Westminster Foundation for Democracy (“WFD”) recognises the organisation’s responsibility to protect those that it works with from sexual exploitation or abuse (SEA) as a result of our programmes. The risk of SEA is higher when there is a power imbalance. This means that children, young people and women are generally more vulnerable than others. WFD’s Code of Conduct sets out our values and expected standard of behaviour of WFD staff and others working with us. This safeguarding policy sets out, in more detail, how WFD will manage and mitigate risks of sexual exploitation or abuse that arise in the course of our work and the implementation of our programmes.
WFD will comply with all relevant legal and donor requirements regarding safeguarding.
- As part of its approach to Code of Conduct and Reporting Concerns, follow the four-stage process: 1) prevent harm, particularly sexual exploitation and abuse and sexual harassment, from occurring; 2) encourage all stakeholders to report concerns and listen to those who are affected; 3) respond sensitively but robustly when harm or allegations of harm occur; and 4) learn from every case.
- Lay out appropriate standards of behaviour for staff and all those engaged by WFD via the WFD Code of Conduct.
- Assess risk at each stage of programme design and implementation and effectively manage risks in line with this Safeguarding Policy and the Risk Management Policy.
- Ensure all staff, governors, contracted experts and sub-contractors/sub-grantees are made aware of this Policy and the standards of behaviour they are expected to adhere to, as set out in the Code of Conduct, with capacity support provided as appropriate.
- Provide appropriate advice and training/support to members of staff regarding the Code of Conduct, this policy, associated procedures, and implementation
- Adhere to legal and donor standards.
- Ensure all staff and partners are made aware of the Reporting Concerns Policy, which sets out several appropriate reporting routes should there be a breach or suspicion of breach of the Code of Conduct or this Policy
- Promote the Reporting Concerns Policy, including the whistleblowing protections referred to in that Policy.
- Ensure a supportive and open environment where staff can feel confident in reporting any safeguarding concerns
- In accordance with the Reporting Concerns Policy, investigate all Safeguarding concerns raised, and ensure fair process in all investigations.
- Seek external legal advice and/or request independent reviews as necessary.
- In principle, WFD will deliver programmes working directly with children or particularly vulnerable adults only by exception
- As part of its response in line with the Reporting Concerns Policy, notify the appropriate authorities and provide full support to enquiries and investigation to ensure perpetrators are held accountable for their actions
Child abuse is all forms of physical and/or emotional ill-treatment, sexual abuse, neglect or negligent treatment or commercial or other exploitation, resulting in actual or potential harm to the child’s health, survival, development or dignity in the context of a relationship of responsibility, trust or power.
A child is defined as anyone under the age of 18 years old regardless of local custom or age of consent locally
Safeguarding is defined as the responsibility that organisations have to make sure their staff, operations, and programmes do no harm (physical or psychological) to children and vulnerable adults, and that they do not expose them to the risk of harm and abuse. Protection from Sexual Exploitation and Abuse (PSEA) and child abuse come under this umbrella term. Generally, the term does not include sexual harassment of staff by staff, which is usually covered by organisation’s bullying and harassment policy, which is contained with WFD's code of conduct.
Sexual Exploitation constitutes any actual or attempted abuse by personnel of a position of vulnerability, differential power or trust for sexual purposes, including profiting monetarily, socially or politically from the sexual exploitation of another. It is a broad term, but it includes transactional sex, solicitation of transactional sex and exploitative relationships.
Sexual Abuse means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. Sexual abuse is a broad term, which includes a number of acts including sexual assault (for example, rape, attempted rape, forcing someone to perform oral sex / touching), sexual offence and sexual offence against a child.
Sexual Harassment is defined as any form of unwanted verbal, non-verbal or physical conduct of a sexual nature with the purpose or effect of violating the dignity of a person, in particular when creating an intimidating, hostile, degrading, humiliating or offensive environment. Sexual harassment includes all such acts perpetrated against beneficiaries, community members, citizens, as well as staff, personnel, etc.
Risks in WFD Programming
The vast majority of WFD’s programmes are focused on political institutions in our partner countries, and our interactions are with one or more of the following groups:
- Members of parliament
- Parliamentary officials
- Political party leaders
- Political party officials
- MPs staff
- Civil society organisations
- Election officials
- Candidates for elected office
- Politically-active individuals
Engaging young people in the political system is a WFD priority but those programmes usually focus on young adults and WFD does not regularly deal directly with children in our programmes. WFD aims not to exclude individuals with childcare responsibility from programme activities and, where possible, schedules activities for standard working hours. There will be cases where parents may bring their children to programme activities.
Most of the activities in WFD programmes involve organised meetings to share expertise or to provide more formal training. These meetings can take place in a range of locations but are typically in parliaments, hotels or other private venues with meeting spaces, or political party offices. The events can take place in the UK or in a partner country and almost always take place during working hours.
WFD programmes also often involve overseas visits by international delegations. Accommodation is always in international standard hotels, but for some participants the visit might be their first time in the country concerned and they might be in situations that are unusual for them.
The general assessment is therefore that risk of SEA is most likely to be for women, and that the greatest risk is if individual women are placed in situations where they would be alone with one or a small number of men, especially in locations in which it would be difficult to seek help.
Another key vulnerable group is young people, who, at an early stage of their career and with limited life experience, may feel pressurised into uncomfortable or dangerous situations to further their career or to avoid ‘offending’ more senior and experienced individuals. They may also be more susceptible to blackmail or persuasion.
However, since individual WFD programmes could depart from the general pattern, new risks could arise. For any WFD-supported activities that may involve vulnerable stakeholders, including children or vulnerable adults, the safeguarding risks will be assessed on a case by case basis, assessed in detail at programme design stage, and regularly reviewed in programme implementation.
Policy Implementation Framework
1. Governance accountability
The Board of Governors of WFD is ultimately accountable for overseeing the enforcement of this Policy and ensuring the proper management of WFD’s arrangements to manage safeguarding.
The Board may delegate this accountability to the People Committee from time to time.
2. Management responsibility
The Chief Executive Officer (CEO), as the Senior Responsible Officer (SRO) for the Code of Conduct, holds overall responsibility for developing and implementing this policy.
At all times, there will be two nominated Safeguarding Officers who will assist the CEO to discharge his or her functions as SRO.
3. Scope and application
The Code of Conduct and this policy applies to all those working for and on behalf of the organisation, including:
- WFD staff, wherever these staff are based (London office, home based, field based);
- WFD Governors;
- Individuals engaged by WFD such as Associates, contracted experts, consultants, agency workers, interns, volunteers or any individuals actively involved in WFD’s programmes; and
- Staff of sub-contractors/sub-grantees or anyone working for or engaged by those organisations such as associates, contracted experts, consultants, interns, volunteers or any individuals actively involved in WFD’s programmes.
Where sub-contractors/sub-grantees have their own safeguarding policy in place, this may be used by the organisation as long as it is deemed suitable and stringent by WFD following a review of the policy.
Sub-contractors/sub-grantees will be required to report any concerns regarding safeguarding to WFD directly prior to engagement and at any point during their engagement with WFD, in addition to following their own internal reporting requirements.
This policy is designed to protect any WFD stakeholder, whether staff, consultants, staff of implementing partners, and individuals and communities with which we work.
4. Stakeholder roles and responsibilities
a) Dissemination of Code of Conduct and this Policy
The WFD Code of Conduct sets consistent standards for behaviour and ethics of all staff, consultants, and implementing partners.
All those working for and on behalf of the organisation including but not limited to: WFD staff, contracted experts, governors, sub-contractors/sub-grantees and, where appropriate, direct beneficiaries shall be made aware of the organisation’s Code of Conduct and the reporting mechanisms in the Reporting Concerns Policy.
All staff, governors, contracted experts and sub-contractors/sub-grantees shall be required to sign an appropriate version of the Code of Conduct and confirm they have read and understood the contents of this policy. Failure to read the policy or misunderstanding of its contents will not be accepted as justification for deviating from the intent. If staff or governors are unsure of any aspect of this policy, they must immediately raise this with the people referred to in Section 6 to seek clarification. Contracted experts or sub-contractors/sub-grantees should contact the SRO of the programme.
Website and poster/business card sized summaries of the Code of Conduct should be produced and shared to ensure that activity participants are aware of WFD’s expectations for behaviour and ethics.
b) Designing and delivering regular activities
At the design stage of each programme, the Senior Responsible Officer (SRO) for the relevant programme will consider and document safeguarding risks that could be reasonably foreseen and identify mitigation measures. These will be reasonable and proportionate given the scope of WFD’s work.
WFD Programme SRO responsibilities: WFD will also take a series of measures to mitigate the risk of SEA occurring during its programme work:
- At programme design phase, WFD will assess the risk of SEA and consider ways to avoid or mitigate the risk through adjustments to the programme
- WFD will provide materials about our Code of Conduct and Reporting Concerns Policy for distribution to programme beneficiaries and partners.
- Briefing material for inward and outward visits will specifically address the Code of Conduct and PSEA
- Transport arrangements will be considered that ensure that women attending are not exposed to additional risks
- Gender balance should ensure that women attending are not at risk of feeling isolated
- Consider the appropriateness of venues used to events and meeting to ensure vulnerable individuals are not put in an environment that increases the risk of SEA. For example, Meeting rooms and facilities should not be isolated
- When taking part in specific WFD activities, all beneficiaries shall be made aware of their right to be safe from abuse, the organisation’s Code of Conduct and reporting mechanisms.
- Make beneficiaries aware of the risk of sharing personal information (e.g. contact details and/or details of accommodation) as this may increase the risk of harassment or abuse
- Conduct thorough due diligence on partnering organisations and specifically ensure that they too have clear and robust policies and procedures in place for managing and mitigating SEA.
WFD Management responsibility:
- Material used for recruitment and commissioning of experts to be involved in WFD activities shall include a statement on WFD’s Code of Conduct and policy on preventing SEA and a requirement to disclose any facts that might relate to a risk of SEA.
- WFD shall strengthen its procedures to specifically cover the risks of SEA when making reference checks on potential experts and use a risk-based approach to vetting.
- WFD’s induction programme for staff and for experts will cover the Code of Conduct and issue of SEA.
- WFD’s website will include a summary of the Reporting Concerns Policy, including contact information for anyone that wants to report an incident
c) Designing and delivering higher risk activities
If, at the design stage of the programme, the SRO for the relevant programme identifies a higher level of safeguarding risk, due to the nature of the event or activity and the participation of children or vulnerable adults, the SRO shall be responsible for taking the following additional steps:
- Consult with the Safeguarding Officers well in advance of the activity or event;
- Use the Good Practice Checklist on Safe Events or Activities to help prepare for the event; and
- Complete a Safe Event or Activity Risk Assessment form, which should be signed-off by a Safeguarding Officer
d) Raising concerns
The Reporting Concerns Policy establishes a unified mechanism for any person to raise concerns about a potential breach of the Code of Conduct and/or this Safeguarding Policy, by a WFD staff member, consultant, or implementing partner.
All stakeholders are encouraged to report any safeguarding concerns under the Reporting Concerns Policy.
WFD appreciates the sensitivity of safeguarding issues and the power imbalances that may make staff and others reluctant to report their concerns. Staff, governors and contracted experts should be reassured that they are protected by the whistleblowing protections incorporated in our Reporting Concerns Policy, with rights set out in a legal framework, and have confidence that they will not be victimised for any concern reported in good faith.
Failure on the part of the sub-contractor/sub-grantee to report cases of SEA or child abuse to WFD will lead to sanctions against the sub-contractor/sub-grantee, up to and including termination of the sub-contract (for the most severe cases).
Any intentionally false or malicious statement or accusation by a staff member against another colleague or third party will be considered misconduct and will result in disciplinary action.
Website and poster/business card sized summaries of the Reporting Concerns Policy should be produced and shared to ensure that activity participants are aware of how to report any actual or potential breaches.
e) Response procedures
WFD will develop Response Procedures which will establish robust guidelines for responding to and investigating any concerns raised under the Reporting Concerns Policy. There will be Non-Compliance Incident Response Procedures and Safeguarding Incident Response Procedures.
All concerns raised will be reviewed and, as appropriate, investigated with due and fair process, including by way of an independent investigation as appropriate.
The Response Procedures will include guidance on the range of sanctions that may be applied in different cases. The following principles will apply:
- Following a full and thorough investigation, any confirmed SEA or child abuse by staff shall be considered gross misconduct and result in immediate summary dismissal (which will be handled in line with WFD disciplinary procedures). Any activity which is deemed to have broken local or UK laws will also be reported to the appropriate authorities.
- Any confirmed SEA or child abuse by contracted experts shall be considered a breach of contract and result in immediate removal from the programme. Any activity which is deemed to have broken local or UK laws will also be reported to the appropriate authorities. A full note will be attached to the individual’s entry on WFD’s Expert Database to ensure the expert is not used again by the organisation.
- Any confirmed SEA or child abuse by a member of sub-contractors’/sub-grantees’ staff or contracted expert shall be considered a breach of contract and result in WFD instructing the sub-contractor or sub-grantee to remove that individual from the programme. WFD will also report any alleged incidents of SEA or child abuse to the perpetrator’s employer (i.e. the sub-contractor/sub-grantee) and will co-operate fully with any further investigation or disciplinary action taken by the employer and to ensure UK or local requirements are followed and, where an activity is deemed to have broken the law, are reported to the appropriate authorities.
WFD will develop Review Procedures which will be a process for periodic review and continuous improvement of reporting on and responses to any concerns raised.
Following any reported concern in relation to the Code of Conduct, including safeguarding issues, WFD will review the Code of Conduct, this safeguarding policy and the Reporting Concerns Policy, and all relevant procedures and identify any improvements to be made. The CEO, as SRO for the Code of Conduct, will be responsible for ensuring implementation of any required improvements.
5. Safeguarding Officers
The current nominated Safeguarding Officers are:
- Jon Spence, Head of HR (Jon.Spence@wfd.org)
- Sophia Fernandes, Senior Adviser, Political Inclusion (Sophia.Fernandes@wfd.org)
At present, the designated Safeguarding Board member is Anthony Smith.
In addition, guidance on incorporating Safeguarding into programme design and advice on donor compliance can be obtained from:
- Karen Rogers, Head of Business Development (Karen.Rogers@wfd.org)