Safeguarding Policy

African Center for Governance, Asset Recovery, and Sustainable Development Ltd/GTE

Safeguarding Policy

April 2025

Acronyms

AC	African Center for Governance Asset Recovery and Sustainable Development
ED	Executive Director
HR	Human Resource
SEA	Sexual Exploitation and Abuse

1. Introduction

At African Center, we are committed to creating a safe and supportive environment for all individuals involved in our work, particularly vulnerable populations who may be affected by asset recovery efforts. As an organization dedicated to promoting transparency, accountability, and justice, we recognize that safeguarding is fundamental to our mission and values.

Our safeguarding policy outlines the principles, practices, and responsibilities that ensure the protection and well-being of all persons we engage with, whether they are beneficiaries, partners, or staff members. This includes protecting individuals from exploitation, abuse, discrimination, and neglect, especially within the complex and sensitive context of asset recovery.

We acknowledge the critical nature of our work in asset recovery, which can involve interactions with vulnerable groups, including those affected by corruption, illicit financial flows, and systemic inequalities. Our safeguarding approach integrates strong preventative measures, clear reporting channels, and mechanisms to address concerns effectively. We are committed to continuous learning and adapting our practices to meet the highest standards of safeguarding to protect the integrity and trust of all stakeholders involved.

Through this policy, we aim to foster a culture of respect, dignity, and responsibility, ensuring that the rights of all individuals are respected and upheld in every aspect of our operations.

1.2 Purpose

The purpose of this Safeguarding Policy is to outline the African Center for Governance, Asset Recovery, and Sustainable Development’s (The African Center) commitment to safeguarding all individuals who encounter the organization, especially vulnerable groups such as children, youth, and at-risk adults. This policy aims to ensure that the safety, dignity, and rights of all individuals are protected and upheld in every aspect of the organization’s operations.

1.3 Scope

This policy applies to all employees, volunteers, board members, contractors, partners, and any other individuals associated with The African Center, regardless of their role or location. The policy covers all activities, programs, and operations of the organization.

1.4 Definitions

Safeguarding: The actions and measures taken to protect individuals, particularly children and vulnerable adults, from harm, abuse, neglect, and exploitation.
Bullying: Repeated aggressive behavior intended to hurt another person, physically, mentally, or emotionally.
Harassment: Unwanted behavior that causes distress or harm, particularly if it is related to a person’s gender, race, age, disability, sexual orientation, religion, or any other protected characteristic.
Sexual Exploitation and Abuse (SEA): Abuse is any behaviour towards a person that causes harm, endangers life or violates rights. Examples of abuse include:
- Physical abuse.
- Sexual abuse.
- Sexual exploitation including:
- Sexual relations with a person below the age of 18 regardless of the age of consent.
- Use of prostitutes even if locally legal.
- Commercial exploitation, including child labour and modern slavery.
- Financial or material – stealing or denying access to money or possessions, expecting favours of any kind in exchange for African Center assets or involvement in a project.
- Emotional abuse.
- Neglect and negligent treatment.
- Discrimination – abuse motivated by discriminatory attitudes towards age, race, religion, gender, disability, sexual orientation or cultural background.

2. Vulnerable Persons Covered by the Policy

All children and young people below the age of eighteen years should be protected from all forms of abuse, neglect, exploitation, and violence and adheres to the fundamental rights of the child as spelled out in the UN Convention on the Rights of the Child of 1989.

Vulnerable adults, persons over the age of eighteen years who are unable to take care of or protect themselves against harm or exploitation for whatever reason, require particular protection.
Both children and vulnerable adults (hereinafter referred to as the “Vulnerable Persons”) have rights as individuals and shall be treated with dignity and respect.

3. Safeguarding Principles

Zero-Tolerance Policy: The African Center has a zero-tolerance approach to any form of bullying, harassment, sexual exploitation, or abuse. Any breach of this policy will result in disciplinary action, which may include termination of employment or contract and referral to relevant authorities.
Respect and Dignity: All individuals associated with The African Center are expected to treat others with respect and dignity, promoting an environment that is inclusive, supportive, and free from any form of discrimination or harm.
Best Interests of the Vulnerable: The organization prioritizes the best interests of vulnerable individuals, including children, youth, and at-risk adults, in all its activities and decisions.
Confidentiality: All safeguarding concerns will be handled with the utmost confidentiality, ensuring that only those who need to know are informed, and that the privacy and dignity of all parties involved are protected.
Empowerment: The African Center empowers individuals to speak out about safeguarding concerns. We will ensure that all individuals are aware of their rights and have access to safe and confidential reporting mechanisms.

4. Roles and Responsibilities

Role of the Board

Ensuring adequate measures are in place to assess and address safeguarding risks.
Putting in place adequate safeguarding policies and procedures, including relevant HR matters.
Making sure policies and procedures are effectively applied in practice and that mechanisms are in place to provide assurance on compliance.
Ensuring those safeguarding policies, practice, and performance are robustly and regularly reviewed to ensure they are up to date and fit for purpose.
Actively promoting a safe culture and strong awareness of everyone’s safeguarding responsibilities.
Taking steps to help deter and prevent safeguarding issues from occurring.
Ensuring there are mechanisms in place to promptly identify and act upon emerging safeguarding trends or issues.
Ensuring that serious incidents are reported to the appropriate authorities.

Role of the Safeguarding Officer’s Team

Ensuring awareness raising/training is undertaken for staff and stakeholders.
Ensuring the policy is implemented.
Discussing safeguarding matters at Strategic Management Team meetings at periodic intervals to help ensure progress and address any challenges with implementing the policy and any cases arising.
Presenting an annual safeguarding report on any instances and action taken/lessons learned to the Board.

Role of the Safeguarding Officer

Receive and register reports of abuse of Vulnerable Persons from African Center staff or staff of African Center’s partners where abuse is observed or suspected.
Collect additional information as appropriate.
Assess risk.
Consult with African Center’s leadership, legal staff, programme staff and Line Managers as appropriate.
When appropriate, consult with external organisations including partners, local agencies, and community leaders.
Make a formal referral if appropriate to the African Center Senior Management, African Center’s partners or local authorities.

If any of the following incidents occur, an African Center staff member must make a report to the Safeguarding Officer:

Abuse is observed or suspected.
An allegation of abuse is made.
A vulnerable Person discloses abuse.
A complaint is made about the possible abuse or exploitation of a Vulnerable Person by an African Center staff member or partner.

Upon receipt of the report, the Safeguarding Officer shall act as appropriate, following the reporting procedures.

Role of Line Managers

Ensuring all new employees receive policy training as part of their induction and onboarding.
Ensuring measures are implemented within their area of responsibility.
Following up and addressing issues appropriately.

Role of HR Staff

Implementing the necessary protective procedures when recruiting new staff.
Documenting who has signed the policy.
Ensuring that briefing on this policy is built into Induction processes.

Role of African Center Staff

Adhering to this policy and the Code of Conduct.
Reporting concerns using the Whistleblowing policy and procedures set out in the Code of Conduct.

African Center staff working on project development or monitoring must be alert to possibilities of the abuse and exploitation of Vulnerable Persons. If such abuse or exploitation is observed, it is the duty of African Center staff to inform the Safeguarding Officer. The staff member should not attempt to investigate the allegation or to discuss it further other than with the Safeguarding Officer who is responsible for further investigation and, if necessary, referral to the police and/or appropriate local authority in the jurisdiction where the reported incident has or may have taken place.

Where a project includes working directly with vulnerable persons (e.g. young people taking part in a workshop), a risk assessment must be carried out in advance and approved by a member of staff. This will include factors such as travel to/from the event; the need for chaperones; safe spaces; access to washrooms; and parental consent.

5. Protecting Vulnerable People

a. African Center staff, Board members, volunteers, and contractors (referred to as “staff” hereafter) shall adhere to the following principles:

All Vulnerable Persons have rights as individuals, without discrimination of any kind and irrespective of race, colour, sex, gender, language, religion, political or other opinion, national, ethnic or social origin, property, disability, sexual orientation, birth or other status.
All Vulnerable Persons have equal rights to protection from abuse and exploitation.
All Vulnerable Persons shall be encouraged to fulfil their potential and inequalities shall be challenged.
The welfare of Vulnerable Persons should be safeguarded and promoted.
Everybody has a responsibility to support the care and protection of Vulnerable Persons.
Non-profit or development organisations have a particular duty of care to Vulnerable Persons with whom they work and come into contact with and with whom their representative’s work.
If a non-profit or development organisation works through partners, they have a responsibility to meet minimum standards of protection for the Vulnerable Persons involved in their partners’ programmes.
Recognition of the importance of working in partnership with African Center’s Partners in the protection of Vulnerable Persons.
Staff will be viewed as representatives of African Center even when not in working hours, and their responsibility to act in accordance with this policy therefore applies at all times.

b. African Center staff shall strive to make African Center’s activities safe and the environment(s) caring for all people, and in particular Vulnerable Persons.

6. Reporting Abuse

The Safeguarding Officer, after being informed of an allegation, will make a preliminary assessment and determine the course of action appropriate to the seriousness of the alleged offence. As a matter of principle, once it is decided that an alleged abuse needs to be investigated, then the Safeguarding Officer will disclose all relevant information to the Management.

The following are key steps in any process to substantiate any reported allegations:

a. Investigate

The Safeguarding Officer will consult with the African Center Line managers as appropriate; if the abuse occurred within the context of a project, both the relevant Project Director and the relevant programme lead will be consulted. The allegation will be investigated and the individual(s) concerned informed of the allegations against him or her, and the course of action to be taken.

At the same time, the Safeguarding Officer will ensure that all information in the possession of the individual suspected is secured for investigation. If appropriate to safeguard African Center during the investigation period, the individual alleged to have committed the abuse may be taken out of his/her position. This may mean the individual is put into another position, put on leave with pay or suspended without pay.

b. Collect evidence

Depending on the magnitude and the complexity of the offense, investigations will be carried out by the African Center Office or, where deemed appropriate, by local authorities such as the police. The involvement of external parties must be approved by the Safeguarding Officer.

c. Report

Ensuring a report is issued on a timely basis detailing the findings and conclusions of the investigation, including recommendations for action to be taken. The report will only be disclosed to the Executive Director and Board, and others with a need to know. This is important to avoid damaging the reputation of those suspected of wrongdoing and subsequently found innocent.

d. Action

In all cases, the course of action will be determined in consultation with the relevant Director and African Center’s legal staff.

7. Safeguarding Measures

Recruitment and Vetting: All staff, volunteers, and contractors will undergo thorough background checks and vetting processes to ensure they are suitable for working with vulnerable groups.
Training and Awareness: Mandatory safeguarding training will be provided to all staff, volunteers, and relevant partners. This training will be regularly updated to reflect best practices and emerging risks.
Code of Conduct: The organization will maintain a Code of Conduct that outlines expected behaviors and responsibilities concerning safeguarding. All individuals associated with The African Center must agree to and adhere to this Code of Conduct.
Safe Programming: All programs and activities will be designed and implemented with safeguarding considerations in mind, ensuring that they do not expose individuals to harm or exploitation.

8. Monitoring and Review

This Safeguarding Policy will be reviewed annually, or more frequently if needed, to ensure it remains relevant and effective. The organization will regularly monitor safeguarding practices and update the policy as necessary.

Approved By:

Jideani Agabaidu
Board Chairman
Date: 28 April 2025

Juliet Ibekaku-Nwagwu
Executive Director
Date: 28 April 2025

Statement of Commitment to Safeguarding

The African Center is committed to creating a safe and inclusive environment for all individuals associated with our organization, including staff, volunteers, beneficiaries, and partners. We believe that everyone has the right to be treated with dignity and respect, free from harm and exploitation.

We recognize the power imbalances that can exist within our organization and the communities we serve, and we are committed to addressing these inequalities. We will strive to create an organizational culture where individuals feel empowered to report any concerns or incidents without fear of reprisal.

Zero Tolerance for Bullying, Harassment, Sexual Exploitation, and Abuse

The African Center has a strict zero-tolerance policy towards bullying, harassment, sexual exploitation, and abuse in any form. We condemn these behaviors as unacceptable and will take all necessary steps to prevent, investigate, and address such incidents.

We are committed to:

Prevention: Implementing comprehensive measures to prevent bullying, harassment, sexual exploitation, and abuse, including staff training, awareness-raising campaigns, and the development of clear policies and procedures.
Reporting: Creating a safe and confidential reporting mechanism for individuals to disclose incidents without fear of retaliation.
Investigation: Conducting prompt, impartial, and confidential investigations of all reported incidents.
Support: Providing support and assistance to victims of bullying, harassment, sexual exploitation, and abuse.
Accountability: Taking appropriate disciplinary action against individuals found to have engaged in such behavior.

We will work collaboratively with other organizations and stakeholders to promote safeguarding standards and best practices.

This statement is a living document that will be regularly reviewed and updated to reflect best practices and evolving needs.

By signing this statement, we reaffirm our commitment to safeguarding and creating a positive and respectful environment for all.

Legal/Compliance Adviser