Scope & Purpose
This policy applies to all Keepers Zambia Foundation employees and related personnel both during and outside normal working hours. Keepers Zambia Foundation policy will apply where it is more stringent than local legislation. This policy sets out Keepers Zambia Foundation's approach to preventing and addressing sexual exploitation, abuse and harassment. This includes:
- Our commitments to prevent sexual exploitation, abuse and harassment and to ensure effective action is taken when problems occur;
- Principles upon which we will base our decision making and actions; and
- Our expectations of all those who work on behalf of Keepers Zambia Foundation.
Policy Statement
Keepers Zambia Foundation has a zero-tolerance policy towards inaction against sexual harassment, exploitation, and abuse. We believe all people have a right to live their lives free from sexual violence and any abuse of power regardless of age, gender, sexuality, sexual orientation, disability, religion or ethnic origin.
We recognise that there are unequal power dynamics across the organisation and in relation to those we serve, and that some people may exploit their position of power for personal gain. Keepers Zambia Foundation will not tolerate its employees, volunteers, consultants, partners or any other representative associated with the delivery of its work carrying out any form of sexual harassment, sexual exploitation or sexual abuse. Keepers Zambia Foundation commits to supporting survivors, improving safeguarding capacity, reporting, investigating, responding to, and preventing sexual harassment and sexual exploitation and abuse.
Keepers Zambia Foundation will use this policy in conjunction with relevant policies to make decisions about how to respond to any complaints and concerns raised. This policy covers sexual harassment as well as sexual exploitation and abuse. This policy does not form part of an employee's terms and conditions of employment and may be subject to change at the discretion of management.
KZF Principles and Commitments
KZF is committed to achieving full, ongoing implementation of the Six Core Principles relating to Sexual Exploitation and Abuse.
KZF's Core Principles
- Sexual exploitation and abuse by KZF employees and related personnel constitute acts of gross misconduct and are, therefore, grounds for termination of employment or contract/agreement. Sexual harassment by KZF employees and related personnel is grounds for disciplinary action up to and including dismissal.
- 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 in the age of the child is not an excuse.
- Exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour by KZF employees and related personnel, is prohibited at all times. This includes buying sex or the exchange of assistance that is due to programme participants.
- Sexual relationships between KZF employees or related personnel and community members we work with are forbidden. Given the contexts where KZF operates, such relationships may be based on inherently unequal power dynamics and may undermine the credibility and integrity of KZF's development work. KZF employees and related personnel must declare any previously existing relationships with community members we work with to their line managers or HR.
- Where a KZF employee or related personnel member develops concerns or suspicions regarding sexual abuse, exploitation or harassment by a fellow worker, whether in KZF or not, they must immediately report such concerns via the established reporting mechanisms.
- KZF employees and related personnel are obliged to create and maintain an environment that prevents sexual exploitation, abuse and harassment and any form of child abuse, and promotes the implementation of this policy. KZF managers at all levels have particular responsibilities to support and develop systems which maintain this environment.
Keepers Zambia Foundation's Commitments
Safe, Respectful and Inclusive Organisational Culture
KZF will make every effort to create and maintain a safe, equitable, and inclusive organisational culture where all those who work for and with KZF, as well as those in the communities where KZF operates, are treated with dignity and their rights and voices are heard and respected. This entails applying KZF's gender justice and feminist working principles, including power sharing. This will provide opportunities to discuss and reflect on emerging themes with a diverse pool of stakeholders (“nothing about us without us”), leading to robust prevention and response work, support for survivors, and accountability for those responsible for sexual exploitation, abuse or harassment.
Reporting Sexual Exploitation, Abuse and Sexual Harassment
- Ensure that we have multiple channels for KZF employees, related personnel, community members we work with, and others to safely report sexual exploitation, abuse and sexual harassment. These channels should be designed in consultation with local communities and staff to ensure that they are safe and accessible.
- Ensure that everyone who works on behalf of KZF and those we serve have information about how to access these safe reporting channels, including messaging suitable for children and people of other diversities. This should include posting reporting procedures in local languages and regularly explaining these channels.
- Provide training and information to all KZF employees and related personnel, particularly focal points for receiving complaints, so they understand their obligations and how to discharge their duties should they receive a complaint. Particular emphasis should be made on confidentiality.
- Abide by the external reporting requirement of the Standard Operating Procedure for Misconduct Reporting. Only staff with delegated authority can report to external donor and regulatory authorities. Survivors and victims have the right to report directly to regulatory authorities within their countries.
Responding to SEAH Reports
KZF will respond in a professional and timely manner to all concerns or allegations of sexual exploitation, abuse or harassment. All concerns or allegations will always be taken seriously, and investigated and acted upon where appropriate, in line with the safeguarding principles below.
Survivor-Centred Approach
A survivor-centred approach creates a supportive environment in which the survivor's rights and wishes are respected and prioritised, their safety is ensured, and they are treated with dignity and respect.
A survivor-centred approach is based on the following guiding principles:
- Safety: The safety and security of the survivor and their children is the primary consideration.
- Confidentiality: Survivors have the right to choose to whom they will or will not tell their story, and information should only be shared with the informed consent of the survivor. An imminent threat of harm to a child or someone else may override confidentiality.
- Respect: All actions taken should be guided by respect for the choices, wishes, rights and dignity of the survivor. The role of safeguarding teams is to facilitate recovery and provide resources to aid the survivor.
- Non-discrimination: Survivors should receive equal and fair treatment regardless of age, gender, race, religion, nationality, ethnicity, sexual orientation or any other characteristic.
Robust and Accountable Case Management
All allegations of SEAH, and subsequent follow-up, will be documented in a secure and confidential database to ensure accountability. The report will be officially acknowledged within 24 hours, and a safeguarding team will convene a case conference to assess immediate risks and next steps within 72 hours.
Investigations
KZF carries out independent, safe, and discreet investigations through trained investigators working with KZF safeguarding teams, recognising the rights of and duty of care to everyone involved, including the complainant and/or survivor, witnesses and subject of complaint (SoC).
Accountable Decision Making
KZF will take swift and appropriate action against KZF employees and related personnel found to have committed SEAH. This may include administrative or disciplinary action, and/or referral to the relevant local authorities if appropriate and safe to do so. An independent and gender-representative decision panel will be assigned in every investigation to ensure impartiality, transparency, and accountability. The decision-making process will be subject to scrutiny by the safeguarding team.
Survivor Support
Survivors of SEAH are entitled to specialised support services. KZF commits to refer survivors to competent support services as appropriate and available, and according to the survivor's wants and needs. Support may include specialist psychosocial support such as counselling, medical assistance, legal counselling and access to KZF's Employee Assistance Programmes where available. Assistance will be made available regardless of whether a formal internal response, such as an internal investigation, is carried out.
Embedding SEAH into KZF Work
Safer Recruitment
In compliance with applicable laws, KZF is committed to preventing perpetrators of SEAH from being hired, rehired or redeployed. Managers and Human Resource teams will ensure robust recruitment screening processes for all personnel, including employees, volunteers, consultants and other representatives. All application forms, interviews and references must address safeguarding and equality requirements and attitudes.
Safe Partnership Agreements
When engaging in partnerships, sub-grant or sub-recipient agreements, KZF will incorporate this policy as an attachment; require contracting entities, individuals, employees and volunteers to abide by a Code of Conduct consistent with this policy; and expressly state that failure to prevent, investigate, report or correct SEAH is grounds for KZF to terminate the agreement. KZF will assess partner capacity, including existing safeguarding policies, procedures and training, and provide capacity building and support as part of entering into a new partnership where these are not in place.
Staff and Partner Training
KZF employees and related personnel must receive PSEAH and safeguarding training as part of their induction, including a briefing on KZF's policies and values, the Code of Conduct, how to report concerns, and where to seek further information about safeguarding and safer practices. Anyone working directly with community members on behalf of KZF must receive additional training on how to receive complaints and handle them safely and confidentially.
Accountability to Communities
KZF will be accountable to the communities it serves by providing clarity about programming activities and services they are entitled to; raising awareness about KZF's Code of Conduct, safeguarding policies and reporting channels; actively seeking feedback on KZF's work, individual behaviours and complaints; and presenting feedback to communities on changes made as a result of community feedback, ideally by a senior KZF representative. These steps should occur regularly throughout the lifecycle of the programme or activity.
Safe Programming
Employees and related personnel are required to take proactive measures to avoid causing inadvertent harm to civilians, actively reduce existing threats, and ensure programmes are conflict sensitive. This includes embedding good practice and SEAH prevention measures throughout the programme and project cycle, including project design, grant proposals, assessments, complaints and feedback mechanisms, and monitoring and evaluation.
Roles and Responsibilities
All KZF Employees and Related Personnel
Everyone who works on behalf of KZF is required to report suspicions or incidences of SEAH involving others. Failure to report a suspicion of SEAH relating to someone else is a breach of KZF policy and could lead to disciplinary action against employees and termination of KZF's relationship with non-employees. There is no obligation for an individual to report an incident that happened to them.
Directors and Trustees
Directors and trustees hold overall accountability for this policy and its implementation.
Executive Director
The Executive Director is responsible for the application of this policy.
Gender Focal Person
The Gender Focal Person provides support to prevent and respond to SEAH alongside their substantive role, raises awareness, conducts training and promotes best practices, receives concerns, supports survivors, reports concerns confidentially, and conducts referrals to specialised services.
Teams, Advisors and Senior Management
Teams, advisors and senior management should offer further support to help implement this policy.
Programme Teams
Programme teams will consult communities in a safe, accessible and culturally appropriate way to ensure that community members and those working on behalf of KZF are familiar with KZF's Code of Conduct, how to raise complaints and concerns, and that KZF will take action. Programme teams should also clearly explain what goods and/or services community members are entitled to and how they are selected.