Table of Contents
Girls Alive Uganda commits to a zero-tolerance policy towards sexual exploitation and abuse (SEA) and considers any such acts a gross misconduct and grounds for dismissal. Girls Alive Uganda recognizes the unequal power dynamics inherent in the education system and community work and our responsibility to protect the human rights of the communities we serve and provide an environment free of sexual exploitation and abuse.
This policy applies to all employees, volunteers and other related personnel of Girls Alive Uganda working with project beneficiaries. This policy also affirms Girls Alive Uganda’s commitment to the welfare of its project beneficiaries and to a survivor-centered approach.
Any complaints related to SEA will be treated with the utmost confidentiality within the power of the organization. Settling of the complaint will lean toward removing the alleged aggressor rather than the survivor. The survivor’s informed consent will be secured before commencing each new step of the response procedures for the reported SEA incident. The survivor may withdraw the complaint or decide to halt further actions at any time, provided it is still within Girls Alive Uganda’s power to comply and the matter has not yet been referred to police.
All complaints of sexual exploitation and abuse will be investigated and disciplinary sanctions up to and including termination of employment/contract will be applied. Any proven false accusations of SEA will be deemed to constitute a violation of this Policy and Code of Conduct and disciplinary sanctions will be applied, as appropriate.
This Protection from Sexual Exploitation and Abuse Policy (December 2020) replaces all and any previous Girls Alive Uganda policies on Sexual Assault, Harassment and Exploitation.
This PSEA Policy and accompanying Code of Conduct are based on:
- The Statement of Commitment on Eliminating Sexual Exploitation and Abuse by UN and Non-UN Personnel, August 2008.
- The IASC Six Core Principles Relating to Sexual Exploitation and Abuse, June 2002.
A. Scope of Application
This PSEA Policy and Code of Conduct applies to all Girls Alive Uganda employees, volunteers and other related personnel in their conduct with Girls Alive Uganda project beneficiaries. For the purpose of this Policy, the term “Employees, Volunteers and other related Personnel” (EVP) includes: all employees of Girls Alive Uganda at headquarter offices and country offices; Directors and Officers; national and international staff; national and international volunteers; national and international interns; and national and international consultants, in addition to individual and corporate contractors of these entities and their related personnel. The term also includes all Girls Alive Uganda affiliated entities and their employees and individuals who have entered into partnership, sub-grant or sub-recipient agreements, and are operating under the umbrella of Girls Alive Uganda programs.
Sexual harassment or abuse incidents taking place among project beneficiaries are not within the scope of application of this Policy nor its Code of Conduct. For such incidents, Girls Alive Uganda may assist the beneficiary by referring him/her to pre-identified local service providers.
B. Code of Conduct
- Girls Alive Uganda has zero-tolerance towards all forms of sexual misconduct. Engagement in any such activities by Girls Alive Uganda employees, volunteers and other related personnel as well as their respective affiliated entities, will be considered an act of gross misconduct and constitutes grounds for disciplinary sanctions up to and including termination of the employment or collaboration agreement.
- Sexual activities with children (persons under the age of 18) or vulnerable adults are strictly prohibited regardless of the local age of consent or local recognition of the status of a vulnerable adult. Ignorance or mistaken belief in the age of the child or the status of the vulnerable adult is not a defense.
- Exchange of money, employment, goods or services for sex, including sexual favors or other forms of humiliating, degrading or exploitative behavior is prohibited. This includes the exchange for services to which program participants are entitled.
- Sexual relationships of Girls Alive Uganda employees, volunteers and other related personnel and their respective affiliated entities with direct and indirect project beneficiaries, including all persons receiving services or assistance from Girls Alive Uganda or its programs, are prohibited since they are based on inherently unequal power dynamics. Such relationships undermine the credibility and integrity of Girls Alive Uganda operations and genuine development program efforts.
- If any Girls Alive Uganda employees, volunteers and other related personnel or their respective affiliated entities have concerns or suspicions regarding a possibility of SEA by another employee, volunteer or other related personnel, s/he must report such concerns via Girls Alive Uganda established reporting channels or as a whistleblower.
- Girls Alive Uganda employees, volunteers and other related personnel and their respective affiliated entities are obliged to make every reasonable effort to ensure and maintain an environment free of SEA and promote the implementation of this Policy.
- Girls Alive Uganda Directors and Leads at all levels have particular responsibilities to support and develop systems that sustain such an environment.
1. The code of conduct is based on the six Core Principles of the UN Secretary-General’s Bulletin (ST/SGB/2003/13).
2.Vulnerable adults are defined as: those aged over 18 years and who identify themselves as unable to take care of themselves/protect themselves from harm or exploitation; or who, due to their gender, mental or physical health, disability, ethnicity, religious identity, sexual orientation, economic or social status, are deemed to be at risk.
3. Local and national laws of the country where YCI programs are implemented.
4. This could include use of background and criminal reference/record checks, verbal referee checks, and interview plans that incorporate behavioral-based interview questions.
C. Girls Alive Uganda Management Commitments
Girls Alive Uganda is dedicated to enforcing and observing this PSEA Policy by way of the following commitments to:
- Foster a positive work environment in which sexual harassment, exploitation or abuse by individuals or groups does not occur; and to lead by example.
- Develop country level strategies to prevent and respond to SEA.
- Incorporate the PSEA Policy and Code of Conduct into onboarding materials and training for all Girls Alive Uganda employees, volunteers and other related personnel, as well as in other relevant organizational Codes of Conduct.
- Incorporate appropriate job responsibilities in designated PSEA Focal Points’ terms of reference to support and ensure effective implementation of the PSEA Policy.
- Ensure that all individual contracts of Girls Alive Uganda employees, volunteers and other related personnel working on international programs are annexed with this Policy, Code of Conduct and Commitments.
- In compliance with applicable laws, make reasonable effort to prevent perpetrators of SEA from being rehired or redeployed. Directors, Project Leads and Human Resources Personnel must ensure robust recruitment screening processes according to best practices for all Girls Alive Uganda employees, volunteers and other related personnel, particularly for those who will have any direct or indirect contact with children and/or vulnerable adults.
- Establish and safeguard accessible complaint mechanisms for reporting SEA by Girls Alive Uganda employees, volunteers and other related personnel and Girls Alive Uganda project beneficiaries.
- Provide training for SEA Focal Points who receive complaints to ensure they understand how to handle and refer such cases.
- Make available a whistleblower channel for Girls Alive Uganda employees, volunteers and other related personnel that guarantees protection from retaliation, and for those who wish to report anonymously.
- To the best of Girls Alive Uganda’s ability, take appropriate action to protect SEA survivors from retaliation when allegations of SEA are made.
- Investigate allegations of SEA involving Girls Alive Uganda employees, volunteers and other related personnel in a timely and professional manner.
- Treat all incidents of SEA with the utmost confidentiality and share related information only on a need to know basis.
- Take swift and appropriate actions against Girls Alive Uganda employees, volunteers and other related personnel who are alleged to have committed acts of SEA.
- Provide basic referral support to help SEA survivors access relevant community-based services, including medical and psycho-social support.
- Create and sustain mechanisms to systematically inform Girls Alive Uganda employees, volunteers, other related personnel and project beneficiaries on measures taken to prevent and respond to SEA.
- Integrate SEA prevention and response mechanisms into country operation plans and allocate a budget towards those activities.
- Assess all Girls Alive Uganda affiliated entities’ PSEA Policy and Code of Conduct. If not already in existence, or not according to appropriate standards, encourage them and provide support to adopt and adhere to this PSEA Policy and Code of Conduct, indicating that failure to respond to reported SEA incidents may constitute grounds for administrative actions up to and including termination of the agreement/contract.
- Encourage Girls Alive Uganda affiliated entities to develop and institutionalize minimum operating standards for SEA prevention within their respective organization and to mainstream it across their work.
- Ensure high level oversight and information systems on SEA reports received and actions taken in order to monitor effectiveness, report progress and improve efforts to prevent and respond to SEA.
D. Commitments of Girls Alive Uganda Employees, Volunteers and other related Personnel
Since the relationship between development workers and beneficiaries of development programs is inherently unequal in terms of power relations and levels of authority, all Girls Alive Uganda employees, volunteers and other related personnel must be vigilant and rigorously avoid any action (suggested, implied or perceived) that would suggest or imply that a sexual act might be demanded as a condition for engaging in offered programs and services. Actions of such nature are at odds with the objectives of Girls Alive Uganda, which is to support and empower vulnerable girls and women in rural communities. As such, violation of this Policy and Code of Conduct undermines the credibility and integrity of Girls Alive Uganda.
All Girls Alive Uganda employees, volunteers and other related personnel must familiarize themselves with this Policy and Code of Conduct and are required to uphold it, put it into action, and understand that Girls Alive Uganda has zero tolerance towards such gross misconduct.
All Girls Alive Uganda Employees, Volunteers and other related Personnel must adhere to the following expectations:
- Commit to create and maintain an environment free from sexual abuse, harassment and exploitation at all times.
- Refrain from requesting any sexual services or sexual favors from direct or indirect project beneficiaries of Girls Alive Uganda, in return for Girls Alive Uganda services.
- Refrain from engaging in any exploitative sexual relationships, including but not limited to sexual favours; exchange of money, employment, goods or services for sex; or any other forms of humiliating, degrading or exploitative behavior.
- Refrain from pursuing services from sex workers at all times while operating under the umbrella of Girls Alive Uganda, regardless of the local and national laws of the project country.
- Refrain from any form of sexual activity with direct and indirect Girls Alive Uganda project beneficiaries because of the inherent conflict of interest and potential for abuse of power in such a relationship.
- Refrain from any active or passive sexual activities with a person under the age of 18, or a vulnerable adult – including voyeurism; consuming, producing or distributing child pornography; or child trafficking – regardless of the national and local laws of the country in which Girls Alive Uganda is operating. Obliviousness or mistaken belief of the child’s age, or the status of the vulnerable adult is not a defense.
- Report any concerns or suspicions regarding possible violations of this Policy and Code of Conduct by Girls Alive Uganda employees, volunteers or other related personnel or their respective affiliated entities’ employees and related personnel via established Girls Alive Uganda reporting channels or as a whistleblower.
- Treat any information related to incidents of sexual abuse, harassment or exploitation with utmost confidentiality and share related information only on a need to know basis, i.e. only with designated relevant parties.
E. Policy Accountability
Directors, Project Leads, PSEA Focal Points and Human Resources personnel bear added responsibility and have a key role to play:
- Ensure that all Girls Alive Uganda employees, volunteers and other related personnel are informed of this Policy and Code of Conduct, understand it, sign it and adhere to it.
- Project Leads and Human Resources personnel are responsible for robust recruitment, onboarding and training in accordance with the Code of Conduct and Commitments.
- Directors and Project Leads are responsible for performance management to mitigate against the occurrence of sexual abuse, harassment and exploitation, including taking corrective action if and when needed.
- Focal Points will ensure that all project beneficiaries are aware of SEA complaint mechanisms and will receive and process all SEA complaints.
- Management are responsible for ensuring investigations are conducted for all credible SEA allegations.
- Management will review the implementation of the PSEA Policy on an annual basis. This includes time-bound, measurable indicators to assess the appropriateness of the SEA Policy, Code of Conduct and Procedures.
The code of conduct is based on the six Core Principles of the UN Secretary-General’s Bulletin (ST/SGB/2003/13)
5. Quantitative indicators can include: number of reported SEA incidents; number of investigated cases, number of survivor/s who received assistance, etc. Qualitative indicators could include: elements evoking an unsafe-work environment which resulted in a SEA incident and recommendation for system improvements, reasons for forging a SEA claim, etc.