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Prevention of Sexual Exploitation, Sexual Abuse, and Sexual Harassment

Policy Statement

This policy defines Conservation International's (CI) guiding principles with respect to Sexual Exploitation, Sexual Abuse and Sexual Harassment (SEAH) and outlines procedures for preventing, mitigating, reporting, investigating, and remedying SEAH. When the context permits, this policy should be read together with CI's Anti-Harassment Policy.

CI does not directly or indirectly condone, encourage, or tolerate participation, or engagement in SEAH or any conduct substantially equivalent to SEAH as defined in this Policy.

Scope

This Policy applies to all CI employees, fellows, interns, volunteers, and representatives (jointly "CI Staff") as well as CI grantees/awardees, contractors, suppliers, consultants and their employees, sub-grantees/-awardees, and representatives (jointly "CI Delivery Partners"). The policy includes both expectations and requirements for CI Staff and Delivery Partners to manage the risk of SEAH and SEAH incidents, should they occur in the delivery of CI business[1].

Principles

This policy is underpinned by six principles.

  • ​Prevention is a shared responsibility: CI believes prevention of SEAH is a shared responsibility and all must play an active role in preventing and addressing any SEAH related concerns in the course of delivering CI Business. CI Staff have an obligation to familiarize themselves with this Policy and report any SEAH Violation.
  • Zero tolerance: CI is committed to adhering to the ethical principles as defined in its Code of Ethics and promotes high ethical work standards as part of our working culture. CI has zero tolerance for SEAH conduct. CI defines tolerance as acting on every allegation in a fair and reasonable way with due regard for procedural fairness.
  • Victim/survivor needs are prioritized: CI is committed to ensuring all our work is underpinned by a "do no harm" approach and prioritizing the rights, needs, and wishes of the victim/survivor while ensuring procedural fairness to all parties.
  • Creating a healthy, inclusive workplace: CI actively promotes equality to provide a collegiate, lawful, and harmonious working and learning environment.
  • Confidentiality and due process: CI will promptly and thoroughly investigate all SEAH complaints and strive for procedural fairness to all parties. Every effort will be made to protect the privacy of all complainants, reporters, and the subjects of complaint. While CI cannot guarantee complete confidentiality, information about the complaint and investigation will be limited to individuals with a need-to-know basis.
  • Accountability and Transparency in reporting: CI holds itself accountable to the people we serve including beneficiaries, communities, our partners, donors, and CI staff. CI is committed to accountability and transparency through appropriate, accessible, and safe reporting mechanisms. We also support our partners to do the same. Stronger reporting allows CI to better monitor SEAH, understand risks, improve systems, and safeguards accordingly.

Prevention and Detection

This Policy takes a risk-based approach to prevent SEAH within our programming. Through the application of CI's Safeguard System[2], projects will assess the level of risk for SEAH occurring with both CI Staff and CI Delivery Partners and apply proportionate preventative measures at both the project level and organizational level as necessary. This may include SEAH protection plans to detect and mitigate SEAH risk.

Reporting

Any CI Staff or Delivery Partner who suspects, experiences, observes, or becomes aware of conduct that violates this Policy, is obligated to report the possible violation immediately through CI's established grievance reporting mechanisms as outlined in CI's Conflict Resolution and Formal Complaints Policy. CI is committed to treating all victims with dignity and respect, to listening and being led by the wishes of the victim where possible and appropriate to do so.

Retaliation against any individual who submits a SEAH report in good faith is prohibited in accordance with CI's Conflict Resolution and Formal Complaints Policy.

Investigations

CI will promptly and thoroughly investigate all SEAH complaints in accordance with its established investigations procedures. Every effort will be made to protect the privacy of all complainants, reporters, and subjects of a complaint. While CI cannot guarantee complete confidentiality, information about the complaint and investigation will be limited to individuals with a need-to-know basis.

CI Delivery Partners shall cooperate and ensure the cooperation of persons and entities (under their control) with CI and CI designated parties in any SEAH related investigation.

As required under applicable donor policies and regulations, CI will report allegations or suspicions of SEAH to donors and cooperate with donor investigations. As appropriate and with the expressed desire of the victim, CI will make reports to state agencies with authority over the criminal prosecution of SEAH offenses.

Consequences of Policy Violations

If an investigation confirms that a SEAH violation by CI Staff has occurred, CI will take disciplinary action, up to and including termination as appropriate. Violation of this Policy, failure to comply with the applicable contractual language in the CI sub-contract or CI sub-award by a CI Delivery Partner will result in remedial action, which may include termination of the sub-contract or sub-award for cause and disqualification from future contracts or grants with CI.

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Definitions:

"SEAH" means Sexual Exploitation, Sexual Abuse, and Sexual Harassment;

"Sexual Abuse" means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. All sexual activity with a child, defined as someone under the age of 18 or under the age of consent as defined by host country law is considered to be sexual abuse.

"Sexual Exploitation" means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, threatening or profiting monetarily, socially, or politically from the sexual exploitation of another;

"Sexual Harassment" any unwelcome sexual advance, request for sexual favor, or other verbal, non-verbal, or physical conduct of a sexual nature, that interferes with work, is made a condition of employment or creates an intimidating, hostile, or offensive environment in connection with the delivery of CI business and, for the avoidance of doubt, Sexual Harassment may occur between or amongst persons of different sexes or genders or of the same sex or gender and may be initiated by any gender or sex[3].

Footnotes:

[1] This Policy addresses the sexual exploitation, abuse and harassment of adults. It does not replace CI's Child Protection and Safeguarding Policy. In addition, CI Staff and CI Delivery Partners are reminded of additional obligations under CI's Workplace Environment Policies as well as CI's Anti-Trafficking In Persons Policy.

[2] CI will adopt a full Safeguard System in the second half of 2021, with policies, standards and procedures for the screening, due diligence, mitigation, monitoring and reporting of environmental and social risks and impacts. The purpose of the CI Environmental and Social Safeguards System ('CI Safeguard System or CISS') is to provide CI staff and Project Teams with procedures to avoid (or minimize) adverse environmental and social impacts, and to enhance positive impacts to the maximum extent possible throughout the project cycle. The CISS promotes human rights by seeking to reduce equity gaps and facilitating the enhancement of social and environmental sustainability.  These commitments expand on existing safeguard policies and procedures already in place for some public funding at CI. By July 2022, CI's Safeguard System will apply to all public and private project and program funding.​

[3] Note: even if an individual voluntarily participates in activities or discussions of a sexual nature, the actions may constitute sexual harassment if the individual indicates that the conduct was unwelcome. Moreover, even consensual sexual relations can constitute sexual harassment if they are so pervasive in the office as to interfere with the work environment or the work performance of others not part of these consensual relationships. Sexual harassment is not gender-based. For the avoidance of doubt, Sexual Harassment may occur between or amongst persons of different sexes or genders or of the same sex or gender and may be initiated by any gender or sex.