Privacy Policy

Protection Against Sexual Exploitation, Abuse and Harassment Policy (PSEAH)

Purpose

IJM does not tolerate sexual exploitation, abuse or harassment (SEAH) of any kind, and confirms its heightened commitment to measures of prevention and safeguarding by:

• Fostering an enterprise-wide and partnership culture actively preventing SEAH.
• Setting expectations for all those who work for, represent, or partner with IJM regarding PSEAH, appropriate behavior, and consequences for misconduct.
• Clarifying IJM’s approach to preventing and addressing SEAH.

Applicability

This policy applies globally to all IJM Representatives and Implementing Partners both during and outside working hours, as well as all IJM Guests during the period of interaction with IJM Representatives and Beneficiaries.

All people and organizations covered by this policy are referred to as “Covered Persons.”

Principles

IJM is committed to the following PSEAH core principles[1]:

1. Sexual exploitation, Abuse and Harassment by Covered Persons constitute acts of gross misconduct and substantiated allegations are grounds for termination of employment/contract.
2. Covered Persons are prohibited from engaging in any form of sexual activity with children[2] (persons under the age of 18), regardless of the age of majority or the locally recognized age of consent. Mistaken belief in the age of the child is not a defense.
3. Covered Persons are prohibited from exchanging money, employment, goods, services, or any other thing of value for sex, including sexual favors, or other forms of humiliating, degrading or exploitative behavior. This includes exchange of assistance due to program participants.
4. Covered Persons are prohibited from engaging in sexual relationships with Beneficiaries since they are based on inherently unequal power dynamics and may undermine the credibility and integrity of IJM’s work. IJM Representatives must disclose any previously existing relationships with IJM program community members to their line managers or People Support focal points prior to beginning employment or contract with IJM.
5. Where a Covered Person develops concerns or suspicions regarding sexual abuse or exploitation by a fellow worker, whether in IJM or not, he or she must report such concerns via IJM’s established reporting mechanisms.
6. IJM Representatives and Implementing Partners are obliged to create and maintain an environment which prevents SEAH and promotes the implementation of IJM’s Code of Conduct. IJM managers at all levels have heightened responsibility to support and develop systems which maintain this environment.
7. IJM Representatives are prohibited from engaging with commercial sex workers or engaging in prostitution of any form whilst on a work trip (including travel and leisure time and field visits) and representing IJM, even if commercial sex is legalized in that country. This kind of conduct goes against IJM’s organizational values and once substantiated will constitute grounds for disciplinary measures including summary dismissal.

IJM, along with its Representatives and Implementing Partners, are committed to ensuring appropriate action in reporting and response to any incidences of SEAH:

Reporting SEAH

Covered Persons have a responsibility to immediately raise concerns regarding SEAH and must not independently investigate allegations or suspicions. Even as reporting protocols evolve over time, IJM commits to:

• Ensure multiple channels for reporting, designed in consultation with stakeholders to ensure transparency, accessibility, and safety.
• Encourage and support reporting and build a culture that promptly addresses reports.
• Train Covered Persons and other relevant individuals on how to access these safe reporting channels, including providing suitable messaging for children and people of diverse backgrounds, and posting reporting procedures in local languages.
• Train key IJM Representatives, particularly designated Safeguarding/ PSEAH Focal Points, on how to receive and respond to reports, to ensure they understand the obligation of confidentiality and anonymity.
• Reassure individuals making reports regarding confidentiality and safety and allow an option for reports to made anonymously, including reports under IJM’s Whistleblower Policy.
• Abide by any applicable external reporting requirements of the Standard Operating procedure for Misconduct Reporting. Only IJM Representatives with delegated authority can report to external donor or regulatory authorities. Survivors, if they so request, will be supported in reporting to regulatory authorities within their jurisdiction.

Response to SEAH reports

IJM will respond in a timely and professional way to all concerns, allegations, and reports of SEAH. All concerns will be taken seriously, investigated and acted upon according to our principles as noted below:

• Survivor-Centered Approach- IJM prioritizes the rights, needs, wishes, and empowerment of survivors of SEAH in both prevention and response to SEAH. Complaints mechanisms will be accessible and designed with the needs of those affected by SEAH in context and in mind. IJM will investigate SEAH complaints sensitively and confidentially with primary concern for the survivor. IJM will offer a supportive environment to facilitate recovery and provide resources to aid the survivor. The safety and security of the survivor and his /her children is the primary consideration. IJM ensures that the survivors will have a right to choose whom to tell their story and all information will be handled confidentially and with the informed consent of the survivor (IJM may only override confidentiality when there is an imminent threat of harm). Survivors, too, will receive equal and fair treatment regardless of their age, gender, race, religion, nationality, ethnicity, sexual orientation or any other characteristic.
• Investigations – IJM will carry out professional, safe and discreet investigations through trained investigators working with IJM’s Safeguarding Team. Due recognition is placed on the rights and the duty of care we owe to everyone involved, this includes the complainant and/or survivor, witnesses and Subject of Complaint (SoC).
• Accountable Case Management- All allegations of SEAH, and subsequent escalation and follow up, will be documented in a secure and confidential database. IJM’s Data Protection Principles will apply. This will ensure IJM remains accountable in all its actions. The report will officially be acknowledged within 24 hours, and the safeguarding team will convene a case conference to assess immediate risks and next steps within 72 hours.
• Survivor support- IJM commits to refer survivors to competent support services as available and appropriate and according to the wishes and wants of the survivor. This support may include, but is not limited to, legal support, specialist psychosocial support such as counselling, medical assistance, security and employee assistance support.

Decision Making- IJM will take swift and appropriate action against IJM representatives and associates who are found to have committed SEAH. This may include disciplinary and administrative actions, termination of contracts and /or referral to relevant local authorities if appropriate and safe to do so. An independent incident management panel will be assigned in every investigation to ensure transparency, impartiality, and accountability. The decision-making process will be subject to scrutiny by the Safeguarding Lead.

Reporting Channels

Anyone, including members of the community we work with and for, can raise a concern or make a complaint to IJM about something they have experienced or witnessed without fear of retaliation or reprisal. Options for reporting:

• Using the anonymous whistleblowing webform, here
• Contacting Safeguarding (PSEAH) Lead at safeguarding@ijm.org

Complaints About Implementing Partners

Where IJM receives a complaint about an Implementing partner organization, IJM requires the partner to respond safely, quickly, and appropriately with the same or functionally equivalent standards of reporting and response as outlined in this policy. IJM will assist the partner to ascertain its reporting obligations. If there is reason to believe that an allegation of abuse has been dealt with inappropriately by a partner, the Partner risks withdrawal of funding or ending the relationship with IJM.

Gender Equality and Power Balance

IJM recognizes that gender, disability, age and impoverishment have a powerful intersection and impact on the likelihood of SEAH happening. IJM, therefore, is committed to addressing gender inequality and power imbalances within the organization and in the delivery of its work. Using a ‘Do No Harm’ approach, IJM actions promote gender equality, safeguarding, social inclusion and accountability.

Zero Tolerance for Retaliation

IJM will take action against anyone, whether they are the subject of a complaint or not, who seek or carry out retaliatory action against complainants, survivors, other witnesses or the subject of complaint. IJM Representatives may be subject to disciplinary action, up to and including termination of employment. Others who work with IJM may have their relationship with IJM terminated.

[1] The six core principles are from The UN Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13) and have been modified by IJM to include sexual harassment and IJM Representatives and associates. The seventh added is IJM specific.

[2] See the UN Convention on the Rights of the Child.

Safeguarding Policy

Purpose

IJM has zero tolerance for exploitation and abuse. We are especially committed to safeguarding because of who we are, what we believe, and what we do. This policy is intended to detail IJM’s commitment to transparency and to the highest standards of organizational safeguarding by:

• Emphasizing the centrality of IJM’s commitment to safeguarding all people who come into contact with IJM, especially Vulnerable People, from all forms of Harm when interacting with IJM.

• Providing a framework for ensuring that IJM programs and activities are informed by survivor leaders and are designed, implemented, and performed with the best interests of Vulnerable People in mind.

• Ensuring that IJM prioritizes prevention and remains accountable in its response to safeguarding incidents.

Applicability

This policy applies to all people working or volunteering on or behalf of IJM, including directors, staff, volunteers, constituents while engaging in IJM activities, contractors or vendors while performing services for IJM (“IJM People”). IJM also requires Implementing Partners to commit to implementing this policy or their own policy that IJM has confirmed as functionally equivalent, including equivalent safeguarding measures and principles.

Safeguarding Principles

1. IJM promotes and seeks to maintain a safe and supportive organizational culture for all people, where all who interact with IJM, including IJM People, partners, and members of communities where IJM works, are treated with dignity and respect, and within an environment where safety, confidentiality, and non-discrimination are ensured.
2. IJM applies the Do No Harm principle. All programs, interventions and activities are designed and implemented with care that they do not cause further harm nor introduce additional risks to anyone who comes into contact with IJM programs or people.
3. IJM People and Implementing Partners are expected to treat all people with the utmost dignity and respect at all times. All IJM People must abide by IJM’s Safeguarding Policy Suite (which includes this policy, the companion Protection against Sexual Exploitation and Abuse Policy[1] , IJM’s applicable Code of Conduct and Safeguarding Procedures).
4. IJM recognizes the additional duty of care to Vulnerable People with whom we work, are in contact with, or who are affected by our work, programs and operations.
5. IJM values diversity and does not discriminate based on gender, age, race/ethnicity, disability, sexual orientation, or other characteristics in its programs or in offering its services to Beneficiaries.
6. IJM prioritizes safeguarding at all levels of the organization. Our safeguarding culture begins with IJM Boards of Directors and is the responsibility of all IJM People.
7. IJM has established high level oversight and accountability for safeguarding efforts, overseen and guided by a dedicated Safeguarding Officer.
8. IJM commits to continuous learning and improvement in our safeguarding policies and procedures. IJM will implement changes based upon periodic self-assessments, monitoring, feedback, and Safeguarding Reports.
9. IJM fosters a culture of transparency and collaboration in our safeguarding work. This entails including and engaging with communities, other organizations, donors, governments, civil society networks, and other local networks as applicable.
10. IJM commits to ethical and protective principles in research, media and communications to ensure Vulnerable People are represented in a dignified way, their participation is not exploitative, and information is used for the agreed purpose and consent.

IJM is committed to incorporating and prioritizing safeguarding in all our work.

Awareness

IJM’s Safeguarding Standards will be communicated to all IJM People. IJM will provide appropriate training on the Safeguarding Policy Suite, and IJM People are required to comply with training requirements. IJM shall make reasonable efforts to provide Beneficiaries with an explanation of who IJM is, what constitutes Harm and what its safeguarding principles are, and how to report any violations or concerns. IJM shall work with the communities it serves to develop communication content and materials and complaint response mechanisms that can be accessed by everyone, including Vulnerable People.

Prevention

IJM shall implement preventative safeguarding measures as appropriate. Sample measures include:

• Screening every candidate for employment and performing background and reference checks to ensure potential hires do not pose a safeguarding threat.
• Requiring all IJM People and Implementing Partners to affirm that they have not harmed Vulnerable People in the past and requiring self-disclosure of any past and future safeguarding incidents which occur.
• Requiring external checks on IJM People and Implementing Partners. These include anti-terrorism checks where needed, police clearance checks or equivalent.
• Requiring and conducting safeguarding due diligence of implementing partners prior to entering partnerships, including requiring enterprise and safeguarding risk management and safeguarding policies and procedures equivalent to those of IJM.
• Conducting an annual risk analysis of all IJM programs, implementing additional risk-management measures for high-risk contexts, and developing action plans to improve safeguarding and accountability.
• Mainstreaming safeguarding in the design and implementation of programs to ensure safer programming.

Reporting

Mandatory Obligation to Report: IJM commits to make reasonable efforts to ensure all IJM People and Implementing Partners are aware of their mandatory duty to report any concerns promptly, including:

• Suspected or known Harm by IJM People or Implementing Partners, operations or programs against anyone who comes into contact with IJM, including Vulnerable People;
• Suspected or known violations of the IJM’s Safeguarding Policy Suite; or
• Any other inappropriate behavior.

All suspected or known safeguarding concerns must be reported by IJM People or Implementing Partners promptly, with a target of 24 hours of becoming aware of the concern, unless it is impossible to do so, or other exceptional circumstances exist. Where safe to do so, and when after taking into consideration the wishes of the survivors and whistleblowers and the risk of further harm (by way of a risk assessment), all alleged incidents of harm that involve a criminal aspect should be reported through the appropriate local law enforcement channels.

IJM shall ensure that IJM People know how to make a Safeguarding Report in accordance with IJM’s Safeguarding Policy Suite when concerns arise. Everyone will have access to safe, accessible reporting channels, including confidential and anonymous reporting channels. Community-based reporting mechanisms which will be designed in consultation with community members and survivors in context, addressing any barriers to reporting.

Anyone, including members of the community we work with and for, can raise a concern or make a complaint to IJM about something they have experienced or witnessed without fear of retaliation or reprisal. Options for reporting include:

• Using the anonymous whistleblowing webform.
• Contacting Global Safeguarding Lead at safeguarding@ijm.org.

Any person at IJM who receives a safeguarding complaint about another organization should refer the report to the IJM safeguarding team, who will report cases to the relevant organizations involved, where safe to do so, and in accordance with IJM’s Safeguarding Procedures. IJM will not investigate cases related to other organizations. However, IJM does have an obligation to report any misconduct, pursuant to IJM’s Safeguarding Procedures.

Responding

IJM takes allegations of misconduct seriously and will promptly and appropriately investigate Safeguarding Reports. IJM will make efforts to ensure its internal investigation and adjudicative procedures are safe, timely, consistent, confidential, and fair. All Safeguarding Reports and related investigations will be handled by persons trained in handling such matters. Any person receiving a Safeguarding Report or charged with responding to a report should follow Safeguarding Case Management procedures and respond in a manner that upholds our safeguarding principles. IJM’s Safeguarding Team must make reasonable efforts to ensure that the complainant, survivor, and witnesses are safe, receive psychosocial support in accordance with their wishes, and that any further risk of harm is mitigated.

IJM will share reports on registered safeguarding concerns, in an anonymized manner, with IJM’s Board of Directors and as required by local law and by any grant or other agreement (unless such disclosure is specifically prohibited by law or would cause greater harm).

IJM shall provide appropriate support to impacted parties during and after investigation of a Safeguarding Report. Following the investigation, IJM shall take appropriate action through learning and continuous improvement.

Recording

IJM will maintain a case management database that is secure and confidential, to ensure quality assurance, accountability, and data protection compliance.

Zero-Tolerance for Retaliation

It is prohibited to engage in any retaliation for making a Safeguarding Report or participating in an investigation, and IJM commits to protect complainants and witnesses from retaliation.

Violations of this policy including during personal time in the home country or overseas, shall result in disciplinary actions, determined on a case-by-case basis, up to and including termination of employment, contract, membership on a governing body of an IJM entity, or any other form of engagement with IJM.

Assess and Manage Risk and Impact

Careful planning and monitoring can identify, mitigate, and reduce the safeguarding risks to all people especially, Vulnerable People, that may be caused by IJM People, operations, and programs. IJM will ensure safety of all who come into contact with IJM, by way of example, implementing enterprise risk management[2], conducting a risk analysis for all programs and partners, developing, and maintaining monitoring tools, and incorporating feedback into IJM’s global risk management process and program development.

Sharing Responsibility for Safeguarding

IJM requires the commitment and investment of IJM Implementing Partners in preventing harm to anyone who comes into contact with their staff, operations, or programs when they are engaged in the delivery of IJM services and programs, or when they are working with IJM in any way.

IJM carries out appropriate and ongoing due diligence on IJM Implementing Partners and requires that implementing partners have an enterprise risk management framework in place and either adopt IJM’s Safeguarding Policy and procedures or equivalent safeguarding standards.

IJM shall support its Implementing Partners by sharing accurate, timely and accessible information, including the results of self-assessments and partner assessments, risk registers, training and other safeguarding materials. Implementing Partners must promptly report safeguarding concerns they have received about the IJM programs or their staff or operations to IJM within 24 hours of discovery.

[1] See PSEAH Policy tab

[2] Enterprise Risk Management as defined by the International Standards Organization (“ISO”) 31000 as revised.