SAVE African Rhino Foundation – Child Protection Policy
Incorporating Child Protection & Prevention of Sexual Exploitation Abuse & Harassment
1.1 The SAVE African Rhino Foundation (SARF) is committed to zero tolerance in relation to child exploitation and abuse.
1.2 This policy details the commitments of SARF and principles on which these are based. They are intended to inform personnel, committee, representatives, funded partners and visitors to projects we support.
2. SCOPE AND DEFINITIONS
2.1 This policy applies to all projects that SARF supplies financial support. In this policy frequently used terms have the meaning set out at paragraph 7.
2.2 In the instance that SARF should directly employ individuals then this policy applies to employee interactions with third parties, including Funded Partners and associated projects.
3. GUIDING PRINCIPLES
3.1 The guiding principles that form the foundations of SARF’s Child Protection Policy are as follows:
3.1.1 A zero tolerance of child exploitation and abuse.
3.1.2 A commitment to assess and manage child protection risk and impact.
3.1.3 Ensuring a shared responsibility for child protection by ensuring the support and cooperation of partner individuals and organisations.
3.1.4 Ensuring procedural fairness when considering a child’s rights or interests.
3.1.5 A recognition of the best interests of the child in all actions will be the primary consideration.
3.1.7 Accountability and transparency – be accountable and transparent in all aspects of
3.2 This policy is guided by DFAT’s Child Protection Policy – see Annexure A for further detail
4. COMMITMENTS UNDER THIS POLICY
Taking in to account the guiding principles above, SARF makes the following commitments.
4.1.1 Foster an awareness and encourage a culture that is mindful of ensuring sound child protection which prevents harm to individuals, within Committee or other Representatives, Personnel, Members and Funded Partners.
4.2.1 That committee promote awareness of this policy to representatives, personnel, funded partners, and visitors to supported projects.
4.2.2 Ensure an understanding of the policy within committee or other representatives, personnel, funded partners or visitors to our supported projects such that they know expected behaviours and the procedure for raising concerns.
4.3.1 SARF will ensure transparency with other organisations when approached in relation to sharing experience of misconduct information regarding Child Protection for the purposes of their own integrity checks.
4.3.2 Ensure all SARF Committee or other Representatives read and acknowledge the Child Protection Policy at the time of being recognised as a committee member or representative.
4.3.3 Assess new projects with Child Protection in mind, including in schools or communities, and at fundraising events. This should include an assessment of the level of risk based on the likelihood and consequence of that risk occurring and what processes are proposed within the project to mitigate the risk.
4.3.4 Ensure the best interests of the child principle is central to risk assessment, risk management and responses to Child Protection concerns.
4.3.5 Assess Child Protection issues in proposed funded projects or events intended to involve children and encourage funded partners to ensure that parents, guardians and event organisers are briefed before the activity that there should be no unsupervised access to children and that the parents, guardians and organisers should take responsibility for the child
4.3.6 If at any time SARF directly employs an individual then the guidelines in Annexure B will be followed
4.4 Report and Respond
4.4.1 Personnel, committee and other representatives must comply with this Policy including to report Child Protection concerns within 24 hours of becoming aware of these concerns to SARF’s President at the time
4.4.2 Provide a safe, effective and accessible Child Protection concern reporting
process and form – See Annexure C
4.4.3 Treat all Child Protection concerns in professionally, sensitively, in a manner that is timely and confidential while also incorporating procedural fairness. In addition, then take immediate, appropriate action in response.
4.4.4 Report Child Protection concerns as required by law.
4.4.5 Anyone found to have breached this Policy may have disciplinary action taken against them. Where any allegations are proven to be true, SARF may terminate a contract of personnel, or appointment of a committee member, acknowledgement of a representatives, funding to a funded partner and/or report the breach to a relevant
professional or legal organisation or authority.
4.5.1 Where possible ensure due diligence and assessment of funded partners regarding Child Protection
4.5.2 Where practicable require and otherwise encourage funded partners to have a policy(ies) in place equivalent to this Policy.
4.5.3 Where Funded Partners do not have their own equivalent Child Protection policy(ies) in place, then SARF will encourage the funded partner to work towards that position while initially encouraging and supporting them to comply with this policy.
4.5.4 Ensure reference is made to Child Protection compliance in all written partnership agreements
4.6 Accountability and Transparency
4.6.1 Promote SARF’s commitment to Child Protection on its website.
5. RESPONSIBILITIES & ACCOUNTABILITIES
The Committee is responsible for:
5.1.1 Creating a culture that recognises the importance of Child Protection;
5.1.2 Approving this Policy.
5.1.3 Taking reasonable steps when considering funded partners to ensure this Policy is upheld.
5.1.4 Promoting the existence of this Policy to all funded partners
5.1.5 Addressing any questions arising in relation to this Policy from any source
5.1.6 Adhering to the principles and commitments under this Policy and not directly or indirectly encouraging others to breach this Policy.
6.1 This Policy will be reviewed every three years by the Committee
7. GLOSSARY AND DEFINITIONS
Abuse – physical abuse – the use of physical force against a child that results in harm to the child. Physically abusive behaviour includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning
– neglect – the failure by a parent or caregiver to provide a child (where they are in a position to do so) with the conditions that are culturally accepted as being essential for their physical and emotional development and wellbeing
– emotional abuse – refers to a parent or caregiver’s inappropriate verbal or symbolic acts toward a child, or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Such acts have a high probability of damaging a child’s self-esteem or social competence
– sexual abuse – the use of a child for sexual gratification by an adult or significantly older child or adolescent. Sexually abusive behaviours can include fondling genitals; masturbation; oral sex; vaginal or anal penetration by a penis, finger or any other object; fondling breasts; voyeurism; exhibitionism; and exposing the child to, or involving the child in, pornography9
– ill-treatment – disciplining or correcting a child in an unreasonable and seriously inappropriate or improper manner; making excessive and/or degrading demands of a child; hostile use of force towards a child; and/or a pattern of hostile or unreasonable and seriously inappropriate degrading comments or behaviour towards a child
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 the law applicable to the child, majority is attained earlier. For the purposes of this policy, SARF considers a child to be a person under the age of 18 years
Child Exploitation – Means one or more of the following:
- committing or coercing another person to commit an act or acts of abuse against a child
- possessing, controlling, producing, distributing, obtaining or transmitting child exploitation material
- committing or coercing another person to commit an act or acts of grooming or online grooming
- using a minor for profit, labour, sexual gratification, or some other personal or financial advantage
Child Exploitation Material – Material, irrespective of its form, which is classified as child abuse material or child pornography material
Child Protection – An activity or initiative designed to protect children from any form of harm, particularly that arising from child exploitation and abuse
Child Protection Concern means when someone is worried about harm to or the safety or well-being of a child because of something seen, heard or experienced, or information that has been given to them. A child protection concern can involve someone at SARF, or from another organisation, endangering the safety or wellbeing of a child as detailed in this policy.
Committee means the group of elected members forming the managing body as defined by SARF’s Rules
Employee means a person directly employed by SARF with employment entitlements.
Exploitation means behaviour exploiting children by seeking out those who are in vulnerable circumstances to use them for the perpetrator’s own purpose, activity or gratification. This could be financial, commercial, sexual or related to extremism/radicalisation and terrorism.
Exploitation involves a process of grooming; when someone builds an emotional connection with a child or adult to gain their trust for the purpose of exploitation. The perpetrator may also manipulate the environment, so victims become isolated from those who could help or support them. Those affected may not realise they have been groomed, or that what has happened is abuse. Exploitation includes but is not limited to: Sexual Exploitation; and Transactional Sex, as further defined in this Policy.
Funded Partner means an individual or organisation partially or fully funded to carry out work by SARF. It does not include suppliers of goods or services, whose conduct is managed separately by the Funded Partner.
Grooming – Generally, refers to behaviour that makes it easier for an offender to procure a
child for sexual activity. For example, an offender might build a relationship of trust with the child, and then seek to sexualise that relationship (for example by encouraging romantic feelings, or exposing the child to sexual concepts through pornography)
Harassment – Means any behaviour that is unwelcome, uninvited or unreciprocated and which a
reasonable person would anticipate as being offensive, humiliating or intimidating. It is no defence to a complaint of harassment that you did not mean to cause offence. Harassment includes but is not limited to Sexual Harassment. Examples of harassment include, but are not limited to:
(a) pictures, graffiti or written materials which are offensive or obscene;
(b) phone calls, letters or messages of any nature which are threatening, abusive or offensive;
(c) insulting or threatening gestures;
(d) dismissive treatment or material expressing prejudice or stereotypical assumptions about the group to which a person may belong;
(e) offensive physical contact or coercive behaviour which may be taken to be derogatory or
(f) persistent following or stalking;
(g) spreading gossip or false or malicious rumours about a person.
Harm – Any detrimental effect on a child’s physical, psychological or emotional wellbeing. Harm may be caused by financial, physical or emotional abuse, neglect, and/or sexual abuse or exploitation whether intended or unintended
Personnel – are either employed by an organisation, engaged by an organisation on a subcontract basis, or engaged by an organisation on a voluntary or unpaid basis. Personnel can include paid staff and volunteers.
Project means a set of activities with a start and end date for implementation aimed at achieving a defined set of objectives. In the context of this Policy it includes engagement with communities connected to a project.
Radicalisation – means the process by which individuals come to support terrorism or violent extremism. Radicalisation may be considered a form of exploitation.
Representatives means a person who represents SARF as agreed by the Committee of SARF.
Sexual Exploitation – as defined by United Nations High Commissioner for Refugees (UNHCR) is defined as an actual or attempted abuse of someone’s position of vulnerability (such as a person depending on you for survival, food rations, school, books, transport or other services), differential power or trust, to obtain sexual favours, including but not only, by offering money or other social, economic or political advantages. It includes trafficking and prostitution.
Sexual Harassment as defined by the UNHCR is any unwelcome conduct of a sexual nature that might reasonably be expected or be perceived to cause offence or humiliation. While typically involving a pattern of conduct, sexual harassment may take the form of a single incident. In assessing whether the conduct causes offence, the perspective of the victim shall be considered.
Sexual harassment can take various forms – from looks and words though to physical contact of a sexual nature. Examples of sexual harassment (non-exhaustive list) include: attempted or actual sexual assault, including rape; sharing or displaying sexually inappropriate images or videos in any format; sending sexually suggestive communications in any format; sharing sexual or lewd anecdotes or jokes; making inappropriate sexual gestures, such as pelvic thrusts; unwelcome touching, including pinching, patting, rubbing, or purposefully brushing up against another person; staring in a sexually suggestive manner; repeatedly asking a person for dates or asking for sex; rating a person’s sexuality; making sexual comments about appearance, clothing, or body parts; name-calling or using slurs with a gender/sexual connotation; making derogatory or demeaning comments about someone’s sexual orientation or gender identity.
Transactional Sex means the exchange of money, employment, goods or services or other benefits
for sex or sexual acts including sexual favours. SARF sees Transactional Sex as
Victim is generally applied where the individual is still in an exploitative situation and/or is
interacting with various systems that regard them as victims of crime.
Zero tolerance means that consequences will apply if allegations are proven.
ANNEXURE A – Child Protection and Professional Behaviours
SARF expects that personnel, committee, representatives, funded partners and visitors to funded projects that involve working or contact with children to adhere to the following behaviours while they are performing or involved with those duties to :
- treat all children with respect
- not use language or behaviour towards children that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate
- not engage children under the age of 18 (1) in any form of sexual intercourse (2) or sexual activity (3), including transactional sex
- wherever possible, ensure that another adult is present when working near children
- not invite unaccompanied children into private residences, unless they are at immediate risk of injury or in physical danger
- not sleep close to unsupervised children unless absolutely necessary, in which case the supervisor’s permission must be obtained, and ensuring that another adult is present if possible (noting that this does not apply to an individual’s own children)
- never use any computers, mobile phones, video cameras, cameras or social media to exploit or harass children, or access child exploitation material through any medium
- not use physical punishment on children
- not hire children for domestic or other labour: which is inappropriate given their age or developmental stage; which interferes with their time available for education and recreational activities; or which places them at significant risk of injury
- comply with all relevant Australian and local legislation, including labour laws in relation to child labour
- immediately report concerns or allegations of child exploitation and abuse and policy noncompliance in accordance with appropriate procedures
(1) Where the child is 16 years or older and the other party is not more than 2 years older; and it can be established that the child consented to the relationship, an exception can be recorded promptly on personnel files.
(2) As defined under the Criminal Code Act 1995.
(3) As defined under the Criminal Code Act 1995.
When photographing or filming a child or using children’s images for work-related purposes:
- take care to ensure local traditions or restrictions for reproducing personal images are adhered to before photographing or filming a child
- obtain informed consent from the child and parent or guardian of the child before photographing or filming a child. An explanation of how the photograph or film will be used must be provided
- ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive
- ensure images are honest representations of the context and the facts
- ensure file labels, meta data or text descriptions do not reveal identifying information about a child when sending images electronically or publishing images in any form
ANNEXURE B – Child Protection and Recruitment
1. In the case that SARF recruits employees then;
(a) During the interview process all applicants who make it to this stage will be advised of SARF’s Child Protection Policy and advised that they will be required to comply with this.
(b) At least two verbal reference checks specifically asking the suitability to have contact with children will be required for the preferred candidate prior to confirming a position of employment.
(c) Candidates will be required to disclose any and all allegations, charges, convictions and other outcomes of any offence which relates to Harm, specifically noting child Abuse and Exploitation.
(d) Before the employee is assigned roles involving time spent alone with children, a police check will be undertaken. If a candidate has spent more than one year overseas in a particular country in the last five years, a statutory declaration will be required of the preferred candidate disclosing any charges and spent convictions related to Child Protection.
(e) Offers may be made to candidates who will not work with children prior to the checks being completed. However, in these cases the contract will explicitly state that employment will be terminated if the checks are unsatisfactory.
(f) Contracts will contain provisions for the prevention of a person from working with children if they present an unacceptable risk to children and dismissal, suspension or transfer to other duties for any employee who breaches SARF’s Child Protection Policy as commensurate.
2. After recruitment
(a) For positions requiring contact or working with children:
(i) specific attention will be paid to the individual’s suitability to work with children; and
(ii) Child Protection is included in the performance review.
Accountability for the above rests with the SARF Committee.
ANNEXURE C – Child Protection Concern – Reporting Process and Form
Part A – Child Protection Concern Reporting Process
1. In all situations first make sure the child or adult is safe. Arrange medical attention as needed.
2. Any Committee, Personnel or Representatives of SARF that become aware of or suspects harm to
a child within the activities of SARF, our funded partners or otherwise or any other breach of the
Child Protection Policy must within 24 hours notify The President of SARF.
3. Part B sets out the Child Protection Concern Reporting Form.
4. If the concern or allegation relates to activities receiving institutional funding, the SARF President will inform the institutional Donor. For example, for DFAT this is within 48 hours depending on the nature of the Child Protection Concern.
6. The President and Committee will jointly consider the nature of the alleged offence, and
decide on the next steps, including any further action needed to ensure the safety and wellbeing of
the victim/survivor, and calling in advice from relevant sources.
10. If any allegations are made suggesting that SARF itself as an organisation has committed
an offence under any laws, then the President must refer this to the relevant authority as appropriate in the circumstances.
11. If the allegation is about the President, then report should be made to the committee and the committee should refer this the relevant authority as appropriate in the circumstances.
Part B – The SAVE African Rhino Foundation Child Protection Concern Reporting Form
ALL INFORMATION IN THIS FORM WILL BE TREATED CONFIDENTIALLY
Personnel, Representatives and Funded Partners must report any behaviour that is suspected of causing Harm and any instances of Policy non-compliance. You can email this form to email@example.com
Information about you (optional for anonymous reporting)
Position in SARF or in relation to SARF
Telephone (incl. Mobile)
Information about the child or adult alleged? Victim/s (if more than one affected, please include all)
Victim request to remain confidential Yes/No/Don’t know
Male / Female / Other / Prefer not to say / Age
Current location of the victim (include who the person lives with if applicable)
Any additional information about the victim, such as injuries, disability, general impressions.
What actions have been taken to ensure the victim’s safety at present?
Information on the suspected Harm
When did it take place (date and time)?
Where did it take place?
SARF Project (if any)
Which institutional donors fund the Project if known?
Were there witnesses? If yes – who are they and how can they be contacted?
How did you become aware of this Child Protection Concern?
Who else has been informed about this Child Protection Concern (include both internal and external e.g. police / doctors)?
If applicable: Information about the suspected perpetrator/person(s) involved
Name Male / Female / Other / Prefer not to say
Alleged perpetrator’s relationship to victim
Alleged perpetrator’s relationship to SARF
Is the alleged perpetrator Australian or living in Australia? Yes / No / Don’t know
Current location Contact details