Safeguarding & Protection from Sexual Exploitation Abuse & Harassment Policy

1. Introduction 

The purpose of the Safeguarding and Protection from Sexual Exploitation, Abuse and Harassment Policy (SPSEAH) is to safeguard our employees as well as applicants, contractors, participants and external partners from any harm of sexual exploitation, sexual abuse and sexual harassment that may be caused because of their engagement with Global Fishing Watch (GFW). External Partners are our funders and collaborators including Donors, Research Programs, Industry, Academic Institutions, International bodies including Civil Society and non-profit organizations,  and Government agencies etc., with whom we have a formal relationship, a Memorandum of Understanding (MOU), a funded project or some threshold of work that we are doing with them.   

Whilst our work does not bring us in contact with children and vulnerable adults, GFW is committed to safeguarding our employees, contractors, and our external partners in pursuit of our mission, and to protect them from sexual exploitation, abuse, and sexual harassment. GFW is committed to addressing this conduct through prevention, reporting, and our response.

GFW does not tolerate Sexual Exploitation, Sexual Abuse and Sexual Harassment (SEAH).

2. Objectives

This policy covers the protection and responsibilities of our employees, contractors, and our external partners, while carrying out their responsibilities for and on behalf of GFW, and guides our employees, contractors, and external partners in protecting those we come in contact with during the course of our duties. 

GFW will actively prevent Sexual Exploitation Abuse & Harassment in its workplaces and projects; raise awareness on how to recognize and report concerns; and respond to all reported Sexual Exploitation Abuse & Harassment complaints.

This policy outlines the organization’s commitments regarding SEAH and informs employees, contractors, and external partners of their associated responsibilities. 

3. Scope

The policy applies to all employees & contractors of GFW. It also applies to partner organizations.

GFW expects external partners to equally uphold its high standards of Safeguarding and Protection from Sexual Exploitation Abuse & Harassment. External partners are expected to have a robust policy in place that reflects good practice on how they will prevent and respond to Sexual Exploitation Abuse & Harassment complaints and concerns involving program participants and their staff. Where External partners do not have a policy in place, they are expected to follow GFW’s policy for all GFW’s projects they are involved in.

This policy applies both during and outside of contracted working hours and will apply under the following circumstances: 

1. Any SEAH incident involving a GFW employee or contractor. 
2. Any SEAH incident involving a Partner employee or representative whilst working on a GFW (funded) project.

The following falls outside the scope of this policy.

1. Non-SEAH forms of abuse e.g., discrimination, bullying and harassment. These are dealt with under the Anti-Harassment and Anti-Bullying Policy, Disciplinary Policy, or Grievance policy.
2. SEAH incidents involving an external partner (and no GFW staff) in non-GFW funded projects. 

4. Definitions

Protection from Sexual Exploitation, Abuse and Sexual Harassment (PSEAH) is the term used by the international humanitarian and the development sector to describe the measures they take to protect people from sexual exploitation, abuse and sexual harassment perpetrated by their own staff and associated personnel. It is now also extended to mean protecting staff and associated personnel from sexual harassment or misconduct within the workplace.      

The Core Humanitarian Standards (CHS), and the Inter-Agency Standing Committee (IASC) Minimum Operating Standards are the most widely recognized on Protection from Sexual Exploitation and Sexual Abuse and Sexual Harassment in the international and development sector. The definitions under these two standards have been adopted for this policy: 

No employees, contractors,  representatives of GFW or external partners should ever abuse their position of power to sexually exploit, sexually abuse or sexually harass program participants, community members, work colleagues or members of the public.

GFW employees and contractors are also  entitled to work in an environment that is free of harassing behavior of a sexual nature. Sexually harassing behavior is prohibited when submission to such conduct is either explicitly or implicitly made a term or condition of employment or of a contractual relationship, is used as the basis for employment or contractual decisions, or when such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment. No form of sexual abuse will be tolerated in the workplace.Sexual harassment is not limited to sexual contact, touching, or expressions of a sexually suggestive nature. Sexual harassment includes all forms of gender discrimination including gender role stereotyping and treating employees differently because of their gender. Comments or jokes that reflect hostility or censure based on sexual orientation or gender identity or expression, such as physical or verbal abuse concerning an individual’s gender, gender identity or gender expression, are considered a form of sexual harassment.

5. PSEAH Principles

This policy is underpinned by the Six Core Principles relating to Sexual Exploitation and Abuse set out by the Inter-Agency Standing Committee (IASC) Working Group on Prevention and Response to Sexual Exploitation and Abuse, (the committee of UN agencies and NGOs involved in the delivery of humanitarian assistance), to support agencies in implementing PSEAH measures. 

GFW has via this policy, adopted the PSEAH Principles and adapted them to include sexual harassment of GFW employees, contractors and external partners, as follows: 

1. Sexual exploitation, abuse, and harassment by GFW staff and external partners go against GFW’s organizational values and the Staff Code of Conduct & Ethics. SEAH by GFW employees will result in disciplinary action up to and including termination of employment. Where external partners are concerned, a breach of this policy will be grounds for terminating funding or partnership arrangements. 
2. Exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour by GFW employees or contractors based on sex are prohibited. 
3. Where a GFW employee or contractor develops concerns or suspicions regarding sexual abuse or exploitation by a fellow worker, whether in GFW or not, they must report such concerns via the  reporting procedure set out below.  Those reporting are not required to have proof or evidence. 
4. GFW staff are obliged to create and maintain an environment which prevents sexual exploitation and abuse, and promotes the implementation of the Staff Code of Conduct & Ethics. Managers at all levels have responsibilities to support and develop systems which maintain this environment.
   
5. GFW does not tolerate any form of sexual exploitation, sexual abuse, and sexual harassment, and takes seriously any SEAH concern or allegation involving GFW staff, contractor or external partners. This means that we will: 
   1. Take proactive steps to prevent sexual exploitation, abuse, and harassment. 
   2. Respond to every reported concern and, where there is indication of a possible violation of this policy, an appropriate investigation will be initiated, and appropriate disciplinary action will be taken in the event a policy violation is found, as required and in line with local laws. 
   3. Hold all GFW employees and contractors to the same standards and procedures, regardless of their position within the organization. 

It also means GFW will use this policy to help ensure that our employees and contractors do not expose external partners or program participants to the risk of SEAH and that all SEAH concerns, or allegations raised in relation to GFW, are appropriately responded to in a timely manner and reported to the appropriate authorities where warranted.   

GFW commits to addressing SEAH throughout its workplace, and activities using the three-pronged approach of prevention, reporting and response. 

6. Reporting 

GFW considers victim-blaming unacceptable and will ensure that complaints of harassment and bullying are taken seriously and addressed in a timely and professional manner.  

Any incident or concern should be reported in accordance GFW’s Reporting procedures 

7. Roles and Responsibilities

At GFW, we believe SPSEAH is everyone’s responsibility. A breach of this policy or any of its associated policies may result in disciplinary actions up to and including terminations for individuals, and for external partners, termination of contracts and/or funding.  

Specific responsibilities are laid down as follows:

a. Chief Executive Officer The Chief Executive Officer is accountable to the Board for the implementation of the GFW PSEAH Policy across the organization. They will: 

1. Champion safeguarding-PSEAH throughout GFW. 
2. Support the Board to develop their individual and collective understanding of safeguarding-PSEAH. 
3. Ensure the organizational strategic plan reflects statutory and sectoral safeguarding PSEAH standards specific to GFW’s activities. 
4. Work regularly with the Senior Executive Group and the Global HR Director to review GFW’s safeguarding-PSEAH practices, ensuring they create a culture and work environment that prevents SEAH to the maximum extent possible. 
5. Work with the Chief Operations Officer and the Global HR Director to manage all safeguarding-SEAH incidents. 
6. Report serious safeguarding-PSEAH incidents to Regulatory bodies to the extent required by applicable law.  

b. Senior Executive Group The Senior Executive Group in conjunction with the Chief Executive Officer is accountable to the Board for the implementation of the GFW PSEAH Policy across the organization. They will: 

1. Stay informed and knowledgeable about the organization’s progress on safeguarding PSEAH against sectoral standards and legal obligations. 
2. Check that GFW’s PSEAH policy and procedures are fit for purpose and up to date. 
3. Ensure all GFW employees and contractors are aware of their safeguarding-PSEAH responsibilities and know how to report and respond to concerns. 
4. Ensure external partners and others funded by GFW have adequate safeguarding-PSEAH policies and procedures in place. 
5. Ensure reported incidents are taken seriously and managed effectively in line with the policy and applicable procedures, and that records are stored securely. 
6. Ensure the safeguarding-PSEAH agenda and action plans are adequately resourced and budgeted for. 

c. Managers 

1. Must promote a culture of respect and inclusion to help prevent sexual exploitation, abuse, and harassment by providing a safe work environment where staff trust the reporting systems and know their concerns will be treated seriously and appropriate action taken. 
2. Ensure supervisors  understand their mandatory duty to report any PSEAH concern they become aware of or suspect.   

d. Program Leads  

1. Collaborate with relevant colleagues to complete or/and ensure completion of, and subsequently review/update, all safeguarding risk assessments i.e., country context analysis, and where applicable, partnership safeguarding assessments. 
2. Assess inherent safeguarding-PSEAH risks in proposed project activities and location context. Ensure GFW’s safeguarding-PSEAH obligations, expectations and considerations are fully embedded and costed in proposals, concept notes and other project development activities and communication.  
3. Support partner organizations’ safeguarding-PSEAH obligations and commitments to ensure they are met and are consistently in alignment with GFW’s principles. 

e. All GFW Staff 

1. Have a responsibility to uphold GFW’s SPSEAH policy and the Staff Code of Conduct & Ethics. 
2. Have a mandatory obligation to prevent and not engage in any form of sexual exploitation, abuse, and harassment policy and may be required to cooperate as needed in any complaint investigation.  
3. Must know and consider the power they (GFW staff) hold because of their position at GFW and take care not to abuse it. 
4. Should actively seek the support and guidance of their line manager or the Global HR Director when
   • unsure of what to do after witnessing an incident or behavior that does not seem right, or 
   • uncertain about whether what they witnessed is a PSEAH issue. 
5. Must not seek to retaliate against complainants, victims, and witnesses involved in a SEAH incident. 

f. Partner organizations 

1. GFW expects its external partners to either have a PSEAH policy, or follow GFW’s policy.  
2. Report all SEAH incidents related to GFW projects promptly to the Program Manager, or a member of the Senior Executive Group, in accordance with the Whistleblower Policy.