alinea’s safeguarding policy

 

1 Purpose

The purpose of this policy is to protect people, particularly Children, At Risk Adults and beneficiaries of assistance, from any harm that may be caused due to their coming into contact with Alinea. This includes harm arising from:

  • the conduct of Representatives and Volunteers associated with Alinea, and,
  • the design and implementation of Alinea’s programs and activities.

The policy lays out the commitments made by Alinea, and informs Representatives and Volunteers of their responsibilities in relation to safeguarding.

 

2 Safeguarding Governance

This Policy is applicable to all Company activities. It is part of the Company’s governance structure and applies to all Representatives and Volunteers as well as to any Project visitors including journalists, politicians and celebrities. Any deviation from this Policy requires the approval of the Responsible Official.

President and CEO Responsible for policy, oversight and review of safeguarding
Management Committee Oversees regular review of safeguarding
President Drives culture of safeguarding
Responsible Official Maintains and ensures implementation of policy and supporting framework
Project Directors and Managers Ensure staff comply with the policy and foster a culture where risks can be identified, escalated and managed
Staff and Contractors Comply with safeguarding policies and procedures

The Company has in place Guidelines, Business Processes, SOPs and Tools to support implementation of this Policy.

The Responsible Official, with input from the business as appropriate, is responsible for maintaining and implementing the related Guidelines, Business Processes, SOPs and Tools.

Guidelines, Business Processes, SOPs and Tools may vary with different operating environments if required by local legislation, Client rules and regulations and other factors, subject to the approval of the Board of Directors.

 

3 Definitions

“At-Risk Adult” Sometimes also referred to as vulnerable adult.  A person who is or may be in need of care by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.

 “Bullying” is offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient. Bullying can include the use of personal strength or the power to coerce through fear or intimidation, not necessarily from someone in a position of authority. Bullying may be physical, verbal or non-verbal. It can include conduct that is not face-to-face, including via text message, email and social media.

 “Business Partner” means any Representative, subcontractor, grantee, sub-grantee, awardee, sub- awardee, adviser, vendor, supplier, landlord or other organization providing goods or services to the Company.

“Child/Children” refers to a person(s) below the age of 18 years.

 “Company” refers to Alinea International Ltd. (Alinea) and all of its subsidiaries or related companies.

 “Compliance” means adherence to laws, codes, regulations, rules, standards, policies and guidelines concerning proper conduct, management, and business transactions.

 “Discrimination” means the unjust or prejudicial treatment of different categories of people, especially on the grounds of a protected class.

 “Employee” means any person who has a part-time, full-time, intermittent, continuous or fixed-term employment relationship with the Company or Business Partner.

 “Exploited” means forcing a person into slavery, servitude or forced labour, sexual exploitation, removal of organs, securing services by threat, or securing services from children or vulnerable adults – see s3 of The Modern Slavery Act 2013.“Guidelines” means the written elaborations on Company policy that provide further information and interpretation for the implementation of policy.

 “Harm” refers to Psychological, physical and any other infringement of an individual’s rights.

 “Health, Safety, Security, Environment (HSSE)” refers to the obligation of the Company and Business Partners to provide a safe working environment and system of work.

 “Human Trafficking” means the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, Forced Labour or services, slavery, or practices similar to slavery, servitude or the removal of organs.

 “Management Committee” refers to the President, Vice Presidents, Chief Financial Officer, Director, Business Development and Office Managers.

 “Manager” refers to any Employee who is responsible for the direction of other Employees.

 “Modern Slavery” is an overarching term encompassing all forms of contemporary slavery including Human Trafficking, slavery, servitude, Descent-based Slavery, Forced Labour, Debt Bondage or Bonded Labour, Forced and early Marriage and Child Labour. It is the recruitment, movement, harbouring or receiving of children, women and man through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. 1926 Slavery Convention defines slavery as ‘the status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised’.

 “Policy” means the policy of the Company from time to time set out in a policy document approved by the Board of Directors.

 “Project” means a piece of work subject to a contract between the Company and any client on which Representatives or Volunteers are engaged.

 “Project Director” refers to the Employee with day to day responsibility for the management of a Project.

 “Representative” means an Employee or any person who has an independent individual contractual relationship with the Company, whether as a contractor, consultant or agent of the Company. This includes non-executive directors of the board.

 “Responsible Official” means the Representative who is accountable for execution of the Company policy.

 “Safeguarding Focal Point” refers to the person within an office or a Project who has formal responsibility for safeguarding concerns.

 “Sexual Abuse”: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It should cover sexual assault (attempted rape, kissing / touching, forcing someone to perform oral sex / touching) as well as rape. Under UN regulations, all sexual activity with someone under the age of 18 is considered to be sexual abuse.

 “Sexual Exploitation” means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. This definition incudes human trafficking and modern slavery. Under UN regulations it includes transactional sex, solicitation of transactional sex and exploitative relationship

 “Sexual Harassment” A continuum of unacceptable and unwelcome behaviours and practices of a sexual nature that may include, but are not limited to, sexual suggestions or demands, requests for sexual favours and sexual, verbal or physical conduct or gestures, that are or might reasonably be perceived as offensive or humiliating.

 “Survivor” means a 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.

 “Standard Operating Procedures” or “SOPs” are the detailed written descriptions of Business Processes that aim to ensure consistency and quality in process execution.

“Tool” means templates, forms, charts, informational and any other material prescribed for use in conjunction with an element of a Policy, Guideline, Business Process and SOPs.

 “Volunteer” means anybody providing voluntary support to the Company who is not a Representative.

“Workplace Harassment” includes but is not limited to, threats, intimidation, bullying, and subjecting individuals to ridicule or exclusion. Harassment is when bullying is because of a person’s identity, or who they are such as their age, gender, race, ethnicity, disability, religion, sexual identity etc. Often harassment is covered by law.

 

4 Safeguarding Policy

Safeguarding, social responsibility and respect for human rights are central to all of Alinea’s expectations of its Projects, Business Partners and Representatives. We operate a zero tolerance attitude towards any form of abuse and require everyone in the scope of this policy to work to eliminate breaches. We do not tolerate failure to act, to prevent or respond.

Safeguarding means protecting peoples’ health, well-being and human rights, and enabling them to live free from harm, abuse and neglect. In our sector, we understand it to mean protecting people, including Children and At Risk Adults, from harm that arises from coming into contact with our Representatives or Projects. This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.

Safeguarding applies consistently and without exception across our Projects, Business Partners and Representatives. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and we have mature, accountable and transparent systems for response, reporting and learning when risks materialize. These systems are survivor-centered and in so far as it is compatible with local and national laws protect those accused until proven guilty. Safeguarding puts beneficiaries and affected persons at the centre of all we do.

Alinea believes that everyone we come into contact with, regardless of race, nationality, ethnic origin, gender reassignment, gender identification, marital status, sex, sexual orientation, culture, religion or belief, pregnancy, maternity, disability, age and any other legally protected category has the right to be protected from all forms of harm, abuse, neglect and exploitation.

Alinea will not tolerate abuse or exploitation by Representatives, Volunteers or visitors to our Projects.

Representatives are required to proactively contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy.

This policy addresses the following areas of safeguarding:

  • human rights;
  • child safeguarding;
  • adult safeguarding;
  • protection from sexual exploitation, abuse and harassment;
  • protection against modern slavery and human trafficking; and
  • discrimination, bullying and Workplace Harassment.

These key areas of safeguarding have different policies and procedures associated with them (see Associated Policies in section 8 below).

Alinea commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.

 

5 Prevention

5.1 Alinea Responsibilities

Alinea will:

  • ensure that the business and its operations respect all fundamental human rights;
  • ensure all Representatives have access to, are familiar with, and know their responsibilities within this policy;
  • design and undertake all its Projects and activities in a way that protects people from any risk of harm that may arise from their coming into contact with Alinea, this includes the way in which information about individuals in our Projects is gathered and communicated;
  • implement stringent safeguarding procedures when recruiting, managing and deploying Representatives and Volunteers;
  • ensure Representatives receive training on safeguarding at a level commensurate with their role in the organization;
  • follow up on reports of safeguarding concerns promptly and according to due process; and
  • take appropriate and proportionate action against persons found in breach of this policy.

5.2 Representative Responsibilities

5.2.1 Respect for Human Rights

Our support for the principles established by UN Convention on Human Rights is enshrined in our business practises and our membership of the UN Global Compact evidences our commitment to upholding human rights. Our Representatives and Business Partners must conduct business in a manner that respects the fundamental human rights of all parties, and are expected to refrain from business practices that compromise universal human rights principals, including labour and safety standards and codes.

Representatives must respect the laws and regulations of the countries we work in, while maintaining an overarching adherence to universal human rights laws.

Representatives must not condone or endorse any policies, laws, practices or behaviours that may compromise our ethical standards.

5.2.2 Child Safeguarding

Alinea is committed to upholding the values and purpose of the UN Convention on the Rights of the Child, which require that Children will be protected from performing any work that is likely to be hazardous, interfere with a Child’s education, or is harmful to a Child’s health or physical, mental, spiritual, moral or social health.

Representatives must understand and appreciate that the responsibility is on them to use common sense and good judgment to avoid actions and behaviours that could be construed as Child abuse.

Alinea Representatives and Volunteers must not:

  • engage in sexual activity with anyone under the age of 18;
  • sexually abuse, exploit, or harass children;
  • subject a child to physical, emotional or psychological abuse, or neglect; or
  • engage in any commercially exploitative activities with children including child labour or trafficking.

5.2.3 Adult Safeguardig

Alinea Representatives and Volunteers must not:

  • sexually abuse or exploit At Risk Adults; or
  • subject an At Risk Adult to physical, emotional or psychological abuse, or neglect.

5.2.4 Protection from Sexual Explotation Sexual Abuse and Sexual Harassment (SEAH)

Alinea Uses the UN definitions to understand what is meant by SEAH:

  • Sexual Exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. Includes profiting momentarily, socially, or politically from sexual exploitation of another. Under UN regulations it includes transactional sex, solicitation of transactional sex and exploitative relationship.
  • Sexual Abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It should cover sexual assault (attempted rape, kissing / touching, forcing someone to perform oral sex / touching) as well as rape. Under UN regulations, all sexual activity with someone under the age of 18 is considered to be sexual abuse.
  • Sexual Harassment: A continuum of unacceptable and unwelcome behaviours and practices of a sexual nature that may include, but are not limited to, sexual suggestions or demands, requests for sexual favours and sexual, verbal or physical conduct or gestures, that are or might reasonably be perceived as offensive or humiliating.

Examples of behaviour that amounts to sexual harassment include but are not limited to:

  • Staring or leering
  • Unnecessary familiarity, such as touching
  • Suggestive comments or jokes
  • Insults or taunts of a sexual nature
  • Intrusive questions or statements about your personal life
  • Sending sexually explicit or suggestive emails or messages
  • Displaying posters, magazines or screen savers of a sexual nature
  • Inappropriate advances on social networking sites
  • Requests for sex
  • Repeated unwanted requests to go on a date
  • Behaviour that may also be considered to be an offence under criminal law such as physical assault, indecent exposure, stalking, obscene communications

Alinea does not tolerate sexual exploitation, abuse, or harassment of any kind within our organization or from those we work with. We recognize that the work we do brings risks of SEAH, particularly for vulnerable communities. Development and humanitarian initiatives can exacerbate inequitable power dynamics inherent within these working contexts including when engaging with vulnerable people, particularly women, girls, sexual and gender minorities, and children, as well as populations who are displaced or otherwise lacking access to basic rights and protections.

Representatives are required to engage proactively; identifying, preventing and guarding against all risks of SEAH. They must be particularly aware of the increased risk to Children and At Risk Adults. Alinea Representatives and Volunteers must not engage in sexual activity with anyone under the age of 18.

Every complaint raised will be taken seriously and investigated in a timely manner but with the survivor’s wishes driving the process.

Alinea Representatives and Volunteers must not:

  • exchange money, employment, goods or services for sexual activity including any exchange of assistance that is due to beneficiaries of assistance; or
  • engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics; or
  • behave in a way that violates another person’s dignity, makes them feel intimidated, degraded or humiliated, or creates a hostile or offensive environment.

5.2.5. Protection from Modern Slavery and Human Trafficking

Alinea does not tolerate or condone Modern Slavery or Human Trafficking. The Company is not required to make a policy statement pursuant to any legislation but is none the less committed to the principles of the Modern Slavery Act 2015, (UK legislation).  We will continue to update our employment standards policy to demonstrate compliance with key legislation on international principles of labour and ethical employment.

Representatives are expected to understand that vulnerability to Modern Slavery and Human Trafficking can be affected by factors related to the presence or absence of protection and respect for human rights, physical safety and security, access to the basic necessities of life (including food, water and health care) and patterns of migration, displacement and conflict.

Alinea Representatives and Volunteers must not:

  • hold another person in slavery or servitude;
  • require another person to perform forced, bonded or compulsory labour; or
  • arrange or facilitate the travel of another person with a view to that person being exploited.

If Modern Slavery or Human Trafficking are suspected, Representatives must report their concerns immediately as outlined below but must not try to intervene on their own as it might make the situation of that individual worse.

5.2.6 Discrimination, Bullying and Workplace Harassment

Alinea values diversity and employs and partners with individuals and organizations from a wide range of cultures and races. The Company is committed to an open and Discrimination free workplace. Representatives will not engage in discriminatory behaviours on the basis of race, nationality, ethnic origin, gender reassignment, gender identification, marital status, sex, sexual orientation, culture, religion or belief, pregnancy, maternity, disability, age or any other legally protected category.

The Company is dedicated to promoting gender equity and inclusive workplaces where persons with disabilities and other disadvantaged or vulnerable groups are reasonably accommodated.

Alinea has a zero tolerance attitude to bullying or any other form of Workplace Harassment.

Representatives must report any actual or suspected complaints or breaches to the company immediately. Any concerns raised will be treated confidentially and expeditiously.

Alinea Representatives and Volunteers must not:

  • Engage in any unlawful discrimination; or
  • Bully any individual or group of people; or

Subject any individual to any form of Workplace Harassment

 

6 Reporting

Alinea will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to Representatives and the communities we work with.

Representatives must report any actual or suspected breaches of this policy immediately. Failure to report a Safeguarding concern could be viewed as negligence and might result in disciplinary action or even dismissal.

Any Representative reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by Alinea’s Whistleblowing Policy.

Alinea will also accept complaints from external sources such as members of the public, partners and official bodies.

6.1 How to Report a Safeguarding Concern

Representatives who have a complaint or concern relating to safeguarding should report it immediately to their Safeguarding Focal Point or line manager. If the staff member does not feel comfortable reporting to their Safeguarding Focal Point or line manager (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to any other appropriate staff member. For example, this could be any member of the Management Committee the Safeguarding Officer or the Director, Risk Management.

Safeguarding Officer, Shelley Priebe: (shelleyp@alineainternational.com)

Director, Risk Management, Charles Duff: (charlesd@alineainternational.com)

Or through Alinea’s Whistleblower Hotline: ethics@alineainternational.com

Or through the Company website: www.alineainternational.com

In addition, where there are suspicions or allegations of improper conduct of any kind in relation to a project funded by the UK Government a report can be made to:

Foreign Commonwealth and Development Office

Counter Fraud and Whistleblowing Unit (CFWU) at reportingconcerns@fcdo.gov.uk or +44 (0) 1355 843747

Or the Modern Slavery Helpline on 08000 121 700 or

website: www.modernslaveryhelpline.org

7 Response

Alinea will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations, recording all complaints in the Safeguarding Register.

Depending on the nature of the breach, Alinea will take appropriate action which may include legal action or disciplinary action up to and including termination. Wherever possible and appropriate, the survivor’s wishes will be taken into account.

Alinea will offer support to survivors of harm caused by Representatives or Volunteers, regardless of whether a formal internal response is carried out (such as an internal investigation). Decisions regarding support will be led by the survivor.

It is essential that confidentiality is maintained at all stages of the process when dealing with safeguarding concerns.  Information relating to the concern and subsequent case management will be shared on a need to know basis only, and will be kept secure at all times.

Non-Retaliation: If a concern has been raised in good faith, Alinea operates a policy of non-retaliation. If the Company is made aware that there has been retaliation appropriate disciplinary steps will be taken, up to and including dismissal where appropriate. Intentionally made false or vexatious reports will not be tolerated and will result in disciplinary action up to and including dismissal where appropriate.

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