Organizational Commitment and Compliance
JSI and World Education, Inc. (JSI/WEI) is committed to keeping children safe. To do so, we have a zero-tolerance policy for any form of abuse, exploitation, or violence. We take every measure to prevent such incidents and to ensure compliance with U.S., host-country, and international child welfare and protection laws and standards.
JSI/WEI will investigate, act upon, and report suspected safeguarding violations in accordance with the provisions of this policy and JSI/WEI’s policies for investigating ethics and fraud violations.
Goals of Child Safeguarding Policy
JSI/WEI often implements programs designed to benefit children and their families. These programs frequently include activities that could raise the risk of child abuse, exploitation, and neglect. It is our responsibility to protect the children we come in contact with from such harm.
JSI/WEI embraces the principles within the UN Convention on the Rights of the Child as its minimum standards of protection for children reached by its programs. The personal conduct of those engaged in work for JSI/WEI—either as direct staff, consultants, volunteers, or as staff of our partners, contractors, vendors, and subrecipients—will be measured against this policy.
JSI/WEI has developed this policy to comply with funders’ child safeguarding requirements, including DFID standards, AIDAR 752.7037 (August 2016), and the USAID Child Safeguarding Mandatory Standard Provision. These standards, clauses, and provisions apply to activities that may involve children and award implementation in which personnel may come into contact with children.
Ethical practices at JSI/WEI are guided by the principle that work and business relationships be conducted with the highest level of honesty, integrity, diligence, fairness, trust, and respect. JSI/WEI safeguarding principles include:
Equality: We will treat all children and adults equally with respect.
Responsibility: We are all responsible for protecting children in our work and daily life. We will demonstrate our commitment to safeguarding in all our interactions with children.
Accountability: We will hold ourselves and others accountable to our safeguarding policies and code of conduct.
Cooperation: We will work closely with government, funders, partner agencies, and beneficiaries to promote a safe environment for children.
Confidentiality: Confidentiality is fundamental to safeguarding, reporting, and investigation processes. We will maintain confidentiality during all stages of a safeguarding investigation, sharing information only on a need-to-know basis. Confidentiality breaches can have serious consequences for all involved in a safeguarding investigation and will result in disciplinary action.
Child-centered approach: In a child-centered approach, the child’s wishes, safety, and well-being are prioritized in all matters and procedures. Investigation and response processes will ensure sensitivity and accountability, avoid re-traumatizing children, maintain focus on the child, and ensure support to survivors.
Child awareness: We will ensure that children understand and are aware of child safeguarding and protection processes.
Children as participants in investigations: We will ensure that care is taken when children are involved in an investigation and that any investigative interview with a child be undertaken within best practice protocols (e.g., child-centered, child-paced, and conducted or guided by a suitably trained practitioner).
Responsiveness: We will ensure that reporting and investigating processes are conducted in a timely manner.
To whom does the Child Safeguarding Policy Apply?
The JSI/WEI Child Safeguarding Policy applies to everyone associated with JSI/WEI, including but not limited to:
- All full-time, part-time, and temporary staff
- Partner staff
- Volunteers and interns
- Subcontractors and sub-recipients
Designated Child Safeguarding Focal Person
Designated child safeguarding focal persons will be identified to support the coordination and implementation of JSI/WEI’s child safeguarding obligations across the organizations.
Child Safeguarding Standards of Behavior
These standards of behavior are expected of and apply to all JSI/WEI staff and associates. Employees, partners, consultants, subcontractors, subrecipients, interns, and volunteers are expected to understand the implications of this code on their language, behavior, actions, and relationships with children.
The JSI/WEI Child Safeguarding Standards of Behavior are applicable to the treatment of children with whom JSI/WEI staff and associates come into contact. Any breach or failure to comply with them will be taken seriously by JSI/WEI and will result in disciplinary action.
The list below is not prescriptive and should be applied in the spirit of providing the highest level of protection and duty of care to children.
When working with children YOU MUST NEVER:
- Hit or otherwise physically assault, harm, or abuse children.
- Engage in sexual activity or have a sexual relationship with anyone under the age of 18 years, regardless of the age of majority/consent or custom locally. Mistaken belief in the age of a child is not a defense.
- Develop relationships with children that could be in any way considered exploitative or abusive.
- Act in any way that may be abusive or place a child at risk of abuse.
- Use language with or behave toward a child in a way that is inappropriate, offensive, abusive, sexually provocative, demeaning, or culturally inappropriate.
- Have a child/children with whom we are working stay overnight at your home or other personal accommodation in which you are staying.
- Condone or participate in children’s behavior that is illegal, unsafe, or abusive.
- Act in ways intended to shame, humiliate, belittle, or degrade children.
- Ignore or fail to report allegations made or concerns expressed by others about children’s welfare.
- Use a computer or other electronic device to view, download, distribute, or create indecent or inappropriate images of children.
- Use children’s images or information without obtaining proper permission and consent.
- Use computers, social media, mobile phones, video, and digital cameras, or other electronic devices and mediums to exploit, harass or bully children.
Ensuring safe communication, including the use of Social Media, is critical in all areas of child safeguarding. JSI/WEI expects its staff to promote dignity and respect in all communications, and ensure that information and images of children will never be used in a way that lessens the child’s safety or dignity. Every effort should be made to ensure that confidentiality is maintained.
Informed consent for use of images and information
We are committed to portraying children respectfully and appropriately. Individuals representing JSI/WEI must adhere to the organization’s guidelines when capturing, storing, displaying, and publishing children’s images. Informed consent from the relevant caregiver and informed agreement from the child in question (according to age of understanding) must be secured before using any information about the child in external communications – written, audio, or visual. Consent must be evidenced on a consent form.
Information and communications technology
JSI/WEI prohibits the use of its computer systems and networks to exploit, harass, or bully children, or to access, create or distribute inappropriate images of them.
JSI/WEI takes preventive steps to reduce the risk of engaging a person who may be unsafe or unsuitable to work with, or be in contact with, children.
JSI/WEI has developed guidelines for recruitment to ensure we hire and engage with, the safest and most suitable staff, volunteers, and partners. Such people act in the best interests of children, protect children from all forms of abuse, and share JSI/WEI’s values. Lack of child-safe recruitment and screening procedures greatly increases the risk of engaging someone who may pose an unacceptable risk of harm (physical, sexual, or emotional) to children.
By promoting child-safe recruitment and screening procedures, JSI/WEI can attract the best people to work with children, and deter those who seek to join JSI/WEI because they want to harm children.
By implementing child-safe recruitment and screening procedures, JSI/WEI aims to create and maintain a child-safe environment, to keep all children safe in the delivery of programs.
For staff who will be working directly with children as part of the scope of their project, JSI/WEI conducts additional due diligence, including special behavior-based questions during interviews; where legal, completes criminal background checks following all applicable local laws; and/or requiring a special signed disclosure that a staff member has not been charged with child abuse or exploitation offenses.
All JSI/WEI job descriptions are required to include the following language:
“JSI/WEI is a child-safe organization, and the safety and wellbeing of children is a priority of our organization. We have robust recruitment procedures to ensure that all staff are suited to work with the children served by our programs.”
All staff are required to take the JSI and World Education Ethics training within 30 days of hire and annually thereafter. Note: the mandatory JSI/WEI Ethics training is being updated to include the Child Safeguarding Policy. In the interim, all staff will receive a supplemental training.
All staff will receive the appropriate level of safeguarding training, and designated child safeguarding focal persons will be trained to the level commensurate with their responsibilities. JSI/WEI’s safeguarding training will be reviewed regularly to ensure it is up-to-date and relevant.
JSI/WEI’s whistleblowing policy encourages people who become aware of wrongdoing in the organization to report their concerns immediately. All incidents are investigated fairly and confidentially. We are committed to non-retaliation against staff members who report possible or actual violation of this policy.
JSI/WEI treats malicious allegations with the utmost seriousness and takes appropriate disciplinary action.
Please refer to the whistleblower policy for more information.
Children rarely speak up when they feel unsafe or are being harmed, especially within organizational or institutional settings. While it is important to encourage children to speak up, JSI/WEI cannot rely on children to let JSI/WEI know if a staff member, volunteer, or consultant is harming them or makes them feel unsafe. It is not the child’s responsibility to disclose such information.
Any action to respond to or investigate a child safeguarding concern should be guided by what is in the best interest of the child and follow JSI/WEI’s standard ethics investigation process in relation to allegations.
Information about reporting violations of JSI/WEI’s Code of Conduct, as well as this child safeguarding policy, is available internally and externally (e.g., the JSI/WEI Code of Conduct Helpline at www.jsi.com and www.worlded.org). We provide several avenues and mechanisms for reporting concerns.
Everyone involved in program activities (ranging from employees to training participants) must be made aware of the JSI/WEI reporting helpline and how to report safeguarding concerns.
Any suspicion or allegation of a safeguarding violation by JSI/WEI staff, partners, contractors, vendors, or subrecipients must be reported within 24 hours to the JSI/WEI Code of Conduct Helpline. The reporter should then communicate the concern to the JSI/WEI Chief of Party/Project Director/Country Director (unless that person is implicated in the allegation). For US Offices, the report should be communicated to the Office Director.
Recognizing the special responsibility of protecting the privacy of a child and the confidentiality of the implicated person, JSI/WEI discourages communication about the details of child safeguarding concerns via e-mail unless absolutely necessary. If e-mail is necessary, subject headings should be vague and inoffensive, and must be flagged as confidential.
The JSI/WEI Chief of Party/Project Director/Country Director/Office Director should involve the designated safeguarding focal person in the incident response and management process. If a project does not have a safeguarding focal person, they should be in touch with HQ Human Resources.
Responding to children’s disclosures of abuse
Because child safeguarding violations involve a minor, JSI/WEI has developed the below additional guidance to ensure safety and appropriate sensitivity.
If information about child safeguarding violations is disclosed by a child, whether or not the complaint is made by the child survivor themselves, the process of reporting and managing the incident will require additional age-appropriate steps and considerations. JSI/WEI staff or partners must keep in mind the age of the child or young person and do the following when receiving disclosures made by a child:
- Listen to and support the child.
- Reassure the child that they did the right thing.
- Assess the risk of ongoing abuse.
- Take action to provide all possible help.
- Do not promise something you can’t deliver.
- Exercise caution and sensitivity in disclosing information (i.e., only to appropriate personnel).
- Contact the appropriate authorities.
Managing reported incidents
JSI/WEI will immediately initiate an investigation of any child safeguarding concern it becomes aware of. This investigation will follow our established policies and processes for all ethics/fraud incident reports. Additionally, for child safeguarding-related incidents, investigations will adhere to the following:
1. Persons reporting the incident and persons who have witnessed inappropriate conduct will be treated respectfully. Statements made by the complainant will be kept in appropriate confidentiality. The complainant will be:
- Interviewed to confirm all relevant facts.
- Given the opportunity to provide relevant facts.
- Given the opportunity to participate in the investigation by providing names/identities of other witnesses and recommending questions to be asked by investigators.
2. Information pertaining to incidents in which children’s rights have been violated should be shared on a ‘need to know’ basis, as deemed by the director of HR at JSI/WEI HQ in consultation with the Chief of Party/Project Director/Country Director, and, if involved, the designated child safeguarding focal person. For US Offices, the report should be communicated to the Office Director. In all instances, children’s names and identities must not be disclosed beyond the appropriate management personnel unless authorized.
3. As with all ethics/fraud violations we investigate, reports of child abuse must be treated seriously and impartially, and appropriate confidentiality maintained. However, JSI/WEI reserves the right to disclose information to other organizations or authorities involving employees terminated on the basis of child safeguarding violations. JSI/WEI complies with funder requirements for reporting such violations.
An employee who is dismissed as a result of misconduct with a child(ren) is not eligible for rehire. For U.S. government-funded projects, JSI/WEI reports all credible evidence of child abuse, exploitation, or neglect to the Federal awarding agency and/or the relevant Office of the Inspector General, which upon review of a case can recommend an implicated individual’s name for debarment.
Every project will be reviewed to determine the level of risk to children. Projects should consult the JSI/WEI Child Safeguarding Guidelines, which supplements this policy.
Monitoring and review
All projects that could potentially affect children must annually review their programs to ensure that the project scope has not changed to affect children. If, after the annual review, a project is determined to be higher risk, it must follow additional actions as described in the JSI/WEI Child Safeguarding Guidelines.
Sub-recipients, Subcontractors, Sub-grantees, Consultants, and Other Agents
JSI/WEI includes child safeguarding requirements in all contractual documents. At a minimum, JSI/WEI partners must:
- Comply with U.S., host country, and international child welfare and protection laws and standards.
- Comply with the JSI/WEI Child Safeguarding Standards of Behavior.
- Maintain procedures to prevent and punish child safeguarding violations.
- Immediately report to JSI/WEI any credible allegations of child abuse, exploitation, or neglect related to the contract.
Additionally, partners working on JSI/WEI projects or activities that involve children or that otherwise present an increased risk to children will be expected to comply with the principles and standards in our child safeguarding policy (or the partner’s equivalent policy). Contractual documents will also include funder-required safeguarding clauses including, as applicable, the USAID Child Safeguarding Mandatory Standard Provision and AIDAR 752.7037 Child Safeguarding Standards.
JSI/WEI will monitor and ensure partner compliance in a manner commensurate with the safeguarding risk posed by the activities or partner. JSI/WEI pre-award assessments will include a review of a partner’s ability to comply with safeguarding requirements and the inherent risk in the project activities that they will be conducting. Monitoring of higher-risk partners and activities will include as applicable compliance in regular reporting, evaluations, and site visits and appropriate safeguarding training of partner staff.
JSI/WEI’s zero-tolerance for any form of child abuse, exploitation, and neglect extends to the actions of its business partners and their employees. The consequences of a partner’s safeguarding violation are explicit and include termination of the contract, along with additional action as required (e.g., referral to appropriate authorities or funder). If JSI/WEI determines that a partner or a partner employee has committed a safeguarding violation, we will take appropriate action including, but not limited to:
- Requiring the party to remove an employee or agent from a project.
- Requiring the party to terminate its relationship with any other contractor, consultant, subcontractor, or sub-recipient found to be in violation.
- Suspending payments to the party until the violation is remedied.
- Immediately terminating the party’s agreement, grant, or contract.
- Excluding the party from further work and other opportunities with JSI.
- Reporting the violation to the funder and appropriate authorities.
All staff are required to sign a code of conduct that commits them to abide by JSI/WEI policies and procedures, including this policy and the standards of behavior included herein. this policy and the standards of behavior included herein. Each new employee is oriented to HR policies and procedures, including the code of conduct (which is part of the employee handbook).
JSI/WEI will ensure compliance with child safeguarding standards through the procedures described and referenced throughout this policy and attached appendices. All JSI/WEI operations are subject to this policy and it will be enforced across all JSI/WEI locations and activities. JSI/WEI will take appropriate action against JSI/WEI employees found to have violated this policy, up to and including termination and referral to local authorities.
Child: A person who has not attained age 18, regardless of the age of majority under local law.
Child safeguarding: The responsibility of organizations to make sure their staff, operations, and programs do not harm or expose children to abuse or exploitation.
Child abuse or maltreatment: Any form of physical (including sexual) abuse; emotional ill-treatment; neglect or insufficient supervision; trafficking; or commercial or transactional child labor; and other exploitation resulting in actual or potential harm to the child’s health, well-being, survival, development, or dignity. Abuse and maltreatment include but are not limited to any act or failure to act that results in death, serious physical or emotional harm, or that presents an imminent risk of serious harm to a child.
Physical abuse: Actual or potential physical harm of a child resulting from an interaction or lack of interaction that is reasonably within the control of a parent or other person in a position of responsibility, power, or trust in relation to the child.
Sexual abuse: The involvement of a child in sexual activities, whether or not the child is aware of what is happening or gives consent. Activities may involve physical contact, including penetrative (i.e., rape) or non-penetrative acts. They also include non-contact activities, such as involving children in looking at or the production of pornographic materials or watching sexual activities, or encouraging children to behave in sexually inappropriate ways.
Emotional abuse or ill treatment: Injury to the psychological capacity or emotional stability of the child caused by acts, threats of acts, or coercive tactics. Emotional abuse may include, but is not limited to: humiliation, control, isolation, withholding of information, and any other deliberate activity that makes the child feel diminished or embarrassed.
Exploitation: The abuse of a child that involves some form of remuneration or in which the perpetrators benefit in some manner. Exploitation represents a form of coercion and violence that is detrimental to the child’s physical or mental health, development, education, or wellbeing.
Neglect: The persistent failure to meet the child’s basic physical and / or psychological needs, likely to result in the serious impairment of the child’s physical or cognitive development. For example, inadequate care and supervision that leaves a child in a situation where s/he could be harmed (but only where this can be avoided).