Code of Practice

Introduction

When deciding to join ABROADER, all members of ABROADER agree to abide by the Code of Practice set out in this document. This Code of Practice is in place to ensure the safety and well-being of the participants, Host Organizations, the local communities and ABROADER. Overall, we would like to ensure a meaningful and rewarding experience for all stakeholders.
ABROADER is an equal opportunity organization and does not discriminate on any basis race, color, creed, gender or sexuality, ideology, religion, economic status, age, or ethnic background. With the aim to be distinguished by the hallmarks of integrity, idealism, and commitment to the common good, ABROADER expects that the members should conduct themselves in a manner that is responsible, professional, respectful, and supportive of the rights of others.
Members within ABROADER should be committed to continual thought and periodic evaluation of the extent to which ABROADER meets and fulfills the ethical standards outlined in this Code of Practice as part of their commitment to ABROADER’s mission.
This code of practice is to be the guidance towards the comprehensive developments, and considered as the preference to whom it may concern while aiming for a safe workplace and a better community. All the principles and rules, as well as the policies are based on the local law, the rights and international standards.
All staff, members and partners have the human rights issues concerning freedom of association, freedom of speech, freedom of the press, and the right to a healthy environment which are the fundamental protection by the Vietnamese government, appropriate to local, regional and international affairs. These things are considered if the staff, members and partners do not break the law or directly/indirectly join hands to commit criminal acts and other negative social influences on individuals, groups or communities. If there are any things being detected as breaking the law and other relevance, each individual, group, or organization has to take responsibility for the Criminal Code, Labor Code, Civil Procedure Code, Criminal Procedure Code of the Socialist Republic of Vietnam.
Violation of any of the following policies can lead to a termination at ABROADER.

1. Participant’s safety first

We at ABROADER want to make sure that our program is a safe trip for participants. Our top priorities are the health, well-being, and safety of the participants. An individual’s interests take a back seat to the participant’s safety.

In the event of an emergency, we would handle events calmly and professionally, going above and beyond our regular office hours to provide great customer care to participants in our programs. If a student’s life is in danger and needs to be rushed to the hospital, program coordinators have the right to act without the agreement of ABROADER’s Director. She/he can help to deposit the student’s hospital charge in advance using ABROADER’s emergency credit card.

At ABROADER, we are taken care of health and safety as much as our families do. Each member is provided health insurance to make sure that we can work and experience fully and at the same time stay healthy. All members must adhere to the Health and Safety rules set forth by the local government in which they reside. All ABROADER staff are required to take First Aid training.

Members of ABROADER are not allowed to consume alcohol, use drugs, or break any other laws in Vietnam. Irresponsible drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited during the time of the program, such as working hours and whenever going out with participants.

2. Abide and respect the local law

Overall, ABROADER members are also expected to, always, comply with all applicable laws and regulations in place during the program. Individuals must ensure that our actions cannot be interpreted as being, in any way, in contravention of local laws and regulations.

• Remain drug and alcohol-free, and avoid the use of controlled substances
• Be transparent, timely, responsible, and effective when working with all the stakeholders involved
• Acknowledge, have read, and will comply with the Preventing Sexual Exploitation, Abuse and Harassment (PSEAH) Policy, Child Protection Policy, Exploitation Modern Slavery Policy, Wildlife Tracfficking policy, Anti-Blibery and Anti-Fraud policy in all ABROADER’s members.

2.1. Child Protection policy

2.1.1. Targets

ABROADER’s Child Protection Policy was designed to give a clear company policy addressing Child Protection and the processes to follow in order to help prevent and identify child abuse. It provides guidance on how to minimize the danger of children being hurt in the course of its activities, as well as what to do if such an event occurs. The policy also establishes clear channels via which any concerns can be expressed without prejudice.

2.1.2. Principles

ABROADER will maintain the following key principles on our Child Protection Policy:

• Maintaining awareness of the laws and regulations in our partners’ locations and taking the necessary steps to ensure compliance as required by our various funding bodies
• Assuring that everyone involved in ABROADER’s operations understands their responsibility to protect children through education and awareness
• Assessing and managing the risk and impact of ABROADER operations on children. Ensure that no one who poses a risk to children is knowingly involved in ABROADER’s programs or operations, either directly or indirectly
• Being involved in relevant situations from partners and individuals, they must always share responsibility for child protection
• Being fairness, transparency, and confidentiality in procedures and decision-making processes involving concerns or allegations, regardless of nationality, beliefs, gender, or other differences.
• Upholding the child’s rights and acting in the child’s best interests.

2.1.3. Code of conduct

ABROADER expects all employees, partners, and individuals involved in the ABROABDER’s business operations to play a professional role with children, which includes establishing and maintaining clear professional boundaries that protect everyone from misunderstandings or violations.
The following behavioral guidelines and expectations must be adhered to:

• Conduct oneself in a way that is consistent with ABROADER’s values.
• Make your environment welcoming, inclusive, and safe for all children and young people. Do not engage in behavior that is meant to humiliate, humiliate, belittle, degrade, or exploit children. This includes inappropriate behavior such as harassment,abuse,sexual provocation, discrimination, and culturally inappropriate behavior.
• Smack, hit, or physically assault children, do not expose them to alcohol or drugs, and do not touch them in an inappropriate or unnecessary manner.
• Do not use technology or social media in an inappropriate manner, or to exploit or harass children.
• Respect all children equally, regardless of gender, race, or other characteristics.
• When photographing or filming a child, or using images of children for commercial aims, obtain permission first and explain how the content will be used.
• Encourage children, young people, participants, staff, and partners to communicate openly.
• Report any concerns as soon as possible in accordance with this policy, disclosing all information available and to one’s knowledge.
• Maintain accountability and avoid putting oneself in uncompromising situations where allegations could be made. Ensure that another adult is present where possible, and do not invite unaccompanied children into a home/hotel or other private location unless there is an immediate risk of injury or physical danger to the child.
• Follow all local, national, and international child protection laws, including labor laws.
• Be a good role model for children.

2.1.4. Risk Assessment

ABROADER recognizes that the certain programs may pose increased risks to children. To mitigate the risk of harm and wrongdoing, ABROADER staff and partners must proactively assess and manage risk to children in accordance with ABROADER’s risk and decision-making processes and documents. Activities and programs that involve working directly with children on a daily basis are considered higher risk and, as a result, require more stringent child safeguarding procedures, such as individual background checks and working with children certificates.

2.1.5. Reporting

All individuals covered by this policy are required to report any witnessed, suspected, or alleged incidents of child exploitation or abuse, as well as any violation of this policy, immediately. All concerns or reports will be taken seriously and must be addressed as soon as possible in a confidential manner that does not jeopardize the victim or the person reporting the abuse. Any incidents should be reported directly to a senior management member. If a crime is involved in the incident, ABROADER will notify the appropriate local law enforcement channels, as well as insurance bodies, to provide the individual with any necessary support.

2.2. Policy to Prevent Sexual Exploitation, Abuse, and Harassment (PSEAH)

2.2.1. Targets

ABROADER does not tolerate sexual exploitation, abuse, or harassment in any form (SEAH). This is true for both our own organization and those with whom we collaborate. This policy is based on the standard reference of the United Nations Human Rights – Convention on the rights of the child.

The Policy outlines both expectations and requirements for ABROADER staff and our partners to manage the risk of SEAH and SEAH incidents that may occur during the course of the ABROADER program’s delivery. Preventing SEAH (PSEAH) is a collaborative effort. All organizations must take an active role in addressing SEAH that occurs during the course of their operations. ABROADER will put the Policy into action through agreements, reporting requirements, and regular communication with our employees and partners.

2.2.2. Key definitions

This Policy employs the following definitions of sexual exploitation, sexual abuse, and sexual harassment, which combine international and Australian definitions:

• Sexual exploitation: any actual or attempted sexual exploitation of a position of vulnerability, differential power, or trust. Profiting monetarily, socially, or politically from the sexual exploitation of another is included.
• Sexual abuse: any interaction in which the child is used for the sexual stimulation of the perpetrator or an observer. Children of all ages, races, ethnicities, and economic backgrounds may experience sexual abuse. Child sexual abuse affects both girls and boys in all kinds of neighborhoods and communities.
• Sexual harassment: is defined as rude, embarrassing, or intimidating sexual behavior. It can take the form of a written, verbal, or physical communication, and it can take place in person or online.
• Fraternization: any business relationship that involves — or appears to involve — partiality, preferential treatment, or improper use of rank or position, including but not limited to voluntary sexual behavior. It includes non-intercourse sexual behavior, a close and emotional relationship involving public displays of affection or private intimacy, and public expression of intimate relations.

2.2.3. Principles

ABROADER will take all reasonable steps to prevent sexual exploitation, abuse, and harassment, as well as to promote the rights of the people and communities with whom we work.
Our Policy is founded on the following principles:

Principle 1: There is no tolerance for inaction
Sexual exploitation, abuse, and harassment will never be tolerated. Zero tolerance does not imply zero incidents, and incident reports may increase as organizations improve their safeguards. Increased reports may indicate increased awareness of SEAH and shifting attitudes, with victims/survivors feeling more comfortable reporting and organizations being more likely to take action.

Principle 2: Effective leadership accelerates culture change.
ABROADER expects leaders to set clear expectations and demonstrate respectful behavior in their workplace interactions. This will help communities, victims/survivors, and whistleblowers feel safe, report concerns, and have confidence that their allegations will be taken seriously.

Principle 3: The needs of victims and survivors are prioritized
Actions to resolve SEAH should be governed by a “harmfulness” mindset that emphasizes victim/survivor rights, needs, and wishes while ensuring procedural fairness for all parties. The survivor is treated with dignity and respect under this method, and they are included in decision-making and given full information. It also guarantees privacy and secrecy and makes no distinctions based on gender, age, race/ethnicity, ability, sexual orientation, or other factors.

Principle 4: It is everyone’s responsibility to prevent sexual exploitation, abuse, and harassment
ABROADER requires the commitment, support, and investment of its partners. All organizations have a responsibility to build their capacity to deal with SEAH that occurs in the course of their work in a sensitive and effective manner.

Principle 5: Gender inequality and other power imbalances are addressed
PSEAH can be caused by inequalities based on worker/beneficiary, ability/disability, ethnic and indigenous status, gender identity and sexual orientation, age, health, and poverty. According to available data, the majority of PSEAH victims/survivors are female, while the majority of perpetrators are male. Therefore, respect for diversity, promotion of gender equality and social inclusion, accountability, and a strong “harmfulness” focus should underpin engagement with intended beneficiaries.

Principle 6: Stronger reporting will enhance accountability and transparency
Sexual exploitation, abuse, and harassment are all examples of a failure to take responsibility. The organizations and individuals who carry out ABROADER business are accountable not only to ABROADER, but also to the communities, customers, and clients for whom the business is intended. ABROADER can better monitor SEAH, understand risks, improve assurance, and collaborate with organizations to improve systems and safeguards as a result of improved reporting. Reporting will also help to keep organizations focused on the issue by reminding them on a regular basis that PSEAH is a core obligation of their job.

2.2.4. Risk Assessment

The policy takes a risk-based, proportional approach to PSEAH. ABROADER staff and partners must determine the level of risk that PSEAH will occur. PSEAH risk and decision-making processes and documents are integrated into existing activity planning and risk management systems. It is the duty of partners to ensure that measures for managing and monitoring SEAH risk are in place.

2.2.5. Reporting

When alleged incidents are reported, ABROADER will collaborate with the organization or individual to manage the incident. In accordance with Principle 3 — Victim/survivor needs are prioritized — the safety and well-being of victims and survivors must be prioritized in reporting, and their information must be treated confidentially. Whistleblowers must feel safe and protected during the reporting process as well. ABROADER anticipates two types of incident reporting:

• Mandatory and immediate reporting of any alleged incident of sexual exploitation, abuse, or harassment related to the delivery of ABROADER business by all staff and ABROADER partners. This includes any alleged incident that could jeopardize ABROADER’s reputation. For example, an allegation made against a senior member of a partner organization’s staff.
• Mandatory reporting of any alleged policy non-compliance by all staff and ABROADER partners, such as failure to adhere to the PSEAH Policy Minimum Standards or principles.

All ABROADER members, staff and partners must report any alleged occurrences of sexual exploitation, abuse, or harassment, as defined by the Policy’s scope. Any suspected or alleged cases of SEAH committed by anybody within the Policy’s scope while performing official duties or conducting business must be reported. ABROADER workers and partners should report any reported occurrence if they are unsure. The ABROADER Risk Management and Response Plan must be followed in all reports of alleged PSEAH events.

2.3. Combatting Exploitation Modern Slavery policy

2.3.1. Introduction

Human trafficking, slavery, servitude, forced labor (including child labor), debt bondage, deceptive recruiting for labor or services, and sexual exploitation, abuse, or harassment are all examples of exploitation in this context.

2.3.2. Commitments

ABROADER’s Commitment to Combatting Exploitation & Modern Slavery:

• All ABROADER’s representatives, partners, stakeholders, and participants are committed to raising awareness about any form of exploitation and agree to take appropriate action if it occurs.
• If exploitation is taking place or there is a risk that it will take place, in an activity related to performing duties in relation to ABROADER or otherwise, you are required to promptly notify your reporting line or a senior management team. To the extent they have control over it, everyone involved must take reasonable steps to address the exploitation or risk of exploitation.
• ABROADER commits to reviewing this policy with our stakeholders on a regular basis and reinforcing our commitment to it, while also encouraging others to follow best practices, raising awareness in the locations where we operate, and encouraging the implementation of similar policies within our network and beyond.
• ABROADER provides training to all new employees on the values included in its wider ethical and value-based approach to experiential learning, including in relation to combatting exploitation and modern slavery, and requires acknowledgment of these values when all contracts and third-party agreements are signed.

2.4. Combating Wildlife Trafficking policy

ABROADER pledges to refrain from illegally hunting, trading, transporting, slaughtering, consuming, possessing, or advertising wild animals.

•  During the program’s implementation, ABROADER and its staff, members, and partners do not collaborate with partners who trade and consume wild animals.
• ABROADER is willing to work with units and authorities to protect and combat wildlife trade.
• ABROADER encourages all employees to live a green lifestyle, protecting the environment and spending time to appreciate nature.
• We hopefully express these positive messages to all youth and those who are concerned about preserving wildlife, which is also becoming one of the critical issues in today’s world that needs to be protected. Corresponding to these points, we also motivate staff, members, and partners to participate in the relevant programs, activities or conferences to boost the understandable knowledge on this policy; so then we can accomplish and share this information with more accurate and objective views, to others.

2.5. Anti-Bribery and Anti-Fraud policy

2.5.1. Targets

ABROADER’s policy is to conduct all aspects of its business in an honest and ethical manner, and to ensure compliance with anti-bribery and anti-fraud laws. ABROADER may face an unlimited fine and be barred from bidding on government contracts if it is found to have participated in corruption or failed to implement adequate anti- bribery and anti-fraud procedures.
Any irregularity or suspicion of irregularity involving employees, shareholders, consultants, vendors, contractors, outside agencies, and/or any persons with a commercial relationship with ABROADER is covered by this policy. Regardless of the alleged wrongdoer’s duration of service, position/title, or link to the ABROADER, any needed inquiry will be conducted.

2.5.2. Company responsibility

• Maintain appropriate internal records to demonstrate the business reason for making any payments to third parties.
• Encourage employees to raise concerns about any problem or suspicion of malpractice as soon as possible.
• Make certain that anyone who raises a concern about bribery is not penalized as a result, even if they are mistaken.

2.5.3. Staff responsibility

Employees must not:

• Accept any financial or other reward from anyone in exchange for performing some service.
• Request a financial or other reward from anyone in exchange for doing you a favor.
• Offer any financial or other reward from anyone in exchange for some favor.

Employees are permitted to: assuming, using their best judgment, that their actions do not constitute bribery, employees are permitted to:

• Receive low-value gifts such as food, drinks, or office decorations as part of friendly interactions with partner companies, language schools, universities, and clients.
• Accept that third parties will willingly pay for a shared meal or round of drinks as part of friendly interaction with partner companies, language schools, universities, and clients.

2.5.4. Action Constituting Fraud

Defalcation, misappropriation, and other fiscal irregularities include, but are not limited to, the following:

• Misappropriation of funds, securities, supplies, or other assets.
• Impropriety in the handling or reporting of money or financial transactions.
• Profiteer as a result of insider knowledge of company activities.
• Disclosing confidential and proprietary information to outside parties.
• Disclosing to other persons securities activities engaged in or contemplated by the company Gifts worth less than $50 are exempt.
• Destruction,defacement,removal or misuse of furniture, fixtures, and equipment.
• And/or other similar or related irregularities.

3. Confidentiality

As a staff at ABROADER, individuals commit to the privacy and confidentiality of the participants and stakeholders including host organizations, host families, and local buddies. Sharing any personal information, not for work purposes and/or without the permission of the person is prohibited.
The findings of the investigation will not be disclosed or discussed with anyone other than those with a legitimate need to know. This is critical in order to protect the ABROADER from potential civil liability and to protect the reputations of individuals suspected but later found innocent of wrongdoing.
All staff, members, partners are entrusting us with your information when working with ABROADER. We recognize that this is a significant responsibility, and we work hard to protect your data and put you in control.

ABROADER’s Commitments for protecting the personal information
This explains why and how we collect and organize personal data provided by you when you work or interact with us. This privacy statement also explains how to exercise your personal data rights.
ABROADER pledges to adhere to the following principles in particular:

• Personal data is processed appropriately with applicable laws in a lawful, fair, and transparent manner.
• In accordance with applicable laws, personal data are collected for specific, explicit, and legitimate goals and are not further processed in ways that are not relevant to the aims.
• ABROADER implements appropriate technical and organizational measures to ensure proper security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction.
• ABROADER agrees to follow all other principles required by applicable regulations on the protection of personal data, particularly those relating to the rights granted to data subjects and the obligations relating to cross-border transfers of personal data.

The main following categories may include:

1. Full name, gender, age, nationality, date of birth

2. Phone number, email address, home address, fax number and other information related to the customer’s needs.

3. CV, résume, university, company, working potential, experience and other references.
Confidential information will be under Vietnamese Government Law and ABROADER’s protection, including but not limited to races, political perspectives, religions, philosophical beliefs and medical conditions.
We pledge that the information will be used to benefit collaboration among staff, members, and partners, as well as the development of our communities. It will be used to secure agreement from staff, members, and partners on the timeline for our collaboration. All things considered, it is expected to keep the staff, members, and partners on track of the benefits and mutual goals with ABROADER.

4. Respect the difference

ABROADER members are required to always conduct herself/himself in a professional and ethical manner. This includes, but is not limited to:

• Respect the participants and stakeholders’ culture and differences
• Be fair, considerate, honest, trustworthy, and cooperative when dealing with all parties
• Familiarize with, and adhere to, relevant organizational arrangements and procedures
• Dress appropriately for the work setting
• Make efforts to understand the cultural difference and learn to adapt accordingly
• Listen, and ask questions for the stakeholders if they need help or clarification; avoid jumping to conclusions.

While working with ABROADER, it is necessary to provide the information for Marketing purposes that reach out to the audience, stakeholders more effectively. However, we understand that it depends on the difference and concrete private from providers, including culture; so it is expected to process it properly to the provider’s agreement and its functions as well. In terms of the specific circumstance, ABROADER will contact to ask permission to publish or use the personal information, data, picture, video, etc for the Marketing goals. In case of disagreement from providers, ABROADER makes a commitment not to use/publish any other relevant personal information, data, picture, video, etc on Social Media, Internet, Website, Page and relevance.
Once again, before using for any other purposes on personal information, data, picture, video; ABROADER will always ask for consent and impress our clear goals for the usage.

5. Value all the stakeholders

At ABROADER, we commit to contributing to the local community. All staff, members, and partners have to deal with problems in a positive attitude and be under the organizational system of ABROADER. In local, regional, and international environments, it is vital to be open-minded and friendly in welcoming every single person and to leave no one behind. Staff are required to act with the attitude of valuing all the stakeholders, including host organizations, host families, and local buddies, and treat them fairly in a professional manner.

• Promptly, enthusiastically, and politely when working with all stakeholders
• Paying close attention to the demands, concerns and giving them complete consideration
• Honest, respectful, and knowledgeable communication
• Following up with all stakeholders in a timely, responsible, and efficient manner
• Working with pride, dedication, and high ethical standards
• Respecting every individual and encouraging participation without any forces

In every program, before sending any applications or documents to the host organization, ABROADER staff needs to check carefully that they meet their requirements and do not hurt the host organization or host families.
Any applications or paperwork involving local buddies must be thoroughly scrutinized to ensure that they pose no risk to any stakeholders in our programs.

Supporting Documentation

• ABROADER Program Policies
• ABROADER Agreement with Host Organization
• ABROADER Risk Management and Response Plan
• Policies preference on European Commission, Pagoda Projects, USAID from the American People, local law, principles and global standard for community development.

Compliance and Assurance

ABROADER will monitor compliance through a range of approaches including performance assessments, reviews, non-government organization accreditation processes, and due diligence checks in compliance with local practice and regulations.
Non-compliance with requirements may lead to suspension or termination of the agreement with a partner.

Implementation and Date Effect

The Policy will be implemented incrementally from November 2021. All employees are required to adhere to and support the implementation of the policy. All existing employees and partners of ABROADER will be informed about their role in the implementation of the policy. All new employees, partners, or individuals will be notified within their agreement signed with ABROADER.

Date Approved: November, 2021
Effective Date: November 2021

Abbreviation

PSEAH: Preventing Sexual Exploitation, Abuse and Harassment
CITES: Convention on International Trade in Endangered Species
USAID: United States Agency for International Development
UN: United Nations
WTO: World Trade Organization

References

1. End Wildlife Trafficking Report. (2021). Eliminate, Neutralize, and Disrupt Wildlife Trafficking Act of 2016. Retrieved from https://www.state.gov/2021-end-wildlife-trafficking-strategic-review/
2. European Commission of Environment. (2016). EU Action Plan against Wildlife Trafficking. Retrieved from https://ec.europa.eu/environment/cites/index_en.htm
3. Pagoda Projects. (2021). Additional Documents on Policies. Retrieved from https://pagodaprojects.com/partner-toolkit/#1586509283218-e9fee0af-657e
4. USAID from the American People, News and Information. (2021). USAID helps Vietnam combat Wildlife Trafficking through Strengthening Policies and Law Enforcement. Retrieved from https://www.usaid.gov/vietnam/program-updates/apr-2021-usaid-helps-vietnam-combat-wildlife-trafficking-through-strengthening-policies
5. British Council of Vietnam. (2021). Child Protection Policy. Retrieved from https://www.britishcouncil.vn/en/about/child-protection-policy
6. Association of Certified Fraud Examiners. (2021) Fraud Resources, Fraud Policy. Retrieved from https://www.acfe.com/fraud-resources.aspx
7. Vietnam Airlines. (2020). Vietnam Airlines’ Customer Privacy Policy. Retrieved from https://www.vietnamairlines.com/vn/en/legal/privacy-policy
8. Avast website. (2021). General Privacy Policy. Retrieved from https://www.avast.com/privacy-policy
9. Niantic website. (2021). Politique de vie privée de Niantic. Retrieved from https://nianticlabs.com/privacy/
10. United Nations Human Rights. (1990). Convention on the rights of the child. Retrieved from https://www.ohchr.org/en/professionalinterest/pages/crc.aspx