Safeguarding Policy

INTRODUCTION

The Policy Innovation Centre (PIC) is committed to promoting a safe, respectful, and inclusive environment for all individuals it engages with. The organization upholds a zero-tolerance approach to all forms of harm, abuse, neglect, exploitation, and misconduct, including sexual exploitation and abuse, harassment, bullying, discrimination, and any practices that compromise the dignity, safety, or well-being of individuals. PIC strictly prohibits such conduct by its employees, directors, officers, agency workers, seconded staff, volunteers, interns, agents, external consultants, third-party representatives, suppliers, and business partners, all of whom are expected to uphold the highest standards of integrity and safeguarding.

PIC recognizes that certain groups, including children, women, and vulnerable adults including persons with disability, may face heightened risks and affirms the right of all individuals especially those under 18 to equal protection from harm, regardless of personal characteristics. This policy applies at all times, including outside regular working hours and across all engagement contexts. PIC is committed to ensuring that all staff, associates, and partners understand and fulfill their safeguarding responsibilities, fostering a culture of accountability, and ensuring that all concerns are addressed promptly and appropriately.

This policy informs PIC staff and associated personnel of their responsibilities regarding safeguarding and complements other key PIC policies, including:

Bullying and Harassment – addressed through PIC’s Respect at Work Policy;
Sexual Harassment – addressed through PIC’s Prevention of Sexual Exloitation, Abuse and Harassment Policy; and
Code of Conduct – which sets out expected professional behavior and ethical standards.
Duty of Care –

SCOPE AND APPLICABILITY

This policy applies universally and without exception to every individual who is engaged, directly or indirectly, in any project-related activity, regardless of contractual status, location, or duration of involvement.

Category	Non-exhaustive Examples
Personnel	All staff (permanent, temporary, international, national), consultants, interns, volunteers, enumerators, researchers, facilitators, trainers, board members
Implementing & Delivery Partners	Lead agencies, sub-grantees, consortium members, community-based organizations, cooperatives, local and international NGOs
Contractors & Related Personnel	Contractors & Related Personnel Vendors, suppliers, transporters, drivers, security firms, caterers, logistics providers, interpreters, fixers, casual laborers, community mobilisers
Third-Party Representatives	Government secondees, visiting donors, auditors, media crews, photographers, evaluation teams
Settings & Contexts	Offices, warehouses, project vehicles, field sites, training venues, community events, distributions, household visits, digital and online platforms, social media interactions, private residences used for project purposes, emergency or overnight settings

The policy binds all listed individuals and entities for the full duration of their association with the project, including preparation, implementation, monitoring, evaluation, and closure phases, and extends to any conduct that impacts on the project’s reputation or the safety of beneficiaries and staff.

RESPONSIBILITIES

The Executive Director is responsible for:

Ensuring adequate measures are in place to assess and address safeguarding risks.

Approving and overseeing safeguarding policies, procedures, and relevant HR processes.

Ensuring policies and procedures are effectively implemented and compliance mechanisms are in place.

Regularly reviewing safeguarding policies, practices, and performance to ensure they remain fit for purpose.

Promoting a strong safeguarding culture and awareness of responsibilities across the organization.

Taking proactive steps to deter and prevent safeguarding issues.

Ensuring mechanisms exist to identify and respond to emerging safeguarding risks and trends.

Ensuring serious safeguarding incidents are reported to the appropriate authorities.

The Strategic Management Team (SMT) is responsible for:

Ensuring effective implementation of the safeguarding policy across the organization.

Integrating safeguarding into strategic and operational discussions.

Reviewing safeguarding matters periodically to track progress and address implementation challenges.

Presenting an annual safeguarding report to the Board, including cases, actions taken, and lessons learned.

The Safeguarding Officer is responsible for:

Serving as the focal point for safeguarding within the organization.

Providing guidance and support on safeguarding concerns and case management.

Coordinating safeguarding awareness and training for staff and stakeholders.

Draft Safeguarding policy

Developing safeguarding protocols for projects to ensure risks are identified, mitigated, and managed throughout implementation.

Managers/Team Leads are responsible for:

Ensuring safeguarding is embedded within their teams and areas of responsibility.

Ensuring all new employees receive safeguarding training during induction.

Implementing safeguarding measures in day-to-day operations.

Following up on, addressing, and escalating safeguarding concerns appropriately.

Human Resources (HR) is responsible for:

Implementing safeguarding considerations in recruitment processes, including necessary background checks.

Documenting staff acknowledgment and sign-off of the safeguarding policy.

Support the coordination of safeguarding awareness and training for staff and stakeholders.

Ensuring safeguarding briefings are incorporated into induction processes.

Advises on how safeguarding breaches will be handled within the existing disciplinary framework, ensuring fairness, confidentiality, and due process for staff involved.

Gender Team is responsible for:

Integrating gender considerations into all safeguarding activities to ensure vulnerable groups, including women and girls, are protected.

Supporting the Safeguarding Officer in awareness-raising and training initiatives with a gender-sensitive approach.

Advising on policies, programs, and project protocols to ensure gender-responsive safeguarding practices.

Monitoring and reporting gender-specific safeguarding concerns and trends.

All Staff and Associated Personnel are responsible for:

Adhering to this policy, the PSEAH Policy, the Code of Conduct, and all other complementary policies as listed in this policy.

Maintaining appropriate professional behavior and upholding safeguarding standards.

Promptly reporting any safeguarding concerns using the whistleblowing policy and reporting procedures.

CONTEXT

What is Safeguarding?

At the Policy Innovation Centre (PIC), safeguarding means creating and maintaining a safe, respectful, and inclusive environment where all individuals are protected from harm, abuse, neglect, exploitation, and discrimination. This applies to everyone PIC engages with, particularly children, women, and vulnerable adults. Safeguarding encompasses all forms of harm, including physical, sexual, emotional, and financial abuse, neglect, discrimination, and any conduct that endangers or exploits individuals. The Policy Innovation Centre (PIC) is committed to safeguarding and expects a proactive commitment from all staff, associates, partners contractors and stakeholders both national and international to prevent and respond to any form of abuse, exploitation, or neglect of vulnerable persons. Abuse is any behaviour or action towards a person that causes harm, endangers life, or violates their rights. Examples include, but are not limited to:

Physical abuse: Any act causing physical harm, injury, or pain.

Sexual abuse: Any sexual activity without consent or imposed upon a person, including sexual relations with a person below the age of 18, regardless of the age of consent.

Sexual exploitation:

Engaging in sexual relations with vulnerable individuals in exchange for money, goods, or services.

Use of prostitutes, even if legally permissible locally, when linked to PIC activities.

Commercial exploitation: Including child labour, forced labour, or modern slavery.

Financial or material abuse: Stealing, denying access to money or possessions, or requiring favours in exchange for access to PIC resources, projects, or benefits.

Emotional abuse: Behaviour that causes psychological harm, fear, or distress.

Neglect and negligent treatment: Failure to provide necessary care or protection, leading to harm or risk of harm.

Discrimination: Abuse motivated by prejudice or discriminatory attitudes toward age, race, religion, gender, disability, sexual orientation, or cultural background

GUIDING PRINCIPLES

These six principles form the non-negotiable foundation for every decision, procedure, and interaction under this policy. They apply to all PIC personnel, partners, and related entities, ensuring the protection, dignity, and well-being of all individuals engaged with or affected by the organization.

Principle	Definition & Core Commitment	Key Requirements & Practical Application
Zero Tolerance	All forms of harm, abuse, neglect, exploitation, and misconduct are completely unacceptable, irrespective of context, intent, cultural norms, or perceived consent.	* Immediate protective action upon any allegation, suspicion, or report. * No mediation, informal settlement, or “cultural” excuses. * Suspension of alleged perpetrators from contact with affected individuals, where relevant. * Mandatory reporting within 24 hours. * Disciplinary sanctions up to termination and referral to appropriate authorities.
People-Centred Approach	The rights, needs, dignity, safety, agency, and informed consent of affected individuals guide every step of prevention, reporting, investigation, and assistance.	* Prioritise safety and well-being above all else. * Individuals decide whether to report, receive services, or participate in investigations. * Informed consent required before any action (medical, legal, information-sharing). * Terminology respects the individual’s preference. * No pressure to forgive, confront, or reconcile.
Do No Harm	All safeguarding actions must prevent further physical, psychological, social, or economic harm to affected individuals, complainants, witnesses, or their families.	* Continuous risk assessment at every stage. * Protection from retaliation, stigma, ostracism, or backlash. * Minimise repeated storytelling and unnecessary interviews. * Secure handling of personal data. * Avoid actions that could jeopardize safety or future justice options.
Accountability & Transparency	Leaders, managers, and the organization are fully responsible for proactively preventing harm, responding decisively, and maintaining open, traceable systems.	* Visible leadership commitment and modelling of ethical behaviour. * Clear documentation and tracking of every case. * Publicly available reporting channels and procedures. * Regular reporting (without identifying individuals) to governance bodies. * Enforced consequences for individuals or organizations that fail standards.
Confidentiality	Information about concerns, affected individuals, and investigations is shared strictly on a need-to-know basis and only with explicit consent where required.	* Encrypted storage and restricted access to case files. * No discussion of cases in public or with unauthorized persons. * Breach of confidentiality is treated as gross misconduct. * Individuals control what information is shared and with whom.
Inclusivity & Non-Discrimination	Safeguarding prevention, reporting, and response mechanisms are accessible, equitable, and free from discrimination on any grounds, including gender, age, disability, ethnicity, religion, sexual orientation, marital status, HIV status, occupation, or any other characteristic.	* Materials and channels available in accessible formats. * Gender-balanced and diverse safeguarding focal points. * Special accommodations for children, persons with disabilities, and marginalised groups.

PREVENTION:

PIC’S Obligation

The Policy Innovation Centre asserts that every individual has the right to live without being exploited or abused sexually. It unequivocally condemns any behavior from its staff, associates, or partners that jeopardizes the safety of beneficiaries or communities. In pursuit of this commitment, PIC pledges:

To providing a safe workplace for its employees and those affiliated with PIC.
Address complaints and concerns promptly and seriously through our Safeguarding Committee.
Educate and train staffs, associates, and partners that sexual exploitation and abuse are considered severe misconduct and may result in termination of employment and legal action.
Maintaining a zero-tolerance stance against any form of abuse.
Ensuring that all staff, associates, and partners have access to safeguarding policy and all as well as other relevant safeguarding policies.

All Staff and Associated Personnel

Child Safeguarding

PIC staff and associated personnel must not directly or indirectly engage in any of the following actions:

Engage in sexual activity with anyone under the age of 18;

Sexually abuse or exploit children;

Subject a child to physical, emotional, or psychological abuse, or neglect;

Engage in any commercially exploitative activities involving children, including child labour or trafficking; or

Undertake any activity with a child, including conversations, interviews, photos, video or audio recording, or requesting any action from them without ensuring the child’s safety and well-being during and after the engagement, following ethical practices for recording, and obtaining the express, fully informed, written, or recorded consent of a parent, adult guardian, or caregiver.

Adult Safeguarding

PIC staff and associated personnel must not directly or indirectly engage in any of the following actions:

Sexually abuse or exploit at-risk or vulnerable adults;

Subject at-risk or vulnerable adults to physical, emotional, or psychological abuse, or neglect; or

Undertake any activity with an at-risk or vulnerable adult including conversations, interviews, photos, video, or audio recording, or requesting any action from them without ensuring their safety and well-being during and after the engagement, following ethical practices for recording, and obtaining their express, fully informed, written, or recorded consent, or that of a parent, adult guardian, or caregiver where appropriate.

Protection from Sexual Exploitation and Abuse

PIC staff and associated personnel must not directly or indirectly engage in any of the following actions:

Exchange money, employment, goods, or services for sexual activity. This includes any exchange of assistance meant for beneficiaries; or

Engage in any sexual relationships with beneficiaries of PIC assistance, as such relationships are based on inherently unequal power dynamics.

In addition, PIC staff and associated personnel are obliged to:

Contribute to creating and maintaining an environment that prevents safeguarding violations and supports the full implementation of this Safeguarding Policy; and

Report any concerns or suspicions regarding safeguarding violations by PIC staff or associated personnel to the designated Safeguarding Officer

OUR APPROACH

PIC’s safeguarding approach is guided by the Rights-Based Approach (RBA) and the Survivor-Centred Approach, and informed by international standards, including the IASC Gender Marker framework. This ensures that our safeguarding process is not only responsive, but also preventive, risk-informed, and gender-sensitive.

Awareness: PIC ensures that all staff, representatives, and affiliated third parties understand and uphold high standards of behaviour, grounded in respect for human rights, dignity, and non-discrimination. Awareness efforts are informed by ongoing analysis of safeguarding risks and vulnerabilities across different groups, recognising how gender, age, disability, and context shape exposure to harm.

Reporting: PIC promotes a safe, accessible, and inclusive environment where anyone can raise concerns or complaints without fear of retaliation. Reporting mechanisms are designed to be confidential, survivor-centred, and accessible to diverse groups, recognising barriers to reporting and differences in access.

Investigation: PIC adopts a survivor-centred and rights-based approach to investigations, working with survivors and complainants to determine their preferred course of action. Individuals retain the right to pursue external legal or administrative options. Investigations are conducted fairly, confidentially, and without bias, ensuring due process while prioritising safety and protection from retaliation.

Support: PIC ensures that survivors are treated with dignity and respect, and have access to appropriate, timely, and confidential support services throughout the reporting and investigation process, regardless of whether a formal complaint is made. Support is tailored to individual needs and informed by an understanding of differential vulnerabilities and risks.

CONFIDENTIALITY OF COMPLAINT

Confidentiality is crucial in PIC. We handle incidents with survivors and others involved respectfully and confidentially. We understand that breaches undermine trust. Preserving confidentiality, especially in cases of harassment and abuse, is essential for safety and privacy. The information is shared only with those who require it for investigation or accountability. In cases of child abuse, reports are treated confidentially to safeguard the child and guardians’ privacy,and are shared only with those who genuinely need it. However, child protection takes precedence over confidentiality, highlighting the importance of sharing information when necessary for a child’s safety.

WHISTLE-BLOWING

Internal whistleblowing at PIC involves staff members reporting observed unethical conduct through the Reporting Channels Provided. Only the Executive Director the Safeguarding Officer and the Human Resource receive these reports. The Disciplinary Committee, chaired by the Chairperson, investigates the cases. Reports include but not limited to the background details and evidence, along with reasons for concern. Whistleblowers remain anonymous but can choose to be contacted for clarification. PIC ensures protection from harassment for whistleblowers.

CONSEQUENCES

Any breach of safeguarding standards is considered a serious form of misconduct and may result in disciplinary action, including termination of employment, referral to law enforcement authorities, and termination of sub-grants or partnerships where applicable. All disciplinary actions will be carried out in accordance with the laws of the Federal Republic of Nigeria. Staff or associated personnel found responsible for safeguarding violations will be ineligible for future engagement with PIC. False and malicious allegations of safeguarding violations are also taken seriously and may result in disciplinary action, including dismissal.

TRAINING AND AWARENESS

PIC is committed to ensuring that all staff and associated personnel are adequately equipped to uphold safeguarding standards through:

Regular training on safeguarding policies and procedures;

Continuous communication reinforcing a zero-tolerance approach to safeguarding violations;

Context-specific and role-based training, including through platforms such as the Gender Foyer;

Ensuring all staff understand safeguarding definitions and principles outlined in this policy; and

Ensuring all staff are fully aware of reporting procedures and their responsibilities in raising concerns.

ACCOUNTABILITY

The Policy Innovation Centre (PIC) is committed to thoroughly assessing all risks associated with safeguarding concerns, including Sexual Exploitation, Abuse, and Harassment (SEAH), involving any individual alleged to have caused harm or the complainant. Where investigations determine that allegations are substantiated, PIC will take appropriate and proportionate disciplinary action, in line with its policies and the laws of the Federal Republic of Nigeria.

ORGANISATIONAL LEARNING

PIC will actively apply lessons learned from safeguarding incidents to strengthen its systems and practices. This includes:

Reducing the risk of recurrence of safeguarding incidents;

Informing and improving policies, procedures, and programme implementation across all functions;

Identifying and addressing systemic gaps or weaknesses in safeguarding practices;

Promoting greater awareness and understanding of safeguarding risks and their impact on individuals, partners, and communities served by PIC.

REPORTING OBLIGATIONS

All PIC Staff and Associated personnels have a duty to report any concerns or suspicions of safeguarding breaches, including inappropriate behaviour towards any beneficiary or service user, whether a child or an adult.

REPORTING CHANNELS

Any safeguarding concerns must be reported through the official PIC safeguarding channels, following the organization’s safeguarding procedures. Staff, partners, and associated personnel are encouraged to use any of the available reporting options to ensure concerns are addressed promptly and appropriately.

Hotline: +234 911 237 9606

Email: [email protected]

If you wish to use our reporting platform Click here

If you wish to use our reporting form Click here

Appendix A: Glossary


Child	Any person under 18 years, irrespective of local country definitions of when a child reaches adulthood
Vulnerable adults/Adult at-risk	An individual aged 18 or older who, due to physical, social, economic, environmental, or other factors, may be at a heightened risk of experiencing abuse, exploitation, or other forms of harm.
Physical Abuse	Physical abuse is a violence, including hitting, kicking, choking, or using weapons, causing harm regardless of intent. It’s not discipline, even if claimed as such.
Child Abuse	Child abuse encompasses physical/emotional harm, sexual abuse, neglect, or exploitation within a relationship of trust/power, endangering the child’s well-being and dignity.
Neglect	Neglect can include depriving a child of education, food, or basic care, which can be as harmful as physical abuse. Due to their vulnerability and reliance on adults, children are especially at risk of neglect.
Forced marriage	Forced marriages are unions where one or both parties, irrespective of age, haven’t willingly provided their consent to the marriage. The PIC actively campaigns against forced marriages, particularly when involving children.
Sexual Abuse	Sexual abuse involves any actual or threatened sexual intrusion by force or in unequal conditions, such as sexual assault or rape. When it comes to children, sexual abuse entails engaging them in sexual activities, regardless of their awareness. These activities may include physical contact like rape or non-penetrative acts like masturbation, as well as non-contact actions like exposing them to sexual images or grooming them for abuse. It’s important to note that sexual abuse can be perpetrated by adults of any gender, as well as by other children.
Sexual Exploitation	Sexual exploitation involves abusing power or trust for sexual gain, including invasion of privacy, forced sex, non-consensual filming, online grooming, and spreading STDs. Child exploitation includes forced labor, trafficking, and involvement in armed conflict. Child sexual exploitation occurs when someone exploits a power imbalance to coerce a child into sexual activity for personal gain, even if it appears consensual, and may involve technology.

Appendix B: Associated policies

PIC has the following specific policies that are related to and support PIC’s ensuring high standards of safeguarding:

Code of Conduct

Duty of Care

Prevention of Sexual Exploitation Harassment and Abuse

Child Safeguarding

Respect at Work

Whistle-blower

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