AfHEA’S Safeguarding: 

Protection from Sexual Exploitation, Abuse and Harassment (SEAH) Policy

Revised: July, 2025

1.0 Purpose and Scope of this Policy

1.1. Purpose 

The purpose of this Safeguarding Policy is to offer clarity to all on how they should interact with children and vulnerable adults when working for, on behalf, or in partnership with AfHEA. This is to ensure that children and vulnerable adults are protected and at the same time AfHEA’s employees are also protected. 

This policy highlights AfHEA’s commitments as well as the responsibilities of AfHEA’s employees and related personnel as far as safeguarding and harassment is concerned. 

AfHEA’s employees refer to: AfHEA’s staff based in the Accra office (whether on full-time or part-time employment), AfHEA’s staff located outside the Accra office, volunteers and consultants.  

AfHEA’s related personnel refer to but is not limited to: AfHEA’s Board members, other members of the Executive Committee not based in the Accra office, event organizers hired during conferences/training workshops, Scientific committee members, conference planning committee members, finance and fundraising committee members, and communications, media and marketing committee members. 

1.2. Scope 

This policy is applicable to all AfHEA employees and related personnel (as defined above) irrespective of their location. 

The policy is a demonstration of AfHEA’s commitment to meet its legal obligation and reassure its employees, related personnel, partners and members of the public on:

• Their expectations of AfHEA to protect and safeguard children and vulnerable adults.
• The existence of an established procedure through which they can safely raise any safeguarding concerns without victimization. 
• That AfHEA will effectively deal with all reports of abuse or potential abuse. 
• The existence of an efficient safeguarding monitoring system.
• That all AfHEA’s employees and related personnel will receive appropriate induction on safeguarding.

2.0 Key Terms and Definitions

3.0 Policy Statement 

AfHEA takes a zero-tolerance approach to the sexual exploitation and abuse of children and adults especially vulnerable adults and does not allow any partner, supplier, sub-contractor, agent or individual involved with AfHEA to engage in any form of sexual abuse or exploitation against vulnerable or other adults associated with its work.

AfHEA believes that every person has the right to be protected from all forms of abuse and exploitation, regardless of their age, gender, religion, race, ethnicity, nationality, disability status, marital status, sexual orientation and any other identity-related status. 

AfHEA also recognizes that everyone has a responsibility towards safeguarding and that it is obligated to institute reasonable measures to uphold the safety and wellbeing of children and adults with whom we encounter in the execution of our work. 

Sexual Activity with Children and Vulnerable Adults

AfHEA prohibits any kind of sexual activity with children. Mistaken belief in the age of the child is not to be used as an excuse. AfHEA prohibits any kind of sexual activity involving adults associated with its work. 

Exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour is prohibited. This includes exchange of assistance in the course of AfHEA’s business. 

Any sexual relationship between parties involved in AfHEA’s business that involves improper use of rank or position is prohibited. Such relationships undermine the credibility and integrity of AfHEA.

Where an AfHEA employee or other related personnel develop concerns or suspicions regarding sexual abuse or exploitation by a fellow worker, he or she must report such concerns via established reporting mechanisms.

AfHEA employees and other related personnel are obliged to create and maintain an environment which prevents sexual exploitation and abuse and promotes the implementation of their code of conduct. Managers at all levels have particular responsibilities to support and develop systems which maintain this environment

Child Marriage

Any AfHEA employee, Volunteer, or Consultant who engages in child marriage will be in violation of AfHEA’s safeguarding policy. A child under the age of 18 is not able to give or withhold consent and thus marriage to a child is considered a form of sexual violence. Any staff married to a child under the age of 18 as per the custom or law of their country, prior to engaging with AfHEA will not be subject to disciplinary action, but this fact will be taken into consideration prior to engagement.

Sexual Exploitation

Sexual activity with any beneficiary is prohibited due to inherently unequal power imbalances.  This is a form of exploitation.  An AfHEA beneficiary (e.g., Mentor -mentee relationship) is defined as anyone who receives services or support from AfHEA or an AfHEA partner.  AfHEA prohibits employees, consultants, volunteers and other related personnel from buying sex.  Prohibited behavior includes any exchange of money, material assistance, employment, goods or services for sex, including sexual favors for job opportunities, or other forms of humiliation or degradation.

Sexual Harassment

Any act of sexual harassment in the form of unwelcome sexual advances, requests for sexual favors, and other conduct that creates a coercive, hostile, intimidating, or offensive work environment is prohibited. Behavior that is uninvited, unreciprocated or unwelcomed can cause the person involved to feel threatened, humiliated or embarrassed. 

Sexual Violence 

Acts involving sexual violence is prohibited. This includes, but is not limited to:

• Unwanted sexual comments or advances or acts against a person’s sexuality using coercion by anyone, regardless of their relationship to the victim, in any setting, including at home and at work.
• Sexual violence involving intercourse (i.e., rape),
• Contact sexual violence (i.e., unwanted touching, but excluding intercourse) and 
• Noncontact sexual violence (i.e., threatened sexual violence, exhibitionism and verbal sexual harassment).

4.0 Responsibilities 

All employees and related personnel of AfHEA are obliged to adhere to this policy and maintain an environment that is free of exploitation and abuse and which encourages reporting if this policy is breached following the laid-down procedures. 

All AfHEA employees and related personnel will:

• Read, understand and uphold AfHEA’S Safeguarding Policy.
• Promote a zero-tolerance approach to exploitation, abuse, and discrimination in all areas of work. 
• Prioritize the safety and wellbeing of children and adults (including neglect) before other considerations. 
• Report any issue that may arise that is likely to violate the wellbeing of a child or a adult (including neglect). 
• Report any untoward behavior of an AfHEA representative in relation to safeguarding. 
• Inform the parent or guardian of a child or young person in situations that call for one-to-one interactions with a child or young person and ensure that another adult is present and knows the purpose of the interactions. 

All AfHEA employees and related personnel will not:

• Sexually assault, harass or violate another person.
• Physically assault, harass or violate another person. 
• Emotionally assault, harass or violate abuse person.
• Engage in discriminatory, illegal, unsafe or abusive behavior. 
• Keep a secret with a child or young person that would negatively impact on their safety and wellbeing. 

Managers at all levels will ensure that:

• All employees and related personnel are aware of this policy and are supported to implement it in their work. 
• They respond to and act immediately a safeguarding concern is raised.
• They support employees and related personnel who communicate any breach of this policy.  

Designated Safeguarding Officer (DSO) will ensure that:

• All safeguarding concerns and reports are handled effectively.
• All staff are trained in safeguarding policy. 
• All referrals to relevant authorities are addressed in a timely manner. 
• This policy is reviewed every 3 years or as necessary. 
• This policy is implemented by all employees and related personnel. 
• Procedures for monitoring and reporting safeguarding concerns are implemented. 

The Board of Trustees will:

• Provide oversight over the implementation of the Safeguarding Policy. 

5.0 Safeguarding Procedures

The following processes help to ensure that everyone follows AfHEA’s Safeguarding Policy.   

5.1. Raising and reporting safeguarding concerns

• AfHEA will ensure that concerned parties have safe, appropriate and accessible channels of reporting or raising safeguarding issues by employees, related personnel and the communities we work with: 
  • Safeguarding concerns can be made formally through our official email addresses and phone numbers or verbally to a trusted individual

Afhea08@gmail.com or safeguarding@afhea.org 

Office Phone: (233) 030 279 7109 / (233) 054 734 7035 

Safeguarding Officer Private Line: +(233) 054 510 7100

• Any individual raising a safeguarding concern will be protected through AfHEA’s Whistleblower Policy.  Please refer to AfHEA’s Human Resources Management Policy & Manual for those procedures.
• All safeguarding concerns should be reported to the designated safeguarding officer. 
• In the event that the designated safeguarding officer is implicated in the safeguarding concern, the issue can be raised directly with the Executive Director or any member of the Board of Trustees. 

5.2. Responding to safeguarding concerns 

The designated safeguarding officer or appointed decision maker will:

• Reach out to the relevant party(s) to get their perspective and recommendations.
• Maintain strict confidentiality of all sensitive and personal data connected with the safeguarding issue, including the names of the person(s) who made the report as much as is possible.  
  • In some instances, in order to properly investigate a case, it may be necessary to share a certain amount of detail. Sharing of information of the case will be on a “need to know” basis and in all circumstances, the victim of the safeguarding incident will be notified in advance should details need to be shared.  
• Refer the concern to the DSO in the event that an AfHEA employee is the subject of the concern and to the Executive Director in the event that the DSO is involved. In this case, the AfHEA employee/DSO will themselves be notified prior to involving the Executive Director.  
• Ensure that AfHEA offers support to the victims of abuse or exploitation perpetrated by its employees or related personnel. 
• If necessary, call upon a third party to investigate the matter raised.  This may include legal authorities in severe cases.  

5.3 Retaliation

AfHEA maintains a zero-tolerance policy for retaliation against anyone for reporting sexual exploitation, abuse or harrasment, assisting in making a complaint, or participating in an investigation.

Any employee, consultant, volunteer or partner who makes a good-faith complaint of sexual exploitation or abuse, assists, testifies, or participates in any investigation or proceeding or who reasonably opposes such conduct in the workplace will not be adversely affected in the terms and conditions of his or her employment or contract, and will not be discriminated against or discharged for engaging in such activity. Some examples of retaliation include but are not limited to the following:

• Termination, demotion, disadvantageous transfers or assignments, refusals to promote, threats, reprimands, or negative evaluations.
• Co-worker hostility or retaliatory harassment, which includes intimidation, gossip, rumors, insults, or otherwise offensive conduct that would subject a person to ridicule or humiliation.
• Any action or combination of actions that is reasonably likely to affect an employee’s job performance or opportunity materially and adversely for advancement

The designated Safeguarding Officer will promptly investigate any suspicion or accusation of retaliation. If the Safeguarding Officer determines that retaliation occurred, appropriate disciplinary action, including possible dismissal of the perpetrator, will be taken.

6.0 Safeguarding in Practice

Safeguarding at AfHEA means proactively creating and maintaining an environment that prevents harm, exploitation, abuse, or harassment to anyone we work with, regardless of whether they are employees, contractors, partners, or other third-party individuals. Safeguarding in practice includes the responsibility to:

• Be alert to potential risks of sexual exploitation, abuse, and harassment (SEAH), including power imbalances.
• Ensure all staff, consultants, vendors, and affiliates know their rights and how to report concerns.
• Respond promptly, appropriately, and confidentially to safeguarding concerns, regardless of the source.
• Report any actual, suspected, or potential safeguarding concerns using the channels outlined in the AfHEA Safeguarding Policy.

All safeguarding incidents must be reported to the Designated Safeguarding Officer (DSO), whether or not they directly involve AfHEA employees. AfHEA’s responsibility includes responding to third-party or independent party complaints if they intersect with our operations or stakeholders.

Reporting to local authorities: Serious safeguarding incidents, particularly those involving credible evidence of sexual violence, child abuse, trafficking, radicalization, or threats of physical harm, must be reported to appropriate local authorities (Police, Social Welfare, or Social Services). This is especially crucial if the incident indicates immediate danger or criminal activity. Illustrative scenarios: 

Scenario 1: Consultant-based example 

During a capacity-strengthening workshop facilitated by AfHEA, an independent consultant reports to a staff member that a government stakeholder, who is also a participant, has been making inappropriate advances through text messages in exchange for future collaboration. The consultant provides screenshots as evidence.

Safeguarding Response:

• The staff member must thank the consultant for sharing the concern and refer them to the Designated Safeguarding Officer (DSO).
• The staff member must make a dated, factual record of the report and forward it to the DSO via official reporting channels.
• The DSO assesses the evidence, investigates appropriately, and initiates safeguarding procedures, including possible removal of the accused from the event.
• If the behavior is deemed criminal or harmful, the case is referred to local authorities.
• AfHEA ensures follow-up with the consultant, maintains confidentiality, and documents all steps.

6.2 Scenario 2: Employee-based example 

A junior staff member at AfHEA confides in their line manager that they have been receiving sexually inappropriate jokes and comments from a senior colleague. The staff member is fearful of retaliation and requests anonymity.

Safeguarding Response:

• The line manager must acknowledge the courage it took to report and reassure the staff member.
• The manager must report the issue to the DSO, even if anonymity is requested.
• The DSO conducts a confidential investigation which involves a fair hearing of both sides, separating the complainant from the accused, and initiates protective measures.
• If the allegation is confirmed, disciplinary action is taken in line with HR policy.
• Where criminal behavior is evident, local authorities are notified.
• The DSO continues regular check-ins with the complainant to ensure well-being and safety.

6.3 Scenario 3 – Independent party based safeguarding concerns

Independent or third party safeguarding issues may arise that can affect AfHEA. This is the case where an individual unrelated to AfHEA directly (a vendor, client, independent contractor, staff of another company or even an outsider) brings a safeguarding concern (in which AfHEA is remotely related) to the attention of a staff or the Designated Safeguarding Officer (DSO). For instance, where an independent contractor shows an AfHEA staff a series of emails or text messages sent by one of AfHEA’s clients that are sexually suggestive, explicit or coercive in nature in exchange for payment on a deliverable. 

Safeguarding Response:

While such conduct is not by a direct AfHEA employee, it is still AfHEA’s duty to work to prevent such a safeguarding issue, or else AfHEA may be held liable. In such a case, it is the duty of the staff of AfHEA or DSO to:

• Understand thoroughly AfHEA’s guidance and reporting arrangements as stipulated under Raising and reporting concerns of the AfHEA Safeguarding Policy (ASP). 

• Understand AfHEA’s scope for the inclusion of independent party complaints (that is, as explained, complaints from individuals who are not directly employed by AfHEA but still interface with either AfHEA’s clients, vendors or suppliers).
  • Kindly note that in addition to the examples of all forms of abuse and exploitation stipulated under Section 3, ‘Policy Statement’ of the ASP, any harm related to neglect, health risks, financial exploitation, discrimination, physical or cyber bullying, grooming or radicalization should be treated as priority and considered as ample grounds for taking action.
• Inform the independent party of the need to escalate the complaint through to the Designated Safeguarding Officer or the Official Reporting portal (email or phone) and reassure the said party of their protection.
  • For staff the duty will then be to PROMPTLY inform via official means (typically a detailed and dated written record of observations) regarding the complaint on behalf of the independent party (and to report any personal suspicions as well), whereas for the Designated Safeguarding Officer it will be to additionally investigate the claim and offer policy-appropriate advice.  
  • Complaints on behalf of independent parties should be devoid of personal bias and opinions and should represent a factual account of the safeguarding issue since this would likely form a key document should legal action be taken. 
• Follow-up at regular intervals on complaint filed to ensure accountability and avoid stale or dead-end investigations
• Based on policy-appropriate advice, follow up on action to be taken, which may vary and involve referral to the appropriate local authorities such as the Police or Social Services if there is a serious case of harm or intention to harm with evidence.