CHILD PROTECTION AND SAFEGUARDING (CPAS)

PURPOSE AND INTRODUCTION

This Policy describes Conservation International’s guiding principles with respect to child protection and safeguarding children. Building upon our core value of respect for all individuals in all aspects of our work, Sustaianble Development Council (SDC) is committed to protecting the rights of children with whom we interact. We abide by applicable U.S, host country, and local child welfare and protection legislation and international standards, whichever provides greater protection. This policy expands on SDC’s Code of Conduct, which outlines ethical standards and acceptable behavior applicable to SDC operations and complements SDC’s Anti-Trafficking Policy and Prevention of Sexual Exploitation and Abuse Policy. This policy should be read and applied with SDC’s Safeguards System (CISS) to avoid or minimize adverse environmental and social impacts, and to enhance positive impacts to the maximum extent possible in our projects.

SDC’s work with communities at times brings SDC staff and delivery partners into contact with children. Integrating child protection and safeguarding in project planning and implementation is of paramount importance to determine potential risks to children associated with project activities and operations and design appropriate mitigation measures. In the implementation of donor-funded projects, SDC will also adhere to child protection and safeguarding policies of those donors that may be more stringent than this Policy.

SCOPE

This Policy applies to all SDC employees, interns, fellows, volunteers, and representatives (jointly, “SDC Staff”), as well as SDC grantees/awardees, contractors, suppliers, consultants, and their employees, sub-grantees/awardees, and representatives (jointly, “Delivery Partners”) engaged by SDC and who come into contact with children, including for the performance of U.S. federal government contracts, awards or cooperative agreements and other applicable agreements.

OUR PRINCIPLES IN ACTION

We aim to create an environment where any issue or concern regarding child protection and safety can be raised and dealt with appropriately. Transparency and accountability are essential to ensure that issues and concerns can be addressed, potentially abusive behavior challenged, and best practices promoted. SDC is committed to safeguarding children through the following principles and related actions:

Awareness: SDC will ensure that all SDC Staff and Delivery Partners are aware of this policy, their responsibilities towards the safeguarding of children, and the ways they can report concerns. SDC requires all SDC Staff to abide by SDC’s Child Protection and Safeguarding Policy and Code of Ethics and complete a policy acknowledgment form. SDC requires all Delivery Partners and their employees, sub-grantees/awardees, and representatives to acknowledge awareness of and compliance with SDC’s Child Protection and Safeguarding Policy and Code of Ethics in grantee agreements and contracts.

Prevention: As an employer, SDC will not directly employ anyone under the age of 18. SDC will ensure, through awareness and prevention activities, that SDC Staff and Delivery Partners minimize risk to children. SDC requires all projects and programs involving children to establish procedures to protect children and report any concerns. This responsibility begins with appropriate screenings and checks completed before hiring new SDC Staff which can include criminal record checks, professional reference checks, and interview plans that incorporate relevant behavioral-based interview questions. This also includes project teams documenting due diligence of Delivery Partner capacity to manage such risks and protection activities, providing capacity building where necessary.

In addition, SDC takes a risk-based approach to prevent child abuse within our programming. Through the application of SDC’s Safeguard System, projects will assess the level of risk for child abuse occurring with both SDC Staff and Delivery Partners and apply proportionate preventative measures at both the project level and organizational level as necessary. This includes screening all SDC projects for contact with children. For those projects that involve direct contact with children, further steps may be required including assessing identified child abuse risks, developing child protection plans to detect and avoid or mitigate child abuse risk, targeted training/capacity building, and where relevant, more frequent monitoring.

Responding: SDC will ensure that appropriate action is taken to address all allegations of abuse promptly. This will include actions specific to alleged perpetrators, as well as provide necessary assistance, referrals, and support to the victim. SDC will implement effective and timely investigation processes. The best interests of the child will be our priority and we will strive to ensure their safety, health, and well-being, including addressing their emotional, psychological, and physical needs.

IMPLEMENTATION

The aim of SDC’s Child Protection and Safeguarding Policy is to protect the best interests of the child and prevent and protect children from abuse.SDC Staff and Delivery Partners that will come into contact with children are required to ensure that all interactions with children are respectful and appropriate. SDC Staff and Delivery Partners may not:

• Use inappropriate language or behavior towards or in the presence of children. This includes harassing, abusive, sexually provocative, demeaning, or culturally inappropriate language or behavior.
• Condone or participate in behavior with children that is illegal, unsafe, or abusive, including being part of harmful traditional practices, spiritual or ritualistic abuse
• Act in ways intended to shame, humiliate, belittle or degrade a child, or otherwise perpetrate any form of abuse.
• Spend excessive time alone with a child, away from others, behind closed doors, in a vehicle, or a secluded area without permission from the child’s parent, guardian, or caregiver. Invite unaccompanied children into private residences unless they are at immediate risk of injury or in physical danger.
• Sleep close to unsupervised children unless absolutely necessary (for example space constraints), in which case the supervisor’s permission must be obtained, and ensure that another adult is present if possible (noting that this does not apply to an individual’s children or family).
• Hit or otherwise physically assault or abuse children.
• Behave physically in a manner that is inappropriate or sexually provocative or develop physical or sexual relationships with children.
• Do things of a personal nature for a child that they could do for themselves or show favor or provide gifts to children to the exclusion of others.
• Be under the influence of alcohol or drugs when assuming responsibility for a child.
• Exploit children for labor (for example dangerous agricultural or forestry activities) or sexual purposes (for example prostitution) or any other conditions that violate this policy and SDC’s Anti-Trafficking in Persons Policy and SDC E&S Standard 7 on Labor and Working Conditions.
• Take or distribute images, videos, or information of a child that would allow a child to be identified without consent from the child’s parent, guardian, or caregiver;
• Take or distribute images of children that are exploitative or do not respect their dignity.

REPORTING REQUIREMENTS AND PROCEDURE

All SDC Staff and Delivery Partners are required to report any child abuse and safeguarding concerns or violations of this policy to CI. Individuals may report concerns on a confidential basis via SDC’s online Ethics Hotline or by emailing info@sustainabledevelopmentcouncil.org. All SDC Staff who receive a report or hear a concern from another individual must immediately share all pertinent information with SDC’s General Counsel and Chief Compliance Officer. For projects with direct contact with children, project-level grievance mechanisms will be designed to be child-friendly and any child abuse-related reports immediately elevated to SDC’s Global Grievance Committee.

SDC will promptly and thoroughly investigate all child abuse complaints in accordance with established investigation procedures. Every effort will be made to protect the privacy of all complainants, reporters, and subjects of a complaint. Delivery Partners shall cooperate and ensure the cooperation of persons and entities (under their control) with SDC and CI-designated parties in any child abuse-related investigation. Retaliation against any individual who submits a report in good faith is strictly prohibited in accordance with SDC’s Conflict Resolution and Formal Complaints Policy.

As required under applicable donor policies and regulations and taking confidentiality and privacy into account, SDC will report allegations or suspicions of child abuse to donors and cooperate with donor investigations. As appropriate and only with the expressed desire of the victim, SDC will make reports to relevant authorities with jurisdiction over the criminal prosecution of child abuse offenses.

CONSEQUENCES OF POLICY VIOLATIONS

If an investigation confirms that a policy violation by SDC Staff has occurred, SDC will take disciplinary action, up to and including termination as appropriate in accordance with its policies and applicable law. Violation of this Policy, failure to comply with the applicable contractual language in the SDC sub-contract or SDC sub-award, or applicable Compliance Plan by a SDC Delivery Partner will result in remedial action, including termination of the sub-contract or sub-award for cause with immediate effect and potential disqualification from future contracts or grants with CI.

DEFINITIONS

• Child: In accordance with the United Nations Convention on the Rights of the Child, ‘child’ means every human being under the age of 18 unless under applicable law, the age of a child is defined as being younger. For the purposes of this policy, SDC considers a child to be a person under the age of 18 years. If the host country defines the age of consent as 21, in that country, “child” means an individual under the age of 21.
• Child Abuse: Any form of physical abuse; emotional ill-treatment; sexual abuse; neglect or insufficient supervision; trafficking; or commercial, transactional, labor, or other exploitation resulting in actual or potential harm to the child’s health, well-being, survival, development, or dignity. It includes but is not limited to any act or failure to act which results in death, serious physical or emotional harm to a child, or an act or failure to act which presents an imminent risk of serious harm to a child.
• Child Labor: SDC follows the International Labour Organization (ILO) definition of child labor. According to the ILO, work that includes light activities, unpaid and paid, such as helping parents for short periods or activities for pocket money that do not interfere with the education and development of children are acceptable. Labor is defined as unpaid and paid involving activities that may be mentally, physically, emotionally, socially, or morally dangerous and harmful to children and interferes with their development and education. The ILO (Minimum Age Convention No.138) establishes 15 as the minimum age for work in general but recognizes that some countries set the minimum age at 14. The age of 18 is set as the minimum age for hazardous labor. Refer to CISS ESS7 guidance for more information.
• Child Protection: Actions to prevent or respond to abuse, neglect, exploitation, and violence against children.
• Child Safeguarding: The obligation of an organization to ensure the delivery of projects and programmatic work that prevent harm and the associated policies, procedures, and practices employed to appropriately address children’s safety within the communities where we work.
• CISS – SDC Safeguard System: System of policies, standards, and procedures for the screening, due diligence, mitigation, monitoring, and reporting of environmental and social risks and impacts. The purpose is to provide SDC 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. Through the application of the Safeguard System, projects that include activities with direct engagement with children may require a Child Protection and Safeguarding Plan that details the extent and type of engagement, training/awareness-raising needs of project staff and delivery partners, and a description of how the grievance mechanism is child friendly, among other things.
• Direct/Indirect Contact: Activities where children/youth are the primary subjects, such as in-school or out-of-school environmental education programming; indirect contact refers to children/youth who may be present in an event setting (e.g., a community meeting) but who are not the primary subject. This also includes any conservation or sustainable production activities where children are known to play a supporting role.
• Emotional/Psychological Abuse: Injury to the psychological capacity or emotional stability of the child caused by acts, threats of acts, or coercive tactics. Emotional abuse may include but is not limited to humiliation, control, isolation, withholding of information, or any other deliberate activity that makes the child feel diminished or embarrassed.
• Exploitation: Abuse of a child where some form of remuneration is involved or whereby the perpetrators benefit in some manner. Exploitation represents a form of coercion and violence that is detrimental to the child’s physical or mental health, development, education, or well-being. This includes economic exploitation through slavery and slave-like practices, harmful or hazardous labor, and sexual exploitation.
• Hazardous Labor: Any activity or occupation that has or leads to adverse effects on a child’s safety, health, and moral development. Hazardous Labor conditions include but are not limited to night work; long hours of work; exposure to physical, psychological, or sexual abuse; work underground, underwater, at dangerous altitudes or in confined spaces; work lifting or moving heavy or unstable loads; work with dangerous machinery, equipment, and tools; and work in unhealthy environments that may expose children to hazardous substances and temperatures damaging to their health.
• Neglect: Failure to provide for a child’s basic needs by those that are responsible for the care of a child.
• Physical Abuse: Acts or failures to act that result in injury (not necessarily visible), unnecessary or unjustified pain or suffering which causes injury, harm, or risk of harm to a child’s health or welfare, or death. These acts are considered abuse regardless of whether they were intended to hurt the child.
• Sexual Abuse: Any actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. All sexual activity with a child is considered to be sexual abuse.