Contents

Policy statement
Purpose and scope
Principles 
    Privacy and confidentiality
Definitions 
    Understanding Abuse
Responsibilities and expectations
Complaints and investigation procedure

  1. Initial contact
  2. Informal resolution
  3. Formal resolution
  4. Outcomes

Annex – Viamo Abuse Prevention Hotlines

Policy statement

Viamo has a zero-tolerance approach to all acts of abuse and exploitation involving Viamo team members in their interactions with other team members, partners and end users.

Viamo is committed to the safety and protection of children and vulnerable adults in the discharge of our work.

Viamo commits to take all complaints about incidents of abuse, or incidents where the safety of children or vulnerable adults is put in jeopardy, seriously. Viamo initiates rigorous investigation of complaints that indicate possible violations and takes appropriate disciplinary action, as warranted.

Purpose and scope

This policy reaffirms Viamo’s commitment to protect our team members, partners and end users from abusive behaviour, including unwanted and inappropriate sexual attention. The policy also aims to ensure the safety of children and vulnerable adults in the discharge of our work. 

This policy applies to complaints of abuse and exploitation involving Viamo team members. Throughout this document, the term abuse includes sexual abuse. The policy is also relevant in the interaction of Viamo team members with children and vulnerable adults in both a direct and/or unsupervised capacity for any Viamo project. 

The Safeguarding Policy on expected behaviour is not limited to what occurs within a Viamo workspace or during working hours. Inappropriate behaviour will not be tolerated at work, or anywhere else. 

Principles 

Viamo employs a holistic approach to preventing abuse and ensuring safeguarding. The approach comprises of: 

  1. Commitment to prevention through training and awareness 
  2. Strong, clear policy, including definitions, commitments, team member Code of Conduct
  3. Leadership support and commitment
  4. Company culture
  5. Clear, confidential complaints, reporting and response process.

Privacy and confidentiality 

All parties to a safeguarding complaint are expected to respect the privacy and confidentiality of all other parties involved and to limit the discussion of the complaint to those that need to know.

Viamo and all individuals involved in the complaint process, will comply with privacy legislation to protect personal information.

Definitions

Abuse – Offending or humiliating someone physically or verbally; threatening or intimidating someone; making unwelcome jokes or comments about someone’s race, national or ethnic origin, colour, religion, age, sex, sexual orientation, marital status, family status, disability or pardoned conviction.

Sexual abuse – is the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. This means that the use of actual force is not necessary to constitute sexual abuse. Sexual abuse can also occur in situations of inequality or under coercive conditions. 

Sexual exploitation – is any actual or attempted abuse of a person, or 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. This means that any individual acting as an intermediary in the organisation of abuse is equally guilty of exploitation.

Zero-tolerance – zero tolerance requires that every staff member, volunteer/intern, consultant and representative, and partner of Viamo at all levels of the organization take on the responsibility to act on rumors of and possible incidents of sexual harassment, sexual exploitation, and other forms of abuse, such as bullying. It requires that the organization respond to all verified incidents with disciplinary action, including dismissal, when appropriate.

Child – Any person below 18 years of age

Vulnerable adult – A person aged over 18 years may be vulnerable (temporarily or permanently) if they:

  • have a learning or physical disability
  • have a physical or mental illness, chronic or otherwise, including an addiction to alcohol or drugs
  • have a reduction in physical or mental capacity
  • are receiving any form of healthcare
  • are detained in custody
  • are receiving community or aid services because of age, health or disability
  • are living in a shelter, refugee camp or residential care home
  • are unable, for any other reason, to protect themselves against significant harm or exploitation.

Viamo team member – broadly includes all team members of Viamo, board members, volunteers, interns, international and local consultants.

Understanding Abuse

Abuse and exploitation can happen once or many times and may include physical, verbal or non-verbal actions. Individuals exposed to this kind of treatment may feel offended, humiliated or violated.

Definitions are provided within this policy for abuse. However, there are instances of abuse and exploitation which may be subjective and circumstantial. Key here is to consider Viamo’s Team Member Code of Conduct as a minimum and strive to maintain an even higher standard of professional conduct. An exhaustive list of behaviours cannot be provided, but below are some examples of ones which may constitute abuse:

  • Hostile gestures
  • Unwelcome teasing
  • Pushing, shoving
  • Sexual pranks, teasing, jokes
  • Verbal comments of a sexual nature
  • Physical touching of a sexual nature
  • Giving sexually suggestive gifts
  • Making sexually suggestive gestures
  • Posting sexually suggestive pictures

Abuse and exploitation may take the more direct form of aggressive, unwelcome behaviour. However, they may take the form of an exchange or a quid pro quo. An example would be offering some kind of benefit to a colleague, subordinate, partner or beneficiary in exchange for a sexual favour or threatening to withhold benefit if sexual favours are not granted. 

Viamo considers all such behaviour unacceptable. 

Responsibilities and expectations

Viamo’s Board of Directors is ultimately responsible for:

  • ensuring a framework is in place to promote the safeguarding of children and vulnerable adults and to prevent the abuse and exploitation of co-workers, beneficiaries and other collaborators in the discharge of the duties of Viamo team members.

Executive Director of Human Resources is responsible for:

  • ensuring that this policy is applied in a timely and consistent manner
  • ensuring the confidentiality of the case, particularly the complainant
  • ensuring the incorporation of job responsibilities (such as staff training, application of complaints and investigation procedure, and incident tracking) in specific job descriptions to ensure effective implementation of organizational strategies to prevent and respond to abuse
  • determining whether or not allegations of abuse are substantiated
  • determining what corrective action is appropriate where an allegation of abuse has been substantiated
  • taking swift and appropriate action against Viamo team members who perpetuate exploitation and abuse. This may include administrative or disciplinary action and/or referral to the relevant authorities for appropriate action, including criminal prosecution, in the abuser’s country of origin as well as the host country
  • providing reports on the safeguarding system, including data on complaints, to the Board of Directors, bi-annually or when appropriate
  • publishing Viamo’s Safeguarding Policy and making best efforts to ensure that Viamo engage in partnership only with organisations with similar policies in place / committed to align with Viamo’s policy.

Human Resources is responsible for:

  • providing regular training on this policy, including during onboarding, to ensure awareness and understanding of definitions and the complaints procedure
  • the day-to-day administration of this policy, including receiving complaints
  • maintaining appropriate records of every complaint and investigation, keeping these records confidential and ready for a routine audit by the Executive Director of Human Resources or Viamo’s Board of Directors
  • in compliance with applicable law and to the best of our ability, prevent perpetrators of exploitation and abuse from being hired/rehired or deployed/redeployed by Viamo. This could include the use of background and criminal reference checks.
  • undertaking a review of Viamo’s Safeguarding Policy at least every five years, making necessary adjustments to ensure that this policy meets the needs of the organization.

Managers are responsible for:

  • fostering a culture of zero tolerance to abusive behavior
  • setting an example about appropriate behaviour in the discharge of work
  • communicating the complaints and investigations procedure in the case of violation of the Safeguarding Policy
  • dealing with safeguarding incidents immediately upon becoming aware of them, whether or not a complaint has been made
  • taking appropriate action during an investigation, including separating the parties when appropriate, providing basic emergency assistance (medical, legal) and basic psychosocial support as appropriate and feasible
  • ensuring safeguarding incidents are dealt with in a sensitive and confidential manner.

Team members are responsible for:

  • treating co-workers, partners and beneficiaries with dignity and respect
  • acting in a manner that ensures the safeguarding of children and vulnerable adults in the discharge of their work
  • reporting incidents of abuse and/or exploitation perpetuated by Viamo team members that they observe or become aware of
  • cooperating fully with a harassment investigation 
  • respecting confidentiality related to the investigation process.

Team members can expect:

  • that reported abuse or exploitation will be dealt with in a timely, confidential and effective manner
  • to have their rights to a fair process and to confidentiality respected during an investigation
  • to be protected against retaliation for reporting abuse or cooperating with an investigation of abuse or exploitation.

End users, partners and the public can expect:

  • that Viamo team members have received training as to what constitutes abuse and exploitation
  • to have a clear, accessible confidential process to report incidents of abuse or exploitation involving Viamo team members where they arise.  

Complaints and investigation procedure 

1. Initial contact

Individuals wanting to make a complaint should do one of the following:

  1. Complete this short web form
  2. Phone a Viamo Abuse Prevention Hotline (please see annex for dial in details by country)
  3. Contact Viamo’s HR team at hr@viamo.io

Viamo’s contact person will:

  • acknowledge receipt within two working days 
  • be available to listen to concerns 
  • not form a view on the merit of any allegations
  • provide information about the complaint procedure
  • advise the person that in some situations where serious allegations are raised – for example, allegations that may expose the organisation to legal liability – the issue may need to be reported to management and dealt with as a formal complaint
  • where appropriate, provide support for a person if he or she wants to try and resolve the issue personally 
  • explain that the complainant can elect to have a friend, family member, or an impartial third person, accompany them during a formal complaint process for support
  • outline other options available to the person, such as lodging a complaint with an external agency or local authorities.

2. Informal resolution

In some situations it may be appropriate to consider informal resolution of an initial complaint without undertaking an assessment of its merit. This approach may be useful where:

  • the complainant indicates a desire to sit down and discuss the matter with the respondent informally and this seems appropriate in the circumstances
  • the information on hand supports a view that the complaint has arisen from a misunderstanding or miscommunication
  • the behaviour being complained about is not serious and does not appear to be abuse, as defined by the organisation’s policy.

Informal resolution may involve:

  • a direct private discussion between the complainant and the respondent
  • an impartial third person conveying information between those involved
  • an impartial third person helping those involved to talk to each other and find a solution.

In some situations the impartial third person may need to be someone external to the organisation, such as a professional mediator.

3. Formal resolution

If a person wants to proceed with a formal complaint, or if this is considered to be the most appropriate course of action, the following steps are recommended.

  1. Obtain information from the complainant

The person handling the complaint should:

      • provide information about the complaint process, potential outcomes and options for support and protection from victimisation
      • ensure the complaint is documented in writing
      • ask the complainant to provide relevant documents or details of witnesses that may support the allegations
      • explain that the process is confidential
      • explain what records of the complaint will be kept, and where
      • explain the action that may be taken if the complaint is found to be vexatious or malicious.

     2. Advise the respondent about the complaint

The person handling the complaint should:

      • advise the respondent that a complaint has been made against him/her and provide as much information as possible about the allegations and supporting information
      • confirm that the respondent will be given the opportunity to respond to the allegations in writing or through an interview
      • provide information about the complaint process, potential outcomes and options for assistance/support
      • explain that the process is confidential
      • explain what records of the complaints will be kept, and where
      • explain that it is unacceptable to victimise someone who has made a complaint.

     3. Assess the information

If the respondent confirms that s/he did what is alleged to have occurred, and if this behaviour would be considered abuse as defined in the organisation’s policy, the next step is to consider an appropriate outcome (see below). It is recommended that the respondent is provided with the opportunity to comment on any proposed decision and outcome before a final decision is made.

If there is disagreement about what happened, the person handling the complaint will consider whether there is other information that will help to determine what happened.

Given the nature of abuse and harassment, there may often be no direct witnesses or documents to support the complainant’s version of events. This does not mean that the allegation is untrue. In these situations, the complainant should be given the opportunity to comment on the information that has been provided by the respondent and to provide any other information to support his or her allegations before a final decision is made. It is generally understood that the person making the decision should be satisfied that it is ‘more probable than not’ that what is alleged to have happened did happen.

In serious cases, external parties may be required in the decision process and criminal charges may follow Viamo’s internal process. 

4. Outcomes

a. Where the allegations are admitted or substantiated

Outcomes for the respondent may include:

      • an official warning
      • a requirement to provide a formal apology to the complainant
      • participation in mediation
      • disciplinary action e.g. suspension, probation or dismissal.

Outcomes for the complainant may include:

      • supportive counselling
      • participation in mediation
      • a change in the work environment e.g. a change in team or location

It is important that the complainant is provided with general information about the outcome of a complaint, as this may affect their decision to pursue the matter with an external agency. The level of detail provided should be balanced against the need to respect the privacy of the respondent.

b. Where the allegations are not admitted or substantiated

Where allegations have not been admitted or substantiated, it may still be appropriate for the employer to take some action as a result of the complaint. For example, it may be appropriate to:

      • re-issue the safeguarding policy to all team members
      • provide refresher training for all staff regarding appropriate behavior.

If such action is taken, it is important that it is not done in a way which could be seen as singling out or punishing the respondent, especially where there has been no finding that he or she has breached the organisation’s policy or Code of Conduct.

Annex – Viamo Abuse Prevention Hotlines

Country Languages Toll Number
Global Ghana English 14158020515
Ghana English, Twi, Hausa, Dagbani, Ga, Ewe 0242437610
Nigeria English, Pidgin, Hausa, Yoruba, Ibo 08139840342
Malawi Chichewa 09999017122
Botswana English, Sestwana
Burkina Faso French, Mooré, Dioula, Fulfulde , Gulmancéma, Lélé 025674309
DRC French, Lingala, Swahili, Kikongo, Tshiluba 0996034119
Mali French, Songhay, Peuhl, Bambara, Tamasheq 044978939
Madagascar Malagasy 0334480072
Mozambique Portuguese, Changana, Macua, Xissena 0840953342
Niger French, Haussa, Zarma, Fulfulde, Tamashaq 096796032
Rwanda Kiryarwanda 0788126016
Uganda English, Runyakitara, Luo, Ateso, Luganda, Lugbara 0200522443
Tanzania Swahili 0784105709
Zambia English, Nyanja, Bemba, Tonga, Lozi 0964863121
Indonesia Bahasa Indonesia 08170795423
Nepal Nepali 0714235716
Cambodia Khmer 0592222952
Afghanistan Dari, Pashto 0729574936
India Hindi, English 02249753507
Senegal French, Wolof, Dioula, Sérere 0328244509
Haiti Haitian Creole, French 0928140179
Kenya Swahili, English 0730750024
Myanmar  Myanmar, Shan, Kayin, Rakhine, Mon, Chin and Kachin   9778883113
Pakistan Urdu, English
Bangladesh Bengali, English
Ethiopia Amharic, English 0115185702