Chapter 1: Introduction

1.1 Overview

Refugee Pathways & Integration Canada (RefPIC) adopts a zero-tolerance policy towards Sexual Exploitation, Abuse, and Harassment (SEAH), reaffirming our commitment to safeguarding the dignity, safety, and rights of all individuals we serve and work with. SEAH undermines trust, violates human rights, and disrupts the integrity of humanitarian missions.

This policy establishes clear principles, procedures, and responsibilities to prevent SEAH, provide support to survivors, and ensure accountability for violations. By implementing robust safeguards, RefPIC aims to uphold the highest standards of ethical conduct and accountability in all aspects of its operations.

1.2 Relevance of SEAH in Humanitarian Settings

In humanitarian contexts, refugees and displaced persons are often at heightened risk of SEAH due to power imbalances, socioeconomic vulnerabilities, and limited oversight mechanisms. Women, children, and individuals with disabilities face disproportionate risks.

Recognizing these challenges, RefPIC’s SEAH Policy is tailored to address the unique vulnerabilities of the populations we serve. This policy integrates preventative measures, reporting mechanisms, and survivor-centered responses to create an environment that prioritizes safety, equity, and accountability.

Chapter 2: Purpose and Scope

2.1 Objectives of the Policy

This policy is designed to:(a) Prevent SEAH by establishing clear behavioral standards and safeguarding mechanisms.(b) Promote accountability by ensuring that all reported cases are addressed through fair and transparent processes.(c) Provide comprehensive support to survivors, prioritizing their dignity and safety.(d) Foster a culture of respect, integrity, and zero tolerance for SEAH across all levels of the organization.

2.2 Applicability of the Policy

This policy applies to:(a) All RefPIC employees, volunteers, contractors, and consultants.(b) Partner organizations, including donors, vendors, and stakeholders involved in RefPIC’s programs and operations.(c) Any individual or group directly or indirectly engaged with RefPIC’s beneficiaries, including third-party service providers.

The policy covers all operational contexts—local, national, and international—and extends to behaviors occurring on or off duty that impact RefPIC’s work, reputation, or beneficiaries.

Chapter 3: Definitions of Sexual Exploitation, Abuse, and Harassment

3.1 Key Definitions

(a) Sexual Exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes, including profiting monetarily, socially, or politically from the exploitation of another person.(b) Sexual Abuse: Any unwelcome sexual act, demand, or intrusion that is coercive or exploitative.(c) Sexual Harassment: Unwelcome sexual advances, requests for sexual favors, and verbal or physical conduct of a sexual nature that creates an intimidating, hostile, or offensive environment.

3.2 Examples of Prohibited Conduct

(a) Soliciting or engaging in sexual acts with beneficiaries in exchange for services, goods, or employment.(b) Making inappropriate sexual comments or gestures.(c) Using authority or influence to coerce sexual favors.(d) Failing to report known or suspected cases of SEAH.

Chapter 4: Prevention Strategies

4.1 Organizational Commitment to Prevention

RefPIC’s commitment to SEAH prevention is demonstrated through:(a) Clear codes of conduct signed by all personnel upon hiring.(b) Integration of SEAH safeguards into all operational procedures and risk assessments.(c) Proactive leadership that prioritizes ethical conduct and accountability.

4.2 Safeguarding Measures

To prevent SEAH, RefPIC will:(a) Conduct mandatory training on SEAH prevention for all staff, volunteers, and partners.(b) Implement robust screening processes for hiring and contracting.(c) Establish systems for regular monitoring and compliance checks, particularly in high-risk contexts.

Chapter 5: Reporting and Complaint Mechanisms

5.1 Channels for Reporting Incidents

RefPIC provides multiple channels for reporting SEAH incidents, including:(a) A secure and anonymous online reporting platform.(b) Dedicated helplines managed by trained safeguarding professionals.(c) Direct reports to supervisors, safeguarding officers, or designated focal points.

These channels are accessible to all beneficiaries, employees, and partners, ensuring that individuals feel safe and supported when coming forward.

5.2 Confidentiality and Protection of Complainants

RefPIC is committed to protecting the confidentiality of all individuals involved in SEAH cases. Complainants will receive:(a) Assurance that their identities and statements will remain confidential.(b) Protection from retaliation or further harm.(c) Immediate access to support services, including counseling, medical care, and legal assistance.

Reports will be handled promptly and with sensitivity to ensure that survivors feel respected and supported throughout the process.

Chapter 6: Investigation Procedures

6.1 Guidelines for Conducting Investigations

RefPIC is committed to upholding a fair, consistent, and survivor-centered approach when handling reports of Sexual Exploitation, Abuse, and Harassment (SEAH). Investigations will follow the steps below to ensure transparency, confidentiality, and accountability:

(a) Prompt Action: Investigations will be initiated within 72 hours of a report being received. Delays will only occur under exceptional circumstances, with documented justification.

(b) Impartial Investigators: Investigations will be conducted by trained personnel or external experts with no conflict of interest in the matter.

(c) Respect for All Parties: The dignity, safety, and rights of complainants, respondents, and witnesses will be respected throughout the process.

(d) Fact-Based Approach: Investigators will gather evidence objectively through interviews, document reviews, and corroboration of allegations.

(e) Documentation: All investigative actions, findings, and outcomes will be documented securely and clearly for transparency and record-keeping.

6.2 Rights and Responsibilities during Investigations

(a) Complainants:

• Right to be informed of investigative procedures and progress.

• Right to safety and confidentiality throughout the process.

• Responsibility to provide truthful, complete, and relevant information.

(b) Respondents:

• Right to be informed of allegations against them and to respond in full.

• Right to fair treatment and a presumption of innocence until proven otherwise.

• Responsibility to cooperate fully with the investigation.

(c) Witnesses:

• Right to anonymity where appropriate and protection from retaliation.

• Responsibility to provide accurate and reliable testimony.

Chapter 7: Support and Protection for Survivors

7.1 Immediate Support Mechanisms

Survivors of SEAH will have access to immediate care, tailored to their physical, psychological, and emotional needs:

(a) Medical Assistance: Immediate access to medical care, including sexual health services, in collaboration with trusted local healthcare providers.

(b) Safe Spaces: Temporary relocation or protection services to ensure the survivor’s physical safety if the accused poses a threat.

(c) Emotional Support: Access to trained counselors and mental health services who specialize in trauma care.

7.2 Long-Term Care and Rehabilitation

RefPIC is dedicated to supporting survivors in their journey to healing and reintegration:

(a) Legal Aid: Assistance in navigating legal proceedings, including filing cases and securing representation.

(b) Community Reintegration: Programs to support survivors in re-establishing their livelihoods and social connections.

(c) Economic Empowerment: Access to vocational training and micro-enterprise initiatives to rebuild independence and resilience.

Chapter 8: Responsibilities of Staff and Partners

8.1 Roles and Expectations

All staff, volunteers, and partners are required to:(a) Complete mandatory training on SEAH prevention and response.(b) Immediately report any suspected or known SEAH cases using designated channels.(c) Actively promote a culture of zero tolerance for SEAH within their teams and communities.

8.2 Adherence to the SEAH Policy

(a) All staff and partners must sign a commitment to abide by the SEAH policy upon onboarding.(b) Refusal or failure to comply with the policy may result in disciplinary action, including termination of contracts or partnerships.

Chapter 9: Disciplinary Actions and Consequences

9.1 Sanctions for Violators

Violations of the SEAH policy will result in proportionate and enforceable sanctions, including:(a) Immediate suspension or dismissal for staff and volunteers.(b) Contract termination for partner organizations.(c) Reporting to local law enforcement agencies where criminal laws have been violated.

9.2 Accountability Measures

(a) Consistency: Sanctions will be applied uniformly regardless of the violator's role, status, or affiliation.(b) Transparency: Outcomes of investigations and subsequent actions will be communicated to relevant stakeholders while maintaining confidentiality.

Chapter 10: Training and Awareness Programs

10.1 Mandatory Training for Employees and Volunteers

RefPIC will implement training modules for all personnel to:(a) Understand SEAH risks and prevention strategies.(b) Identify and address early warning signs of misconduct.(c) Familiarize themselves with reporting and response protocols.

10.2 Raising Awareness through Workshops

(a) Community Engagement: Conduct workshops with host communities to raise awareness about SEAH prevention and support available to survivors.(b) Ongoing Education: Regularly update training materials to incorporate emerging best practices and lessons learned from previous cases.

Chapter 11: Monitoring and Review

11.1 Mechanisms for Monitoring Policy Effectiveness

RefPIC will ensure the SEAH policy remains effective and relevant by:(a) Conducting regular audits of SEAH-related processes and outcomes.(b) Establishing feedback loops to capture input from survivors, staff, and community stakeholders.(c) Publishing an annual report summarizing policy performance and areas for improvement.

11.2 Annual Review and Revisions

(a) The SEAH policy will be reviewed annually to incorporate legal updates, organizational feedback, and emerging trends.(b) A Safeguarding Committee will oversee revisions, ensuring alignment with RefPIC’s broader mission and values.