Protection from Sexual Exploitation, Abuse and Harassment (PSEAH) Policy
This policy outlines our commitment to safeguarding from Sexual Exploitation, Abuse and Harassment (SEAH).
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Document No |
RISK_POL_11 |
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Original Issue
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08/2019
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Authorised By
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Executive
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Last Review
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06/2026
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Next Review
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06/2029
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Document No
RISK_POL_11
RISK_POL_11
RISK_POL_11
RISK_POL_11
Background
Sexual exploitation, abuse and harassment (SEAH) are forms of gender-based violence and abuses of power causing profound harm to individuals and communities. SEAH is perpetrated in workplaces and communities in all sectors and countries.
Research and development projects in Australia and internationally often take place within contexts structured by inequalities and power imbalances. A risk based and intersectional approach must be applied to PSEAH, recognising that factors such as context, gender, race, ethnicity, disability, sexual orientation, socio-economic status, structural inequity and systemic marginalisation can increase vulnerabilities.
Burnet is committed to preventing and actively managing and mitigating the risk of SEAH and responding appropriately when it occurs. This means taking all reasonable actions to:
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protect project participants, communities and personnel
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proactively reduce SEAH risk and prevent SEAH incidents
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provide a safe environment for anyone to raise a concern
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take seriously and immediately respond to concerns and incidents in a way which prioritises the rights, dignity and needs of victim-survivors.
Protection from SEAH (PSEAH) is also referred to as ‘safeguarding against SEAH’.
Purpose
The Burnet Protection from SEAH Policy provides a whole-of-organisation framework to implement PSEAH measures and embed a strong safeguarding culture across Burnet.
Scope
The policy applies to:
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Children, youth, and research and project participants
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Burnet workers: members of the Burnet Board, employees, students, directors, contractors and any of their employees, sub-contractors and any of their employees, consultants and any of their employees, honorary and/or visiting researchers, honorary and/or visiting appointees, visitors, labour hire workers, outworkers, apprentices, trainees, work experience/placement students and volunteers, or any person representing Burnet at all times (in and outside work hours)
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Partners/accompanying friends/family of staff on work trips, immediate dependants of Burnet staff who are internationally mobilised
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Partner organisations.
Reports of alleged abuse and exploitation incidents against individuals under the age of 18 years must follow Burnet’s Child and Youth Safeguarding Policy.
Policy principles
Safe organisational culture
Burnet does not tolerate sexual exploitation, abuse and harassment including transactional sex by anyone who works for or is associated with Burnet and has zero tolerance for SEAH in all areas of our workplace, research and project work and advocacy and communication. This means zero tolerance for acts of SEAH and zero tolerance for inaction to prevent, report or respond to SEAH. PSEAH must be embedded in governance, leadership and organisational culture at Burnet through clear accountability, leadership commitment, investment of resources and continuous review and improvement of policies and practices to maintain a strong and open safeguarding culture.
Promoting gender equity, diversity and inclusion
At Burnet, we believe that gender equity is both a fundamental human right and a cornerstone of health equity. Advancing gender equity therefore requires an intersectional approach that acknowledges and responds to the diverse realities of women and gender-diverse people across our workforce, research, programs, and partnerships. Burnet recognises that people may be at increased risk of SEAH due to age, gender diversity, sexual orientation, disability, ethnicity, socio-economic status, displacement, or other factors. We will address barriers to participation, protection, reporting and support such as language, safety, racism, discrimination and accessibility and will ensure all actions and decisions in relation to PSEAH at Burnet are inclusive and equitable.
Victim-survivor centred approach to SEAH prevention and response
Action to address SEAH should be underpinned by a ‘do no harm’ approach prioritising the safety, rights, needs and wishes of the victim-survivor. This approach treats victim-survivors with dignity and respect, keeps them informed, protects their confidentiality and involves them in decision-making. Responses to incidents must be trauma-informed and enable access to support services.
Preventative, risk-based and locally led approach
Burnet will be proactive in minimising the risk of SEAH and creating safe environments in all contexts, both in the physical environment and online. Actions to prevent SEAH will be embedded in policies, research and development projects, recruitment, training and operations. Where possible, Burnet will consult women, girls, and other groups in vulnerable situations as well as partners, when assessing SEAH risk and in developing effective and relevant mitigation measures. Locally led PSEAH approaches will build on existing community and national mechanisms and inform Burnet’s safeguarding system.
Definitions
Vulnerable adults
Are individuals aged 18 years and over who may be at increased risk of harm, abuse, or exploitation due to factors such as gender, mental or physical health, disability, ethnicity, religious identity, sexual orientation, economic or social status, or circumstances arising from disasters, conflict, or displacement. These individuals may face barriers to protecting themselves or accessing support and services and therefore require additional safeguarding measures. Recognising that all people can be vulnerable if the circumstances make them so, it is a term intended to convey that an adult may be experiencing circumstances that make them vulnerable at a point in time.
Sexual exploitation
Any actual or attempted abuse of a position of vulnerability, differential power or trust for sexual purposes, including but not limited to profiting monetarily, socially or politically from the sexual exploitation of another. For example, coercing individuals into engaging in sexual activities in exchange for aid, services, employment opportunities or other benefits.
Sexual abuse
The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. This includes all forms of sexual assault, rape, molestation and other forms of non-consensual sexual activity.
Sexual harassment
Any unwelcome conduct of a sexual nature that occurs in circumstances in which a reasonable person, aware of those circumstances, would anticipate that the person being harassed might feel offended, humiliated or intimidated. Sexual harassment can take many forms. It can be overt, covert or subtle. It can be repeated or a one-off incident. Sexual harassment can happen in person, over the phone or online – including via social media. Anyone can experience sexual harassment, regardless of their sex, gender identity, sexual orientation or intersex status. Examples include but are not limited to: unwelcome physical touching, jokes, comments or messages of a sexual nature; suggestive looks, staring or leering; display of or circulation of sexually exploitative material; and sharing or threatening to share intimate images or video without consent. (Also see Burnet Respect in Our Workplace Policy)
Victim-survivor
Victim-survivor is a term used to describe a person who is, or has been, sexually exploited, abused or harassed. The term ‘victim-survivor’ acknowledges both the harm suffered (victim) and the resilience or agency of the individual in coping with the aftermath (survivor). This term emphasises a supportive, rights-based approach to addressing their needs and upholding their dignity throughout the reporting and response process
Transactional sex
A person can be sexually exploited through transactional sex (the exchange of money, employment, goods or services or other advantages for sex or sexual acts), even in places where sex work is legal. In high-risk settings, such as international development research settings, it is often impossible to distinguish between exploitative and non-exploitative transactional sex. Where there are power imbalances at play (based on gender, age, ability, authority, social and economic inequality, etc), the potential for exploitative transactional sex is heightened.
Fraternisation
Fraternisation refers to any intimate or social relationship occurring in the course of conducting business. This could involve – or appear to involve – partiality, preferential treatment or improper use of rank or position, including but not limited to consensual sexual behaviour. Where there are power imbalances at play (based on gender, age, ability, authority, social and economic inequality, etc), particularly in high-risk settings, including research and development settings, the potential for exploitative fraternisation is heightened.
Online abuse
Online or tech-based abuse (sometimes known as ‘technology-facilitated abuse’) is behaviour that uses an online space or digital technology to threaten, intimidate, bully, harass, humiliate, exploit or coerce someone and often involves stalking, sexual harassment, and other forms of intimidation. It can significantly impact an individual’s social and psychological wellbeing and may lead to physical harm. Online abuse includes bullying and sexual harassment in the workplace where women are at particularly high risk of experiencing it.
Partner
The term ‘partner’ is used broadly to capture any collaborator, government agency, organisation or stakeholder (funded or unfunded) with which Burnet works and/or which is important to achieving program outcomes and sustainability.
Policy implementation
Burnet leadership – Executive Council, working group heads, professional services leaders
- A commitment to effective leadership and clear messaging to enable PSEAH.
- Creating and maintaining an environment where it is safe to raise concerns and make reports regarding SEAH
- Embedding PSEAH obligations in practice, visibility of PSEAH risk management, and monitoring compliance with policies and codes of conduct
- A commitment to communication of the PSEAH Policy and Safeguarding Code of Conduct to all Board members, Burnet workers, partners, and visitors to projects.
Burnet Board
- Accountable for the oversight of the PSEAH Policy and visibility of PSEAH risk management.
- Oversight through the Finance, Audit, Risk and Investment Committee (FARIC) of PSEAH risk management (organisational and project level), and SEAH reports.
All Burnet workers
- Prevent, report and respond to any SEAH concerns
- Sign on and comply with policies, adhere to the PSEAH Policy and Safeguarding Codes of Conduct
- Share the responsibility for PSEAH
Management
- Responsible for promoting awareness of the PSEAH Policy and Safeguarding Code of Conduct with the people they manage
- Ensure that a standing agenda item on safeguarding (child safeguarding and PSEAH) is considered at team meetings
- Responsible for actively providing information to project participants and the community on expected behaviours of Burnet workers and promote projects specific reporting mechanisms
- Hiring managers and Project Managers have the responsibility for ensuring safe recruitment and integrity screening procedures are applied and they will be supported through training and resources to enable this.
- Ensure that a safeguarding project level risk assessment in undertaken and regularly monitor risk assessment and all efforts to prevent, detect and manage safeguarding risks and reports
- Incorporate requirement to comply with the PSEAH Policy and Safeguarding Code of Conduct in contracts, partner agreements, Memorandum of Understanding (MoU) and clause for breach.
- Responsible for undertaking a due diligence assessment of all partners, which includes their safeguarding policies and practices
- Responsible for ensuring partners are compliant or have a plan in place to develop or strengthen their PSEAH policies & practices and that this is documented and coordinated across managers who are working with the same partners
Safeguarding team
Safeguarding Manager
- Responsible for strengthening Burnet safeguarding systems and processes and work with all disciplines and teams across Burnet to implement PSEAH standards and measures.
- Lead good practice in PSEAH, provide technical support, develop resources, review safeguarding, policies and procedures; deliver training, monitoring compliance and collaborating with the Safeguarding Focal Points, country program staff and partners in locally led safeguarding approaches.
- Conducting periodic audit of integrity screening to ensure that requirements and measures are adhered to, supports good risk management and allows for continued strengthening of safe recruitment and screening processes.
- Support program and project level PSEAH risk management and partner due diligence and compliance
- Lead continuous improvement through development and implementation of a safeguarding action plan
- Report on safeguarding implementation and SEAH risks to the FARIC
- Monitor compliance with Department of Foreign Affairs and Trade (DFAT), Australian Council for International Development (ACFID) and other donor requirements
- Receive reports of SEAH incidents, manage and investigate reports, ensure a survivor centred and trauma informed approach and report to DFAT as required
- Escalate SEAH risks to the Executive and FARIC as required
Safeguarding focal points
- As part of locally led safeguarding, Safeguarding Focal Point/s are appointed in each country office and are responsible for:
- Meeting regularly with the Safeguarding Manager and working together to put in place safeguarding measures
- Developing safeguarding resources, posters, and training materials that are relevant to the context and work of the office, with support from the Safeguarding Manager
- Delivering safeguarding induction/training sessions as required
- Promoting safeguarding awareness and providing support to staff on safeguarding issues and changes to safeguarding policies and procedures
- Sharing good practice safeguarding practices across the Safeguarding Team to strengthen safeguarding at Burnet
- Monitoring and responding to safeguarding issues, advising on SEAH risks in programs and identifying ongoing training and support needs with the Safeguarding Manager
- Working in collaboration with the Safeguarding Manager, Country Director/Deputy Country Director and People to respond, manage and investigate safeguarding (child and SEAH) reports
- Providing advice on local referral and support options where required
People/HR teams either in Australia or country offices
- Ensure that Burnet workers are informed of their responsibilities and obligations under the PSEAH Policy and sign the Safeguarding Code of Conduct
- Oversight that Burnet workers receive appropriate safeguarding induction and training
- Responsibility for compliance with Burnet safe recruitment and screening requirements
Safe recruitment and screening
Burnet will apply risk-based and robust safe recruitment and screening procedures to prevent the recruitment of individuals who pose a risk of SEAH, including those who may misuse positions of power, authority or trust in adult or community settings.
Burnet will conduct safe recruitment and integrity screening for Burnet employees, Board members, students, consultants, individual contractors and sub-contractors, and will apply a risk-based approach to other roles in the broader Burnet worker category.
This includes:
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A statement that confirms Burnet’s commitment to safeguarding in advertisements and job descriptions
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Providing applicants with Burnet’s PSEAH Policy and Safeguarding Code of Conduct during the recruitment and onboarding process.
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Screening should include reference checks, recent police checks, working with children or working with vulnerable people checks or locally appropriate alternatives such as personal declaration forms or statutory declarations (only to be used where other checks are not practicable or feasible). Where local equivalents are not available, acceptable alternatives may include documentation from a government or legal authority and endorsement from a community or religious leader.
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Additional integrity measures include targeted messaging, focused questions during interviews and questioning about PSEAH at all stages of recruitment and onboarding, and ongoing monitoring of worker behaviour and adherence to safeguarding policies and processes.
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Employment/engagement contracts which contain suspension (with or without pay) or transfer to other duties for any employee/consultant who is under investigation for SEAH breaches and provision to dismiss any employee/consultant after an investigation.
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Sign and comply with the PSEAH Policy and Safeguarding Code of Conduct as a condition of commencing with Burnet. A written record of policy agreement will be retained on file.
Visitors
All visitors to Burnet project locations must sign the Safeguarding Code of Conduct and be accompanied and supervised by Burnet employees at all times.
Partner personnel
Burnet projects teams will collaborate with international partners to implement safe recruitment and screening measures and meet both Burnet and donor compliance requirements.
Safeguarding Code of Conduct
As part of this Policy several key commitments have been identified and incorporated in the Safeguarding Code of Conduct. The Safeguarding Code of Conduct outlines the expected behaviours of all Burnet workers when interacting with adults especially adults in vulnerable situations.
Any breach of the Burnet Protection from SEAH Policy or Safeguarding Code of Conduct will lead to disciplinary action which may include suspension (with or without pay) and/or termination of employment for workers or termination of association and/or contract with Burnet for other Burnet representatives.
Burnet may terminate a contract with a consultant, contractor, sub-contractor, partner or volunteer immediately and without prejudice to any claim for damages on giving written notice to the person/organisation if the person is in breach of the PSEAH Policy or Safeguarding Code of Conduct.
Induction and training
All Burnet employees, Board members, students, and other relevant Burnet workers must complete the mandatory Safeguarding online module as part of induction and undertake safeguarding refresher training annually.
Tailored and comprehensive safeguarding training and information sessions for Burnet workers and periodic training for partners will be budgeted and coordinated by the project team and Safeguarding team.
Training modules will include an understanding of:
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Sexual exploitation, abuse and harassment and victim and survivor centred approaches
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SEAH risks and impacts and an awareness of how intersectional risks may increase the risk of SEAH, to provide a safe environment for project participants and communities
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Burnet workers responsibilities and obligations for PSEAH including the importance of safe workplaces for Burnet’s personnel
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Overview of donor policies and standards and the ACFID Code of Conduct requirements in related to the prevention of sexual exploitation, abuse and harassment.
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Expected behaviours under the Burnet PSEAH Policy and Safeguarding Code of Conduct and consequences of policy or Code of Conduct breach including disciplinary and legal implications
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How to report allegations, suspicions or concerns of SEAH and the barriers to reporting.
All Burnet workers must attend a safeguarding pre-departure briefing before their first work trip or when visiting a new country for work purposes within a 2-year period.
Safer programming
As part of a shared responsibility, Burnet will collaborate with overseas and Australian partners to negotiate shared goals and respective contributions with partners to strengthen PSEAH.
Burnet will work with all partners (funded and unfunded) to implement safeguarding standards and requirements which must be covered and documented, including sharing safeguarding knowledge to consider the perspectives and knowledge of primary stakeholders and an analysis of power dynamics and issues of gender equity. Where appropriate this includes:
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Ensuring documented discussions with government partners on safeguarding requirements occur at least every 2 years to clarify all key safeguarding areas.
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Training and information resources are offered (not stipulated) to regional government partners, including connections to local providers.
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National level Safeguarding Profiles are developed to ensure Burnet is across national context, legislation and policies and to identify any gaps in legislated safeguarding practices.
Safeguarding clauses and mutually agreed reporting obligations must be included in partnership agreements, service agreements and Memorandum of Understanding (MoU) noting that when signing a MoU with government departments, Burnet will use government agreement templates.
For all Burnet partners, Burnet will assess partner activities to identify safeguarding risk factors and determine whether the partner’s safeguarding policies meet Burnet safeguarding standards (which align with the DFAT Child Protection and PSEAH Policy standards), as appropriate to the level of risk. Based on this assessment, Burnet will either support partners to develop or revise their own safeguarding policies and codes of conduct, or to adopt Burnet’s safeguarding policies. Burnet will provide safeguarding training to partners that is proportionate to the level of risk and the nature of the activities.
As a DFAT accredited non-government organisation (NGO), Burnet must ensure partner organisations apply the relevant DFAT PSEAH Standards when engaged to perform any DFAT-related business. Burnet is responsible for:
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Ensuring documented exchange and discission of relevant safeguarding policies and practices with partners
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Ensuring partner action plans are realistic, risk-sensitive and implemented within a reasonable timeframe
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Maintaining documented evidence of expectations for partners and how partners will manage risks in relation to SEAH
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Monitoring progress and providing technical assistance and support where needed.
Safeguarding risk management
Documented project safeguarding risk assessments in relation to SEAH including mitigation actions tailored to the activities and context, must be undertaken using the Safeguarding Risk Assessment section of the Project Operational and Safeguarding Risk Assessment template.
Safeguarding risk assessments must clearly outline factors that heighten risks for adults, be completed before the project commences and reviewed and approved by the Safeguarding Manager.
Safeguarding risk assessments must take an intersectional approach – recognising that factors such as gender, race, ethnicity, disability, sexual orientation, and systemic marginalisation can increase vulnerability and shape safeguarding needs. The assessment must identify safeguarding risks, risk ratings, the mitigation actions, responsible persons and the timeframes for implementation of mitigations. Safeguarding risk assessments must be regularly reviewed and updated at least annually and mitigation actions monitored throughout the life of the project.
Burnet delivers programs in high-risk settings including development settings. For all DFAT-funded projects, Burnet must take a risk-based approach in applying the DFAT PSEAH Policy PSEAH Standards. Burnet project teams and the Safeguarding Manager must assess activities, as well as those of any partners, to identify risk factors for SEAH using the Project Operational and Safeguarding Risk Assessment template. Burnet must put controls in place to manage and monitor the risk of SEAH and ensure processes are adhered to and continue to monitor for any change in risk settings.
Informed consent
Burnet considers the safe and ethical use of images and social media essential to safeguarding individuals and communities, especially those in vulnerable situations. This includes obtaining and documenting free, prior and informed consent.
Informed consent applies to all information, images, stories and recordings collected for research, evaluation, and donor and supporter purposes when Burnet workers or external contractors take photos, videos, audio and interviews used in Burnet official publications. It also applies to any content shared between Burnet workers, and from Burnet workers to other people, whether through social media messaging apps or on Burnet workers’ personal social media.
Burnet will:
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Obtain informed consent before taking or using images, recordings, personal data or stories of any individual with special care taken when involving people in marginalised, dependent or vulnerable situations
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Ensure all media is respectful, dignified and non-identifying, unless explicit, informed consent is provided
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Not use images, recordings, data and stories beyond a determined timeframe. Individuals can specify how long their informed consent remains valid.
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Provide training/briefings to staff, students, volunteers, consultants, partners and contractors on safe and ethical digital media practices, including the risks of misuse, stigmatisation, humiliation or harm due to, for example, an individual’s health condition or survivor of gender-based violence (GBV) or abuse being identified.
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Implement systems to reduce online safeguarding risks, including grooming, stalking, re-identification of individuals and the inappropriate or exploitative use of personal stories or imagery
The following standards apply when photographing or filming:
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explain how the photograph or film will be used, and with an interpreter if necessary
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take care that local traditions or restrictions for reproducing personal images are adhered to before photographing or filming
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photographs, images and videos present project participants and community members in a dignified and respectful manner and not in a vulnerable, disempowering, humiliating or submissive manner
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images, videos and interviews should also only be used for the purposes they were collected, as an honest representation of the context and facts. It is not appropriate to use images from one project or of one person to reflect the situation or context in another area.
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all informed consent files and forms must be stored safely and securely.
PSEAH reporting and investigation
Burnet provides a safe, accessible and confidential process for anyone to make a SEAH concern or incident.
Procedural fairness
No negative action will be taken against any person who informs Burnet in good faith of incidents and risks. However, those who wilfully inform Burnet using false information will be subject to investigation and consequences as per disciplinary procedures.
Burnet will ensure that all incidents and reports are handled according to the principles of confidentiality, safety, impartiality, procedural fairness, timeliness, and accuracy. All incidents and reports and the names of people involved will be handled in the strictest of confidence. Details will only be disclosed on a ‘need to know’ basis, where required by relevant local or Australian law, or when a report to police or appropriate authorities is made.
The rights of all those involved in a report and investigation, including those of the subject of concern, will be upheld.
Safeguarding reporting process
Who must report
Burnet workers and partners must immediately (within 24 hours) report any concerns, observations, allegations, disclosures or behaviour that is suspected of being SEAH, or a suspected breach of Burnet's PSEAH Policy and Burnet Safeguarding Code of Conduct.
What to report
- An observation or disclosure (by a Burnet worker, project participant, community member or partner personnel) of SEAH, transactional sex or harm
- An observation or disclosure of potential risk of SEAH, transactional sex or harm
- A breach of the Burnet PSEAH Policy or Safeguarding Code of Conduct
- An observation or disclosure of behaviour which could be considered online abuse
- Online or tech-based abuse or exploitation materials that are received on Burnet electronic equipment (this can include, but is not limited to, SPAM, popups, text messages, emails, or social media communications).
A report must be made when:
- Suspected harm is due to the actions or inactions of a Burnet worker, partner personnel or due to the actions of a person representing Burnet
- An alleged criminal offence has been committed against a person, and the matter will be reported to the relevant authorities both in the country where the crime was committed and to Australian authorities.
When to report
The report must be made immediately, or within 24 hours, of becoming aware of the incident, suspicion, or risk.
Who to report to
Reports must be made to one or more of the following:
- Safeguarding Manager
- Safeguarding Focal Point (Country offices)
- Member of People/Human Resources team, either in Australia or country office
- Line Manager/Country Director or Representative/Working Group Head/Activity Leader: if the worker feels comfortable doing so, and if they are not the alleged subject of concern or implicated in the report
- Via safeguarding@burnet.edu.au
- The Integrity Line, online or by phone (it should be noted that in certain circumstances where the report is of a criminal nature, anonymity may not be able to be maintained. Burnet may have a legal obligation to investigate and/or report a matter to external parties).
Safeguarding reports can be made by email, phone or in person. The person receiving the report (if not the Safeguarding Manager) must enter the report into the incident management system and confidentially notify the Safeguarding Manager.
Reports associated with a partner
SEAH reports or a suspected breach of the partner’s Safeguarding Policies or Code of Conduct, where the subject of concern is employed or engaged by the partner, will be managed by the partner following the partners’ reporting and referral processes, including reporting to local authorities. The Safeguarding Manager and Safeguarding Focal Points must be provided with updates and outcomes of the report and any investigation by the partner.
Partners, project participants and members of the community
Partners, project participants and members of the community may also report concerning the conduct or behaviour of Burnet workers, partners or visitors. Burnet will ensure project participants, communities and partners are informed about expected behaviours, reporting mechanisms and investigation processes in accessible and culturally appropriate ways. All Burnet offices and project locations (e.g. health care centres where our project may be implemented) will have information, such as posters and dedicated safeguarding phone numbers, to report complaints or concerns relating to SEAH. Members of the public may also report misconduct including SEAH via complaints@burnet.edu.au
For DFAT funded projects
Burnet is mandated to immediately report (within 24 hours) to DFAT any suspected, alleged or known SEAH incidents related to DFAT business. Failure to report in accordance with the DFAT PSEAH Policy may result in disciplinary, contractual or legal consequences.
The Safeguarding Manager will prepare the report, and it will be reviewed by the relevant Safeguarding Focal Point, Human Resources Manager and Manager People Operations. A copy of the report will be sent to the Head, OHS and Compliance and Director International Operations. Reports will be submitted to DFAT using the DFAT Incident Notification Form via seah@dfat.gov.au
What happens after a report is made
All safeguarding incident reports will be documented, investigated, and responded to. Safeguarding incident records will be securely stored on Burnet’s Riskware system with access restrictions.
Burnet leadership is responsible for managing any SEAH incidents and risks. The Safeguarding Manager with the Safeguarding Focal Points and the Manager People Operations/Human Resources Manager, will coordinate the response and provide expert advice and support to leadership and management in responding to incidents. Any person with an actual or perceived conflict of interest must not participate in the assessment or investigation of a safeguarding report.
A safeguarding report and investigation management plan will be developed by the Safeguarding and relevant Country/Australian teams and will include:
- An assessment of any immediate risks to the safety of the survivor, children of the survivor and the notifier and if required development of a safety plan with the survivor
- An assessment of the incident report information
- An outline of the specific actions to be taken, a time frame, and those persons responsible for taking the action required.
Actions may include:
- reporting to local, national or international authorities in accordance with local or extraterritorial laws if it is safe for the victim-survivor and in some cases the subject of concern, and with the victim-survivor’s consent to do so.
- following a formal investigation, a confirmed breach of the PSEAH Policy or Safeguarding Code of Conduct may lead to the commencement of performance and disciplinary procedures.
Survivor centred and trauma informed approach
A victim-survivor approach puts the safety including cultural safety, rights, wishes, dignity and wellbeing of the victim-survivor first to prevent re-traumatisation and avoid stigma, blame, retaliation or discrimination. A trauma- informed approach recognises how trauma affects people’s behaviour and decision-making and responds with care, flexibility and respect.
To ensure an effective, preventative and trusting reporting environment Burnet will apply a survivor centred and trauma informed approach to responding and managing SEAH concerns and incidents.
Burnet Safeguarding Focal Points, the Safeguarding Manager and partners may refer survivors to local women’s agencies, family violence and sexual assault services, health and legal services, specialist sexual offences and gender-based violence police, emergency accommodation, psychologists and counselling providers, community-based services in accordance with their needs, wants and wishes as per a survivor-centred approach.
In situations where the alleged subject of concern is a Burnet worker or someone associated with Burnet, Burnet may be legally and procedurally required to report the allegation and investigate, in contradiction to the survivors wishes. In these circumstances this would be discussed with the survivor in a sensitive and trauma informed way and, as best practice, obtain the informed consent of the survivor prior to sharing any identifying information.
Safeguarding system strengthening
Burnet is committed to a culture of continual quality improvement and ensuring that our policies, procedures and practice is regularly reviewed and analysed to identify opportunities to strengthen its approach to safeguarding. This includes assessing feedback, performance against PSEAH standards as well as project and risk assessment outcomes, outputs and indicators which provide a baseline for further improvement. A Safeguarding Audit will be conducted periodically and reported to the Burnet FARIC and Board.
Legislation
Anyone under the scope of this Policy is subject to local criminal, workplace and gender-based violence laws. Relevant Australian legislation includes:
- Modern Slavery Act 2018
- Fair Work Act 2009
- Work Health and Safety Act 2011
- Sex Discrimination Act 1984 – including the positive duty legislation requiring Australian employers and organisations to proactively prevent sexual harassment, sex discrimination, and related unlawful behaviours in the workplace.
- Criminal Code Act 1995
Conventions, standards and frameworks
- Common approach to protection from SEAH (CAPSEAH) is a guide for organisations working in humanitarian, development and peace settings to take action and align efforts to protect people from SEAH Home | CAPSEAH
- The United Nations Convention on the Elimination of all Forms of Discrimination Against Women
- United Nations Declaration on the Rights of Indigenous Peoples Article 22.2 - States shall take measures, in conjunction with indigenous peoples, to ensure that indigenous women and children enjoy the full protection and guarantees against all forms of violence and discrimination.
- ACFID Code of Conduct and PSEAH ACFID Code of Conduct Topic Guide
- DFAT PSEAH Policy 2025
- DFAT Child and Adults Safeguards Implementation Handbook April 2026
- DFAT Gender Equality, Disability and Social Inclusion analysis – Good practice notes
- Australian Charities and Not-for-profits Commission (ACNC) Governance Standards
Related Burnet policies and procedures
- Respect in Our Workplace Policy
- Child and Youth Safeguarding Policy
- Safeguarding Code of Conduct
- Code of Conduct Policy
- Family and Sexual Violence Policy PNG
- Disability Inclusion Policy
- Social Media Policy
- Photography and Videography Guidelines Policy
- Complaints and Disputes Procedure
- External Stakeholders Complaints Handling Policy
- Safeguarding Topic Guides
- International Operations Program Quality and Standards Manual and Project Management Handbook
Acronyms used in the PSEAH Policy
ACFID – Australian Council for International Development
DFAT – Australian Government, Department of Foreign Affairs and Trade
FARIC – Burnet Finance, Audit, Risk and Investment Committee
NGO – non-government organisation
PSEAH – Protection from Sexual Exploitation, Abuse and Harassment
Version control
Reviewed and approved by Finance, Audit, Risk and Investment Committee: 24 July 2026
Endorsed by Board: 4 August 2026