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ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
ImpactMojo 101 Series · Free Forever
Safeguarding
& PSEA
101
Protection from Sexual Exploitation, Abuse and Harassment in Development and Humanitarian Work — Policy, Reporting and Survivor-Centred Response
Do No HarmSouth Asia FocusDonor-Aligned107 SlidesFree Access
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
What this course gives you
Development and humanitarian work puts staff in positions of power over people who are often poor, displaced, or in crisis. That power can be abused. Safeguarding is how organisations make sure the help they offer never becomes a source of harm — and it is the responsibility of every staff member, not a specialist few.
  • Speak the language — safeguarding, PSEA, sexual exploitation, abuse, harassment, and the abuse of power that underlies them all.
  • Know the red lines — the code-of-conduct rules you must never cross with the people you serve.
  • Receive a disclosure well — using the survivor-centred approach, so a person who tells you is safer, not sorrier.
  • Report safely — through the right channels, protecting confidentiality and the person who came forward.
  • Build prevention in — safe recruitment, risk assessment, community complaint mechanisms and a speak-up culture.
One idea runs through everything: those who use aid to exploit rely on silence. Safeguarding replaces silence with clear standards, safe reporting and a survivor-centred response.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Who this is for — and how to read it
Who it is for
Every person connected to a development or humanitarian organisation in South Asia — field staff, drivers, volunteers, consultants, board members, partners and sub-grantees. Safeguarding duties do not stop at the office door or the payroll edge.
How to read it
Ten short parts, from definitions to standards to what to actually do when someone discloses harm. Read it before you start fieldwork, and revisit it when you take on new duties, partners or communities. It complements — never replaces — your own organisation’s policy and focal point.
A note on care. This subject touches real harm and real survivors. If any part is distressing, pause. The goal is not to alarm you but to make you a safe person to disclose to and a reliable person to report through.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
01
Part One
Orientation
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Why every staff member needs this — not just leads
Safeguarding failures rarely happen because an organisation lacked a policy. They happen because ordinary staff did not recognise a warning sign, did not know how to receive a disclosure, or did not report what they saw. Prevention lives in everyday behaviour, not in a document on a shelf.
  • You are the frontline — the person a survivor is most likely to tell is the staff member they already trust, not a distant hotline.
  • You hold power — deciding who gets on a beneficiary list, who receives cash, who is hired locally. Power is exactly what exploitation abuses.
  • You set the tone — what you tolerate, joke about, or stay silent about tells others what is acceptable.
  • You may be the only witness — a colleague’s inappropriate conduct in the field may be seen by you and no one else.
Safeguarding is not an add-on to your job. In work that touches vulnerable people, it is the job — the precondition for doing any good at all.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Safeguarding in one sentence
Safeguarding
The responsibility that organisations have to make sure their staff, operations and programmes do no harm to the people they work with — and do not expose them to abuse or exploitation.
It is a broad umbrella. Under it sit protection of children, protection of at-risk adults, and — the focus of much of this course — protection from sexual exploitation, abuse and harassment (SEAH). All of it flows from a single humanitarian principle: do no harm.
Not the same as security or HR alone. Safeguarding is about the people we serve and work alongside — it overlaps with child protection, gender-based-violence response, HR conduct, and duty of care, but it is bigger than any one of them.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
How this course is organised — the ten parts
PartWhat it covers
1 OrientationWhy safeguarding is everyone’s job; the language and the map
2 DefinitionsSafeguarding, PSEA, exploitation, abuse, harassment, abuse of power
3 Why it mattersOxfam Haiti, the sector reckoning, under-reporting, donor rules
4 StandardsIASC six core principles, the UN SG Bulletin, the CHS
5 Red linesZero tolerance, the code of conduct, ICT and imagery
6 Recognising & receivingSigns, disclosures, the survivor-centred approach, do & don’t
7 ReportingChannels, confidentiality, referral pathways, protection from retaliation
8 InvestigationFairness, outcomes, the Misconduct Disclosure Scheme
9 PreventionRisk assessment, safe recruitment, focal points, partners
10 In practiceWorked scenarios, mistakes, myths, FAQ, checklist
Your own organisation’s policy and code of conduct sit on top of these global standards, translating them into local rules and channels.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
A first glossary — terms you will meet
  • SEAH — Sexual Exploitation, Abuse and Harassment; the umbrella acronym for the harms this course addresses.
  • PSEA — Protection from Sexual Exploitation and Abuse (of the people we serve, by those who serve them).
  • Survivor — a person who has experienced sexual violence or exploitation; preferred to ‘victim’ for its emphasis on agency and recovery.
  • Disclosure — when someone tells you they have experienced or witnessed harm.
  • Focal point — the trained person in an organisation responsible for receiving and channelling safeguarding concerns.
  • Referral pathway — the mapped route to medical, psychosocial, legal and safety services for a survivor.
  • Duty bearer / power holder — anyone whose role gives them authority over an affected person.
Each term is unpacked in full in the parts that follow — this is a map, not the territory.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Safeguarding protects two overlapping groups
The people we serve
Beneficiaries, affected communities, children, and at-risk adults who come into contact with our programmes. Protecting them from exploitation and abuse by staff is PSEA. The power imbalance is stark: we hold the aid they need.
The people we work with
Our own staff, volunteers and partners — protected from sexual harassment and abuse by colleagues in the workplace. The power imbalance here is between coworkers, managers and juniors.
Both matter, and they are different. The distinction between PSEA (harm to affected populations) and SH (harm between staff) shapes which policy, channel and response applies — we return to it in Part 2.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
The idea at the centre: power
Strip away the acronyms and safeguarding is about one thing: the abuse of unequal power. An aid worker deciding who eats, a manager holding a career, an adult before a child — each gap in power can be used to coerce, exploit or silence.
The reframe
“Was there consent?” is the wrong first question. “Was there a power imbalance?” is the right one.
When one person controls another’s access to food, shelter, medicine, a job or a grade, apparent ‘consent’ cannot be freely given. This is why sexual relationships with beneficiaries are prohibited regardless of what either party says.
Hold this lens through every rule that follows. The red lines are not arbitrary — each closes off a way that power over vulnerable people can be turned into sexual gain.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Why we say ‘survivor’ and choose words with care
  • Survivor, not victim — centres the person’s strength and recovery, not only the harm done to them (use ‘victim’ only where a legal or clinical context requires it).
  • Alleged, until proven — refer to a ‘subject of concern’ or ‘alleged perpetrator’; fairness to all parties is a safeguarding principle, not a loophole.
  • Believe, do not judge — receiving a disclosure is not investigating it; your job is to listen and refer, not to decide truth.
  • No blaming language — never ask what someone wore, drank or did to ‘invite’ harm; the responsibility is always the perpetrator’s.
Words are part of safety. The language we use signals whether it is safe to disclose. Careless words close mouths that a careful word would open.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
The mindset to carry into the rest of this course
  • It can happen here. “Not in our organisation” is exactly the belief that lets it continue. Assume risk exists and manage it.
  • Prevention beats response. Every rule is designed to stop harm before it occurs, not just to clean up after.
  • Reporting is loyalty, not betrayal. Protecting the mission means protecting the people it serves — even from a colleague.
  • Confidentiality protects survivors, not perpetrators. Discretion about a survivor’s identity is sacred; silence that shields an abuser is complicity.
  • You are not alone. You are one link in a system — focal points, investigators and referral services carry the rest.
Keep these five in mind. The technical content that follows only works if the underlying attitude is right.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
02
Part Two
Definitions
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Safeguarding — the widest circle
Safeguarding
The set of policies and practices by which organisations protect the people they work with — staff, beneficiaries and communities — from harm caused by their own personnel, operations or programmes; and act promptly when harm is alleged.
  • Prevent — reduce the chance of harm through vetting, training, codes of conduct and risk assessment.
  • Report & respond — make it safe to raise concerns, and respond in a survivor-centred way.
  • Learn — investigate, hold people accountable, and change systems that let harm occur.
Safeguarding covers all forms of harm — physical, emotional, neglect, exploitation — but this course concentrates on the sexual harms grouped as SEAH, where the sector’s failures have been gravest.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
PSEA — protecting the people we serve
PSEA — Protection from Sexual Exploitation and Abuse
The measures organisations take to protect the populations they serve from sexual exploitation and sexual abuse committed by their own staff, volunteers, partners and associated personnel.
PSEA is the humanitarian sector’s specific term for one direction of harm: by an aid worker, against an affected person. It was formalised by the UN in 2003 after abuses by aid workers in West Africa, and sharpened after 2018.
Note the direction. PSEA is not about a beneficiary harming a staff member, nor primarily about staff-on-staff harm. It is about the unique betrayal of an aid provider exploiting the very people the aid is meant to help.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Sexual exploitation — the UN definition
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.
— UN Secretary-General’s Bulletin, ST/SGB/2003/13, Section 1
  • Exchange sex for aid — demanding sex to add someone to a beneficiary list, release rations, or approve a grant.
  • Transactional sex with an affected person, even ‘paid’ — the vulnerability makes it exploitation.
  • Trafficking or facilitating the sexual exploitation of others in the community.
The defining feature is the abuse of a power gap, not the presence or absence of force. Money changing hands does not make it acceptable — it is precisely the exchange that the definition prohibits.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Sexual abuse — the UN definition
The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.
— UN Secretary-General’s Bulletin, ST/SGB/2003/13, Section 1
  • Rape and attempted rape — the gravest form, and a serious crime under national law.
  • Sexual assault — any unwanted sexual contact or intrusion.
  • Coerced sexual acts — where ‘consent’ is extracted through threat, deception or the abuse of unequal conditions.
Exploitation vs abuse. Sexual exploitation abuses a position of power or trust for sexual purposes; sexual abuse is the physical intrusion itself. They often occur together, and both are serious misconduct — and usually crimes.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Sexual harassment — usually staff-to-staff
Sexual harassment
Any unwelcome sexual advance, request for sexual favour, or verbal, non-verbal or physical conduct of a sexual nature that creates an intimidating, hostile or offensive environment — typically in the workplace, between colleagues.
  • Verbal — sexual comments, jokes, propositions, repeated unwanted attention.
  • Non-verbal — leering, sexual images, suggestive messages.
  • Physical — unwanted touching, blocking, assault.
  • Quid pro quo — linking a promotion, contract or grade to sexual compliance.
In India, workplace sexual harassment is governed by the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (the ‘PoSH Act’), which requires an Internal Committee in every eligible workplace.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Abuse of power — the engine of it all
Every category above shares one root: someone with more power — over aid, over a job, over a body — uses it for sexual ends. Naming the power imbalance is what makes safeguarding coherent.
Positional
Control over aid, lists, cash, services, hiring
Relational
Trust, status, age, gender, information
Situational
Crisis, displacement, dependence, isolation
Why ‘consent’ is not enough. Where power is this unequal, agreement can be coerced without a single threat being spoken. The rules therefore prohibit the conduct outright, rather than asking whether a vulnerable person ‘agreed’.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
PSEA vs sexual harassment — the crucial difference
PSEA (SEA)Sexual harassment (SH)
Who is harmedAffected populations — beneficiaries, community, childrenStaff, volunteers, personnel — colleagues
Who causes itAid workers & associated personnelFellow personnel — peers, managers
Power gapProvider over recipient of aidWithin the organisation’s hierarchy
Typical policyPSEA policy, code of conduct, referral pathwaysAnti-harassment / PoSH policy, internal committee
Governing standardST/SGB/2003/13, IASC principles, CHSLabour law; in India, the PoSH Act 2013
Both are ‘SEAH’ and both are unacceptable. But the response systems differ — misfiling a beneficiary’s complaint into an HR process, or vice versa, can leave a survivor unprotected.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
The SEAH umbrella — how the terms fit
SE
Sexual Exploitation
+
SA
Sexual Abuse
+
SH
Sexual Harassment
=
SEAH
the whole umbrella
  • SEA (exploitation + abuse) targets affected people — the domain of PSEA.
  • SH (harassment) targets colleagues — the domain of workplace / PoSH policy.
  • SEAH is the combined acronym used by donors and standards bodies to cover all three at once.
You will see all these acronyms in donor contracts and policies. When in doubt, ask: who is being harmed, and by whom? — that tells you which part of the umbrella, and which response, applies.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Children — a special and absolute category
Child
Any person under the age of 18 — regardless of the local age of majority or age of consent — following the UN Convention on the Rights of the Child, which India ratified in 1992.
  • No consent is possible. A child cannot consent to sexual activity with an adult; the question of consent does not arise.
  • Mistaken age is no defence. Believing a child was older does not excuse the conduct (ST/SGB/2003/13).
  • Child safeguarding is its own discipline — covering abuse, neglect and exploitation of children in all programme contact.
In India, the Protection of Children from Sexual Offences (POCSO) Act, 2012 criminalises sexual offences against under-18s and imposes mandatory reporting duties — a legal layer on top of every safeguarding policy.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
At-risk adults — protection is not only for children
Safeguarding also protects adults who, because of circumstance or condition, are at heightened risk of harm and less able to protect themselves. In crisis and development settings, that includes a very large share of the people we serve.
  • People in crisis — displaced, disaster-affected, or dependent on aid for survival.
  • People with disabilities — who face higher rates of violence and greater barriers to reporting.
  • Women and girls — in contexts of entrenched gender inequality and gender-based violence.
  • Marginalised groups — Dalit, Adivasi, minority, LGBTQ+ and stateless people, who may distrust or be excluded from formal systems.
Vulnerability is not a fixed trait — it is created by situations. Our programmes can either reduce it or, through careless power, deepen it.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
03
Part Three
Why it matters
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Oxfam in Haiti — the case that changed the sector
After the catastrophic 2010 Haiti earthquake, senior Oxfam staff working on the relief response used sex workers — including at premises paid for by the charity — amid concerns that some may have been under-age. An internal 2011 inquiry led to dismissals and resignations, but the conduct was not made public at the time.
2010–11
Misconduct during the post-earthquake response
Feb 2018
The Times exposes the story publicly
The Times, 2018
Jun 2019
UK Charity Commission publishes its inquiry report
Charity Commission for England & Wales
The scandal was not only the abuse itself but the handling — a flawed investigation, and too little done to establish whether minors were involved. Cover-up compounded harm.
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What the sector learned in 2018
The Oxfam revelations triggered a wave of disclosures across the aid world and a hard, public reckoning. Governments, donors and agencies accepted that SEAH was not a few bad apples but a systemic failure of culture, accountability and power.
  • Parliamentary scrutiny — the UK International Development Committee held an inquiry into sexual exploitation and abuse in the aid sector.
  • A global summit — donors and agencies met at the London Safeguarding Summit (October 2018) and made concrete commitments.
  • New mechanisms — the Misconduct Disclosure Scheme was launched to stop abusers moving quietly between organisations.
  • Donor conditions — safeguarding capacity became a condition of funding, not an optional extra.
The Charity Commission’s conclusion became a sector motto: “No charity is more important than the people it serves or the mission it pursues.”
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Do no harm — the foundation stone
The first responsibility of anyone offering help is to ensure that their help does not become a new source of harm.
— The humanitarian ‘do no harm’ principle
Aid arrives in moments of acute need and dependence. That is exactly what makes it a vector for exploitation if it is not safeguarded. An aid worker who abuses this position betrays not only the survivor but the entire premise of the work.
Safeguarding operationalises do-no-harm. It is the concrete answer to a simple question: how do we make sure the people we came to help are never harmed by us?
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The power imbalance at the heart of it
Development and humanitarian settings concentrate power in the hands of providers. A family may depend on a single ration card, a single cash transfer, a single decision by a field officer. That dependence is the raw material of exploitation.
What the provider holds
Food, water, shelter, cash, medicine, registration, jobs, information, and the discretion to grant or withhold them — often with little oversight in remote sites.
What the recipient faces
Survival need, displacement, loss of networks, language barriers, and fear that complaining will cut off the very aid they depend on.
This is why the rules are absolute rather than case-by-case. Where the power gap is this wide, prohibiting the conduct is the only reliable protection.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Why exploitation is so badly under-reported
  • Fear of losing aid — reporting the person who controls your rations feels like risking your family’s survival.
  • Fear of retaliation — from the perpetrator, their colleagues, or the community.
  • Stigma and shame — survivors may be blamed, ostracised, or seen as having dishonoured their family.
  • No safe or trusted channel — complaint mechanisms that are unknown, inaccessible, or not confidential.
  • Disbelief and power — a staff member’s word is often believed over a beneficiary’s.
  • Normalisation — where exploitation is common, survivors may not know it is wrong or reportable.
The reporting gap is not evidence of low prevalence — the opposite. Low numbers of reports usually mean unsafe channels, not the absence of harm. Silence is the perpetrator’s greatest ally.
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Why donors now demand safeguarding
Since 2018, major institutional donors treat safeguarding capacity as a precondition of funding. Weak safeguarding is now a fiduciary and reputational risk that funders actively screen for.
  • Policy & procedures — a written safeguarding and PSEA policy, code of conduct, and reporting mechanism.
  • Named responsibility — trained focal points and board-level accountability.
  • Safe recruitment — vetting, references and misconduct checks for staff and partners.
  • Flow-down clauses — the same standards contractually passed to every partner and sub-grantee.
  • Incident reporting — a duty to notify the donor of serious safeguarding incidents within set timelines.
For a South Asian NGO, this means safeguarding is not only an ethical duty but a practical condition of accessing international funding — and increasingly of domestic and CSR funding too.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
The cost of getting it wrong
Human cost — the one that matters most
Lasting trauma, physical harm, unwanted pregnancy, disease, exclusion and stigma for survivors and their families. This is irreversible and comes first in every calculation.
Organisational cost
Loss of donor funding and public trust, staff turnover, legal liability, and — for an NGO — the collapse of the community relationships that make any programme possible.
Oxfam responded to its crisis by tripling safeguarding investment, creating a dedicated Director of Safeguarding, and putting thousands of staff through mandatory training. The lesson is that prevention is far cheaper — in every currency — than the aftermath.
Never let organisational reputation be protected at a survivor’s expense. Reputational damage from abuse is real — but the damage from covering it up is always worse.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Why this matters especially in South Asia
  • Deep inequality — gaps of caste, class, gender and religion widen the power distance between staff and communities.
  • Recurrent crises — floods, cyclones, droughts and displacement create repeated moments of acute dependence on aid.
  • Large informal workforce — many field volunteers, daily-wage and community workers fall outside formal HR systems and training.
  • Strong stigma — norms around honour and sexuality make disclosure especially costly for survivors, particularly women and girls.
  • Distrust of formal systems — marginalised groups may fear police or authorities, narrowing safe reporting routes.
These realities do not make safeguarding impossible — they make locally designed, community-based and confidential complaint mechanisms essential rather than optional.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
From awareness to zero tolerance
01
Deny — ‘not here’
02
Acknowledge — it can happen
03
Prevent & respond — systems in place
04
Culture — safe to speak
‘Zero tolerance’ does not mean zero incidents — no honest organisation can promise that. It means zero tolerance of inaction: every concern is taken seriously, every report is acted on, and no seniority or usefulness buys anyone immunity.
The danger of ‘zero tolerance’ misread as ‘zero incidents’ is that it pushes problems underground. A mature organisation expects reports — a rising number of reports through safe channels is often a sign the system is working.
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04
Part Four
The standards & framework
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The safeguarding framework at a glance
InstrumentWhat it gives you
IASC Six Core PrinciplesThe six non-negotiable rules on SEA, adopted across the humanitarian system (2002, revised 2019)
ST/SGB/2003/13The UN Secretary-General’s Bulletin — the source definitions and prohibitions
Core Humanitarian StandardNine commitments on quality and accountability to affected people (2014, revised 2024)
Misconduct Disclosure SchemeAn inter-agency mechanism for sharing SEAH findings in recruitment (2019)
National lawe.g. India’s POCSO Act 2012 and PoSH Act 2013 — the binding legal floor
Your own organisation’s policy and code of conduct sit on top, translating these global standards into local rules and channels. The slides that follow unpack each.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
The IASC six core principles — part 1
In 2002 the Inter-Agency Standing Committee agreed six core principles on protection from sexual exploitation and abuse, revised in 2019. They are the humanitarian sector’s shared, non-negotiable baseline.
  • 1 · Gross misconduct. Sexual exploitation and abuse by humanitarian workers constitute acts of gross misconduct and are therefore grounds for termination of employment.
  • 2 · No sex with children. Sexual activity with children (persons under 18) is prohibited regardless of the local age of majority or consent. Mistaken belief in a child’s age is not a defence.
  • 3 · No exchange for sex. Exchange of money, employment, goods or services for sex — including sexual favours or other humiliating, degrading or exploitative behaviour — is prohibited. This includes assistance that is due to beneficiaries.
Source: IASC Six Core Principles Relating to Sexual Exploitation and Abuse, 2019 revision.
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The IASC six core principles — part 2
  • 4 · No relationships that abuse power. Any sexual relationship between those providing assistance and protection and a person benefiting from it that involves improper use of rank or position is prohibited — such relationships undermine the credibility and integrity of humanitarian work.
  • 5 · Duty to report. Where a worker develops concerns or suspicions about sexual abuse or exploitation by a fellow worker — whether in the same agency or not — they must report it through established mechanisms.
  • 6 · Duty to sustain the environment. Workers must create and maintain an environment that prevents sexual exploitation and abuse. Managers at all levels have particular responsibility to support and develop systems that maintain it.
Principles 5 and 6 make safeguarding active: it is not enough to refrain from harm yourself — you must report others’ harm and help build a culture that prevents it. Source: IASC, 2019.
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The UN Secretary-General’s Bulletin (ST/SGB/2003/13)
Issued in October 2003 after an inquiry into sexual exploitation of refugees by aid workers in West Africa, the Bulletin set the definitions and prohibitions that the whole sector now uses. It classifies SEA as serious misconduct for all UN staff and calls on partners to apply the same standards.
  • Section 1 — defines ‘sexual exploitation’ and ‘sexual abuse’ (the definitions in Part 2 of this course).
  • Section 3 — sets the prohibitions: gross misconduct, no sex with under-18s, no exchange for sex, relationships with beneficiaries strongly discouraged, duty to report, managers’ duty.
  • Section 4 — requires that these standards be extended to cooperating partners and contractors.
The Bulletin is the common ancestor of the IASC principles and most agency codes of conduct — when a policy cites ‘the SG Bulletin’, this is it.
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The Core Humanitarian Standard — nine commitments
The CHS (2014, revised 2024) sets out what quality and accountability to affected people look like. Its 2024 edition, shaped by consultation with more than 4,000 people across 90 countries, frames communities as active rights-holders. Safeguarding is woven throughout — most explicitly in the commitments on do no harm and safe complaints.
  • Communities can exercise their rights and participate in decisions that affect them.
  • They access timely, effective support matched to their needs and priorities.
  • They are better prepared and more resilient to future crises.
  • Support does not cause harm to people or the environment — the safeguarding commitment.
  • They can safely report concerns and complaints and see them addressed — the complaints commitment.
  • They access coordinated support — and organisations learn, are well-led and manage resources responsibly.
Source: Core Humanitarian Standard on Quality and Accountability, 2024 edition.
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CHS Commitment on complaints — safe and accessible
The CHS makes an accessible complaints mechanism a defining feature of a quality response — not a bureaucratic extra. If people cannot safely tell you when something is wrong, you cannot claim to be accountable to them.
  • Known — communities know the mechanism exists and how to use it, in their own language.
  • Accessible — multiple channels (in person, phone, box, third party) reachable by women, children and marginalised groups.
  • Safe & confidential — people can complain without fear, and sensitive complaints (including SEAH) are handled with special care.
  • Responsive — complaints are acknowledged, acted on, and the complainant is informed of the outcome where safe.
A complaint mechanism that does not explicitly welcome and safely route SEAH complaints will systematically miss them — because those are the complaints people are most afraid to raise.
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A mandatory-reporting culture
Under the IASC principles and virtually every agency code, reporting a safeguarding concern is not optional. If you know or suspect that a colleague or partner has committed SEAH, you are obliged to report it through your organisation’s mechanism.
  • Report suspicions, not just proof. You are not the investigator — you do not need certainty to raise a concern.
  • Cross-agency duty. The duty applies even if the person you are concerned about works for a different organisation.
  • Failure to report can itself be a disciplinary matter — silence is not neutral.
The tension to hold: a mandatory duty to report can sit uneasily with a survivor’s wish for confidentiality. The survivor-centred approach (Part 6) and referral practice (Part 7) exist precisely to navigate this — report the concern while protecting the survivor’s safety and choices.
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Organisational duty of care
To the people we serve
A duty to protect beneficiaries and communities from harm by the organisation’s own personnel — through policy, vetting, training, safe programming and functioning complaint channels.
To staff and volunteers
A duty to provide a workplace free from harassment and abuse, to support those who report, and to protect them from retaliation. Duty of care runs in both directions.
  • Leadership accountability — boards and senior managers own safeguarding, not just a junior focal point.
  • Resourcing — budgets, staff time and expertise, not just a policy PDF.
  • Continuous — the duty does not pause between incidents; prevention is ongoing.
Duty of care turns good intentions into an enforceable organisational responsibility — one that donors, regulators and courts increasingly hold organisations to.
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How the standards fit together
01
SG Bulletin — definitions & prohibitions
02
IASC principles — sector baseline
03
CHS — accountability to people
04
Your policy & code — local rules
The instruments are not competing rulebooks — they nest. The SG Bulletin supplies the definitions; the IASC principles turn them into shared conduct rules; the CHS embeds them in accountability to communities; and your organisation’s code translates all of it into the specific channels, focal points and consequences that apply where you work.
What binds you day to day is your own code of conduct and national law — but they draw their authority and content from these global standards.
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05
Part Five
The red lines & code of conduct
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Zero tolerance — what the red lines are
A code of conduct converts the standards into personal rules you agree to follow. The core prohibitions — the ‘red lines’ — are absolute: crossing them is serious misconduct, regardless of context, consent claims, or seniority.
  • No sexual activity with anyone under 18 — mistaken age is no defence.
  • No exchange of aid, money, jobs or services for sex — in any form.
  • No sexual relationships with beneficiaries — the power imbalance makes them exploitative.
  • No sexual harassment of colleagues, partners or community members.
  • A duty to report any concern about a colleague or partner.
The following slides take each red line in turn — because the difference between a policy that protects people and one that sits in a drawer is whether staff genuinely understand where the lines are.
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Never with a child — and age is no defence
The absolute rule
No sexual activity with any person under 18 — regardless of the local age of consent, and regardless of what you believed their age to be.
A child cannot consent to sexual activity with an adult. “They told me they were older” and “the local age of majority is lower” are explicitly not defences under ST/SGB/2003/13 and the IASC principles.
  • It is a crime, not only misconduct — in India, the POCSO Act 2012 applies, with mandatory reporting to authorities.
  • Reporting is legally required. Knowledge or suspicion of child sexual abuse must be reported under POCSO — failing to do so is itself an offence.
  • Programme contact counts. The rule covers all children reached through your work, not only registered beneficiaries.
If you are ever uncertain whether someone is over 18 in a work context, treat them as a child. There is no acceptable margin of error here.
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No transactional or exchange sex
Exchanging anything of value — money, employment, food, non-food items, transport, favours, or the assistance beneficiaries are already entitled to — for sex is prohibited. This is why many agency codes prohibit paying for sex outright while on duty or in programme areas, where such transactions overlap with vulnerable, aid-dependent populations.
  • ‘Paid’ does not make it acceptable. The power gap means the exchange is exploitation, not a fair transaction.
  • Withholding entitlements as leverage — delaying someone’s rations or registration to pressure them — is a grave form of this abuse.
  • Facilitating others’ exchange — arranging or turning a blind eye — also breaches the code.
This is the exploitation the West Africa and Haiti scandals exposed — aid, or the promise of it, traded for sex. It is the conduct the whole PSEA architecture was built to stop.
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No sexual relationships with beneficiaries
Sexual relationships between staff and beneficiaries … are based on inherently unequal power dynamics … and are strongly discouraged.
— ST/SGB/2003/13, Section 3.2(d)
Because the provider holds power over the recipient’s access to aid, a relationship between them cannot be assumed to be freely chosen. Many organisations go beyond ‘strongly discouraged’ and prohibit such relationships outright, or require immediate declaration and reassignment.
“But we’re in love” is not a safeguarding answer. The rule is not a judgement on feelings — it is a recognition that the power imbalance makes genuine consent impossible to verify. If a relationship arises, declare it and let the organisation manage the conflict of interest.
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Conflicts of interest — declare them
A conflict of interest arises when a personal relationship or interest could improperly influence — or appear to influence — a decision you make in your role, such as who is selected, hired, or served. In safeguarding terms, undeclared relationships are where exploitation hides.
  • Beneficiary selection — enrolling a relative, friend, or someone you have a relationship with.
  • Local hiring — recruiting community members you have personal ties to, especially into roles with power.
  • Procurement & cash — steering resources toward people you are connected to.
  • Dual relationships — being both a service provider and in a personal relationship with a recipient.
The rule is simple: declare, don’t decide. Disclose the connection to your manager and step back from the decision. Declaration protects you as much as it protects the community.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Gifts, favours and aid diversion
Gifts and favours seem minor but they are the on-ramp to exploitation — they create obligation, blur boundaries, and can be used to groom or to buy silence. Codes of conduct restrict them for exactly this reason.
From beneficiaries to staff
Accepting gifts, hospitality or favours from people who depend on your decisions creates a debt that can be called in later — and signals that access can be bought.
From staff to beneficiaries
Giving personal gifts, money or preferential treatment to selected individuals is a classic grooming pattern and a route to exchange-based exploitation.
Aid is not yours to grant as a favour. Diverting entitlements to favoured individuals — or withholding them as punishment — corrupts the fairness that keeps aid safe. Keep relationships professional and transparent.
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Safe use of ICT, phones and social media
  • No sexual or exploitative content — never use organisational or personal devices to access, create or share sexual material involving beneficiaries or children.
  • Boundaries in messaging — do not build private, unsupervised online relationships with beneficiaries, especially children; keep contact professional and, where possible, on official channels.
  • Online grooming — the same power dynamics operate online; digital contact is covered by the same red lines as in-person contact.
  • Data of survivors — never store, forward or discuss identifying details of a case on personal devices or informal chat groups.
The device is not a loophole. As programmes digitise — cash by phone, remote registration, WhatsApp helplines — safeguarding must follow. A message can exploit as surely as a meeting.
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Imagery & photography of the people we serve
Photographs and stories are powerful — and easily exploitative. Dignity, consent and child protection govern every image an organisation takes or uses.
  • Informed consent — explain how an image will be used, in a language the person understands, before taking it; they can decline without losing any assistance.
  • Children — obtain consent from the child and a parent or guardian; never publish identifying details that could put a child at risk.
  • Dignity, not pity — no degrading, sexualised, or humiliating portrayals; show people as agents, not objects of charity.
  • No private imagery — never take photos of beneficiaries for personal use, and never in private, medical or bathing settings.
Consent for a photo is not consent forever — respect requests to remove images, and store all imagery of children and survivors securely.
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The code of conduct — pulling it together
A code of conduct gathers the red lines into a single document that every staff member, volunteer, consultant and partner signs. Signing is not a formality — it is a personal, accountable commitment.
  • Signed on joining — and re-affirmed periodically, so it stays live, not filed and forgotten.
  • Applies everywhere — on and off duty in programme areas, online, and in every interaction with communities.
  • Binds partners too — sub-grantees and contractors sign equivalent standards (Part 9).
  • Carries consequences — breaches are disciplinary matters up to dismissal, and often criminal referral.
Know your own code. This course covers the shared standards, but the document that binds you is your organisation’s code and policy — read it, and ask your focal point about anything unclear before you are in the field.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Professional boundaries — the everyday version
Most safeguarding is not about dramatic red lines but about maintaining clear, consistent professional boundaries in ordinary interactions — the habits that keep power from tipping into abuse.
  • Meet transparently — avoid being alone with a beneficiary or child in a private setting; use open, visible spaces.
  • Keep contact professional — personal phone numbers, social media, home visits and one-to-one favours all need care.
  • Be consistent and fair — treat all beneficiaries equally; special attention to one person is a warning sign to yourself as much as to others.
  • Model it for others — junior staff and volunteers take their cues from how you behave.
The test. Ask: would I be comfortable if my manager, the community, and the survivor’s family saw exactly what I am doing? If not, don’t do it.
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06
Part Six
Recognising & receiving
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Signs and risk indicators to notice
Exploitation rarely announces itself. It shows up as patterns — in a colleague’s behaviour, in a beneficiary’s distress, or in how a programme is run. Noticing early can prevent harm.
In a colleague / power holder
Unexplained favouritism; private meetings with beneficiaries; controlling who accesses a person; secrecy; boundary-pushing ‘jokes’; unexplained gifts or spending; resistance to oversight.
In an affected person
Sudden fear, withdrawal or distress; avoiding a particular staff member; unexplained access to goods or money; signs of injury; a child’s changed behaviour; reluctance to be alone with someone.
Signs are not proof. They are prompts to pay attention and, where a concern crystallises, to report — not to accuse. Trust your unease enough to raise it through the proper channel.
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What a disclosure actually looks like
A disclosure is rarely a formal statement. It is more often a hesitant comment, a third-hand mention, or something noticed in passing. Recognising it as a disclosure — and responding well — is a core skill for every staff member.
  • Direct — a survivor tells you what happened to them.
  • Indirect / hinted — “a friend of mine…”, or a vague reference testing whether it is safe to say more.
  • Third-party — a community member, family member or colleague reports on someone’s behalf.
  • Behavioural — no words, but signs that prompt a gentle, safe opening.
A person may test you first with a small disclosure to see how you react. Your response to that first hint decides whether the full story is ever told. Treat every hint as important.
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The survivor-centred approach — four principles
Everything you do after a disclosure is governed by one framework: the survivor-centred approach. It puts the rights, needs and wishes of the survivor at the centre of every decision. It rests on four principles.
Safety
The survivor’s safety and security come first, at every step
Confidentiality
Share information only on a strict need-to-know basis, with consent
Respect
The survivor’s choices, wishes, rights and dignity guide all actions
Non-discrimination
Fair, equal treatment for every survivor, without judgement
These four principles — safety, confidentiality, respect, non-discrimination — are the standard across GBV and PSEA response. Memorise them; they resolve most dilemmas you will face.
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What survivor-centred means in practice
  • Believe and validate — take what you are told seriously; do not interrogate or demand proof.
  • Restore control — the survivor decides what happens next, at their pace; abuse takes away control, so your response must give it back.
  • Informed choice — explain the options and what each involves, including reporting, and let them choose.
  • Do no further harm — avoid actions that expose the survivor to retaliation, stigma or re-traumatisation.
  • Their safety over your process — if a step would endanger the survivor, pause and seek specialist advice.
The hard case: mandatory reporting duties can conflict with a survivor’s wish not to report. Be honest about what you must do, minimise information shared, prioritise safety, and seek guidance from your focal point — never promise absolute secrecy you cannot keep.
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Receiving a disclosure — DO
  • Find a private, safe space — where you will not be overheard or interrupted.
  • Listen calmly and patiently — let them tell it their way, in their own words and time.
  • Believe them — say clearly it was not their fault and you are glad they told you.
  • Respect confidentiality — explain who you may need to inform and why, before you do.
  • Ask what they need — and about their immediate safety.
  • Give honest information — about options and services, without pressuring a choice.
  • Refer to trained help — medical, psychosocial and specialist support (Part 7).
  • Record only the essentials — accurately, factually, and store securely.
You do not need to be an expert. Your job is to receive with care and connect the survivor to those who are — safely and without judgement.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Receiving a disclosure — DON’T
  • Don’t promise secrecy you cannot keep — be honest about your reporting duty from the start.
  • Don’t investigate — no probing questions, no gathering evidence, no confronting the alleged perpetrator; that is the investigator’s role.
  • Don’t judge or blame — never ask what they wore, did, or why they didn’t leave.
  • Don’t react with shock or disgust — your visible reaction can silence them.
  • Don’t force a decision — do not pressure them to report, to name someone, or to act before they are ready.
  • Don’t share the story — not with colleagues, not on chat groups, not with the community.
  • Don’t take photos of injuries or make them repeat the account unnecessarily.
The most common harm after a disclosure is caused by well-meaning responders who investigate, gossip, or over-promise. Restraint is part of care.
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Helpful things to say — and to avoid
Say something like thisNever say this
“Thank you for telling me. That took courage.”“Are you sure? That doesn’t sound like him.”
“What happened is not your fault.”“Why didn’t you say something sooner?”
“Your safety matters most. Are you safe right now?”“What were you wearing / doing there?”
“You decide what happens next. I’ll explain the options.”“You must report this to the police today.”
“I can’t keep this fully secret, but I’ll only tell those who need to know to help you.”“Don’t worry, I won’t tell anyone at all.”
“There are people trained to support you. May I connect you?”“Tell me exactly what he did, step by step.”
You do not need perfect words. Warmth, calm and honesty matter more than a script — a survivor remembers how safe you made them feel.
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When the survivor is a child
Disclosures involving children carry additional legal and ethical duties. The survivor-centred principles still apply, but a child’s best interests — and mandatory legal reporting — shape the response.
  • Best interests of the child guide every decision (UN CRC).
  • Mandatory reporting. In India, POCSO 2012 makes reporting child sexual abuse a legal obligation — you cannot keep a child’s disclosure of abuse confidential in the way an adult can request.
  • Be honest and age-appropriate — do not promise secrecy; explain simply what you must do next.
  • Do not interview — note what the child says spontaneously; specialist, trained interviewers handle the rest.
  • Involve guardians carefully — unless a parent or guardian may be the source of harm.
Child cases move faster and involve authorities sooner. Know your organisation’s child-safeguarding procedure and your legal reporting duty before you are ever in this situation.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
Looking after yourself — secondary trauma
Receiving disclosures of abuse is emotionally heavy. Responders can experience secondary or vicarious trauma — and a depleted responder cannot support survivors well. Self-care is part of the safeguarding system, not a luxury.
  • Debrief appropriately — with your focal point or supervisor, respecting confidentiality (share the impact on you, not identifying details as gossip).
  • Know your limits — you are a first responder and a bridge to services, not a counsellor or investigator.
  • Access support — staff care, supervision and peer support exist for a reason; use them.
  • Watch for signs — sleeplessness, numbness, intrusive thoughts, cynicism; take them seriously.
Organisations have a duty of care to responders too. A culture that supports its staff to receive disclosures well is one where more survivors are helped.
ImpactMojoSafeguarding & PSEA 101www.impactmojo.in
The first hours after a disclosure
01
Ensure immediate safety
02
Offer & arrange medical care
03
Refer to support with consent
04
Report through the channel
  • Safety first — is the survivor at ongoing risk from the perpetrator? Address that before anything else.
  • Time-sensitive medical care — some post-assault care (e.g. emergency contraception, HIV prophylaxis) is only effective within hours; offer referral urgently but never force it.
  • With consent — adult survivors choose which services and referrals proceed (child cases follow legal duties).
  • Then report — notify the focal point per your policy, sharing the minimum necessary.
Move with urgency on safety and health, and with patience on everything else — the survivor sets the pace of the rest.
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07
Part Seven
Reporting
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Safe and accessible reporting channels
People will only report if it is safe, known and possible to do so. A good reporting system offers multiple routes, because no single channel reaches everyone — women, children, people with disabilities and marginalised groups each need an accessible option.
  • Multiple channels — in person, phone hotline, complaint box, email, a trusted community member, or a partner agency.
  • Known — actively communicated to communities in their own languages, including for those who cannot read.
  • Accessible — reachable by the least-powerful; consider gender of the receiver, distance, cost and literacy.
  • Confidential — designed so that using them does not expose the complainant.
  • Independent option — a route that bypasses the person a complaint might be about.
A hotline that only works in English, only during office hours, and is answered by the district manager will never surface a complaint against that manager. Design channels for the people least able to use them.
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Confidentiality & protecting survivor information
Confidentiality is not secrecy that shields perpetrators — it is the disciplined protection of a survivor’s identity and information, shared only with those who genuinely need it to help, and only with the survivor’s informed consent where the law allows.
  • Need-to-know only — the fewest people possible, each with a clear reason.
  • No identifying details in emails, chat groups, shared drives or casual conversation.
  • Secure storage — case records locked or encrypted, access-restricted, and retained only as long as needed.
  • Consent to share — explain to the survivor who will receive information and why, before sharing.
  • Data protection law applies — e.g. India’s Digital Personal Data Protection Act, 2023 treats such data as highly sensitive.
A single careless breach — a name in a group chat, a file left open — can expose a survivor to retaliation and destroy trust in the whole system. Treat survivor information as the most sensitive data you hold.
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Referral pathways — the four kinds of help
PathwayWhat it provides
Medical / healthInjury treatment, emergency contraception, HIV/STI prophylaxis, forensic care — often time-critical
PsychosocialEmotional support, counselling, safe-space and community-based mental-health services
Legal / justiceLegal aid, information on rights and options, support to pursue a case if the survivor chooses
Safety / securityProtection from ongoing harm — safe shelter, relocation, removing the perpetrator’s access
Map it in advance. A referral pathway is only useful if it exists before you need it — know the nearest survivor-friendly clinic, One Stop Centre, counsellor, legal-aid contact and helpline for your area, and keep the list current.
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Making a referral well
A referral is only survivor-centred if it is done with the survivor’s consent, protects their information, and connects them to services that will treat them with the same care you did.
  • Informed consent to refer — explain each service and let the survivor choose which, if any, to accept (child cases follow legal duties).
  • Share the minimum — only the information the receiving service needs, with consent.
  • Warm handover where possible — accompany or actively connect, rather than handing over a phone number and hoping.
  • Follow up on safety — check the survivor reached help and is safe, without pressuring.
  • Know the quality of services — refer only to services you trust to be confidential and non-judgemental.
India’s One Stop Centres and the women’s helpline (181) and childline (1098) are common referral points — verify local availability and reliability before relying on any single one.
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Whistleblowing — raising concerns about the organisation
Whistleblowing is reporting wrongdoing — including safeguarding failures, cover-ups, or abuse by senior staff — in the public interest. It is distinct from a survivor’s disclosure: a whistleblower may be a staff member reporting what they have witnessed or suspect.
  • Protected act — good-faith reporting of concerns is protected; you should never be penalised for it.
  • Escalation routes — when the normal channel is compromised (e.g. the concern is about your manager), a whistleblowing policy provides an alternative, often confidential or external, route.
  • Good faith, not certainty — you need a genuine, reasonable concern, not proof.
  • Confidential handling — the whistleblower’s identity is protected as far as possible.
A functioning whistleblowing route is what stops another Haiti-style cover-up — it gives staff a safe way to speak when those above them are the problem.
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Protection from retaliation
Non-negotiable
No one who reports a concern in good faith — survivor, witness or whistleblower — should suffer any negative consequence for doing so.
Retaliation — dismissal, demotion, exclusion from aid, threats, ostracism — is itself a serious safeguarding violation, and a powerful signal to everyone else to stay silent.
  • Retaliation against a beneficiary — cutting off assistance to someone who complained — is grave misconduct.
  • Retaliation against staff — is a disciplinary offence and often unlawful.
  • Monitor after a report — actively check that the person who came forward is not being punished.
A single act of retaliation left unaddressed can undo years of trust-building. Protecting reporters is not an afterthought — it is what makes reporting possible at all.
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What to report — and to whom
What to report
Any concern, suspicion, allegation or witnessed incident of SEAH — whether about a colleague, a partner, a volunteer, or the way a programme is run. You do not judge whether it is ‘serious enough’; you report it.
To whom
Your safeguarding/PSEA focal point or the channel named in your policy. If the concern involves that person, use the alternative or whistleblowing route. Child abuse cases also trigger legal reporting duties (e.g. POCSO).
  • Report facts, not conclusions — what you saw or were told, not your theory of guilt.
  • Report promptly — delay can endanger the survivor and lose the chance to act.
  • Protect confidentiality — even in reporting, share only with those in the chain who need to know.
If you are unsure whether something crosses a line, report it and let the trained focal point decide. Under-reporting is the sector’s chronic failure — not over-reporting.
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Mandatory reporting vs the survivor’s wishes
The hardest dilemma in safeguarding: your organisation requires you to report SEAH, but an adult survivor may not want a report made. Both the duty and the survivor’s autonomy are real. Navigate, don’t ignore, the tension.
  • Be honest up front — explain your reporting duty before a survivor tells you everything, so they can decide how much to share.
  • Separate reporting from services — a survivor can accept medical and psychosocial help without a formal investigation proceeding, in most adult cases.
  • Report the concern, protect the person — safeguarding systems can often be alerted to a risk while limiting identifying detail and respecting the survivor’s safety choices.
  • Children are different — the child’s best interests and legal duties override a request for secrecy.
  • Seek guidance — your focal point exists precisely for these judgement calls.
Never resolve this by promising an adult survivor total secrecy you cannot deliver, and never by steamrolling their wishes. Honesty and specialist guidance are the way through.
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Reporting checklist
  • Is the survivor safe right now? Address immediate risk first.
  • Have I offered urgent medical care (with consent), given its time-sensitivity?
  • Do I know my reporting channel and focal point — and the alternative if the concern involves them?
  • Have I been honest with the survivor about what I must report and to whom?
  • Am I sharing the minimum necessary information, on a need-to-know basis?
  • Have I recorded the facts accurately — what was said/seen, dates, no assumptions — and stored it securely?
  • Have I avoided investigating — no questioning the alleged perpetrator or gathering evidence?
  • Have I referred to support services with consent?
  • Is the person who reported protected from retaliation?
  • For a child: have I followed child-safeguarding and legal reporting duties?
Keep this checklist accessible. In the moment, structure prevents the mistakes that good intentions alone do not.
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08
Part Eight
Investigation & accountability
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Who investigates — and how
Once a report is made, investigation is a specialist task — not something a manager or the person who received the disclosure improvises. Trained investigators establish the facts through a fair, confidential, documented process.
  • Trained & independent — investigators with no conflict of interest in the case; sometimes an external specialist.
  • Fact-finding, not prosecution — an administrative process to determine, on the balance of probabilities, whether misconduct occurred.
  • Documented & confidential — evidence gathered and stored securely, access tightly limited.
  • Survivor-centred throughout — minimising re-traumatisation, avoiding repeated interviews, respecting safety and dignity.
  • Separate from criminal justice — where a crime may have occurred, the survivor’s choice and legal duties determine referral to police.
If you receive a disclosure, your role ends at reporting and supporting — do not attempt to investigate yourself, however well-meaning. Amateur investigation destroys evidence, endangers survivors, and can void a fair process.
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Fairness to all parties
A survivor-centred process is not incompatible with fairness to the person accused. Both matter, and a credible system protects both — a rushed or biased process can leave a survivor without justice and an innocent person wrongly condemned.
For the survivor / complainant
Safety, confidentiality, respect, support throughout, protection from retaliation, and being kept informed of progress and outcome as far as possible.
For the subject of concern
To be treated as innocent until a finding is made, to know the allegation, to respond, and to a process free of bias — while any necessary interim safety measures are in place.
Interim measures are not punishment. Suspending or reassigning a subject of concern during an investigation protects the survivor and the process — it does not pre-judge guilt.
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Possible outcomes and discipline
Where an investigation substantiates SEAH, consequences follow — proportionate to the misconduct, and consistent, so that seniority or usefulness never buys immunity.
  • Disciplinary action — up to and including summary dismissal; SEA is defined as gross misconduct.
  • Criminal referral — where the conduct is a crime (e.g. rape, child sexual abuse), referral to police/authorities, respecting the survivor’s choices and legal duties.
  • Recorded for references — a substantiated finding is disclosed to future employers via the Misconduct Disclosure Scheme.
  • Systemic action — fixing the gaps (supervision, access, culture) that allowed the harm.
  • Notifying donors/regulators — serious incidents reported per contractual and legal duties.
Consistency is everything. An organisation that dismisses a junior offender but quietly reassigns a senior one has no safeguarding — only the appearance of it.
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Feedback and support to the survivor
  • Keep them informed — that the report was received, that action is being taken, and the outcome as far as confidentiality and fairness allow.
  • Continued support — access to medical, psychosocial and safety services does not end when the investigation ends.
  • No conditionality — support and continued assistance are never dependent on cooperating with an investigation.
  • Manage expectations honestly — explain what the process can and cannot deliver, and its limits, without false promises.
  • Respect their choices — including a decision not to pursue a case, within legal limits.
A survivor who reports and then hears nothing feels abandoned — and the community learns that reporting is pointless. Closing the loop, safely, is part of the duty of care.
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Information-sharing limits during a case
Investigations run on strict information discipline. The instinct to update colleagues, reassure the community, or explain a suspension must be resisted — loose information endangers the survivor, the process, and the rights of the accused.
  • Need-to-know only — details confined to those directly handling the case.
  • No naming — neither survivor nor subject of concern is named beyond the process.
  • No speculation — do not discuss theories, guilt or ‘what really happened’ with anyone.
  • Secure records — access-controlled files, careful email discipline, no chat groups.
  • Consistent line — if asked, staff say only that a matter is being handled through the proper process.
Over-sharing during an investigation is one of the most common ways organisations re-harm survivors and collapse otherwise sound cases. Discipline here is protection.
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The Misconduct Disclosure Scheme
Launched in January 2019 by the Steering Committee for Humanitarian Response (SCHR) and coordinated with the CHS Alliance, the Misconduct Disclosure Scheme stops abusers moving quietly between organisations — the ‘pass the trash’ problem the Haiti scandal exposed.
  • A minimum standard for sharing information about substantiated SEAH during recruitment.
  • Not a database — there is no central register; recruiting organisations request a ‘Statement of Conduct’ from a candidate’s former employers.
  • Covers at least five years of employment history for relevant roles.
  • Legally robust template — a standard form that lets past employers disclose findings without undue legal risk.
It works. By the sector’s own reporting, the scheme has blocked hundreds of hires of individuals with a history of SEAH — people who would otherwise have simply started again at the next agency. Source: CHS Alliance / SCHR.
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When it is a crime — referral to authorities
Much SEAH is not only misconduct but a criminal offence. An internal investigation does not replace the criminal justice system — and in some cases the law requires notification regardless of internal process.
  • Child sexual abuse — mandatory reporting to authorities under POCSO 2012 in India; failure to report is itself an offence.
  • Serious crimes against adults — rape and sexual assault are crimes; referral is guided by the survivor’s informed choice, safety, and legal duties.
  • Do not compromise a criminal case — internal fact-finding must not contaminate evidence or pre-empt police work.
  • Survivor-centred referral — support the survivor through any justice process; never force it where the law leaves it to their choice.
Know the line between what your organisation handles administratively and what must go to the authorities. When in doubt on a criminal matter — especially involving a child — seek legal and specialist advice immediately.
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Learning from cases — closing the loop
Every case, substantiated or not, is a chance to strengthen the system. Accountability is not only about the individual — it asks what in the organisation allowed the risk, and fixes it.
  • Root-cause review — what gap in supervision, access, culture or recruitment created the opportunity?
  • Update controls — tighten the specific weaknesses the case revealed.
  • Anonymised learning — share lessons without identifying anyone, to improve practice sector-wide.
  • Track trends — patterns across cases (locations, roles, programme types) point to where prevention must focus.
  • Report transparently — to boards and donors, on numbers and actions, without breaching confidentiality.
Organisations that learn openly from incidents become safer. Those that treat every case as a reputational threat to be buried repeat their failures — and betray the people they serve.
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Common investigation and accountability pitfalls
  • Amateur investigation — well-meaning staff questioning witnesses or confronting the accused, destroying evidence and endangering the survivor.
  • Protecting the senior — applying rules to junior staff but quietly moving powerful offenders on.
  • Over-sharing — details leaking into chat groups and community talk.
  • Retaliation ignored — failing to protect the reporter, silencing everyone else.
  • Survivor forgotten — the process focuses on the accused and the organisation, and the survivor hears nothing and gets no support.
  • Cover-up under ‘reputation’ — the failure at the heart of Haiti; concealment always compounds harm.
Notice how many of these are cultural, not technical. A fair, survivor-centred, transparent culture prevents most of them — which is what Part 9 is about.
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09
Part Nine
Prevention & culture
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Safeguarding risk assessment
Prevention starts by asking, systematically, where and how harm could occur in a given programme — then designing controls to reduce it. A safeguarding risk assessment is as basic as a security or financial one.
  • Who is at risk — which groups are most vulnerable (children, women, people with disabilities, the displaced)?
  • Where the power sits — which roles control access to aid, cash, lists, or jobs?
  • Risk points — distributions, registration, cash transfers, transport, residential settings, remote sites with little oversight.
  • Contextual risk — crisis, displacement, weak local services, high impunity.
  • Controls — the specific measures (segregated queues, female staff, complaint boxes, dual oversight) that reduce each risk.
Do the assessment at design stage, not after an incident — and revisit it when the context, partners or programme change. Risk is dynamic.
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Safe recruitment — vetting and references
The single most effective prevention measure is not hiring people who pose a risk. Safe recruitment builds safeguarding into every step of bringing someone on board.
  • Value-based screening — interview questions and scenarios that probe attitudes to power, boundaries and safeguarding.
  • Reference checks — always taken up, always covering conduct, with direct questions about any safeguarding concerns.
  • Misconduct disclosure — use the Misconduct Disclosure Scheme’s Statement of Conduct for relevant roles, covering at least five years.
  • Verify identity and gaps — check gaps in employment history and confirm claimed roles.
  • Role-proportionate — the more contact with vulnerable people, the deeper the checks.
A charismatic candidate is not a vetted candidate. Perpetrators are often skilled at interviews — which is exactly why references and misconduct checks, not gut feeling, must decide.
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Background checks and self-declaration
Background checks
Where available and lawful, criminal-record and register checks for roles working with children or at-risk adults. Availability and reliability vary widely across South Asia — use them where they exist, but never rely on them alone.
Self-declaration
A signed declaration of any prior safeguarding findings or relevant convictions, plus agreement to the code of conduct. A false declaration is itself grounds for dismissal.
  • Layer the measures — references + misconduct check + declaration + probing interview together, since no single check is sufficient.
  • Apply to everyone — staff, volunteers, consultants, drivers and partners with community contact.
  • Document — keep records of checks done, so recruitment can be audited.
In low-record-availability settings, references and the Misconduct Disclosure Scheme carry more weight — make them non-negotiable rather than assuming a clean record means a safe hire.
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Induction and regular training
A policy no one has read prevents nothing. Training turns standards into shared understanding — and must reach everyone, repeatedly, in a form they can absorb.
  • At induction — every new person, before field contact, learns the code, the red lines and how to report.
  • Regular refreshers — annual or more; safeguarding fades without reinforcement.
  • Role-relevant — deeper training for focal points, managers, investigators and those in high-contact roles.
  • Accessible — in local languages and formats that suit staff with low literacy or limited formal education, including volunteers and daily-wage workers.
  • Practical — scenario-based, so people know what to do, not just what the policy says.
After its crisis, Oxfam put thousands of staff worldwide through mandatory safeguarding training. Reaching everyone — not just headquarters — is the point.
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Safeguarding focal points
A focal point is the trained, designated person responsible for safeguarding in a team, office or programme — the human infrastructure that makes reporting real.
  • Known and reachable — staff and communities know who they are and how to reach them.
  • Trained — to receive disclosures, manage confidentiality, refer, and channel reports.
  • Empowered — with authority, time and senior backing to act, not a title added to an overloaded role.
  • Diverse and accessible — ideally including women and people communities can approach comfortably; more than one, so a complaint about one is not stuck.
  • Connected — linked to referral services, investigators and leadership.
A focal point in name only — untrained, unsupported, or the same person a complaint might be about — is worse than none, because it looks like a system while failing survivors.
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Community-based complaint mechanisms
The people best placed to report exploitation are the communities experiencing it — but only if they know a mechanism exists, trust it, and can reach it safely. Building this with communities, not for them, is central to prevention.
  • Co-design with the community — ask which channels women, children and marginalised groups would actually feel safe using.
  • Raise awareness — tell communities their rights, that aid is free and never to be exchanged for anything, and how to complain.
  • Multiple, accessible routes — in-person, phone, box, trusted intermediary; consider gender, language, literacy and distance.
  • Feedback loop — act on complaints and show the community that reporting leads somewhere.
  • Inter-agency coordination — in multi-agency settings, shared mechanisms so people can complain about any actor.
A simple, trusted message repeated everywhere — “aid is always free; no one may ask you for anything, especially not sex, in exchange” — is itself a powerful prevention tool.
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Managing partners and downstream sub-grantees
Safeguarding responsibility flows down the whole chain of delivery. An organisation is accountable for the conduct of its partners, sub-grantees, contractors and their staff — not only its own employees. This is where risk often concentrates and oversight is weakest.
  • Assess partners — check whether they have safeguarding policies, focal points, and capacity before funding them.
  • Flow-down clauses — contractually require the same standards, codes and reporting duties throughout the chain.
  • Build capacity, don’t just police — support smaller local partners to develop safeguarding rather than only imposing conditions.
  • Joint reporting routes — ensure a survivor can report regardless of which organisation in the chain is involved.
  • Monitor — include safeguarding in partner reviews and spot-checks.
“It was the partner’s staff, not ours” is not a defence. Donors and communities hold the whole chain accountable — and so should you.
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Building a speak-up culture
Policies, checks and channels only work inside a culture where people believe it is safe and expected to speak up. Culture is the deepest layer of prevention — and the hardest to fake.
  • Psychological safety — staff can raise concerns without fear of blame, ridicule or reprisal.
  • Consistent enforcement — rules applied to the powerful as firmly as to the junior, so people believe reporting matters.
  • Openness about incidents — treating reports as the system working, not as failures to hide.
  • Everyday challenge — a norm where inappropriate ‘jokes’ and boundary-pushing are called out early.
  • Power questioned — attention to how power operates in teams and with communities.
The clearest sign of a healthy safeguarding culture is not zero reports — it is reports flowing through safe channels and being handled well. Silence is the danger sign.
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Leadership and tone from the top
No charity is more important than the people it serves or the mission it pursues.
— UK Charity Commission, on the Oxfam inquiry, 2019
  • Board accountability — safeguarding owned at the top, with a named lead and regular reporting.
  • Resourced — budget, staff and expertise, not an unfunded mandate.
  • Modelled — leaders demonstrate the boundaries and the openness they demand of others.
  • No exceptions for stars — the most damaging signal a leader can send is protecting a valuable but abusive colleague.
Every serious safeguarding failure the sector has examined traces back, in part, to leadership that prioritised reputation, funding or a star performer over the people the organisation existed to serve. Tone from the top is not soft — it is decisive.
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10
Part Ten
In practice
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Worked scenario — receiving a disclosure
Setup. During a cash-distribution visit, a woman quietly tells you that the community volunteer who manages the beneficiary list asked her for ‘a favour’ to keep her family on it, and hints it was sexual. She is frightened and says she doesn’t want to lose the payments.
What you do
Find a private space. Listen calmly, thank her, tell her it is not her fault and that aid is her right, not a favour. Explain honestly that you must report the concern but will share only what is needed and protect her identity. Ask about her safety and what support she wants. Refer with consent. Report to your focal point.
What you must not do
Do not confront the volunteer or investigate. Do not promise total secrecy. Do not discuss it with other staff or the community. Do not remove her from the list or let anyone cut her aid — that would be retaliation.
Lesson. This is textbook exchange-based exploitation by associated personnel. Receive it survivor-centredly, report it, protect her aid and safety — and let trained investigators take it from there.
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Worked scenario — a code-of-conduct grey area
Setup. A colleague tells you, in confidence, that he has developed a genuine romantic relationship with an adult woman from the community his team serves. “We’re both consenting adults,” he says. “It’s nobody’s business, and I don’t decide her aid anyway.”
Why it is not simply private
His organisation provides assistance the woman depends on. Even if he does not personally control her aid, the relationship sits within an inherently unequal power dynamic — exactly what ST/SGB/2003/13 addresses. It is at least ‘strongly discouraged’, and many codes prohibit it outright.
What you advise / do
Encourage him to declare the relationship to management immediately so the conflict of interest can be managed — e.g. reassignment away from that community. Explain that declaring protects both of them and the organisation. If he refuses, you have a duty to raise the concern yourself.
Lesson. Grey areas are resolved by the power-imbalance test and by declaration, not by staff privately deciding a rule doesn’t apply to them. “We’re in love” does not remove the power gap.
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Worked scenario — a community complaint
Setup. A complaint box in a relief camp yields an anonymous note, in the local language, saying a driver is “taking girls” in the distribution vehicle in exchange for extra rations. There is no name, no date, and the note is barely legible.
  • Take it seriously. Anonymity and vagueness do not make a concern less real — they reflect how unsafe reporting feels. Do not dismiss it.
  • Report, don’t investigate. Pass it to the focal point through the proper channel; do not question the driver or the community yourself.
  • Interim safety. Consider measures that reduce risk while the concern is assessed — e.g. changing distribution arrangements, dual staffing of vehicles — without pre-judging guilt.
  • Check the mechanism. That the note came anonymously suggests fear; strengthen safe, accessible reporting so more can come forward.
  • Corroborate through proper process — by trained investigators, not informal community questioning that could endanger a survivor.
Lesson. Anonymous, vague community complaints are common and must be handled with the same seriousness and discipline as a named report — they are often the only safe way people can raise alarm.
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How risk shows up across sectors
SectorWhere the risk concentrates — and a control
Cash & foodControl over who is on the list and who gets paid — segregate roles, audit lists, publicise that aid is free
WASHIsolated water points and unlit, non-segregated latrines — site and light facilities with women’s input
HealthPrivate clinical contact and power over care — chaperones, female staff, clear consent and boundaries
EducationAdults’ trusted access to children — vetting, open-door teaching, child-safeguarding training
Livelihoods / skillingSelection for jobs and training as leverage — transparent criteria, complaint routes, no favours
The pattern repeats: wherever a staff member controls access to something people need, and oversight is thin, exploitation risk rises. Map those points in your programme and put a control on each.
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Common mistakes — and what to do instead
Common mistakeDo this instead
Promising a survivor total secrecyBe honest about reporting duties before they disclose fully
Investigating the concern yourselfReport to the focal point; leave investigation to trained staff
Treating ‘no reports’ as ‘no problem’Assume under-reporting; strengthen safe, accessible channels
Sharing case details with colleaguesStrict need-to-know; no names in emails or chat groups
Applying rules to juniors but not the powerfulConsistent enforcement regardless of rank or usefulness
Focusing on the accused, forgetting the survivorKeep the survivor informed and supported throughout
“It was the partner’s staff, not ours”Own the whole chain; flow standards down to sub-grantees
Almost every mistake here comes from good intentions applied without training — which is exactly why knowing the right reflex in advance matters.
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Myths and facts
MythFact
“Safeguarding is HR’s / the focal point’s job.”It is every staff member’s responsibility — you are the frontline.
“It couldn’t happen in our organisation.”That belief is exactly what lets it continue. Assume risk exists.
“If she was paid, it’s not exploitation.”The power imbalance makes exchange of aid or money for sex exploitation.
“They consented, so it’s fine.”Where power is deeply unequal, consent cannot be assumed to be free.
“Few reports means we don’t have a problem.”Low reporting usually means unsafe channels, not low prevalence.
“Reporting a colleague is disloyal.”Protecting the people we serve is the deepest loyalty to the mission.
“I mistook the child’s age, so I’m not liable.”Mistaken age is explicitly no defence.
Each myth is a door that lets harm continue. Closing it in your own thinking is the first act of prevention.
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Frequently asked questions
  • What if I’m not sure it’s serious enough to report? Report it anyway. It is not your job to judge severity — the focal point decides. Under-reporting is the chronic failure.
  • What if the concern is about my own manager? Use the alternative or whistleblowing route in your policy — you are protected from retaliation for reporting in good faith.
  • The survivor asked me to tell no one. Must I still report? Be honest that you have a duty to report the concern; you can protect their identity, share the minimum, prioritise safety, and seek focal-point guidance. Child cases carry legal reporting duties.
  • What if I only have a suspicion, no proof? Suspicions are reportable. You do not need evidence — gathering it is the investigator’s job, not yours.
  • Does this apply off duty? Yes — the code covers conduct in programme areas and online, on and off duty.
  • What if it’s a partner’s staff, not mine? Still report; the duty and the standards flow across the whole chain.
When in doubt on any question: protect the survivor’s safety, share only what is needed, and ask your focal point. Those three moves rarely go wrong.
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Your safeguarding checklist
  • Know the red lines — no sex with under-18s, no exchange for sex, no relationships with beneficiaries, no harassment.
  • Know your code and policy — and sign it meaningfully, not as a formality.
  • Know your focal point — and the alternative route if the concern involves them.
  • Know the referral pathway — nearest medical, psychosocial, legal and safety services, kept current.
  • Receive disclosures well — believe, listen, don’t judge, don’t promise secrecy, don’t investigate.
  • Protect confidentiality — need-to-know only; secure records; no chat-group details.
  • Report promptly and honestly — facts, not conclusions; the minimum necessary.
  • Protect reporters — watch for and stop any retaliation.
  • Build prevention in — risk assessment, safe recruitment, accessible complaint mechanisms.
  • Model the culture — boundaries, openness, and challenging what is wrong.
Keep this where you can reach it. Safeguarding is a set of everyday habits far more than a single dramatic moment.
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Further reading and key resources
  • UN Secretary-General’s Bulletin ST/SGB/2003/13 — the source definitions and prohibitions on SEA.
  • IASC Six Core Principles Relating to Sexual Exploitation and Abuse (2019) — the sector baseline.
  • Core Humanitarian Standard on Quality and Accountability (2024 edition) — the nine commitments, including safe complaints.
  • IASC PSEA resources and the Safeguarding Resource and Support Hub (RSH) — practical tools and templates.
  • The Misconduct Disclosure Scheme (SCHR / CHS Alliance) — the Statement of Conduct and how-to-implement guidance.
  • UK Charity Commission inquiry report into Oxfam GB (2019) — the case that reshaped the sector.
  • National law — in India, the POCSO Act 2012, the PoSH Act 2013, and the Digital Personal Data Protection Act 2023.
Above all, read your own organisation’s safeguarding and PSEA policy and code of conduct — that is the document that binds you, and it translates all of the above into the channels and duties where you work.
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Key takeaways
  • It is everyone’s job. Safeguarding lives in the everyday behaviour of every staff member — not in a policy or a single focal point.
  • Power is the core. Every red line closes off a way that power over vulnerable people can be turned into sexual gain; where power is unequal, consent cannot be assumed.
  • Know the red lines. No sex with under-18s (mistaken age is no defence), no exchange of aid for sex, no relationships with beneficiaries, no harassment — and a duty to report.
  • Be survivor-centred. Safety, confidentiality, respect, non-discrimination — believe, don’t judge, don’t investigate, don’t promise secrecy, and refer to support.
  • Report safely. Through the right channel, protecting confidentiality and the reporter from retaliation.
  • Prevent by design. Risk assessment, safe recruitment, the Misconduct Disclosure Scheme, focal points, community complaint mechanisms, and partner oversight.
  • Silence serves perpetrators. A culture where it is safe to speak — and where reports are acted on regardless of rank — is the strongest protection there is.
Everyone’s business. No exceptions. If you take one thing from this course: when in doubt, protect the survivor’s safety, share only what is needed, and report to your focal point.
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Safeguarding & PSEA 101 · Complete
Everyone's business.
No exceptions.
CC BY-NC-ND 4.0·Free Forever·ImpactMojo 101 Series