Give Freedom International Child Protection Policy and Code of Conduct

Give Freedom International acknowledges they share a common commitment to prevent and protect children from exploitation and abuse. Give Freedom International stands by a policy to have zero tolerance towards child exploitation and/or abuse.

(1) Scope of this policy

This policy extends to all Give Freedom International staff, board members, volunteers, contractors and funded partners (such as NGOs) including any of their contractors, sub-contractors, consultants, advisors or any individual or organisations affiliated with the above listed organisations or funded partners. The Give Freedom International Child Protection Policy seeks to uphold these principles and includes expectations of Give Freedom International staff and funded partners.

(2) Reports and notifications

Child exploitation and abuse is not tolerated by Give Freedom International and attracts criminal penalties under Australian legislation. All partners funded by Give Freedom International are expected to act in accordance with Give Freedom International’s Child Protection Policy and Code of Conduct, and abide by their own relevant policies, international declarations, conventions, agreements and domestic legal frameworks, which seek to protect children.

If you have been abused or have any concerns relating to the abuse or exploitation of children within your community or if you or a child is in immediate danger, contact your local police.

3) General enquiries

All Give Freedom International enquiries can be made at:

Phone: 1300 081 190

Email: info@givefreedom.org.au

Web: givefreedom.org.au

Child Protection Policy—Introduction

Give Freedom International is committed to preventing and protecting child and/or vulnerable persons from exploitation and abuse. Give Freedom International’s Child Protection and Privacy Policy (referred to as ‘the Policy’) has a zero-tolerance stance against child and/or vulnerable person exploitation and abuse. Give Freedom International Child Protection Policy seeks to uphold these principles and includes expectations of Give Freedom International staff, board members, funded partners and broader contractors (see Policy Scope).

(4) Policy Scope

The Give Freedom International Child Protection Policy extends to all Give Freedom International Staff and Partners.

(5) Definitions

For the purposes of this Policy:

“Partners” includes:

Contractors and any of their personnel, sub-contractors, consultants, advisors or any affiliated individuals or organisations; or
Funded or non-funded partners (such as NGOs) including any of their personnel, contractors, sub-contractors, consultants, advisors or any affiliated individuals or organisations.

“Staff” includes:

Give Freedom International staff or personnel;
Give Freedom International board members; or
Give Freedom International volunteers.

“Vulnerable Person/s” means:

A Child or Children; or
An individual aged 18 years and above who is or may be unable to take care of themselves; or
An individual aged 18 years and above who is unable to protect themselves against harm or exploitation by reason of age, illness, trauma or disability, or any other reason.

(6) Policy Principles

(6.1) Principle 1—Zero Tolerance

Give Freedom International takes a zero-tolerance stance against child and/or vulnerable person exploitation and abuse. Give Freedom International functions to minimise the risks of child exploitation and abuse associated with its functions and expects its partners to adhere to the same obligations under this Policy (see ‘Reporting’). Give Freedom International will not knowingly engage—directly or indirectly—anyone who poses a risk to children and/or vulnerable persons. Child exploitation and abuse will attract criminal, civil and disciplinary sanctions. Those involved with Give Freedom International are responsible to report all incidences of child and/or vulnerable person exploitation or abuse.

(6.2) Principle 2—A Shared Commitment

Give Freedom International believes that protecting children and/or vulnerable persons from exploitation and abuse is a shared responsibility extending to their partners (see ‘Policy Scope’) and the broader local and international community from which it operates.

(6.3) Principle 3—Best Interests of the Child

Give Freedom International is committed to upholding the rights of the child and/or vulnerable person and Australia’s obligations as a signatory to the United Nations Convention on the Rights of the Child. As a primary consideration, all actions concerning children must be in the best interests of the child and/or vulnerable person.

(6.4) Principle 4—Seek to Identify, Mitigate, Manage or Reduce

Give Freedom International acknowledges that while it is not possible to eliminate all risks of child and/or vulnerable person exploitation and abuse, with careful management they can seek to identify, mitigate, manage or reduce such risks as part of their functions.

(6.5) Principle 5—Procedural Fairness

Give Freedom International is required to act in accordance with Australia’s child protection obligations under local and international laws, conventions or any other obligations and where possible, including ensuring individuals are afforded procedural fairness.

(7) Policy Responsibilities

(7.1) Give Freedom International Staff Responsibilities

Give Freedom International Staff must ensure and manage child protection risk. All Staff are required to sign the Give Freedom International Code of Conduct.

In addition to this:

Board members and personnel employed by Give Freedom International have a current Criminal Record Check.
Individual Volunteers in contact or engaged with children and/or vulnerable persons on behalf of Give Freedom International as a minimum will be required to:
Have a current Volunteer Working with Children check (if living in Australia). For those living outside Australia, have a current Criminal Record Check.
Undertake appropriate child protection training as outlined by Give Freedom International.

Give Freedom International is responsible for:

Identifying child protection obligations of their Staff and Partners.
Document and undertake risk assessments to ensure clear and transparent reporting.
Review policies where necessary.
Identifying child protection risks that might arise in circumstances involving their Staff and Partners (such as contractors) and ensuring their contractual agreements and obligations minimise child protection risks (see Give Freedom International Partner Responsibilities).

(7.2) Give Freedom International Partner Responsibilities

All Give Freedom International Partners are expected to act in accordance with this Policy (see Policy Scope). This includes in situations where there is contact with children and when there is no contact with children.

(7.2.1) Minimum standards identified as involving “contact with children and/or vulnerable person(s)”

Give Freedom International requires Partners:

Have a child protection policy in place.
Recruit and train personnel appropriately. As a minimum make personnel aware of the organisations child protection policy, undertake appropriate criminal checks and train employees.
Develop a documentation plan to ensure downstream Give Freedom International funded partners (i.e. sub-contractors) meet minimum standards.
Undertake initial risk assessments of the organisation and activities and have clear and transparent internal reporting mechanism or procedure for their personnel to report concerns. Including a requirement that all suspected or alleged instances of child abuse, exploitation, harm or child protection policy non-compliance is reported internally to their organisation and Give Freedom International, and to local law enforcement authorities.
Be committed to affording personnel with procedural fairness and fair working conditions when responding to allegations, investigations and applicable disciplinary actions.

(7.2.2) Minimum standards identified as involving “NO contact or impact on children and/or vulnerable person(s)”

Partners are generally not required to implement the minimum standards set out in (7.2.1)
However, any Partner that is child-focussed is required to meet the minimum standards set out in (7.2.1) irrespective of whether Give Freedom International funds their activities or they are identified as working or in contact with children and/or vulnerable persons.

(8) Management of the Policy

Give Freedom International will make sure they:

Effectively implement the Policy.
Undertake regular reviews of the Policy.
Report all child exploitation and abuse, policy non-compliance and code of conduct breaches are responded to by Give Freedom International.
Monitor partner investigations and ensure child protection policies exist for their funded partners, including undertaking through audits and spot checks.

(8.1) Supporting Implementation Documents

The following documents aid in supporting the implementation of the Policy:

Give Freedom International Conduct of Conduct
Give Freedom International Digital/Social Media Policy

(9) Reporting

It is mandatory for staff, board members and partners to immediately report any suspected or alleged case of child and/or vulnerable person exploitation, abuse or policy non-compliance by anyone within scope of the policy in connection with official duties or business. Members of the community can also report. All reports should be made to:

Phone: 1300 081 190

Email: info@givefreedom.org.au

(9.1) What to Report

Child and/or vulnerable person exploitation and abuse is not tolerated by Give Freedom International and attracts criminal penalties under Australian legislation. All partners funded by Give Freedom International are expected to act in accordance with Give Freedom International’s Code of Conduct and those principles outlined in this document, and abide by their own relevant policies, international declarations, conventions, agreements and domestic legal frameworks, which seek to protect children.

Staff and Partners must report any behaviour that is suspected of being child and/or vulnerable person exploitation or abuse (including possession of child exploitation material) or policy non-compliance by:

Give Freedom International Staff or Give Freedom International Partners
Personnel of a Give Freedom International funded contractor or civil society organisation, including subcontractors
A Give Freedom International funded volunteer
An employee of a Commonwealth Government Agency
Any report made to you by anyone relating to child exploitation and abuse or policy non-compliance by a Give Freedom International staff or Give Freedom International funded or non-funded partner
Any Australian citizen, Australian permanent resident or Australian company.

Where an individual or organisation has already reported, but becomes aware of additional information, the individual or organisation must also report that information.

Child Protection Code of Conduct—Introduction

(9.2) Aims

The aim of Give Freedom International is to create a safe culture for children and/or vulnerable persons, it’s Staff and Partners. The Give Freedom International Code of Conduct (“Code”) outlines the expected behaviour and practices necessary to achieve this so that children and/or vulnerable persons can enjoy a safe community. We invite our Staff and Partners to commit to this behaviour and practices by reading and signing this document.

(9.3) Scope

This Code applies to all Give Freedom International Staff and Partners, particularly if you are:

Employed to work at Give Freedom International either directly or indirectly or for an affiliated entity or Partner, where you will work with children and vulnerable persons.
A member of a decision-making body that provides oversight of the services for children or vulnerable persons for Give Freedom International or an affiliated entity or Partner.
Working in child related roles for Give Freedom International or for an affiliated entity or Partner.
Partners of Give Freedom International must use or embed this Code and any other Give Freedom International related Policies into their existing policies and processes.

(10) Definitions

“Partners” includes:

Contractors and any of their personnel, sub-contractors, consultants, advisors or any affiliated individuals or organisations; or
Funded or non-funded partners (such as NGOs) including any of their personnel, contractors, sub-contractors, consultants, advisors or any affiliated individuals or organisations.

“Staff” includes:

Give Freedom International staff or personnel;
Give Freedom International board members; or
Give Freedom International volunteers.

“Vulnerable Person/s” means:

A Child or Children; or
An individual aged 18 years and above who is or may be unable to take care of themselves; or
An individual aged 18 years and above who is unable to protect themselves against harm or exploitation by reason of age, illness, trauma or disability, or any other reason.

(11) Why is this Important?

(11.1) For Staff and Partners

It provides Give Freedom International Staff and Partners with a clear outline of appropriate conduct so you:

can be sure of what conduct is expected;
can adjust your conduct if needed;
can identify areas for improvement;
can ensure your conduct supports a safe environment.

(11.2) For Members of the Community

The Code provides assurance to the members of the community generally and particularly parents and guardians of children and/or vulnerable persons.

(11.3) For Leaders of the Community

The leadership of Give Freedom International and Partners have a duty to protect children and/or vulnerable persons including within that community. This value is also a high priority within the wider community as evident by child protection legislation and an organisation’s duty of care.

The Code provides Give Freedom International’s leadership team with comfort that those working in the team have committed themselves to contributing, in their conduct, to an environment that is safe for all. If there are people who don’t meet this standard of conduct, the Code also assists the leaders to identify them and pinpoint how to support and manage risks, so that child and/or vulnerable person’s safety remains a top priority.

(12) Minimum Behaviour Requirements

(12.1) Minimum Behaviour for Staff and Partners

Give Freedom International Staff and Partners undertaking business on behalf of Give Freedom International involving contacting or working with children and/or vulnerable persons are expected to adhere to the following behaviour while they are performing these duties:

Treat all children and vulnerable persons with respect.
Not use language or behaviour towards children and/or vulnerable persons that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate.
Not engage children and/or vulnerable persons under the age of 18 in any form of sexual intercourse or sexual activity, including paying for sexual services.
Wherever possible, ensure that another adult is present when working near children and/or vulnerable persons.
Not invite unaccompanied children and/or vulnerable persons into private residences, unless they are at immediate risk of injury or in physical danger.
Not sleep close to unsupervised children unless necessary, in which case the supervisor’s permission must be obtained, and ensure that another adult is present if possible (noting that this does not apply to an individual’s own children).
Never use any computers, mobile phones, video cameras, cameras or social media to exploit or harass children and/or vulnerable persons, or access child and/or vulnerable persons exploitation material through any medium.
Not use physical punishment on children and/or vulnerable persons.
Not hire children and/or vulnerable persons for domestic or other labour which:

is inappropriate given their age or developmental stage;
interferes with their time available for education and recreational activities; or
places them at significant risk of injury.

Comply with all relevant Australian and local legislation (country or jurisdiction specific), including labour laws in relation to child labour.
Immediately report concerns or allegations of child and/or vulnerable persons exploitation and abuse and policy non-compliance in accordance with appropriate procedures.
Immediately disclose all charges, convictions and other outcomes of an offence that relates to child and/or vulnerable persons exploitation and abuse, including those under traditional law, which occurred before or occurs during association with Give Freedom International.
Be aware of behaviour and avoid actions or behaviours that could be perceived by others as child and/or vulnerable persons exploitation and/or abuse.

These behaviours are not intended to interfere with normal family interactions.

(12.2) Photographing or filming

When photographing or filming a child or using children’s (and/or vulnerable persons) images for work-related purposes:

Take care to ensure local traditions or restrictions for reproducing personal images are adhered to before photographing or filming a child and/or vulnerable persons.
Obtain informed consent from the child and parent or guardian of the child before photographing or filming a child. An explanation of how the photograph or film will be used must be provided. This also applies to vulnerable persons.
Ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children and/or vulnerable persons should be adequately clothed and not in poses that might be viewed as sexually suggestive.
Ensure images are honest representations of the context and the facts.
Ensure file labels, meta data or text descriptions do not reveal identifying information about a child when sending images electronically or publishing images in any form.

(13) Code of Conduct Breaches

Breaches of the Code of Conduct will be handled like any other complaints brought to the attention of Give Freedom International or their affiliates and Partners, which is informed by best practice approaches to addressing child and vulnerable person protection allegations.

Alleged criminal conduct will be reported to authorities.
Alleged breaches will be investigated and if sustained may result in:

Give Freedom International disciplinary action and / or
further training and/or
closer supervision and/or
being required to sign or resign the code of conduct and/or
no longer be able to work with children on behalf of Give Freedom International.

Serious alleged breaches will be reported to local law enforcement.

(13.1) How will Code of Conduct breaches be handled?

The following principles will be used in handling an alleged breach:

The breach will be considered as an allegation that needs investigation.
The alleged breach will be kept confidential in accordance with governing Privacy Laws of that country, and where deemed necessary Australian Privacy laws.
The person subject to the allegation will be told the details of the allegation, given some time to prepare a response and be given an opportunity to give a response all before a decision is made.
The person subject to the allegation MUST be removed immediately from any and all duties involving contact with children until the matter has been completely investigated.
In handling alleged poor conduct Give Freedom International is committed to balance the following competing needs:

The needs of the complainant to be heard and for confidentiality, justice, restitution and closure.
The needs of the wider community for the prosecution of the investigation to deliver a finding and for the timely implementation of the recommendations from the investigation.
The needs of the person subject of the allegation for procedural fairness, confidentiality and closure.