Protection from Sexual Exploitation and Abuse

(PSEA): A Practical Guide and Toolkit for UNICEF

and Partners
1 April 2020

Prepared by Yvonne Kemper, independent consultant

Acknowledgments
Resources from many organisations are referenced and linked as resources throughout this
Toolkit. The valuable work done on PSEA by these and many other organisations is
acknowledged here.

Note
This is an updated final draft version of the PSEA Toolkit. It is undergoing copy editing and
graphic design. The graphic designed version is expected to be available by late May 2020, and
will replace this one on the website, using the same link.
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Glossary
Beneficiaries The individuals, groups, or organizations that directly or
indirectly benefit from an intervention, project, or program.
Child A person under the age of 18, regardless of the age of majority
or age of consent locally.
Complainant The person who initially notifies UNICEF or its partners of the
sexual exploitation and abuse allegation.
Gender-based violence An umbrella term for violence directed toward or
(GBV) disproportionately affecting someone because of their actual or
perceived gender identity. Sexual exploitation and abuse is a
form of GBV.
Implementing partners Entity responsible and accountable for implementation of the
(“partners”) intended programme. It may include government institutions,
intergovernmental organizations, civil society organizations and
UN agencies.
Informed consent The voluntary agreement of an individual who has the capacity
to give consent, and who exercises free and informed choice.
Personnel This include UNICEF or partners’ employees as well as sub-
contractors, consultants, interns or volunteers associated with or
working on behalf of UNICEF or the partner organization.
Sexual exploitation and “Sexual exploitation” is any actual or attempted abuse of a
abuse (SEA) 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” is the actual or threatened physical intrusion of a
sexual nature, whether by force or under unequal or coercive
conditions. This includes non-contact and online sexual
exploitation and abuse.
Survivor Refers to a person who is, or has been, sexually exploited or
abused.
Whistleblower Any UN or partner agencies’ personnel who reports SEA
Zero-tolerance policy UN policy establishing that sexual exploitation and abuse by UN
personnel (including by partners) is prohibited and that every
transgression will be acted upon.

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Note: For additional definitions relating to PSEA, see: UN, Glossary on Sexual Exploitation and Abuse, 2nd edition, July 2017.

Table of Contents
ACKNOWLEDGMENTS 1

GLOSSARY 2

1. INTRODUCTION 5
1.1. BACKGROUND 5
1.2. ABOUT THE TOOLKIT 6

2. ORGANIZATIONAL SELF-ASSESSMENT 7

3. FOUNDATIONS 14
3.1. INTRODUCTION 14
3.2. DEFINITION 14
3.3. GLOBAL POLICIES AND STANDARDS 15
3.4. ADDITIONAL RESOURCES 16

4. PREVENTION 17
4.1. INTRODUCTION 17
4.2. POLICIES AND PROCEDURES 18
4.3. TRAINING AND AWARENESS-RAISING 20
4.4. RISK MITIGATION AND SAFE PROGRAMMING 22
4.5. ADDITIONAL RESOURCES 24

5. REPORTING 25
5.1. INTRODUCTION 25
5.2. REPORTING MECHANISMS 26
5.3. REPORTING ALLEGATIONS TO UNICEF 29
5.4. ADDITIONAL RESOURCES 29

6. ASSISTANCE 29
6.1. INTRODUCTION 29
6.2. ASSISTANCE AND REFERRALS 30
6.3. ADDITIONAL RESOURCES 33

7. INVESTIGATION 34
7.1. INTRODUCTION 34
7.2. INVESTIGATION PROCEDURES 35

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7.3. INVOLVEMENT OF UNICEF IN INVESTIGATION PROCESS 38
7.4. ADDITIONAL RESOURCES 38

8. TOOLKIT 40
TOOL 1: SAMPLE TEMPLATE FOR ACTION PLAN ON PSEA
TOOL 2: SAMPLE TEMPLATE PSEA POLICY 40
TOOL 3: SAMPLE ROLES AND RESPONSIBILITIES ON PSEA 48
TOOL 4: SAMPLE TERMS OF REFERENCE (TOR) FOR PSEA FOCAL POINT 49
TOOL 5: CHECKLIST FOR PSEA-SENSITIVE RECRUITMENT, CONTRACTING AND PERFORMANCE MANAGEMENT 51
TOOL 6: SAMPLE PSEA TRAINING AGENDA 53
TOOL 7: PSEA RISK ASSESSMENT AND MANAGEMENT FOR SAFE PROGRAMMES 56
TOOL 8: SAMPLE PROGRAMMATIC ACTIONS BY SECTOR FOR MINIMIZING PSEA RISKS 58
TOOL 9: SAMPLE INCIDENT REPORT FORM FOR SEA ALLEGATIONS 61
TOOL 10: SAMPLE REFERRAL FORM 62
TOOL 11: SAMPLE TERMS OF REFERENCE FOR INVESTIGATOR OF SEA ALLEGATIONS 64
TOOL 12: SAMPLE CONFIDENTIALITY REMINDER NOTE FOR SEA INVESTIGATIONS 66
TOOL 13: TEMPLATE FOR RISK ASSESSMENT AND MANAGEMENT DURING SEA INVESTIGATION 67

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1. Introduction
1.1. Background
All forms of sexual exploitation and abuse (SEA) are a violation of human rights and an abuse of
a position of power over a vulnerable population that the United Nations and other
humanitarian and development actors have pledged to protect. SEA can lead to serious,
sometimes life-long, adverse consequences for the survivors, particularly child survivors.
Furthermore, SEA undermines the integrity and reputation of the UN and other humanitarian
and development actors and can threaten the security of their personnel and operations.
Recent failures by UN agencies and NGOs to respond effectively to allegations underscore the
urgent need to scale up efforts.1
UNICEF is fully committed to improving protection from sexual exploitation and abuse (PSEA)
and takes a leadership role in addressing outstanding challenges. Notably, as the Inter-Agency
Standing Committee (IASC)’s Principals’ Champion on SEA and Sexual Harassment for 2018/19,
UNICEF’s Executive Director will focus on scaling up: (i) safe and accessible reporting
mechanisms, (ii) quality, survivor-centered support, and (iii) accountability for every child and
adult survivor in all humanitarian responses. Delivering on these commitments involves
ensuring UNICEF and its partners have adequate safeguards and take appropriate action to
tackle SEA.
UNICEF developed this Guide and Toolkit (“the Toolkit”) to support partners to strengthen their
policies and practices on PSEA. Partners may include – but are not limited to - government
institutions, inter-governmental organizations, and civil society organizations, including NGOs.
Partners’ subcontractors are subsumed within this definition. In addition, the Toolkit provides
technical advice and support for partners with contractual agreements to fully comply with
SEA-related aspects of UNICEF’s Partnership Cooperation Agreement (PCA). 2
This toolkit is primarily intended for UNICEF partner organizations but the content may also be
useful for individual UNICEF teams and other organizations. The Toolkit uses the term
“organizations” throughout to refer to UNICEF, partners and other agencies that may be using
the Toolkit. UNICEF also plans to release a series of additional knowledge products for
personnel, partners and other stakeholders to complement this Toolkit and bolster joint efforts
for a more systematic, widespread response to SEA.

1
Independent Panel Review of the UNICEF Response to PSEA, UNICEF, New York, NY, 2018; Reuters, “Rise in sexual abuse cases
in aid groups as more victims speak up”, February 10, 2019.
2
UNICEF amended its PCA in June 2018 to ensure its partners’ policies and procedures on PSEA fully comply with UN standards.

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1.2. About the Toolkit

Objectives
The Toolkit is designed to strengthen the capacities of organizations in fulfilling their
responsibilities to prevent and respond to SEA. It specifically aims to:
 Increase organizations’ understanding and support of PSEA;
 Support organizations in strengthening their systems on PSEA;
 Improve coordination, communication and coherence among UNICEF, partners and other
relevant actors relating to PSEA;
 Contribute to improved accountability towards affected populations.
Structure
The Toolkit’s structure enables organizations with different capacities and needs to focus on the
aspects of PSEA that require the most urgent attention. Its seven sections are:
 Organizational Self-Assessment: includes a set of core standards and accompanying
indicators to help organizations identify their strengths related to PSEA and areas where
improvements are needed.
 Foundations: presents relevant definitions, policies and standards.
 Prevention: provides guidance on organization-wide policies and procedures, training
for personnel, and risk assessment, mitigation and prevention in all programming
efforts.
 Reporting: provides guidance on internal and external reporting mechanisms to enable
or facilitate prompt and confidential reporting.
 Assistance: provides guidance on facilitating immediate, professional survivor-centered
assistance and follow-up, either directly or through referral to other service providers.
 Investigation: provides guidance on ensuring prompt and adequate investigations and
follow-up.
 Toolkit: contains a set of practical tools, such as sample forms, templates, and
checklists.
Throughout these sections, the Toolkit emphasizes the need for organizations to engage
beneficiaries and local communities in all their PSEA efforts, given that they are most directly
affected by these abuses and have unique knowledge and skills.

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2. Organizational Self-Assessment
This organizational self-assessment is intended to give organizations a baseline for tracking progress of their organizational
capacities on PSEA. These standards are aligned with the United Nations Protocol On Allegations Of Sexual Exploitation And Abuse
Involving Implementing Partners and relevant international standards, including the IASC (Inter-Agency Standing Committee)
Minimum Operating Standards for PSEA (MOS-PSEA) and the Core Humanitarian Standard on Quality and Accountability (CHS).
Partners may use this self-assessment to develop an understanding of their organizational strengths and areas of improvement on
PSEA.
Based on the assessment’s findings, organizations may develop an action plan that reflects identified areas for improvement on
PSEA (see Tool 1: Sample Template for Action Plan on PSEA). Organizations may revisit this assessment at regular intervals (i.e.
every six or 12 months). The assessment can also help identify areas where they require external support from partners, such as
trainings, technical advice, funding or increased coordination with inter-agency activities.
To support organizations’ efforts in addressing identified capacity gaps, this Toolkit provides practical guidance and tools on PSEA
organizational policies and procedures, including an extensive list of additional resources in each section.
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Instructions on the rating system for the assessment:
The table below provides (a) core standards on PSEA organizational policies and procedures which are the minimum requirement
and (b) indicators to support the fulfillment of the minimum requirements of each core standard. Organizations may use the
“comment” section to document the organization’s recent progress as well as support needs.
1 – Absent: The organization is not working towards this standard.
Give this score if the organization does not meet the requirement

2 – Progressing: The organization has made some progress towards applying this standard, but certain aspects need to be improved.
Give this score if the organization partially meets the standard, e.g., meeting one or two of the indicators
Apply this if the organization meets none of the criteria
3 – Adequate: The organization fully meets this standard.
Give this score if the organization fully meets the standard and all indicators.
Apply if the organization meets 2 of the 3 criteria
After reviewing and scoring the organization’s compliance with these standards, add up the totals for each standard to obtain a total
score. This total score indicates the organization’s current capacities on PSEA and its related risk rating.
Total Score PSEA Organizational Capacities SEA Risk Rating
8 or less Low High
9 – 14 Needs improvement Moderate
15 – 18 Adequate Low

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Standard and Indicators 1 2 3 Proof of evidence

Core Standard 1: Organizational Policy     Code of conduct

An organizational policy on PSEA exists and describes appropriate standards of conduct, Comments:  PSEA policy
other preventive measures, reporting, monitoring, investigation and corrective measures.
(see: PSEA Toolkit Section 4.2.1. Policies).  Documentation of
Indicator 1: Organizational policy includes: a) a definition of SEA (that is aligned with the standard procedures
UN's definition); b) a description of behavior expected of personnel on- and off-duty for all personnel to
(reflecting the IASC’s Six Core Principles Relating to SEA 3); and c) an explicit statement receive/sign PSEA
of zero-tolerance for SEA (i.e. SEA as a ground for disciplinary actions, which may result policy
in termination of employment).
 Other (please
Indicator 2: The organizational policy on PSEA (e.g. code of conduct) is signed by all specify):
personnel, including employees, volunteers, contractors, and others.
Indicator 3: The organization displays information on PSEA policy and procedure, _______________
including the code of conduct and reporting channel details, in its own offices and at
project sites.

Standard and Indicators 1 2 3 Proof of evidence

Core Standard 2: Organizational Management and HR Systems     ToR (e.g. with PSEA
The organization’s management and HR systems account for PSEA by: responsibilities)
Comments:
1: The organization’s contracts and partnership agreements include a standard clause  Contracts/partnership
requiring contractors, suppliers, consultants and sub-partners to commit to a zero- agreements
tolerance policy on SEA and to take measures to prevent and respond to SEA, and
 Recruitment
2: There is a systematic vetting procedure in place for job candidates (e.g. reference procedure (e.g.
checks, police records, Google searches) in accordance with local laws regarding reference check with
employment, privacy and data protection, including checking for prior involvement in SEA questions related to
or other safeguarding concerns. SEA/child
safeguarding)
(see : PSEA Toolkit Section 4.2.2. Procedures).
Indicator 1: The standard contracts and partnerships agreements include clauses:  Other (please
prohibiting SEA, and requiring the partner or contractor to take measures to prevent and specify):

3
The Core Principles were updated in September 2019.
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respond to SEA allegations.
__________
Indicator 2: Reference check templates include
_____
request for confirmation of no past allegations
for SEA.

Standard and Indicators 1 2 3 Proof of evidence

Core Standard 3: Mandatory Training     Annual training plan

Required 1: The organization holds mandatory trainings for all personnel on the Comments:  Training agenda
organization’s SEA policy and procedures and the training includes 1) a definition of SEA
(that is aligned with the UN's definition); 2) a prohibition of SEA; and 3) actions that  Attendance sheets
personnel are required to take (i.e. prompt reporting of allegations and referral of  Other (please
survivors). specify):
(see: PSEA Toolkit Section 4.3.1. Training).
_________________
Indicator 1: The organisation has a formal documented PSEA training package.
Indicator 2: The organization requires all personnel to participate in its PSEA training on a
recurring basis and retains an internal record of attendance (i.e. name of trainees, date of
training, type of training, training provider).

Standard and Indicators 1 2 3 Proof of evidence

Core Standard 4: Reporting     Communication

materials
The organization has mechanisms and procedures for personnel, beneficiaries and
communities, including children, to report SEA allegations that comply with core  PSEA awareness-
Comments:
standards for reporting (i.e. safety, confidentiality, transparency, accessibility) and raising plan
ensures that beneficiaries are aware of these.
(see PSEA Toolkit Section 4.3.2. Awareness-raising and Section 5.2. Reporting
 Description of
Mechanisms).
reporting
Indicator 1: The organization has communication materials on PSEA and reporting mechanism(s)
channels available in locally relevant languages and presented in a way that all groups,
 Whistleblower policy
including children, understand.

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Indicator 2: The organization has a description  Other
of how personnel and beneficiaries can report (please
SEA allegations and the organization’s specify):
procedures for handling these allegations, _______
including those involving personnel of other _______
entities. __
Indicator 3: The organization limits the number
of people with access to reported information
and removes identifying information of those
involved when sharing information.

Standard and Indicators 1 2 3 Proof of evidence

Core Standard 5: Assistance and Referrals     List of service

providers
The organization has a system to ensure survivors of SEA, including children, receive Comments:
immediate professional assistance, referring them to relevant service providers.  Description of referral
(see PSEA Toolkit Section 6.2. Assistance and Referrals). process for survivors
of GBV/SEA
Indicator 1: The organization has an updated list of local service providers and/or contact
with local GBV coordination mechanisms (i.e. GBV sub-cluster) for all programme  Referral form for
sites/areas. survivors of GBV/SEA

Indicator 2: The organization has a procedure to guide the referral process, outlining the  Other (please
steps that personnel, particularly those receiving complaints, need to take, including specify):
follow-up to referrals. _________________
Indicator 3: The organization has a referral form for survivors of GBV/SEA.

Standard and Indicators 1 2 3 Proof of evidence

Core Standard 6: Investigations     Written process for

The organization has a process for investigation of allegations of SEA and can provide review of SEA
Comments:

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evidence that it has appropriately dealt with allegatio
past SEA allegations, if any, through ns
investigation and corrective action. (see PSEA
 Dedicate
Toolkit Section 7.2. Investigation Procedures).
d
Indicator 1: The organization has a process for resource
reviewing allegations of SEA and deciding on s for
the need for investigation and other next steps investiga
(e.g. assistance for adult/child survivors and/or tion(s)
others, need for investigation); this involves a and/or
system for recording all SEA allegations commit
involving its personnel and its response ment of
measures. partner
Indicator 2: The organization has access to an for
experienced, impartial and trained investigator support
to conduct an investigation on SEA; this may  PSEA
involve using in-house capacity, hiring an investiga
external investigator, or getting a commitment tion
of partner(s) for support. policy/pr
Indicator 3: The organization has a system for ocedure
providing organizational oversight of an s
investigation (e.g.  Other
information-sharing/communications, risk (please
assessments), including disciplinary measures specify):
in case of substantiated allegations.
__________
_______

TOTAL PER RATING (i.e. count all 1s, 2s and 3s)

GRAND TOTAL (i.e. 1s + 2s + 3s)

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PSEA organizational capacities
SEA Risk Rating

PSEA Assessment of [Name of the Organisation]:

Assessment completed by:

Email address:

Signature Date of Assessment

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3. Foundations
3.1. Introduction
Global policies established by the UN and the Inter-Agency Standing Committee (IASC) guide
efforts by UN agencies and partners to address SEA. These bodies recognize the need for a
more concerted effort of the aid sector to tackle SEA and also focus on protecting the rights and
well-being of affected communities. Simultaneously, individual UN entities and NGOs have
taken the initiative to reinforce their respective policies on PSEA, as part of their PSEA
commitments outlined in the UN Secretary General’s Special Measures for Protection from
Sexual Exploitation and Abuse (ST/SGB/2003/13) and the IASC Minimum Operating Standards
for PSEA (MOS-PSEA). The following provides an overview of relevant definitions and global
policies and standards.

3.2. Definition
The UN Secretary-General Bulletin (“Special Measures for Protection from Sexual Exploitation
and Abuse” (ST/SGB/2003/13) introduced the following standard definition for sexual
exploitation and abuse, which applies to any sector and context 4:
 “Sexual exploitation” is 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” is the actual or threatened physical intrusion of a sexual nature,
whether by force or under unequal or coercive conditions.
SEA are forms of gender-based violence (GBV), which describes any harmful act perpetrated
against a person’s will that is based on socially ascribed differences between women and men.
Furthermore, SEA may also involve child safeguarding violations if the “conduct by (the
organization’s personnel) causes significant harm to a child including any kind of physical,
emotional or sexual abuse, neglect or exploitation” 5, highlighting the need for focused attention
on children as part of PSEA efforts.6

3.3. Global Policies and Standards

4
In terms of the definition of SEA, it is important to distinguish between SEA and sexual harassment. In both instances sexual
misconduct is perpetrated by personnel of UN agencies or its partners. However, the survivors of SEA are beneficiaries or
community members, while the survivors of sexual harassment are personnel of UN agencies or partners themselves. This
Toolkit only covers SEA. For sexual misconduct that involves personnel of UN agencies or its partners as survivors, see SG
Bulletin on Prohibition of discrimination, harassment, including sexual harassment, and abuse of authority (ST/SGB/2008/5.
5
PCA, para. 14.1 (d)
6
UNICEF, Child Safeguarding Toolkit for Business, A Step-by-Step Guide to Identifying and Preventing Risks to Children who
Interact with your Business, UNICEF, May 2018. For practical guidance on child safeguarding, see: Keeping Children Safe, Child
Safeguarding Standards and How to Implement Them, 2014
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The UN and IASC have each developed global policies to tackle SEA that are complementary and
serve as benchmarks for quality programming. Key documents are:
 IASC Six Core Principles (2002; updated 2019), in which IASC encourages agencies to
integrate the following items into their respective codes of conduct:
1) “Sexual exploitation and abuse by humanitarian workers constitute acts of gross
misconduct and are therefore grounds for termination of employment.
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 agency or not, he or
she must report such concerns via established agency 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.
 Secretary-General’s Bulletin (2003) (“Special Measures for Protection from Sexual
Exploitation and Abuse” (ST/SGB/2003/13) (“SG’s Bulletin”)
o Incorporates the aforementioned principles
o Stipulates that SEA “constitute(s) serious misconduct (and) therefore grounds for
disciplinary measures, including summary dismissal”
o Obliges UN staff and all entities and individuals who have cooperative agreements
with the UN to report incidents of abuse
In addition, UN agencies and partners are committed to pursuing a survivor-centered approach
for responding to GBV, including SEA. This approach seeks to empower survivors and promote
their recovery by prioritizing their rights, needs and wishes. 7 Key standards for applying this

7
IASC, Guidelines for Integrating Gender-Based Violence Interventions in Humanitarian Action: Reducing Risk, Promoting
Resilience and Aiding Recovery, 2015, p.46-47

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approach include:
 Safety: The safety and security of the survivor 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. (For more information on informed consent, including of children, see Section
6.2. Assistance and Referrals)
 Respect: Respect for the choices, wishes, rights and dignity of the survivor should guide
the decisions by organizations. The role of case managers is to provide the survivor with
the information s/he needs to make informed decisions and to facilitate recovery.
 Non-discrimination: survivors should receive equal and fair treatment regardless of
their age, gender, race, religion, nationality, ethnicity, sexual orientation or any other
characteristics.

3.4. Additional Resources

Key documents (selection)
 UN Protocol on Allegations of Sexual Exploitation and Abuse Involving Implementing
Partners, March 2018.
 Secretary-General's Bulletin: Special Measures for Protection from Sexual Exploitation
and Sexual Abuse (ST/SGB/2003/13) (“SG’s Bulletin”), October 2003.
 Secretary-General’s Bulletin, Staff Rules and Staff Regulations of the United Nations
(ST/SGB/2018/1), January 2018.
 IASC, Plan of Action and Core Principles of Codes of Conduct on Protection from Sexual
Abuse and Exploitation in Humanitarian Crisis, June 2002.
 IASC, Statement of Commitment on Eliminating Sexual Exploitation and Abuse by UN
and Non-UN Personnel, December 2006.
 IASC, Minimum Operating Standards for PSEA (MOS-PSEA), January 2016.
 IASC, “Global Review of Protection of Sexual Exploitation and Abuse from UN, NGO, IOM
and IFRC personnel, July 2010.
 IASC, Guidelines to Implement the MOS-PSEA, June 2013.
Overviews on PSEA/SEA
 UN Website on PSEA: https://www.un.org/preventing-sexual-exploitation-and-abuse/

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 IASC PSEA Taskforce: http://www.pseataskforce.org/
 Interaction PSEA overview https://www.interaction.org/topics/prevention-of-sexual-
exploitation-and-abuse/8
 The Core Humanitarian Standard on Quality and Accountability (CHS) Alliance –
Protection from Sexual Exploitation and Abuse https://www.chsalliance.org/what-we-
do/psea
 International Council of Voluntary Agencies (ICVA), The Long Run to PSEA, June 2018.

4. Prevention
4.1. Introduction
The long-term goal of PSEA is to create an environment where beneficiaries are safe and
respected and can access the protection and assistance they need without fear of any form of
exploitation or abuse. However, there is growing recognition that “no country, no institution
and no family is immune from sexual exploitation and abuses” 9 and a need to prioritize
preventative measures.
By creating organizational systems and raising awareness among personnel, beneficiaries and
local populations regarding PSEA, organizations can lay the groundwork for more effective
reporting of and response to violations. Likewise, effective reporting and response structures
can also serve as a prevention measure, for example by encouraging survivors and witnesses to
report violations or helping deter potential perpetrators.
This section covers the following key areas of SEA prevention:
 Types of policies and procedures needed and how to monitor their effectiveness
 Features of effective training and awareness-raising

 Risk assessment and risk management for programming

4.2. Policies and Procedures

Managers at all levels are responsible for putting in place adequate PSEA policies and
procedures, overseeing their implementation and revising them as needed. 10 Having adequate
systems in place makes it easier for management and personnel – even those with limited

8
IASC Statement of Commitment on Sexual Harassment and Abuse , 12 February 2018.
9
Address to High-Level Meeting on the United Nations Response to Sexual Exploitation and Abuse, by António Guterres, 18
September 2017.
10
For further reference on PSEA minimum operating standards policies and procedures, see IASC, PSEA-MOS, January 2016

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knowledge on gender-based violence (GBV), SEA, child protection, justice and other related to
concerns – to assume responsibilities and work jointly on this issue. Senior managers, in
particular, need to demonstrate their commitment to PSEA and create an environment where
all personnel prioritize accountability to beneficiaries and local communities.
4.2.1. Policies
Policy documents demonstrate an organization’s commitment to preventing and responding to
SEA and taking strong action in response to allegations. Organizations can either use their
existing documents, such as their codes of conduct, to articulate their organization’s policy or
create a stand-alone PSEA policy, depending on their capacities and needs. 11 (see Tool 2:
Sample template for PSEA Policy). In general, they should consider the following aspects when
creating or strengthening these policy documents:
 Incorporate core content, including 1) a definition of SEA (that is aligned with the UN’s
definition); 2) a clear description of behavior expected of personnel on-and off-duty
(reflecting the IASC’s Six Core Principles Relating to SEA); 3) an explicit statement of zero
tolerance for SEA (i.e. SEA as a ground for disciplinary actions, which may result in
termination of employment).
 Explicitly protect individuals, including personnel (former and current), who report
misconduct from any form of retaliation, such as adverse employment action (e.g.
termination, compensation decreases, poor work assignments) for personnel and
withdrawal of access to goods and services for beneficiaries. 12
 Consult relevant stakeholders, such as personnel, beneficiaries and communities
(including children); local government authorities and informal structures (e.g. women’s
and human rights groups); and those with specific expertise on GBV, child protection and
related issues.
 Make the policy relevant, ensuring that it is written in a manner that is applicable to the
various contexts (i.e. local/national/global) the organization works in and is easy to
understand for all of its target audiences, including personnel, beneficiaries and
communities (including children).
 Get sign-off from senior leadership to ensure they will provide the support needed to put
the policies into practice.
 Publicize the policy widely by distributing it among personnel, beneficiaries, communities
and others (e.g. posters in public places, intranet/internet, copy with contracts, child-
11
For sample codes of conduct, see International Rescue Committee (IRC), the IRC Way. Our Standards for Professional Conduct
and the Code of Conduct for Norwegian Refugee Council (NRC) Staff, which includes references to PSEA. For sample PSEA
policies, see CESVI PSEA Policy and the International Federation of Red Cross and Red Crescent Societies (IFRC) Secretariat PSEA
Policy
12
For sample Whistleblower policies, see: Oxfam America, Whistleblower Protection Policy; CARE International UK, Whistle-
blowing Policy

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friendly materials) and integrating it into training and awareness-raising efforts (see
Section 4.3. Training and Awareness-raising).
 Require all personnel to sign their receipt and acknowledgement of relevant policies (see
Section 4.3.1. Awareness-raising).
.
4.2.2. Procedures
Procedures outline how to put PSEA-related policies into effect and create the organizational
infrastructure to support their implementation. The following actions can help establish or
reinforce organizational procedures:
 Clarify roles and responsibilities, in particular of managers, HR, and personnel as per the
organization’s policies (see Tool 3: Sample Roles and Responsibilities on PSEA). This may
include designating PSEA focal point(s) to assume key responsibilities, such as the
development of internal systems, training and awareness-raising of personnel, and
coordination with other relevant actors (see Tool 4: Sample Terms of Reference (ToR) for
PSEA Focal Points).
 Update HR processes (as needed) to align hiring practices (e.g. job announcements,
background/reference checks, interview process), sub-contractor contracts and
partnership agreements, and performance processes and disciplinary measures (in the
event of proven allegations) with SEA policies (see Tool 5: Checklist for PSEA-Sensitive
Recruitment, Contracting and Performance Management).
 Prepare an appropriate process for reporting and responding to allegations (see Section
5: Reporting, Section 6: Assistance, and Section 7: Investigation). This may include
guidance on how field offices can adapt these processes to their specific local context.
 Integrate PSEA into the organization’s planning, programming and operational
processes (e.g. strategic planning, budgeting, programme cycle management) and ensure
the organization allocates sufficient human and financial resources.

Accountability
Accountability measures allow organizations to monitor the implementation of policies and
procedures on PSEA and make improvements as needed. Accountability also entails sharing
relevant information and feedback with beneficiaries and local communities. This helps build
trust in the organization and encourages them to report any serious concerns in the future.
Organizations should take the following measures to ensure accountability:
 Monitor the implementation and effectiveness of strategies on PSEA by including one
or more indicators in monitoring frameworks (e.g. percentage of reported survivors who

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requested assistance who were referred within 48 hours of referral/receipt of case,
percentage of employee terminations for SEA offences).
 Include regular opportunities for community-level monitoring. Ask questions about
awareness, experiences or observations related to programming (e.g. power dynamics,
quality of services, engagement with communities), including SEA, and availability and
use of reporting mechanisms.
 Regularly communicate to personnel, beneficiaries, and others regarding the
organization’s efforts and respond to their feedback on programming, including SEA-
related issues without providing details on specific cases (e.g. “In the past six months,
we received feedback about x, y, and z by x number of people. Because of this, we have
made the following changes…”). This involves keeping survivors, witnesses, alleged
perpetrators and complainants informed on relevant aspects of the investigation
process (see Section 7.2. Investigation Procedures).
 Review and learn from actual incidents within or outside their organization (e.g. staff
meetings, PSEA trainings) and adapt PSEA policies and procedures periodically to reflect
lessons learned.
 Document and share progress, opportunities and challenges in prevention and
response with senior management and other key stakeholders (e.g. donors, partners,
independent bodies, inter-agency groups, communities), including in relevant reports
(e.g. annual, donor reports).

4.3. Training and Awareness-raising

Misconceptions and a lack of willingness or capacity by some personnel to adequately address
SEA frequently prevent organizations from implementing PSEA policies. Training and
awareness-raising of personnel play a central role in building an organizational culture that
does not tolerate abuse. These efforts can help address knowledge gaps and create a more
open discourse on SEA, which remains a sensitive issue in many cultures.
4.3.1. Training
Organizations should organize mandatory training on PSEA for all their personnel on a regular
basis (see Tool 6: Sample PSEA Training Agenda). Organizations can draw on existing training
modules to develop training content that is most relevant for their participants. 13 In order to
make their trainings most effective, organizations should:

13
For example, UNICEF provides a free PSEA e-learning course (through Agora) that contains relevant content for both UN and
partner personnel. Other online trainings include Interaction Prevention of Sexual Exploitation and Abuse Training Guide,
December 2013; UN Training on PSEA, https://www.un.org/preventing-sexual-exploitation-and-abuse/content/training, and
specifically focused on PSEA focal points, OCHA, Inter-Agency Training for PSEA Focal Point, (see PSEA Taskforce website, “Focal
Point”).

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 Include core content, such as 1) a clear definition of SEA (that is aligned with the UN’s
definition); 2) a clear prohibition of SEA; and 3) actions that personnel are required to
take (i.e. prompt reporting of allegations and referral of survivors). It is also essential to
familiarize personnel with the organization’s reporting and referral procedures and
provide them with relevant contact details (e.g. PSEA focal points).
 Offer in-person, highly interactive trainings to ensure that personnel retain the
information and are able to apply it in practice. For example, actual scenarios and case
studies -set in the participants’ local context if possible- can help them understand how
to use standards and rules in practice.
 Adapt training content to the audience by describing their PSEA-specific roles and
responsibilities and presenting examples of SEA that participants might encounter in
their everyday work.
 Increase accountability by requiring participants to acknowledge in writing their
responsibilities for complying with the code of conduct and the consequences for
breaching it.
 Offer regular re-fresher trainings to ensure that personnel are aware of the latest
policies and procedures.14

4.3.2. Awareness-raising
Organizations should conduct activities to raise awareness among their personnel, beneficiaries
and local communities, including children, and others on PSEA and their organization’s relevant
policies and procedures. For example, some beneficiaries and community members may not
understand what SEA is, why it is dangerous, what their rights are, and what they can do to
prevent and respond to incidents. Personnel also need continuous reminders so that they can
realize their roles and responsibilities in reporting and responding to SEA. Awareness-raising
efforts may include the following actions:
 Develop core PSEA messages for
o Beneficiaries and community members covering 1) beneficiary rights (i.e.
assistance is free; the right to information about the project/program; the right
to be treated with respect, the right to report inappropriate behavior, etc.) 2)
prohibited behaviour of personnel; 3) how to report complaints (e.g. hotlines,
contact of PSEA focal points)
o Personnel covering 1) definition and prohibition of SEA, 2) relevant roles and

14
PSEA-MOS requires members to conduct annual refresher training (MOS-PSEA).

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responsibilities, 3) the organization’s reporting and referral procedures, including
relevant contact details (e.g. PSEA focal points) (see Section 4.3.1. Training; see
Section 5.2. Reporting Mechanisms)
 Adapt communication messages, materials and channels to the various target
audiences, including children, using relevant languages and a communication style that
is appropriate and accessible to the audience, especially to groups considered at higher
risk of abuse (see Tool 7: PSEA Risk Assessment and Management for Safe
Programmes). For example, adolescent girls may be more comfortable discussing
personal issues as part of peer-to-peer discussions, while some personnel may prefer to
receive information in a memo or short email. Always test communication materials and
messages with the target audience before dissemination.
 Widely publicize PSEA-related information by using a variety of communication
channels (e.g. website, social media, staff/community meetings, posters, radio or
television announcements, town criers, story boards). In some cases, there may be
opportunities to work with other organizations on awareness-raising activities, including
as part of GBV and child protection campaigns. Organizations should highlight
beneficiary rights in project/program awareness materials before and during
implementation.

4.4. Risk Mitigation and Safe Programming

Humanitarian and development projects can exacerbate existing risks of SEA or create new
risks, depending on their scope and scale. For example, in areas where beneficiaries and
communities struggle economically and violence against women and children is more
prevalent, organizations should anticipate that some personnel may attempt to abuse their
power, particularly if they are in charge of distributing food, water, health supplies, and/or
cash. SEA incidents may occur even when programmes do not directly involve beneficiaries, for
example when personnel interact with participants off-site or in their free time. There are also
risks of online SEA whereby perpetrators use information and communication technology (e.g.
emails, texts, social media, communication apps) to commit abuses. 15
In order to identify and mitigate or avoid risks of SEA through programming 16, organizations
should take the following actions:

15
For example, some types of online SEA include online grooming (i.e. establishing a relationship with a person to facilitate
either online or offline sexual contact), production, dissemination and possession of online SEA materials (i.e. depicting
sexualized images of person), sextortion (i.e. coercing and blackmailing children for sexual purposes) and live streaming of
sexual abuse. For more information regarding online SEA and other types of online violence, see: UNODC, Online Child Sexual
Exploitation and Abuse, in: E4J University Module Series: Cybercrime (accessed July 15, 2019); UNICEF, Child Safety Online
Global Challenges and Strategies, 2011.
16
Risk prevention means reducing the likelihood of SEA occurring whereas risk mitigation means reducing the adverse impact of
SEA.

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 Conduct thorough and inclusive risk assessments on SEA before designing projects, if
possible as part of the initial needs assessment (see Tool 7: PSEA Risk Assessment and
Management for Safe Programmes).17 This may include site safety mapping, focus group
discussions with intended beneficiaries and other stakeholders (including women,
children, local authorities/communities, etc.) and other relevant research methods. As
part of this assessment, it is useful to identify groups that are most marginalized and at
heightened risk of SEA (e.g. children with disabilities) to ensure that design strategies
are as targeted and effective as possible.18
 Consult with beneficiaries and local communities, including at-risk groups (e.g.
adolescent girls, people with disabilities, Lesbian, Gay, Bisexual, Transgender, Intersex
(LGBTI) communities), as part of the initial needs assessment and routine monitoring to
identify locally relevant risks and protection measures (that are in line with international
laws and standards). Consultations should be safe and culturally appropriate.
 Incorporate general prevention and safety measures for SEA in the organization’s
standard programme design, such as:
o Ensure that safe recruitment practices are followed for hiring programme
personnel, including local volunteers, day laborers, etc.; this includes using a
recruitment panel that includes at least one woman (see Tool 5: Checklist for
PSEA-Sensitive Recruitment, Contracting and Performance Management)
o Ensure that all personnel are PSEA-trained and have signed the code of conduct,
and reporting and response procedures are set up before the start of the
programme.
o Include female personnel in programme implementation teams, where possible
specifically if their roles require direct interactions with beneficiaries (e.g. food
distributions, health clinics, child-friendly spaces, schools/temporary learning
spaces, community centers), given that the majority of perpetrators of SEA are
men.
o Ensure that there are shared responsibilities of processes during programme
intervention so that more than one person is involved (“segregation of duties”).
o Engage women and at-risk groups in the planning, design, implementation and
monitoring of activities to the extent possible and if safe for those involved
o Provide assistance interventions in safely accessible and well-lit areas.

17
World Bank Group, Working Together to Prevent Sexual Exploitation and Abuse: Recommendations for World Bank
Investment Projects, Report of the Global Gender-Based Violence Task Force, July 2017.
18
For a list of at-risk groups, see IASC, Guidelines for Integrating GBV Interventions in Humanitarian Action, September 2015, p.
11-12.

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o Design programmes in a manner that limits one-on-one interactions between
beneficiaries, particularly children, wherever possible.
o Proactively communicate information about aid distribution procedures to the
community (“aid is free”; beneficiary s; administrative requirements; how to
report concerns; etc.) and take advise from the community to engage effectively.
o Prominently display in their offices and on work sites SEA-related information
and the organization’s policies and procedures, including how to report
inappropriate behavior by the organization’s personnel, using a language and
communication style that personnel and communities can understand.
 Take programmatic actions to minimize SEA risks and help connect survivors to
appropriate care in cross-sectoral programming and in distinct sectors (see Tool 8:
Sample Programmatic Actions by Sector for Minimizing PSEA Risks). Organizations
should also ensure that SEA-related prevention and safety measures are reflected in
programme budgets and monitoring frameworks.

4.5. Additional Resources

Policies and procedures
 Interaction, Interaction Step by Step Guide to Addressing Sexual Exploitation and Abuse,
June 2010.
 Keeping Children Safe, Child Safeguarding Standards and How to Implement Them, 2014
 CHS Alliance, PSEA Implementation Quick Reference Handbook, 2017.
Training modules
 InterAction, Interaction Prevention of Sexual Exploitation and Abuse Training Guide,
December 2013 and Introduction to Sexual Exploitation and Abuse (through Kaya)
 UNICEF PSEA e-learning course (through Agora)
 UN Training on PSEA,
https://www.un.org/preventing-sexual-exploitation-and-abuse/content/training
 OCHA, Inter-Agency Training for PSEA Focal Point, (see PSEA Taskforce website, “Focal
Point”).

 IASC, Learning Package on Protection from Sexual Misconduct for UN Parnter

Organizations.

Recruitment process

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 IASC, Challenges and options in improving recruitment process in the context of PSEA by
our own staff, April 2014.
 The Steering Committee for Humanitarian Response, The Misconduct Disclosure
Scheme, December 2018.
Risk mitigation and risk management
 UN Peace Operations, UN Peace Operations, Sexual Exploitation and Abuse Risk
Management Tool, June 2018.

 IASC, Guidelines for Integrating GBV Interventions in Humanitarian Action , September

2015.
 Global Protection Cluster Protection Mainstreaming Tool Kit, 2017

5. Reporting
5.1. Introduction
Survivors and witnesses rarely speak out on SEA due to fear of potential repercussions (e.g.
losing assistance, retaliation), a lack of adequate reporting channels, and other factors.
Similarly, personnel also do not always share information or concerns of potential SEA, for
example due to fear of revenge (e.g. bullying or job loss) or because they do not want to cause
problems for their colleague(s) or harm their organization’s reputation.
Organizations can (re-)design their reporting channels to reflect these concerns and encourage
safe and confidential reporting by personnel and beneficiaries, as part of their overall
commitments to PSEA. More effective reporting of SEA is also an essential step to ensure
survivors receive appropriate assistance and to end impunity.
This section covers the following key aspects of reporting SEA allegations:
 Core principles of effective reporting
 Types of reporting mechanisms
 Awareness-raising on available reporting channels
 Sharing reported information with UNICEF.

5.2. Reporting Mechanisms

Organizations can use both internal and external reporting mechanisms to facilitate reporting
of SEA allegations or concerns by personnel and beneficiaries. Where possible, they should seek
to incorporate PSEA reporting mechanisms into broader feedback or complaints mechanisms in

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order to benefit from these channels’ levels of trust, discreteness, and resources. Regardless of
the accountability mechanism(s) used, partners will need to have their own reporting
procedures to facilitate prompt and confidential internal reporting to senior management and
subsequently UNICEF and other relevant actors. Reporting mechanisms should also have the
ability to refer SEA complaints involving personnel of another entity (e.g. UN agency, NGO) to
the respective entity for follow-up, where legally possible.
Organizations should consider the following elements when (re-)designing and using reporting
mechanisms:
 Ensure that reporting mechanisms adhere to core principles of effective reporting:
o Safety: avoid creating or exacerbating risks for those reporting allegations or
concerns, as well as other parties involved (e.g. survivor, alleged perpetrator).
This involves ensuring that referral procedures and protection measures (e.g.
whistleblower policy) are set up before promoting the use of a reporting
mechanism (see Section 6:.2. Assistance and Referrals). Organizations should
also restrict access to incident reports and keep reports stored safely (e.g. using
passwords or encryptions for computers and lock offices when unattended).
o Confidentiality: enforce strict information-sharing practices, i.e. limiting the
number of people who have access to the reported information; using code
names when referring to those involved and omitting information that could
reveal their identity (e.g. date of birth, address, phone number, description of
unique physical traits); and keeping information on the identity and personal
information separate from incident and related reports. People should also have
the option of anonymous reporting.
o Transparency: obtain prior informed consent of the complainant, unless the
complainant is a UN or partner personnel, who have a mandatory obligation to
report SEA. Organizations should share confidentiality procedures with all
complainants, explaining clearly how information will be shared, with whom and
for what purpose, including for investigations and assistance to survivors. This
also includes notice of the organization’ obligations for mandatory reporting (see
5.3. Reporting Allegations to UNICEF).
o Accessibility: make reporting mechanisms easy-to-use and remove potential
barriers for usage (e.g. difficult or foreign language, costs and time needed for
using them), keeping in mind their target audiences, including people of different
ages, genders, educational backgrounds, abilities, etc.19

19
For information on child-friendly complaints mechanisms, see: UNICEF, Child-friendly Complaint Mechanisms. National human
rights institutions (NHRIs) Series: Tools to support child-friendly practices, February 2019.

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 Identify to what extent their organization can use existing inter-agency complaints
mechanisms to enhance internal reporting. This includes assessing to what extent these
inter-agency mechanisms adhere to above-mentioned core reporting standards and
allow access to reports concerning their personnel for response and follow-up. Likewise,
organizations should ensure that their reporting mechanisms align with inter-agency
mechanisms in-country. The in-country PSEA network (where it exists) or other
coordination bodies can help organizations identify relevant complaints mechanisms in-
country. It may also be worth identifying relevant regional or international bodies that
personnel, beneficiaries and/or others can access, in case they do not trust in-country
mechanisms.
 Give personnel and beneficiaries, including children, access to multiple reporting
mechanisms (internal/external) that meet their needs and preferences to the extent
possible. For example, some people may be too embarrassed to talk to a person about
an incident, while others may not feel comfortable sending sensitive information via
email. Similarly, some community members (or personnel) may not trust internal
reporting channels and prefer to share information with an external body (see point
below on community-based complaints mechanism). Possible reporting mechanisms
(internal/external) may include in-person reporting to designated personnel (e.g. direct
supervisors, PSEA focal points or internal oversight offices), inter-agency staff, or
others20; reporting via free phone hotlines, SMS, text messaging or email; 21 or use of
secure suggestion/complaint boxes (with no specific signage on them to avoid any direct
association with SEA) .
 Support the establishment and functioning of community-based, inter-agency
complaint mechanisms that are equipped to handle GBV complaints, including SEA.
Community-based inter-agency mechanisms allow communities that receive services
from multiple organizations to access one channel for reporting allegations involving
personnel, thus facilitating more streamlined, efficient reporting. These mechanisms
should be free to use and usually include various reporting channels (e.g. dedicated
phone lines, complaint boxes, e-mail addresses, help desks and/or designated trusted
persons).22
 Consult beneficiaries and local communities (including women, children, people with
disabilities, and other relevant stakeholders) on risk factors for SEA; challenges for
raising complaints; preferred methods for reporting; and how to make reporting

20
This involves providing the designated people with clear instructions on how to record and report complaints (i.e. what forms
to use, how to treat information, when and how to report complaints).
21
For example, the U-Report is a free social messaging system that allows everyone to speak out about development issues.
https://ureport.in/
22
IASC Best Practice Guide Inter-Agency Community-Based Complaints Mechanisms, September 2016

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mechanisms safe, confidential, transparent and accessible.
 Widely publicize all available reporting channels to personnel, beneficiaries and local
communities (see Section 4.3.2: Awareness-raising). Importantly, organizations should
inform personnel about mandatory reporting both in writing (e.g. memo, detailed email)
and verbally (e.g. meeting, conference call), incorporating the following content:
o A clear description of behaviours that constitute SEA, stressing the need to
report when in doubt about a case
o The obligation of all personnel to report any suspicions or concerns and
consequences for failing to report (e.g. disciplinary measures)
o The option of reporting information anonymously
o The organization’s protections for those who makes an allegation in good faith
(e.g. whistleblower policy, protection plans for complainants)
o Details regarding who to report to and what information to share to allow for
proper response and follow-up
o Explanation of how the organization will use the information (i.e. who will
receive the reports and the internal procedure for response and follow-up).
 Ensure that the report of the alleged incident (Tool 9: Sample Incident Report Form on
SEA Allegations23) is as detailed as possible while adhering to aforesaid standards of
effective reporting see core principles of effective reporting). Organization should train
personnel who may receive complaints (e.g. PSEA focal points, protection officers, M&E
officers) on relevant procedures and remind them to:
o Use the complainant’s own wording to describe facts, violations and persons
involved in the case to the extent possible.
o Indicate where relevant information is missing and add essential contextual
information where needed.
o Remember that their role is not to investigate but rather to relate the facts for
others to follow-up.

5.3. Reporting Allegations to UNICEF

Partners’ reporting obligations partially derive from their relationship with UNICEF. As a part of
the UN system, UNICEF is required to report any SEA allegation involving its own or its partners’
personnel to the UN Secretary-General on a quarterly basis. Accordingly, beyond reporting to
their own management, partners are required to “promptly and confidentially, in a manner that
23
Organizations can adapt this sample incident report form or use the IASC, Model Complaints Referral Form (SEA) (accessed
July 16, 2019).

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assures the safety of all involved, report allegations of sexual exploitation and abuse” arising
from their Partnership Agreement to UNICEF. 24 Partners can submit their concerns or suspicions
to the UNICEF Head of Office in-country or the UNICEF Director, Office of Internal Audit and
Investigations (OIAI), through the email hotline ([email protected]).
Furthermore, partners should keep UNICEF (through the head of the respective country office)
informed on reported cases by sharing regular updates on findings relating to the case, the
investigation process and outcome (see Section 7.3. Involvement of UNICEF in Investigation
Process) and referrals for survivors and others.

5.4. Additional Resources

 IASC Best Practice Guide Inter-Agency Community-Based Complaints Mechanisms ,
September 2016
 Save the Children, Programme Accountability Guidance Pack. A Save the Children
Resource, 2013 (particularly chapter 4 “Handling feedback and complaints”, p. 25-42)
 Transparency International, Complaints Mechanisms Reference Guide for Good Practice,
2016 (Note: This guide is focused on anti-corruption and malpractice but contains
guidance that is applicable to other types of complaints mechanisms.)

6. Assistance
6.1. Introduction
Global policies and commitments on PSEA emphasize a survivor-centred and rights-based
approach that supports the survivors to receive the protections and remedies they desire, need
and are entitled to. Furthermore, supporting survivors to access quality services in a timely
manner is essential to help survivors, beneficiaries and others regain trust in the integrity of aid
organizations. UNICEF is committed to working with partners to provide and/or facilitate quality
services to survivors, as part of ongoing child protection (CP) and GBV programming. 25
This section covers the following key aspects of facilitating assistance to survivors:
 Eligibility criteria for assistance
 Types of service needs (e.g. psycho-social, medical, legal)
 Referral processes, including informed consent/assent
 Survivor-centered approaches to service provision

24
PCA, para. 14.4.
25
Witnesses, complainants/whistleblowers and alleged perpetrators may also have protection and support needs due to the
allegation. For more information on this, see: Section 7.2. Investigation Procedures.

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6.2. Assistance and Referrals

It is the responsibility of organizations to ensure survivors of SEA allegedly perpetrated by their
personnel receive immediate professional assistance, either by providing them with direct
services or referring them to relevant service providers where consent is given. Organizations
should consider the following aspects when facilitating assistance:
 Ensure that survivors have access to assistance regardless of decisions by organizations
or others to investigate the case and regardless of the outcome of an investigation.
Survivors are also not required to identify the perpetrator or prove that they are
survivors of SEA to access services. As appropriate organizations should account for the
protection and support needs of witnesses, complainants, alleged perpetrators and
other individuals connected to the case (see: Section 7.2. Investigation Procedures).
 Have an updated list of local service providers, which should provide options for both
children and adult survivors where relevant (e.g. names of a pediatric and adult medical
care provider). In many cases, organizations can use or adapt the mapping of existing
GBV and CP services and referral pathways of relevant inter-agency bodies, such as the
in-country PSEA Network and in-country GBV and CP coordination groups. Especially in
cases involving children, organizations should also consult with UNICEF country offices. 26
The table below provides an overview of the types of services survivors may need.
Type of service Description

Safety  Immediate safety or protection measures for survivors and

witnesses to address the risk of retaliation or further violence,
such as survivor safety planning, safe shelter (i.e. space that
offers temporary safety to individuals fleeing harm), relocation
support

Medical care  Medical care, including post-exposure prophylaxis (PEP) to

prevent HIV ((within 72 hours of possible exposure); treatment
for Sexually Transmitted Infections (STIs), pregnancy care,
emergency contraception

Psychosocial support  Mental health care, emotional and practical support, either
individually or community-based

Legal services  Legal assistance services, including free legal counselling, legal
representation and other support (Note: If possible, such legal
representation and support should be provided independently

26
In some cases, organizations may also be able to access additional funding to provide specialized services through the Trust
Fund in Support of Victims of Sexual Exploitation and Abuse (the “Trust Fund”) established by the Secretary-General. For more
information on the Trust Fund, see: https://conduct.unmissions.org/remedial-trust-fund

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from the alleged perpetrator’s employer.)

Basic material  Provision of food, clothing, shelter, school re-integration and

assistance livelihood support to the survivor

Support for children  Medical and psychosocial care and pursuit of paternity and child
born as a result of support claims, in conjunction with relevant national
SEA governments

 Have a set procedure to guide the referral process that is aligned with existing inter-
agency procedures and protocols. The process should outline the steps that personnel,
particularly those receiving complaints, need to take and should provide them with
updated referral forms (see graphic below and Tool 10: Sample Referral Form). Make
sure that those involved in the process are adequately trained on how to safely and
confidentially refer GBV/SEA cases for assistance, including those cases involving
children. If possible, the process should entail referring the survivor first to a case
manager or social worker, who can then facilitate referral to other appropriate services.
If organizations are unable to conduct the referral process on their own, they should
contact external and pre-identified GBV or CP service providers or organizations for
support.

Explain referral Contact service

provider(s), e.g.
process and Assess survivor's Identify relevant service
survivor eligibility;
document informed needs provider(s)
relevant rreferral
consent protocol

Make referral (and Follow up with survivor Store information

assist with transport, and receiving and ensure
where possible) agency/ies confidentiality

Figure 1: This graphic outlines key steps involved in the referral process. Please note that caseworkers should be flexible in
applying these steps and should adapt this process to meet the needs of the survivor, including those who are children.

 Always obtain informed and voluntary consent before facilitating assistance, respecting
the right of a person27, including children (depending on their age and capacities), to
freely choose which type of support services they want to access or to decline services
27
Persons with disabilities may need specific support to enable their ability to provide informed consent depending on the
nature of their disability (e.g. physical, intellectual, mental).

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entirely. To ensure informed consent, caseworkers must ensure that the adult or child
survivor fully understands the services available and the referral process, potential risks
and benefits of receiving services, and what information will be collected and how it will
be used, including confidentiality and its limits (see point below regarding
“confidentiality”). During this consultation, caseworkers should avoid raising unrealistic
expectations among survivors particularly in locations where adequate services are
limited, such as remote or emergency settings. 28
When dealing with children, caseworkers should communicate the information in a
child-friendly manner, adapting it to the child’s age, maturity, language, gender and
culture (i.e. simplifying content) and obtain informed consent from both the child
(taking into account his/her evolving capacities) and one of the child’s parents or
guardians.29 At the same time, it is essential for organizations to ensure that the best
interest of the child serve as the primary guide for making decisions regarding assistance
and referrals (see point below on “the best interests of the child”).
 In the case of children, prioritize the best interests of the child, choosing the course of
action that is most effective in protecting the child’s rights to safety and ongoing
development. For example, in some cultures, the survivor’s parents/caregivers may
want (or force) the girl to get married to the alleged perpetrator to “protect family
dignity” or for other reasons, which violates the girl’s rights and exposes her to
additional harm. In such instances, experienced caseworkers can help the girl and her
parents/caregivers make informed decisions, applying the best interests of the child
principle. Depending on their in-house expertise and the complexity of the case,
organizations may also need to request technical support from UNICEF and/or other
GBV and CP partners.
 Respect confidentiality, protecting identifying information of all those involved in the
alleged incident. Organizations should collect, share and store information on these
cases safely and according to agreed-upon data protection policies (also see “principles
of effective reporting”). In particular, organizations should share this information only
with a limited number of individuals and on a “need-to-know” basis and ensure this
happens with the survivor’s explicit permission.
In exceptional cases, organizations may need to refer cases – even without the
survivor’s informed consent – when there are safety concerns for the survivor or others
28
For guidance on how to support survivors in areas where GBV actors are not present, see Global Protection Cluster / IASC,
GBV Pocket Guide, March 2018.
29
For younger children, who are by law or nature too young to agree to the services, caseworkers should seek their “informed
assent,” an affirmative agreement to accept the services and ask for parents’ permission. For more information on informed
consent and informed assent, see Inter-agency Guidelines for Case Management and Child Protection. The Role of Case
Management in the Protection of Children: A Guide for Policy and Programme Managers and Caseworkers,
http://www.cpcnetwork.org/wp-content/uploads/2014/08/CM_guidelines_ENG_.pdf

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or when they are required by law to report crimes. Organizations should always explain
to survivors (and/or their guardians where appropriate) these limitations of
confidentiality (see “informed consent”).
 Consider potential risks for survivors (and their families) and take safety precautions,
as needed. This means being careful to avoid causing any additional harm to survivors
(and their families) as a result of how the case is being managed (e.g. possible revenge
acts due to mishandling of case information). Organizations should also be careful to
manage survivors’ expectations regarding the organization’s capacity to ensure the
survivor’s safety.

6.3. Additional Resources

Assistance for all survivors
 UN Victim Assistance Protocol (forthcoming).
 Guidelines for Integrating Gender-Based Violence Interventions in Humanitarian Action
Reducing risk, promoting resilience and aiding recovery, IASC, 2015.
 SEA Victim Assistance Guide: Establishing Country-Based Mechanisms for Assisting
Victims of Sexual Exploitation and Abuse by UN/NGO/IGO Staff and Related Personnel,
ECHA/ECPS UN and NGO Task Force on Protection from Sexual Exploitation and Abuse,
April 2009.
 Minimum Standards for Prevention and Response to Gender-based Violence in
Emergencies, UNFPA, 2015.
 UN Victim Assistance Strategy
Assistance for child survivors
 Caring for Child Survivors of Sexual Abuse: Guidelines for health and psychosocial
service providers in humanitarian settings, International Rescue Committee/UNICEF,
2012
 Inter-agency Guidelines for Case Management and Child Protection. The Role of Case
Management in the Protection of Children: A Guide for Policy and Programme Managers
and Caseworkers, The Child Protection Working Group, January 2014

7. Investigation
7.1. Introduction

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Investigating allegations is essential to implementing the zero-tolerance policy of the UN and its
partners on SEA and increasing accountability for violations. Organizations are required to
ensure that investigations of allegations of SEA involving their personnel take place without
delay. However, conducting such investigations can be a dangerous, complex and oftentimes
costly undertaking. Even in cases where organizations have strong PSEA policies that include
disciplinary measures against perpetrators, they may lack the internal capacities or resources
needed to conduct or oversee the needed investigations; there may also be a lack of qualified
investigators in the locations they work in and/or weak capacities of national and local law
enforcement agencies.
This makes it even more essential for organizations to assess their investigation capacities early-
on (see Section 2: Organizational Self-Assessment) and work with relevant donors and/or other
partner organizations to identify options to meet their needs and capacities (e.g. using pro-
bono legal services, requesting a partner to sponsor/deploy investigator(s)).
This section covers the following key aspects of investigations:
 Internal processes for reviewing allegations
 Management of investigations
 Follow-up to investigations
 Involvement of UNICEF in investigation processes involving partners.

7.2. Investigation Procedures

Organizations should have a standard process (or policy)30 to ensure investigations of SEA
allegations follow due process and protect the safety and rights of those involved, including
survivors, witnesses and alleged perpetrators. They should also ensure that investigations are
survivor-centered, respecting survivors’ rights to safety, confidentiality, respect and non-
discrimination (see Section 3: Foundations). The following are some key points for organizations
to consider when managing (or overseeing) investigations:
 Set up an internal process for reviewing all allegations and deciding on next steps,
including the need for an internal investigation and/or referral to local law enforcement
authorities (where appropriate as determined by the organization and when possible,
the survivor)31; immediate consequences for alleged perpetrator in terms of their work

30
Note that IASC-MOS requires members to create an investigation policy, which provides a clear framework that assists
organizations to conduct quality, confidential, safe, and transparent investigations into allegations of misconduct involving
personnel.
31
Organizations may choose not to refer a case to local law enforcement if they believe the local context or the country’s
governance or legal structures are not robust enough to protect the survivor(s) and others involved in the case or even put
them in danger. Considerations into whether to report to national law enforcement include the nature of the complaint, wishes
of the survivor and his/her capacity to give informed consent, and concerns about the legal/judicial processes in that specific
country. In cases where it is determined not to report to local authorities, it is advisable for organizations to consult with a
lawyer and keep documentation and evidence to support their decision.

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(e.g. suspension, change of job responsibilities); assistance for survivors and others; and
communication with the parties involved, partners and others. Some criteria for making
decisions regarding the investigation process include the nature of the abuse (i.e. breach
of the organization’s code of conduct/national criminal law), reliability of source(s) of
allegation, availability of hard evidence (e.g. photographs), and risk(s) for the survivor(s)
associated with the investigation process. In general, organizations should always keep a
record explaining the rationale for their course of action; this is particularly useful if they
decide to revisit the case at a later stage.
 Deploy or hire experienced, impartial and trained investigator(s) who are qualified to
handle cases that require a high degree of sensitivity and confidentiality (see Tool 11:
Sample Terms of Reference for Investigator of SEA Allegations).32 The investigator(s)
should speak the language of witnesses and be familiar with local laws if possible. 33
Furthermore, it is critical to agree with the investigator(s) from the outset on the scope
of the investigation, coordination and communication processes (e.g. regular check-ins
with managers), deliverables and timelines, contingency plans, and other key aspects of
the investigation.
 Identify and manage conflicts of interest by verifying that personnel and external
experts involved in the investigation do not have personal or professional relations to
the survivor, witnesses, complainants/whistleblowers, or the alleged perpetrator or
have a vested interest in the outcome of the investigation, which may compromise their
objectivity. If and when organizations become aware of such a conflict of interest, they
should immediately remove the concerned individual from the case, stop them from
further contact with all parties involved in the case, and request them to agree in
writing to keep information on the case confidential.
 Manage information-sharing and communications in order to protect those directly
involved as well as the integrity of the process. This involves:
o Distinguishing between communications on the process of an investigation (e.g.
state of investigation process), which should be transparent, and details relating
to the case (e.g. identity of parties involved, details of incident), which should be
treated confidentially.
o Defining which individuals need to have access to what type of information.
o Having a secure information-management system for keeping electronic and
32
Organizations can draw on several resources to bolster their capacities to conduct investigations. In particular, OCHA has
established an investigations fund to provide rapid grants to IASC entities to support investigations into SEA and sexual
harassment allegations .The CHS Alliance also maintains a pool of certified PSEA Trainers and Investigators (for names of
consultants, see: CHS Alliance Approved Trainers and Investigators).
33
If this is not the case, organizations should consider hiring discreet, independent and professional interpreters and local
lawyers to support investigator(s). Depending on the case and cultural context, it may also be beneficial to select a female
investigator if possible.

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non-electronic data with access limited to those directly involved in managing or
overseeing the investigation (e.g. using password protection for computers and
keeping them in a secure place; keeping paper documents and other evidence in
locked cabinets in a secure room; avoiding any identifying information in written
communications, such as emails, WhatsApp and others).
o Providing investigators (internal/external) with access to relevant internal
documents, records and personnel, as well as adequate and administrative
support to conduct investigations effectively.
o Requesting all parties directly involved in the investigation process (e.g.
investigators, survivors, witnesses, alleged perpetrators, designated
managers/personnel) to keep the content of their interviews confidential (see
Tool 12: Sample Confidentiality Reminder Note for SEA Investigations).
o Setting up a system for keeping survivors, witnesses, alleged perpetrators and
complainants informed on relevant aspects of the investigation process (i.e.
determining who is responsible for sharing what type of information with whom
and at what frequency).
 Provide adequate protection and other support to survivors, witnesses and
complainants/whistleblowers, and alleged perpetrators (as part of their duty of care
for personnel) throughout the investigation process as needed. Organizations should
adapt their support to each person’s specific needs and wishes (accounting for age,
gender, abilities, other factors) to offer adequate support, closely working with
protection actors and those providing services to survivors and others (See Section 6.2:
Assistance and Referrals). For example, individuals directly involved in the case may
require independent legal counsel and/or an advisor/support person to provide
emotional support, share updates on the investigation, and to serve as a liaison with the
investigation team as needed. Child survivors and witnesses are likely to require
additional support to ensure that the investigation process is conducted in a child-
friendly manner (e.g. child-friendly interview techniques, engagement of
parents/caretaker).34
 Assess and manage risks relating to the investigation process by conducting a
comprehensive risk assessment (see Tool 13: Template for Risk Assessment and
Management during SEA Investigations). If risks are substantial, organizations should
develop more robust protection plans. It is important for organizations to review their
risk assessments (and protection plans) regularly as the situation may be evolving.
 Follow up on investigation outcomes, including through the following actions:
34
UNICEF/UNODC, Handbook for Professionals and Policymakers on Justice Matters involving Child Victims and Witnesses of
Crime, Criminal Justice Handbook Series, UN, New York, 2009, as well as its child-friendly version)

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o Make the outcomes of the investigation available to the survivor and accused
party and follow up with them to find out if they require additional psychosocial
or other support (see Section 6.2: Assistance and Referrals).
o In case a complaint is substantiated, take appropriate disciplinary actions against
the perpetrator that corresponds to the severity of the offense committed,
ranging from a written reprimand to dismissal. Update personnel files of the
perpetrator accordingly and share relevant information with potential employers
as part of their background checks to the extent legally possible.35
o Report the case to relevant local law enforcement authorities, including the
police and/or judicial authorities, and, if the case concerns a child, relevant child
protection institutions, as needed and where considered appropriate by the
organization and when possible, the survivor.36
o Use investigation reports to identify institutional weaknesses in preventing and
responding to PSEA that require changes in the organization’s policies,
procedures and staffing (see Section 4.2.3 Accountability).

7.3. Involvement of UNICEF in Investigation Process

UNICEF requires its partners to “properly and without delay investigate allegations of sexual
exploitation and abuse… by (their) employees, personnel, or subcontractors” based on its own
obligations under the UN Protocol on SEA Allegations Involving Implementing Partners. In order
to “determine whether the partner has taken appropriate investigative and corrective actions”,
partners should “keep UNICEF informed during the conduct of the investigation, without
(violating) due process rights of any persons involved.” 37
Upon completion of the investigation, partners should also “promptly provide reports on the
outcome of the investigations” and if requested, share “any relevant details… and evidence…
for examination and further use by UNICEF” to the extent legally possible. 38 In cases where
competent national authorities are conducting (or have conducted) the investigation, UNICEF
may relieve the partner of its contractual obligation to conduct an internal investigation. In
those cases, partners should support UNICEF in obtaining information on the status and
outcome of the investigation to the extent legally possible. 39
Partners should confidentially share this information with the UNICEF head of office in country
or the UNICEF Director, Office of Internal Audit and Investigation ([email protected]) in a
35
For example, the inter-agency misconduct disclosure scheme adopted by the Steering Committee for Humanitarian Response
(SCHR) establishes a minimum standard for organisations to share information as part of their recruitment process about
people who have been found to have committed sexual abuse, sexual exploitation or sexual harassment “misconduct” during
employment. https://www.schr.info/the-misconduct-disclosure-scheme
36
See footnote above regarding “referral to local law enforcement agencies”
37
PCA, para. 14.5
38
PCA, para. 14.5
39
PCA, para. 14.5

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manner that assures the safety of all involved.

7.4. Additional Resources

Complaints and investigation processes
 IASC, Model Complaints and Investigation Procedures and Guidance Related to SEA
(Draft), 2004.
 IASC, Guidelines to Implement the Minimum Operating Standards for PSEA, March 2013.
 IASC, Fund for Investigations into Sexual Exploitation, Abuse, and Sexual Harassment, April
2019
 Keeping Children Safe, Management of Child Safeguarding Allegations, 2016.
 WHO, Ethical and safety recommendations for researching, documenting and
monitoring sexual violence in emergencies, 2007.
 CHS Alliance, Investigation of Cases of Sexual Exploitation and Abuse by Aid Workers:
Challenges and Recommendations, Background paper to 2016 CHS Alliance PSEA
Conference 5-6 September 2016: Bangkok, Thailand.
 CHS Alliance, Guidelines for Investigations - A guide for humanitarian organisations on
receiving and investigating allegations of abuse, exploitation, fraud or corruption by
their own staff, 2006 (revised in 2015).
 International Council of Voluntary Agencies (CVA), Building Safer Organisations:
Training materials on receiving and investigating allegations of abuse and exploitation
by humanitarian workers, 2007.

Investigations involving child survivors and witnesses

 UNICEF/UNODC, Handbook for Professionals and Policymakers on Justice Matters

involving Child Victims and Witnesses of Crime, Criminal Justice Handbook Series, UN,
New York, 2009, as well as its child-friendly version).

38
8. Toolkit
Tool 1: Sample Template for Action Plan on PSEA
ACTION PERSON REQUIRED/AVAILABLE TARGET DATE FOR STATUS
RESPONSIBLE RESOURCES (e.g. financial, COMPLETION (i.e. not started/in
HR, logistics) progress/completed)

Core Standard 1: Organizational Policy

An organizational policy on PSEA exists and
describes appropriate standards of conduct,
other preventive measures, reporting,
monitoring, investigation and corrective
measures. (see: PSEA Toolkit Section 4.2.1.
Policies).

Example 1: Revise HR Policy to include definition of Ginia n/a 30 March 2019 In progress
SEA; standards of behaviour; & zero tolerance of
SEA;

Example 2: Revise code of conduct to include Ahmed n/a 30 March 2019 In progress
specific aspects related to SEA

Example 3: xxx

Core Standard 2: Organizational Management

and HR Systems
The organization’s management and HR systems
account for PSEA by:
1: The organization’s contracts and partnership
agreements include a standard clause requiring
PSEA Toolkit
1 April 2020
ACTION PERSON REQUIRED/AVAILABLE TARGET DATE FOR STATUS
RESPONSIBLE RESOURCES (e.g. financial, COMPLETION (i.e. not started/in
HR, logistics) progress/completed)

contractors, suppliers, consultants and sub-

partners to commit to a zero-tolerance policy on
SEA and to take measures to prevent and
respond to SEA, and
2: There is a systematic vetting procedure in
place for job candidates (e.g. reference checks,
police records, Google searches) in accordance
with local laws regarding employment, privacy
and data protection, including checking for prior
involvement in SEA or other safeguarding
concerns.
(see : PSEA Toolkit Section 4.2.2. Procedures).

Example 4: Revise templates for partnership Severine n/a 31 May 2020 Not started
agreement and service contract to include clause
on PSEA

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ACTION PERSON REQUIRED/AVAILABLE TARGET DATE FOR STATUS
RESPONSIBLE RESOURCES (e.g. financial, COMPLETION (i.e. not started/in
HR, logistics) progress/completed)

Core Standard 3: Mandatory Training

Required 1: The organization holds mandatory
trainings for all personnel on the organization’s
SEA policy and procedures and can provide
documentation evidencing regular training, and
Required 2: The training includes 1) a definition
of SEA (that is aligned with the UN's definition);
2) a prohibition of SEA; and 3) actions that
personnel are required to take (i.e. prompt
reporting of allegations and referral of survivors).
(see: PSEA Toolkit Section 4.3.1. Training).

Example: Develop full day face to face PSEA Ginia to hire Required $1000 31 May 2020 Not started
training package, meeting criteria described in consultant
section 4.3.1

Example: Revise Orientation Package for new staff Alfonso n/a 30 April 2020
to include requirement for PSEA training

Example: Include PSEA Refresher training in annual Chief, HR n/a 31 January 2020
all staff retreat as standing agenda item

Core Standard 4: Reporting

The organization has mechanisms and
procedures for personnel, beneficiaries and
communities, including children, to report SEA
allegations that comply with core standards for
reporting (i.e. safety, confidentiality,

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ACTION PERSON REQUIRED/AVAILABLE TARGET DATE FOR STATUS
RESPONSIBLE RESOURCES (e.g. financial, COMPLETION (i.e. not started/in
HR, logistics) progress/completed)

transparency, accessibility) and ensures that

beneficiaries are aware of these.
(see PSEA Toolkit Section 4.3.2. Awareness-
raising and Section 5.2. Reporting Mechanisms).

Example 8: Design, translate and widely Sophie Required: $1500 1 May 2019 Not started
disseminate awareness-raising and reporting (translation, design,
mechanisms posters in all work sites printing)

Available: $300
(translation)

Core Standard 5: Assistance and Referrals

The organization has a system to ensure
survivors of SEA, including children, receive
immediate professional assistance, referring
them to relevant service providers.
(see PSEA Toolkit Section 6.2. Assistance and
Referrals).

Example 9: Using Tool 10 as template, develop Innocent n/a 15 January 2019 Completed
Referral Form

Example 10: Advocate for local PSEA Network to Susan n/a 31 March 2020 Not started
develop Contact List of qualified Service Providers
for referrals for use by all NGOs in sector

Core Standard 6: Investigations

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ACTION PERSON REQUIRED/AVAILABLE TARGET DATE FOR STATUS
RESPONSIBLE RESOURCES (e.g. financial, COMPLETION (i.e. not started/in
HR, logistics) progress/completed)

The organization has a process for investigation

of allegations of SEA and can provide evidence
that it has appropriately dealt with past SEA
allegations, if any, through investigation and
corrective action. (see PSEA Toolkit Section 7.2.
Investigation Procedures).

Example 11: Adapt and adopt Tools 11, 12, and 13 Julius n/a 30 April 2020 In progress
for Investigations

Example 12: Apply to IASC, Fund for Investigations Magnano n/a As required For future use
into Sexual Exploitation, Abuse, and Sexual
Harassment, April 2019 for any future
investigations

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Tool 2: Sample Template for PSEA Policy 40

Policy title: Protection from Sexual Exploitation and Abuse

Policy objective: To promulgate policy of zero tolerance for sexual exploitation and abuse (SEA) for all [Organization] employees and related
personnel and ensure that roles, responsibilities and expected standards of conduct in relation to SEA are known within [Organization]. To create
and maintain a safe environment, free from SEA, by taking appropriate measures for this purpose, internally and in the communities where
[Organization] operates, through robust prevention and response work.
Targeted Audience: All [Organization] employees and related personnel.
Effective Date: xx.xx.xxxx
Mandatory Revision Date: xx.xx.xxxx

1. Policy statement:
1.1. SEA violates universally recognized international legal norms and standards and are unacceptable behaviors and prohibited conduct for
all humanitarian workers, including Organization] employees and related personnel. 41
1.2. [Organization] has a policy of zero tolerance towards SEA. All [Organization] employees and related personnel 42 are expected to uphold
the highest standards of personal and professional conduct at all times, and to provide humanitarian assistance and services in a manner that
respects and fosters the rights of beneficiaries and other vulnerable members of the local communities.

2. Scope of application:
2.1. This policy sets out [Organization] approach to prevent and respond to SEA. The policy applies to all employees and related personnel,
both on-and off-duty.

3. Definitions43:
3.1. For the purposes of the present policy the term ‘sexual exploitation’ means 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.
40
Template developed by UNFPA
41
UN Secretary General’s Bulletin ST/SGB/2003/13, 2003. https://undocs.org/en/ST/SGB/2003/13
42
The term “related” personnel include, for example, sub-contractors, consultants, interns or volunteers associated with or working on behalf of the [Organization].
43
Both definitions are adopted from the Secretary General’s Bulletin ST/SGB/2003/13, 2003. https://undocs.org/en/ST/SGB/2003/13

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3.2. Similarly, the term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under
unequal or coercive conditions.

4. Commitment to PSEA:
4.1. [Organization] will make every effort to create and maintain a safe environment, free from SEA, and shall take appropriate measures for
this purpose in the communities where it operates, through a robust PSEA framework, including prevention and response measures.
4.2. This PSEA framework, affirms [Organization] commitment to the UN Secretary General’s Bulletin on Special Measures for protection from
sexual exploitation and sexual abuse (ST/SGB/2003/13) and to achieving full, ongoing implementation of the IASC Six Core Principles relating
to SEA44.

5. Six core principles45:

5.1. SEA by [Organization] employees and related personnel constitute acts of gross misconduct and are therefore grounds for termination of
employment46.
5.2. 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 defense.
5.3. 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 exchange of assistance that is due to beneficiaries.
5.4. Any sexual relationship between [Organization] employees or related personnel and beneficiaries of assistance or other vulnerable
members of the local community that involves improper use of rank or position is prohibited. Such relationships undermine the credibility
and integrity of humanitarian aid work.
5.5. Where an [Organization] employee or related personnel 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 reporting mechanisms.
5.6. All [Organization] employees and related personnel are obliged to create and maintain an environment which prevents SEA and
promotes the implementation of this policy. Managers at all levels have particular responsibilities to support and develop systems which
maintain this environment.
6. PSEA framework:
6.1. Prevention:
6.1.1. Vetting: [Organization] systematically vets all prospective job candidates in accordance with established screening procedures.

44
IASC Six Core Principles; available at: https://interagencystandingcommittee.org/inter-agency-standing-committee/iasc-six-core-principles-relating-sexual-exploitation-and-
abuse.
45
Modified for the purposes of this PSEA policy. These acts are not intended to be an exhaustive list.
46
Including all other forms of contractual agreements, such as for example volunteer assignment.

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6.1.2. Training: [Organization] holds mandatory induction and refresher trainings 47 for all employees and related personnel on the
Organization’s SEA policy and procedures.

6.2. Response:
6.2.1. Reporting: [Organization] has safe, confidential and accessible mechanisms and procedures for personnel, beneficiaries and
communities, including children, to report SEA allegations that and ensures that beneficiaries are aware of these.
6.2.2. Investigation: [Organization] has a process for investigation of SEA allegations in place and shall properly and without delay conduct
an investigation of SEA by its employees or related personnel or refer to the proper investigative body if the perpetrator is affiliated with
another entity.
6.2.2.1. Referral to National Authorities: If, after proper investigation, there is evidence to support allegations of SEA, these cases may
be referred to national authorities for criminal prosecution.
6.2.3. Victim assistance: [Organization] has a system to promptly refer SEA survivors to available services, based on their needs and
consent.
6.3. Cooperative arrangements:
6.3.1. All [Organizations] contracts and partnership agreements include a standard clause requiring contractors, suppliers, consultants
and sub-partners to commit to a zero-tolerance policy on SEA and to take measures to prevent and respond to SEA.
6.3.2. The failure of those entities or individuals to take preventive measures against SEA, to investigate allegations thereof, or to take
corrective action when SEA has occurred, shall constitute grounds for termination of any cooperative arrangement.

47
The training includes at a minimum: 1) a definition of SEA (that is aligned with the UN's definition); 2) a prohibition of SEA; and 3) actions that employees and related
personnel are required to take (i.e. prompt reporting of allegations and referral of survivors).

46
Tool 3: Sample Roles and Responsibilities on PSEA
Note: Organizations are strongly encouraged to integrate PSEA-related roles and responsibilities into
their personnel’s existing terms of references, particularly if their involvement is more substantial (e.g.
PSEA focal point).
Personnel Sample Roles and Responsibilities
Management  Provide oversight of PSEA prevention and response
 Review and update PSEA-related policies and guidance
 Ensure attention and resources to PSEA across the organization
 Facilitate and oversee investigations of SEA allegations
 Coordinate with other organizations on PSEA, including donors
PSEA Focal  Support senior management to meet their PSEA-related responsibilities
Point
 Report concerns or issues with PSEA implementation to senior management
(in coordination
with  Receive reports of SEA allegations and coordinate the response
gender/GBV/CP
personnel where  Conduct training and awareness-raising of personnel and others on PSEA
available)
 Coordinate with other relevant actors on PSEA, including inter-agency efforts
Human  Conduct screening for past SEA violations, and other code of conduct and policy
Resources violations (e.g. fraud, corruption, abuse of power), as part of recruitment process
 Ensure all personnel sign the organization’s code of conduct
 Integrate a PSEA clause in contract agreements, including when subcontracting
 Support communication with personnel during investigation of SEA allegations
 Keep PSEA-related documents of personnel on file, including signed codes of
conduct
All Personnel  Uphold the code of conduct and PSEA-related policies
 Actively participate in SEA-related trainings and awareness-raising efforts,
including support for dissemination of PSEA materials
 Report allegations of SEA through the designated reporting channels
 Participate in investigations of SEA allegations as appropriate
 Identify and mitigate/avoid SEA-related programme risks (particularly for
personnel involved in programming)
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Tool 4: Sample Terms of Reference (ToR) for PSEA Focal Point 48

Note: Organizations can adapt this sample ToR to include their organization’s mandate and mission,
commitments to PSEA and specific expectations for PSEA focal points within their organization. Where
possible, organizations should consider having at least two focal points in each office, including one
female and one male focal point.

Terms of Reference:
Protection from Sexual Exploitation and Abuse (PSEA) Focal Point

1. Background
[Include brief description of the organization’s commitment and policies on PSEA.]
1. Purpose
The purpose of the PSEA focal point is to have a designated staff member who supports senior
management in coordinating the development and implementation of PSEA policy and procedures.
2. Scope of Work
Key roles and responsibilities of PSEA focal points include:
Prevention
 Conduct periodic assessments of [name of organization]’s PSEA policies and practices and
suggest improvements to senior management.
 Conduct training and awareness-raising sessions on PSEA for all personnel on a regular
basis.
 Work with human resource and other relevant personnel (name other relevant personnel
working on related issues, e.g. gender, CP) on PSEA-related aspects, including ensuring that
all personnel sign the code of conduct and that screening for past SEA violations is a regular
part of the recruitment process.
 Facilitate awareness-raising campaigns with beneficiaries and local communities on the
definition of SEA, the standards of conduct expected of [name of organization]’s personnel,
and the various mechanisms for raising SEA allegations or concerns, including contact
details.
Reporting allegations of SEA
 Manage the development of internal procedures for personnel to report incidents of sexual

48
Adapted from various sample ToR, including Terms of Reference for in-country Network on Protection from Sexual
Exploitation and Abuse by UN/NGO/IGO Personnel, produced by the ECHA/ECPS UN and NGO Task Force on Protection from
Sexual Exploitation and Abuse, November 2008; Terms of Reference for Focal Points on Protection from Sexual Exploitation and
Abuse by individuals providing humanitarian services within the Syrian refugee emergency response Jordan, produced by PSEA
Network Jordan, March 2016.

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exploitation and abuse safely and confidentiality.
 Receive reports of SEA allegations and related information and coordinate the response
according to relevant procedures.
 Report concerns or issues with PSEA implementation to senior management.
Response to SEA allegations
 Once a complaint is received, coordinate [name of organization]’s response, including
referral of SEA survivors for immediate, professional assistance and referral of the case for
further investigations to [name of organization’s entity responsible for handling internal
investigations].
Other responsibilities
 Coordinate [name of organization]’s PSEA activities with relevant organizations, including
inter-agency initiatives, as appropriate.
 Support senior management in implementing other PSEA-related activities, as appropriate.
3. Competencies and Experiences
 Proven integrity, objectivity and professional competence
 Demonstrated sensitivity and knowledge of cultural and gender issues; experience in GBV
programming is preferred
 Fluent in [name of locally relevant language(s)]
 Demonstrated experience of working directly with local communities
 Proven communication skills
Upon appointment, the focal point will undergo organization-specific training on PSEA, as soon as
feasible.

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Tool 5: Checklist for PSEA-Sensitive Recruitment, Contracting and

Performance Management 49

Checklist for PSEA-Sensitive Recruitment, Contracting and Performance

Management
 Include a sentence in job announcements to notify candidates that background and reference
checks will be conducted and ethics is part of annual performance appraisals
 Require applicants to self-declare prior issues of sexual or other misconduct, termination of past
employment, criminal records, and concerns registered with government authorities regarding
contact with children, and to consent to the disclosure of any such information by their former
employers during verification of references
 Conduct background checks (e.g. police records, Google searches) and contact references to vet
for former misconduct in accordance with local laws regarding employment, privacy and data
protection
 Ensure gender-balanced interview panels during hiring processes and conduct gender neutral
interviews50
 Ask candidates interview questions about ethics and ethical dilemmas (e.g. What’s your idea of
an ethical organization? Tell me about a time when you faced an ethical challenge.)
 Require candidates to review and sign the code of conduct before being offered a contract
 Include a PSEA clause51 in employment contracts, including when subcontracting
 Outline disciplinary measures in the event of proven SEA allegations (e.g. termination of
contract)
 Include training in PSEA as part of onboarding process and provide refresher courses at regular
intervals during employment tenure
 Include adherence to code of conduct (e.g. participation in PSEA trainings) in performance
appraisals of staff
 Include in the performance appraisals of senior staff their effectiveness in creating and
maintaining an environment which prevents and responds to SEA
 Freeze professional advancement/recruitment opportunities of individuals under investigation
 In cases of confirmed misconduct, take robust disciplinary action (e.g. dismissal, suspension,
written censure or other administrative/corrective measures) and, where this involves possible
49
Based on IASC, PSEA-MOS, January 2016; IASC, Summary of IASC Good Practices: Preventing Sexual Exploitation and Abuse
and Sexual Harassment and Abuse of Aid Workers, May 2018.
50
Also see UNICEF Gender Balance Strategies and Tools, accessed July 8, 2019
51
Organizations can adapt the following language for the PSEA clause: “The Contractor shall take all appropriate measures to
prevent sexual exploitation or abuse of anyone by its employees or any other persons engaged and controlled by the
Contractor to perform any services under the Contract. Any breach of the provision by the Contractor shall entitle [name of
organization] to terminate the contract with immediate effect.”

50
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criminal conduct, consider reporting the incident to local law enforcement authorities 52
 Maintain an internal database documenting any disciplinary measures on personnel, including
dismissals, to avoid rehiring them at a later point in time
 Systematically share relevant information of personnel known to have committed SEA with
other potential employers during background checks, to the extent legally possible.

52
Organizations may choose not to refer a case to national law enforcement (see previous footnote on referral to local law
enforcement agencies)

51
Tool 6: Sample PSEA Training Agenda
Note: Organizations should modify this training agenda based on the specific audience.
ACTIVITY EST. TIME RESOURCES

INTRODUCTION

Welcome and introduction 15 min  Handout: Training agenda

 Introduction of trainer(s) and learners
 Overview of training agenda
 Expected learning outcomes

SESSION 1: UNDERSTANDING SEXUAL EXPLOITATION AND ABUSE

Presentation: Key definitions and concepts 15 min  Handouts: Copies of SG’s

Bulletin
 Definition of SEA
(ST/SGB/2003/13),
 UN Zero-Tolerance Policy on SEA
organization’s code of
 Roles and responsibilities of personnel in preventing and responding to SEA
conduct and other
relevant documents

Case scenarios: Is this SEA? 45 min

 Present practical scenarios and discuss which ones may be cases of SEA and why

Group exercise: Impacts of SEA 30 min

 Ask learners to identify the (potential) consequences of SEA on a) the survivor(s), b) the
community, c) the organization, and d) others

SESSION 2: TAKING ACTION AGAINST SEA

Presentation: Overview 20 min  Handout of relevant tools

of UNICEF’s PSEA Practical
PSEA Toolkit
1 April 2020
 Overview of responses to SEA (prevention, reporting, investigation and referral) Guide Toolkit for UNICEF
 Guiding principles (including survivor-centered approach) and Partners (e.g.
organizational self-
assessment, action plan
template, PSEA risk
assessment and
mitigation)

Group discussion: Prevention 45 min

 Discuss how to identify and mitigate risks of SEA in their context (What are warning signs?
Why are they ignored? What more can the organization do to prevent SEA?)

Presentation: Reporting 20 min  Handout with contact

information of reporting
 Mandatory reporting
channels and policy for
 How to report SEA allegations, including confidentiality issues and “the best interest of the
protecting whistleblowers
child”
and/or complainants
 Protections for those reporting SEA allegations
Presentation: Investigations 15 min
 Overview of investigation process
 Consequences for personnel if allegations are substantiated
 Responsibilities of personnel to fully participate in any investigation
Presentation: Assistance 10 min
 Service needs of survivors (and witnesses)
 Survivor-centered approaches and informed consent
 Referral pathways
CONCLUSIONS

Conclusions 20 min Feedback forms

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 Summary of key learnings
 Ask each learner to provide at least one answer to the question: “How do you plan to apply
what you just learned in your work?”
 Feedback on training

54
Tool 7: PSEA Risk Assessment and Management for Safe Programmes
Area Questions to Consider for Risk Assessment Possible Management strategy(ies)

Profile of  What is the demographic profile of the population in the  Adapt awareness-raising efforts on PSEA to meet
beneficiaries target areas (e.g. sex, age, education level, income level, specific needs of beneficiaries
household size, percentage of female- and child-headed
 Conduct targeted messaging campaigns for those
households, marriage age, religion, race/ethnicity, migration
groups that are highly susceptible to SEA
status, etc.)?
 What are some of their characteristics of the population
that may render individuals more susceptible to SEA? Which
groups are particularly vulnerable? 53

Profile of  Is there an adequate gender balance of personnel involved  Re-adjust gender balance of personnel involved in
personnel in programming, particularly of personnel directly engaging programming
with beneficiaries and local communities or responsible for
 Recruit additional female personnel involved in
recruitment?
programming as needed
 Have personnel been sufficiently vetted and trained in
 Conduct (refresher) training(s) on PSEA (e.g.
regards to PSEA?
annually), specifically focused on possible risks
associated with the specific programme
 Review HR files of personnel and conduct additional
screening to identify previous misconduct as needed

Programme  Does the programme create or exacerbate existing  Arrange periodic monitoring visits by someone in a
approaches imbalances between personnel and members of the management or programme oversight role
community?
 Change location(s) of distribution to make it more
 Does the programme involve direct interaction between public

53
For a list of at-risk groups, see pages 11-12 of the IASC, Guidelines for Integrating GBV Interventions in Humanitarian Action, September 2015. Also note that some individuals
may have overlapping vulnerabilities (e.g. adolescent girls, mothers with disabilities).
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personnel and beneficiaries, especially children?  Ensure that personnel wear visible forms of
identification (e.g. caps, vests, T-Shirts) when
 How are personnel delivering goods and services (i.e.
conducting programme activities and provide such
private/public, working in pairs/alone, gender-mixed)?
forms of identification where needed
 Do personnel wear visible forms of identification (e.g. caps,
 Restrict access of external visitors to programme
vests, T-Shirts) when conducting programme activities?
activities, to the extent possible
 Are external visitors allowed to attend programme activities
unaccompanied? Who is in charge of making these  Ensure that programme participants are regularly
decisions? informed of their rights, of expected behaviour of
personnel, and how to report concerns

Programme  Where do programme activities take place (camp, informal  Create a more secure environment at programme
context settlement, host community, rural/urban setting, etc.)? location (e.g. install lights, hire night guards)
What are specific risks associated with this location (e.g. lack
 Work with communities to adapt complaints
of availability of complaints mechanisms or service
mechanisms to meet their needs
providers, insecurity)?
 Ensure that beneficiaries are aware of and can
 What is the attitude of beneficiaries towards GBV concerns?
access inter-agency mechanisms for complaints in
How comfortable would beneficiaries be reporting SEA
the programme location(s)
concerns?
 Is there an inter-agency mechanism for community
feedback/complaints in this location?

56
Tool 8: Sample Programmatic Actions by Sector for Minimizing PSEA Risks
Note: Before taking any programmatic actions, organization should ensure that programme design reflects SEA risks (see “General prevention
and safety measures”). The following table outlines sample programmatic actions organizations can additionally take in distinct sectors to
minimize SEA risks and help connect survivors to appropriate care. For more examples, please see: IASC, Guidelines for Integrating GBV
Interventions in Humanitarian Action, September 2015).

SECTOR Sample Programmatic Actions

Child Protection  Work with GBV specialists to develop child/adolescent-friendly messaging on GBV (“safe/unsafe touch”, etc.) and
(CP) how to report abuse.
 Ensure adequate supervision and monitoring of family tracing and reunification activities, particularly when
children travel with personnel.
 Build capacity of community-based CP mechanisms on how to respond to GBV/SEA cases.
 Support the development and implementation of standard operating procedures (SOPs) that specifically address
how to manage GBV/SEA cases involving children.
 Support GBV service providers to ensure services are accessible and appropriate for children and adolescents.

Education  Assess the costs associated with school or vocational training (e.g. school fees/supplies, transportation) and
associated risks for exploitation.
 Minimize situations where a student’s advancement depends on a single teacher and ensure regular supervision
of school staff.
 Help ensure female students’ and teachers’ menstrual health and hygiene (MHH) needs are met, both to improve
school attendance and to reduce risk of sexual exploitation in exchange for MHH.
 Ensure students and school staff have access to reporting mechanisms and raise awareness on SEA risks in
schools.
 Include GBV and psychological first aid (PFA) in capacity-building plans for teachers and other school staff.

Health  Consider integrating GBV response services into existing health interventions (sexual and reproductive health,
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1 April 2020
antenatal services, etc.) to minimize stigma and increase accessibility.
 Work with GBV/CP/protection actors to identify and address potential barriers for survivors in accessing health services
(e.g. availability of private space for examination, presence of same-sex health workers).
 Coordinate with other health partners to address gaps in knowledge and equipment for providing GBV services to both
adult and child survivors.
 Ensure health workers understand mandatory reporting on SEA and can communicate their reporting obligations to
survivors; develop a system to enable health workers to access support from GBV/CP specialists, if needed.
 Train health services providers on survivor-centered approaches of working with GBV survivors, as needed, and set up
systems to protect confidential patient information.

Nutrition  Monitor challenges different beneficiaries (e.g. child-headed households, people with disabilities, etc.) are facing
in accessing services (e.g. registration, ration cards) and work with relevant organizations to address them.
 Consider co-locating nutrition services with a health facility and/or a women-friendly space to help facilitate
referrals for GBV/SEA survivors.
 Share information about available reporting and response mechanisms related to GBV/SEA during meetings with
beneficiaries and communities (e.g. mother-to-mother support group discussions).

Water, Sanitation  Assign women to roles that require direct interaction with beneficiaries and local communities (e.g. hygiene
and Hygiene promoters; latrine/bathing facility/water point monitors).
(WASH)
 Ensure women are adequately represented in WASH/ water point committees.
 In consultation with communities, especially women and children, identify access concerns and risks for different
beneficiaries related to WASH (e.g. water buckets that are too heavy for children; lighting in toilets, MHH).
 Monitor potential abnormal behavior in women and children’s behavior related to WASH (e.g. if it takes women
and children unusually long to collect water).

Communication  Work with other programmes to develop and disseminate SEA-related information materials for their respective
for Development beneficiaries (e.g. programme eligibility criteria, distribution procedures, reporting mechanisms, etc.).
(C4D)
 Support GBV/CP/protection actors to create simplified versions of the referral pathway for use in community

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outreach activities (e.g. use of locally-appropriate drawings or symbols).
 Work with GBV specialists to ensure that community-based complaints mechanisms respect global standards for
safe and ethical GBV data management and information sharing (e.g. confidentiality of incident data). 54

54
See WHO Ethical and safety recommendations for researching, documenting and monitoring sexual violence in emergencies

59
Tool 9: Sample Incident Report Form for SEA Allegations
This sample incident report form is intended for organizations’ internal reporting processes. If reports
are shared with UNICEF or others, this should be done confidentially and in a manner that assures the
safety of all involved (see Section 5.2. Reporting Mechanisms).

Sample Incident Report Form for SEA Allegations

CONFIDENTIAL: Please restrict access to this document and keep it stored safely (e.g. using passwords or
encryptions for computers and locking lock offices when unattended). Always use code names when referring to
individuals involved in the case, omit information that could reveal identities (e.g. date of birth, address, phone
number, description of unique physical traits) and keep information on the identity and personal details of
persons involved separate from incident and related reports.

1. Details on how, when, and by whom, the allegation was received:

2. Description of alleged incident, including dates, times and locations:
3. Description of alleged or suspected survivors (e.g. name, age, gender, ethnic origin/nationality,
specific needs):
4. Description of alleged or suspected perpetrators (e.g. name, age, gender, nationality, organizational
affiliation/position, previous record of misconduct):

5. Actions taken by organization in response to allegations to date (e.g. referral for assistance,
investigations, notification of UN/Host Government):

6. Actions taken by other organizations or entities (e.g. UN, Host Government) in response to the
allegation:

7. Requested support from partners (e.g. support for SEA survivors, investigations)

Report transmitted by:

Name: Contact info (email, phone):

Title: Date:
Tool 10: Sample Referral Form 55

REFERRAL FORM
CONFIDENTIAL: Please restrict access to this document and keep it stored safely.
Note: Please share copies of filled out referral forms with the survivor and receiving agency and keep a
copy for the organization’s internal records and follow-up.
Referring agency
Agency/org: Contact:

Phone: Email:

Location

Receiving agency
Agency/org: Contact:

Phone: Email:

Location

Survivor information
Name: Phone:

Address: Age:

Sex Nationality:

Language: ID number

If survivor is a minor (under 18)

Name of primary caregiver: Relationship to child:

Contact information for caregiver: Is child separated or unaccompanied?  Yes  No

Caregiver is informed about referral?  Yes  No (If no, explain)

Background Information/Reason for referral and services already provided

Has the survivor been informed of the referral? Has the survivor been referred to any other
organization?
 Yes  No (If no, explain below)
c Yes  No (If yes, explain below)

55
Adapted from: IASC Reference Group for Mental Health and Psychosocial Support in Emergency Settings, Inter-Agency
Referral Form and Guidance Note, 2017
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Services requested
 Mental Health Services  Protection Services  Shelter

 Psychosocial Support  Legal Assistance  Material Assistance

 Social Services  Education  Nutrition

 Medical Care  Livelihood Support  Support for children born as a

result of SEA

Please explain any requested services:

Consent to release information. (Read with survivor/ caregiver and answer any questions before s/he signs
below. Sign on behalf of survivor/caregiver if consent is given verbally and survivor/caregiver cannot sign.)
I, _______________________(survivor name), understand that the purpose of the referral and of disclosing this
information to ________________________(name of receiving agency) is to ensure the safety and continuity of
care among service providers seeking to serve the client. The service provider,______________ __(name of
referring agency), has clearly explained the procedure of the referral to me and has listed the exact information
that is to be disclosed. By signing this form, I authorize this exchange of information.

Signature of responsible party (survivor or caregiver if a child):

Date (DD/MM/YY):

Details of Referral
Any contact or other restrictions?  Yes  No (If yes, please explain below)

Referral delivered via:  Phone (emergency only)  E-mail  Electronically (e.g., App or database)  In
Person

Follow-up expected via:  Phone  E-mail  In Person. By date (DD/MM/YY):

Information agencies agree to exchange in follow up:

Name and signature of recipient: Date received (DD/MM/YY):

_____________________________________________________________________________________________
Tool 11: Sample Terms of Reference for Investigator of SEA Allegations 56

56
Adapted from: Scoping tool for Terms of Reference (adapted from SOS Children’s Villages International), included in: Keeping
Children Safe, Management of Child Safeguarding Allegations, 2016.

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Terms of Reference:
Investigator of SEA Allegations

1. Background
[Include brief description of the SEA allegation and other relevant information that may support the
investigation.]
2. Purpose and Objectives
The purpose of this investigation is to conduct a thorough, objective and effective investigation of the
above-mentioned reported SEA allegations and other related incidents, in accordance with
professional standards and best international practice.
Specific objectives are to:
1) Assess whether the allegations reasonably amount to SEA, and possibly, an offence under
national law;
2) Review evidence presented and gather further evidence that might support or undermine
the allegations;
3) Present a summary of the evidence and conclusions.
3. Scope of Work
Key deliverables are:
 Work plan, including detailed methodology of investigation (e.g. review of relevant
documents, site visit(s), interviews with relevant stakeholders)
 Recommended plan of actions for protecting survivors, witnesses, alleged perpetrators and
the organization during investigation process
 Investigation report, including
1) Executive Summary
2) Introduction
3) Allegations (i.e. listing all allegations; names of the organization’s policies/code of
conduct and laws potentially violated)
4) Investigative approach (e.g. interviews, review of documents)
5) Chronology of events
6) Analysis of evidence
7) Retaliation and protection risks (and steps taken to address them)
8) Analysis of adequacy of organization’s response to SEA allegation
9) Conclusions regarding evidence to substantiate or not the allegation(s)
10) Recommendations (including areas of improvement for the organization’s response
to PSEA)

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4. Key Required Skills and Experiences

 Experienced, reliable professional investigator with experience in dealing with highly sensitive
cases
 Trained in conducting interviews, including with children and people who experienced trauma
 Demonstrated sensitivity and knowledge to cultural diversity and gender issues, including GBV
experience if possible
 Fluent in relevant languages for interviews with personnel and other witnesses, including
(specify)
 Proven communication and organizational skills

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Tool 12: Sample Confidentiality Reminder Note for SEA Investigations

Confidentiality Reminder for SEA Investigations
You have been asked to provide assistance in an investigation of allegations of sexual exploitation or
abuse involving personnel that is currently being undertaken. You may be interviewed, asked to provide
documents, computer files and other records, or asked to assist in some other way. Internal
investigations are a key part of our organization’s commitment to preventing and responding to sexual
exploitation and abuse.
As a participant in an investigation, there are certain points you need to know:
1. Co-operate. You are encouraged to co-operate with the investigations and respond to all questions
and requests from investigators honestly and fully.
2. Keep it confidential. You must keep confidential the fact that an investigation is underway and
anything discussed with you as part of the investigation.
3. No retaliation. Our organization does not tolerate any type or threat of retaliation against anyone
who reports a violation or cooperates in an investigation.
4. Don't play detective. Do not try to carry out your own inquiries or exhort witnesses as this may
disrupt the ongoing investigation.
5. No obstruction. Never attempt to interfere with or obstruct an investigation.
Your compliance with these requirements is imperative. Violations can potentially result in severe
discipline up to and including discharge and referral to criminal charges.
Thank you very much for assisting the organization with its investigation. If you learn or remember
anything else that might be relevant to the investigation, or if you have any questions please contact
me.
Name:
Email:
Phone:
Mobile:

65
Tool 13: Template for Risk Assessment and Management During SEA Investigation 57

CONFIDENTIAL: Please restrict access to this document and keep it stored safely.

RISK ASSESSMENT MANAGEMENT

No. Who is at Identified risk(s) Likelihoo Previous measures to Additional mitigation By By when
risk? d of risk* manage risk(s) to date measures whom?

Exampl Survivor Alleged perpetrator Medium Verbal communication to Written warning to Anne By 5 March
e pressuring survivor to alleged perpetrator to alleged perpetrator 2019
withdraw allegations abstain from contact with regarding (immediately
survivor (3 February consequences of )
2019) continued contact

1. DRAFT

2.

3.

* High/Medium /Low

57
Adapted from Template of SOS Children’s Village, in: Keeping Children Safe, Management of Child Safeguarding Violations, 2016.
https://www.keepingchildrensafe.org.uk/how-we-keep-children-safe/capacity-building/resources/management-child-safeguarding-allegations