leaders as Champions
- Coordination and Collaboration
- Normative and Regulatory Instruments
ANNEX ONE: Definitions
Sexual Exploitation and Abuse (SEA) and Sexual Harassment (SH) are unacceptable breaches of fundamental human rights and a deep betrayal of SRADHA’s core values. The sexual exploitation and abuse of those who depend on SRADHA for assistance runs counter to all our personal and organisational values. It is unconscionable, it is intolerable, and it is often criminal. Equally intolerable is the sexual harassment of our fellow aid workers including volunteers.
Working closely with local partners and communities, SRADHA has significantly stepped up its fight against SEA and SH. This work is informed by, and taking place in tandem with, the work of related actors including the communities, donors, and civil society organizations.
In 2019, an independent review of SRADHA’s response to protection from sexual exploitation and abuse and an independent review of how the organization has dealt with claims of sexual harassment in the workplace were completed. Both reviews have delivered a comprehensive set of recommendations which are being addressed in line with this strategy. In addition, an Independent Task Force of external and internal advisors on Workplace Gender Discrimination & Harassment was established in 2019 to review current practices and provide recommendations to effectively and systematically prevent and address workplace gender-related discrimination, harassment and abuse of power.
This document presents SRADHA’s vision for preventing and responding to both SEA and SH and sets out concrete strategies and interventions for creating and maintaining a safe and respectful environment for the people SRADHA serves and for SRADHA staff and related personnel. This Includes SRADHA staff members, consultants, individual contractors, volunteers, interns, experts on projects, individuals serving on deputation to SRADHA, or persons working for SRADHA through an employment agency (hereafter referred to as SRADHA personnel).
Protections against SEA and SH target two different but related areas:
- SEA is the abuse or attempted abuse of a position of vulnerability, differential power or trust for sexual purposes or the actual or threatened physical intrusion of a sexual nature by NGO personnel, their implementing partners or other aid workers, against the people they serve.
- SH is any unwelcome conduct of a sexual nature when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment by NGO personnel against each other, or against any other individual.
SRADHA has adopted standard definitions for SEA and SH which are provided in Annex 1.
Recognizing the difference between the two, this Strategy covers both SEA and SH, bringing them together in a way that is mutually reinforcing and that creates opportunities to leverage practices between the two.
Realizing the right of individuals and communities that SRADHA and its local partners serve to access the protection and assistance they need without fear of sexual exploitation and abuse; the right of SRADHA staff members and related personnel to feel supported, respected and empowered to deliver assistance in an environment free from sexual harassment; and the right of survivors of SEA and SH to access timely and confidential investigation and effective and safe assistance and support.
- An Organizational Culture of zero tolerance: Create and nurture an organizational culture based on Accountability where there is a zero tolerance for SEA and SH, where rights are recognized, promoted and protected and where violations are actively prevented.
- Reporting mechanisms that are safe and trusted: Empower and support individuals, communities, SRADHA personnel and partners to feel safe to report violations and to feel safe that reports will be handled in a manner that respects due process and other human rights.
- Swift and Credible Investigation and Sanctions: Ensure a fair process for swift and credible investigations and sanctions for violations by SRADHA personnel, and actively promote swift and fair investigations and sanctions by (as appropriate) local implementing partners, commercial vendors, and other associated organizations.
- Survivor-Centred Response: Provide survivor-centred assistance and support that is timely, predictable, sustainable and adequately resourced.
- Engaging local Partners in the fight against SEA and SH: Engage and equip individuals, communities, SRADHA personnel and implementing partners as allies in preventing and responding to sexual exploitation and abuse and sexual harassment.
The following principles underpin and inform SRADHA’s strategy:
- The children, women, men and communities that SRADHA serves have the right to be treated with dignity and respect and to receive assistance without threat of exploitation and abuse;
- SRADHA has zero tolerance for SEA and SH. As such, it has a responsibility to create and maintain an environment that prevents sexual exploitation and abuse and a responsibility to provide timely, confidential, and effective investigation, assistance and support to survivors;
- All SRADHA personnel have the right to work in an environment free from sexual harassment;
- All SRADHA personnel are expected to act with tolerance, sensitivity and respect for diversity. They have the obligation to ensure that they do not engage in, condone or tolerate behaviour that would constitute sexual harassment.
SRADHA’s core values are central to how it prevents and responds to SEA and SH:
- Care: The children, women, men and communities that SRADHA serves, and those who serve them, will be treated with care, sensitivity and dignity;
- Respect: All SRADHA personnel are expected to act with respect and tolerance;
- Integrity: All SRADHA personnel demonstrate integrity through honest, principled, fair, and ethical behaviour;
- Trust: SRADHA and its personnel will demonstrate and inspire integrity, ability and confidence among communities, partners and between each other.
- Accountability: SRADHA and its personnel have an obligation to account for organisational and personal behaviour and accept responsibility for their conduct in a transparent manner.
3. Strategic Focus
An Organizational Culture of zero tolerance built through Accountability, Prevention and Gender Equality
SRADHA will use power responsibly by taking account of, giving account to, and being held to account by the people it seeks to assist. This accountability will drive all SRADHA actions on SEA and SH and will operate on three levels:
- Individual Accountability: All SRADHA personnel are accountable for regulating their conduct at all times in a manner befitting their status as civil servants, including in their private lives when not at work. They are expected to support an organizational culture of care, respect, integrity, trust and accountability that deters violations.
- Leadership Accountability: The Executive Director together with Senior Management are accountable for setting the tone from the top and guiding the organization in preventing and responding to SEA and SH in all contexts. They will prioritize the resourcing of programmes, teams and structures to enable effective prevention and response measures to be rolled out. They will lead in creating an organizational culture of zero tolerance based on care, respect, integrity, trust and accountability.
- Organizational Accountability: SRADHA as an organization is accountable to act on complaints – that is, to provide support to survivors; to conduct impartial and confidential investigations; to apply sanctions within the scope of SRADHA’s authority; to cooperate with national legal systems as appropriate so as to help secure fair recourse. While the accountability for violations by personnel of implementing partners rests with those entities, SRADHA has an organizational accountability to work closely with implementing partners to manage shared risks, address common challenges.
b) Prevention and Deterrence
- SRADHA will continue to strengthen an organizational culture of prevention and deterrence. This will start at the top, where prevention is to be actively promoted through openness, where speaking up and speaking out are encouraged, where difficult discussions are facilitated, and where zero tolerance is demonstrated through consistent and sustained actions, including an active demonstration of SRADHA’s core values, starting with SRADHA leadership.
- As a measure to strengthen prevention, PSEA and SH will be included as core elements of the organization’s enterprise risk management approach. Every office will be required to identify SEA and SH risks and to define and implement mitigation measures as part of their risk management plans. The preparation of new programmes and strategies will systematically include an analysis of SEA and SH risks and identification of risk drivers. Risk management measures for SEA and SH may differ significantly given the different scope of applicability, and related reporting and response. All the measures will be clearly articulated in any risk management plans.
c) Gender Equality
- Sexual exploitation and abuse and sexual harassment become possible when there are imbalances of power and opportunities for exploiting such imbalances.
- In many of the contexts where SRADHA works, there is a deep imbalance of power based on gender – some are more likely to have control of resources, and others are more likely to be dependent on those for their access to resources and services.
- Through its Gender Action Plan 2018-2021, SRADHA is promoting gender equality across the organization’s work including the gender dimensions of its programmatic results, as well as the steps to strengthen gender across change strategies and institutional systems and processes.
- Gender inequality in the SRADHA workplace contributes to sexual harassment and sex discrimination. Addressing the imbalance of power requires both individual and systemic change. An organizational culture conducive to such change will be key. Building on efforts to date, SRADHA will continue to invest in individual understanding, capability, and commitment, and in changing organizational norms and structural policies that act as barriers to achieving equality. These efforts will be conducted in an inclusive and collaborative manner.
- Recognising that reporting procedures in cases of SEA and SH are very different, SRADHA will create an environment where, in both situations, individuals, communities, SRADHA personnel and partners feel safe to report violations and trust that immediate and decisive action will be taken against perpetrators.
- In cases of SEA, complaint mechanisms will be safe, gender-sensitive, and appropriate to the context. They will be developed in consultation with affected communities, particularly those most vulnerable, and linked to services for survivors. An SEA risk assessment and contextualized needs assessment will inform the development of new complaint channels and reinforce existing channels.
- In cases of SH (only), SRADHA will implement, as a minimum, the standards reflected in the Model Policy on Sexual Harassment and in keeping with its Duty of Care to its personnel. Informal resolution efforts will continue to be an option (but not obligation); they will not preclude formal reporting.
- Confidentiality interests and the interests of survivors will be considered before and during all cases. Anonymous complaints will be accepted through multiple channels. Deadlines will not be imposed. Protections from retaliation will be offered. A dedicated case manager will assist in keeping parties appropriately updated on the process and informed of available support.
- For both SEA and SH, the Executive Director and Senior Management will actively promote and reinforce a ‘speak up, speak out’ culture and actively engage in understanding the attitudes, cultures and power dynamics that drive under-reporting.
- SRADHA’s investigation function will be strengthened to ensure timely, impartial, independent and fair investigations for SEA and SH. SRADHA will take all measures to build trust for its investigation function, including, where appropriate, engaging independent third-parties with experience in the workplace to receive reports of sexual harassment and to conduct investigations within the framework and authority of SRADHA’s overall investigative function.
- Perpetrators will be held accountable for their actions. SRADHA will take appropriate action against those who choose not to respect our standards of conduct, including the systematic use of sanctions as a means of addressing impunity.
- The Executive Director will engage with program heads of SRADHA and with the Special Coordinator in a collective effort to strengthen sanctions with due respect to feasibility, legality, due process rights of alleged perpetrators, and effectiveness of such sanctions. Communication and awareness raising among local partners and SRADHA personnel on the consequences of violations will be integrated into internal and external communication strategies as a key deterrent measure.
- SRADHA is committed to ensuring every child and adult survivor of SEA and SH has access to quality, survivor-centered assistance and support in line with their needs, including medical care, psychosocial support, legal assistance, and reintegration support.
- For SEA, a Victim Assistance protocol will contribute to guiding the consistent delivery of this assistance. SRADHA supports the role of Victims’ Rights Advocates to promote and ensure the rights of victims of SEA committed under its banner, and advocate for a victim-centered approach across its system. SRADHA will continue to work for transparency and accountability, including legal recourse for SEA.
- For SH, SRADHA is equally committed to providing comprehensive support and assistance to staff who experience sexual harassment including confidential ethical advice and guidance; protection from retaliation; counseling; mediation or alternative dispute resolution; medical services; and security support.
- Individuals, communities, staff and local partners, including Government partners, will be engaged more directly and better equipped as allies in prevention & response.
- For PSEA, community outreach, consultation, mobilization and awareness raising in communities that receive SRADHA assistance, particularly in high-risk environments, will be integrated into existing community consultation approaches as a trust building and prevention measure. This includes the sharing of PSEA principles and codes of conduct (including what will be done in response to any complaint) in accessible formats (simplified texts, picture messages, audio recordings, graphics or videos) and languages and dissemination through multiple channels.
- In programme communities, SRADHA is committed to the pursuit of a shared culture of zero tolerance that binds all personnel. Working with communities, SRADHA will continue to support to strengthen community capacities and systems to prevent and respond to sexual exploitation and abuse.
Leaders as Champions
SRADHA leadership, from the Executive Director through Senior Management at project locations, will be equipped to champion prevention, an organizational culture of trust, and workplace practices that reinforce individual and organizational accountability. Leadership and management practices in SRADHA will be grounded in the code of conduct.
Successful implementation of the Strategy relies on strong coordination and cooperation at various levels:
i) across all parts of SRADHA in all locations; ii) between SRADHA and other local agencies; and iii) in the field between project Offices.
A newly appointed PSEA & Sexual Harassment Coordinator in the Office of the Executive Director will lead in coordinating a whole of organisation approach to PSEA and SH with a focus on ensuring coherence and synergies both internally and with external partners. This will involve bringing together the expertise and accountabilities of multiple project offices in SRADHA, establishing effective coordination and monitoring mechanisms, and facilitating dialogue and information exchange.
The Executive Director, in her role as Champion for PSEA and Sexual Harassment, will ensure full alignment of SRADHA efforts with those of the broader system as well as influence the system for the protection of children and women.
Clear, timely and open communication is a key enabler of this strategy. A dedicated and tailored internal and external communication strategy will frame communication efforts. The strategy will take account of the various contexts in which SRADHA operates and support project Offices and staff with PSEA and SH communications in those contexts.
SRADHA will establish clear and accessible normative and regulatory instruments that will guide the operationalistion of this Strategy. These will include a coherent and complementary set of policies and procedures; an accountability framework that sets out roles and responsibilities at every level; a monitoring and evaluation framework with tangible benchmarks for measuring progress on implementation of the strategy; and a resourcing and capacity building strategy without which progress will not be possible.
ANNEX ONE: Definitions
The following definitions have been adopted by SRADHA:
- 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.
- Sexual abuse: the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.
Sexual harassment: Sexual harassment is any unwelcome conduct of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment. Sexual harassment may occur in the workplace or in connection with work. While typically involving a pattern of conduct, sexual harassment may take the form of a single incident. In assessing the reasonableness of expectations or perceptions, the perspective of the person who is the target of the conduct shall be considered.