Introduction

ABROADER does not tolerate sexual exploitation, abuse, or harassment (SEAH) of any kind. This applies to our own organization and extends to those we work with.

The Policy outlines both expectations and requirements for ABROADER staff and our partners to manage the risk of SEAH and SEAH incidents should they occur in the delivery of the ABROADER program. Preventing SEAH (PSEAH) is a shared responsibility. All organizations must play an active role in addressing SEAH that occurs during their business. ABROADER will give practical effect to the Policy through agreements, reporting requirements, and regular communication with our staff and partners.

Key Definition

This Policy uses the following descriptions of sexual exploitation, sexual abuse, and sexual

harassment, which combine international and Australian definitions:

Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially, or politically from the sexual exploitation of another.

Sexual abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual offenses, including but not limited to: attempted rape (which includes attempts to force someone to perform oral sex); and sexual assault (which includes non-consensual kissing and touching). All sexual activity with someone under the age of consent (in the law of the host country or under Australian Capital Territory law [16 years], whichever is greater) is considered to be sexual abuse.

This Policy uses the following descriptions of sexual exploitation, sexual abuse, and sexual

harassment, which combine international and Australian definitions:

Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially, or politically from the sexual exploitation of another.

Sexual abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual offenses, including but not limited to: attempted rape (which includes attempts to force someone to perform oral sex); and sexual assault (which includes non-consensual kissing and touching). All sexual activity with someone under the age of consent (in the law of the host country or under Australian Capital Territory law [16 years], whichever is greater) is considered to be sexual abuse.

Sexual harassment: A person sexually harasses another person if the person makes an unwelcome sexual advance or an unwelcome request for sexual favors, or engages in other unwelcome conduct of a sexual nature, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated, or intimidated. Sexual harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated or one-off, and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against beneficiaries, communitymembers, and, citizens, as well as staff and personnel.

Fraternization: any relationship occurring in the course of conducting business 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 sexual behavior not amounting to intercourse, a close and emotional relationship involving public displays of affection or private intimacy, and the public expression of intimate relations.

Scope

The policy scope applies, but is not limited to:

• ABROADER staff
• External service providers, independent contractors, and accommodation providers
• ABROADER program participants, both staff and students
• ABROADER program host organizations

All staff, service providers, contractors, and program participants are expected to comply with the principles and reporting requirements specified in this Policy.

ABROADER students are reminded of other obligations that may apply to them i.e: the program Code of Conduct.

Providers must also abide by their own relevant policies, international declarations, conventions, agreements, and domestic legal frameworks that relate to preventing sexual exploitation, abuse, and harassment. 

Through our partnership agreements, ABROADER will seek our best effort to ensure that PSEAH is upheld in other organizations that we work with.

Principles

ABROADER will take all reasonable steps to prevent sexual exploitation, sexual abuse, and sexual harassment and to promote the rights of people and communities with whom we work.

The principles that underpin our Policy are:

Principle 1: Zero tolerance of inaction

Sexual exploitation, abuse, and harassment are never acceptable. Zero tolerance is not the same as zero incidents and reports of incidents may increase as organizations improve safeguards. Increasing reports may indicate a growing awareness of SEAH and changing attitudes, with victims/survivors feeling more comfortable reporting and organizations more likely to take action.

Principle 2: Strong leadership accelerates culture change 

ABROADER expects leaders to set clear expectations and model respectful behavior in their interactions at work. This will support communities, victims/survivors, and whistleblowers to feel safe, report concerns, and be assured their allegations are taken seriously.

This can include strong, actionable human resource procedures that embed gender equality and PSEAH; inclusion of PSEAH discussions on board meeting agendas; having senior champions responsible for PSEAH, and encouraging staff gender balance, particularly in senior roles. Leaders should encourage scrutiny of their own behavior and that of senior management.

Principle 3: Victim/survivor needs are prioritized

Action to address SEAH should be underpinned by a “do no harm” approach prioritizing the rights, needs, and wishes of the victim/survivor while ensuring procedural fairness to all parties. 

This approach treats the survivor with dignity and respect, involves them in decision making and provides them with comprehensive information. It also protects privacy and confidentiality, does not discriminate based on gender, age, race/ethnicity, ability, sexual orientation, or other characteristics, and considers the need for counseling and health services to assist the victim/survivor with their recovery.

Principle 4: Preventing Sexual Exploitation, Abuse and Harassment is a shared responsibility

ABROADER requires the commitment, support, and investment of its partners for this Policy to be effective. All organizations have a responsibility to build their capacity to deal sensitively and effectively with SEAH that occurs in the course of their work.

Principle 5: Gender inequality and other power imbalances are addressed

Available data indicates that the majority of SEAH victims/survivors are female, and the majority of perpetrators are male. However, there are also other power imbalances at play. Inequalities based on the distinctions of worker/beneficiary; ability/disability; ethnic and Indigenous status, religion, gender identity and sexual orientation, age, health, and poverty can also result in SEAH. The intersection of gender with other forms of inequality can further increase the likelihood of SEAH occurring. Engagement with intended beneficiaries should be based on respect for diversity, promotion of gender equality and social inclusion, accountability, and a strong “do no harm” focus.

Principle 6: Stronger reporting will enhance accountability and transparency

Sexual exploitation, abuse, and harassment are failures of responsibility. The organizations and individuals who deliver ABROADER business are not only accountable to ABROADER but also to the communities, customers, and clients for whom the business is intended. Stronger reporting allows ABROADER to better monitor SEAH, understand risks, improve assurance, and work with organizations to improve systems and safeguards accordingly. Reporting will also help to focus organizations on the issue by providing a regular prompt that PSEAH is a core obligation of their work.

Risk Assessment

The Policy takes a risk-based, proportional approach to PSEAH. ABROADER staff and partners must assess the level of risk for SEAH occurring. Risk and decision-making processes and documents are incorporated into existing activity planning and risk management processes. ABROADER will try our best to assess risk and ensure the policy is upheld by the partners we work with.  It is the responsibility of ABROADER partners to ensure controls are in place to manage and monitor the risk of SEAH and ensure processes are adhered to.

Reporting

When alleged incidents are reported, ABROADER will work with the organization or individual to track incident management. In accordance with Principle 3 — Victim/survivor needs are prioritized — victims’ and survivors’ safety and well-being must be paramount to reporting and their information treated confidentially. Whistleblowers must similarly feel safe and protected during the reporting process. ABROADER expects two kinds of incident reporting: 

• Mandatory and immediate (within two working days of becoming aware of an alleged incident) reporting by all staff and ABROADER partners of any alleged incident of sexual exploitation, abuse, or harassment related to the delivery of ABROADER business This includes any alleged incident that poses a significant reputational risk to ABROADER. For example, an allegation against a senior staff member of a partner organization 
• Mandatory reporting (within five working days) by all staff and ABROADER partners of any alleged Policy non-compliance; for example, failure to adhere to the PSEAH Policy Minimum Standards or principles 

Who Reports 

All ABROADER staff and partners, as defined under the Policy’s scope must report any alleged incidents of sexual exploitation, abuse, harassment, or policy non-compliance. 

What is reported 

Reporting is for any suspected or alleged cases of SEAH perpetrated by anyone within the scope of the Policy in connection with official duties or business. If in doubt, staff and ABROADER partners should report an alleged incident. 

How to report 

All reports of alleged SEAH incidents should be made in line with the ABROADER Risk Management and Response Plan.

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 practices and regulations.

Non-compliance with requirements may lead to suspending or terminating any active agreement with a partner.

Supporting Documentation

• ABROADER Risk Management and Response Plan
• ABROADER Program Policies
• ABROADER Agreement with Host Organization

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.