POLICY FOR PROTECTION FROM SEXUAL

EXPLOITATION AND ABUSE (PSEA)

AUSSIE ASSOCIATION OF
SOMALIA.
AYAN NOR MOALIM
EXECUTIVE DIRECTOR 2022
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1. INTRODUCTION
AAS takes a Zero tolerance approach to sexual exploitation and abuse (SEA). It can
occur when people in power exploit or abuse vulnerable people/populations for sexual
purposes. Often there can be unequal power dynamics/relations across an organization
and in relation to beneficiaries and communities we work with and as such we face a
risk that some staff may exploit their position of power for personal gain. AAS will not
tolerate any form of sexual harassment, sexual abuse or sexual exploitation and
considers such acts as serious misconduct, which constitutes grounds for disciplinary
measures. This extends to all employees, partners or any other representatives
associated with the delivery of our work. AAS takes seriously its duty and acknowledges
the particular vulnerability of women, girls, at risk adults and boys to sexual exploitation
and abuse. AAS undertakes an obligation not to put women, girls and boys at risk by
ensuring that all efforts are made to prevent sexual exploitation and abuse to
beneficiaries, the communities we serve and our employees. This policy builds on
AAS’s Code of Conduct and other associated policies and procedures 

2. PURPOSE OF THE POLICY 

AAS Protection from Sexual Exploitation and Abuse Policy has been developed to
ensure all AAS employees make ethical decisions to ensure the maximum protection of
our beneficiaries, our communities, our employees and our organization from
exploitation and abuse. We have developed our policy in accordance with the six core
principles adopted by the Inter Agency Standing Committee Task Force on Prevention
and Response to Sexual Exploitation, the principles of the United Nations Secretary
General’s Bulletin on Special Measures for protection from sexual exploitation and
sexual abuse (ST/SGB/2003/13) and the United Nations Convention on the Elimination
of All Forms of Discrimination Against Women (CEDAW). AAS believes all people have
a right to live their lives free from fear and any form of abuse of power regardless of
age, gender, sexuality, disability, religion or ethnic origin 

3. DEFINITIONS

Sexual Exploitation:

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.

Sexual Abuse:
Actual or threatened physical intrusion of a sexual nature, whether by force or under
unequal or coercive conditions

Child:
Is any individual under the age of 18, irrespective of local country definitions of when a
child reaches adulthood. 

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4. SCOPE OF THE POLICY
This PSEA policy applies to all Employee of AAS, both on-and off-duty. 

5. IASC Six Core Principles Relating to SEA

In order to protect and keep our beneficiaries in safe environment free from all forms of
SEA, as well as ensure the integrity of AAS and its activities. Therefore, all the
EMPLOYEES of AAS must be adhered to the IASC Six Core Principles relating to SEA,
listed below; 

i. Sexual Exploitation and Abuse by humanitarian workers including AAS

EMPLOYEE constitute acts of gross misconduct and are therefore grounds for
termination of employment
ii. 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
regarding the age of a child is not a defense
iii. 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 beneficiaries
iv. Any sexual relationship between the EMPLOYEE of AAS and the beneficiaries of
assistance of otter vulnerable members of the community that involves improper
use of rank or position is prohibited. Such relationships undermine the credibility
and integrity of AAS.
v. Where the EMPLOYEE of AAS develops concerns or suspicions regarding
sexual abuse or exploitation by a fellow worker, whether in the same organization
or not, he/she must report such concerns via established reporting mechanisms 

vi. All the EMPLOYEE of AAS are obliged to create and maintain an environment
which prevents SEA and promotes the implementation of the IASC Six Core
Principles relating to SEA. Managers at all levels have responsibilities to support
& develop systems which maintain this environment. 

CONSEQUENCES OF NONCOMPLIANCE
Consequences of noncompliance will include disciplinary actions up to dismissal,
removal, termination of contract and/or referral to appropriate law enforcement agency
or legal authority 

6. AAS CODE OF CONDUCT 

To allow AAS to achieve its vision and mission depends upon the individual and
collaborative efforts of all AAS's Employees must uphold and promote the highest
standards of ethical and professional conduct and abide by Self Help Africa’s policies.
This policy sets the minimum standards to be followed by all AAS’s Employees to
protect our beneficiaries, the communities we serve and our colleagues from sexual
exploitation and abuse by AAS’s Employees. To that end our employees sign our Code
of Conduct and agree that they must behave in a manner befitting AAS’s employee.
They accept the following as minimum standards of behavior: 

a) The AAS’s Employee will commit to the promotion of and respect for human rights
and will always treat people with respect and courtesy. The AAS’s Employee will obey
local laws and respect local customs.
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b) The AAS’s Employee will uphold the reputation of the organization and in their
professional and personal conduct act in a manner which is consistent with the values
of the organization.
c) The AAS’s Employee will safeguard and treat responsibly all information, assets and
resources to which they have access by reason of their work/working with Self Help
Africa.
d) The AAS’s Employee will avoid/deciare conflicts of interest and will not engage in
corruption or any criminal activities.
e) The AAS’s Employee will not engage in bullying or harassment, including sexual
harassment, and will not engage in discrimination of any kind.
f) The AAS’s Employee will not be under the influence of alcohol or drugs while
engaged in AAS duties.
g) The AAS’s Employee will maintain professional relationships with beneficiaries,
respecting their privacy and dignity and will not use their position to form an
inappropriate or exploitative
h) relationship with a beneficiary.
i) The AAS’s Employee will maintain professional relationships with their colleagues,
respecting their privacy and dignity and will not use their position to form an
inappropriate or exploitative relationship with a colleague.
J) The AAS’s Employee will not commit any act that could result in physical, sexual or
psychological harm or suffering to another person. 

k) The AAS’s Employee will not engage in any sexual activity with a child under the age
of 18 regardless of the age of consent or majority in the country where they are working.
Mistaken belief regarding the age of the child is not a defense. 

l) The AAS’s Employee will not engage in sexual activity with a beneficiary. 

m)The AAS’s Employee will not exchange money, offers of money, employment, goods
or services in return for sex or sexual activity. 

n) The AAS’s Employee will immediately report any breaches or suspected breaches of
this code of conduct to their line manager or a more senior manager as appropriate, up
to board level. 

7. ROLES AND RESPONSIBILITIES:

7.1. AAS Board of Governance (BOD)

The PSA related roles and responsibilities of AAS BOD include;
Hold accountable and custodian of this PSEA POLICY
Provides all necessary support to the ED of AAS for successful implementation of this
PSEA POLICY.

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c) Review quarterly report of PSEA implementation at each AAS BOD quarterly

meeting 

d) To be role model in reinforcing implementation of the core principles and

commitments of PSEA POLICY

7,2. Executive Director-ED

The PSEA related roles and responsibilities of the ED of AAS include; 

a} Hold accountable and ultimately responsible implementation of this policy 

b} Revisions and updating of this policy as needed and seek approval of the AAS BOD 

c) Ensure adequate resource including funding in place to support implementation of

this policy 

d} Appoint PSEA focal point from the AAS senior management levels 

e) Appoint or recruit SEA Investigation Manager from within AAS and/or external 

f} Provide oversight of this policy implementation and other related policies of AAS 

g) Provide quarterly report of PSEA implementation to the AAS BOD within a period of
10 days before the date of the AAS BOD quarterly meeting h} To be role model in
reinforcing implementation of core principles and commitments of this PSEA POLICY

7.3. Senior Managers 

The PSEA related roles and responsibilities of the senior management include;
a) Promoting awareness and application of this POLICY
b) Lead implementation of SEA prevention and response framework outlined in this
POLICY
c) Ensure that their EMPLOYEEL understand and sign off with this POLICY and
AAS Code of Conduct
d) Participate and contribute to the revision and updating of the POLICY and other
related policies
e) Advice the ED for implementation & alignments of this POLICY across AAS
policies and programs
f) Support and collaborate with PSEA Focal Point, Investigation Manager and HR
Manager
g) Facilitate and oversee investigations of SEA allegations
h) Coordinate with other organizations on PSEA, including donors, relevant clusters
and other partners
i) To be role model in reinforcing implementation of core principles and
commitments of this POLICY

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7.4. Program Teams: 

The PSEA related roles and responsibilities of the program teams include; 

a) To conduct safe and culturally appropriate consultations with beneficiaries on risk

mitigation and safe programing to minimize SEA risks and help connect survivors to
appropriate care and services 

b) To ensure that both beneficiaries and program team members are familiar with this
POLICY 

c) Promote community awareness on PSEA including but not limited to definitions of

SEA, prohibited behavior 

of EMPLOYEEL, how to raise and report SEA complaints, procedure for response and
referral of SEA complaints and contact details of the PSEA focal point 

d) To inform beneficiaries for goods/services available for them, entitlement and

selection criteria 

e) To collaborate & work with PSEA focal point and provide any required support on
PSEA related issues

7.5. Human Resources 

The PSEA related roles and responsibilities of the human resource include; 

a) Support and collaborate with senior managers, program teams, as well as advice
to ED & BOD 
b) Ensure all EMPLOYEEL understand and sign off PSEA policy, code of conduct
and other related policies 
c) Implementation of PSEA-sensitive recruitment, contracting and performance
management 
d) Act as resource point for guidance to all EMPLOYEEL 
e) To be role model in reinforcing implementation of core principles and
commitments of this POLICY

7.6. PSEA Focal Point 

PSEA focal point shall be appointed by the ED and once appointed will undergo training
on PSEA and other related policies of AAS.
He/she is PSEA point of contact and designated to support senior managers in
implementation and coordination of PSEA framework.

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7.7. All AAS EMPLOYEE
The PSEA related roles and responsibilities of all EMPLOYEEL include; 
a) To read, understand and uphold core principles, commitment and standards of
this PSEA policy, alongside with AAS Code of conduct and other PSEA of AAS.
b) Must sign this POLICY and AAS Code of Conduct
c) Complete the mandatory PSEA training
d) Actively participate PSEA awareness and dissemination of PSEA messages
e) Report allegations of SEA through designated reporting channels
f) Participate in investigations of SEA allegations as appropriate and cooperate fully
with investigation
g) Ensure the confidentiality of any reported SEA incident
h) To be role model in reinforcing implementation of core principles and
commitments of this PSEA POLICY 

8. PSEA PREVENTION AND RESPONSE FRAMEWORK

8.1. Prevention 

8.1.1. Safe Recruitment:

AAS has updated its HR policy and aligned with PSEA policy into its hiring process to
ensure robust recruitment screening, vetting and referencing process for all
EMPLOYEE, includes clauses on PSEA throughout its employment cycle inducing job
announcements/advertisements, job descriptions, background/reference checks,
interviews, EMPLOYEE contracts, performance management processes and
disciplinary measures in the event of proven allegations with SEA policies.
Sign off on PSEA Policy for all EMPLOYEE is mandatory and shall be part of the
contracts.

8.1.2. Training:
It is a mandatory that all new EMPLOYEE of AAS to receive PSEA training with briefing
on the Code of Conduct and other related policies of AAS as part of their induction
when they are joining to AAS. Furthermore, all existing EMPLOYEEL of AAS must
receive continues and refresher trainings on PSEA with special consideration given to
those working directly with beneficiaries on behalf of AAS 

8.1.3. Awareness Raising 

AAS is committed to promote awareness on PSEA among its EMPLOYEE, beneficiaries
and communities, through efforts may include of the following actions; 

 Developing PSEA communication messages that include beneficiary rights,

prohibited behaviors EMPLOYEE, definition of SEA, roles & responsibilities, SEA
complaints reporting and referral procedures, well as contact details of the PSEA
focal point 

 Adaption of international standard and locally relevant PSEA communication

messages, materials and channels to the various target audiences using Somalia
language, in some cases considering local dialects ~ seems necessary and
communication style that is appropriate and accessible to the target audience
especially groups considered as higher risk of abuse. For example, adolescent
girls may be more comfortable discussing personal issues as peer-to-peer
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discussions, while some EMPLOYEE may prefer to receive information in memo
or email. However, AAS shall always test its communication messages and
materials with the respective target audiences before dissemination. 

 Widely publicize and disseminate PSEA communication messages by using

various communication channels such as EMPLOYEE/community meetings,
printed IEC materials, AAS website, social media, mobile phone SMS texts, local
FM radios and various available Somali TV stations including Somali National TV
(SNTV) respective federal member state TVs and other popular private Somali
TV stations. 

8.1.4. Risk Mitigation and Safe Programming

AAS is committed to identify, mitigate and avoid risks of SEA through its programming
and for this purpose shall take on the following actions: 

 Conducting an inclusive risk assessment before designing projects as part of

initial needs assessment and the site safety mapping, focus group discussions
with intended beneficiaries and other stakeholder, (women, girls, children,
disability groups, minority tribes, communities and local authorities) plus research
methods. As part of the assessment, AAS shall identify groups that are mostly
marginalized and at higher risk of SEA to ensure that designing strategies of the
projects/programs are as targeted and effective as possible.
 Consulting with the beneficiaries and communities in manner of safe and
culturally appropriate to identify SEA at risk groups as part of initial needs
assessment and routine monitoring. AAS shall identify relevant risks and
protection measures that are in line with international standards 

 Take proactive measures to avoid causing inadvertent harm to civilians,

contribute to actively reduce existing threats and ensure programs are conflict
and gender sensitive. This includes embedding good practice, programmatic
actions to minimize SEA risks and help connect survivors to appropriate care in
cross-sectoral programming and in distinct sectors. AAS also ensures that SEA-
related prevention and safety measures are reflected in project/program cycle
including the budget and monitoring framework 

8.2. Response
8.2.1. Reporting
To ensure effective and efficient reporting of SEA complaints, AAS commits to; 

a) Adhere to the principles of survivors centered approach by promoting confidentiality,

transparency, respect, safety, anonymity, seek informed consent from all complainants
of SEA and ensure that its EMPLOYEEL, beneficiaries and community know where and
how to report SEA complaints, as well as available service providers of humanitarian
and legal assistance at local and national level 

b) Develop safe, confidential, respect, non-discrimination, affordable, accessible

reporting and complaint mechanisms for its EMPLOYEEL and beneficiaries to report
SEA complaints, as well as encourage to report SEA complaints without fear of reprisals
and victimization by having multiple reporting channels where complaints can be
reported in assured privacy and confidentiality. 
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c) The safe, confidential, affordable and accessible reporting channels specific for the
beneficiaries include; locked and secured complaint boxes available at all offices and
project sites of AAS, 24/7 free talk and SMS messaging hotline telephone & SEA
reporting desk all handled by female PSEA focal point. All EMPLOYEE must report to
their line manager, HR/Compliance Officer 

d) Nominate and train two PSEA focal points (one female and one male) to receive SEA
complaints and support implementation and monitoring of the PSEA policy 

e) Provide regular training for more EMPLOYEE at all AAS offices and project sites in
order to ensure adequate EMPLOYEE available for assistance and support to survivors
including referral to appropriate authorities responsible for investigations of SEA
allegations with respect to criminal cases 

f) Ensure transparent processing of SEA complaints in professional and timely manner.

Alt concerns of SEA allegations will always be taken seriously, investigated and acted
upon where appropriate, including immediate suspension of alleged perpetrator from
the EMPLOYEE until investigation is concluded and if investigation result is declared
that the EMPLOYEE commits guilty to SEA, then AAS will take appropriate disciplinary
actions including immediate termination of contract with blacklisting of any future
engagements with AAS and/or referral to relevant authority for criminal prosecution 

g) In promptly and confidentially in a manner that assures the safety of all involved, AAS
will report allegations of sexual exploitation and abuse arising from its partnership
agreement with Donors and UN including UNICEF AAS shall also share regular updates
on reported cases, investigation process and outcome including referrals and
assistance for survivors 

8.2.2. Victim Assistance and Referral 

AAS committed to survivor-centered approach that supports SEA survivors to receive

protections and remedies they desire, need and are entitled to. Therefore, to achieve
the survivor-centered approach, AAS will take on the following actions;

 Ensure SEA survivors have unhindered access to assistance and referral

regardless of decisions by investigating entities and outcome of an investigation 
 No requirements to identify the perpetrator or prove of SEA survivors to access
their entitled services 
 Updated list of service providers and referral forms available at all project sites
and EMPLOYEE of AAS must be familiar with the referral pathway 
 AAS shall consult with UNICEF, Somalia GBV working group and child protection
area of responsibility (CPAOR.) Jn. cases of involving children 

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3.2.3. Investigation 
AAS is committed to conduct investigations of SEA allegations involving by its
EMPLOYEEL in professional and timely manner, as well as protect the safety & rights of
those involved, including survivors, witnesses and alleged EMPLOYEE.
All concerns of SEA allegations will always be taken seriously, investigated and acted
upon where appropriate. AAS has procedures for handling SEA complaints, if the SEA
allegation involved by the PARSONNEL of AAS other than PSEA focal point or/and
HR/Compliance Officer and ED, the SEA allegation will be handled HR/Compliance
Officer who will review SEA allegation and if there is a need for investigation will form
internal investigation committee (IIC) from the AAS senior management. If the SEA
allegation involved by PSEA focal point or/and HR/Compliance Officer, the SEA case
will be handled by the ED of AAS who will review the SEA allegation and if there is need
for investigation will form internal investigation committee (IIC) from AAS senior
managements. 

If the SEA allegation involved by the ED, then the SEA case will be handled by the
Chair of AAS BOD who will review the case and if there is a need for investigation will
form an internal investigation committee (IIC) from AAS BOD and senior managements
excluding the ED. However, all EMPLOYEEL at any rank involved SEA allegation will
be subject to immediate suspension until investigation process is concluded and if
investigation result is declared that alleged EMPLOYEEL commits guilty to SEA, then
AAS will take appropriate disciplinary actions including termination of contract with
blacklisting for any future engagements with AAS and/or referral to relevant authority for
criminal prosecution. 

if the SEA allegation is involved by the EMPLOYEEL from other agency, then AAS will
refer the case to the concerned agency of alleged EMPLOYEEL and only with the
consent of the survivor, AAS will refer to the relevant law enforcement and legal
authority, as well as AAS will confidentially share and report SEA case to its Donors and
mandated UN including UNICEF 

Furthermore, AAS will ensure all documented evidences of SEA allegations and
subsequent follow-up to be held securely and strictly confidential. The name (s) of the
complainant (s) will not be revealed to the person(s) involved in the allegation or to any
other persons without consent of the complainant (s). All sensitive information related to
SEA allegation will always be treated as highly confidential and shared only with
discretion and on a need-to-know basis. 

In conclusion, currently AAS lacks the capacity and resources needed to conduct
complex and sensitive SEA investigation, while availability of qualified investigators in
Somalia is limited and if available costs are too high. Therefore, AAS will ensure to
engage a hired professional investigator when required fund is available or secure
investigative expertise as appropriate by seeking support from other partner
organizations and/or potential, donors to sponsor professional investigator to conduct
such SEA investigations if reported. However, AAS BOD is committed to rise fund for
training of its own investigator in the near future and will further review its PSEA
POLICY 

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9. MONITORING AND REVIEW OF POLICY 

The ED will oversight implementation of the POLICY and in collaboration with

HR/Compliance Officer and PSEA ' focal points will monitor implementation and
effectiveness of this POLICY through monitoring framework including regular
community level monitoring, communications with EMPLOYEEL of AAS and
beneficiaries, periodically review and lessons learned, documentation and quarterly
progress reports including opportunities and challenges submitted to the AAS BOD, the
relevant Donors and funding partners. 

Furthermore, The ED in collaboration with HR/Compliance Officer and PSEA focal

points will organize PSEA quarterly review meeting at management level for
improvement and update this POLICY according to the specified timeframe.
The ED will recruit external consultant for review of the POLICY if seems necessary
subject to. The ED will further seek technical assistance to "the Networks which AAS is
a member or Donors for support of consultancy provision required to review the PSEA
POUCY. Finally, the ED will mobilize any required resources for monitoring and review
of the POLICY internally and externally.

CONTACTS
Email; info@aas.org.so
Website; Www.aas.org
Phone; +252613646428/9

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