SEXUAL EXPLOITATION, ABUSE

AND HARASSMENT (SEAH) RISK

ASSESSMENT GUIDELINE
A Toolkit for Green Climate Fund (GCF) Financed
Activities
 SEAH Risk Assessment Tool

Contents
Acronyms .............................................................................................................................. 3
Introduction ........................................................................................................................... 4
Purpose and Scope of the Tool ............................................................................................. 4
PART 1: What is SEAH? ....................................................................................................... 5
Definition of SEAH and differentiation with other related terminology ................................ 5
Examples of co-benefits associated with undertaking SEAH risk mitigation in projects and
programmes. ..................................................................................................................... 6
Who perpetrates SEAH? ................................................................................................... 6
Part 2: SEAH Risks in GCF-Financed Activities .................................................................... 7
Contextual risk and mitigating factors ................................................................................ 7
Project-related risk factors ................................................................................................. 8
Potential SEAH risks in GCF’s Results Areas .................................................................. 10
Part 3: Assessment and Mitigation of SEAH Risks .............................................................. 14
The GCF Programming Cycle ......................................................................................... 14
Risk screening ahead of concept note submission (Stage 3 of the programming cycle) .. 16
SEAH Risk Screening Checklist ...................................................................................... 17
Risk assessment & mitigation when developing Funding Proposals (Stage 4 of the
programming cycle) ......................................................................................................... 19
Checklist of Potential SEAH Risk Mitigation Measures .................................................... 19
Addressing SEAH during project implementation (Stage 8 of the programming cycle) .... 21
Tracking SEAH risks/monitoring (Stage 8 of the programming cycle) .............................. 21
Responding to reports: taking a survivor-centered approach ........................................... 22
Annex 1 - SEAH in ESMP/ESMF (or other instrument) – Mitigation Measures Menu ... 25
Annex 2 - SEAH Internal GCF Risk Assessment Tool for appraisal of 1st-level SEAH
due diligence ................................................................................................................ 27

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Acronyms
AE Accredited Entity
DD Due diligence
ERBD European Bank for Reconstruction and Development
EE Executing Entity
ESIA Environmental and Social Impact Assessment
ESMP Environmental and Social Management Plan
ESP Environmental and Social Policy
ESS Environmental and Social Safeguards
FGD Focus Group Discussions
GBV Gender-Based Violence
GBVH Gender-Based Violence and Harassment
GCF Green Climate Fund
GRM Grievance Redress Mechanism
IFC International Finance Corporation
IPO Initial Public Offering
IPV Intimate Partner Violence
NDA National Designated Authority
PII Personally identifiable information
RESP Revised Environmental and Social Policy
SEAH Sexual exploitation, sexual abuse, and sexual harassment
VAWG Violence against women and girls
WB World Bank

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Introduction
In fulfilling its mission to promote a paradigm shift towards low-emission and climate-resilient
development pathways, GCF is dedicated to maintaining the highest integrity standards in
the conduct of its operations. As such, in 2019 the GCF adopted its Policy on the Prevention
and Protection from Sexual Exploitation, Sexual Abuse and Sexual Harassment (SEAH
Policy, revised in 2021).
In September 2021, the GCF Board also approved revisions to its Environmental and Social
Policy (ESP), which reaffirmed its commitment to addressing SEAH and outlined specific
requirements. The Revised Environmental and Social Policy (RESP) can be found here.
The revisions require accredited entities (AEs) to positively demonstrate they have
conducted due diligence and assessed the risk of SEAH in the development of their funding
proposals and have put in place measures to prevent and mitigate any risks that were
identified. Further, it requires GCF to develop a SEAH Action Plan to be used by the GCF,
outlining concrete actions as to how the requirements of the revised policy will be
implemented by the Secretariat. The SEAH Action Plan was finalized in early 2022 and can
be found here. Finally, the RESP required the Secretariat to develop a SEAH Risk
Assessment Tool, to be used by both the Secretariat and AEs to guide them in their
assessments of SEAH risk. This document fulfills this requirement.
The RESP applies to all GCF-financed projects and programmes submitted for consideration
by the Board on or after its thirty-second meeting (16 May 2022). The SEAH provisions in
the RESP work together with the GCF’s Updated Gender Policy. A major update to this
policy was completed in 2019. Relevant provisions included a requirement for a gender
assessment to be conducted, and Gender Action Plan (GAP) prepared, for every GCF-
funded project or program.

Purpose and Scope of the Tool

This tool is a guide to help the Secretariat, AEs and executing entities (EEs) understand
SEAH and be able to assess the SEAH risks related to proposed projects in order to predict,
mitigate and ideally prevent SEAH from occurring. The tool applies to all GCF-financed
activities and to both public and private sector entities. It may be updated by GCF
periodically, as required, in order to further incorporate good practice and lessons learned,
and to mirror the evolution of GCF’s ESS standards.
The tool aims to assist the Secretariat and AEs to undertake their responsibilities under the
RESP and to operationalize the objectives and priorities in the SEAH Action Plan,1
especially priority area #2 on capacity development and tools and priority area #5 on
knowledge generation. The SEAH requirements in the RESP are listed in Box 1 below.
Box 1: Key SEAH requirements in the RESP:
• Undertake SEAH due diligence on all activities proposed for GCF financing (para 40);
• Identify any risks or potential adverse impacts on women, men, girls, and boys as early as
possible as part of screening, differentiated by gender and age where relevant, and reflect
these in relevant safeguards instruments (para 19(a));
• Include measures to prevent, address and eliminate SEAH in the relevant safeguard’s
instruments (including the ESIA and ESMP as appropriate) (para 19(a)(i));
• Implement, monitor, and continuously improve all measures to mitigate and manage the
identified risks and impacts (para 19(a)(ii));
• Monitor and report progress and performance to GCF and stakeholders throughout
implementation (para 19(a)(iii));

1 SEAH Action Plan seah-action-plan-gcf-financed-activities.pdf (greenclimate.fund)

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• Establish accessible and inclusive survivor-centred and gender-responsive GRMs, with specific
procedures for SEAH (para 19(b)(i));
• Establish modalities to provide timely services and redress to survivors, including as
appropriate, medical care, psychosocial support, legal support, community driven protection
measures, and reintegration (para 19(b)(ii));
• Incorporate SEAH considerations in ways that not only “do no harm,” but also improve
environmental and social outcomes and generate accessible and inclusive co-benefits to the
environment and the communities, including women and girls; (para 8)
• Ensure that measures to manage environmental and social (including SEAH) risks and
impacts, including, as relevant, information disclosure, stakeholder engagement, and grievance
redress, are incorporated in the agreements with executing entities including tendering
documents and contracts (para 15).

The tool also complements and links with relevant practices of the GCF e.g., the gender
assessment and GAP included as part of the Funding Proposal package (per requirements
in the Updated Gender Policy), as there is overlap in subject matter. As most of the SEAH
and/or gender-based violence (GBV) issues are also covered in the gender assessment and
sometimes mitigation measures are included in the GAP, these key documents provide
supplementary information on SEAH risk assessment and mitigation.

PART 1: What is SEAH?

Definition of SEAH and differentiation with other related terminology
SEAH covers a range of harmful behaviours which fall into three distinct but related
categories. In GCF’s RESP these are defined as:

• 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 - actual or threatened physical intrusion of a sexual nature, whether

by force or under unequal or coercive conditions;

• Sexual Harassment - including unwelcome sexual advances, requests for sexual

favours, and other verbal or physical conduct of a sexual nature, that interferes with
work, or is made a condition of employment, or creates an intimidating, hostile or
offensive environment in connection with a Fund-related activity.
These behaviours may be perpetrated as a one-off act or on a repeated basis over a period
of time. In either case, they can cause a range of sexual, physical, psychological, and
economic harm to those who experience them.
The majority of SEAH is perpetrated by men against women and girls. As a result, some
organisations choose to address SEAH as part of a wider focus on GBV or as part of a
specific focus on violence against women and girls (VAWG). However, both GBV and
VAWG cover a range of behaviours which extend beyond SEAH, including those which are
not explicitly sexual, such as physical and psychological violence. Unlike SEAH, GBV and
VAWG are also terms which are commonly used to describe violence perpetrated within
families and by current and former intimate partners (known as intimate partner violence, or
IPV).
It is important to note that while the majority of SEAH is perpetrated by men against women
and girls, anyone can perpetrate or experience SEAH. SEAH can also be perpetrated
against boys and men, as well as people with other gender identities.

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Nevertheless, given the close and overlapping relationship between SEAH and GBV, much
of the SEAH-focused guidance included in this tool is also relevant to assessing, preventing,
and responding to GBV. The tool has also been developed based on an awareness that
sexual violence is often perpetrated alongside other forms of violence, including physical
violence.
Box 2: IFC Performance Standards

GCF uses the International Financial Corporation (IFC) Performance Standards (PS) as its interim
ESS standards. The standards include requirements to address violence and harassment in general, in
particular in PS2 and PS4. For this reason, the GCF Board decided to add SEAH-specific requirements in
the RESP, to emphasize the matter and scale up the due diligence requirements. The interim standards
include:
• PS2: Labor and Working Conditions emphasizes the protection of basic rights of workers, including
promoting safe and healthy working conditions and protecting and promoting the health of workers.
• PS4: Community, Health, Safety and Security recognises that project activities, equipment, and
infrastructure can increase community exposure to risks. It also includes the need to anticipate and
avoid adverse impacts on the health and safety of communities and adopt measures to minimise risk
to them.

Examples of co-benefits associated with undertaking SEAH risk mitigation in

projects and programmes.
Beyond the SEAH safeguarding (“do no harm”), the RESP also puts emphasis on improving
social outcomes and generating co-benefits. The following are some of the examples of
SEAH safeguarding co-benefits that projects and programs could leverage on:

• An e-transit station or bus stop with better lighting and security in place is safer for
communities in general, and enhance use of green transport;
• Inclusion of SEAH awareness messages e.g., reporting channels in e-buses or bus
stops that help build community awareness in general;
• Empowering most vulnerable populations to speak up on any social issues including
SEAH during risk assessment (increase their voice and agency).
• Shelters in the construction sites can be safer in general – providing adequate
lighting, security e.g., CCTV etc.;
• Increase in the percentage of female construction workers and gender equality as
sites become safer and more inclusive;
• Conduct regular formal and informal sessions with targeted populations on any
emerging and/or potential SEAH risks and mitigation measures.
• Empowering the most vulnerable populations to speak up on any social issues
including SEAH and other issues during community/project assessments (increase
their voice and agency);
• Involve men and boys in developing initiatives that will bring sustainable solutions for
SEAH – encourage male engagement in social inclusion.
• Identifying options to provide safe market access especially for women, for example
by working with women traders and entrepreneurs, can enhance gender equality.
Who perpetrates SEAH?
SEAH can be perpetrated in many different situations and by people in various positions
within or outside of an organisation or project. The perpetration of SEAH usually involves an
imbalance of power, for example based on gender and/or other factors, such as race, age,

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disability, employment or migrant status. This tool is primarily focused on SEAH which may
be perpetrated by those working on GCF-financed activities (counterparties), against other
workers or against beneficiaries or community members.

Part 2: SEAH Risks in GCF-Financed Activities

SEAH is widespread and SEAH risks are present across all sectors and all countries. Levels
of risk, however, can vary considerably and it is vital that GCF partners and stakeholders are
aware of factors which are associated with an increased likelihood that SEAH may be
perpetrated. These risk factors may relate to the wider context in which GCF-financed
activities are being delivered as well as project activities themselves. As such, a SEAH risk
assessment needs to consider both contextual risks and project-specific risks.

Contextual risk and mitigating factors

Contextual risk factors include income levels, societal norms and attitudes towards women
and other marginalised groups, discriminatory laws, a lack of legislation – or lack of
enforcement of such legislation - protecting women and others from SEAH, community
dynamics, and a lack of available support services.
For example, a country may have laws criminalizing rape and sexual assault. However, if the
country does not have legislation or policies prohibiting sexual harassment in the workplace,
stalking, intimate partner violence and/or sexual exploitation, this evidences a lack of
knowledge and concern around these issues and provides an environment where these
sorts of behaviours are normalised, not condemned. Further, if laws/policies are present but
not enforced by relevant justice systems, this is also a contextual risk factor – survivors are
less likely to report violations if there is no enforcement, causing a hidden crisis of SEAH
incidents.
High levels of GBV, domestic violence (or IPV) and child marriage are also indicative of a
national context where SEAH could be common and socially normalized, and therefore may
occur in projects. Many countries have adopted National Gender Action Plans to strengthen
their response to these types of violence, which predominantly affect women.
A low legal age for marriage (anything below 18 years) and/or a high prevalence of child
marriage (despite laws prohibiting child marriage) also suggests an environment where
women’s health, education and empowerment are not prioritized, presenting a higher risk of
SEAH. High prevalence of child marriage suggests a high prevalence of forced marriage,
which is a form of modern slavery. The ILO estimates that 22 million people are trapped in
forced marriages, an increase of 6.6 million from 2016 to 2021.2 Nearly 15 million of these
are women and girls.
The social dimensions of climate change are multi-faceted. Women and girls are
disproportionately affected and experience more significant risks, burdens, and impacts,
making their vulnerability a product of the intersection between gendered social roles,
discrimination, and poverty. Indigenous women are also especially vulnerable to SEAH,
suffering compounding discrimination and marginalization, and severe power imbalances in
many countries. Poverty intersects with SEAH risk as it is closely interrelated with lack of
asset ownership, which can also make it more difficult, especially for women, to exit violent
relationships. In addition, growing resource scarcity as a result of climate change may lead

2 ILO, Global Estimates of Modern Slavery (2022). Accessible at:

https://www.ilo.org/wcmsp5/groups/public/---ed_norm/---
ipec/documents/publication/wcms_854733.pdf

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to coping mechanisms and survival strategies that put most poor people at a higher risk of
SEAH.
The number of services for survivors of SEAH is indicative of the importance a country
places on this issue - resources follow the strategic vision of the government. Where the
country lacks services, not only is this a risk factor for SEAH itself, but also means that a
crucial mitigation measure is absent.3 Comprehensive service provision includes women’s
shelters, adequate medical care, psychological services, social services and legal aid.
War, internal conflict or natural disasters are major risk factors for SEAH, as these situations
often mean people become displaced or lose property, housing and means of livelihood,
leaving them vulnerable to exploitation and abuse both by others in the community and by
staff of organizations who are charged with bringing in humanitarian aid and essential goods
and services. Conflict in one part of the country can also cause increased SEAH risks to
another part, due to internal displacement. War, conflict or natural disasters in neighbouring
countries can cause the same issue as refugees flood previously stable areas where
projects may have been running for some time.
Importantly, many of the above risk factors can be exacerbated by climate change. Climate
change can make the perpetration of sexual violence more likely – or at least increases
opportunities for perpetrators. For example, projects may be operating in areas hit by
climate shocks in which basic resources have become scarcer and people are desperate for
access to resources, increasing their vulnerability to sexual exploitation through
transactional sex.
Broadly speaking, climate change causes increased inequality, poverty and insecurity, which
leads women, girls, and vulnerable men and boys to be more susceptible to SEAH.
Furthermore, they may be displaced by natural disasters or instability caused by climate
change, causing even greater intersectional vulnerabilities. This means the beneficiaries of
projects, as well as nearby communities, are likely to have an even greater power imbalance
vis-à-vis the implementers of these projects, and thus can be more at risk of SEAH.
Women’s access to financial resources, land, education, health and other rights and
opportunities are often limited due to structural and cultural barriers, such as inadequate
representation in the law, unequal or inadequate property rights, ineligibility for credit, and
cultural norms that prioritize men’s access and opportunities before women. These barriers
impinge upon their capacity to adequately cope with and adapt to climate change and
prevents them from fully contributing to or benefiting from climate adaption and mitigation
initiatives. They also present risk factors for SEAH, making women more vulnerable to
sexual exploitation and less able to report SEAH and access support and justice, reducing
deterrents for perpetrators, meaning they can act with impunity.

Project-related risk factors

Despite the importance of GCF-partners understanding the role that the wider context plays
in determining levels of SEAH risk, it will not always be possible for GCF-financed projects to
directly address underlying risk factors in the wider context. The most important thing is to
understand – and pre-empt – how GCF-financed activities might interact with contextual
factors to create or exacerbate SEAH risks at the project level. In other words, AEs must
understand the contextual risk, and then determine how the project may exacerbate the risk

3 It is important to note that sometimes larger cities will have services available, but not rural areas. In
this case, the lack of services in the area is not a risk factor, but the mitigation side is still absent.
Projects may need to “import” services in high-risk environments.

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of SEAH. GCF Accredited Entities (AEs) and Executing Entities (EEs) can then ensure they
create the conditions that make SEAH less likely to occur, and ensure projects are equipped
to respond effectively and safely if it does.
Box 3: Expectation management, proportionality and “do no harm”.

GBV and SEAH are perpetrated in every country and region in the world. GCF projects cannot be
expected to fix inherent, intractable problems, however, GCF projects should not increase or
exacerbate harm and should try to have a positive impact within their sphere of influence. A “do no
harm” approach means that it is important to take into consideration that there is a risk that projects
may inadvertently reinforce harmful gender norms and behaviours and they should aim to mitigate
against this. The principal ethos here is that the project aims to do good, not harm, to the
country/community in which it is operating - and that potential negative consequences of project
interventions must be explored and mitigated, while also seeking co-benefits.

There are a variety of ways in which project activities can interact with contextual factors in
order to increase the risk of SEAH being perpetrated. Common risks factors for GCF-
financed activities are descried below.
1. Power imbalances and control over resources: A range of power dynamics are at
play within GCF-financed activities. These may include, inter alia, unequal power
between:

• Managers and employees;

• Project employees and beneficiaries;
• Project employees and community members;
Imbalances of power, especially where unchecked decision-making power is concentrated in
certain individuals, can increase the risk of SEAH. For example:

• Beneficiaries – or potential beneficiaries - can be dependent on project workers as

gatekeepers to project resources. This power dynamic can be exacerbated when
project workers are given control over life-changing resources such as the allocation
of compensation for displacement or access to food and water during a crisis.
Power imbalances can also be more explicit, for example when security personnel are
armed and given authority to control people’s behaviour. Although security personnel can
offer some protection to workers and community members from violence, they can also
abuse their power to perpetrate SEAH.
2. Movement of workers away from home: The movement of workers away from home
to far off worksites can increase their vulnerabilities to SEAH and increase opportunities
for perpetration. For example:

• A large influx of male workers to an area, especially poor communities, can increase
opportunities for sexual exploitation by temporary workers whose income and access
to resources is far greater than those in the local community. Being away from family
and social networks can also make them feel there will be fewer repercussions for
perpetrating SEAH. The same can apply to any workers travelling through remote
communities to transport goods.

• Migrant workers can be more vulnerable to SEAH perpetrated by colleagues,

community members and others. Their potential lack of knowledge of local support or
law enforcement services, or in some cases inability to speak the local language, can
reduce the likelihood that they would report SEAH, increasing a sense of impunity

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among perpetrators. Risks can be even higher when migrant workers are on
temporary contracts, are working informally or may not have the legal right to work,
meaning the chance of them reporting to authorities or complaining to an employer is
low.
3. Opportunities to perpetrate SEAH out of view of others: The physical location and
design of project worksites can also impact on likelihood that SEAH will be perpetrated.
For example:

• Worksites based in remote locations can increase opportunities to perpetrate SEAH

away from witnesses. Being located far away from service providers and redress
mechanisms can also mean there are reduced opportunities for reporting, weakening
the deterrent for perpetrators. Nearby communities will be smaller and unable to
cope with even minimal labor influx.

• Poorly lit and isolated spaces within project worksites can also provide opportunities
for perpetrators, including poorly placed and unlockable toilets and poorly maintained
or mixed worker accommodation. SEAH risks can also be heightened during
journeys to and from work, especially at times of day when there are few people
around and transport options may be limited.
In addition to these risk factors, highly pressurised environments can also be associated with
a greater likelihood that SEAH may be perpetrated, in particular sexual harassment.

Potential SEAH risks in GCF’s Results Areas

Table 1 below identifies SEAH risks which are more common in different sectors.4 These are
not exhaustive lists of all possible SEAH risks associated with each area/sector, but rather
can serve as a useful starting point for AEs and others in assessing SEAH risks related to
projects/programmes.5
Table 1: SEAH risks related to GCF’s Result Areas

Result Area Common SEAH Risk Factors

Health, Food GCF-financed activities related to transforming farming and food systems,
and Water enhancing food and nutritional security, and increasing food production
Security commonly involve the following, which can be associated with higher
levels of SEAH risk:
▪ Frequent transportation of goods;
▪ Remote and isolated work sites;
▪ Lack of facilities in agricultural project sites and farm worker
accommodation or other physical spaces, as well as overcrowded
and/or mixed worker accommodation and lack of separate facilities
especially for women;
▪ The engagement of temporary, seasonal and migrant workers, often
exacerbated by precarious employment conditions and low levels of
unionisation which reduce the likelihood of workers reporting SEAH for
fear of losing jobs;

4 The table has been structured around the 8 result areas for climate change mitigation and
adaptation of the GCF.
5 This table builds upon guidance provided in the following documents by EBRD, CDC and IFC:

“Addressing Gender-Based Violence and Harassment: Emerging Good Practice from the Private
Sector,” “Addressing Gender-Based Violence and Harassment (GBVH) in the Construction Sector,”
“Addressing Gender-Based Violence and Harassment (GBVH) in the Transport Sector, and
“Addressing Gender-Based Violence and Harassment (GBVH) in the Manufacturing Sector.”

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▪ Seasonal fluctuations in workload which can increase the likelihood of

physical and verbal abuse in an attempt to immediately boost
productivity, contributing to an environment where SEAH is tolerated;
▪ High levels of need for basic resources may put project workers in a
position of power. Where community members lack food and water
security and are in desperate need, their vulnerability to sexual
exploitation can be heightened;
▪ Multiple small project sites with lack of access to GRM or ways to
report SEAH;
▪ Lack of digital penetration amongst farm workers and small, remote
communities resulting in lack ability to communicate SEAH issues or
risks or access services;
▪ Lack of SEAH knowledge, training and services due to disparate
project sites.
Energy Investment projects in renewable energy and in increasing access to clean
Generation energy, and in energy generation from renewable resources may have
and Access SEAH risks such as:
▪ Remote and isolated work sites, with small communities nearby;
▪ Poorly designed or maintained worker accommodations, including lack
of separate facilities for female workers;
▪ Labor influx;
▪ Engagement of migrant and temporary workers;
▪ Male dominated sector; wherein women working in traditionally male
working environments increases SEAH risk and risk of community
backlash against women;
▪ Presence of security personnel;
▪ Low levels of unionization;
▪ High levels of interaction between project workers and community
members in stakeholder engagement of large infrastructure and
natural resource projects (including greenfield projects), especially
where resettlement or land acquisition processes are taking place,
where power imbalance is wide.
Infrastructure Major infrastructure is relevant in many sectors including transportation,
and Built telecommunications, water and energy, agriculture and health (such as
Environment building of hospitals, roads, energy infrastructure etc.). SEAH risks which
are likely to arise include:
▪ Poorly designed or maintained worker accommodations, including lack
of separate facilities for female workers;
▪ Large influx of male workers from outside the project area, resulting in
increased risk of SEAH for affected communities, workers and service
users;
▪ Poor recruitment and hiring practices of subcontractors, including
precarious employment conditions;
▪ Low levels of unionisation and temporary agency workers reduces
chances of workers reporting SEAH for fear of losing employment;
▪ Engagement of temporary informal and migrant workers, including day
laborers;
▪ Long hours and sporadic or unpredictable shift work render women
and other vulnerable groups at increased risk, especially when
travelling on public transport;
▪ Male dominated sector, wherein women working in traditionally male
working environments increases SEAH risk and risk of community
backlash against women;

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▪ High levels of interaction between project workers and community

members in stakeholder engagement of large infrastructure projects,
especially where resettlement or land acquisition processes are taking
place, where power imbalance is wide.
Buildings, Increasing the efficiency of building and appliances and green building
cities, construction in cities may include the following SEAH risks:
industries ▪ Poorly designed project sites and other physical spaces;
and ▪ Lack of separate facilities for women workers;
appliances ▪ Presence of security personnel who are contracted to provide
protection but who can also perpetrate SEAH;
▪ Low levels of unionisation and temporary agency workers (reduces
chances of workers reporting SEAH for fear of losing employment);
▪ Precarious employment conditions render workers more vulnerable;
▪ Use of temporary informal and migrant labor;
▪ Manufacturing workers (especially women and low-paid workers) at
increased risk of violence and harassment, especially verbal and
physical violence;
▪ Home-based workers who carry out manufacturing piecework;
▪ Male dominated sector, wherein women working in traditionally male
working environments increases SEAH risk and risk of community
backlash against women;
▪ Potentially multiple small project sites with lack of access to GRM or
ways to report SEAH.
Livelihoods of Livelihood resilience and enhancement includes social protection
people and programs, strengthening the resilience of the agricultural sector,
Communities diversification of livelihoods, migration, disaster protection through
insurance, communal pooling, and other systems of mutual support.
SEAH risks can include:
▪ Project operation in rural and remote areas – hard to reach areas that
may also mean lack of SEAH risk mitigation services;
▪ Lack of access to GRMs;
▪ May involve contact with indigenous communities; within these,
indigenous women are especially vulnerable to SEAH, suffering
compounding discrimination/ marginalisation and severe power
imbalance;
▪ Migration may increase risk of SEAH due to population mobility and
vulnerability;
▪ Frequent transportation of essential goods;
▪ Seasonal pressures and the influx of seasonal migrant workers are
common;
▪ Pressure to boost productivity to meet seasonal deadlines;
▪ Contact of project with other very marginalised or vulnerable
communities;
▪ Social protection programs and access to insurance programs involve
contact by project workers with individuals, often with door-to-door
sign up;
▪ If involving cash transfers and/or assets (especially to women), can
increase the risk of SEAH and GBV, vis-à-vis unequal power dynamics
with the service provider or the provider of the transfer
▪ Considerable power imbalances between the service provider
(providing the insurance, loan, cash transfer etc.) and
communities/individuals;
▪ Remote and isolated work areas, where workers often have to travel
long distances to and from work.

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Transport Transport projects include financing of low-emission public transport,

development of electric vehicles and new generation fuels and promoting
policies and planning for transit-oriented and mobility-based transport.
Risks may include:
▪ Building or upgrading public transport may involve worker
accommodation or other physical spaces which are poorly designed
and/or maintained or are overcrowded or do not have separate female
facilities;
▪ High levels of migrant and temporary labor;
▪ Low levels of unionisation;
▪ Poor recruitment and hiring practices of contract workers;
▪ Long hours and sporadic or unpredictable shift work render women
and others more vulnerable travelling to and from work, and at work
out of normal hours;
▪ Male dominated sector increases SEAH risk, especially where power
dynamics are shifted with a female worker/breadwinner and risk of
community backlash against women
Once construction is finished and use begins:
▪ Poor design of transport facilities may leave women, girls and
vulnerable populations more at risk of SEAH, particularly of
harassment (i.e., lack of CCTV, no lighting in unsupervised spaces,
poor lighting at stations and terminals, cramped spaces, conditions
that promote overcrowding, absence of emergency buttons for
passengers, etc.);
▪ Poor design does not mitigate risks to female drivers or transport
workers who may experience high levels of violence and harassment
by colleagues, supervisors and users of services;
▪ High rate of interaction between workers and service users in this
sector.
Ecosystems Ecosystems and ecosystem services projects involve securing resilience
and and functionality of forests, rainforests, coral reefs, managed forests and
Ecosystem agricultural lands under conditions of climate change. Risks may include:
Services ▪ Remote locations where there is little/no access to grievance
mechanisms or SEAH risk mitigation services;
▪ Interaction with indigenous communities, and particularly indigenous
women, in areas where they suffer compounding discrimination and
marginalization, and power imbalances;
▪ Presence of other marginalised communities (due to poverty, rural
and/or remote status);
▪ Low mobile phone or digital penetration, resulting in a lack of access
to information and grievance mechanisms;
▪ Frequent interaction between project workers and community
members, particularly during stakeholder engagement or where
resettlement or land acquisition processes are taking place;
▪ Remote and isolated work areas, where workers often have to travel
long distances to and from work;
▪ Labor influx: even minor labor influx in these remote areas
exacerbates SEAH risk
Forest and Forest conservation and restoration projects may include the following
Land Use SEAH risks:
▪ Remote locations, where there is little/no access to grievance
mechanisms or SEAH risk mitigation services;
▪ Forest conservation and restoration project sites may include worker
accommodations which may be poorly designed and/or maintained;

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 SEAH Risk Assessment Tool

▪ Frequent interaction with other marginalised communities (due to

poverty, rural and/or remote status) at increased risk of SEAH;
▪ Low mobile phone or digital penetration, resulting in a lack of access
to information and grievance mechanisms;
▪ Labor influx: even minor labor influx in these more remote areas
exacerbates SEAH risk;
▪ Remote and isolated work areas, where workers often have to travel
long distances to and from work.

Part 3: Assessment and Mitigation of SEAH Risks

Projects can exacerbate existing SEAH risks or create new ones. AEs are required to
therefore conduct a SEAH risk assessment for each GCF-funded project/programme.6 Once
SEAH risks have been identified, mitigation measures can be applied to address those
SEAH risks, which need to be built into the project cycle.

The GCF Programming Cycle

The GCF programming cycle provides an entry point for SEAH risk assessment and
mitigation. Risks must be anticipated upstream and managed throughout the project’s
lifecycle. Adequate flexibility must be built into the project so that implementers have the

6 The SEAH assessment should utilize some of the information from the gender assessment.

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opportunity to pivot or change aspects of the project based on how risks and impacts
materialize. The various relevant entry points for SEAH risk assessment and mitigation in
the specific project stages are outlined in table 3 below.
Table 2: SEAH risks assessment and mitigation throughout the project cycle

Stage Name Action

3 Concept Note • AE to conduct environmental and social (E&S) risk
submission screening, which must include risks of SEAH and risks of
exacerbating SEAH stemming from the project activities;
• Conduct stakeholder engagement in relation to potential
SEAH risks;
• AE needs to ensure it has the relevant expertise at this
stage and subsequent stages;
• Note key risks in Concept Note.
4 Funding • AE to conduct environmental and social assessment and
Proposal prepare management instruments;
Development • Recommend including an assessment of GBV risks and
mitigation in the gender assessment and GAP;
• Include a summary of the mitigation commitments in the
ESMF/ESMS/ESMP;
• Disclose the instruments to stakeholders and continue
stakeholder engagement activities;
• Include a budget for mitigation measures.
5 Funding • Any SEAH issues that have been missed will be raised by
Proposal the GCF Secretariat during the 2nd-level due diligence
appraisal review and proposals will be sent back to the AEs for
revisions/further assessment.
• The ESMF/ESMS/ESMP must contain measures as to
how the AE will address SEAH in the project (if any risks
identified).
8 Monitoring • As the AE/EE implements the project, AE ensures the
Implementation commitments in relation to SEAH risks in the
ESMP/ESMF are adhered to;
• All mitigation must be in place prior to project activities
commencing;
• Once project activities have begun, AE monitors the
grievance mechanism complaints;
• Continue informal stakeholder engagement;
• AE reports on SEAH safeguarding as part of ESS in its
Annual Performance Reports.
9 Adaptive • If monitoring or complaints from the grievance mechanism
Management suggests SEAH risks and impacts are not being
addressed effectively, the AE must adjust its strategies;
• Reinstitute formal stakeholder engagement with relevant
stakeholders;
• Potentially provide more budget for SEAH safeguarding;
10 Evaluation, • AE manages and submits final evaluation report of the
Learning and funded activity, which should note any SEAH issues that
Project Closure arose during the project and how they were effectively
dealt with.

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 SEAH Risk Assessment Tool

• SEAH complaints may still be made to GCF’s

independent review mechanisms after the closure of the
project.

At the stages of the GCF project cycle, AEs should consider all people involved, in all their
diversity, with special attention paid to marginalized and especially vulnerable groups. For
example:

• AE employees, consultants
• National Designated Authority employees
• GCF employees, consultants
• Contractor employees
• Subcontractor employees
• Beneficiaries
• Community members
• Other stakeholders
AEs must also consider where SEAH could occur, including:
1. Within the project or workplace (against workers in the workplace). This could be
perpetrated by other workers, or community members or outsiders brought onto the
project site;
2. Outside the project/workplace, in the community surrounding the project (by project
workers against community members, or community members against project workers)
Within these areas, sub-areas include on the worksite, in worker accommodation, between
workers outside the worksite (for example, in a social context at a bar or restaurant); in
spaces where communities congregate, such as at places of worship, schools, shops,
markets etc.
Box 4: Working with others from the start

Governments, Civil Society Organizations (CSOs), Indigenous Peoples Organizations (IPOs), service
providers and communities are key SEAH risk management partners and should be consulted during early
stakeholder engagement activities both in relation to the identification and the mitigation of SEAH risks. For
example, governments, both at the national and local level, can work with the AE to ensure potential risks
are addressed, by putting in place laws, policies or structures, if necessary, to ensure communities and
workers are protected. In regard to service provision, service providers, be they government or civil society,
can help to ensure there are resources in place to assist survivors of SEAH and to provide a survivor-
centered response. CSOs, who are often, due to proximity, better informed on the challenges and potential
effects the project could have on a community, can advise AEs about the realities on the ground, provide
research or statistics based on their work, and advise on potential mitigation measures. In particular, CSOs
and NGOs who work with women and children should be consulted. If consulting with communities directly,
care should be taken when discussing SEAH risks and mitigation measures. Consultations should never
directly ask stakeholders about their individual experiences of GBV or SEAH as this requires niche
specialist skills, training and well-equipped support services, as well as cultural sensitivity and knowledge.

Risk screening ahead of concept note submission (Stage 3 of the

programming cycle)
During Stage 3, when concept notes are being developed, AEs must conduct E&S risk
screening, including in relation to risks of SEAH which may be created or exacerbated by
project activities. In order to conduct this risk screening in a robust way, AEs may use the
checklist provided below. However, if AEs have their own checklist or other tool which
covers these risk factors, these can be used instead. Training may be available to AEs to

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build their capacity to undertake future risk screenings. The outcome of this screening will
inform the overall environmental and social risk category (A, B or C), in conjunction with the
screening of all other environmental and social risks. Once the checklist is filled in, the
information can be used as a starting point to conduct a focussed and more in-depth
assessment of relevant risks during Stage 4 (see section below).
It is important to note that SEAH risks begin immediately upon a project being conceived.
SEAH can occur internally within the AE itself or through its staff’s interactions with other
entities or individuals. Further, since initial stakeholder consultations will begin at this stage,
this presents direct interactions (either in person or virtual) between actors, and therefore the
risk of SEAH being perpetrated. There are often significant power imbalances between
stakeholders. Those individuals running stakeholder consultations must advise all sessions
and public meetings about the project grievance mechanism. This will be done in any event
in relation to feedback about the proposed project, however, it will be important to mention
that stakeholders may also complain about SEAH (or indeed any unethical behaviour) by AE
staff or anyone else involved in the proposed project. AEs should aim to have their own
institutional SEAH policy and employee Code of Conduct in place before approaching GCF,
the terms of which can then be cascaded to EEs or other contracted entities, via contractual
or procurement documents.

SEAH Risk Screening Checklist

Ensuring basic risk mitigation measures are in Responsibility Comments
place ahead of stakeholder engagement

Does the AE have a SEAH Policy (or SEAH AE

provisions in another policy)?
If the AE has contracted out stakeholder AE/Consultant
consultations, does that entity have a SEAH Policy
(or are they contractually bound to apply the
AE’s)?
Does the AE have an employee Code of Conduct? AE
If the AE has contracted out stakeholder AE/Consultant
consultations, does that entity have an employee
Code of Conduct (or are they contractually bound
to apply the AE’s)?
Have AE employees and consultants conducting AE/Consultant
stakeholder consultations been trained on
preventing SEAH and the Code of Conduct?
Does the AE have a grievance mechanism in AE
place in case of early SEAH complaints from
stakeholder engagement?
Does the AE have a specialist on staff who can AE
undertake the more advanced assessment in
Stage 4 as well as deal with early SEAH
complaints if they arise; and if not, does the AE
require budget and /or assistance with this?
Contextual Level (and Baseline Conditions) Reference Comments
Does the country have laws prohibiting sexual National /State law
harassment / stalking generally? (Gender Assessment)
Do labor laws prohibit sexual harassment in the National/State law
workplace? (Gender Assessment)
Does the country have laws prohibiting intimate National/State law
partner violence (IPV)? (Gender Assessment)
What is the prevalence of GBV in the country? National statistics
(Gender Assessment)
What is the legal age a person can marry? National law

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 SEAH Risk Assessment Tool

Despite any laws, what is the prevalence of child National statistics

marriage in the country?
What is the income level of the country? World Bank ranking
(H, HM, M, LM, L)
Where does the country rank on global gender World Bank Reports /
indices? Other
Is there a national action plan on GBV and/or National government
sexual harassment?
Does the country have specialized services for Local gov / NGOs
survivors of GBV (at both the national and local
level) including women’s shelters, adequate
medical facilities and facilities which provide
psycho-social support?
Is the country currently experiencing war, internal National / Media
conflict or humanitarian disaster?
Project Level Risks Responsibility Comments
Are women concentrated in lower paid roles and AE
mostly line-managed and supervised by men?
Are piece-rate systems or other performance- AE
related pay structures used where individuals are
in control of how much other workers get paid?
Will project workers have control over life- AE
changing resources such as the allocation of
compensation for displacement or access to basic
or highly sought-after resources?
Will security personnel be used? Will they be AE
armed?
Will there be an influx of male workers into the AE
project area (as opposed to only using local
labor)?
Are local communities poor and lacking basic AE
resources?
Will migrant workers be employed by the project, AE
especially those who may not speak the local
language? Will they be employed on a temporary
or daily basis?
Will project workers all have formal contracts?
Will goods frequently be transported over long AE
distances, especially through poor and/or remote
communities?
Are worksites or project activities based in AE
remote locations? Will worksites be spread out,
with isolated spaces?
Will project workers live in the community or in AE
worker housing? If in worker housing, is it mixed
sex?
Will workers be required to travel long and AE
potentially unsafe distances, and at times of day
when transport options may be limited?
Will the project operate in highly pressurised work AE
environments, with tight seasonal deadlines?
Is the project located within a male-dominated AE
sector where female workers will be employed?
Have communities, especially low income/ AE
vulnerable communities, voluntarily raised
concerns in relation to SEAH/GBV during
consultations?
Have any changes been made to project design or AE
adaptive management undertaken due to

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concerns of stakeholders and communities? (If

yes, work through this checklist again)

Risk assessment & mitigation when developing Funding Proposals (Stage 4 of

the programming cycle)
In stage 4, when funding proposals are being developed, AEs should undertake appropriate
integrated assessments that take into consideration the combined E&S risks (including
SEAH risks and impacts) that were flagged during initial screening, including the nature,
magnitude and complexity of the impacts and the specific characteristics of the influence
area. A social specialist will be needed to assess SEAH risks. AEs may use an in-house
social specialist, consultant or third-party expert for this.
Box 5: Readiness and Preparatory Support Program

The RESP stipulates that SEAH provisions will be operationalized via the SEAH Action Plan, and that
“the GCF may provide guidance to accredited entities to assist them to undertake the necessary SEAH
risk assessment. In addition, direct access accredited entities may request resources (such as funding
for third party advice) through the Readiness and Preparatory Support program to assist them in
conducting their SEAH risk assessments.”7 Thus, if the AE does not have capacity to conduct the
SEAH risk assessment, as outlined in this tool, an expert consultant can be hired to assist the process.

If no SEAH risks were flagged (or raised by stakeholders) during stage 3 of the programming
cycle, this should be questioned (as it would be highly unusual). Most often, SEAH risks will
be flagged or identified during screening (for example by using the Checklist in stage 3), and
then when assessed in more detail either the risks are found to be low, requiring no specific
action, or it is determined that even though the risks may be more significant, that measures
can be put in place to either prevent or mitigate them.
The following checklist gives AEs guidance on general (not project-specific) mitigation
measures that can be put in place to reduce SEAH risks in projects, preventing it from
happening in the first place and ensuring effective and safe response when it does. Note
that not all of these mitigation measures are strictly required by GCF, however they can be
adopted by the AE in consideration of a proportionate response to the SEAH risks identified.

Checklist of Potential SEAH Risk Mitigation Measures

Mitigation Comments
POLICY AND CODE OF CONDUCT
Does the AE have a SEAH policy which covers the project?
Does the project have a Code of Conduct prohibiting SEAH by workers?
Are clauses included in procurement contracts which commit contractors,
subcontractors, suppliers, drivers and security personnel (if applicable) to
adhere to the AE Code of Conduct (or EE equivalent)?
SUPERVISION AND TRAINING
(For larger, longer-term projects) Is there a trained SEAH specialist in the
project team?
Does the project plan to train all project workers on the Code of Conduct,
SEAH and what is prohibited behaviour?
RECRUITMENT AND PERFORMANCE ASSESSMENT
Are recruitment procedures in place, with interview panels staffed by at
least two people?
Are candidates' identities checked at interview and are references
requested?
Are all workers required to be hired on formal contracts?

7
GCF RESP Section V (g), (h), p 10.

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 SEAH Risk Assessment Tool

Are written procedures in place for performance appraisals, promotions,

and any performance-related pay increases (if applicable)?
GRIEVANCE REDRESS MECHANISMS (GRM)
Does the project have a GRM for community members to raise SEAH-
related complaints and concerns and is it confidential and survivor-
centred, with multiple reporting channels?
Does the project have a GRM for project workers to raise SEAH-related
complaints and concerns and is it confidential and survivor-centred, with
multiple reporting channels?
Are the staff who manage the GRMs equipped and trained to respond to
SEAH reports in a safe and effective way?
Are persons, communities and countries affected or potentially affected by
the activities consulted and that effective SEAH GRMs to receive
complaints and feedback are established and function in a collaborative
manner and in a way that is complementary to GCF independent Redress
Mechanism, and requiring that any gaps or weaknesses be addressed?

Are affected communities (or likely to be affected, by the GCF-financed

activities) informed about SEAH GRMs at all three levels – at the earliest
opportunity of the stakeholder engagement process and in an
understandable format and in all relevant languages?

INVESTIGATION AND RESPONSE

Are there written procedures for dealing with SEAH complaints or
concerns and a dedicated and trained female staff member to deal with
these (if no specialist is available)?
Has a service provider mapping been undertaken to identify which
services are available for survivors of SEAH?
If there are no public or private service providers in the area, has the
project identified and budgeted for outside providers?
AWARENESS RAISING
Will/have gender-sensitive and culturally appropriate outreach materials
been prepared (such as posters, signage, etc.) on SEAH in all relevant
languages?
Has the community been informed about potential SEAH risks for the
project and how to prevent them and use the GRM?
Have any rapid mobile surveys or text surveys been developed to regularly
obtain feedback from workers and/or the community?
PROCUREMENT AND PARTNERSHIP
Have SEAH prohibitions and mitigation measures been included in
procurement documents?
Are there clauses in the EE contract requiring them to prohibit SEAH in
their workforce?
PHYSICAL WORKSPACE
Will separate facilities for men and women be provided at all work sites?
Are SEAH risks included in workplace safety assessments, including
worker accommodation and transportation?
Are project workers informed of areas that are off-limits, for example areas
around schools (or other places where children are present)?

During this stage, risks and mitigation measures need to be inserted into both the GAP (as
needed related to gender) and draft ESMF/ESMS/ESMP.
Annex 1 sets out further potential project-specific mitigation measures that AEs may adopt if
particular SEAH risks/topics are identified during screening and subsequent assessment.
The table in Annex 1 uses a “menu” format that can correspond to the ESMP.

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Addressing SEAH during project implementation (Stage 8 of the programming

cycle)
Once the project/program has been approved and first disbursement made, AEs and/or
contractors need to have:
A project/program Code of Conduct prohibiting SEAH (amongst other behaviours). This
should be signed by all workers at the same time the work contract is signed. The Code of
Conduct must be made available in languages the workers understand. This will be
particularly relevant if migrant workers will be employed. Individual employment contracts
should also contain a prohibition on SEAH.
A GRM in place for immediate, timely, mandatory and confidential reporting of SEAH
incidents. This GRM may be the same one set up for stakeholder engagement i.e., part of
the overall project/program GRM, or can be a standalone GRM with different, survivor-
centred procedures. Survivor-centred procedures are essential in either case, and existing
GRMs may need to be adapted or expanded to include survivor-friendly reporting channels.
In larger projects/programs with higher SEAH risks, a trusted, local, expert third party may
be contracted to run this GRM.
A plan for training all workers on SEAH and their roles in prevention and response. It
is best practice to conduct training of all contractor and subcontractor employees (and/or any
community workers) on SEAH and the relevant provisions in the Code of Conduct within the
first few days of project activities commencing, in conjunction with occupational health and
safety training and any other required trainings. Aspects of SEAH training should be
repeated regularly (at least monthly) during daily/weekly briefings. New employees must
also undergo the training before beginning work.
Awareness raising of workers and local community members. Anti-SEAH posters and
signs should be prepared and posted around the work sites and project/program areas,
including in bathrooms and labor accommodation. Projects with large labor influx should
engage third party monitors to regularly inspect the work site and conduct worker interviews.
Clear leadership from senior management. Managers should be made aware of their
heightened responsibilities in relation to (1) reporting SEAH if and when they see it, (2)
providing regular, clear information about consequences to workers, and (3) ensuring there
is no retaliation against workers who make complaints or report inappropriate behaviour.
Specific training for managers may be appropriate depending on the project/program
context. Project Managers must be able to communicate with migrant workers in a language
they understand.
A social specialist should be engaged on larger projects (and/or Category A projects)
and should be a resource and focal point for advice on SEAH incidents, as well as an
alternate, trustworthy internal source for reporting. Strengthened supervision systems, and
incentives for reporting inappropriate behaviour combined with clarity on the consequences
of such behaviour are some ways in which managers of project/programs can prevent SEAH
from occurring.

Tracking SEAH risks/monitoring (Stage 8 of the programming cycle)

important if the project design or implementation changes. AEs should note that receiving no
reports could be a sign that reporting mechanisms are either not accessible or not trusted by
project/program workers and/or the community. The GAP should be reviewed and updated if
and when a SEAH incident occurs, and mitigation measures strengthened in relevant areas.
Taking stock of lessons learned and applying adaptive management to the project/program

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should be undertaken on a regular basis and at least every six months during
implementation.
The social specialist engaged to work in the project/program team should continue
stakeholder and community consultation throughout implementation, undertaking regular
consultations with women, youth, persons with disabilities and other vulnerable groups. All
groups should be reminded of the GRMs and the fact that anonymous complaints can be
made. They should also be made aware of the SEAH services available in the
project/program area, which can be accessed even if a survivor does not wish to make a
complaint to the project/program’s GRM. Only the SEAH specialist should advise workers
and community groups about SEAH services, as this may be a sensitive issue. All
specialists must be well trained and experienced in this area.
The social specialist should also:
▪ Track whether reporting mechanisms are being used – looking at where reports are
coming from/not coming from, and seeking to identify patterns;
▪ Ask workers and community members if they are aware of and trust reporting
mechanisms, understand their rights and what constitutes SEAH;
▪ Check whether workers demonstrate knowledge and understanding of the policy and
code of conduct – and can locate them;
▪ Check whether community members have knowledge of what behaviors to expect
from project/program workers and which are prohibited; and
▪ Check mitigation measures are consistently being implemented – e.g., undertake
spot checks to see if contracts include clauses, use basic records to track whether
SEAH training is being delivered, check reporting mechanisms are functioning, use
monitoring visits to check whether awareness-raising materials are clearly visible and
awareness-raising exercises are being delivered and engaged with.
Project/programs involving a large workforce should consider developing a worker app to
collect mass anonymous feedback and conduct rapid surveys of workers on many different
topics, such as SEAH, violation of worker rights and occupational health and safety issues.
The app may also provide a pathway for grievance reporting and use of the GRM.
AEs/EEs must report SEAH incidents or complaints to the GM to GCF, although the AE/GM
should not provide any personally identifiable information (PII).
The AE should also include annual reporting on SEAH safeguarding as part of its reporting
on ESS through section 4 of the APR.

Responding to reports: taking a survivor-centered approach

The RESP mandates that GRMs need to be survivor-centered and gender-responsive. The
survivor-centered approach involves a rights-based approach and considers the entirety,
and diversity, of survivors’ lived experiences. It involves framing those against whom SEAH
is perpetrated not simply as unidimensional victims of violence/harassment, but as survivors,
for whom the experience of violence is now a part of their lived experience but does not
serve to define them. A survivor-centered response ensures that the response to incidents
is non-discriminatory and respects and prioritizes the rights, needs and wishes of survivors,
with special attention to the most marginalized and vulnerable groups who are particularly at
risk or may be specifically targeted for SEAH.

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In practical terms this means the survivor:

• Should be kept informed about the process;

• Should participate in the decision-making process;
• Should be informed clearly about the options available to them for redress and make
their own decision about what option is right for them;
• Must provide prior informed consent if staff use or disclose their information.

Staff interacting with the survivor and/or handling information regarding the
allegation must:

• Disclose mandatory reporting requirements before asking survivors for information;

• Maintain confidentiality;
• Ensure safety of the survivor;
• Apply the principles of safety, confidentiality, respect, and non-discrimination;
• Follow the law in the country and report any incident that requires mandatory reporting;
• Not make decisions for the survivor or try to influence their decision (for example to seek
counselling, report to police (unless the country has mandatory reporting requirements).

When the survivor is a child, the approach must also:

• Always consider the best interests of the child; and

• Engage with the family/caregivers and/or legal guardians as appropriate and/or required
by law.

When the survivor is a person with disability, all the required SEAH support services
must be carried out in an inclusive manner and intersectional lenses must be put into
consideration (where required, seek expertise)

In this vein, key areas to consider during project/program implementation include:

❖ Take a phased approach if necessary. Consider the greatest SEAH risks and
which groups may be most vulnerable. Establish accessible mechanisms in these
areas first if resources are constrained.
❖ Equip community members, workers, and other stakeholders with knowledge.
Everyone who interacts with a project/program should know that they have a right to
report a concern related to SEAH, how to do so and the process that would ensue.
Communicate clearly and repeat the message. Plan how this communication will be
managed and monitored across all operations.
❖ Update complainants on the status of processes regularly. This includes
outlining expected timeframes and providing prompt responses to any questions.
❖ Provide information on the support and safety measures available. This can
include communicating through worker representatives, trade unions and local
organisations (while maintaining confidentiality).
❖ Identify a diverse pool of individuals to be responsible for the company’s
response to reports. This should consider diversity, including gender and race, as
well as people from indigenous or migrant groups.

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❖ Include worker representation in any worker grievance committees. This

includes providing the option for workers to have a representative or co-worker
present. These steps help reduce power imbalances within a management-led
grievance mechanism.
❖ Ensure protection for those workers on grievance committees. This includes
making sure they are not at risk of losing their jobs or being harassed because of
their involvement.
❖ Roll out mandatory training and provide guidance to all those who might
receive a report. In particular, this includes managers and occupational health and
safety focal points. Equip workers with guidance appropriate to their role in
responding to reports.
Guiding principles in working with survivors and witnesses of SEAH include the importance
of creating a safe and accessible environment. They should also highlight the importance of
engaging with survivors with sensitivity, understanding, and reflection as well as
independence, objectivity and non-judgement. The GRM must also be context-specific,
hence all actions should be based on an understanding of the local legal and social context.
Creating a safe and accessible environment includes ensuring safeguarding measures are
in place for survivors and whistle-blowers, and that medical, psychological, housing, and
legal support is available for survivors.
Ensuring the implementation of safety planning, and an accessible and inclusive
environment (ensuring childcare, safe transport, provisions for survivors with a disability) is
also key, as is addressing the increased risk of SEAH for certain groups. Maintaining an
environment that is confidential and anonymous is also paramount - there cannot be a risk
that survivors are identified when attending investigation interviews or meetings.
Part of engaging with survivors with sensitivity, understanding and reflection is ensuring that
any processes involving them are survivor-led and designed. This also involves providing
options for survivors on how they want to engage. Informed consent must be received for
any engagement, images, quotes or written work and communication must be clear, friendly,
and realistic vis-à-vis expectations. Survivor-centered responses prioritize the rights and
needs of people who have experienced SEAH and listen to their wishes. They also protect
people who experience, witness or report SEAH, as well as those who seek to address it.
They must also be collaborative and entail work with internal and external stakeholders to
identify risks, prevent SEAH and respond to reports.
AEs should note that many SEAH behaviors are also criminal in nature and should be
reported to the police, if the survivor agrees (a survivor-centered response requires the
organization to gain the survivor’s permission). However, this does not absolve the
organization for which the perpetrator works from taking action. This action may be taken in
conjunction with a criminal case (for example suspending the alleged perpetrator without pay
until a decision is reached by the police and/or courts) or if not, criminal case is filed, should
be dealt with via the internal investigation processes of the GRM. Survivor-centered
grievance mechanisms and redress should be available for all survivors.

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Annex 1 - SEAH in ESMP/ESMF (or other instrument) – Mitigation Measures Menu

This table provides a non-exhaustive “menu” of potential SEAH risks in project/program that can be added to the ESMP or another relevant
instrument. Project and Program developers should consider these specific risks and additional mitigation measures particularly if assessing a
high-risk project/program or a project to be delivered in a conflict or fragile environment. Mitigation measures are also in “menu” form and can
be chosen depending on resources and relevance. The likelihood and impact assessment are not to “score” risks, simply to help identify the
biggest risks that may require significant financial and human resources. Any relevant risks and mitigation should be added to the ESMP/ESMF
(or other relevant ESS instrument) and GAP in relation to the gender component where necessary.

Likelihood Potential Risk Mitigation

Description of [Potential] Risks
(LMH) Impact (LMH) Measures
Contextual Risks
National Level Risks • Work with relevant gender/social welfare Government
• Lack of laws prohibiting SEAH ministries and departments, other anti-gender-based violence
• Lack of strong legal system to enforce laws organizations or networks;
• Low levels of prosecution of SEAH incidents • Strong enforcement of the AEs SEAH (and/or its equivalent)
• Lack of national action plans or policies on policy;
preventing SEAH • Enforcement of SEAH related laws as it pertains to the
project/program.
Societal Risks
• Work with local government or authorities to sensitize
• Sociocultural norms that promote or does not
community members on SEAH safeguarding;
challenge SEAH
• Identify male champions where applicable to act as allies on
• Low levels of awareness on rights, SEAH
SEAH safeguarding;
etc. Limited services for SEAH survivors.
• Provide SEAH training to project stakeholders and
communities.
Project Risks
• Higher risk of SEAH in project/program area
• As above societal risks and;
than national average
• Support local officials in campaigns on prevention of SEAH;
• Limited SEAH protection services in
• Leverage existing relationships with government stakeholders;
project/program area
identify champions / supporters / changemakers within the
• High rates of femicide or sexual violence
government (specifically on SEAH);
(e.g., used as a tactic of war) in
• Conduct SEAH awareness-raising within the community;
project/program areas

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• Women fear that participation or employment
in the project/program may exacerbate
ongoing forms of SEAH
• Increased risk of SEAH in the transport and
infrastructure project/program activities
26
SEAH Risk Assessment Tool
• Where such severe barriers exist, extensive community
consultation is required to understand all the social and issues
that may further reinforce SEAH – and identify (inclusive and
participatory) measures to address these barriers;
• Undertake SEAH sensitization campaigns/trainings and/or
disseminate relevant SEAH messages to the targeted
communities;
• Include SEAH messages (including reporting mechanisms) in
construction sites, e-buses (and other modes of transport)
• Provide in the community on SEAH risks, how to report them
and the services available including SEAH GRM.
GREEN CLIMATE FUND
SEAH Risk Assessment Tool

Annex 2 - SEAH Internal GCF Risk Assessment Tool for appraisal of 1st-level SEAH
due diligence

General Mitigation Responsibility Comments

Has a GBV and SEAH risk assessment been GCF
undertaken for the project/program? (See
above sections of this table)
What is the capacity of the AE to identify and GCF
deal with risks?
Have mitigation measures been identified to GCF
address risks?
Are the measures appropriate to mitigate the GCF
risks identified?
Does the project/program’s Gender GCF
Assessment raise GBV and SEAH issues?
Have women and girls been consulted (and if GCF
so, what was the method of consultation) about
the project/program design? Did they raise any
GBV/SEAH issues?
For all of the above, have the risks and GCF
mitigation been included in the ESMP (or
another relevant instrument)?

GREEN CLIMATE FUND 27