Protection from Sexual Exploitation, Abuse and Harassment Policy

1. Statement of Commitment

The Diplomacy Training Program (DTP) is committed to a world in which all people can realise their human rights and live with dignity. Central to this vision is the recognition that all people have the right to be free from sexual exploitation, sexual abuse and sexual harassment (SEAH).

This Policy establishes DTP’s framework for protecting all people engaged with DTP from SEAH, and sets out DTP’s reporting and response procedures. DTP recognises that protection from SEAH is a shared responsibility for its Board, staff, partners and participants, and is committed to fostering a culture of safety, respect and accountability across all of its activities.

2. Scope

This policy applies to all DTP activities in Australia and overseas, and to anyone who represents DTP, is engaged by DTP, or participates in DTP programs. This includes, but is not limited to, DTP’s Board of Directors, DTP Personnel, DTP Partners, and Program Participants.

This policy operates in conjunction with DTP’s other policies and procedures, including the General Code of Conduct, Child Protection Policy, Complaints Policy, Incident Reporting Guidelines and Procedures, Gender Policy, Privacy Policy, and Whistleblower Protection Policy.

3. Guiding Principles

The following principles reflect the values and beliefs that underpin DTP’s approach to safeguarding and inform all aspects of this policy:

Zero tolerance
DTP has a zero-tolerance approach to SEAH in all aspects of its work, and zero tolerance for inaction to prevent, report or respond to SEAH. This commitment applies equally to the DTP Board of Directors, DTP Personnel, DTP Partners and Program Participants.
Human dignity and rights
DTP’s work is grounded in the belief that every person has the right to be treated with dignity and respect, and to be free from exploitation, abuse and harassment. These rights are universal and non-negotiable.
Victim-centred approach
DTP places the safety, rights, needs and wishes of victims at the centre of all safeguarding responses. Victims will be treated with dignity, compassion and respect.
Do no harm
DTP is committed to ensuring that its programs, activities and responses to SEAH do not cause further harm to those affected. All actions will be assessed for their potential impact on victims and vulnerable individuals.
Shared responsibility
Safeguarding is the responsibility of everyone associated with DTP. All DTP Personnel and DTP Partners share an obligation to prevent SEAH, to respond appropriately when it occurs, and to foster a culture of safety and accountability.
Inclusion and equity
DTP recognises that vulnerability to SEAH is not uniform. Factors including gender, age, disability, ethnicity, sexual orientation, socio-economic status and displacement can increase a person’s risk. DTP’s safeguarding approach seeks to be inclusive, equitable and responsive to these intersecting factors.
Cultural sensitivity
DTP works across diverse cultural contexts in the Asia-Pacific region. Safeguarding responses will be culturally informed and, where appropriate, developed in consultation with local partners and communities.
Confidentiality and privacy
DTP is committed to protecting the privacy of all persons involved in safeguarding matters and to handling personal information in accordance with its Privacy Policy and applicable law.

4. Broader Context

DTP delivers human rights training programs across the Asia-Pacific region, working with human rights defenders, community advocates, Indigenous peoples’ rights advocates, and other marginalised groups in Australia, Pacific Island nations, South-East Asia and South Asia. This work takes place in diverse settings, many of which carry inherent safeguarding risks.

SEAH causes serious and lasting harm to victims, including physical and psychological injury, loss of livelihood, damage to relationships and community standing, and re-traumatisation through inadequate responses. In international development and human rights contexts, SEAH also causes institutional harm which erodes trust, undermines program outcomes, and damages the communities that organisations like DTP exist to serve.

DTP’s operating context gives rise to specific safeguarding risks that make this Policy essential. These include:

Power imbalances
DTP’s programs involve relationships between staff, trainers and participants in which differential power, whether organisational, financial, cultural or social, can be exploited. Program participants and community advocates, particularly those from marginalised groups, may be especially vulnerable.
Remote and international settings
Many of DTP’s programs are delivered in countries where access to support services is limited, local legal frameworks may be less sophisticated, and oversight mechanisms may be less robust. These settings increase both the risk of SEAH occurring and the difficulty of responding effectively.
Participant vulnerability
DTP’s programs reach individuals who have often experienced significant hardship, including human rights defenders operating in high-risk environments, Indigenous peoples facing systemic discrimination, and persons from communities experiencing poverty, displacement or conflict. Such experiences can compound vulnerability to SEAH.
Third-party engagement
DTP works with a wide network of partners, trainers and other external individuals. This extends DTP’s safeguarding obligations beyond its immediate workforce and requires active due diligence and compliance measures.
Online and hybrid delivery
DTP’s programs include online and hybrid components, which create distinct risks including digital harassment, inappropriate contact through online platforms, and reduced visibility of participant wellbeing.

All DTP Personnel and DTP Partners are expected to understand this context and to apply the principles and requirements of this Policy accordingly.

5. Implementation of Policy

5.1 Zero tolerance for sexual exploitation, abuse and harassment

DTP has a zero-tolerance approach to sexual exploitation, abuse and harassment in all aspects of its work, and zero tolerance for inaction to prevent, report or respond to SEAH.
DTP Board Members, DTP Personnel, DTP Partners and Program Participants are strictly prohibited from engaging in any form of sexual abuse, sexual exploitation, or sexual harassment. Prohibited behaviour includes retaliation against anyone who makes (or is suspected of making) a SEAH report or raising a SEAH concern, or intimidating, threatening, or coercing any person to prevent them from reporting SEAH.
All DTP Personnel and DTP Partners must sign the DTP SEAH Code of Conduct located at Annexure A of this policy.
Breaching this policy may constitute serious misconduct that may justify the termination of the employment of DTP Personnel, a DTP Partner’s engagement with DTP, the appointment of a DTP Member of the Board, a Program Participant’s inclusion in DTP courses, or any other form of engagement or activity.
Criminal conduct will be reported to the relevant authorities.

5.2 Reporting incidents is mandatory

Mandatory and immediate reporting, and in any event within 24 hours, of all actual and suspected SEAH is required of all DTP Members of the Board, DTP Personnel and DTP Partners. The process of making a SEAH report is outlined in Section 7.
There is no mandatory reporting requirement for victims of SEAH. However, DTP strongly encourages victims to report any conduct they believe contravenes this Policy. DTP relies on this reporting to effectively respond to SEAH, provide support to victims, and prevent future instances of SEAH.

5.3 Take a victim-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. This approach treats victims with dignity and respect while ensuring procedural fairness to all parties.

5.4 Promote inclusion and equity

DTP Personnel and DTP Partners must ensure all actions and decisions are inclusive and equitable, recognising that people may be at increased risk of SEAH due to age, gender identity, sexual orientation, disability, ethnicity, socio-economic status, displacement, or other factors.
Efforts must address barriers to participation, protection, reporting, and support such as language, safety, discrimination and accessibility.

5.5 Procedural fairness

DTP is committed to conducting all SEAH investigations and responses in a manner that is proportionate and fair to all parties. Where legally permitted, a person against whom an allegation has been made will be informed of the nature of the allegation and given a reasonable opportunity to respond before any determination is made.
All investigations will be conducted without bias or predetermination of outcome.
DTP will endeavour to resolve all matters in a timely manner and will keep all parties informed of the progress of any investigation to the extent consistent with confidentiality obligations.

5.6 Prioritise prevention

This Policy must be shared with all DTP Personnel and DTP Partners.
DTP Personnel and DTP Partners must be proactive in minimising the risk of SEAH and creating a safe environment in all contexts, both in the physical environment and online.
Induction and ongoing training for DTP Personnel in relation to SEAH must be conducted annually to maintain DTP’s organisational commitment to PSEAH.
All Program Participants must receive a copy of the most recent PSEAH Factsheet (Annexure C).
DTP must include safeguarding clauses outlining DTP’s PSEAH expectations in all contracts, agreements, grants and memoranda of understanding.
DTP must complete context-level PSEAH risk assessments for all programs.
DTP must incorporate PSEAH assessments into the due diligence process for partners.
DTP recruitment processes must include screening and reference checks that address PSEAH.
Where required, DTP must support DTP Partners in developing their own SEAH policy and training that meet DTP’s standards.

6. Transactional Sex and Fraternisation

6.1 Transactional sex

Transactional sex is prohibited for all DTP Personnel, DTP Partners and Program Participants in high-risk settings.

6.2 Fraternisation

Fraternisation is prohibited for all DTP Personnel and DTP Partners in high-risk settings. Relationships that pre-date the relevant program or activity are not prohibited, provided they are disclosed to DTP in advance. Where fraternisation is disclosed, DTP will consider whether any conflict of interest or safeguarding risk arises and will take appropriate action.

7. Reporting SEAH

Anyone can raise a concern or make a complaint to DTP about something they have experienced or witnessed, without fear of retribution. There are several ways to report actual or suspected SEAH:

Lodge a report in writing using DTP’s Incident Reporting Form. This form is available at Annexure B of this policy and is provided to all program participants. Completed forms should be submitted to [email protected].
Make a verbal complaint in person to DTP staff or to the designated PSEAH Officer for the relevant program. The PSEAH Officer for each program will be identified in program induction materials and communicated to participants at the commencement of the program.
Make a verbal complaint by telephone on +61 2 9385 3549.

Where the PSEAH Officer is unavailable or implicated in the concern being reported, reports should be directed to your program coordinator or the Executive Director.

Anonymous reporting is available. DTP will act on anonymous reports to the extent possible, but may have limited ability to follow up with the individual or provide personalised support where the reporter has not been identified.

8. Responding to Reports of SEAH

8.1 Appropriate response

DTP will respond to concerns or issues raised in a timely and appropriate manner. This may include conducting a safe, formal and independent investigation if necessary. DTP may work with partner organisations to ensure that responses are culturally and gender appropriate and meet local legislative requirements.

8.2 Support for victims

DTP is committed to ensuring that victims have access to appropriate support throughout the reporting and response process. DTP will endeavour, to the extent possible in the relevant context, to assist victims to access counselling, medical care, legal assistance and other support services. The needs and wishes of the victim will be central to all support decisions.

8.3 Confidentiality

DTP will endeavour to maintain confidentiality during the investigation of SEAH complaints. Information that identifies individuals involved in a complaint will be limited to essential personnel and will not be shared further without obtaining the informed consent of those involved, except as required by law.

Individuals involved in the reporting/investigation process will be made aware of the importance of maintaining confidentiality and may be asked to sign a confidentiality agreement. DTP Personnel who breach confidentiality may be subject to disciplinary action up to and including termination of employment, and others who work with DTP may have their relationship with DTP terminated.

8.4 Complaints about DTP Partners

Where DTP receives a complaint or report about a DTP Partner, DTP will expect that entity to respond safely, quickly and appropriately. DTP will assist the DTP Partner to ascertain its reporting obligations. Where appropriate, DTP will work with the DTP Partner to address the issue through an appropriate independent investigation. If the outcome is that abuse has occurred, ongoing work with the DTP Partner may be terminated.

8.5 Legal obligations

In some instances, DTP may be required to provide details of a report or complaint to a regulatory or law enforcement agency. This may require DTP to identify the person who made, or who is involved in, the complaint or report to that agency.

8.6 PSEAH Officer

DTP’s PSEAH Officer is the recommended first point of contact for SEAH reports and is responsible for coordinating DTP’s response. The PSEAH Officer can be contacted at:

Email: [email protected]
Tel: +61 2 9385 3549
Attention: PSEAH Officer

9. Policy Review

The Board of DTP will review this policy periodically, and at least every three years, or sooner if practice or changes in legislation or funding obligations indicate the need for change.

Date of first adoption	August 2018
This revision adopted	April 2026
Date for renewal	March 2029

10. Definitions

Term	Definition
DTP Board of Directors	Members of DTP’s Board of Directors
DTP Partner	An organisation, supplier, or other service provider engaged by or connected to DTP.
DTP Personnel	A staff member, volunteer, trainer, or intern engaged by DTP.
Fraternisation	A romantic, sexual, or intimate relationship which occurs in the course of DTP activities.
High-risk setting	Any DTP training program, whether in Australia or outside Australia, or any DTP activity outside of Australia.
Safeguarding	Safeguarding and safeguards are measures taken to avoid or minimise the potential negative impacts of DTP’s operations, business activities and programs on the communities and environments in which we work and operate. In the context of this Policy, DTP seeks to promote safe and respectful workplaces and minimise the risks of SEAH in its operations.
SEAH	Sexual exploitation, sexual abuse and sexual harassment.
SEAH Code of Conduct	The DTP Sexual Exploitation, Sexual Abuse and Sexual Harassment Code of Conduct, included as Annexure A of this policy.
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.
Transactional sex	The exchange of sex or sexual acts for money, goods, services, employment, protection or other material or social benefit, including where such exchange occurs under conditions of unequal power, vulnerability or coercion.
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 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 occur in person, over the phone or online, including 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 pornographic material, and sharing or threatening to share intimate images or video without consent.
Program Participant	A participant in a training program run by DTP.
PSEAH	Prevention of sexual exploitation, sexual abuse and sexual harassment.

Annexures

PSEAH Code of Conduct
Incident Reporting Form
PSEAH Factsheet, March 2026