Purpose of Policy Guidance Tearfund is committed to supporting our partners develop and implement key policies and procedures in order to progress towards best practice and operational excellence. For all policies the basic criteria must be included. Gold criteria will improve the policy, but they are not required. The purpose of this document is to equip Country Staff, Cluster Safeguarding Focal Points and Cluster Compliance Officers to assess partner policies (existing or new) to ensure that the necessary content is captured. Follow-up questions to ask the Partners to ensure that the policy and procedures are being implemented can also be found in PD-G4 Monitoring Visit Checklist. When thinking about a partners policy please also consider the reputational risk to the partner or Tearfund if an issue came to rise and how the policies would mitigate against that. When the partner sends in a policy it is checked by the country team against this guidance. Support will be given by the appropriate cluster roles. Safeguarding policy Safeguarding template Basic content to be captured in policy or other relevant documents: ● ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation The policy and procedure are known by the staff at induction and through regular training so that safeguarding is everyone's responsibility The policy must be workable in the partners context and comply with the local laws Definition of safeguarding Definition of Children (everyone under 18 years) Definition of vulnerable adults (anybody over 18 that has particular care, support or special needs or when the person is dependent or reliant on others. Conflict and disasters might also be the cause of some of these short term or long term vulnerabilities. A vulnerable adult is also whoever identifies themselves as unable to take care of themselves or to protect themselves from harm/exploitation.) A statement that recognises the organisations duty of care towards children and vulnerable adults, and that all children and adults have rights to protection from harm Description of different types of abuse (see template safeguarding policy) Scope of policy - all staff, volunteer and representatives All staff, volunteers and representatives must immediately report any concerns 1 ● ● ● ● ● ● ● A statement that partner organisations (third parties to Tearfund) must either have their own safeguarding policy or abide by the organisations Commitment to annual training Assignment of safeguarding focal point Prevention procedures - risk assessments, safe recruitment, code of conduct, programme design, images, media / communication, training Reporting procedures - point of contact, email, phone number, expected response times Response procedures - investigation, monitoring, review Reference to the code of conduct Gold level content which would improve the safeguarding policy: ● ● ● ● ● ● The policy has clear statements about identifying and mitigating organisational and programmatic safeguarding risks Clear job descriptions including safeguarding responsibilities are mentioned It outlines how new staff and representatives receive information on the organisation's safeguarding commitments and are trained. There is a clear commitment to disseminate the safeguarding policy and its principles to the beneficiaries and communities. Beneficiary and child friendly community posters are displayed in offices and field sites. There is a description and process in place to address neglect which is made unknowingly Fraud and Bribery Policy Fraud and Bribery Template Policy Basic content to be captured in policy or other relevant document: ● ● ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation The policy must be workable in the partners context and local legislation Definitions of Fraud, Bribery, Loss and Corruption - consider the legislative definition within the country Definition of Loss Statement that the organisation has a zero tolerance for fraud, bribery and corruption Scope of policy - all staff, volunteer and representatives Statement that all staff, volunteers and representatives are responsible for reporting fraud, bribery or corruption Reporting mechanisms: reference to whistleblowing policy and code of conduct List of instances who will be notified in a fraud case Consequences for perpetrating fraud, bribery or corruption A statement that all efforts will be made to recover losses 2 ● Outlining steps the organisation takes to reduce the risk of fraud, bribery and corruption Gold level content which would improve the fraud and bribery policy: ● ● ● Response procedure Legal references Values statement Countering Crime and Terrorism Financial Sanctions, Anti-Terrorism and Anti-Money Laundering Policy Template Basic content to be captured in policy or other relevant document: ● ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation The policy must be workable in the partners context Definitions of Terrorism, Money Laundering and Financial Sanctions Committment that funds will not be used for purposes of terrorism or money laundering Reporting mechanism: reference to whistleblowing policy All staff, volunteers, consultants and other representatives must immediately report if they believe that any funds have been used for terrorism or by a proscribed party Steps that will be taken to prevent use of funds by a proscribed party, for terrorism or money laundering (for example screening of partners and suppliers) Statement that the policy is applied in all programmes and operations The policy must cover both funds flowing into and out of the organisation Commitment to staff training Gold level content which would improve the countering crime and terrorism policy: ● ● ● ● Funding Sources Policy Screening procedure A list of specific responsibilities per role (i.e. who will do screening checks, who will clear potential matches, who will verify checks) Investigation and response procedure Whistleblowing policy Whistleblowing template 3 Basic content to be captured in policy or other relevant document: ● ● ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation The policy must be workable in the partners context Definition of whistleblowing: A confidential reporting method where an individual or group can report a concern or provide information to an organization regarding the wrongdoing or malpractice of an individual or group. Confidentiality for the person ‘Blowing the Whistle’ Protection for the person ‘Blowing the Whistle’ Example of whistleblowing incidents and concerns that should be raised. Referece to safeguarding, fraund and bribery, conflict of interest, countering crime and terrorism policies. Statement that the organisation takes malpractice seriously, commitment to transparency, openness and accountability Reporting procedures - point of contact, email, phone number Different ways of reporting for staff, partners and communities Response procedures - investigation, monitoring, review Includes anti-slavery and human trafficking Gold level content which would improve the whistleblowing policy: ● ● Reporting posters or flowcharts Training and communications plan Health and Safety Policy Health and Safety Policy Template Basic content to be captured in Health and Safety policy or other relevant document: ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation Scope of policy - all staff, volunteers and representatives, visitors (assets- secondary) The policy must be workable in the partners context and apply to all locations, the partner is based in Recognition that there is risk in the work of the organisation and how risks will be managed Statement that the partner has a duty of care to all its employees and people affected by its business Statement that all employees have responsibility to care for their own and colleagues and those they line manage health and safety at work. This should include responsibility to 4 ● ● follow management instructions, use health & safety equipment that is provided and to report any incidents. Failure to follow procedures may be a disciplinary issue. Staff and visitors cannot be required to take actions beyond acceptable levels of risk. Name a role with overall responsibility for health and safety, including delegates as applicable. Gold level content which would improve the Health and Safety policy: ● ● ● ● ● ● ● Reference to local health, safety and security legislation if applicable A risk appetite statement Risk assessments will be done for each location and each new project Incident reporting procedures Travel arrangements and safety and security arrangements for travel (i.e. safety briefings) Indication of what the organisation will provide in the case of an incident (i.e. medical care, money, prayer, pastoral support) Indicate whether the organisation has a policy on the following topics: kidnap and ransom, use of armed personnel, use of weapons and handling of ammunition etc. Personal Conduct Policy / Code of Conduct Code of Conduct Template Policy Basic content to be captured in Personal Conduct policy or other relevant documents: ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation The policy must be workable in the partners context Scope of policy - all staff, volunteers and representatives A Statement that lists how you would like staff to behave, for example: with integrity and honestly, trust, respectful, accountability, maintaining effectiveness, in line with organisational values etc. Principles: what we are committed to and how we want staff to behave in line with that. All staff must adhere to the laws and be respectful of local contexts Consequences of a breach (i.e. disciplinary action): the organisation will take fair and proportionate action Whom to refer to in case of any questions or doubts List of acceptable and unacceptable behaviours Gold level content which would improve the Personal Conduct policy: ● References to other policies: Conflict of interest, data protection, safeguarding, fraus, loss and bribery, health and safety, whistleblowing, policy on sharing faith etc. 5 Logistics and Procurement Policy Procurement Policy Template Basic content to be captured in Logistics and Procurement policy or other relevant documents: ● ● ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation The policy must be workable in the partners context Scope of policy - all staff, volunteers and representatives A Statement that all procurement of services, goods and work must be ethical, competitive, fair, transparent, appropriate, properly approved and in compliance with donor requirements. Reason for the policy: to ensure value for money and compliance with donor requirements Procurement thresholds which must not exceed Tearfund's limits, and procurement methods relative to the thresholds. ○ Note that thresholds should take into account total expected procurement value over the length of the contract. Option for a derogation and approval process for that. Authorisation roles and responsibilities, ensuring segregation of duties. Statement that ethical criteria when selecting suppliers are taken into account, such as child labour, human rights abuses, links to the arms industry or organised crime, etc. Statement that procurement information is kept confidential, and no supplier is made aware about prices quotes by a competitor or the internal budget, as this could give them an unfair advantage. Supplier performance is managed against each contract. Payments are made after receiving goods or services. Any upfront payments or payments in installments are pre-authorised by the management. Gold level content which would improve the Logistics and Procurement policy: ● ● ● ● ● ● Links to related policies: Personal Conduct Policy, Whistleblowing Policy, Fraud, Loss and Bribery policy, Conflict of Interest policy Procurement Procedure Reference to PARCEL Special arrangements for the first phase of emergency responses Statement that goods/services should be clearly specified at the start of the process References or special arrangements for sourcing pharmaceutical or medical goods and food, if required. In those cases adhere to local regulations and donor requirements and quality is ensured. 6 Conflict of Interest Policy Conflict of Interest policy template Basic content to be captured in Conflict of Interest policy or other relevant documents: ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board/synod / governing body and is being implemented throughout the organisation The policy must be workable in the partner’s context Scope of policy - all staff, volunteer and representatives Definition of Conflict of Interest, including the term “could influence or be seen to influence or constrain them” Definition of Conflict of Loyalty Definition of Personal Financial Interest Definition of Connected Persons Definition of Actual Conflict Definition of Perceived Conflict A Statement that all staff, trustees and other representatives will perform their duties and conduct their private lives in such a way that any conflict of interest with the organization's interests are avoided or managed properly. Process for declaring conflicts of interests Why the policy is needed: Conflicts of Interest that are not declared or properly managed result in risks for the organisation, such as financial, legal, compliance or moral risks. Outline of the responsibility of every staff member, volunteer, trustees or representative: avoid conflicts of interests, declare any conflicts of interest, manage any conflicts of interest carefully, comply with this policy and report any breaches Guidance on steps above, including reference to whistleblowing policy, and ways a conflict of interest can be managed through the removal of a person from conflict of interest, extra approval levels etc. Guidance on how to get a conflict of interest removed if it no longer exists Gold level content which would improve the Conflict of Interest policy: ● ● ● ● Conflict of Interest Form and where it should be submitted to Regular reminders to disclose conflicts of interests Conflict of interest register Links to related policies and procedures: whistleblowing, personal conduct, expenses, procurement Image Use Policy Image Use policy template 7 Basic content to be captured in Image Use policy or other relevant documents: ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● Dated within the last 3 years (review period) The policy has been approved by the board / synod / governing body and is being implemented throughout the organisation The policy must be workable in the partner’s context Scope of policy - all staff, volunteers and representatives, including freelancers used by the organisation Commitment to respect the dignity of the subject, including getting consent before taking any pictures or videos and not to exploit the subject. Commitment to providing a balanced portrayal of reality, including avoiding stereotypes and showing locals as agents for their own good commitment to using images truthfully, including not implying the image is of something that it is not or to deliberately misrepresenting the situation commitment to maintaining standards of taste and decency consistent with the organisation’s values and its supporters: no pornographic or obscene images, no images of dead or naked bodies commitment to maintain high technical standards, including use of highest quality images available, no manipulations (including cropping and editing videos) which might distort the reality commitment to respect the legal and moral rights of the photographer, including guidance on copyrights and working with third parties commitment to mitigating the risk to communities and individuals depicted, including adhering to the safeguarding policy guidance on consent Pseudonym guidance Guidance on public photography Guidance on storage and use of images, including storing metadata securely. Gold level content which would improve the Image Use policy: ● ● ● If using images in a general way this is noted in the description (i.e. there is a similar project to the one being described) No cropping of images which distort the reality being depicted Inclusion of Consent form template 8