PSEA Policy

Human Resources & Organizational Development

Protection from Sexual Exploitation and Abuse (PSEA)

Version Control
Update
Date/Month issued Author
Version No information/Remarks

0.0 September 2017 Asif First Draft

1.0 20 Mar 18 Mamun Reviewed by Director &

Head of HR

2.0 02 Apr 18 Mamun/Asif Review & Feedback

3.0 06 July 18 Marc/Ken/Stephane Feedback

4.0 08 Aug 18 Asif/Mamun/ED Reviewed & Updated

and Approved by the
ED

5.0 18 Oct 2021 Communications/ Branding i.e. logo,

Asif/Mamun watermark & copywrite.
Table of Contents. ED’s
kind consent has been
taken by Mr. Mamun –
SR. Director & HOHR

6.0 07 January 2022 Education/Asif/Mamun Updated as per the

feedback of UNICEF i.e.
referral section. ED’s
kind consent has been
taken by Mr. Mamun –
SR. Director & HOHR

7.0 15 January 2022 Asif/Mamun/ED Feedback from ED

8.0 02 Feb 2022 Education/Asif/Mamun/ Further changes to

ED match the requirements
of UNICEF i.e. on & off
duty matter. ED’s kind
consent has been taken
by Mr. Mamun – SR.
Director & HOHR

Date/Month Issued: July 23

Version: 13.0
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9.0 10 Feb 2022 Education/Asif/Mamun/ Further changes in
ED referral section. ED’s
kind consent has been
taken by Mr. Mamun –
SR. Director & HOHR

10.0 13 March 2022 Asif/Mamun/ED Updated the reporting

section, Added PSEA
Committee & Updated
Action Plan as per the
instruction of SR.
Director & HOHR. ED’s
kind consent has been
taken by Mr. Mamun –
SR. Director & HOHR

11.0 27 February 2023 Education/Asif/Mamun/ Based on the feedback

ED from UNICEF PSEA
team, as per the
instruction of SR.
Director & HOHR. ED’s
kind consent has been
taken by Mr. Mamun –
SR. Director & HOHR

12.0 14 May 2023 Asif/Mamun/ED As per the

reassessment guideline
from UNICEF. as per
the instruction of SR.
Director & HOHR. ED’s
kind consent has been
taken by Mr. Mamun –
SR. Director & HOHR.

Updated areas are:

Training part, investigation
decision part, reporting part,
referral pathways and awareness
raising plan

13.0 3 July 2023 Asif/Mamun/ED As per the

reassessment guideline
from UNICEF. as per
the instruction of SR.
Director & HOHR. ED’s
kind consent has been
taken by Mr. Mamun –
SR. Director & HOHR.

Updated areas are: Policy

part – mandatory training for
stakeholders during on boarding.
reporting mechanism accessibility
and investigation timeline

Date/Month Issued: July 23

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Table of Contents
1.Purpose ............................................................................................................................. 4
2.Scope................................................................................................................................. 4
3.Sexual Exploitation and Abuse (Sea) ................................................................................. 4
4.What Is Sexual Harassment ............................................................................................... 5
5. What Is Not Sexual Harassment ....................................................................................... 6
6. Non-Sexual Harassment at Workplace.............................................................................. 6
7. Harassment by Non -Employees ....................................................................................... 6
8. Policy ................................................................................................................................ 7
Six Core Principles Relating to Sexual Exploitation and Abuse ............................................. 8
9.Responsibilities .................................................................................................................. 9
10.Behaviors Towards Community/Beneficiaries ................................................................ 10
11.Procedures and Community Based Complaint Mechanisms .......................................... 12
11.1 Complaint Process .................................................................................................. 12
11.2 Informal Intervention ................................................................................................ 15
11.3 Formal Complaints Procedure/Investigation ............................................................ 15
11.4 Referral Pathways/Procedures for Dealing with Criminal Conduct ........................... 20
12. Awareness Raising Plan ............................................................................................... 22
13. Action Plan .................................................................................................................... 25

Date/Month Issued: July 23

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1.Purpose

Every employee of Friendship as well as its affiliates has the right to work and interact in an
environment free from sexual exploitation and abuse, physical violence, harassment,
intimidation, or offensive behavior including sexual harassment and in which issues of
harassment will be resolved without any fear of reprisal.

Objective of this policy to make available reporting and protection mechanisms and address
any acts of sexual exploitation and abuse, physical violence and sexual harassment. This also
aims to address the behavior of Friendship staffs and affiliates within its own-work environment
and towards the third parties and to protect vulnerable populations from possible sexual
exploitation and abuse by any Friendship staff and affiliates in the areas of operations.

It is a Friendship policy, in accordance with a positive work environment, discrimination – free

work environment, that Sexual Exploitation and Abuse (SEA), physical violence and sexual
harassment in the workplace is completely unacceptable and will not be tolerated.
FRIENDSHIP has a policy of zero tolerance to prevent any kind of sexual harassment in the
workplace. Conduct will be subject to discipline, ranging from a warning to termination from
employment.

2.Scope

This policy applies to all FRIENDSHIP employees (both on-and off-duty) and
affiliates/stakeholders related to Friendship in particular Donors, Doctors, Volunteers/Interns,
Journalist, Suppliers/Vendors, Contractors and Visitors and providing protection to all staffs,
beneficiaries including children, and other stakeholders from SEA.

3.Sexual Exploitation and Abuse (Sea)

Sexual exploitation - any actual or attempted abuse of a position of vulnerability, differential

power, or trust, for sexual purposes, including, but not limited to, threatening, or profiting
monetarily, socially, or politically from the sexual exploitation of another.

Sexual abuse - the actual or threatened physical intrusion of a sexual nature, whether by
force or under unequal or coercive conditions.

PSEA – Protection from Sexual Exploitation and Abuse (PSEA) is the mechanism to protect
the survivors from any unwanted/illegal sexually abusing and harassing by the perpetrators.

Date/Month Issued: July 23

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4.What Is Sexual Harassment

Sexual harassment is defined as verbal or sexual advances, requests for sexual favours, and
other sexual conduct which is offensive or objectional to the recipient including, but not limited
to suggestive comments, slurs or gestures and offensive posters, cartoons, pictures or arts.
physical contact; written and oral remarks, gossip, jokes and banter to the opposite or same
sex.

Examples of sexual harassment include, but are not limited to,

a. staring or leering
b. unnecessary familiarity, such as deliberately brushing up against you or unwelcome
touching
c. suggestive comments or jokes
d. insults or taunts of a sexual nature
e. intrusive questions or statements about private life
f. displaying posters, magazines or screen savers of a sexual nature
g. sending sexually explicit emails or text messages
h. inappropriate advances on social networking sites
i. accessing sexually explicit internet sites
j. requests for sex or repeated unwanted requests to go out on dates
k. behavior that may also be considered to be an offence under criminal law, such as
physical assault, indecent exposure, sexual assault, stalking or obscene
communications
l. Attempts or efforts to establish physical relation having sexual implication by abuse
of administrative, authoritative or professional powers;
m. Indecent gesture, teasing through abusive language having sexual implication.
n. Taking still or video photographs for the purpose of blackmailing and character
assassination;
o. Preventing participation in organizational activities on the ground of sex and/or for the
purpose of sexual harassment;
p. Exerting pressure or posing threats in case of refusal to love proposal;
Friendship is also committed to follow the definition of sexual harassment set forth by the
Ministry related to this law of People’s Republic of Bangladesh.

Date/Month Issued: July 23

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5. What Is Not Sexual Harassment

Sexual harassment does not include compliments which are socially acceptable in nature.
Behaviour that is based on mutual relation, friendship and respect is not sexual harassment.

6. Non-Sexual Harassment at Workplace

Behavior such as making racist or negative comments can also be construed as workplace
harassment. Offensive gestures, drawings, or clothing also constitute harassment. Employee
should address this sort of workplace bullying in the same way that they would sexual
harassment – by reporting it to Sector/Unit Head and Human Resources & Organizational
Development and, if nothing is done, by filing a harassment claim with the Executive Director.

Instances of workplace harassment include discrimination such as:

a. Making negative comments about an employee's personal religious beliefs or trying to

convert them to a certain religious ideology.
b. Using racist slang, phrases, or nicknames
c. Making remarks about an individual's skin color or other ethnic traits
d. Displaying racist drawings, or posters that might be offensive to a particular group
e. Making offensive gestures
f. Making offensive reference to an individual's mental or physical disability
g. Sharing inappropriate images, videos, emails, letters, or notes
h. Offensively talking about negative racial, ethnic, or religious stereotypes
i. Making derogatory age-related comments
j. Wearing clothing that could be offensive to a particular ethnic group

Non-sexual harassment isn't limited to these examples. Non-sexual harassment includes any
comment, action, or type of behavior that is threatening, insulting, intimidating, or
discriminatory and upsets the workplace environment.

7. Harassment by Non -Employees

We will endeavor to protect employees and beneficiaries from reported harassment and give
protection from sexual exploitation and abuse by non – employees such as vendors, suppliers
and other parties i.e. Donors, Doctors, Volunteers/Interns, visitors, journalist etc who have
workplace contact with our employees.

Date/Month Issued: July 23

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8. Policy

1. Friendship will not tolerate sexual harassment, sexual exploitation, and abuse under
any circumstances. Responsibility lies with every Manager, Supervisor and employees
or stakeholders to ensure that sexual harassment does not occur.

2. This policy applies to any work-related context, including conferences, work functions,
social events, and official trips.

3. No employee or stakeholder or including children at any level should subject any other
employee or stakeholders or including children to any form of sexual exploitation,
abuse, and harassment.

4. Every employee of Friendship, volunteer and beneficiary including children will get
orientation on Protection from Sexual Exploitation and Abuse (PSEA) and Sexual
Harassment base on this PSEA policy.

5. Every employee of Friendship will get mandatory regular training on Protection from
Sexual Exploitation and Abuse (PSEA) and Sexual Harassment base on this PSEA
policy, ideal once year. The training attendance sheet will be maintained accordingly
for internal record.

6. Stakeholders of Friendship will get mandatory training on during onboarding

Protection from Sexual Exploitation and Abuse (PSEA) and Sexual Harassment base
on this PSEA policy, ideal once year.

7. Safeguarding taskforce will provide training (or meetings) to the beneficiaries,

consultants, vendors/contractors, and volunteers/interns at least once a year. Record
of the training/meetings will be kept as an attendance to share with HR.

8. PSEA and Sexual Harassment elimination related messages must discuss with all
stakeholders, vendors/contractors, visitors, beneficiaries including children of
Schools/Learning Centers, SMC/LCMC, Religious Leaders through different sessions,
meetings, and trainings.

9. Friendship strongly encourages any employee who feels they have been sexually
harassed/abused to take immediate action. If an employee or stakeholder feels
comfortable in doing so, it is preferable to raise the issue with the person directly with
a view to resolving the issue by discussion. The employee or stakeholders should
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identify the harassing behaviour, explain that the behaviour is unwelcome and
offensive and ask that the behaviour stops.

10. Alternatively, or in addition, they may report the behaviour in accordance with the
relevant procedure to Human Resources & Organizational Development. Once a
report is made to the HR & OD, then the organisation has the right to determine how
the report should be dealt with in accordance with its obligations and this policy.

11. Any reports of sexual exploitation, abuse and harassment will be treated seriously and
promptly with sensitivity. Such reports will be treated as completely confidential up to
the point where a formal or informal complaint is lodged against a particular person, at
which point that person must be notified under the rules of natural justice.

12. Complainants/Survivors have the right to determine how to have a complaint treated,
to have support or representation throughout the process, and the option to discontinue
a complaint at any stage of the process.

13. The alleged harasser/ perpetrator also has the right to have support or representation
during any investigation, as well as the right to respond fully to any formal allegations
made. There will be no presumptions of guilt and no determination made until a full
investigation has been completed.

14. No employee or stakeholders will be treated unfairly because of rejecting unwanted

advances. Disciplinary action may be taken against anyone who victimizes or retaliates
against a person who has complained of sexual exploitation, abuse, and harassment,
or against any employee or stakeholders who has been alleged to be a
perpetrator/harasser.

15. All employees and stakeholders have the right to seek the assistance of the relevant
tribunal or legislative body to assist them in the resolution of any concerns.

16. Managers or Supervisors who fail to take appropriate corrective action when aware of
exploitation, abuse and harassment of a person will be subject to disciplinary action.

Six Core Principles Relating to Sexual Exploitation and Abuse:

1. Sexual exploitation and abuse by humanitarian workers constitute acts of gross

misconduct and are therefore grounds for termination of employment.

Date/Month Issued: July 23

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2. Sexual activity with children (persons under the age of 18) is prohibited regardless of
the age of majority or age of consent locally. Mistaken belief regarding the age of a
child is not a defence.
3. Exchange of money, employment, goods, or services for sex, including sexual favours
or other forms of humiliating, degrading or exploitative behaviour is prohibited. This
includes exchange of assistance that is due to beneficiaries.
4. Any sexual relationship between those providing humanitarian assistance and
protection and a person benefitting from such humanitarian assistance and protection
that involves improper use of rank or position is prohibited. Such relationships
undermine the credibility and integrity of humanitarian aid work.
5. Where a humanitarian worker develops concerns or suspicions regarding sexual
abuse or exploitation by a fellow worker, whether in the same organization or not, he
or she must report such concerns via established organization reporting mechanisms.
6. Humanitarian workers are obliged to create and maintain an environment which
prevents sexual exploitation and abuse and promotes the implementation of their code
of conduct. Managers at all levels have particular responsibilities to support and
develop systems which maintain this environment.”

9.Responsibilities

1. Each Manager is responsible for properly implementing this policy within his or her
area of supervision. Understand and are committed to the rights and entitlements of
all employees or beneficiaries including children, stakeholders to attend work and
perform their duties, without fear of being sexually harassed in any form.

2. They should understand what constitutes an act of sexual harassment, sexual

exploitation, and abuse; all reasonable steps are to be made to eliminate sexual
harassment, exploitation and abuse.

3. All employees and beneficiaries including children, Stakeholders are regularly made
aware of their obligations in relation to providing a workplace free from sexual
harassment, sexual exploitation, and abuse; they provide an environment which
discourages harassment and victimization and set an example by their own behavior.

4. Managers take immediate and appropriate corrective action asap whenever they
become aware of any offensive action related to sexual exploitation and abuse.

Date/Month Issued: July 23

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5. It is the responsibility of the Human Resources & Organizational Development
Department to ensure that: policies and procedures are regularly reviewed and (if
necessary) amended; policies and procedures are complied with; regular guidance
and education is provided to employees and beneficiaries including children through
respective Sector/CSU regarding sexual exploitation and abuse, harassment, and
inappropriate behavior in the workplace.

6. Managers are aware of their obligations and responsibilities in relation to sexual

exploitation and abuse, and the rights and entitlements of their employees and
beneficiaries including children, Stakeholders; ongoing support and guidance is
provided to all employees in relation to the prevention of sexual exploitation and abuse.

10.Behaviors Towards Community/Beneficiaries

1. All staff of friendship are bound to follow organizational gender policy, PSEA policy in terms
of beneficiaries including children (students, parents, guardians, vendors, and any other
stakeholders.)

2. If unexpectedly any a PSEA related incidents with our beneficiaries including children by
the Friendship’s staffs, then it would be considered and handled within shorter possible of
time through a proper investigation against the accused of.

3. If any Friendship staff found guilty in any PSEA related cases, Friendship applies the
highest punishment up to termination from employment against the person who is guilty.

4. If the victim including children claimed assistance related law and law-enforcing agencies
considering his/her condition, Friendship follows a referral pathway to save the victims and
to ensure justice for the mankind.

5. Maintain good manners, refer all office personnel respectfully (For both seniors and
juniors) and maintain respect to beneficiaries including children.

6. Personal dealings leading to sexual exploitation and abuse are strictly prohibited at the
field level (Community including children and Staff).

7. Swimming and bathing are fully restricted to chars, in camp and our field areas.

8. You must inform your supervisor if you stay in the field after evening.
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9. Do not take anything-Food, any gift or borrow from the community.

10. Do not buy anything from the community/beneficiaries.

11. Do not stay in beneficiaries’ room for rest (sleep)/night stay.

12. Always respect beneficiaries’ community culture. Do not disrespect the beneficiaries.

13. Maintain good manner with the beneficiaries, any sort of sexual exploitation & abuse will
not be tolerated.

14. We must guide/support our beneficiaries in proper reporting system of sexual exploitation
& abuse related matters.

15. Maintain utmost confidentiality regarding any reporting system of sexual exploitation &
abuse related matters.

16. Prioritize char protocols of Local Government Institutations (PLGI) according to the
purpose of implementing Programmes in terms of all issues especially sexual exploitation
and abuse.

17. It is highly discouraged to go on the chars and camps alone.

18. Avoid discussing unethical issues so that no one feels disturbed while traveling by boat.

19. Avoid saying something that might be indirectly/directly discriminating towards others.

20. Provide accurate information about respective issues, in case of insufficient data on the
related issue it is advised to take further time to gather more information or introduce any
other official who have the access to the information especially for PSEA cases.

21. Put utmost importance in ensuring positive non-discriminatory environment for the
physically challenged community members and maintain gender balancing.

22. Child protection Policy shall be followed if any children is victim of SEA related issues.

Date/Month Issued: July 23

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11.Procedures and Community Based Complaint Mechanisms

11.1 Complaint Process

1. Sexual exploitation and abuse or harassment can occur at any level of the
organization, can be experienced by both men and women, and may involve a co-
worker, beneficiaries including children, stakeholders, supervisor, manager. Lack of
intent is no defense in sexual harassment/ sexual exploitation and abuse; cases.

2. Employees or beneficiaries including children, Stakeholders who believe they are the
subject of sexual harassment/ sexual exploitation and abuse; should take firm, positive
and prompt action.

3. For immediate action or reporting on PSEA issues, multiple reporting channels are
available and easily accessible for the staff, volunteers, stakeholders, vendors, and
beneficiaries, including children.

Friendship reporting channels include:

a. Mobile phone number and email address of the PSEA Focal Point displayed in the
PSEA posters displayed in all project offices, Learning Centers, Primary Health Clinics,
schools, communities, plinth, Hospitals and all the working areas of Friendship.

b. Complaint boxes are available in the field offices and all service points of Friendship.

PSEA Reporting Mechanism: Established Friendship reporting mechanism regarding SEA

responses aligned with the core reporting standards of UNICEF PSEA Toolkit:

I. Accessibility:
a. Multiple accessible channels for reporting, such as email address and phone number
of PSEA Focal Point are displayed in the clearly visible safeguarding posters; and
physical drop-boxes for complaint submission are available in all field offices.
Reporting mechanisms are accessible for the beneficiaries in due consideration of the
beneficiaries profile.
b. Reporting options are available in multiple languages.
c. Reporting mechanism is widely publicized and easily accessible to all stakeholders,
including beneficiaries, staff, volunteers, and partners through discussion, training,
parents meeting, religious meetings, community meetings etc.

Date/Month Issued: July 23

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II. Responsiveness:
a. Trained focal points within the organization will receive and respond to reports promptly
and sensitively.
Report any PSEA related matter to the PSEA Focal:
Name: Ms. Manjura Rahman Khan
Designation Assistant Manager – HR and OD
Office Location: Head Office
Email Address: manjura@friendship.ngo
Cell Number: 01944535880

b. As mentioned in PSEA Investigation Management SOP, Friendship management will

follow the law of the country while forming the investigation committee, that is within
30 days of receiving of the allegation or as soon as possible depending on the nature
of the allegation. PSEA Focal will clearly communicate the expected timeframe for
response and investigation to the complainant.

c. As per SOP, the management will assess the allegation and if the allegation needs to
be referred to external bodies i.e., Police, Friendship management will refer
accordingly.

d. As mentioned in SOP, by keeping the Survivor Centered Approach in mind, the

investigation management team through the PSEA focal will communicate with the
survivor whether the survivor needs any support or security (such as Psychosocial
support, Counselling, Safety, Police Support, Medical Support, and any other support).

III. Safety:

Establish procedures to ensure the safety and well-being of survivors, witnesses, and
reporters throughout the reporting process.

a. As per SOP, as soon as Friendship receives SEA complaint, Management will relocate
the alleged immediately from the place of incident to another place or will be sent to
administrative leave, depending on the nature of the allegation.
b. The investigators will conduct the interview with the interviewees as per the set
guidelines in the PSEA toolkit.
c. The investigators before interviewing the survivor will communicate with the
investigation management team/PSEA focal if the survivor wants to sit with the
investigators. If yes, the investigators will ask for a survivor consent form signed by the
survivor from the investigation management team/PSEA focal.
d. Offer information and support services to survivors, including referral pathways to
medical, legal, and psychosocial assistance through the PSEA referral form.
Date/Month Issued: July 23
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IV. Confidentiality:
a. As per SOP, to assure confidentiality to those reporting incidents of SEA and protect
their identity throughout the process, the investigators will ensure the interviewees
related to the investigation must sign the confidentiality agreement.
b. Survivors through the PSEA focal sign a Survivor Consent form to clearly communicate
the confidentiality measures are in place to build trust and encourage reporting.
c. To limit access to information only to individuals directly involved in the response and
investigation, and maintaining strict data protection and security measures, the
investigators will sign the Confidentiality Agreement and share information regarding
the allegation only on a need-to-know basis.

V. Transparency:

a. As per SOP, to ensure clear and transparent procedures for handling reports of SEA,
the management will immediately let the related donors/partners know about the
outcome of the reported allegation through incident reporting template of the PSEA
toolkit, if needed.
b. A copy of the actions (termination, job closing etc.) will be preserved in the Personal
File for future records.

4. On the other hand, if complaint implicate a person of a different organization, then the
report will be sent to that organization’s Focal Point through Friendship Focal Point.
After getting any complaints on sexual exploitation and abuse or sexual harassment,
PSEA Focal Point will report to the Human Resources and Organizational
Development immediately.

5. If the behaviour continues, or if the employee or beneficiaries including children,

stakeholder feels unable to speak to the person(s) directly, they should contact their
supervisor or Manager. Alternatively, an employee or beneficiaries including children
stakeholder may contact the Human Resources & Organizational Development
Department.

6. The Managers/Focal Points will provide support and ascertain the nature of the
complaint and the wishes of the complainant. The manager will take steps to stop any
SEA incident and to make aware of its collaborators if any.

7. Manager/Focal point reports PSEA to HR & OD of Head Office to mitigate a PSEA

case immediately, no matter whatsoever.
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8. If Managers/Focal Points are one of the assaulting sources and involved, immediately
report to Human Resources & Organizational Development.

9. Even a survivor including children assumes any mis-leading judgement to her/him from
local authority, s/he can directly be compliant to the Executive Director of FRIENDSHIP
for her/his justice.

11.2 Informal Intervention

1. The Manager will explain the employee or beneficiaries including children,

Stakeholders’ rights and responsibilities under organisation’s policy, procedures and
Equal Employment Opportunity or anti-discrimination legislation.

2. Where possible, the employee or beneficiaries including children, Stakeholders should

make the perceived harasser(s)/perpetrator aware of that they find their behaviour
offensive, unwelcome, unacceptable, and that it needs to stop immediately.

3. Informal intervention may be undertaken through a process of mediation or

conciliation. During informal intervention the alleged harasser will be made aware of
the allegations being made against them and given the right to respond.

4. If any employee, volunteers, beneficiaries including children, stakeholders, visitor,

vendors etc. observes that someone related to Friendship is violating the PSEA policy
he/she must report to his/her PSEA Focal Point. If the Manager or Focal Point
becomes the perpetrator, then inform the higher authority or Human Resources and
Organizational Development. Then the concerned authority will mediate the SEA
cases between the perpetrator and the survivor if they completely agreed.

5. This procedure will be completed when the complainant/survivor including children and
the respondent/perpetrator come to an agreement on the procedure to be followed. If
this occurs, no record will be made of the proceedings, and any subsequent
proceedings. If this does not occur, formal procedure should be followed.

11.3 Formal Complaints Procedure/Investigation

1. Description of the Process to Decide on the Need for an Investigation:

I. Initial Assessment:
a. The process begins with an initial assessment conducted by the Head of
HR/Safeguarding In Charge/PSEA focal or the assigned investigation team formed by
Date/Month Issued: July 23
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 PSEA Policy
the investigation management team and usually consisting of 2-5 members. This
assessment aims to evaluate the seriousness and credibility of the allegations or
information received regarding a potential violation of PSEA standards by collecting
specific date, time and details of the incident.
b. The Head of HR/Safeguarding In Charge/PSEA focal or investigation team will review
the available information, including any reports, complaints, or concerns raised by staff,
beneficiaries, or other stakeholders. They will consider the nature and details of the
allegations, the potential impact on individuals and the organization, and any
supporting evidence.

II. Consultation and Decision-Making:

a. The Head of HR/Safeguarding In Charge/PSEA focal or investigation team will consult

with relevant stakeholders, including senior management, human resources, legal
advisors, and other relevant departments or individuals, as appropriate.
b. The consultation process involves sharing relevant information, discussing the
potential risks, and considering the available options for responding to the allegations.
The decision to initiate an investigation should be made collectively, considering the
severity and credibility of the allegations, the potential harm caused, and the
organization's duty to protect its beneficiaries and staff.

III. Decision Criteria:

When deciding on the need for an investigation, the following criteria should be considered:

a. Credibility: Assess the credibility of the information received, including the source,
consistency, and supporting evidence.
b. Severity: Evaluate the potential impact of the alleged misconduct on the individuals
affected and the organization.
c. Legal and Policy Compliance: Determine whether the allegations involve a violation
of applicable laws, policies, or codes of conduct.
d. Relevance: Assess whether the allegations are directly related to PSEA concerns,
ensuring they fall within the scope of the investigation procedure.

IV. Documentation and Record-Keeping:

a. All decisions made during the process of deciding on the need for an investigation
should be documented, including the rationale behind the decision.

Date/Month Issued: July 23

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 PSEA Policy
b. A record of the information received, consultations held, and the decision-making
process should be maintained in a confidential and secure manner.

V. Communication and Notification:

a. Once the decision is made to initiate an investigation, relevant stakeholders should be

notified, including senior management, human resources, legal advisors, and other
departments involved in the investigation process.
b. Communication should be handled sensitively and confidentially, with due
consideration for the rights and privacy of all parties involved.

2. HR and OD will form an Investigation Team consisting of 2-5 trained members

including HR & OD, central PSEA Focal Point (assuming trained) and
Programme/Project Focal (if they are trained). There is one Central PSEA Focal Point
from HR & OD and at least one from each project.

3. Investigation will be carried out as per SOP of Investigation Management.

4. The Manager (if trained) /PSEA Focal Point may be obliged to carry out a formal
investigation in relation to a complaint of sexual exploitation and abuse, harassment
etc, upon getting permission from HR and OD or Executive Director.

5. The formal procedure will be managed & coordinated by the Investigation Management
team or HR and OD or Executive Director.

6. Formal investigations may be conducted internally or by an external investigator/a

freelance consultant if HR and OD or the Executive Director permits.

7. An investigation involves collecting information about the complaint and then making
a finding based on the available information as to whether the alleged behaviour
occurred. Once a finding is made, the investigator(s) will make a report about resolving
the complaint. Also, only if Friendship Management thinks so and allowed to inform
the respective Donor/Partner/Associates /PSEA Network, then only the team will keep
respective Donor/Partner/Associates PSEA Network/Donor informed during the
conduct of the investigation without (violating) due process rights of any persons
involved, so that respective Donor/Partner/Associates /PSEA Network/Donor can
determine whether the team has taken appropriate investigative and corrective
actions.

Date/Month Issued: July 23

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8. The investigation team may need to interview the parties involved (which may include
the complainant/survivors, the respondent/perpetrator, and any witnesses) to obtain
information regarding the complaint. The investigator will comprehensively and
accurately document all information obtained during the interviews including the
parties involved, timing, location, and nature of conduct complained against.

9. If the investigation team considers it appropriate for the safe and efficient conduct of
an investigation, workplace participants may be stood down from work or provided with
alternative duties during an investigation in which case they will be paid their normal
pay during any such period.

10. Safety and security of the survivors, witnesses and the respondents should be ensured
by the appropriate authority. If the survivor is a child, then the investigation should be
followed the Child Protection policy and mechanisms.

11. Throughout the investigation process, all parties involved in the investigation will be
regularly kept informed about the investigation.

12. Records are to be kept and filed in a confidential and secure place. If no confidential
area is available, these notes may be sealed and forwarded to the Human Resources
& Organizational Development Department, where they will be maintained, unopened,
in a confidential filing system. These records should be kept for a period of three years.

13. The findings as to whether sexual exploitation, abuse and harassment has occurred
will be determined on the basis of the evidence, and on the balance of probabilities.

14. Based on the findings, possible outcomes of the investigation may include, but will not
be limited to, any combination of the following:

a) Counselling/Psychosocial Support/Psychological First Aid or altogether.

b) Disciplinary action against the harasser/teaser (e.g. demotion, transfer, suspension,
probation or dismissal)
c) Official warnings that are noted in the respondent’s personnel file.
d) Disciplinary action against the person who complained if there is strong evidence that
the complaint was vexatious or malicious.
e) Conciliation/mediation conducted by an impartial third party where the parties to the
complaint agree to a mutually acceptable resolution.
f) Reimbursing any costs associated with the harassment.
g) Re-crediting any leave taken because of the harassment.
h) On completion of the investigation, all parties will be informed about the investigation
findings and the outcome of the investigation.

Date/Month Issued: July 23

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15. Following an investigation concerning a Sexual Exploitation, Abuse, or sexual
harassment complaint (irrespective of the findings), the Manager/Focal Point will:

a) Consult with the parties involved to monitor the situation and their wellbeing.
b) Educate and remind all employees and Stakeholders of their obligations and
responsibilities in relation to providing a workplace free from bullying.

16. Outcomes will depend upon factors such as:

a) The severity and frequency of the incident/harassment related to Sexual Exploitation,

Abuse.
b) The weight of the evidence
c) The wishes of the person who was harassed/abused
d) Whether the harasser/perpetrator could have been expected to know that such
behaviour was a breach of policy
e) The level of contrition
f) Whether there have been any prior incidents or warnings.

17. If the investigation determines that Sexual Exploitation, Abuse or sexual harassment
has occurred, the investigator must forward a summary of the complaint and the action
taken to the Human Resources & Organizational Development Department. A copy
may be placed in the respondent’s personnel file by the Human Resources &
Organizational Development, in accordance with Performance Counselling
procedures.

18. The Manager will monitor the outcome to ensure that the offensive behavior has
ceased, and that neither party has been victimized. This may involve follow-up
interviews.

19. If there has been any substantiated victimization, disciplinary procedures will be
followed. Of course the file will be kept/documented with the highest confidentiality.

20. As mentioned in PSEA Investigation Management SOP, Friendship management will

follow the law of the country, and as per the Bangladesh Labor Law, Clause No. 24(d):
any enquiry shall be concluded within sixty (60) days including forming of investigation
committee.

Date/Month Issued: July 23

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However, tentative timeline of enquiry/investigation is given below:
21.

Sl Activity Description Duration of Remarks

Completion
1 Incident Recording As soon as
receiving
the
complaint
2 Initial Assessment of the 4-5 days Management Sharing and the
Complaint/Incident requirement of investigation
need; however, depending on
the nature of the allegation a
quick assessment will be
completed.
3 Investigation 2 days
Committee/Investigation
Appointment
4 Investigation Plan 4-5 days Depending on the nature of the
case, a quick investigation plan
will be carried out.
5 Risk Assessment 2 days
6 Documents & Evidence Review 5 days Depending on the case, a quick
document review will be carried
out.
7 Confidentiality Notice 1-2 days
8 On-Site Visit 1-2 days Reaching the incident site
9 Conduct Interview 7-8 days Depending on the case, a quick
interview will be carried out.
10 Draft Report 5 days Depending on the case, a quick
report will be prepared.
11 Debriefing 2-3 days
12 Final Report 5 days
13 Management Decision 2-3 days
14 Actions Taken 1 day
15 Remedial Follow-up 2-3 days
16 Donor Reporting 1 day

11.4 Referral Pathways/Procedures for Dealing with Criminal Conduct

Friendship adheres to the principles of a survivor-centric approach, respect victims' rights,

maintain privacy and confidentiality, and ensure that the assistance provided is non-
discriminatory, culturally appropriate, and in line with the best interests of the victim. The
referral pathway should be continuously reviewed and improved to enhance the support
offered to victims while minimizing any potential harm.

1. Referral Pathways:
I. Initial Contact and Assessment:

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a. Provide a dedicated contact number and email address in posters and booklet for
victims to contact the PSEA focal.
b. Trained staff members, i.e., PSEA focal should conduct an initial assessment of the
victim's needs and situation, ensuring a victim-centered and empathetic approach.

II. Safety and Immediate Support:

a. As per SOP, if the victim is in immediate danger, refer them to emergency services or
law enforcement as necessary.
b. Offer immediate support services, such as a safe space, emergency shelter, medical
assistance, or legal aid, depending on the nature of the victim's situation.
c. Ensure that the victim's safety and well-being are always prioritized.

III. Comprehensive Needs Assessment:

a. Conduct a detailed needs assessment through PSEA focal to identify the victim's
specific needs, including medical, psychological, legal, and social needs.
b. Engage with the victim in a sensitive and culturally appropriate manner, considering
their age, disability, and gender, and ensuring non-discrimination.
c. Respect the victim's right to privacy and confidentiality, explaining the limitations of
confidentiality when necessary; victim shall sign the Survivor Consent Form and the
PSEA focal may seek informed consent from the victim before sharing information or
making referrals.
IV. Referral and Coordination:
a. Based on the needs assessment, PSEA focal will develop a personalized referral plan
for the victim.
b. Collaborate with a network of service providers, including healthcare professionals,
legal experts, social workers, counselors, and other relevant stakeholders.
c. Prioritize referrals to organizations and professionals who uphold a victim-centered
and rights-based approach, ensuring their services are accessible to all victims,
regardless of their participation in investigation or accountability procedures.
d. Ensure the referrals are culturally appropriate and sensitive to the victim's background
and experiences.
e. Maintain regular communication with the referred organizations to track the progress
of the victim's case and ensure a coordinated and holistic response.

V. Follow-up and Support:

a. Provide ongoing support to the victim throughout the referral process and beyond.
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b. Conduct follow-up assessments to monitor the effectiveness of the provided services
and address any emerging needs.
c. Offer psychosocial support, counseling, or support groups to assist victims in their
recovery and empowerment.

VI. Monitoring and Evaluation:

a. Collect feedback from victims about their experiences with the referral process and
services received.
b. Regularly review the pathway to identify areas for improvement and incorporate
lessons learned.

2. Some forms of severe exploitation, abuse and or sexual harassment (e.g. sexual
assault, stalking, indecent exposure, physical molestation, obscene phone calls) may
constitute criminal conduct.

3. While Friendship is committed to treat most of the exploitation, abuse and or sexual
harassment complaints at Organizational level as far as possible, but this type (above
point) of conduct is not suited to internal resolution. Such complaints should be treated
by the criminal justice system and the maximum processing time for referral where
applicable & required to the appropriate authority will be as soon as reasonably
possible.

4. In relation to alleged criminal offences such as rape or sexual assault, the matter must
be immediately referred to the Human Resources & Organizational Development.
Employees/ or beneficiaries including children, Stakeholders should be advised of the
option of police support or intervention. It is not the obligation or duty of Friendship to
report such matters to the police on behalf of the complainant/survivor, beneficiaries
including children.

5. The survivor will be referred for professional assistance, if needed.

12. Awareness Raising Plan

1. Objective:

The objective is to raise awareness and promote the prevention and response to Sexual
Exploitation and Abuse (SEA) within Friendship, in line with the principles outlined in the PSEA

Date/Month Issued: July 23

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 PSEA Policy
toolkit. By implementing this plan, Friendship aims to create a safe environment for
beneficiaries, staff members, and partners.

2. Target Audience:

a. Beneficiaries (children, women, vulnerable populations)

b. Staff members (including all levels of management and field staff)
c. Local partners and stakeholders

3. Strategies and Activities:

3.1 Develop and Adapt Policies:

a. Review and update existing PSEA policy, ensuring it is aligned with the PSEA toolkit.
b. Develop an easily understandable version of the policy, i.e., safeguarding booklet.
c. Translate safeguarding booklet and other safeguarding policies including PSEA into
multiple languages as necessary to ensure comprehension and accessibility, i.e.,
Bangla, English & Burmese languages.

3.2 Training and Capacity Building:

a. From recruitment to onboarding through job advertisement, written & viva interviews
to reference verification and orientation of new staff, induct new staff on safeguarding
policies including PSEA.
b. Conduct mandatory SEA prevention and response training for all staff members,
focusing on awareness, identification, reporting, and response protocols, at least once
a year.
c. Deliver training to beneficiaries, empowering them to recognize and report SEA, and
inform them about available support services through safeguarding taskforce.

3.3 Communication and Awareness Campaigns:

a. Utilize various communication channels, including posters, websites, and social media,
to disseminate key messages, reporting mechanisms, and support services.
b. Facilitate dialogue sessions with beneficiaries to foster open discussions on SEA-
related issues and reinforce prevention measures through CHW visits and FDMC
Meeting.

Date/Month Issued: July 23

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 PSEA Policy
3.4 Reporting Mechanisms and Support Services:

a. Establish accessible and confidential reporting mechanisms, including direct calls to

PSEA Focal, email, and complaint boxes, ensuring that beneficiaries and staff feel safe
to report incidents.
b. Publicize reporting mechanisms within the organization and among beneficiaries
through posters, emphasizing protection measures against retaliation.
c. Keeping the service provider list updated to strengthen referral pathways through
PSEA referral form to ensure survivors receive appropriate and timely support services
from relevant professional bodies, organizations and or authorities.

3.5 Monitoring, Evaluation, and Learning:

a. Regularly collect data from safeguarding taskforce on reported incidents, response

rates, and the impact of awareness campaigns to ensure ongoing improvements.
b. Incorporate lessons learned from previous incidents and feedback into capacity-
building initiatives and policy revisions.

4. Timeline:

Implementing the PSEA awareness-raising plan is an ongoing process. Regular review and
updates from the taskforce are necessary to ensure its continued effectiveness.

5. Budget:

Allocate sufficient resources to support training, communication materials, awareness

campaigns, reporting mechanisms, and support services.

Date/Month Issued: July 23

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 PSEA Policy
13. Action Plan

SL# Actions Status Remarks

1. Policy in place with the required information and details In Practice and available
2. Community based compliant Mechanism as well as In Practice and available
Procedures to file compliant & reporting
3. Raising Awareness, communication, and dissemination of In Practice and available
information through emails, notice board, regular training, and
regular meetings at community level
4. Background Checks before officering employment or In Practice and available
partnership or contract.
5. Face to face Training Program including other Safeguarding In Practice and available
Policies.
6. Separate Chapter in Friendship Human Resources Policies In Practice and available
and Procedures
7. Separate Clause in Friendship High Level Code of Conduct In Practice and available
8. Separate Clause in Appointment and Contract Letter In Practice and available
9. Specific clause in Recruitment Policy In Practice and available
10. Specific Safeguarding clause in all Job Advertisement where In Practice and available
PSEA matter is mentioned
11. Specific Safeguarding clause in Interview Rating Sheet where In Practice and available
PSEA matter is mentioned
12. Specific question both in written & viva on Safeguarding where In Practice and available
PSEA matter is mentioned
13. Training Module on PSEA In Practice and available
14. Maintaining Incident Database and Register In Practice and available
15. Train and aware respective (as applicable), Available and in practice
from May 22
Teachers/Facilitators, Community recruited ones,
volunteers/interns, Community Caretaker, Animal Health
Worker (Para Vet), Para Solar Technician, Flood Volunteer,
Friendship Community Medic-aide (FCM), Inclusive Citizenship
Community Staff, Vendors of both Admin & Procurement and
anyone related to that sector & csu work on Safeguarding
Policies and how to report Safeguarding incident if they are
victim of safeguarding by them
16. It is advised to the respective Sector/CSU to educate their Available and in practice
from May 22
respective visitors (as applicable) – foreign guest, donors,
partners, visiting doctor/medical teams, journalist, media
personnel, vendors or their hired ones & representatives who

Date/Month Issued: July 23

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 PSEA Policy
will be visiting Friendship working areas to perform any work for
Friendship, on Safeguarding Policies and reporting mechanism.
17. Ensure that all the Friendship project’s RISK in terms of Available and in practice
from May 22
Safeguarding issues are analyzed by the respective sector
quarterly – share the record/evidence with HR
18. All the line managers held responsible to act as Role Model and Available and in practice
from May 22
discuss the Safeguarding Policies & its reporting mechanism
with their staff at least once in a month and keep the record of
the meeting/sessions for quarterly sharing with HR
19. Translated into Bangla In Practice and available
20. Discussion of Safeguarding Matters where PSEA matter Available and in practice
from next meeting
mentioned in Leadership Meeting as well as EC Board meeting.
21. New joiners are inducted on Safeguarding Policies where PSEA In Practice and available
matter mentioned within the 30 days of the date of join.
22. PSEA Poster In practice and available
23. Name : Ms. Manjura
Rahman Khan, Lead
Designation: Senior
Executive – HR and OD
Office Location : Head
Office
Email Address :
manjura@friendship.ngo
Cell Number : 01944535880

Name: Anwarul Amin,

PSEA Committee
Member
Designation: Assistant
Director and Head of Internal
Audit
Office Location: Head Office
Email Address:
anwarulamin@friendship.ngo
Cell Number:01711173243

Name: Babita Rani Das,

Member
Designation: Senior Program
Specialist, Health
Email Address:
babita@friendship.ngo
Cell Number:01716426655
Vetting
a. procedures before signing agreement with all In Practice and available
Friendship’s collaborators/stakeholders/partners. – PSAE
Clause added in the agreement.
24. Focal Person Name : Ms. Manjura
Rahman Khan
Designation: Senior
Executive – HR and OD

Date/Month Issued: July 23

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 PSEA Policy
Office Location : Head
Office
Email Address :
manjura@friendship.ngo
Cell Number : 01944535880
25. Dedicated Email Address to send compliant In Practice and available
26. Complaint Box in all Friendship Working Areas In Practice and available
27. Strong Reporting system by maintaining the proper In Practice and available
confidentiality through Compliant and Feedback Management
Policy
28. Participatory Community Reporting/Complaint Mechanism In Practice and available
29. Code of Conduct – Behavior with Community and In Practice and available
Beneficiaries
30. Whistler Blower Policy to ensure the proper reporting In Practice and available
31. Child Protection Policy ensure the proper implementation of In Practice and available
this policy
32. Separate program run by Health Sector on “GVB & PSEA” In Practice and available
33. Performance Management of the Staffs with a separate In Practice and available
dimension called “Contribution to Friendship”
___________________________________________________________________

Date/Month Issued: July 23

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