SCI POLICY: PROTECTION FROM SEXUAL EXPLOITATION,

ABUSE AND HARASSMENT (PSEAH)

Functional Area: Safeguarding

Owner (Name + Position): Susan Grant , International Safeguarding Director

Approved by: Chet Kuchinad, Chief People Officer

Date of Approval: 07/06/2021
Date for Review: 20/11/2022
Languages (Inc. hyperlinks): Arabic, English, French & Spanish
Applicable to: All SCI REPRESENTATIVES1 and all Save the Children Member employees
deployed/seconded to or visiting SCI offices and programs.

SECTION 1: PURPOSE

As a child rights organisation, Safeguarding the children and adults with whom we come into contact
through our work is a key priority for Save the Children International (SCI). This policy is one of the
safeguarding policies under the Safeguarding Policy Framework, and has been developed specifically
to protect adults and children from Sexual Abuse and Exploitation and Harassment (SEAH) by our
organisation. SEAH is a form of safeguarding abuse that is also included in the Child Safeguarding
Policy and Code of Conduct.

Context and purpose. Save the Children believes that all people - children and adults alike - deserve to be
treated with dignity and respect. As a child rights and SOCIAL JUSTICE organization promoting the education,
health, and protection of children, Save the Children works in some of the most complex contexts across the globe
to deliver programs and activities to children in some of the world’s most VULNERABLE COMMUNITIES.
While we recognize the special vulnerabilities of children, we are also cognizant of the fact that vulnerable adults
are susceptible to abuses by humanitarian and development workers. This risk is of particular concern to INGOs
in which inherent power imbalances exist and high levels of trust are granted. These inequalities can be
exacerbated by other factors such as socio-economic status, gender, age, disability, ethnic & tribal identity, faith or
religious affiliation, and/or sexual orientation, all of which can reinforce dependency and increase vulnerability to
SEXUAL EXPLOTATION, ABUSE and HARASSMENT (SEAH).

Commitment. This policy outlines Save the Children’s commitments to prevent and respond to sexual
misconduct to ensure that all children and adults living in AFFECTED COMMUNITIES - even those who may
not be directly involved in our program activities - are protected from SEAH. This includes putting the safety,
wellbeing, needs, and interests of the VICTIM/SURVIVOR FIRST.

Zero tolerance. Save the Children has zero tolerance for sexual exploitation, abuse, and/or harassment by any
of its representatives. All credible concerns and allegations will be addressed in accordance with policy.

1 Bold capitalisation of words denotes that this is a specifically designed term and to refer to Section 3 Definitions.

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 Personal safeguarding obligations. As a representative of Save the Children, working with children and adults
in some of the world’s most vulnerable and marginalised communities, you must demonstrate the highest standards
of behaviour and conduct. You are personally accountable to meet these 5 safeguarding obligations, both in your
private and professional life - 24 hours a day, 7 days a week:
1. Respect: Treat everybody with respect, dignity, and professionalism.
2. Do no harm: Do not abuse, exploit, or harm any child or adult, or place anybody at risk of harm.
o Do not engage in any sexual activity with anyone under the age of 18 regardless of the age of
majority or consent in the country. Mistaken belief regarding the age of a child is not a defence.
o Do not have sexual contact with RECIPIENTS of humanitarian and development aid, or use your
position, influence, or trust by requesting, persuading, or coercing another person to engage in
sexual activity.
o Do not exchange goods, money, favours or services for sex or SEXUAL FAVOURS.
o Do not hit or otherwise physically assault or abuse any child or adult. GROOMING children
and/or adults in person or online is a form of SEA and is not acceptable in any circumstances.
o Do not commit any other abuse or harm, whether deliberate or unintentional.
o Do not engage in FRATERNISATION with colleagues within or external to our organisation.
3. Prevent: Take action to prevent abuse, exploitation, harm or accidents.
o Ensure that all activities and spaces are safe by identifying risks and implementing preventative
measures.
o Assess and address safeguarding risks regularly.
o Avoid being alone with a child you work with or a vulnerable adult in the community.
4. Lead: Follow and promote our safeguarding policies and code of conduct, within and beyond our work.
5. Report: Any concerns of harm or risk of harm need to be reported within 24 hours. If in doubt - report.
Failure to report constitutes a breach of this policy.

Safeguarding Policy Framework. The PSEAH policy forms part of SCI’s wider safeguarding policy
framework that includes SCI’s Child Safeguarding Policy, the Global Child Safeguarding Protocol, the
Anti-harassment, Intimidation and Bullying Policy, Modern Slavery & Human Trafficking Policy, and
the Code of Conduct. These policies, along with their accompanying protocols and procedures, provide
standards to reflect Save the Children’s commitment to first prevent harm and abuse, and then report and respond
whenever concerns arise.

SECTION 2: POLICY SATEMENT(S)

1. Scope and Application

1.1. This policy applies to all SCI employees at the Country, Regional, Centre levels and those working
within any other SCI Unit (incl. Geneva, Brussels and New York Offices) and for staff or
representatives from Member organizations visiting SCI offices or programs.
1.2. All Save the Children representatives have a duty to uphold the principles of the PSEAH policy and
commit to maintaining an environment that prevents any form of violence against children and adults
1.3. Any behaviours demonstrated by an SCI Representative that contradicts this policy, whether during
or outside of working hours, must be reported and will be treated as a violation of this policy.
1.4. Sexual exploitation, abuse, harassment and fraternisation by Save the Children representatives
constitute an act of gross misconduct. Anyone found to have engaged in such behaviour is subject
to disciplinary action, including dismissal and exclusion from any future engagement with SCI.

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2. PSEAH Principles & Responsibilities

2.1 Our commitment to human and child rights is fundamental for creating a safe and equitable
organisation that reflects the diversity of our global communities and practices inclusivity in all we
do. As such, all programmatic and operational decisions will reflect our collective commitment to
these principles.
2.2 We believe that the principles of this policy require our intentional and sustained engagement with
children and adults in affected communities. For this reason, we are committed to communicate
and socialise this policy with the children and adults in the affected communities where we
implement programmes and projects, and we will listen to and integrate their feedback to ensure
our safeguards against SEAH reflect the voices of the communities.
2.3 Our Trustees and Senior Leadership are accountable for this policy and its implementation.
2.4 We are committed to promoting, creating and maintaining a safe and healthy organisational culture.
As SCI staff and representatives, we are all responsible to prevent and report concerns of sexual
exploitation, abuse, and harassment.
2.5 Our leaders are accountable for fostering a safe organisational culture. Leaders must ensure that all
staff are aware of the contextualised risks associated with SEAH within their function.
2.6 Our organisation provides mandatory training to ensure we are all aware of how to detect, prevent,
and report concerns of Sexual Exploitation, Abuse, and Harassment (SEAH). Our leaders are
responsible to ensure staff complete training and are aware of this policy.
2.7 We will foster healthy and safe interactions with children, adults in affected populations, and with
colleagues. Our leaders are responsible for contextualising the risks associated with SEAH within
their teams.
2.8 Our leadership across the Centre, Regions, and Countries will ensure that all reported allegations
and investigations are managed in accordance with the reporting and investigation procedures and
timelines.
2.9 Our Senior Leadership and Board are responsible to ensure the cost of implementing this policy is
reflected in operational plans, budgets and funding proposals.
2.10 We will assess and respond to all credible suspicions, concerns and allegations of SEAH. Failing to
report or inaction is not acceptable and may lead to disciplinary and/or other relevant action.
2.11 We will develop and maintain organisation-specific safeguarding mechanisms, with appropriate levels
of dedicated capacity and allocated resources at all levels of the organisation, to prevent and respond
to all forms of SEAH.
2.12 Safeguarding Focal Points (SGFPs) are appointed to promote awareness, prevention, and responding
to safeguarding risks.

3. Safer Recruitment

3.1. Recruitment and selection of employees and others must reflect robust recruitment measures
including thorough criminal background checks available in each jurisdiction, employment references
from official sources, and thorough interviewing to evaluate the suitability of a candidate to work
with children and vulnerable populations.
3.2. Successful candidates must declare in writing – prior to commencing their roles - their commitment
to follow Save the Children’s policies and procedures including this PSEAH Policy. Selected
candidates must be made aware of the binding nature of these policies, procedures and codes of
conduct, which apply equally to personal and professional life, unless this is specifically prevented by
local legislation.
3.3. We seek to employ and contract only those people who are aligned with our vision, mission and
values. To the legal extent possible, we will share information with the global Save the Children
network or with other organisations to prevent the hiring and circulation of anyone who may
directly or indirectly pose a risk of harm to children and adults.
3.4. Human Resources and hiring managers are responsible to safely recruit, to ensure induction
processes have been carried out, and to deliver mandatory safeguarding training within the
designated timeframe. Human Resources is responsible for maintaining records of completed
training.

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 4. Safer Programming

4.1. Safer Programming is an approach through which we systemically embed a (child) safety “lens”
beginning with the program design and spanning throughout implementation and monitoring &
evaluation until the project cycle is closed. It embodies our commitment to “Do Not Harm,” and
involves continuous engagement with communities, partners, suppliers, and other relevant
stakeholders throughout the project life cycle.
4.2. All of our projects and activities must be properly resourced and have measures in place to prevent
and mitigate the risk of SEAH throughout the project cycle.
4.3. All of our projects and activities including humanitarian responses, programmatic activities/events,
media, communication, policy, marketing, and campaigns, must be assessed for child and adult
safeguarding risks and the potential for increased vulnerability due to the nature of the activity and
the local context. This includes drawing on or conducting relevant GENDER POWER
ANALYSIS.

5. Safer Partnerships

5.1 Our partners are responsible to adhere to the principles of safeguarding, including Protection
Against Sexual Exploitation and Abuse (PSEAH).
5.2 All agreements with our partners2 and sub-awardees include a commitment to child and adult
safeguarding, including PSEAH. If a partner elects to use its own policy, that partner’s safeguarding
policies must be of an equal or higher standard for protecting children and adults from sexual
exploitation, abuse and harassment.
5.3 All partners and sub-awardees must receive a safeguarding and PSEAH briefing to understand the
safeguarding risks associated with the project, and outlining expected behaviours. Agreement to
comply must be made prior to starting any work or activities with or on behalf of SCI.
5.4 Partners are expected to respond safely, quickly and appropriately to all concerns. Where
appropriate, SCI may provide support with any internal investigation.

6. Reporting & Responding

6.1. All suspected or known child or adult safeguarding concerns must be reported by SCI
Representatives within 24 hours of becoming aware of the concern, unless it is impossible to do so
or other exceptional circumstances exist.
6.2. Any safeguarding suspicion, concern or allegation must be reported through one of the official SCI
reporting channels. Report:
 directly on DATIX Cloud as a Safeguarding concern;
 through the Country Office Safeguarding Lead or Safeguarding Focal point within your
location, project or the Regional Safeguarding Director;
 through the Country Director or Head of Office;
 through the Humanitarian Response Lead;
 through the Global Safeguarding Director or any other senior leader at the location; or
 through the Whistleblowing System email: whistleblowing@savethechildren.org
 through the independent Whistleblowing Hot Line Safecall www.safecall.co.uk/report
6.3. Any information relating to a suspicion of SEAH must be treated with utmost confidentiality and
not be shared with any third party other than those identified as part of the defined reporting
channels.

2
Includes suppliers, contractors, or other who deliver a service.
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7. Robust and Accountable Case Management

7.1. We will manage and maintain robust reporting and case management systems to ensure all credible
allegations of SEAH made against any Representative engaged in its activities are appropriately
addressed.
7.2. Any act of SEAH committed by our Representatives constitutes an act of gross misconduct and may
be grounds for termination of any future engagement with SCI.
7.3. We are committed to act swiftly and hold accountable any Representative who has committed
SEAH. Personnel and disciplinary actions are subject to scrutiny by the appropriate senior
management team and review, when required, by the SCI Board.
7.4. SCI is committed to socialising recommendations and/or lessons learned from alleged incidents to:
 reduce the risk or re-occurrence of incidents
 influence policy, procedures and practices across all functions to correct any system weakness
and gaps across Save the Children and elsewhere, when appropriate;
 improve systems and mechanisms to safeguarding children and adults
 create a better understanding of the risks and impact of SEAH on individuals, organisations
and the communities where we operate

8. Victim/Survivor Support & Care

8.1. We believe that all survivors have the right to participate in their care and recovery plan, and assist
us in determining the best course of action whenever possible and practical. Our survivor-centred
approach to SEAH will ensure that the survivor’s well-being, wishes, experiences, needs and rights
are at the center of all of our decisions and actions.
8.2. We are committed to providing available support and assistance, should survivors choose to pursue
them. Anyone who experiences sexual exploitation, abuse and harassment by an SCI Representative
or as a direct result of our work is eligible to receive support and assistance that is contextually
appropriate and in a manner that does not isolate, stigmatise or re-traumatise the survivor. This
may include medical treatment, accessing legal assistance, psychosocial support, relocation and other
protection services.
8.3. We are committed to providing survivors access to support regardless of whether they wish to
make a complaint or participate in an investigation.

9. Information, Communication & Digital Technology

9.1. We understand that data misuse, sharing, or imagery can put children and adults in affected
populations at a greater risk for experiencing SEAH. We are committed to ensuring that all
information systems and communication technologies, including the internet, social networking sites
and the use of digital imagery is assessed for SEAH risks and adequate mitigation strategies are in
place.
9.2. We know that with the introduction and increasing use of digital technology in our programming
work, it is important to protect children and adults in affected communities by socialising those
risks and ensure that protective measures have been taken.
9.3. We will not use any personally identifiable information (PII) of survivors within our
communications, publicity, or fundraising materials. This includes but is not limited to names, images,
and geographical locations or any information that may be triangulated to identify of a survivor
through multiple small pieces of information. INFORMED CONSENT to use a survivor’s words
or story will not be confused with consent to use any aspect of their identity.
9.4. We will comply with all data protection laws and policies when managing children’s and adults’
personal data. All of our Representatives collecting child or adult data on our organisation’s behalf
or in relation to any of our work must adhere to SCI policies, procedures and practices or ensure
their own mechanisms comply with legal requirements for Data Retention Protection

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 10. Relevant Laws and Endorsements

10.1. This policy will be implemented in accordance with;

 All relevant UK laws related to protection from sexual abuse, violence and harassment, and
those outlining measures for reporting known or alleged cases of abuse;
 Applicable laws in the countries where SCI operates; and
 The UN Secretary General’s Bulletin ‘Special Measures for Protection from Sexual
Exploitation and Sexual Abuse’ (ST/SBGB/2003/13)
10.2. Where this policy exceeds any legal requirements, SCI will adhere to the standards in this policy to
the extent allowed applicable by law.
10.3. We will report criminal behaviour to relevant authorities, except where doing so will create
additional harm for a victim/survivor and or others.
10.4. Reasons for not reporting to the police or relevant authority must be documented, approved by
the Country Director. Where there are international protocols around the reporting of
perpetrators within their home countries or abroad, SCI will report appropriately.
10.5. We have a responsibility to report incidents of PSEAH to the UK Charity Commission.
10.6. We endorse the Inter-Agency Standing Committee (IASC) six principles in relation to SEA.

11. Reporting to the Board

11.1 All serious safeguarding incidents, including incidents of SEAH, are reported to our SCI Board.
11.2 An annual safeguarding report is submitted to the SCI Board.
11.3 The SCI/SCA Board has a designated Safeguarding Trustee to reinforce increased accountability,
transparency and leaning, and to apply and strengthen safeguarding mechanisms across SCI/SCA and
build a safeguarding culture.

SECTION 3: DEFINITIONS
Word/Term Definition
Adult Safeguarding within Save the Children refers to our collective and
individual responsibility to prevent and respond to any form of abuse, exploitation
or harassment committed by Save the Children employees or representatives,
Adult Safeguarding
against any person 18 years and older receiving benefits, engaged in community
programming, and/or living in the affected communities and populations where
we operate.
Any location in which SCI has a business presence which may include but is not
Affected limited to delivering programmes, services, and projects, responding to a
Communities/populations humanitarian crisis, working on a development project, and/or delivering a
campaign.
Child Safeguarding is making Save the Children safe for children. It involves our
collective and individual responsibility and actions to ensure that all children are
protected from deliberate or unintentional acts that lead to the risk of or actual
harm by Save the Children staff, representatives and third parties, who come into
Child Safeguarding contact with children or impact them through our development interventions,
humanitarian responses and operations. This includes our direct programme
implementation, work through partners and management of children’s personal
data.

The process through which assessments analyse the factors that may create an
Contextual Safeguarding enabling environment for the perpetration of sexual exploitation and abuse,
including the characteristics and relative power of the people involved, and make

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 recommendations to reduce these opportunities and promote safety for the most
vulnerable and exposed.

Suppliers, contractors, individuals and organisations engaged by SCI or a primary

Downstream Partner Partner to provide a service or implement SCI’s work. Sub-grantees.

Any relationship occurring in the course of conducting business, that involves — or

appears to involve — partiality, preferential treatment or improper use of rank or
position including but not limited to voluntary sexual behaviour. It includes sexual
Fraternisation behaviour not amounting to intercourse, a close and emotional relationship
involving public displays of affection or private intimacy and the public expression of
intimate relations.

Gender power analysis is an assessment that takes into consideration the

inequalities of gender in communities and beneficiary groups, as well as with SCI
Gender Power Analysis employees, volunteers and representatives, and recognises the ways in which these
contribute to inequalities and vulnerability.

The cultivation of emotional relationships with those in positions of vulnerability or

inequitable power, with the intention or potential of manipulating these
Grooming
relationships into sexualised dynamics in the future.

Harassment consists of unwanted conduct, whether verbal, physical or visual, which

is related to a person’s sex, gender, marital status, sexual orientation, race (including
colour, nationality or ethnic or national origin), religion or belief, age or disability
Harassment with the purpose or effect of violating the dignity of a person or creating an
intimidating, hostile, degrading, humiliating or offensive environment. Such conduct
may take place on a single occasion or on several occasions.

Informed consent is an ongoing agreement, which is freely given based upon a clear
appreciation and understanding of the facts, implications and future consequences
of an action. In order to give informed consent, the individual concerned must have
all relevant facts at the time consent is given and be able to evaluate and
Informed Consent understand the consequences of an action. It is for SCI to ensure the person
understands that they have the power to exercise their right to refuse to engage in
an action without justification and/or to not be coerced (i.e. being persuaded based
on force, coercion or threats, either direct or implied).

Protection from Sexual Exploitation, Abuse and Harassment. Terms defined

PSEAH separately in this section.

Any person who receives any assistance (including all types of goods, services,
opportunities, training) directly or indirectly (as the parent or caregiver of children
Recipient involved in SCI programmes and activities) or partner NGO, regardless of the
length of time of their relationship with SCI.

Those connected with SCI’s work, this includes all employees, board trustees,
partner employees, agency workers, consultants, volunteers, incentive workers,
interns, casual workers, sponsors, trainees, donors, SC member employees or
Representatives
associates, celebrities, media personnel on visits to SCI programmes, contractors,
and suppliers.

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 Save the Children Association (SCA)
SCA is a Swiss registered association that holds the membership and governance
structure for Save the Children globally. Each Member is one of 30 Members of
Save the Children Association.

SCI/SCA Save the Children International (SCI)

SCI is a wholly-owned subsidiary of SCA, which is a UK company regulated by the
UK Charity Commission. Members who want to program outside their own
country have an agreement with SCI for SCI to provide those programs. SCI is
the operating arm managing the ROs and COs

Any person over 18 years of age who receives money, goods or services in
exchange for sexual or sexualised acts, and who define those activities as income-
Sex Worker
generating, even if they do not identify as sex workers or as exploited.

The threatened or actual physical intrusion of a sexual or sexualised nature, including

inappropriate touching, by force or under unequal or coercive conditions, sexual
assault and rape. It may also include threatened or actual non-physical intrusion
(unwanted and/or uninvited exposure to pornography, texts, images, and so on, the
Sexual Abuse sharing of images, texts and so on, demands for sexualised photographs etc.).
Sexual abuse can happen anywhere – and it can happen in person or online.
Grooming can often lead to sexual abuse being perpetrated.
Any actual or attempted abuse of a position of vulnerability, differential power, trust,
or dependency, for sexual or sexualised purposes. This includes the offer or promise
Sexual Exploitation of monetary, social, political benefits as an incentive or form of coercion.
Sexual Exploitation can happen anywhere – and it can happen in person and online.
Grooming is often a component of sexual exploitation.
Any sexual or sexualised acts, in exchange for something such as money, goods,
Sexual Favours services, opportunities and so on. Also includes demands for inappropriate
photographs, filming, and exposure to pornography and so on.
Any unwanted and/or uninvited conduct of a sexual or sexualised nature, which has
the purpose or effect of violating an individual’s dignity, or creating an intimidating,
Sexual Harassment hostile, degrading, humiliating, or offensive environment for that individual. This
conduct may or may not be criminal, and it may or may not be direct physical
touching.
The objective of creating a fair and equal society in which each individual matters,
Social Justice their rights are recognized and protected, and decisions are made in ways that are
fair and honest.
The person/s against whom a complaint has been received i.e. The person who has
Subject of Concern allegedly committed the act or failed to act in a way that protects children.
A person who has experienced, or is experiencing sexual exploitation abuse and or
Survivor harassment in relation to their involvement with SCI or in any other agency
organisation.
Within SCI’s definition this is includes community volunteer and incentive worker.
Volunteers Country offices may use additional terms and it is important to understand and
identify all categories of volunteers within each location and project.
Including but not limited to Refugee Camp, Internally Displaced Persons (IDP) Camp,
Vulnerable communities
disaster and conflict zones

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SECTION 4: RELATED DOCUMENTS
1 Safeguarding Policy Framework Policy
2 SCI Code of Conduct
3 SCI Child Safeguarding Policy
UN Convention on the Rights of the Child
4 UN Declaration of Human Rights
UN Secretary-General’s Bulletin on the Prevention of Sexual Exploitation and Abuse
5 IASC 6 principles relating to SEA
6 SCI Anti-Harassment Policy
7 SCI Modern Slavery & Human Trafficking Policy
8 SCI Whistleblowing Policy
9 SCI PSEAH Procedure
7 SCI Child Safeguarding in Humanitarian Procedure
8 SCI Safeguarding Investigation Procedure
9 SCI Incident Reporting Procedure
10 SCI Disciplinary Policy
11 SCI Safer Programming Guidelines
12 SCI Social Media Policy
13 SCI Global Image Guidelines
14 SCI Data Retention Policy
15 Global Diversity, Equity and Inclusion policy English | French | Spanish | Arabic | Portuguese

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Annex I: Commitments to prevent sexual exploitation, abuse and harassment (SEAH) within our
organisation

 Create and maintain a safe and equitable organisational culture that prevents and opposes sexual exploitation, abuse
and harassment of children and adults and any other form of child abuse.
 Treat everyone with dignity and respect and challenge attitudes and behaviours that contravene SCI’s Safeguarding
policies - PSEAH Policy, Child safeguarding, Anti-harassment, Intimidation and Bullying Policy and Code of Conduct.
 Display a high standards of professional behaviour at all times and live SCI’s values.
 Declare immediately any sexual relationships with people within your line of management (whether a direct line
manager or are farther up the same management line). This reduces the risk of any abuse of power in the workplace.
Declaring such a relationship does not automatically determine that the relationship is consensual.
 Immediately report any suspicion, concern or allegation of SEAH committed against a child or adult by an SCI employee
or associate through the available reporting channels.
 Disclose to SCI any civil judgement or criminal conviction that relates to allegations of your involvement in sexual
exploitation, abuse and harassment of anyone which has occurred before or during your association with SCI.
 Make sure another adult is present when working with children and adults in affected communities.
 Always consult with the SCI local office and gain permission with regard to the taking of photographs for official SCI
business and adhere to relevant media and communication policies.
 Always ensure that for work-related purposes when children and adults are photographed or filmed SCI’s media and
communications procedures and guidance are followed. This includes:
 Complying with local traditions or restrictions for re-producing personal images.
 Obtaining informed consent from the person. If the person is under the age of 18, consent should also be
obtained from the parent or guardian before photographing or filming a child, explaining how the photograph
and film will be sued and who will see it.
 Ensure photographs, films and videos and any other medium present children and adults in a dignified and
respectful manner and not in a vulnerable or submissive manner.
 Ensure children and adults are adequately clothed and not put in poses/situations that could be wrongly
interpreted or put them at risk.
 Ensure that file labels, metadata, geotracking, or text descriptions do not reveal identifying information about a
child or adult in affected communities when sending images electronically or publishing images in any form.
 Ensure images are honest representations of the context and the facts.
 Always check that the right safeguarding measures are in place and be aware of your role and responsibilities to keep
children and adults safe across all operational and programmatic work.
 Understand and be aware of the context in which you are working, including the risks and vulnerabilities of the
different groups of children and adults with whom SCI comes into contact either directly or through digital technology.
 Cooperate fully and confidentially in any SCI investigation of concerns or allegations of SEAH committed against
children and adults associated with SCI’s work or the work of a partner;
 Comply with all relevant local legislation and relevant international protocols 3, including laws in relation to sexual,
gender based and domestic violence.
 Be aware of behaviour and actions or behaviours that could be perceived by others as exploitative or abusive to
children and adults.

Annex II: Unacceptable behaviours

× Engaging in any form of sexual activity or develop physical/sexual relationships with children (persons under the age of
the age of 18) regardless of the age of consent locally. Ignorance or mistaken belief in the age of a child is not a
defence4.
× Engaging in exploitative sex and fraternisation, which means any relationship occurring in the course of conducting SCI
business, that involves — or appears to involve — partiality, preferential treatment or improper use of rank or position
including, but not limited to voluntary sexual behaviour. It includes sexual behaviour not amounting to intercourse, a
close and emotional relationship involving public displays of affection or private intimacy and the public expression of
intimate relations.
× Exploiting your position of trust to enter a new relationship with other members of my community.
× Engaging in sexually abusive or exploitative relationships with members of the communities in which SCI works, within
the workplace or within the home, for example domestic workers.
× Engaging in exploitative sexual relationships with recipients of direct or indirect aid/assistance from SCI (e.g., the parent
or caregiver of children benefitting from SCI programming).

3
UN Secretary General’s Bulletin on the Prevention of Sexual Exploitation and Abuse and IASC six Principles in relation to SEA.
4
Definitions of “sexual exploitation” and “sexual abuse” from the UN Secretary General’s Bulletin: Special measures for protection from sexual exploitation and
sexual abuse (ST/SGB/2003/13)

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 × Inferring, suggesting, requesting, and/or demanding any sexual favours from members of the communities in which we
work, in return for anything – including protection, assistance (goods, services, resources, opportunities), or
employment, nor imply the same.
× Engaging the services of SEX WORKERS, irrespective of the local or national laws or norms regarding sex work or
the laws of their home country or the location in question.
× Engaging in undeclared sexual relationships with employees from our downstream partners, including lateral
partnerships such as those organisations we work with in Consortia where SCI is providing funding to the other
organisation.
× Supporting or taking part in any form of sexually exploitative or abusive activities, including downloading or sharing
indecent images or pornographic materials, the trafficking and modern slavery of human beings, or sexual or
exploitative relationships with human beings who have been trafficked or engaged in early child and forced marriage.
× Using language or behaviour towards children and adults that is inappropriate, harassing, abusive, sexually provocative,
demeaning or culturally inappropriate.
× Inviting unaccompanied children into private residences, unless they are at immediate risk of injury or in physical
danger.
× Hiring children for domestic or other labour, which is inappropriate given their age or developmental stage which
interferes with their time available for education and recreational activities or which places them at significant risk of
injury or exploitation, including sexual exploitation, abuse and harassment.
× Using language or behaviour towards children or adults that is inappropriate, harassing, abusive, sexually provocative,
demeaning or culturally inappropriate.
× Asking for or accepting personal contact details or invitations to share personal contact details (this includes email,
phone numbers, social media contacts/platforms, address, webcam, skype, zoom etc.).
× Using any computers, mobile phones, video cameras or social media to exploit or harass children or adults, or
accessing child exploitative or any other indecent or inappropriate materials or internet sites.
× Failing to report any allegations, causes for concern, or suspicions of the sexual exploitation, abuse and harassment of
another person.
× Failing to take corrective action to prevent and or manage risk when designing and implementing SCI programs and
activities. This includes research, advocacy, campaigns and media related activities and events, which directly involve
children and or vulnerable adults.

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