Prevention of Sexual Exploitation, Abuse, and Harrasment (PSEAH) policy

1. Scope

This Policy applies globally to any of The HALO Trust’s (HALO) employees, partners, and other representatives, both during and outside of working hours. This includes the Trustees, senior managers, officers, other employees, consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with HALO, wherever they are located.

This Policy applies across all HALO operations, except where local legislation imposes more stringent requirements. In all other circumstances, HALO’s standards take precedence.

2. Internationally Agreed Standards

HALO is committed to implementing:

• Inter-Agency Standing Committee (“IASC”) Six Core Principles on PSEAH;

• IASC Minimum Operating Standards in PSEAH; and

• Core Humanitarian Standards on Quality and Accountability.

3. HALO PSEAH Commitments

• SEAH is gross misconduct and grounds for dismissal.

• Sexual activity with anyone under the age of 18 is strictly prohibited, regardless the age of majority locally.

• Exchange of money, employment, goods, services or assistance for sex, or other degrading, threatening or exploitative behaviour are prohibited.

• Sexual relationships between staff that are based on unequal power dynamics are prohibited (e.g., between supervisors and staff). Where relationships develop outside this constraint, staff should speak to a member of HALO’s Human Resources department to ensure there is no perceived or real conflict of interest, or abuse of authority and this will be recorded.

• International staff must not engage in sexual relationships with members of affected communities due to the inherent unequal power dynamics.

• Locally recruited staff must declare relationships with community members to ensure no abuse of power; any risk or conflict of interest may require relocation of affected staff.

• Sexual relationships between locally recruited staff, living in the community, and local populations must not exploit unequal power dynamics.

• Unwanted sexual behaviour or sexualised communication of any kind (in person or online) is strictly forbidden.

• All staff and related personnel have a duty to report any actual or suspected SEAH.

• All staff, and especially Managers, must actively promote a safe and respectful working environment.

• Sexual exploitation, abuse and sexual harassment by HALO staff and related personnel constitute acts of gross misconduct and are therefore grounds for termination of employment.

• HALO is committed to the Survivor Centred Approach.

• HALO will ensure that the PSEAH principles are embedded into all areas of work.

4. Responding to SEAH Concerns

HALO will respond in a timely and survivor focused manner to SEAH reports, with zero tolerance to no action to any reports received.

Response to SEAH reports will follow the Standard Operating Procedure for SEAH investigations and will have oversight by the Global Safeguarding Lead.

Safeguarding investigations will ensure the rights of and duty of care to everyone involved

All responses to SEAH reports will follow the following principles:

• Survivor-centred;

• Confidential;

• Professionally lead with oversight by the Global Safeguarding Lead;

• Following due process;

• Survivor support signposting; and

• Accountable decision making.

5. Definitions

Perpetrator: a person (or group of persons) who commits an act of sexual exploitation or abuse. For the purposes of this guideline, a perpetrator means HALO staff or related personnel.

Reporter: a person who reports safeguarding misconduct.

Sexual Abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. This would include forced marriage and sexual slavery and includes sexual activity with a child.

Sexual Exploitation: any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially, or politically from the sexual exploitation of another, such as exchanging money, goods, jobs, promotions, or services for sex.

Sexual Harassment: Any unwelcome sexual advance, request for sexual favour, verbal or physical conduct or gesture of a sexual nature, exposure to a sexual act, or any other behaviour of a sexual nature that might reasonably be expected or be perceived to cause offence or humiliation to another.

Such conduct will also be considered sexual harassment when it interferes with work, is made a condition of employment, or creates an intimidating, hostile or offensive work environment. While typically involving a pattern of behaviour, it can take the form of a single incident. Sexual harassment may occur between persons of the opposite or same sex. Both males and females can be either the victims or the offenders.

Sexual Relationship: Includes but is not limited to a staff member or related personnel having a physically intimate relationship, or an online sexually related relationship via social media, text or telephone.

Subject of Complaint (SoC): a person who has had an allegation of misconduct made against them.

Victim/Survivor: The person who it is alleged has been the subject of sexual harassment, abuse or exploitation.

Victim/Survivor centred approach: places the rights, wishes, needs, safety, dignity and well­being of the victim/survivor at the centre of all prevention and response measures concerning sexual exploitation and abuse (SEA) and sexual harassment (SH).

Last updated 12 August 2026