Purpose
Plan International Australia (PIA) is a global independent development and humanitarian organisation. We strive for a just world that advances children’s rights and equality for girls. We work alongside communities globally with children, young people and adults to deliver programs to see girls valued and empowered, so that future generations inherit and brighter and more equitable future.
PIA believes every child and young person has the right to live a life free from any form of violence, and deserves to grow up in a safe, peaceful, nurturing and enabling environment where they can fully exercise their rights. (As detailed in the Plan International position statement ‘The Rights of Children and Young People to Live Free From Violence’). Violence against any child or programme participant is against, not only the values and principles we uphold as described in this Policy, but also in direct opposition to the aims of our work. It is therefore imperative to our mandate to ensure that children and programme participants do not experience harm, abuse, exploitation, or any other form of violence because of their engagement with us or our programmes/projects, events, and processes.
As a member of the Plan International Federation, PIA is fully committed to Plan International’s Global Safeguarding Policy and Safeguarding Implementation Standards. Therefore, this policy and code of conduct draws on the Global Safeguarding Policy and Standards and aims to ensure that PIA takes all possible steps to ensure the safeguarding of children and programme participants against all forms of violence. It calls for creating an open and aware environment where concerns for the safety and wellbeing of a child or programme participant can be raised and managed in a fair and just manner, which protects the rights of all. This will be achieved by identifying and managing risks at all levels of our operations that may lead to harm.
In line with Plan’s global commitments, PIA commits to embracing Gender Responsive Intersectional Safeguarding in implementing this policy. We will strive to take full account of an individual’s gender and overlapping social identities and lived experience to understand the increased or decreased power individuals face in relation to one another. We recognise that depending on their intersecting identities, all individuals, women and girls in particular, can experience prejudice and a range of oppressions beyond gender inequality, for example white supremacy, colourism, racism, discrimination based on a person’s disability, age, ethnicity, language, sexual orientation or sexual identity. They may be at increased risk of being targeted for violence, abuse and discrimination by those with more power and they may find it more difficult to access services, find support or solidarity. We use this understanding to identify and respond to an individual’s specific safeguarding needs. Our risk assessments; project and programme designs; and safeguarding measures must fully consider and be aware of cultural/societal norms and all intersecting vulnerabilities .
PIA also recognises the emerging risks of harm and abuse related to increasing contact with children, young people and programme participants within a digital environment including recording, storing and sharing personal information through digital means and remain committed to carefully considering and mitigating these risks in the delivery of our work.
Specific guidelines for implementing various aspects of this policy are further explained in detail within PIA Safeguarding Procedures.
Scope
The PIA Safeguarding Policy applies to all individuals who come into contact with children and programme participants in the delivery of our work including but not limited to Staff, Managers, Leaders, Board Directors, Volunteers, other Associates and Visitors, all of whom are referred to collectively as ‘PIA Representatives’ who must comply with its requirements and understand the sanctions that may be applied for breaches of the policy.
In line with Plan’s Global Policy on Values, Conduct and Whistleblowing, this Policy and Code of Conduct is binding for PIA representatives at all times-both during and outside of working hours and in all aspects of a PIA representative’s life.
The protective scope of this policy covers:
- all children, those aged under 18, regardless of their association with Plan International or our programmes/projects; and
- any child or adult who is the target of, or who we know will be immediately affected by, one or more Plan International associated projects or initiative outputs, hereafter referred to as programme participant
While we are a child-focused organisation our work reaches and involves programme participants of all ages, as such we have a responsibility to safeguard these programme participants, irrespective of their age.
Where children who are not programme participants experience violence in the communities, they will be referred to the appropriate authorities, support services and/or absorbed into our protection and other programming interventions as appropriate/needed/can be done.
Policy Statement
PIA is fully committed to safeguarding all children and programme participants from all forms of violence. We take very seriously our responsibility and duty to ensure that we, as an organisation, and anyone who represents us and have contact with children and/or programme participants , does not in any way harm, abuse or commit any other act of violence against children and programme participants or place them at risk of the same.
PIA commits to:
- Creating a safe and inclusive culture that allows children, programme participants as well as PIA representatives to thrive and feel secure while engaging with PIA; and supports people to understand, exercise their rights and report any concerns. We promote the active involvement of children and programme participants in their own protection.
- Addressing the drivers of gender inequality and unequal power relations that can lead to harm and violence, including sexual harassment, sexual exploitation and sexual abuse (SHEA) through gender responsive intersectional safeguarding of all children and programme participants from all forms of violence by PIA representatives.
- Strengthening and sharing the capacity of all PIA representatives so they understand, and are supported in meeting, their safeguarding roles, responsibilities, and their duty to do no harm. We take positive action to prevent anyone who might be a risk to children and programme participants from becoming involved with us.
- Promoting child and programme participant safe practices, approaches, interventions and environments which respect, recognise and respond to the specific safeguarding needs and the diverse safeguarding risks faced by children and programme participants based on their gender and other identities. We will challenge and do not tolerate inequality, discrimination or exclusion.
- Encouraging, facilitating and receiving all reports related to safeguarding or SHEA concerns. We are committed to ensuring appropriate, adequate and accessible mechanisms for reporting are in place for staff, associates, children, programme participants and communities at large.
- Responding in a timely, effective, safe, comprehensive, procedurally fair and confidential manner to all Safeguarding complaints, allegations and incidents, ensuring victims’/survivors’ perspectives, voices and best interests are central to any efforts to prevent and respond to any safeguarding concern and providing necessary support to victims/survivors. We have zero tolerance to inaction on safeguarding and SHEA reports.
- Making continuous improvements to PIA’s safeguarding policies, systems and practices based on regular analysis and learning about what is working well and what needs to be done differently. We will actively collaborate with peers within the Plan Federation and across the Australian and International NGO community to improve effectiveness and to draw on sectoral best practices to inform PIA’s safeguarding work.
This policy should be read in conjunction with our PIA Policy on Preventing Sexual Harassment, Exploitation and Abuse (PSHEA) which provides our clear and explicit stance on SHEA of children and programme participants. When reading this policy, it should be understood that when we use the term ‘safeguarding’ this includes safeguarding all children and programme participants from all forms of violence including sexual violence. It is also noted that Plan International’s Safeguarding Implementation standards lay down the requirements for embedding safeguarding measures as outlined in this policy across PIA’s operations and interventions.
Guiding principles
This policy is underpinned by the following set of principles that guides its implementation:
1. Indisputable Rights
All children aged under 18 years have equal rights to protection from all forms of violence as declared in Article 19 of the United Nations Convention on the Rights of the Child. In addition, the Universal Declaration of Human Rights recognises fundamental human rights, the dignity, worth and equal rights of people at any age. PIA respects and upholds the rights of all children and programme participants irrespective of any identities they may hold including their: age, sex, gender, gender identity, sex characteristics, sexual orientation, nationality, ethnic origin, colour, race, language, religious or political beliefs, marital status, disability, physical or mental health, family, socio-economic or cultural background, class, any history of conflict with the law or any other aspect of their background or identity. Inequality, exclusion, and discrimination will be challenged and will not be tolerated.
All children and programme participants must be empowered and encouraged to fulfil their potential. Decisions made about children and programme participants will be made as far as possible with their participation and in their best interests, giving full consideration to how such decisions will affect them.
2. Zero tolerance to inaction
PIA believes that any form of violence against children and programme participants is unacceptable and we will not tolerate inaction on any reports of safeguarding concerns. We recognize that zero tolerance does not mean there will be no reports or incidents, nor does it mean that all reports of breaches will result in termination of contracts or employment without due process and investigations. Instead, zero tolerance for inaction means we will act on all safeguarding concerns and allegations, ensuring that our actions are timely, appropriate, and centred on the best interest of the victim/survivor , taking into account their specific safeguarding needs and vulnerabilities. We will take all reports of safeguarding concerns seriously and will respond to them as a matter of priority and in accordance with relevant procedures. Where investigations are deemed necessary, they will be carried out by appropriately experienced and qualified professionals. No one will be victimised for making a complaint in good faith- without malice and not for personal gain- and support will be provided to all involved and as relevant.
3. Survivor-centered
In responding to safeguarding concerns and allegations and breaches of this policy, PIA will be guided by the safety, rights, needs, wishes and empowerment of the victim/survivor, while ensuring procedural fairness to all parties. All decisions and actions will be trauma informed; PIA will recognise the potential and actual impacts of trauma and aim to prevent re-traumatisation. We will retain the privacy and dignity of the victim/survivor by maintaining confidentiality (within the limits of responding to the report), treating them respectfully, involving them in decision making, as appropriate, and providing comprehensive information and committing to referrals and assistance to support the recovery and safety of the victim/survivor.
Referring incidents of a potentially criminal nature to law enforcement or relevant authorities will be done after taking into account the wishes of an adult victim/survivor, the best interest assessment of a child victim/survivor and the welfare and safety of all parties. Where local or national laws mandate PlA to report a potential crime to the police or welfare authorities an appropriate safety plan that manages the risks for all concerned must be implemented.
Support will be offered to victims/survivors, complainants according to our survivor-centred approach and regardless of whether a formal response is carried out (e.g. an investigation). Support will also be offered as appropriate to others involved in an incident management process, recognising the impact this can have, for example on witnesses and those accused of carrying out inappropriate or harmful behaviours. This can include specialist psychosocial counselling, medical support, legal support and/or access to other specialist support as appropriate and as needed. Victims/Survivors and complainants can choose if/when they would like to take up the support options available to them. We are committed to learning from victims/survivors and complainants and being guided by them, where safe and appropriate to do so. We will ensure that cases are referred to appropriate professionals and organisations and that due diligence is taken to ensure that they act in line with our values and puts the welfare of all parties concerned as the highest priority.
4. Equality and inclusion
PIA recognises that gendered imbalances in power and social inequality are key drivers for violence and SHEA. We recognise that in all societies in which we work, gender and social inequality exists; staff, associates, and programme participants may have learned to accept unequal norms and stereotypes; and that the very nature of our work can unintentionally create and maintain differential power and unequal opportunities.
We take an intersectional approach to safeguarding. We consider the ways that multiple identities together create a person’s experiences of power, gender and social inequality and therefore vulnerability to violence and SHEA. We take appropriate measures to address implicit and explicit biases and other forms of discrimination and violence, which may arise because of a person’s diverse identity and/or position in society. We support the empowerment and inclusion of victim/survivors in the response process, in a manner that promotes equality, equity and ultimately their increased safety and protection.
5. Shared responsibility
PIA believes that all Plan representatives have a role to play in keeping children and programme participants safe across our work. Everybody has a responsibility to uphold the principles of this policy, understand their specific responsibilities for the effective implementation of this policy and take action to undertake these responsibilities. These particular responsibilities extend to those individuals or organisations that are associated with PIA including contractors and partner organsiations. Therefore, everyone working for, or associated with PIA’s work, must be aware of and adhere to the provisions of this policy. PIA will take measures ensure that PIA representatives and partners, as appropriate to their engagement with Plan, are skilled, confident, understand, accept and are well supported in meeting their Safeguarding responsibilities and engage positively with children, programme participants and communities.
6. Open and accountable
We are open and transparent and will hold ourselves to account for our commitment to safeguard children and programme participants. Our leaders will set clear expectations and take personal and organisational responsibility to create safe and inclusive environments to ensure a culture of equity and inclusion. We will provide information on this policy to all programme participants, children, members of communities in which we work, staff, associates and visitors. We will explain our commitments so that everybody understands how to exercise their rights and how to report any concerns related to safeguarding. We will also involve them in the development of safeguarding measures within PIA in accordance with their age, gender, abilities, and evolving capacities.
We will ensure safeguarding is mainstreamed into all we do and all our approaches; safeguarding concerns can be raised and discussed; poor practice and inappropriate behaviours can be challenged and addressed; and safeguarding measures will be regularly reviewed and strengthened.
Risk identification and management
PIA recognises that most PIA representatives have the best intentions towards children and programme participants, and work (with PIA) to promote their wellbeing and safety. However, unfortunately, we are also at risk of being targeted by those wanting to use the trust and position as a PIA representative to access children and programme participants with an intention to exploit or harm them. Further, there are multiple factors that increases the risk of harm and abuse of children and programme participants in the delivery of our work as a child and youth focused development and humanitarian organisation and in contexts where we work. PIA understands that the effects of abuse on an individual are both devastating and long term and will therefore take proactive steps to identify and minimise safeguarding risks across all aspects of our work.
PIA will not permit a person to work with children or programme participants if they pose an unacceptable risk to children and programme participants’ safety or wellbeing. PIA will seek to ensure it creates safe environments for children and programme participants by thoroughly assessing and managing risks to children and programme participants in all of our operations, activities, projects, programmes, partnerships, and actively monitoring them on a regular basis. PIA ensures gender responsive safeguarding measures are integrated into all areas of our work and all PIA representatives (as relevant to their engagement with the organisation) are trained in recognising, assessing, mitigating, systematically reviewing and effectively managing risks at all levels of the organisation. Safeguarding risks are assessed by the organisational Risk Assessment Team, included in our organisational risk register where relevant and needed and monitored by the leadership and governing body on a regular basis.
Roles and Responsibilities
Everyone who works with, and engages with Plan, has a responsibility to ensure that children and programme participants are safeguarded and protected. The responsibilities detailed below are mandatory for those who fall within the scope of the policy.
Plan International Australia Staff, Managers, Leaders, Board Directors, Volunteers, other Associates, and Visitors must:
1. Never abuse and/or exploit a child or programme participants or act/behave in any way that places a child or programme participant at risk of harm
2. Sign onto and agree to abide by this policy, code of conduct and the procedures relevant to them as outlined in the PIA Safeguarding Procedures document
3. Immediately report any safeguarding concerns and breaches of the policy and code of conduct in line with PIA and/or applicable local office procedures and this policy.
4. Respond to a child or programme participants who may have been harmed, abused or exploited in accordance with their age, gender, abilities, PIA and/or applicable local office procedures and this policy.
5. Cooperate fully and confidentially in any investigation of concerns or allegations of harm to children or programme participants.
6. Participate in child protection/safeguarding induction and training as relevant to their relationship with PIA.
7. Commit and contribute to building an environment where children and young people feel respected, supported, safe and protected and encouraged to discuss (and voice) their concerns.
8. Always treat children and programme participants in a manner which is respectful of their rights, integrity and dignity, considers their best interests and does not expose them to, or place them at risk of, harm. For example: when taking images/pictures during visits, interacting with children or generating stories of children, ensure that this is done in a manner consistent with the appropriate Plan International policies, procedures and standards.
Managers will ensure that:
9. PIA participants working in their area of responsibility are aware of, sign onto and agree to abide by this policy, code of conduct, PIA procedures and the Safeguarding Implementation Standards applicable to their role or engagement.
10. This policy is fully embedded within their areas of responsibility in accordance with the Safeguarding Implementation Standards and PIA safeguarding procedures.
11. Children, programme participants and communities in which we work are made aware of the provisions of this policy and code to ensure they have the confidence and ability to report any safeguarding concerns and/or incidents occurring against children and programme participants.
12. They support and develop systems which maintains an environment which is safe for, and prevents violence against children and programme participants; and
13. All PIA Participants, who have reported child safeguarding concerns or are alleged to have harmed a child or a programme participant are given appropriate care, support and protection in dealing with all aspects of the case including any safety concerns and potential reprisals which may arise from the incident or from the reporting of such concerns.
Executive Leadership Team will ensure that:
14. They provide visible and committed leadership to drive a culture that is dedicated to promoting gender responsive intersectional safeguarding and the enabling environment required for safe reporting.
15. PIA implements the PIA Policy, Procedures and Safeguarding Implementation Standards as they apply to our context, people (PIA representatives), children and young people with whom we engage, as well as the processes, programmes, projects, events and activities we undertake.
16. The Executive Leadership Team reviews all organisational safeguarding risks and incidents on a regular basis.
PIA’s Board will ensure that:
17. Ensuring the Executive Leadership Team is held accountable for driving a safe organisational culture, which promotes understanding of gender and intersectionality.
18. Demonstrating leadership on safeguarding issues through decision-making by the Board (collectively and individually). This includes ensuring that Board members are themselves held to account if they engage in breaches of this policy.
19. Ensuring that safeguarding is a regular item on the Board’s agenda, and that the Executive Leadership Team reports to the Board on the implementation of this policy including incidents/reports, to sufficiently enable the Board to monitor organisational safeguarding risks and measure the success of safeguarding initiatives.
20. Ensuring diversity of the Board and Executive Leadership Team.
Reporting
It is mandatory for all PIA representatives to confidentially report all concerns, suspicions or allegations of harm to a child or programme participant and/or breaches of this policy and/or Code of Conduct immediately (latest within 24 hours). If you are a PIA employee/representative and you witness/suspect that a Plan International staff, associate or visitor is breaching PIA/Pl Safeguarding Policy, you must also report your concerns even if they do not come under this policy. Such instances are to be reported to the relevant Plan Country Office and/or PI Global Hub through designated channels for management. If a PIA representative is unsure how to report a safeguarding concern involving a Plan International employee, associate or visitor, they must notify PIA through the channels listed below for advice and support to make a report.
Community members or any other external person are also encouraged to immediately notify PIA of any concerns, suspicions or allegations or instances of harm and abuse against themselves or someone they know perpetrated by anyone associated with Plan International Australia.
Reports or notifications can be made through the following channels:
| For PIA representatives | For community members |
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PIA will take all reports of safeguarding concerns seriously and will respond to them as a matter of priority and in accordance with PIA Safeguarding Procedures and Plan International’s global guidelines for case management and investigations. Where investigations are deemed necessary, they will be carried out by appropriately experienced and qualified professionals who are trained on sensitive investigations and a victim/survivor centred approach.
If the report constitutes a criminal offence, this will be immediately reported to the relevant authorities, including the police and any statutory agencies. If the report pertains to a donor funded project (e.g, DFAT-Department of Foreign Affairs & Trade), it will be immediately reported to the donor in line with PIA’s contractual obligations.
Deidentified incident reports will be provided to the CEO, COO and the Associate Director of Organisational Development and Culture. The Executive Leadership Team, Risk and Assurance Team and the Board will also receive regular deidentified reports on safeguarding incidents (at least once in a quarter).
Complaint/Concern Handling Process
| Who can report? | Anyone: Programme participants including children and young people, family or community members, PIA representatives, local partners |
| What should be reported? | Allegations, suspicions, concerns of breaches of this Safeguarding Policy |
| When should it be reported? | Immediately or latest within 24 hours, ensuring the safety of the victim first and foremost |
| Who acts on the report? | PIA Safeguarding Delegate in collaboration with the relevant PIA Executive Leader |
| What will happen? |
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| Possible outcomes |
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Sanctions
Breaches of this policy will be investigated in accordance with disciplinary procedures and contractual agreements, or a referral may be made to statutory authorities for criminal investigation. Breaches may incur sanctions including disciplinary action leading to possible dismissal, termination of all relations including contractual and partnership agreements, and where relevant, appropriate legal or other such actions.
If a legitimate concern about the suspected abuse of a child or programme participant is raised but proves to be unfounded on investigation, no action will be taken against the reporter. However, appropriate sanctions will be applied in cases of false and malicious accusations.
Review of Policy
This policy will be reviewed every three years. The Safeguarding Delegate will manage the review in consultation with all relevant stakeholders. The policy review will be approved by the Executive Leadership Team and the Board.
Implementation and Monitoring of Policy
PIA Risk Assurance Team will monitor the implementation of this policy on an annual basis and provide a report to the Chief Executive Officer (CEO) and the Board. The CEO in collaboration with the Board is responsible for ensuring the implementation and monitoring of this policy.
Policy implementation documents:
The following documents are referred to and are to be used when implementing this policy:
- Plan International Australia Safeguarding Procedures (available upon request)
- Plan International Global Child Protection Standards and Implementation Manual (PDF)
- Plan International Australia Whistle Blowers Policy
References
- Plan International 2017: Global Policy Safeguarding Children and Young People
- ACFID Code of Conduct
- DFAT Child Protection Policy 2017
- Intersectionality and Safeguarding for Civil Society Organisations working in Humanitarian or Development Settings, Safeguardingsupporthub.org (2021) (PDF)
- National Principles for Child Safe Organisations, Australian Human Rights Commission 2018 (PDF)
- Child Safe Standards, Commission for Children and Young People, Victoria (2022)