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Code of Conduct

ACLED’s policy on sexual exploitation, abuse, and harassment is outlined in our Code of Conduct for Protection from Sexual Exploitation, Abuse, and Harassment.

Authored by ACLED Human Resources
Effective as of 21 March 2022
Updated on 23 March 2023

INTRODUCTION

The Armed Conflict Location & Event Data Project (ACLED) does not tolerate sexual exploitation,
abuse, or harassment (SEAH) of any kind. This applies to our own organization and extends to those
we work with (e.g., partners, vendors, donors, etc.).

This Policy outlines both expectations and requirements for ACLED staff and our partners to manage
the risk of SEAH and SEAH incidents, should they occur in the delivery of ACLED business.

Preventing SEAH (PSEAH) is a shared responsibility. All organizations must play an active role in
addressing SEAH that occurs in the course of their business.

The Policy is able to be adapted to the many contexts in which ACLED activities are delivered.
ACLED staff and partners will need to apply judgment based on the risk context in which they are
operating. This includes ACLED-related trips and all communication using remote work tools, such as
email, instant messaging applications, and audio and video calls.

ACLED is committed to providing a safe environment for all staff members and partners. ACLED
abides by and commits to the standards outlined in the UN Secretary-General’s Bulletin (ST/
SGB/2003/13), focusing on special measures for protecting vulnerable populations from sexual
exploitation and abuse.

ACLED has a separate Safeguarding policy outlining how ACLED keeps people safe, setting out,
especially what we expect of everyone working with children, young people, and adults at risk of harm
in our projects. All ACLED employees are expected to acknowledge and comply with Safeguarding
and PSEAH policies.

DEFINITIONS

This Policy uses the following descriptions of sexual exploitation, sexual abuse, and sexual
harassment:

Sexual Exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or
trust for sexual purposes. It includes profiting monetarily, socially, or politically from sexual exploitation
of another.

Sexual Abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or
under unequal or coercive conditions. It covers sexual offenses including but not limited to: attempted
rape (which includes attempts to force someone to perform oral sex); and sexual assault (which
includes non-consensual kissing and touching). All sexual activity with someone under the age of
consent is considered to be sexual abuse.

Sexual Harassment: A person sexually harasses another person if the person makes an unwelcome
sexual advance or an unwelcome request for sexual favors or engages in other unwelcome conduct
of a sexual nature in circumstances in which a reasonable person, having regard to all the
circumstances, would have anticipated the possibility that the person harassed would be offended,
humiliated or intimidated.

Sexual harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated
or one-off, and perpetrated by any person of any gender towards any person of any gender. Sexual
harassment can be perpetrated against beneficiaries, community members, citizens, as well as staff
and personnel, and it can be in-person or virtual.

IMPLEMENTATION

Implementation of this Policy will be conducted in accordance with the ACLED Policy Implementation
Procedure, which provides guidance on communicating the policy to the organization.
All ACLED representatives share responsibility for the implementation and monitoring of this Policy.

Board of Directors: It is the responsibility of the Board of Directors to ensure that there is a robust
policy and procedure for reporting on SEAH, to monitor SEAH issues as it feels necessary, and to
decide whether to report serious incidents to the government or legal authorities.

Executive Director: The Executive Director must ensure that the organization has a designated staff
member (“Designated PSEAH Lead”) to support the implementation of this Policy and its associated
procedures and guidance. The Executive Director must ensure that the appointed individual has the
relevant knowledge, skills, and experience to fulfill responsibilities and that they have the time and
resources necessary for them to fulfill these responsibilities to the best of their abilities. The Executive
Director must ensure that all Board Members are made aware of the PSEAH Policy.

Designated PSEAH Lead: The purpose of the Designated PSEAH Lead is to champion the full
implementation of the Safeguarding Policy. They must fulfill their responsibilities to the best of their
abilities. When the Designated PSEAH Lead is unavailable, or an individual believes it would be
inappropriate to discuss a safeguarding matter with them, any ACLED representative with concerns
should contact the Executive Director directly or the Human Resources department.

Line Managers: All ACLED managers must ensure that the staff, volunteers, or consultants they
recruit or others for whom they have line-management responsibility or who they are holding the
relationship with, are made aware of the policy, relevant procedures, and guidelines. They are to
ensure they receive training and guidance appropriate to their role.

All ACLED Representatives: In addition to adhering to the principle of this policy, all representatives
who receive an allegation or disclosure of abuse from any source, or who suspect abuse or have a
wider concern about the risk of harm, must report this to the Designated PSEAH Lead.
In addition to this policy, the Designated PSEAH Lead must ensure that there is an appropriate range
of procedures and guidance relevant to our work. This will include:

• Safeguarding Policy
• Code of Conduct
• Recruitment and selection
• Induction, training, and on-going support
• Responding to a SEAH concern
• Confidentiality and information sharing
• Soliciting and publishing information and images
• Supporting our international partners to raise awareness and monitor and report SEAH
• Guidelines in specific circumstances
• Guidelines for fundraising from adults at risk

This policy and its associated Procedures and Guidance work alongside our wider policy framework.
Where there is any conflict between this policy and its associated procedures and other policies,
procedures, or established ways of working, the priority is always to protect people at risk of harm.

REPORTING

The Armed Conflict Location & Event Data Project (ACLED) is committed to taking all appropriate
measures to prevent sexual exploitation, abuse, or harassment of anyone by its employees, agents,
independent contractors, or any other persons engaged with ACLED to provide support and services
to clients of ACLED.

ACLED shall refrain from and shall take all reasonable and appropriate measures to prohibit its
employees or other persons engaged and controlled by it from exchanging any money, goods,
services, or other things of value for sexual favors or activities or from engaging in any sexual
activities that are exploitive or degrading to any person.

All ACLED staff and partners must report any alleged incidents of sexual exploitation, abuse, or
harassment or Policy non-compliance. Reporting is for any suspected or alleged cases of SEAH
perpetrated by anyone within the scope of the Policy in connection with official duties or business.

If in doubt, staff and ACLED partners should report an alleged incident. Individuals and organizations
found not reporting alleged incidents will be viewed as non-compliant.

How to Report: All reports of alleged SEAH incidents should be made to the ACLED PSEAH Lead,
which will be announced in the communication of this Policy to the organization, to the Executive
Director, or to the Human Resources department at [email protected].
Where safe to do so, and when in accordance with the wishes of the survivors and whistleblowers, all
alleged SEAH incidents that involve a criminal aspect should be reported through the correct local law enforcement channels.

SUPPORT FOR SURVIVORS

If a US-based employee is a victim of SEAH, that employee is referred to our organization’s
Employee Assistance Program (EAP). This service provides free and confidential assessments,
counseling, and follow-up services to employees. Selected services that might be of particular
relevance in this instance include the following:

• Telephone or virtual counseling for professional assessment for employees
• Legal consultation
• Employee trainings
• Online legal resource center
• Multicultural and multilingual providers available nationwide
• Emergency services available 24 hours/day, seven days/week

If the victim of SEAH is an international employee or one of our clients or consultants, they are
referred to an outside therapist. ACLED will work with our International Professional Employer
Organization (PEO) to provide adequate support, depending on the victim's country of residence.