SEA & Harassment Policy



1.       Introduction

This policy details the expectations and requirements for all staff of The HALO Trust (‘HALO’) on issues relating to the prevention of and protection from sexual exploitation and abuse (‘SEA’) and harassment.

Each member of staff is expected to review and abide by the principles set out in this policy, and any subsequent training or guidelines, throughout the duration of their employment with HALO.

The policy draws upon and is linked to existing policies and procedures. It should be reviewed in conjunction with the following global HALO policies and guidelines: Code of Ethical Conduct, Equality and Diversity Policy, Safeguarding Policy, Staff Code of Practice and Policies (SCPP), Whistleblower Policy, Complaints Policy, and Disciplinary Procedure.

It is the policy of HALO to comply fully with the following related UK legislation: Sexual Offences Act (2003), Equality Act (2010) and Protection from Harassment Act (1997).

Any questions about this policy, or related policies, should be directed to HALO’s Human Resources department.

2.       Values and Core Principles

HALO implements a strict policy of prevention of and protection from SEA and harassment, with regard to both staff and beneficiaries of HALO’s work. All staff are obligated to adhere to the regulations laid out within this policy.

The values and core principles of HALO’s approach to SEA and harassment are:

  •        HALO takes a zero tolerance approach to any forms of SEA and harassment. All reports will be investigated thoroughly and dealt with appropriately.
  •        HALO senior management is committed to a workplace free of harassment.
  •        HALO will treat all reported incidents with utmost confidentiality; the identities of the alleged harasser, affected person(s), as well as the informant will be kept confidential unless the organisation assesses that disclosure is necessary for safety reasons.
  •        All reported incidents of SEA and harassment will be handled impartially and independently by neutral parties who are not directly involved and have no conflict of interest in the case.
  •        HALO practices a policy of non-retaliation to ensure that the reporting informant is not victimised following any reported incident.

3.         Definitions[1]

3.1       Harassmentis any improper and unwelcome conduct that might reasonably be expected or be perceived to cause offence or humiliation to another person. Harassment may take the form of words, insinuations gestures or actions which tend to annoy, alarm, abuse, demean, intimidate, belittle, humiliate or embarrass another or which create an intimidating, hostile or offensive work environment. Disagreement on work performance or on other work related issues is normally not considered harassment and is not dealt with under the provisions of this policy but in the context of performance management.

3.2       Sexual harassment is any unwelcome sexual advance, request for sexual favour, verbal or physical conduct or gesture of a sexual nature, or any other behaviour of a sexual nature that might reasonably be expected or be perceived to cause offence or humiliation to another, when such conduct 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.

3.3       Abuse of authority is the improper use of a position of influence, power or authority against another person. This is particularly serious when a person uses his or her influence, power or authority improperly to influence the career or employment conditions of another, including, but not limited to, appointment, assignment, contract renewal, performance evaluation or promotion. Abuse of authority may also include conduct that creates a hostile or offensive work environment which includes, but is not limited to, the use of intimidation, threats, blackmail or coercion. Discrimination and harassment, including sexual harassment, are particularly serious when accompanied by abuse of authority.

3.4       Discrimination is any unfair treatment or arbitrary distinction based on a person’s race, sex, religion, nationality, ethnic origin, sexual orientation, disability, age, language, social origin or other status. Discrimination may be an isolated event affecting one person or a group of persons similarly situated, or may manifest itself through harassment or abuse of authority.

3.5       For the purposes hereof, sexual harassment, exploitation and abuse of authority including (but not limited to) the types of behaviour set out in clause 4 of this policy shall collectively be referred to as ‘Prohibited Conduct’.

4.         Behaviour and Communications

SEA and harassment constitute acts of serious misconduct and are therefore grounds for disciplinary measures, including dismissal. The following behaviours and communications are deemed to be non-acceptable:

  •        Sexual activity with children (persons under the age of 18) is strictly prohibited regardless of the age of majority or age of consent locally.
  •        Exchange of money, employment, goods or services for sex, including sexual favours or other forms of humiliating, degrading, threatening or exploitative behaviour, is prohibited. This includes exchange of assistance that is due to beneficiaries.
  •        Sexual relationships between HALO staff which are based on unequal power dynamics are prohibited. Where relationships develop outside of this dynamic staff should speak to a member of the Human Resources department to ensure there is no perceived conflict or potential abuse of authority.
  •        Sexual relationships between HALO international staff and beneficiaries and local populations are prohibited as they are based on inherently unequal power dynamics.
  •        Unwanted interactions or communications of any form conducted by HALO staff – in person or via phone or social media platforms – deemed to be harassing in nature are strictly forbidden.
  •        Communications between HALO staff and beneficiaries, or other HALO employees, must not contain any direct or indirect reference of a sexual nature.

The following behaviours and communications are deemed to be acceptable and set minimum standards of conduct for staff:

  •        Interactions and communications between HALO staff should always be conducted in a respectful and professional manner
  •        Interactions, communications and relationships between HALO staff and beneficiaries and local populations should be conducted in a manner which is culturally acceptable and sensitive, respectful and neutral in approach

5.         Expectations of Staff

HALO is uncompromising in its attitude to any deviation from the creation and maintenance of an environment which prevents SEA and harassment, and promotes the implementation of this policy. HALO management and staff at all levels have specific responsibilities to support and develop systems, which maintain this environment.

All staff members have the obligation to ensure that they do not engage in or condone any behaviour which would constitute Prohibited Conduct with respect to their peers, supervisors, supervisees, other persons performing duties for HALO and beneficiaries of HALO’s work.

All staff have the duty to take all appropriate measures to promote a harmonious work environment which is free of intimidation, hostility, offence and any form of Prohibited Conduct. Staff must act as role models by upholding the highest standards of conduct in this regard. In addition, senior programme staff have the obligation to ensure that complaints of Prohibited Conduct are promptly addressed in a fair, thorough and impartial manner.

6.         Preventive Measures and Staff Support

In order to ensure no Prohibited Conduct is undertaken by HALO staff the following preventive measures will be taken:

  •        HALO will conduct mandatory training for all newly recruited staff as part of their introduction to raise awareness of HALO’s zero tolerance of Prohibited Conduct.
  •        HALO will provide guidance on relevant policy and procedures and will foster the creation of a working environment which is free of any Prohibited Conduct.
  •        Where necessary targeted training for managers and supervisors will be conducted, completion of which may be a requirement for advancement to successive levels of responsibility.
  •        HALO managers and supervisors shall maintain open channels of communication and ensure that staff members who wish to raise their concerns in good faith can do so freely and without fear of adverse consequences.

7.         Complaint Mechanism

HALO has in place a clear and confidential mechanism of complaint to deal with any suspected breaches of this policy. All reported/suspected incidents will be investigated and sanctioned appropriately through the following actions:

  •        Individuals who believe they are victims of Prohibited Conduct are encouraged to report the problem as early as possible to an appropriate member of HALO staff.
  •        Any individual reporting an allegation of Prohibited Conduct is encouraged to keep a written record of events, noting dates, places, a description of what happened and the names of any witnesses and of anyone who may have information concerning the incident or situation.
  •        All reports and allegations of Prohibited Conduct shall be handled with sensitivity in order to protect the privacy of the individuals concerned and ensure confidentiality to the maximum extent possible. This may be through the immediate manager, senior manager or Human Resources. Concerns may also be raised via the Whistleblower Policy, in which case the report will be dealt with according to those procedures.
  •        Managers and supervisors have the duty to take prompt and concrete action in response to reports and allegations of Prohibited Conduct. Failure to take action may be considered a breach of duty and may result in disciplinary proceedings.

8.         Disciplinary Action

Any form of Prohibited Conduct by HALO staff shall constitute an act of gross misconduct and therefore be grounds for termination of employment.

9.         Training

Upon employment and through refresher training, HALO provides staff with a clear policy on what constitutes Prohibited Conduct and acceptable behaviour in the workplace. Where appropriate HALO will ensure more detailed training for staff on the prevention of Prohibited Conduct.

10.       Monitoring and Review

This policy will be reviewed at least annually by the Trustees or more frequently if required. Employees are invited to comment on this policy and suggest ways in which it might be improved by contacting the Trustees or the Head of Human Resources.

This policy does not form part of any employee’s contract of employment and HALO may amend it at any time.



Last reviewed by Trustees on: 27 February 2018



[1] Definitions taken from UN Secretary-General’s bulletin on Prohibition of discrimination, harassment, including sexual harassment, and abuse of authority dated 11 February 2008