Safeguarding Policy

Organizational Commitment

JSI is committed to protecting the rights and dignity of the populations we serve, as well as creating safe workplaces for our staff, volunteers and other associates. Exploitation, sexual abuse, sexual harassment and child abuse and child neglect violate human rights and are a betrayal of our core values.

JSI has zero-tolerance for any form of sexual misconduct, abuse, exploitation, or violence, as well as for inaction on allegations of such behavior. JSI will take every reasonable measure to prevent such incidents and will investigate, act upon, and report suspected safeguarding violations in accordance with the provisions of this policy and JSI’s policies for investigating ethics and fraud violations.

Safeguarding is the responsibility of all JSI staff, regardless of role, and all JSI associates. These policies specifically apply to staff and associate interactions, both during and off work hours, with all populations with whom we work, as well as all children we come into contact with. The personal conduct of those engaged in work for JSI—either as direct staff, consultants, volunteers, or as staff of our partners, contractors, vendors, and subrecipients—will be measured against this policy.

Please refer to the list of definitions at the end of this policy.

Goal of Safeguarding Policy

The overall goal of our safeguarding efforts is to create an organizational culture for safeguarding whereby harm and abuse of those working within, and with, JSI is prevented.

We recognize that we have a particular responsibility to protect the children and vulnerable adults we come in contact with from such harm and abuses of power. JSI staff and programs regularly come in contact with vulnerable populations, including children. In these situations, beneficiaries may be at risk of abuse or exploitation due to their dependence or reliance on others for services, basic needs, or protection. This Safeguarding Policy details the measures JSI will take to protect children and vulnerable adults we come into contact with from exploitation and abuse. It encompasses both Protection against Sexual Exploitation and Abuse (PSEA) measures and Child Safeguarding measures.

This policy compliments, and works in conjunction with, JSI’s Sexual Harassment and Anti-Trafficking policies, which are included within the JSI Code of Conduct.

JSI embraces the principles within the UN Convention on the Rights of the Child, the Keeping Children Safe Standards, Inter-Agency Standing Committee’s Six Core Principles Relating to Sexual Exploitation and Abuse, as its minimum standards of protection for children and other beneficiaries reached by our programs. In line with these principles, this policy prohibits JSI employees and associates from engaging in any exploitation, sexual abuse, child abuse, and child neglect, supporting or advancing these actions, or intentionally ignoring or failing to act upon allegations of these actions.

Safeguarding Principles

Ethical practices at JSI are guided by the principle that work and business relationships be conducted with the highest level of honesty, integrity, diligence, fairness, trust, and respect. JSI safeguarding principles include:

Equality: We will treat all children and adults with equal respect, without discrimination, regardless of their race, sex, gender, gender identity or expression, religion, nationality, ethnic origin, sexual orientation, disability, age, language, social origin or any other shared characteristic or trait.

Responsibility: We are all responsible for protecting children and vulnerable adults with whom we work or come into contact with from exploitation and abuse. We will demonstrate our commitment to safeguarding in all our interactions with children and beneficiaries.

Accountability: We will hold ourselves and others accountable to our safeguarding policies and code of conduct. We will monitor JSI employees’ and associates’ compliance with this policy and take appropriate action in response to allegations of violations, including, but not limited to, dismissal of personnel.

Cooperation: We will work closely with government, funders, partners, and beneficiaries to promote a safe environment for children and vulnerable adults. We will report alleged violations of this policy and will cooperate fully with investigations whether completed internally, or by U.S. government authorities, other funders, or local authorities.

Survivor-centered approach: JSI will take a survivor-centered approach to all allegations. JSI will place the survivor’s experiences, considerations, and needs at the center of the process, with appropriate due process and accountability for alleged perpetrators. Investigation and response processes will ensure sensitivity and accountability, avoid re-traumatizing survivors, maintain focus on the survivors, and ensure support to survivors.

Best interest of the child: JSI will prioritize the best interests of the child when responding to alleged violations involving a child. Determining what is in the best interest of the child considers the best possible outcome for a vulnerable child who has been exposed to violence, abuse, exploitation, or neglect.

Awareness: We will ensure that JSI employees and associates are aware of this policy and their obligations under it. We will ensure that children, beneficiaries and the communities we interact with understand and are aware of safeguarding policies and reporting processes.

Survivors as participants in investigations: We will ensure that care is taken when survivors are involved in an investigation and that any investigative interview with a survivor be undertaken in a survivor-centered manner. When children are involved in an investigation we will ensure the child’s wishes, safety, and well-being are prioritized and will undertake additional best practice protocols (e.g., child-centered, child-paced, and conducted or guided by a suitably trained practitioner).

Responsiveness: We will ensure that reporting and investigating processes are conducted in a timely manner.

Scope

The JSI Safeguarding Policy applies to everyone associated with JSI, including but not limited to:

  • All full-time, part-time, and temporary JSI employees
  • Volunteers and interns
  • Consultants
  • Business partners (subcontractors, subrecipients, vendors) and their employees
  • Partner staff
  • Any other organization or individual provided access to or contact with beneficiaries

Standards of Behavior

JSI employees and associates are prohibited from engaging in any exploitation, sexual abuse, child abuse, and child neglect, supporting or advancing these actions, or intentionally ignoring or failing to act upon allegations of these actions.

These standards of behavior provide specific principles that must be followed and actions that must be avoided in order to comply with this policy. These standards are expected of and apply to all JSI staff and associates. Employees and associates are expected to understand the implications of these standards on their language, behavior, actions, and relationships with beneficiaries, especially children. Any breach or failure to comply with these standards will be taken seriously by JSI and will result in disciplinary action.

Protection from Sexual Exploitation and Abuse (PSEA) Standards of Behavior

The JSI PSEA Standards of Behavior are applicable to the treatment of beneficiaries with whom JSI staff and associates come into contact. The list below is not prescriptive and should be applied in the spirit of providing the highest level of protection and duty of care to beneficiaries.

JSI employees and associates are expected to adhere to the following Standards of Behavior:

  • Sexual exploitation and abuse by JSI staff and associates constitute acts of gross misconduct and are therefore grounds for termination of employment or contractual relationships;
  • Sexual activity with children (persons under the age of 18) is prohibited regardless of the age of majority or age of consent locally. Mistaken belief in the age of a child is not a defense;
  • Exchange of money, employment, goods, or services for sex, including sexual favors or other forms of humiliating, degrading, or exploitative behavior is prohibited. This includes exchange of assistance that is due to program/project beneficiaries;
  • Any sexual relationship between JSI staff/associates and beneficiaries that involves improper use of rank or position is prohibited. Such relationships undermine the credibility and integrity of JSI’s work;
  • Where a JSI staff member or associate develops concerns or suspicions regarding sexual exploitation or sexual abuse by a fellow worker, whether JSI staff or associate staff, he or she must report such concerns via established reporting mechanisms;
  • JSI staff and associates are obliged to create and maintain an environment that prevents sexual exploitation and abuse. Managers at all levels have particular responsibilities to support and develop systems that maintain this environment.

Child Safeguarding Standards of Behavior

The JSI Child Safeguarding Standards of Behavior are applicable to the treatment of all children with whom JSI staff and associates come into contact with both during and outside work. The list below is not prescriptive and should be applied in the spirit of providing the highest level of protection and duty of care to children.

When working with children YOU MUST NEVER:

  • ● Hit or otherwise physically assault, harm, or abuse children.
  • Engage in sexual activity or have a sexual relationship with anyone under the age of 18 years, regardless of the age of majority/consent or custom locally. Mistaken belief in the age of a child is not a defense.
  • Develop relationships with children that could be in any way considered exploitative or abusive.
  • Act in any way that may be abusive or place a child at risk of abuse.
  • Use language with or behave toward a child in a way that is inappropriate, offensive, abusive, sexually provocative, demeaning or culturally inappropriate.
  • Have a child/children with whom we are working stay overnight at your home or other personal accommodation in which you are staying.
  • Condone or participate in children’s behavior that is illegal, unsafe or abusive.
  • Act in ways intended to shame, humiliate, belittle, or degrade children.
  • Ignore or fail to report allegations made or concerns expressed by others about children’s welfare.
  • Use a computer or other electronic device to view, download, distribute, or create indecent or inappropriate images of children.
  • Use children’s images or information without obtaining proper permission and informed consent.
  • Use computers, social media, mobile phones, video and digital cameras or other electronic devices and mediums to exploit, harass or bully children.
  • Employ anyone below the minimum age established by local law or employ anyone under the age of 18 for work likely to harm the individual’s health, safety, or morals.

When possible, JSI staff and associates should avoid being alone with children who are beneficiaries of our programs. Bearing in mind however that we must also recognize a child’s autonomy and right to privacy and confidentiality, particularly in a medical or clinical setting. In keeping with this policy’s child-centered approach, unsupervised interactions are not prohibited when in the best interest of the child. This includes when necessary to protect a child’s privacy or confidentiality, when a lack of privacy would discourage children from accessing a program (for example, family planning services), and when a child seeks to disclose abuse.

Compliance Plan

The following requirements represent JSI’s baseline safeguarding compliance plan. JSI will ensure compliance with safeguarding standards through the procedures described and referenced throughout this policy and attached appendices. All JSI operations are subject to this policy and it will be enforced across all JSI locations and activities.

Safe Programming

Assessment
JSI will consider safeguarding in project planning and implementation. It is each project’s responsibility to ensure full compliance with this policy and ensure its integration into program planning and implementation. Every project will be assessed to determine the level of safeguarding risk. Projects should consult the JSI Safeguarding Guidelines, which supplements this policy.

Monitoring and Compliance
JSI will monitor and ensure compliance with this policy in a manner commensurate with the safeguarding risk posed by the activities. At a minimum, every project must ensure compliance with the Standards of Behavior and the baseline Compliance Plan stated in this policy. When the project risk assessment determines a project to be higher risk, JSI projects will implement a more detailed safeguarding compliance plan as appropriate for the size and complexity of the project, the nature and scope of activities, and the operating context.

All projects that could potentially affect children must annually review their programs to ensure that the project scope has not changed to affect children. If, after the annual review, a project is determined to be higher risk, it must follow additional actions as described in the JSI Safeguarding Guidelines.

Awareness

JSI will take the following steps, at a minimum, to inform staff and associates about the requirements of this policy:

  • This Safeguarding Policy is incorporated in full in the JSI Code of Conduct. All JSI employees receive orientation on their duties and obligations under the code of conduct, including this policy and the standards of behavior included herein. All staff are required to confirm, in writing, their receipt of the code of conduct and their commitment to abide by JSI policies and procedures.
  • All staff are required to take the JSI Safeguarding course within 30 days of hire and annually thereafter. All staff will receive the appropriate level of safeguarding training, and designated safeguarding focal persons will be trained to the level commensurate with their responsibilities. JSI’s safeguarding training will be reviewed regularly to ensure it is up-to-date and relevant.
  • Ensuring that JSI staff and associates know that this policy can be publicly accessed on the JSI website.
  • All contractual instruments issued by JSI to associates include safeguarding requirements commensurate with the risk posed by the associate or its work. At a minimum, contractual instruments issued by JSI require compliance with the Standards of Behavior listed in this policy and the URL for the location of this policy.
  • JSI has developed a safeguarding poster to communicate the activities prohibited and encouraging the reporting of violations or concerns. This poster should be translated into the most common languages spoken locally. The poster may also be modified to be culturally appropriate and sensitive to the context. Copies of the JSI safeguarding poster must be hung in each JSI office. Additionally, copies of the poster will be hung wherever we work, especially anywhere we may come in contact with children. Examples include ministry offices (if permitted), health clinics or facilities, rec centers or community gathering places, schools, etc.

Designated Safeguarding Focal Person

Designated safeguarding focal persons will be identified to support the coordination and implementation of JSI’s safeguarding obligations across the organizations.

Safe Communication

JSI expects its staff to promote dignity and respect in all communications. JSI will ensure that information and images of beneficiaries, particularly children, are never used in a way that lessens beneficiaries’ safety or dignity. JSI communications must never include images or stories that are inappropriate, disrespectful, or could create stigma, this includes images of nudity, individuals in distress, or any depiction that could inadvertently expose vulnerable populations to stigma or compromise their privacy, such as those in identifiable locations associated with sensitive issues like TB or HIV clinics.  This safe communication requirement applies to all communications including the use of information and visuals (i.e., photographs and video) on social media platforms, websites, and online and print materials. See JSI’s Ethical Storytelling Practices Framework for additional guidance.

Informed consent for use of images and information
We are committed to portraying individuals, especially children, respectfully and appropriately. Individuals representing JSI must adhere to the organization’s guidelines when capturing, storing, displaying, and publishing beneficiaries’ images. Informed consent from the individual or, if the subject is a child, from the relevant caregiver and informed agreement from the child in question (according to age of understanding), must be secured before using any information about the beneficiary in external communications – written, audio, or visual. Consent must be evidenced on a consent form. Except to the extent consent has been specifically granted, every effort should be made to ensure that confidentiality is maintained.

Consult the JSI photo consent form and FAQs for more information, linked here.

Information and communications technology
This safeguarding policy applies to all JSI staff and associate interactions and communications with beneficiaries, including online and on social media. JSI prohibits the use of its computer systems and networks to exploit, harass, or bully beneficiaries, or to access, create or distribute inappropriate images of children.

Recruitment

JSI takes preventive steps to reduce the risk of engaging a person who may be unsafe or unsuitable to work with, or be in contact with, beneficiaries. JSI has developed guidelines for recruitment to ensure we hire, and engage with, the safest and most suitable staff, volunteers, and partners. Such people act in the best interests of beneficiaries, protect children from all forms of abuse, and share JSI’s values. Lack of beneficiary-safe recruitment and screening procedures greatly increases the risk of engaging someone who may pose an unacceptable risk of harm (physical, sexual or emotional) to beneficiaries, particularly children.

By promoting beneficiary-safe recruitment and screening procedures, JSI can attract the best people to work with beneficiaries, and deter those who seek to join JSI because they want to harm beneficiaries.

By implementing beneficiary-safe recruitment and screening procedures, JSI aims to create and maintain a safe environment, to keep all beneficiaries safe in the delivery of programs.

For staff who will be working directly with beneficiaries, particularly children, as part of the scope of their project, JSI conducts additional due diligence, including special behavior-based questions during interviews; screening questions during the reference check stage; where legal, completes criminal background checks following all applicable local laws; and/or requiring a special signed disclosure that a staff member has not been charged with child abuse or sexual misconduct offenses. Only volunteers who have undergone child-safe recruitment and screening procedures can be engaged to work with or be in direct or indirect contact with children.

All JSI job descriptions are required to include language similar to the following:

“JSI is committed to protecting the populations we serve from exploitation, sexual abuse, child abuse and child neglect. We are a child-safe organization and the safety and wellbeing of children is a priority of our organization, as is the prevention of sexual exploitation and abuse in any form. We have zero-tolerance for such behavior and we will take every measure to prevent such incidents. We have robust recruitment procedures to ensure that all staff are suited to work with the communities served by our programs.”

Reporting

Mechanisms
JSI will ensure the availability of safe and accessible reporting mechanisms. Everyone involved in program activities (ranging from employees to training participants) must be made aware of the JSI reporting mechanisms and how to report safeguarding concerns.

JSI’s standard method of reporting violations of JSI’s Code of Conduct, as well as this safeguarding policy, is the JSI Code of Conduct Helpline. The Helpline is available internally and externally at www.jsi.com and www.worlded.org. Individuals may report violations via the online portal, toll-free telephone number, mobile intake, and, in some countries, a country specific telephone number. Reports made through the Helpline are confidential and reporters may remain anonymous if they choose.

Projects are also encouraged to discuss the best type of reporting channels for their country, operating context, and individuals they come in contact with. Where possible, children and communities should be asked how they would like to report safeguarding concerns – and be ready to make those avenues available. If additional reporting mechanisms are introduced, there must be a process to log those cases through the JSI Code of Conduct Helpline.

Recognizing the special responsibility of protecting the privacy of the survivor and the confidentiality of the implicated person, JSI discourages communication about the details of safeguarding concerns via e-mail unless absolutely necessary. If e-mail is necessary, subject headings should be vague and inoffensive, and must be flagged as confidential.

Requirements
Survivors, particularly children, often have difficulty speaking up when they feel unsafe or are being harmed, especially within organizational or institutional settings. While it is important to encourage survivors to speak up, JSI cannot rely on survivors to let JSI know if a staff member, volunteer or associate is harming them or makes them feel unsafe. It is not the survivor’s responsibility to disclose such information.

JSI employees are required to report any suspected violations of this policy they become aware of to the JSI Code of Conduct Helpline immediately. Failure to report suspected violations of this policy is itself a violation of this policy and will result in disciplinary action. The reporter should then communicate the concern to the designated safeguarding focal person. If a project does not have a safeguarding focal person, they should communicate the concern to the JSI Chief of Party/Project Director/Country Director (unless that person is implicated in the allegation) or US Human Resources. The number of people notified should remain at a minimum to ensure confidentiality.

When JSI receives credible evidence from any source that alleges a violation of this policy, JSI Vice President, Contracts & Compliance, or his/her designee, will immediately report to USAID or other funders as required by the terms of our agreements with those funders. When appropriate, JSI will also report allegations to local authorities.

Responding to Allegations

Any action to respond to or investigate a safeguarding concern must be survivor-centered and follow JSI’s standard ethics investigation process in relation to allegations. Allegations concerning a child must also be guided by what is in the best interest of the child. In addition, the designated safeguarding focal person must be involved in the incident response and management process.

Responding to children’s disclosures of abuse
Because child safeguarding violations involve a minor, JSI has developed the below additional guidance to ensure safety and appropriate sensitivity.

If information about child safeguarding violations is disclosed by a child, whether or not the complaint is made by the child survivor themselves, the process of reporting and managing the incident will require additional age-appropriate steps and considerations. JSI staff or partners must keep in mind the age of the child or young person and do the following when receiving disclosures made by a child:

  • The safety and welfare of the child is always the first priority.
  • Listen to and support the child.
  • Reassure the child that they did the right thing.
  • Assess the risk of ongoing abuse.
  • Take action to provide all possible help.
  • Do not promise something you can’t deliver.
  • Exercise caution and sensitivity in disclosing information (i.e., only to appropriate personnel).
  • Contact the appropriate authorities.

Managing reported incidents
JSI will immediately initiate an investigation of any safeguarding concern it becomes aware of. This investigation will follow our established policies and processes for all ethics/fraud incident reports. Additionally, for safeguarding-related incidents, investigations will adhere to the following:

  1. Ensuring the safety of the survivor and witnesses is always the first priority. JSI will take appropriate action to protect and support beneficiaries who are the subject of concerns regarding possible safeguarding violations and the witnesses who report such violations. These actions may include referrals to organizations that can provide medical care, security, legal aid, and counseling. The safety of other potentially involved individuals (survivor’s family, alleged perpetrator, JSI staff, etc) must also be considered.
  2. The investigation will be conducted by a qualified, impartial team free of any influence that could impair the team’s judgment. If internal capacity is not available, JSI will engage outside experts to conduct the investigation.
  3. Persons reporting the incident and persons who have witnessed inappropriate conduct will be treated respectfully. Statements made by the complainant will be kept in appropriate confidentiality. The complainant will be:
    – Interviewed to confirm all relevant facts.
    – Given the opportunity to provide relevant facts.
    – Given the opportunity to participate in the investigation by providing names/identities of other witnesses and recommending questions to be asked by investigators.
  4. Appropriate confidentiality must be maintained. Personally identifiable information (PII) pertaining to incidents in which a survivor’s rights have been violated should be shared only to a limited number of specified people on a ‘need to know’ basis, as deemed by the VP, Contracts & Compliance or designee, in consultation with the designated safeguarding focal person. Appropriate steps must be taken to ensure the secure transfer and storing of information. In all instances, PII, including survivors’, witnesses’ and alleged perpetrators’ identities, must not be disclosed beyond the appropriate management personnel, unless authorized.
  5. While appropriate confidentiality must be maintained, JSI reserves the right to disclose, to the extent allowed by law: information required to be disclosed to proper authorities; information required to comply with funder reporting requirements, and; information involving employees terminated on the basis of safeguarding violations to other organizations or authorities.
  6. JSI will cooperate fully with any US Government agencies responsible for any investigations, audits or corrective actions relating to this policy, including, but not limited to, providing timely and complete responses to document requests, and providing reasonable access to JSI facilities and staff.

Whistleblowing

JSI’s whistleblowing policy encourages people who become aware of wrongdoing in the organization to report their concerns immediately. All incidents are investigated fairly and confidentially. We are committed to non-retaliation against staff members who report possible or actual violation of this policy. JSI will not discharge, demote, discriminate or otherwise retaliate against an employee or any other person who, in good faith, reports or threatens to report a violation of this policy, or who cooperates with any government investigation of such reports.

JSI treats malicious allegations with the utmost seriousness and takes appropriate disciplinary action.

For more information, employees should refer to the whistleblower policy in the JSI Code of Conduct or country-specific Local Hire Employee Manual (LHEM), as applicable.

Sub-recipients, Subcontractors, Sub-grantees, Consultants, and Other Agents

JSI includes safeguarding requirements in all contractual documents. At a minimum, JSI business partners must:

  • Comply with the JSI Safeguarding Standards of Behavior.
  • Maintain procedures to prevent and punish safeguarding violations.
  • Immediately report to JSI any credible allegations of exploitation, sexual abuse, child abuse, or child neglect related to the contract or agreement.

Additionally, business partners working on JSI projects or activities that involve children or that otherwise present an increased risk to beneficiaries will be expected to comply with the principles and standards in our safeguarding policy (or the partner’s equivalent policy). Contractual documents will also include funder-required safeguarding clauses including, as applicable, the USAID Mandatory Standard Provision, Safeguarding Against Exploitation, Sexual Abuse, Child Abuse, and Child Neglect, AIDAR 752.7013, Contractor-Mission Relationships (Deviation No. M-OAA-DEV-AIDAR-22-08c), and AIDAR 752.7037, Child Safeguarding Standards.

JSI will monitor and ensure business partner compliance in a manner commensurate with the safeguarding risk posed by the activities or partner. JSI pre-award assessments will include a review of a partner’s ability to comply with safeguarding requirements and the inherent risk in the project activities that they will be conducting. Monitoring of higher-risk partners and activities will consist of, as applicable, including compliance in regular reporting, evaluations, and site visits, and appropriate safeguarding training of partner staff.

JSI’s zero-tolerance for any form of exploitation, sexual abuse, child abuse, and child neglect extends to the actions of its business partners and their employees. The consequences of a partner’s safeguarding violation are explicit and include termination of the contract, along with additional action as required (e.g., referral to appropriate authorities or funder). If JSI determines that a partner or a partner employee has committed a safeguarding violation, including failing to report or take reasonable steps to prevent violations, we will take appropriate action including, but not limited to:

  • Requiring the party to remove an employee or agent from a project.
  • Requiring the party to terminate its relationship with any other contractor, consultant, subcontractor, or sub-recipient found to be in violation.
  • Suspending payments to the party until the violation is remedied.
  • Immediately terminating the party’s agreement, grant, or contract.
  • Excluding the party from further work and other opportunities with JSI.
  • Reporting the violation to the funder and appropriate authorities.

Definitions

The following definitions apply to this policy:

Associates: Any individual or organization working with JSI or provided access or contact with beneficiaries including, but not limited to, business partners (consultants, subcontractors, subrecipients, vendors and other entities in a contractual relationship with JSI), interns, volunteers, and, for purposes of reporting concerns or suspicions of safeguarding violations, other implementing partners JSI works alongside.

Beneficiary: Any child or adult, typically a host-country resident or national or refugee from a third country, who is a recipient of, derives advantage from, or is helped by JSI activities or interventions.

ChildA person who has not attained age 18, regardless of the age of majority under local law.

Child abuse: Emotional, physical, sexual, or any other ill-treatment carried out against a child by an adult. Child abuse includes economic exploitation likely to interfere in the child’s education or to harm the child’s health, well-being, survival, development, or dignity including child labor, trafficking, forced labor, slavery or practices similar to slavery.

Child labor: Employment of (a) children below 14 years of age or, if higher than that age, the minimum age of employment permitted by the law of the country or countries where employed, or the age of the end of compulsory schooling in that country or countries, whichever is higher; and (b) persons under the age of 18 for work that, by its nature or the circumstances in which it is carried out, is likely to harm the child’s health, safety or morals.

Child Neglect:  The persistent failure to meet the child’s basic physical and / or psychological needs in the absence of the child’s parent or guardian when the care of the child is associated with the award activities. For example, inadequate care and supervision that is likely to result in the serious impairment of the child’s physical or cognitive development or that leaves a child in a situation where s/he could be harmed (but only where this can be avoided).

Emotional abuse or ill treatment: Injury to the psychological capacity or emotional stability of the child caused by acts, threats of acts, or coercive tactics. Emotional abuse may include, but is not limited to: humiliation, control, isolation, withholding of information, and any other deliberate activity that makes the child feel diminished or embarrassed.

Exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust, including for the purposes of profiting monetarily, socially, or politically. Exploitation represents a form of coercion and violence that is detrimental to the individual’s physical or mental health, development, education, or wellbeing. When carried out for a sexual purpose this constitutes sexual exploitation.

Physical child abuse: Acts or failures to act resulting in injury (not necessarily visible) or unnecessary or unjustified pain or suffering without causing injury, harm, or risk of harm to a child’s health or welfare, or death.

Safeguarding: The responsibility of organizations to make sure their staff, operations, and programs do not harm or expose children and vulnerable adults to exploitation, sexual abuse, child abuse, and child neglect.

Sexual abuse: Any actual or threatened physical intrusion of a sexual nature toward another person whether by force or under unequal or coercive conditions. When carried out against a child by an adult, such conduct is considered sexual abuse even in the absence of force or unequal or coercive conditions and regardless of whether or not the child is aware of what is happening or gives consent. Activities may involve physical contact, including penetrative (i.e., rape) or non-penetrative acts. They also include non-contact activities, such as involving children in viewing or producing pornographic materials, or encouraging children to behave in sexually inappropriate ways.

Sexual Harassment: Sexual harassment is a form of unlawful discrimination and is defined as unwelcome verbal, non-verbal, or physical conduct of a sexual nature that creates an intimidating, hostile, or offensive working environment. This can include but is not limited to: unwanted sexual advances, requests for sexual favors, sexually suggestive remarks or jokes, unwanted touching or physical contact, display of sexually explicit materials, and any other behavior of a sexual nature that interferes with an individual’s work performance or creates an intimidating, hostile, or offensive environment. The difference between Sexual Harassment and Sexual Exploitation and Abuse (SEA) is that Sexual Harassment is targeted at fellow JSI staff, contractor staff, consultants, etc., while SEA is targeted at children and vulnerable adults in the communities we serve. Sexual Harassment is prohibited by JSI’s Sexual Harassment Policy included in the JSI Code of Conduct.

Survivor: The individual who is, has been, or is suspected to have been, exploited or sexually abused, abused or neglected.

Vulnerable Adult: Is a person who for physical, social, economic, environmental or other factors can be more vulnerable to abuse and exploitation. We recognize that the work we do puts our staff, partners etc. in positions of power and the beneficiaries of our activities may, through their circumstances and relative lack of power, be vulnerable to SEA.