Safeguarding Policy

Safeguarding Policy

Against discrimination

  • Huairou Commission aims that each person working for our organization respect all peoples’ rights, including children’s rights, and contribute to a working environment characterized by mutual respect, integrity, dignity and non-discrimination. Additionally, this policy aims to comply with the prohibitions stated in the following anti-discrimination laws: discrimination is strictly prohibited federal, state and local laws, including Title VII of the Civil Rights Act of 1964, the Age Discrimination Act of 1975, and the Americans with Disabilities Act of 1990. This policy complies with the prohibitions stated in these anti-discrimination laws. Acts of discrimination will be subject to disciplinary measures up to and including termination.
  • It is Huairou’s policy to afford equal recruitment, employment, training, compensation, benefits, promotions, disciplinary actions and terminations. Huairou does not discriminate on the basis of race, color, creed, religion, sex, national origin, age, or disability, under federal, state, and local law, regulation or ordinance. Huairou will investigate staff complaints alleging violations of equal opportunity standards.
  • Huairou complies with the Americans with Disabilities Act (ADA) and applicable state and local laws prohibiting employment discrimination against qualified individuals with disabilities. Huairou will provide reasonable accommodations to a qualified individual with a disability.
  • Huairou will also provide reasonable accommodations based on the need of pregnancy, childbirth or related medical conditions consistent with applicable federal, state, and local law. Huairou will also provide reasonable accommodation for an employee’s sincerely held religious belief, provided it does not constitute an undue hardship on Huairou.

Against harassment

  • Huairou is committed to a work environment free from harassment. Harassment is understood as any unwanted behavior, physical or verbal (or even suggested), that makes a reasonable person feel uncomfortable, humiliated, mentally distressed or unsafe. Harassment includes – but is not limited to – words, gestures or actions which tend to annoy, alarm, abuse, demean, intimidate, belittle or cause personal humiliation or embarrassment to another; or that cause an intimidating, hostile or offensive work environment. It includes harassment based on any grounds such as race, religion, color, creed, ethnic origin, physical attributes, gender or sexual orientation. It can include a one-off incident or a series of incidents. Harassment may be deliberate, unsolicited and coercive. Harassment may also occur outside the workplace and/or outside working hours. All employees, consultants, and interns regardless of their positions, are expected to behave or comply with this policy and to take appropriate measures to ensure that this type of misconduct does not occur.
  • Any employee who is found to have acted in violation of this policy will be subject to appropriate disciplinary action, which may include termination.

Against sexual harassment, exploitation and abuse

  • At Huairou Commission, we believe all people have a right to live their lives free from sexual violence and any abuse of power regardless of age, gender, sexuality, sexual orientation, disability, religion or ethnic origin. We recognize that there are unequal power dynamics across the organization and in relation to those we serve, and that we face the risk of some people exploiting their position of power for personal gain. Therefore, Huairou Commission will not tolerate its employees, volunteers, consultants, partners or any other representative associated with the delivery of its work carrying out any form of sexual harassment, sexual exploitation or sexual abuse.
  • Huairou Commission commits to supporting survivors, improving safeguarding capacity, reporting, investigating, responding to, and preventing sexual harassment and sexual exploitation and abuse.
  • Huairou Commission is committed to achieving full, ongoing implementation of the Six Core Principles relating to Sexual Exploitation and Abuse by the Inter-Agency Standing Committee (IASC) Working Group on Prevention and Response to Sexual Exploitation and Abuse, the Inter- Agency Standing Committee Minimum Operating Standards on Prevention of Sexual Exploitation and Abuse (PSEA).

Huairou Commission’s Six Core Principles on Prevention of Sexual Exploitation, Abuse and Harassment (PSEAH)

  • Sexual exploitation and abuse by Huairou Commission Employees and Related Personnel constitute acts of gross misconduct and are, therefore, grounds for termination of employment or contract/agreement. Sexual harassment by Huairou Commission Employees and Related Personnel is grounds for disciplinary action up to and including dismissal.
  • Sexual activity with children (persons under the age of 18) is prohibited regardless of the age of the majority or age of consent locally. Mistaken belief in the age of the child is not an excuse.
  • Exchange of money, employment, goods, or services for sex, including sexual favors or other forms of humiliating, degrading or exploitative behavior by Huairou Commission Employees and Related Personnel is prohibited at all times. This includes buying sex or the exchange of assistance that is due to program participants.
  • Sexual relationships between Huairou Commission Employees or Related Personnel and community members we work with are forbidden. Given the contexts where Huairou Commission operates, such relationships may be based on inherently unequal power dynamics and may undermine the credibility and integrity of Huairou Commission’s work. Huairou Commission Employees and Related Personnel must declare any previously existing relationships with community members we work with to the management.
  • Where a Huairou Commission or Related Personnel develops concerns or suspicions regarding sexual abuse or exploitation or sexual harassment by a fellow worker, whether in Huairou Commission or not, he or she must immediately report such concerns via the established reporting mechanisms.
  • Huairou Commission Employees and Related Personnel are obliged to create and maintain an environment that prevents sexual exploitation, abuse and harassment and any form of child abuse and promotes the implementation of this Policy.
  • The Huairou Commission will make every effort to create and maintain a safe, equitable, and inclusive organizational culture where all those who work for and with the Huairou Commission are treated with dignity and their rights and voices are heard and respected. This entails applying gender justice and feminist working principles that include power sharing. This will present us with the opportunities to discuss and reflect on emerging themes with a diverse pool of stakeholders (“nothing about us without us”) that will lead to robust prevention and response work to SEAH, offering support to survivors, and holding those responsible for sexual exploitation, abuse or harassment, to account.

Safeguarding commitments

  • The Huairou Commission is dedicated to fulfilling the following commitments to prevent and respond to sexual exploitation, abuse and harassment (SEAH) as highlighted in the six Core Principles above.
  • We will lead robust prevention and response work to SEA, offering support to survivors, and holding those responsible for sexual exploitation, abuse or harassment, to account.
  • Channels to speak up: we aim to ensure that we have multiple channels for employees, related personnel, community members we work for and with, and others to safely report sexual exploitation and abuse and sexual harassment. These channels should be designed in consultation with local communities and staff to ensure that they are safe and accessible.
  • Ensure that everyone who works on behalf of Huairou Commission and those we serve have information about how to access these safe reporting channels, including messaging that is suitable for children and people of other diversities. This should include posting reporting procedures in local languages and regularly explaining these channels.
  • Provide training and information to all employees and related personnel, particularly focal points for receiving complaints, to ensure they understand their obligations when receiving a complaint.
  • Only staff with delegated authority can report to external donors and regulatory authorities. Survivors/Victims have the right to report directly to regulatory authorities within their country. The Huairou Commission will assist survivors/victims in making a report if they request this.
  • Survivor Center Approach: Creates a supportive environment in which the survivor’s rights and wishes are respected, prioritized, their safety is ensured, and they are treated with dignity and respect. A survivor-centered approach is based on the following guiding principles:
    Safety: The safety and security of the survivor and her/his children is the primary consideration;
    1. Confidentiality: Survivors have the right to choose to whom they will or will not tell their story, and information should only be shared with the informed consent of the survivor. Although there may be instances where an imminent threat of harm to a child or someone else may override confidentiality;
    2. Respect: All actions taken should be guided by respect for the choices, wishes, rights and dignity of the survivor. The role of safeguarding teams is to facilitate recovery and provide resources to aid the survivor;
    3. Non-discrimination: Survivors should receive equal and fair treatment regardless of their age, gender, race, religion, nationality, ethnicity, sexual orientation or any other characteristic.
  • Robust and accountable case management: all allegations of SEAH, and subsequent follow-up, will be documented in a secure and confidential database to ensure accountability. The report will be officially acknowledged within 24-hours, and a safeguarding team will convene a case conference to assess immediate risks and next steps within 72 hours.
  • Huairou Commission will carry out independent, safe, and discreet investigations, through trained investigators, recognizing the rights of and duty of care to everyone involved, including complainant and/or survivor, witnesses and subject of complaint (SoC).
  • The Huairou Commission will take swift and appropriate action against their Employees and Related Personnel who are found to have committed SEAH. This may include administrative or disciplinary action, and/or referral to the relevant local authorities if appropriate and safe to do so.
  • An independent and gender representative decision-making panel will be assigned in every investigation to ensure impartiality, transparency, and accountability (e.g., for country cases the panel may include people from outside of country).
  • The Huairou Commission commits to refer survivors to competent support services as appropriate and available and according to the wants and the needs of the survivor. Support may include specialist psychosocial support such as counseling, medical assistance, and legal counseling.
  • Huairou Commission has a zero-tolerance policy towards inaction against sexual harassment, exploitation, and abuse.

Anti-Fraud and Corruption Policy

Scope
Huairou’s anti-fraud and corruption policy applies to staff members, contractors and consultants; volunteers and interns; the Governing Council; and partner organizations.

Definitions

Fraud is defined as dishonestly obtaining a benefit, or causing a loss, by deception or other unlawful and/or unethical means. Fraud can cover many activities including, but not limited to, the following:

  • Forgery, alteration or misrepresentation of information on documents (e.g., checks, bank drafts, bank statements, time sheets, invoices, quotations, agreements, receipts)
  • Theft, misappropriation or destruction of funds, securities, supplies or other assets
  • Impropriety in the handling of money or financial transactions;
  • Authorization or receipt of payment for goods not received, services not performed, travel and entertainment expenses not incurred, and/or hours not worked;
  • Using Huairou funds to pay for personal expenses;
  • Inappropriate use of the organization’s records and disclosing confidential and proprietary information to outside parties, without consent;
  • Unauthorized use of inventory, furniture, fixtures, equipment or other assets; or
  • Any apparent violation of Federal, State or local laws related to fraudulent activities.

Corruption is defined as the offering, giving, soliciting, or acceptance of an inducement or reward that may improperly influence the action of a person or entity. Examples of corruption include: bribery, conspiracy, or extortion.

Money laundering is the process by which the proceeds of crime are converted into assets, which appear to have a legitimate origin. One area where a charity could be involved is by receiving donations in cash, which the charity is subsequently asked to repay by check or pass on to a third party. This would result in the donor receiving what is referred to as “laundered” money, as it is now from a reputable source. It may not be challenged by the authorities or banking system in the way a large cash sum would, and helps to obscure the trail back to the original corrupt source of the funds.

Legal Obligations

  • Huairou Commission adheres the United States of America federal, state, and local legislation and standards.
  • Huairou Commission’s partners and projects overseas adhere to any local legislation in respect to fraud and corruption.

Commitments to prevent Fraud and Corruption Fraud and Corruption commitments

  • The Huairou Commission is committed to protecting funds and other property entrusted to it by donors, from attempts by – members of the public, contractors, consultants, volunteers, partner organizations, direct beneficiaries, staff or Governing Council members – to gain financial or other benefit by deceit. The Huairou Commission will take all reasonable steps to prevent fraud and will act promptly when actual or suspected fraud is identified.
  • Huairou Commission maintains a ‘zero tolerance’ attitude towards fraud and corruption and:
    • Requires that all staff report any case of suspected or detected fraud and corruption immediately;
    • Adopts a risk management approach to the prevention, detection and investigation of suspected fraudulent and corrupt activity that is incorporated in to its business processes, management practices, internal controls and related activities;
    • Ensures the application of appropriate sanctions against those who have committed fraud and engaged in misconduct, including contacting the police;
    • Actively pursues losses to ensure recovery of funds wherever possible.