Policy on Protection from Sexual Exploitation, Abuse and Harassment (SEAH)

1. Purpose and rationale

The Open Dialogue Foundation group (“ODF” or “the Foundation group”) is an international, human rights and rule of law organisation that conducts research, advocacy, humanitarian and related activities in multiple countries, often in high‑risk and crisis contexts. The organisation works with and for people who may already face discrimination, violence, persecution and displacement.

In all of its activities, ODF is committed to ensuring that every person it works with, or comes into contact with through its work, is protected from sexual exploitation, sexual abuse and sexual harassment (collectively “SEAH”). ODF will not tolerate SEAH in any form, by any person associated with the organisation or its work.

The purpose of this Policy is to set out binding standards of conduct and organisational measures to prevent, detect and respond to SEAH, in line with international good practice and the requirements of public and private donors. It forms part of the ODF group’s wider safeguarding framework and is to be read together with relevant codes of conduct, human resources policies, complaints procedures and data‑protection rules.

2. Scope and application

This Policy applies to the entire Open Dialogue Foundation group, meaning the following legal entities and any legal successors to them:

a) Fundacja Otwarty Dialog / Open Dialogue Foundation (Poland);
b) Fundacja Otwarty Dialog – Polska / Open Dialogue Foundation – Poland (Poland);
c) Open Dialogue Foundation Inc (United States of America);
d) Open Dialogue Foundation fondation privée (Belgium);
e) Hromadska Spilka “Vidkryty Dialoh” (Ukraine).

Throughout this document they are referred to jointly as “ODF” or “the Foundation group”. Where necessary, each entity may adopt annexes specifying local procedures and legal requirements, which must be consistent with this Policy.

The Policy covers SEAH that occurs:
a) in any ODF workplace, office, mission, project site or other location where ODF representatives are present for work purposes;
b) during any ODF‑related travel, event or social activity; and
c) online or via digital communications where the conduct is connected to ODF’s work or status.

The Policy applies to all persons engaged by or associated with ODF in any capacity, including:
a) board members and members of supervisory or management bodies;
b) employees, whether permanent, fixed‑term, full‑time or part‑time;
c) interns, volunteers and fellows;
d) consultants, contractors and service providers, including drivers, security staff and interpreters;
e) partner organisations and their personnel, where they are working on ODF‑funded or joint activities;
f) visitors to ODF premises and participants in ODF missions or delegations.

Compliance with this Policy is a condition of employment, engagement or partnership with ODF. Breach of this Policy may result in disciplinary measures, including termination of employment or contracts, and in appropriate cases referral to law‑enforcement or regulatory authorities.

3. Definitions

For the purposes of this Policy, the following definitions apply. They are based on international standards and may be further specified in local procedures where required by national law.

a) Sexual exploitation: any actual or attempted abuse of a position of vulnerability, differential power or trust, for sexual purposes, including but not limited to profiting monetarily, socially or politically from the sexual exploitation of another person.

b) Sexual abuse: the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

c) Sexual harassment: any unwanted conduct of a sexual nature, or based on sex or gender, that has the purpose or effect of violating the dignity of a person, in particular when creating an intimidating, hostile, degrading, humiliating or offensive environment. A single incident may amount to sexual harassment.

d) Child: any person under the age of 18, irrespective of the age of majority in the relevant jurisdiction.

e) Vulnerable adult: a person aged 18 or over who, by reason of age, disability, illness, trauma, economic or social hardship, displacement, dependency, deprivation of liberty, discrimination or any similar reason, is or may be unable to protect themselves from harm or exploitation.

f) Survivor: a person who has experienced SEAH. The term “complainant” is used for a person who reports SEAH, and may be a survivor, a witness or another third party.

g) SEAH incident: any allegation, suspicion, concern or confirmed occurrence of sexual exploitation, sexual abuse or sexual harassment involving an ODF representative, or occurring in an ODF‑related context.

4. Guiding principles

ODF’s approach to SEAH is grounded in the following principles:

a) Zero tolerance for SEAH: ODF does not tolerate SEAH in any form. All concerns or allegations will be taken seriously, assessed promptly and, where appropriate, investigated and addressed. Zero tolerance does not mean that every allegation is assumed to be true, but that all allegations are treated seriously and handled in line with due process.

b) Do no harm: All actions taken under this Policy seek to minimise the risk of further harm to survivors, complainants, witnesses and others affected.

c) Survivor‑centred approach: ODF will respect the rights, needs and wishes of survivors as far as possible, including their right to choose whether, when and how to report and whether to engage with investigative or legal processes, subject to any mandatory reporting obligations.

d) Confidentiality and data protection: Information about SEAH concerns will be shared strictly on a need‑to‑know basis and stored securely, in line with applicable data‑protection laws.

e) Non‑discrimination: ODF will ensure that all persons, regardless of sex, gender, sexual orientation, gender identity or expression, race, ethnicity, nationality, religion, disability, age or any other status, are protected equally from SEAH and have equal access to reporting channels and support.

f) Accountability and transparency: ODF’s leadership is accountable for implementing this Policy and will report regularly on its implementation to governance bodies, donors and, where appropriate, the public, while protecting confidentiality.

5. Standards of conduct and prohibited behaviour

All persons to whom this Policy applies must adhere to the following standards of behaviour. The examples listed are not exhaustive.

5.1 General standards of conduct

All ODF representatives must:
a) treat all people with dignity and respect;
b) avoid any behaviour that could reasonably be perceived as sexually inappropriate, abusive or harassing;
c) maintain professional boundaries with colleagues, partners and persons affected by ODF’s work;
d) avoid situations which may place them at risk of allegations of SEAH, such as being alone behind closed doors with a beneficiary where this is not necessary; and
e) immediately report any concerns or suspicions of SEAH in accordance with this Policy.

5.2 Sexual exploitation and abuse of people affected by ODF’s work

The following conduct is strictly prohibited and will normally constitute gross misconduct:
a) any sexual activity with a child;
b) any sexual activity with a beneficiary, community member or other person directly affected by ODF’s work where there is a power imbalance, whether or not the activity appears consensual;
c) the exchange of money, employment, goods, services, protection or other assistance for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour;
d) any form of sexual activity that is forced, coerced, non‑consensual or takes advantage of a position of vulnerability or dependency;
e) any act of grooming, including building a relationship of trust with a child or vulnerable adult for the purpose of sexual exploitation or abuse; and
f) production, possession, access, distribution or viewing of child sexual abuse material, or the use of ODF equipment or networks for such purposes.

5.3 Sexual harassment in the workplace

ODF prohibits sexual harassment between colleagues, and between ODF representatives and partners, donors, public officials, journalists or any other person they interact with in the course of their work. Prohibited conduct includes, but is not limited to:
a) unwelcome sexual advances or requests for sexual favours;
b) unwanted physical contact of a sexual nature;
c) sexually explicit or suggestive comments, jokes, gestures or messages;
d) display or sharing of sexually explicit or sexist material, including online; and
e) any conduct of a sexual nature that creates an intimidating, hostile or offensive work environment, even if not directed at a particular individual.

5.4 Children and vulnerable adults

ODF recognises that children and vulnerable adults face increased risks of SEAH. In addition to the prohibitions listed above, ODF representatives must:
a) never be alone with a child or vulnerable adult in a private space where they cannot be observed, unless this is necessary for their work and has been approved and documented;
b) not develop relationships with children or vulnerable adults that could in any way be perceived as exploitative or abusive;
c) ensure that photographs, videos and other images of children are made and used in accordance with informed consent procedures and with respect for their dignity and safety; and
d) immediately report any concerns about possible abuse or neglect of a child or vulnerable adult, whether or not the concern involves an ODF representative.

5.5 Digital communication and social media

The standards in this Policy apply equally to online behaviour. ODF representatives must not:
a) use personal or organisational electronic devices, email accounts or social media to solicit or engage in sexually explicit conversations or share sexual images with beneficiaries, colleagues or others connected to ODF’s work;
b) send or request sexual images or content from persons affected by ODF’s work; or
c) engage in online harassment, including sharing rumours or intimate information about others.

6. Prevention and risk management

ODF will take proactive steps to prevent SEAH by addressing risks in human resources, programme design and implementation, and its relationships with partners and suppliers.

6.1 Recruitment, vetting and human resources

ODF will:
a) include explicit reference to SEAH standards and this Policy in all relevant job descriptions and vacancy notices;
b) conduct appropriate background checks and reference checks, in line with national law, with specific questions about any previous findings or concerns related to SEAH or serious misconduct;
c) require all staff, volunteers and consultants to sign a code of conduct that incorporates SEAH provisions as a condition of engagement;
d) ensure that new starters receive mandatory induction on this Policy and related procedures; and
e) integrate SEAH obligations into performance management and disciplinary procedures.

6.2 Programme and mission design

In planning and implementing its advocacy, monitoring, humanitarian and other activities, ODF will:
a) assess SEAH risks associated with each type of activity, including work in detention facilities, conflict‑affected areas, shelters and other high‑risk settings;
b) design activities in ways that minimise power imbalances and opportunities for SEAH, for example by ensuring that distributions or services are not controlled by a single individual;
c) provide clear information to participants, beneficiaries and communities about their right to be safe from SEAH and how to raise concerns; and
d) ensure that logistics, accommodation and transport arrangements for staff, partners and beneficiaries take into account SEAH risks.

6.3 Partners, contractors and visitors

ODF will seek to work only with partners and suppliers who share its commitment to preventing and responding to SEAH. In particular, ODF will:
a) integrate SEAH clauses into partnership agreements and major supplier contracts, including requirements to have appropriate policies, reporting mechanisms and disciplinary measures;
b) assess SEAH‑related capacity and risks during partner due‑diligence processes and take reasonable steps to support partners in strengthening their safeguards where needed; and
c) inform visitors, delegates and other short‑term participants in ODF activities of this Policy and their obligation to comply with its standards.

7. Reporting and complaints

ODF encourages and expects all staff, volunteers, beneficiaries and other stakeholders to speak up about any concern or suspicion of SEAH. Failure by an employee or other representative to report SEAH concerns may itself constitute a disciplinary offence.

7.1 Who can report

Reports or complaints can be made by anyone, including survivors, witnesses, colleagues, partner staff, community members, journalists or other third parties. Anonymous reports will be accepted and considered, although they may be more difficult to investigate.

7.2 Reporting channels

ODF will maintain multiple safe and accessible channels for reporting SEAH concerns, which may include:
a) line management (the complainant’s or another manager);
b) a designated SEAH or safeguarding focal point within each entity;
c) a confidential email address or online form managed by a small, trained team;
d) where feasible, telephone or messaging hotlines publicised to communities and beneficiaries; and
e) external whistle‑blowing or ombudsperson mechanisms, where available.

Each ODF entity will specify the details of its reporting channels in an annex or separate procedure and will ensure that they are communicated clearly to staff, partners and communities in appropriate languages.

7.3 Protection from retaliation

ODF will not tolerate retaliation against anyone who, in good faith, reports a concern, participates in an investigation or supports a survivor or complainant. Any act or threat of retaliation will be treated as a serious disciplinary matter.

7.4 Confidentiality and data protection

ODF will treat all SEAH reports as confidential. Information will be shared only with those who need to know in order to assess the concern, implement protective measures, conduct an investigation or fulfil legal and donor obligations. Personal data will be handled in accordance with applicable data‑protection laws, including the EU General Data Protection Regulation where relevant.

8. Response and investigations

ODF will respond to SEAH concerns promptly, fairly and in a survivor‑centred manner, while respecting the rights of all parties and the presumption of innocence until responsibility is established.

8.1 Initial response and survivor support

Upon receiving a SEAH report, ODF will:
a) acknowledge receipt of the report as soon as reasonably possible and explain the next steps;
b) assess any immediate risks to the survivor, complainant, witnesses or others and take steps to ensure their safety, including separation of the alleged perpetrator from the survivor where appropriate;
c) offer information about, and where possible facilitate access to, medical, psychosocial, legal and other support services, taking into account the survivor’s wishes; and
d) consider whether any mandatory reporting obligations to state authorities apply and, where they do, inform the survivor and others concerned as far as possible.

8.2 Internal investigation

Where a SEAH allegation concerns an ODF representative, or occurs in an ODF‑related context, ODF will decide whether to initiate an internal investigation or take other action based on the seriousness and credibility of the allegation, the wishes of the survivor and any ongoing state investigations.

Any internal investigation will:
a) be led by staff or external experts with appropriate skills, independence and sensitivity;
b) follow a documented procedure that respects the rights of all parties, including the right of the person accused to be informed of the allegations and to respond;
c) seek to collect and preserve relevant evidence, while avoiding any actions that could jeopardise criminal investigations; and
d) result in a written report setting out findings on the balance of probabilities and recommending appropriate measures.

8.3 Outcomes, sanctions and referrals

If a SEAH allegation is substantiated, ODF will take proportionate disciplinary and corrective action, which may include:
a) verbal or written warnings;
b) changes in duties, supervision or workplace;
c) suspension or dismissal of staff; termination of volunteer agreements or consultancy contracts;
d) termination or non‑renewal of partnership or supplier agreements; and
e) reporting the matter to relevant professional bodies, regulators or law‑enforcement authorities, subject to the survivor’s safety and wishes and applicable law.

Even where an allegation is not substantiated, ODF may take steps to address underlying risks, such as improving supervision, revising procedures or providing additional training.

9. Roles and responsibilities

Preventing and responding to SEAH is a shared responsibility across the ODF group. The following roles have specific duties under this Policy.

9.1 Governing boards and supervisory bodies

The governing boards and supervisory bodies of each ODF entity will:
a) formally adopt this Policy and ensure its integration into the organisation’s governance framework;
b) allocate sufficient resources, including staffing and budget, for its implementation;
c) receive and review periodic reports on SEAH risks, incidents and responses, in anonymised form;
d) oversee the management’s handling of serious SEAH cases; and
e) periodically review and, where necessary, update this Policy.

9.2 President, Executive Director and senior management

The President of the Foundation, the Executive Director and senior management of each entity will:
a) promote a culture of respect, safety and accountability in which SEAH is not tolerated;
b) ensure that this Policy is operationalised through procedures, training, supervision and monitoring;
c) appoint one or more SEAH or safeguarding focal points with clear terms of reference and authority;
d) ensure that SEAH risks and incidents are communicated to relevant donors in line with contractual obligations; and
e) cooperate with lawful investigations by competent authorities.

9.3 Managers and coordinators

All managers and project coordinators are responsible for:
a) embedding SEAH prevention measures in their teams’ work and project plans;
b) ensuring that staff and volunteers under their supervision receive appropriate induction and refresher training on this Policy;
c) creating a safe environment in which team members feel able to raise concerns; and
d) promptly escalating SEAH reports in accordance with established procedures.

9.4 SEAH / safeguarding focal points

Designated focal points will:
a) act as confidential contact persons for SEAH concerns within their entity or office;
b) provide guidance to managers and staff on the application of this Policy;
c) support the coordination of responses to SEAH incidents, including survivor support and investigations; and
d) contribute to monitoring, learning and periodic review of SEAH‑related practice.

9.5 All personnel and associated persons

Every person covered by this Policy is responsible for:
a) understanding and complying with the standards set out herein;
b) participating in mandatory training as required;
c) treating all people they interact with through ODF’s work with dignity and respect; and
d) promptly reporting any SEAH concerns or suspicions through the available channels.

10. Implementation across the ODF group

This Policy is adopted at group level and is binding on all ODF entities listed in section 2. Each entity will take the steps necessary to give it legal effect in its jurisdiction and to align local procedures with its provisions.

10.1 Local procedures and legal compliance

Each entity will:
a) identify applicable national laws and mandatory reporting obligations related to SEAH and ensure that its procedures comply with them;
b) develop or adapt local procedures, including complaints mechanisms and investigation protocols, consistent with this Policy;
c) establish or designate reporting channels suitable for its context; and
d) ensure that third‑party organisations implementing activities on its behalf are contractually required to adhere to equivalent SEAH standards.

10.2 Cross‑border cases

Where a SEAH incident involves more than one ODF entity or occurs in a country where ODF is not registered, the entities concerned will coordinate their response, taking into account applicable laws, donor requirements and the best interests of the survivor. Responsibility for leading the response will be agreed on a case‑by‑case basis.

11. Communication, training and awareness

ODF will ensure that this Policy is communicated clearly and effectively and that all relevant persons receive appropriate training. In particular, ODF will:

a) make the Policy available in the working languages of each entity and, where feasible, in the languages of the main communities it works with;
b) integrate SEAH messages into induction programmes, staff meetings, volunteer briefings and partner workshops;
c) provide periodic refresher training tailored to different roles and levels of responsibility; and
d) display information about SEAH and reporting channels in offices, centres and, where appropriate, online platforms.

12. Monitoring, reporting and review

ODF will monitor the implementation of this Policy and regularly assess the effectiveness of its SEAH prevention and response measures.

Each entity will provide, at least annually, an anonymised report to its governing bodies and, where required, to donors, summarising SEAH‑related activities, incidents and lessons learned. Aggregated information may be included in group‑level reports, while respecting confidentiality.

This Policy will be reviewed at least every three years, or earlier if required by changes in law, donor requirements or organisational learning. Proposed amendments will be submitted to the relevant governing bodies for approval.

13. Entry into force

This Policy was approved by the competent governing bodies of the ODF group entities on the dates indicated in the respective resolutions of those bodies. It enters into force for each entity on the date of its adoption and replaces any previous SEAH or PSEAH policies within the ODF group.