Safeguarding policy

HelpAge International’s global safeguarding policy for all staff, trustees, consultants and volunteers as of August 2023.

1. Purpose

HelpAge International is the secretariat to a global network of organisations promoting the right of all older people to lead dignified, healthy and secure lives.

We are committed to ensuring that everyone we interact with as we deliver our mandate is protected from all forms of harm and abuse arising from our programmes, operations and staff. All HelpAge representatives are expected to uphold the highest standards of behaviour set out in our Code of Conduct and we will act against wrongdoers who use their position of trust to harm anyone including older people/ adult at risk of harm and children.

As an organisation we want to protect all members of the communities where we work from harm caused by our work, whether intentional or unintentional.

The purpose of this policy is therefore to protect all people from harm that may be caused as a result of our work. All people refer to older people, at-risk adults, children and our own staff.

This includes harm arising from:

• The conduct of staff or representatives of HelpAge.
• The design and implementation of HelpAge’s programmes and activities, including through partners.
• The operations of HelpAge that support its activities.

The policy sets out the commitments made by HelpAge to everyone who comes into contact with its work and informs staff and representatives of their responsibilities in relation to safeguarding.

This policy does not cover:

• Bullying and Harassment (sexual harassment) in the workplace (considered as safeguarding concerns) – is covered by HelpAge’s Equal Opportunities and Dignity at work policy. Reporting of these concerns should follow the protocol outlined in this policy.
• Protection concerns in the community, including child protection concerns not caused by HelpAge International Representatives.

Prevention of Sexual Exploitation and Abuse (PSEA)

In common with the humanitarian and development community we use this term to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel. The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)

HelpAge safeguards everyone who encounters its work, including protecting staff from harm and inappropriate behaviour such as bullying and harassment.

Further definitions relating to safeguarding are provided in the Glossary in the Appendices.

3. Scope

This Global Safeguarding Policy applies equally to everyone associated with HelpAge, including but not limited to:

• All permanent and temporary employees contracted by HelpAge.
• Network members
• Volunteers and interns
• Consultants
• Invited visitors (including donors/funders; media/journalists/politicians)
• Board of Trustees
• Partner organisations (NGOs, CSOs etc) where deemed appropriate (Partner organisations that would prefer to use HAI policy to ensure the HAI minimum standard on policy is met will be welcome to contextualise this policy as appropriate to suit their needs).
• Accompanying family members of expat/international employees.
• Third- party contractors (i.e suppliers, builders, contractors etc) where deemed appropriate.

The term ‘representatives’ will be used to refer to all people from the list above and associated with HelpAge.

4. Policy statement

HelpAge believes that everyone we encounter regardless of age, disability, sex, gender reassignment, sexual orientation, religion, ethnic origin, marriage/civil partnership status, maternity or pregnancy or other characteristic has the right to be protected from all forms of harm, abuse, neglect, discrimination and exploitation.

HelpAge acknowledges that harm and abuse perpetrated towards children, older people/ at-risk adults is rooted in an inherent power imbalance between the individual and the organisation (and its representatives). Gender inequality, culture or ethnicity, being a person with a disability or a displaced person can also exacerbate power dynamics which can lead to harm, abuse and exploitation by those in a position of power and/or authority.

HelpAge organisational culture is critical in preventing harm and abuse from occurring, as well as building and maintaining an open, transparent and equitable culture where all representatives feel safe to speak out about unacceptable behaviour. We seek to ensure that a safe work environment is experienced by all HelpAge Representatives.

This policy will address the following areas of safeguarding: child safeguarding, adult safeguarding, and protection from sexual exploitation and abuse.

HelpAge commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response and promoting good governance and accountability.

HelpAge safeguarding work is underpinned by the following ethical commitments:

• HelpAge has a duty of care and responsibility to keep all individuals safe with whom we come into direct or indirect contact.
• HelpAge employees and representatives have a duty of care to report any incident or concern that is witnessed, suspected or overheard.
• HelpAge implements a zero-tolerance approach to safeguarding. Suspected breaches of this policy are taken seriously, and we will take appropriate disciplinary action where needed.

5. Core Principles

The following principles are upheld by this policy:

• Safeguarding is everyone’s responsibility, and anyone associated with HelpAge has a duty to uphold the principles laid out in this policy and to report concerns or suspicions of a breach of this policy.
• HelpAge international human rights frameworks.
• HelpAge abides by core international safeguarding standards, including the Inter-Agency Standing Committee Minimum Operating Standards for the Prevention of Sexual Exploitation and Abuse (IASC MOS-PSEA), Keeping Children Safe and the Core Humanitarian Standard on Quality and Accountability (CHS).
• HelpAge abides by the principle of non-discrimination in all of its safeguarding work. This includes ensuring all individuals are protected from all forms of harm, abuse, neglect and exploitation regardless of race or social origin, disability, gender, religious or political beliefs, sexual orientation, gender identity, gender expression or sex characteristics (SOGIE), ethnic or national origin, age, belief, partnership status, pregnancy or parental status, health status or any other status.
• HelpAge adheres to the Do No Harm principle across all our work.
• A survivor-centred approach is applied to safeguarding case management and empowering the survivor at all times. HelpAge will act in the best interests of the child where concerns involve children.
• HelpAge strives to empower those we work with and for, building their agency and engaging them in a way that they fully understand their right to safety when engaging with any representative or activity associated with the organisation. Different empowerment approaches will be required depending on the group being engaged and their evolving capacities.
• HelpAge takes a standards-based approach to safeguarding. Where there is discrepancy between national laws and practices, international laws, conventions and standards, particularly laws concerning children and youth, the most protective measures will apply.
• HelpAge values underpin this Safeguarding Policy.

This policy contains ten interlinked and mutually reinforcing standards which aim to ensure the HelpAge is a safe organisation. No standard can be considered in isolation and each standard must be given equal weight and importance across the organisation.

6. HelpAge Safeguarding Standards

Standard One: Leadership, Accountability and Governance

HelpAge has an obligation to put in place all feasible safeguarding measures to ensure the safety and protection of children, older people/ at-risk adults. HelpAge will designate responsibility for safeguarding to employees across the organisation to ensure that safeguards are monitored regularly. HelpAge commits to ensuring this policy is mainstreamed across the organisation to ensure adherence to international safeguarding standards. HelpAge will support the adaptation of the policy to ensure adherence to relevant national laws and cultural context.
HelpAge Board of trustees hold the ultimate accountability to ensure that this Global policy is implemented. Safeguarding will be a standing item in Board meetings and will have a designated safeguarding trustee. The Board will be actively engaged in ensuring safeguarding and systems are in place to allow for senior oversight and monitoring of HelpAge safeguarding work, including risk.

Standard Two: Building a Safe Organisational Culture

All HelpAge leadership and management teams will prioritise safeguarding within the organisation and take steps to build an organisation where employees feel safe to challenge issues of power and bias as well as promote equality, diversity and inclusion. Management teams will have clear accountabilities and responsibilities for safeguarding, they will proactively reflect and take action to ensure their behaviours and actions promote a transparent, safe and inclusive culture. This will be done by building their own awareness on the connection between equality, diversity and inclusion and a safe work environment, reflecting on the leadership behaviours that promote a safe organisation and addressing any identified gaps or opportunities to strengthen their leadership team’s commitment to safeguarding.

Standard Three: Training & Knowledge building on safeguarding

HelpAge will actively promote its Global Safeguarding Policy in ways that are accessible, informative and easy to understand (I.e. translation into appropriate languages) for all representatives. This will be achieved through dedicated inductions and training as well as organisational communications on HelpAge safeguarding approach and ensuring individuals are fully aware of their safeguarding responsibilities.
All employees and representatives receive mandatory safeguarding training within prior to direct engagement with any programme participant or community members and participate in yearly refresher trainings.

Plans for raising-awareness and training on HelpAge Global Safeguarding Policy and procedures will be included in the budget lines of all HR departments at head office. Provisions for safeguarding capacity building and training will be identified and included in programme budgets.

Standard Four: Human resources and safe employment cycle

HelpAge recognises that abuse can occur within organisations who are dedicated to the wellbeing and protection of children, older people/at-risk adults and other community members who interact with the organisation. Safeguarding measures will be embedded into all human resource activity. We will recruit employees and volunteers who share HelpAge values and are committed to safeguarding. We will ensure that all employees, volunteers, contractors, visitors, consultants, third party vendors, and others undertaking work on behalf of the organisation understand their safeguarding responsibilities and have the knowledge and skills necessary to fulfil their obligations.
Safer recruitment steps will be taken throughout the recruitment process to minimise the risk of bringing someone into the organisation who is unsuitable to work with project participants.

All employees will participate in exit interviews with records reviewed periodically to capture learning held by HR. Exit interviews will include questions related to the organisation’s ability to implement the Global Safeguarding Policy and procedures.

Standard Five: Safe programming and risk management

HelpAge commits to ensuring that safeguarding is built into all proposals, project design and implementation. Safe programming promotes equality, equity, reduces risk and increases protection. HelpAge commits to ensuring proposals include a safeguarding risk assessment and a budget for; mitigating safeguarding risks, safeguarding training, enhanced risk assessments and case management. Where possible, HelpAge will take a participatory approach to conducting risk assessments and developing risk mitigation plans.

Where proposals are developed as part of a consortium, due diligence processes will be followed that assess partners safeguarding practices. Where safeguarding policies and procedures do not align with HelpAge’s the partner will be required to adopt and follow HelpAge policy and/or procedures if it is felt their standards fall below sector best practice.

Safeguarding Focal Points will be identified and tailored reporting and response mechanisms established and communicated to participants, community, employees and partners. Safeguarding awareness-raising will be incorporated into activities for older people/ at-risk adults and adults (caregivers, social workers etc.). All programmes will hold regular open discussions with participants, employees, volunteers and partners to evaluate the implementation of safeguarding procedures throughout the implementation period of the programme.

Standard Six: Working with older people and the community

HelpAge works with older people who are often at heightened risk of experiencing harm and abuse due to their age. We commit to ensuring our interactions are safe and recognise unequal power dynamics that may be at play. HelpAge commits to ensuring safe, inclusive and participatory involvement of older people in communities in its programmes, research and advocacy work. HelpAge will ensure employees, volunteers, third party contractors, consultants, and researchers sign and comply with the guidelines laid out in our Code of Conduct relating to appropriate and inappropriate behaviour towards participants of HelpAge programmes and of participants towards other participants during HelpAge activities.

HelpAge will conduct awareness-raising activities where appropriate for project participants, their caregivers, and the wider community prior to the start of any programme and at regular intervals throughout the programme cycle. Awareness raising activities will ensure participants and the community are familiar with HelpAge Global Safeguarding Policy, procedures, and reporting processes, activities will also ensure they understand what is expected from HelpAge representatives as outlined in the Code of Conduct. We will ensure that activities are context specific and are sensitive to age, gender and culture and any other requirements individuals may have. HelpAge will ensure that participants feel empowered to provide feedback and commit to adhering to Core Humanitarian Standard (CHS) commitments.

Standard Seven: Reporting and responding

HelpAge will ensure that it has robust reporting and response processes in place that are accessible to the older people, community and employees and are adapted to the local context. HelpAge will ensure that all safeguarding concerns are responded to efficiently and are recorded on a global tracking log. HelpAge reporting and response processes are underpinned by the following principles.

• Mandatory Internal Reporting – HelpAge requires mandatory reporting of harm or abuse/exploitation caused by our programmes, employees or interventions. Failure to report will be considered a serious breach of HelpAge Global Safeguarding Policy and appropriate action will be taken.
• Historical Reports – Concerns about harm or abuse must be internally reported where the abuse is historical. Most abuse is not disclosed until many years after it has occurred, but the risks of harm older people may require investigation.
• Equal right to protection – Protection from harm and abuse is the right of all older people/ community members engaging with HelpAge activities.
• Duty of Care – We will effectively respond to, and keep a record of, all concerns reported and ensure that any response operates in the survivor’s best interests. This duty of care includes any concerns that are raised anonymously.
• Survivor centred-approach – HelpAge promotes a survivor-centred approach to all safeguarding concerns in line with the Inter-Agency Standing Committee on PSEA.
• Confidentiality – Will be always maintained. The identity of all named individuals/entities related to the concern will be kept confidential to the highest degree possible. Disclosure of information will be made only to relevant parties on a strictly need- to-know basis.
• Sensitivity – Incidents of abuse are potentially traumatising for both the survivor and all those associated with the concern. Any investigation process will be undertaken with the utmost sensitivity and respect for all those associated with the case.
• Country Context – Detailed country context mappings that include national laws, legal frameworks, and support services for referrals are developed and regularly reviewed and updated for all locations.

Reporting to authorities: In every case in which a criminal offence appears to have been committed the default position should be for immediate referral to the police or other competent authorities for consideration of criminal action. However, consideration must be given to the national context within which the allegations have arisen, and a survivor-centred approach applied. A Do No Harm risk assessment must always be carried out and the findings should inform the decision-making process on whether to report to the authorities. The country context mapping should inform the risk assessment and the survivor’s wishes must also be considered before deciding on whether or not to report. Any decision to not report allegations which constitute a criminal offence (e.g. sexual abuse) to police or other competent authorities must be documented in the risk assessment, with clear reasons for not doing so. Decisions not to report criminal issues to the relevant authorities must be recorded on the global safeguarding register and the Chief Executive Officer (CEO) alerted to this decision.

Reporting to regulators: It is a requirement to report all serious safeguarding concerns to the regulatory body in the relevant Country. It is the responsibility of the Safeguarding Lead to ensure that the report is made.

Reporting to donors: Reporting requirements of donors should be clearly documented in agreements with donors and reports should be made in line with timelines specified in a confidential manner.

Referral services: HelpAge commits to undertaking a country context mapping to ensure we understand the legal and cultural context and have mapped referral services for survivors and all those affected by the concern (e.g. medical, psychosocial, and legal). Mappings should be tailored as part of the risk assessment process for all programme locations to ensure all those affected by harm and abuse are supported in accessing relevant and appropriate support services.

Record keeping: All information relating to safeguarding case management should be recorded carefully and comprehensively. This is to ensure accurate documentation of the incident. Information that both corroborates and contradicts the allegation should be recorded. All information gathered, as well as decisions taken and the reasons for them, should be clearly outlined in the case management process and included in final investigation reports. All case management data should be anonymised and securely archived after 10 years.

All safeguarding concerns relating to abuse, exploitation, bullying and harassment should be reported to the Global Safeguarding Lead via:

– Email to concerns@helpage.org

– Respective in country Safeguarding Focal Point

Standard Eight: Partnerships, contractors and suppliers

Partners, contractors and suppliers will undergo due diligence processes to determine if the safeguarding measures they have in place meet the HAI safeguarding Minimum standards set out in HelpAge Global Safeguarding Policy. Where the due diligence process identifies gaps that do not meet sector safeguarding standards, the entity will be consider adopting HelpAge Global Safeguarding Policy. They will be supported to build their understanding and ability to implement the relevant standards as set out in this policy and develop their own as needed.
All partnership agreements and contracts with contractors, suppliers, or any other entity delivering work in partnership with, or on behalf of, HelpAge, must include a clause on the safeguarding of children, older people/ at-risk adults. Partners, contractors and suppliers will be briefed on HelpAge Global Safeguarding Policy at the start of their engagement with the organisation. Partnership agreements will specifically detail the arrangements between HelpAge and the partner in respect of the procedures for case identification, reporting and handling between the two entities. HelpAge will work with partners embracing the partnership principles of trust, capacity development and will regularly monitor how partners, contractors and suppliers are implementing their safeguarding commitments as stated in their partnership agreement or contract. Where commitments are not being met, HelpAge will conduct a review with the entity to understand the gaps and challenges and put an action plan in place to address the identified gaps.

Standard Nine: Advocacy, media, and communications

HelpAge will deliver quality communications, campaigns, media and advocacy work in a way that minimises the risk of harm to older people and prioritises their wellbeing and safety. Our priority is to ensure that any engagement by an individual with HelpAge communications and advocacy activities is a meaningful and informed process. Any content that is collected will prioritise the dignity and respect of individuals and ensure rigorous vetting procedures are followed prior to public dissemination.

Informed consent must be obtained prior before carrying out any media, communications and advocacy activity, and any content gathering should be accompanied by a full briefing for those providing consent. Individuals will be depicted as active participants in their own lives and inside their communities with a balanced depiction of the life of the individual or group being presented.

All representatives of the media visiting our work must: sign the HelpAge Global Safeguarding Policy; attend a safeguarding briefing prior to any engagement with programme participants; and always be accompanied by a HelpAge representative.

Standard Ten: Safeguarding data privacy and digital safeguarding

HelpAge adopts the ‘Do No Harm’ principle and compliance with data protection laws ensuring that any safeguarding data collected about, or from, older people is used in ways that respect their privacy and minimise the risk of harm. The main principle to safeguard protection for data should be data minimisation, we will ensure that the minimum amount of data is collected, only data that is directly relevant and necessary to accomplish HelpAge stated safeguarding purposes will be collected.

Before sharing safeguarding data, employees must ensure that unless required for case management or referral purposes, all identifiable data is removed including names, addresses, and contact details before sharing both internally and externally (eg with donors, media, stakeholders, communities). Names of programme participants should always be replaced with a code and a data processing agreement should be in place when sharing externally.

Guidelines on use of social media by staff, trustees, volunteers and consultants should be adhered to as outlined in the HelpAge Code of Conduct.

7. Appendices

Appendix one: Glossary of terms

Accountability: The process of using power responsibly, taken account of, and being held accountable by different stakeholders, and primarily those who are affected by the exercise of such power.

At-risk adult: An individual 18 years of age or above who is unable to protect themselves from harm, abuse and exploitation for any reason; is at increased risk due to their gender, sexual orientation, gender identity, gender expression and sex characteristics (SOGIE), age, disability, ethnicity, race, economic or social status; as a result of conflict or disaster; or experiences a power differential that puts them at risk.

Child: Every human being below the age of 18.

Abuse: Abuse is any act which individuals, institutions or processes do – or fail to do – which directly or indirectly results in a negative impact on another. Refer to forced labour, trafficking, emotional abuse, exploitation, financial/material abuse, grooming, neglect, online abuse, physical abuse, sexual abuse, spiritual abuse, and traditional harmful practices for specific definitions.

Bullying: Repetitive, intentional hurting of one person or group by another person or group, where the relationship involves an imbalance of power. It can happen face to face or online.

Do No Harm: Taking steps to avoid exposing people to additional risks through the actions of those who deliver international development and/or humanitarian programmes by understanding the broader context and mitigating potential negative effects on the broader social, economic and political environment.

Emotional abuse: Persistent emotional maltreatment that impacts negatively on an individual’s emotional state. This can include restriction of movement, degrading treatment, humiliation, bullying (including cyber bullying), threats, discrimination, ridicule or other non-physical forms of hostile or exclusionary treatment.

Exploitation: This encompasses, but is not limited to, the following forms of exploitation:

• Commercial exploitation of an individual occurs when that person works or does activities for the benefit of others but does not benefit in any way or experiences harm as a result of the work. This includes, but is not limited to, domestic work, forced participation in armed conflict, including the use of child soldiers, and involvement in harmful and hazardous work.
• Sexual exploitation is a form of exploitation and sexual abuse that involves an individual being engaged in any sexual activity in exchange for money, gifts, food, accommodation or any other material needs (e.g. prostitution, trafficking and the exploitation of and creation and dissemination of sexually explicit videos and pictures). This can also occur online where an act of a sexually exploitative nature is carried out against an individual. It includes any use of information and communication technology that results in sexual exploitation or results in or causes images/other material documenting the exploitation to be produced, bought, sold, possessed, distributed or transmitted.

Financial/material abuse: Includes theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, corruption or the misuse or misappropriation of property, possessions or benefits.

Grooming: Behaviour that makes it easier for an offender to procure an individual for sexual activity. It happens when there is a power differential or well-planned manipulation in a relationship, which the abuser exploits for their own satisfaction. This is a common tactic used by perpetrators against children for sexual activity. However, older people can also be groomed. This can occur during face-to-face or online contact.

Harassment: Unwanted conduct, including threads and demands, which offends, intimidates or humiliates someone. It can be a one-off or repeated act.

Harm: Any detrimental effect on an individual’s physical, psychosocial, or emotional wellbeing. Harm may be caused by abuse, exploitation, harassment, bullying, assault, or any action that puts the person at risk, whether intentionally or unintentionally.

Neglect: Persistent failure to meet an individual’s basic physical and/or psychological needs or provide adequate care and support for them. This includes the failure to protect children, youth and at-risk adults from harm as well as provide adequate nutrition, shelter and safe living conditions.

Online abuse: Any form of abuse that happens whilst interacting with digital technology. It can happen anywhere, for example social media, text messages and messaging apps, email, online chats, online gaming, and live-streaming sites. Examples of online abuse include cyberbullying, grooming, sexting, sexual abuse, psychological/emotional abuse and sexual exploitation.

Protected Characteristics: The United Nations refers to international human rights legal frameworks that combat specific forms of discrimination, including discrimination against indigenous peoples, migrants, minorities, people with disabilities, discrimination against women, racial and religious discrimination, or discrimination based on sexual orientation and gender identity.

Physical abuse: Actual or potential physical harm perpetrated by another person, adult or child. This may involve hitting, shaking, poisoning, burning or other physical acts.

Safeguarding: Set of organisational policies, procedures and practices employed to ensure HelpAge is a safe organisation, responsible for protecting individuals from the risk of harm, abuse, exploitation and neglect caused by those who have a duty to protect and care for them.

Sexual abuse: Forcing or enticing an individual to take part in sexual activities. The sexual abuse of children occurs whether or not the child is aware of what is happening. This may include rape, oral sex, penetration, masturbation, kissing, rubbing and inappropriate touching. It also includes engaging an individual in the viewing or production of sexual images, witnessing sexual activities and the encouragement to behave in sexually inappropriate ways.

Survivor-centred approach: A survivor-centred approach recognizes that the survivor, the person to whom the harm has been done, has the right to be treated with dignity and respect and not be exposed to victim-blaming attitudes; express their wishes for what action they would like to happen to deal with the harm and abuse instead of feeling powerless; privacy and confidentiality; non-discrimination based on gender, age, race/ethnicity, ability, sexual orientation, HIV status or any other characteristic; and receive comprehensive information and support to help them decide what action to take instead of being told what to do.

Trafficking: Any involvement in the recruitment, transportation or receipt of an individual for the purpose of exploitation, by means of threat, force or other forms of coercion.

Inter-Agency Standing Committee (IASC): IASC is a unique inter-agency forum for coordination, policy development and decision-making involving the key UN and non-UN humanitarian partners. The IASC was established in June 1992 in response to United Nations General Assembly Resolution 46/182 on the strengthening of humanitarian assistance. General Assembly Resolution 48/57 affirmed its role as the primary mechanism for inter-agency coordination of humanitarian assistance.

Partner: HelpAge develops partnerships with other organisations who are committed to our mission and to develop our work and extend our global reach. Partners who receive funding from HelpAge to deliver programmes undergo our internal due diligence process which includes safeguarding measures. We work with them to build capacity and support them  strengthen their safeguarding measures throughout the life of the programme.

Protection from Sexual Exploitation and Abuse (PSEA): The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel.  The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13).

Survivor: The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive. However, it is the individual’s choice how they wish to identify themselves.

Appendix two: Safeguarding Concern Reporting Form

Appendix three: Reporting flowchart