NECPAD’S Child and Client Protection Policy

The policy and procedures described in this document apply to all NECPAD staff, board members, volunteers, interns, researchers, outside consultants, interpreters, partner staff, parents, caregivers and outside visitors such as individual donors, that have direct or indirect contact with children or clients in connection with NECPAD. For the remainder of this document, the phrase “associated individuals” will be used to refer to all of these groups of people.

The term “client” refers to any child or adult survivor of slavery – or some other injustice – who is involved in some manner in a project or program related to NECPAD. Associated individuals of NECPAD are required to act according to this policy when: interacting with children or clients in any project work; utilizing children’s or clients’ knowledge for publicity or for formal or informal research; observing children or clients for any purposes; and interfacing with children or clients in any other situation.

The term “child” is separately identified to recognize the greater level of vulnerability of children in general, whether or not they are survivors of slavery or clients of NECPAD. Recognizing this, NECPAD requires that all associated individuals of NECPAD follow the guidelines of this policy during their interactions with any child, whether or not such interaction is related to professional work with NECPAD.

For the purposes of this document, the term “abuse” will refer to: physical, sexual or emotional injury or threat of injury to a child or client; the neglect of a child or client’s needs; or, the failure to protect a child or client from danger or illness.

Statement of Principles

As NECPAD and its associated individuals take on the critical task of ending global slavery, first and foremost, it is essential to recognize the deep vulnerability of former and current child and adult slaves, in addition to the general vulnerability of children. With this understanding, the NECPAD Child and Client Protection Policy begins with the notion that, in this important work, we must first “Do No Harm.” Specifically, without question, associated individuals of NECPAD should never physically, sexually or emotionally abuse any child or client in any manner. Moreover, associated individuals must act positively in a manner which protects and promotes the rights of children and clients. These rights, according to NECPAD, include the right to a healthy and safe environment and the opportunity to achieve one’s full potential. Children and clients should be valued, listened to, respected and understood within the context of their own culture, religion and ethnicity. Furthermore, associated individuals of NECPAD should work to empower children and clients by encouraging their participation in decisions which affect them. NECPAD staff and associated individuals must comply with these behavioral guidelines in both their professional and personal interactions with children, whether at work or outside.

To this end, interactions with children must follow the NECPAD Code of Conduct with regards to children and clients. To ensure maximum compliance with this Code of Conduct, NECPAD will implement a system involving

1. prevention,
2. reporting and
3. appropriate responsive action.

All associated individuals of NECPAD are required to comply with the prevention, reporting and ;2responsive action procedures outlined later in this document.

Related Code of Conduct to Child Protection Policy

Positive Steps:

• Be aware of potential abuses by maintaining open dialogue with children and clients; proactively ask children and clients about their interactions with NECPAD staff and associated individuals.
• Inform children and clients of their right to be free from abuse and explain what is appropriate and inappropriate behavior by others.
• Encourage children and clientsto raise concerns about abuse by clarifying the procedure which they should take to do so.
• Affirm the dignity of children and clients such that they are listened to, respected, understood and valued, even when rigid societal structures (caste, class, etc.) or societal norms (gender, age, etc.) suggest otherwise.
• Guarantee that children and clients fully understand the nature of their participation in any projects or programs.
• Obtain children’s and clients’ permission (not only adult or caregivers’ permission) to use images and stories for publicity and, prior to use, ensure that there would be no repercussions to the child or client when the individual is featured publicly.
• Respect children or client decisions to refuse to be interviewed or photographed and avoid negative, degrading or stigmatizing images of children and clients.
• Promote an organizational culture in which abuses do not go unchallenged and complicity in violation of these codes is condemned.
• Organize and plan workplace spaces and activities to minimize risks.
• Implement a reporting procedure which enables NECPAD staff and associated individuals, as well as unassociated individuals, to raise concerns about child or client abuse.
• Take seriously any concerns raised about abuse, support any individual who raises such a concern, and comply fully with investigations of abuse.
• Ensure the protection of children or clients who may be the subject of this abuse and seriously take into account the needs and wishes of the survivor of abuse.

Limitations on Behavior:

• Do not hit or otherwise physically abuse children or clients
• Do not develop physical/sexual relations with a child or client.
• Do not use language or give suggestions which are inappropriate, abusive or offensive.
• Do not behave in a sexually provocative manner
• Do not develop inappropriate relationships with children or clients that may be considered exploitive.
• Do not place a child or client in a risky situation.
• Do not spend time alone with a child or client
• Do not take a child or client home with you, especially to stay overnight and especially if nobody else will be present.
• Do not share a bed or room with a child or client.
• Do not “do things for children (or clients) of a personal nature that they can do for themselves”.
• Do not condone, or participate in, illegal, unsafe or abusive behavior of children or clients.
• Do not act in a manner which shames, humiliates, belittles or degrades children or clientsor otherwise perpetrates emotional abuse.
• Do not discriminate against or favor particular children or clientsto the exclusion of others.
• Do not make promises to children or clientsthat you cannot fulfill.

Action Plan

1. Prevention

Key for preventing child and client abuse is a formal process for raising awareness about the issues involved in working with children and clients, and ensuring that all individuals who may come in contact with children or clients of NECPAD agree to the principles outlined in the Child and Client Protection policy. In this vein, the following steps should be taken for properly briefing all associated individuals:

NECPAD staff, board members, volunteers, interns, researchers, outside consultants, interpreters – These individuals must read this Child and Client Protection Policy and formally agree to its principles by signing the document. These individuals must be given an opportunity to ask questions and receive adequate response from NECPAD staff about the policies outlined in this document. The NECPAD staff member responsible for distributing this policy to individuals will be the relevant supervisor, where one exists. If there is not a specific supervisor, the Director will hold responsibility for distribution. This should occur during the process of formalizing an individual’s relationship with NECPAD (e.g. hiring, contracting, etc.) or at the point that this policy is formally approved and adopted by NECPAD. All associated individuals who may come into contact with children or clients of NECPAD or of its partners will be required to sign a disclosure affidavit that provides a checklist of offenses, where they can voluntarily provide information about any past criminal history, if one exists. The affidavit also gives consent to obtain verification from U.S. law enforcement agencies and the child abuse central registry.

 

Partner staff – Representative staff of NECPAD’ partner organizations will be required to read this Child and Client Protection Policy and formally agree to its principles by signing the document. These individuals must be given an opportunity to ask questions and receive adequate response from NECPAD staff about the policies outlined in this document. As well, the partner organization must have in place, or plan within a reasonable period of time to put into place, a child and client protection policy of its own. It is hoped that this process will take the form of a dialogue such that differences in opinion due to cultural or social context are addressed. However, at the same time, NECPAD solemnly abides by the principles in this document and requires that its partner organizations do the same. This dialogue and process will take place during the development of the formal partnership agreement between NECPAD and its partners. More specific requirements for NECPAD partners will be outlined below in a section entitled “Sharing Our Child and Client Protection Standards with Partner Organizations.”

Outside visitors – Ad hoc visitors, such as interested individual donors or media personnel, who may come into contact with children and/or clients of NECPAD or of its partner organizations will be required to read this Child and Client Protection Policy and formally agree to its principles by signing the document prior to the initiation of the visit. These individuals must be given an opportunity to ask questions and receive adequate response from NECPAD staff about the policies. These individuals will also be required to sign a disclosure affidavit.

Parents or caregivers – While NECPAD will not require any formal or informal discussion with parents or caregivers about these policies, it will consider them “associated individuals” for the purposes of preventing child and client abuse and for freeing children and clients from such abuse. This means that if it is suspected that a parent or caregiver is abusing a child or client involved in an NECPAD-related project, it is necessary that the problem is reported and addressed.

1. Reporting

NECPAD has developed the following reporting procedure to ensure a safe space and clearly-defined system for voicing concerns whether by children, staff, visitors, etc. The procedure intends to enable immediate action to reports of suspected abuse.

Box 1: The Obligation to Report

Who should report an incidence or suspicion of abuse? According to NECPAD values, anyone associated or unassociated with NECPAD who has suspicions or concerns that a child or client with which NECPAD works is being abused-no matter how minor the abuse or how minor the impact on the child appears to be. Who must report an incidence or suspicion of abuse? NECPAD staff and associated individuals. Failure to report is unacceptable and may subject the individual to disciplinary action. While NECPAD understands that there are many reasons why individuals may be afraid to report abuse, such as concern about being mistaken, reprisals to that person, reprisals to the abuser, endangering a child or client further, etc., it is necessary to consider, most importantly, the consequences to the child or client if the abuse does exist and continues.

The procedure for reporting cases of potential child or client abuse are:

1. Attempt to write down in detail what you observed and any related conversations that you have had.
2. Immediately report the case to your direct supervisor at NECPAD in order to prevent further harm to the child or client. If you are not the person that had the initial suspicion, but rather, someone confided in you, you are still required to report the concern to your NECPAD supervisor. If you do not have a direct supervisor or are unclear about the chain of command, make the report to the Director of NECPAD. The Director should maintain full records of these conversations. Information should only be passed to those people who need to be aware of the case as described in this procedure. Extreme vigilance must be exercised in protecting confidential information.
3. Avoiding any delay, your supervisor should inform the Director of NECPAD who should immediately inform the Board of Directors about the case. In this step, the Director should give you the option of being present and presenting the case yourself. As well, if you were not the person with the initial concern, that person should be given the opportunity to be present, present the case himself/herself or submit a separate report.
4. The Board of Directors must discuss the issue immediately and set forth a plan of action which determines

• Whether there is a likely immediate danger to the child or client, and if so, what should and will be done to protect that individual.
• Whether the Board will conduct its own investigation and in what manner it will be conducted. This includes the decision of whether an external agency based in, or near, the locality of the child or client should be called upon to handle the investigation. When making this difficult decision, it is important to recognize that NECPAD does not have the “statutory role” to investigate such abuse and may not be

Box 2: Recognizing Abuse

NECPAD understands that it may be difficult to assess whether a child or client is being abused. Beyond obvious indications such as marks of physical abuse, other signs may include: anxiety, reduction of contact with others, reduced self-esteem, aggressive behavior, self-damaging behavior or activities, and intellectual impairment. It is also necessary to recognize that some children and clients may be at relatively more risk. Example are children and clients with disabilities, females subject to power differences between males and females and children from minority ethnic or religious communities. You, as an associated individual, are not expected to possess expertise in determining whether abuse exists. However, there are some clear signs which immediately obligate you to report potential abuse. These are: ·         Physical marks or symptoms of abuse ·         A child or client’s own disclosure to someone ·         Word of mouth evidence that is overheard or directly provided

***If at any point in this process, an individual fails to fulfill her/his obligation to report, any other person knowing of the apparent abuse may bring the report directly to the Board of Directors.***

Box 3: Responding to a disclosure

If you have received information from an individual who is concerned about possible abuse of a child or client, you should respond in the manner described below. This is especially crucial if it is a child or client that is divulging personal information to you Listen and allow the child, client or other individual to explain the situation in their own words. ·         Reassure the individual that he/she has not done anything wrong. ·         Maintain a positive and supportive attitude. ·         Provide the individual with information on what is likely to happen next. ·         If it is a child or client, do not ask direct or detailed questions at this time.

III. Disciplinary Action

If it is determined by the Board of Directors – with input from the Executive Director and other relevant NECPAD staff and associated individuals – that the accused individual has committed the abuse in question, disciplinary action must be taken. In making a decision about whether and what form to take disciplinary action, the following factors must be considered:

• The intent of the individual charged
• The context and nature of the abuse
• The harm to the child or client
• Other factors as deemed relevant.

Box 4: Maintaining appropriate confidentiality

Confidentiality is a vital component of this process. You should only reveal the report of abuse to the appropriate person as described in the reporting process outlined in this document. However, at the same time, you must not promise a child or client or another individual who has provided you with information about abuse that you will keep the information as secret. Rather, you must discuss the Child and Client Policy process and safeguards with the individual and listen to the individual’s concerns.

Disciplinary action may result in termination of the relationship between NECPAD and the individual whether through formal dismissal, termination of contract or otherwise. NECPAD may also determine that the case is such that criminal prosecution should be sought against the individual. As well, if the individual is a member of a partner organization, NECPAD will need to determine whether to terminate the relationship with the organization, as well. This will be based upon both the partner organization’s response and its expected ability to prevent such future abuses, as well as the criteria listed above. NECPAD expects that partner organizations will implement their own child and client protection policies to handle cases in which their own staff and other individuals who come into contact with their children and clients, including associated individuals of NECPAD, are implicated in an abusive act.

Sharing Our Child and Client Protection Standards with Partner Organizations

For NECPAD to effectively protect the children and clients which come into contact with our programs and organization as a whole, it is essential that our partner organizations meet the standards outlined in this document. NECPAD partner organizations include those organizations with which we hold formal short-term or long-term partnerships. Examples are: grassroots NGOs, advocacy NGOs, NGO project partners, research institutes, among others. The following requirements, in addition to those outlined above, will be relevant to our partner relationships:

• NECPAD must inquire into the partner organization’s policies and procedures to protect children and clients from abuse, and must introduce the NECPAD Child and Client Protection Policy to the partner.
• The partner organization must agree to the principles outlined in the NECPAD Child and Client Protection Policy by signing this document.
• If the partner organization does not have a policy and procedure in place to prevent or properly address the problem of child and client abuse, the partner must develop such a policy and procedure by ______________ (an agreed-upon date to be determined on a case-by-case basis). The components of this policy should include at least the following:
  • A clear organizational statement of principles/code of conduct on child and client protection
  • A process for raising awareness and achieving buy-in about these principles within the organization. This should include, at the least, organizational staff, board members and volunteers.
  • A reporting process for enabling open communication about suspected incidences of child and client abuse
  • A disciplinary action process with clear guidelines in terms of who holds responsibility for making disciplinary decisions and how those decisions will be made.

Note: The member of a partner organization who signs this document should do so as a representative of the organization, not as an individual. If the partner organization will not sign the NECPAD Child and Client Protection Policy and/or if it will not agree to put into place its own child and client protection policies and procedures, NECPAD will not develop or maintain a formal partnership with the organization.

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NECPAD’S ENVIRONMENTAL HEALTH AND SAFETY POLICY (E H S)

E H S V A L U E

We work safely in a manner that protects and promotes the health and well-being of the individual and the environment.

E H S P O L I C Y

NECPAD’s policy to operate in a safe, responsible manner which respects the environment and the health of our employees, our clients and the communities where we operate. We do not compromise environmental, health or safety values.

We will comply with all laws and regulations.

We are committed to continual review and improvement of our environment, health and safety performance and will include environmental, health and safety objectives, targets and metrics in our annual business or operating plans. We support the responsible use of natural resources, energy conservation, waste minimization, and pollution prevention.

All NECPAD employees are expected to understand, promote and assist in the implementation of the Policy and its accompanying principles

E H S P R I N C I P L E S

NECPAD’s EHS Policy includes the following key principles:

• We value human life above all else and manage risks accordingly. NECPAD is committed to eliminating fatalities. Fatality risk hazards are prevented by communicating clear expectations to employees that all work must be accomplished safely and by providing the training, tools, equipment, and accountability to safely perform their jobs. NECPAD promotes a culture where compromises to safe actions and conditions are unacceptable.
• We relentlessly pursue an EHS incident free workplace. NECPAD works to prevent incidents or adverse impacts, in addition to responding to them after an occurrence. Our goal is a work place that is incident free. Line management is accountable for assuring the means to accomplish this goal and employees must contribute to this goal. Training to equip employees with the skills necessary to recognize and prevent potential incidents will be provided.
• We comply with all laws and set higher standards for ourselves and our clients where unacceptable risks are identified.
• We support sustainable development by incorporating social responsibility, economic success and EHS excellence in our decision making process. NECPAD integrates EHS management with business and operating management to ensure that EHS issues are considered in conjunction with financial aspects, when decisions are made regarding new and existing facilities, processes, products, services, acquisitions and divestitures.
• We measure and assess our performance and are open and transparent in our communications. NECPAD will submit itself for audits especially with respect to EHS performance on a regular basis to evaluate EHS Policy conformance, strengths/weaknesses in environmental, health and safety management processes and plans, and to identify actions that need to be taken to prevent incidents or to correct deficiencies. Appropriate NECPAD officers, Directors and Senior Managers will periodically be informed of the audit findings. NECPAD will communicate promptly and openly with individuals, concerned parties and communities who request information regarding our EHS policy and the significant environmental, health and safety potentials or impacts of our operations.
• We use our EHS knowledge to enhance the safety and wellbeing of our communities. NECPAD periodically sponsors internal and external activities that reduce or minimize potential EHS impacts of our activities and to advance EHS in the communities where we operate.
• We are all accountable for conforming with and deploying our EHS Value, Policy and Principles. Employees, including contract employees are responsible for working in a manner that respects the health and safety of the individual and the environment. Such behavior is a requirement of the workplace. Line management is accountable for assuring compliance with the EHS Policy and responding to environmental, health and safety issues or concerns.

I M P L E M E N T I N G A U T H O R I T Y

The Board of Directors of the Network for Community Planning and Development (NECPAD) is the principal implementing authority for these policies. The Board shall adopt, implement and integrate policies and procedures and provide compliance oversight on environmental health and safety issues. NECPAD’s EHS section led by its EHS Officer is responsible for providing technical guidance, oversight, consultation, training and specialized services to assist NECPAD in meeting its public health, safety and environmental protection responsibilities.