Of the Prevention of Sexual Exploitation and Abuse
of the Non-Governmental Organisation “Ukrainian Security and Cooperation Centre”
1.1. This Policy on the Prevention of Sexual Exploitation and Abuse (hereinafter referred to as the SEA Policy) sets out the principles, standards, rules and procedures for the prevention, detection, reporting, investigating and responding to cases of sexual exploitation, sexual abuse and sexual harassment within the non-governmental organisation “Ukrainian Security and Cooperation Centre” (hereinafter referred to as the Organisation).
1.2. The Policy has been developed in accordance with the Constitution of Ukraine, the Criminal Code of Ukraine, the laws of Ukraine, as well as the international standards of the United Nations and the Inter-Agency Standing Committee (IASC) on protection against sexual exploitation and abuse.
1.3. The Policy applies to members of the Organisation, members of the General Assembly, members of the Board, the Chair of the Board, staff, volunteers, partners, donors, external experts and consultants, contractors, beneficiaries and any other persons acting on behalf of or in the interests of the Organisation.
1.4. The Organisation applies a policy of zero tolerance towards any form of sexual exploitation, sexual abuse and sexual harassment.
1.5. The purpose of the Policy is:
preventing sexual exploitation and abuse;
creating a safe environment for beneficiaries, staff and other stakeholders;
ensuring effective, accessible and safe reporting mechanisms;
properly investigating incidents;
protecting the rights, safety and dignity of victims.
1.6. The SEA Policy applies during working hours and outside working hours, during business trips, travel, training sessions, events, and during any type of leave (annual leave, sick leave, parental leave, etc.).
1.7. The SEA Policy applies both within the Organisation’s premises and outside them, provided that the conduct is related to the Organisation’s activities or may affect its reputation, the safety of beneficiaries or persons involved.
1.8. Key principles of the SEA Policy:
Safe environment — All persons involved in the Organisation’s activities are required to create and maintain an environment free from sexual exploitation and abuse.
Children are protected — Any sexual conduct involving children (persons under the age of 18) is strictly prohibited.
Colleagues are protected — Any exchange of sexual favours for money, work, positions, goods or services, including the hiring of sex workers, is prohibited.
Beneficiaries are protected — It is prohibited to abuse power, influence or authority for the purpose of engaging in sexual relations with beneficiaries.
Duty to report — Every person involved in the Organisation’s activities is obliged to report any suspicions or known instances of sexual exploitation and abuse.
Zero tolerance — Sexual exploitation and abuse are serious violations and may constitute grounds for immediate termination of cooperation.
1.9. This list of principles is not exclusive. Other forms of unacceptable behaviour relating to sexual exploitation or harassment may also constitute grounds for disciplinary action.
1.10. Overall supervision of the implementation of the SEA Policy is exercised by the Chair of the Board, whilst direct coordination is carried out by the SEA Officer appointed by a decision of the Board.
1.11. The SEA Policy is reviewed at least once every three years or in the event of changes to legislation or international standards.
2.1. In this Policy, the following terms are used with the following meanings:
Sexual exploitation — any abuse of a vulnerable position, power or trust for sexual purposes, including the receipt of material or non-material benefits in exchange for sexual acts.
Sexual abuse — any act of a sexual nature without voluntary consent, involving the use of force, threats or taking place in a situation of inequality.
Sexual harassment — unwanted conduct of a sexual nature that violates a person’s dignity or creates a hostile, humiliating or threatening environment.
A child — any person under the age of 18.
A victim — a person who has suffered or may have suffered sexual exploitation or abuse.
The SEA Officer — a person appointed by a decision of the Board, responsible for receiving reports and coordinating the response.
3.1. The organisation carries out appropriate background checks on staff, volunteers and partners within the limits permitted by Ukrainian law.
3.2. The organisation does not involve in its activities any persons who:
are registered with a mental health or addiction treatment centre;
have been dismissed from previous jobs due to unethical behaviour towards service users or colleagues.
3.3. Should any of the circumstances set out in clause 3.2 come to light during the course of cooperation, the Organisation shall terminate its relationship with the person concerned.
3.4. All persons involved are required to undergo training on the SEA Policy and to sign a written informed consent form undertaking to comply with it (Appendix 1).
3.5. The Organisation regularly conducts training and awareness-raising activities on the prevention of sexual exploitation and abuse.
4.1. Any person, including an employee, volunteer, beneficiary, partner or witness, may report a suspected incident of sexual harassment.
4.2. The form set out in Annex 2 to this Policy may be used for reporting.
4.3. The reporting channels are:
the Organisation’s email address;
a verbal or written application submitted to the Chair of the Board or to the person authorised to deal with SEA matters.
4.4. Reports may be made anonymously.
4.5. Any form of retaliation or adverse consequences against a person who has reported an incident in good faith is prohibited.
5.1. The designated SEA officer carries out an initial assessment of the report within three working days.
5.2. The initial assessment includes:
assessment of the risks to the victim;
verification of the adequacy of the information;
decision on whether to launch an investigation.
5.3. In the event of reasonable suspicion, the authorised person shall notify the Chair of the Board, who shall initiate the formation of an Investigation Committee comprising at least three members.
5.4. The Commission shall conduct the investigation in accordance with the principles of confidentiality, impartiality and respect for the rights of the parties.
5.5. The investigation shall not exceed 30 calendar days.
5.6. A written report containing recommendations shall be drawn up based on the results of the investigation (Appendix 3).
6.1. If a breach is confirmed, the Organisation shall implement appropriate response measures, including:
dismissal from employment;
termination of contracts;
dissolution of a partnership;
reporting to the police.
6.2. If an incident appears to constitute a criminal offence, the Organisation shall notify the law enforcement authorities.
6.3. In cases involving children, notification of the law enforcement authorities is mandatory and must be made without delay.
6.4. It is prohibited to impose any sanctions on persons who have in good faith reported a SEA or refused to participate in such activities.
7.1. The organisation ensures that victims have access to information regarding psychological, medical and legal support.
7.2. All measures are carried out on the basis of informed consent and with respect for the dignity of the victim.
I, ____________________________________________ (full name), position / role within the Organisation ____________________________________, hereby confirm that I:
have read the Policy on the Prevention of Sexual Exploitation and Abuse (SEA);
understand the principles of zero tolerance for sexual exploitation and abuse;
undertake to comply with the provisions of the SEA Policy in the course of any activities connected with the Organisation;
am aware of my obligation to promptly report any facts known to me or any suspicions regarding violations of the SEA Policy;
have been informed that a breach of the SEA Policy may give grounds for disciplinary, civil or criminal liability.
Signature: ______________________ Date: _______________
1. Date of notification: __________________________
2. Method of submission: □ verbal □ written □ digitally □ anonymously
3. Does the applicant wish to remain anonymous?: □ yes □ no
4. Description of the incident / suspicion (location, date, circumstances): __________________________________________________________________
5. Details of the victim (if available): __________________________________________________________________
6. Details of the suspected offender (if available): __________________________________________________________________
7. Is there an immediate threat to safety?: □ yes □ no
The Investigation Committee, comprising: ________________________________, having reviewed the findings of the internal investigation into a possible breach of the SEA Policy,
DETERMINED: (summary of the established facts)
CONCLUSION: □ The breach of the SEA Policy has been confirmed □ No breach of the SEA Policy has been confirmed
RECOMMENDATIONS:
imposition of disciplinary measures
termination of the working relationship / contract
reporting to the police
other measures: ____________________________________
Signatures of the members of the Commission: ____________________ ____________________ ____________________
