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PSEA Policy


This document is prepared to articulate Policy for Protection Against Sexual Exploitation & Abuse (PSEA Policy). PSEA policy is applicable at the organizational, community and beneficiary levels. The systems and procedure for minimizing and managing issues as and when arises is articulated as a step-by-step process. PSEA Policy is a living document and would be improved as and when required. A formal review of the policy would be undertaken at the end of each year to know the number of cases, frequency of cases, nature of cases and need for improving the policy. In case of need for improvement, the policy would be improved and presented to board of directors for approval without any delay.


Special Talent Exchange Program (STEP) strives to create and maintain a work environment in which people are treated with dignity, decency and respect. The environment of the STEP should be characterized by mutual trust and the absence of intimidation, oppression and exploitation. STEP will not tolerate unlawful discrimination or harassment of any kind. Through enforcement of this policy and by education of employees, STEP will seek to prevent, correct and discipline behavior that violates this policy.

All employees, regardless of their positions, are covered by and are expected to comply with this policy and to take appropriate measures to ensure that prohibited conduct does not occur. Appropriate disciplinary action will be taken against any employee who violates this policy. Based on the seriousness of the offense, disciplinary action may include verbal or written reprimand, suspension, or termination of employment.

Executive Director and Project Director who knowingly allow or tolerate discrimination, harassment or retaliation, including the failure to immediately report such misconduct to human resources (HR), are in violation of this policy and subject to discipline.

Prohibited Conduct Under PSEA Policy

STEP in compliance with all applicable federal, state and local anti-discrimination and harassment laws and regulations, enforces this policy in accordance with the following definitions and guidelines:


It is a violation of STEP’s PSEA policy to discriminate in the provision of employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person’s race, color, national origin, age, religion, disability status, sex, sexual orientation, gender identity or expression, genetic information or marital status.

In Pakistan it has been difficult for women to fully contribute to their country’s development because the environment to work, in general, is difficult and un-supportive. Women commonly face inappropriate behavior and harassment on the streets, at the work place and in public places.

The government has been trying to increase the number of women employees for the last several years, but even the minimum quota of 5% remains unfilled. Outside the government some women are working in senior positions and are running businesses, but, in general, the trend of women working in government or private employment has not become popular. Regardless of the economic and social compulsions to earn an income, women have to face several hurdles to work outside their homes.

Discrimination of this kind may also be strictly prohibited by a variety of Pakistan Government laws, including Title ‘Protection Against Harassment of Women at Workplace, Act 2010’. This policy is intended to comply with the prohibitions stated in these anti-discrimination laws. Discrimination in violation of this policy will be subject to disciplinary measures up to and including termination.

2. Harassment

STEP prohibits harassment of any kind, including sexual harassment, and will take appropriate and immediate action in response to complaints or knowledge of violations of this policy. For purposes of this policy, harassment is any verbal or physical conduct designed to threaten, intimidate or coerce an employee, co-worker, or any person working for or on behalf of STEP. The following examples of harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of PSEA policy:

  • Verbal harassment includes comments that are offensive or unwelcome regarding a person’s national origin, race, color, religion, age, sex, sexual orientation, pregnancy, appearance, disability, gender identity or expression, marital status or other protected status, including epithets, slurs and negative stereotyping.
  • Nonverbal harassment includes distribution, display or discussion of any written or graphic material that ridicules, denigrates, insults, belittles or shows hostility, aversion or disrespect toward an individual or group because of national origin, race, color, religion, age, gender, sexual orientation, pregnancy, appearance, disability, sexual identity, marital status or other protected status.

3.       Sexual harassment

Sexual harassment is a form of unlawful employment discrimination and is prohibited under STEP’s anti-harassment policy. According to the Law called ‘Protection Against Harassment of Women at Workplace, Act 2010. The intention of the Law is to provide an opportunity to all organizations, public, private and civil society, to develop a self-regulatory mechanism whereby organizations could handle the problems related to sexual harassment internally. Adoption of this Code has become mandatory for all organizations. It requires management to take charge of the transformation of their institutional culture and make it dignified for both women and men.

Sexual harassment occurs when unsolicited and unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature:

  • Is made explicitly or implicitly a term or condition of employment.
  • Is used as a basis for an employment decision.
  • Unreasonably interferes with an employee’s work performance or creates an intimidating, hostile or otherwise offensive environment.
  • Sexual harassment may take different forms. The following examples of sexual harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:
  • Verbal sexual harassment includes innuendoes, suggestive comments, jokes of a sexual nature, sexual propositions, lewd remarks and threats; requests for any type of sexual favor (this includes repeated, unwelcome requests for dates); and verbal abuse or “kidding” that is oriented toward a prohibitive form of harassment, including that which is sexual in nature and unwelcome.
  • Nonverbal sexual harassment includes the distribution, display or discussion of any written or graphic material, including calendars, posters and cartoons that are sexually suggestive or show hostility toward an individual or group because of sex; suggestive or insulting sounds; leering; staring; whistling; obscene gestures; content in letters, notes, facsimiles, e-mails, photos, text messages, tweets and Internet postings; or other forms of communication that are sexual in nature and offensive.
  • Physical sexual harassment includes unwelcome, unwanted physical contact, including touching, tickling, pinching, patting, brushing up against, hugging, cornering, kissing, fondling, and forced sexual intercourse or assault.

Courteous, mutually respectful, pleasant, no coercive interactions between employees that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.

4.       Consensual Romantic or Sexual Relationships

STEP strongly discourages romantic or sexual relationships between a manager or other supervisory employee and an employee who reports directly or indirectly to that person, because such relationships tend to create compromising conflicts of interest or the appearance of such conflicts. In addition, such a relationship may give rise to the perception by others that there is favoritism or bias in employment decisions affecting the staff employee.

Moreover, given the uneven balance of power within such relationships, consent by the staff member is suspect and may be viewed by others, or at a later date by the staff member, as having been given as the result of coercion or intimidation. The atmosphere created by such appearances of bias, favoritism, intimidation, coercion or exploitation undermines the spirit of trust and mutual respect that is essential to a healthy work environment. If there is such a relationship, the parties need to be aware that one or both may be moved to a different department or other actions may be taken.

If any employee of STEP enters into a consensual relationship that is romantic or sexual in nature with an employee who reports directly or indirectly to that employee, or if one of the parties is in a supervisory capacity in the same department in which the other party works, the parties must notify the Manager HR or other appropriate corporate officer. Because of potential issues regarding quid pro quo harassment, STEP has made reporting mandatory. This requirement does not apply to employees who do not work in the same department or to parties where neither one supervises or otherwise manages responsibilities over the other.

Once the relationship is made known to STEP, the company will review the situation with human resources in light of all the facts (reporting relationship between the parties, effect on co-workers, job titles of the parties, etc.) and will determine whether one or both parties need to be moved to another job or department. If it is determined that one party must be moved, and there are jobs in other departments available for both, the parties may decide who will be the one to apply for a new position.

If the parties cannot amicably come to a decision, or the party is not chosen for the position to which he or she applied, the Manager HR and senior management will decide which party will be moved. That decision will be based on which move will be least disruptive to the organization as a whole. If no other jobs are available for either party, the parties will be given the option of terminating their relationship or resigning.

5.       Retaliation

No hardship, loss, benefit or penalty may be imposed on an employee in response to:

  • Filing or responding to a bona fide complaint of discrimination or harassment.
  • Appearing as a witness in the investigation of a complaint.
  • Serving as an investigator of a complaint.

Lodging a bona fide complaint will in no way be used against the employee or have an adverse impact on the individual’s employment status. However, filing groundless or malicious complaints is an abuse of this policy and will be treated as a violation.

Any person who is found to have violated this aspect of the policy will be subject to discipline up to and including termination of employment.

6.       Confidentiality

All complaints and investigations are treated confidentially to the extent possible, and information is disclosed strictly on a need-to-know basis. The identity of the complainant is usually revealed to the parties involved during the investigation, and the Manager HR will take adequate steps to ensure that the complainant is protected from retaliation during and after the investigation. All information pertaining to a complaint or investigation under this policy will be maintained in secure files within the HR department.


The policy is based on the recognition of the factual inequalities between persons and these inequalities continue to persist and grow in our society, making discrimination as one of the most widespread forms of exclusion. The following factors drive the PSEA policy:

  1. Equality is embedded in human rights.
  2. Equality through the empowerment of children, women and men without any differences of disability, ability or any other aspects is critical for good governance.
  3. Women’s and men’s dynamic contribution to society as individuals, workers and citizens is critical for sustainable development.
  4. Empowerment of disadvantaged groups (and women are by far the disadvantaged group in our society) is a key strategy for poverty alleviation and social change.
  5. The situation of women in Pakistan deserves greater attention; any Programme or strategy that fails to pay adequate attention to gender equality is likely to have less than desirable impact on human and institutional development of the country.
  6. Children and women are vulnerable to any kind of abuse hence it is extremely important to ensure their protection and joyful participation in development activities.
  7. Persons with disability are vulnerable to any kind of abuse and security threat therefore it is extremely important to ensure their protection and right to access and utilize basic services and opportunities for realizing their full potential and enjoy their lives like all others.
  8. To sensitize the staff, partners and beneficiaries towards protection of women, children, vulnerable individual/groups particularly in crises and during implementation human driven programmes.

Guiding Principles

STEP’s PSEA policy is guided by the following principles:

  1. STEP strongly condemns any form of exploitation, abuse and harassment with any of the programme beneficiary is promised to ensure the strict actions against the perpetrators for the protection of its beneficiaries, staff and partner communities;
  2. Touching any child or woman no matter they are staff or amongst beneficiaries is the discretion of the individuals but STEP as an organization considers it as an act of perpetration towards sexual exploitation, abuse and harassment;
  3. Motivating people by offering them project benefits or by paying money for illegitimate relationships is the discretion of the individual and STEP will impose strict actions once realized;
  4. None of the staff, volunteers or consultants at STEP are allowed to have any relationship with beneficiaries including children to avoid such situation cropped up and strict action will be ensured against the perpetrators as STEP wants to maintain its rapport in the communities and element of working with honesty and respect both for its workers and beneficiaries;
  5. The person who has reported any sort of act categorized under sexual exploitation, sexual abuse and harassment other than perpetrator and accuser/victim will be provided protection and kept in secret;
  6. While investigating any accusations, STEP will ensure transparency, accountability, honesty and impartial act for accuser and accused to be perpetrator and similar principles will be guided to consultants, volunteers and partner organizations of STEP;
  7. Legal marriages following the individuals religious and national requirements and customs are not to be included under the umbrella of sexual exploitation, sexual abuse and harassment;
  8. STEP as an organization will ensure that sexual exploitation, sexual abuse and harassment does not occur and staff of STEP, its consultants, volunteers and partnering communities are well aware of its policy and consequences;
  9. STEP as an organization will develop programmes by including staff orientation and sensitization towards its PSEA policy.
  10. At the time of hiring and appointments, the individual staff members of STEP will be provided a session on the PSEA policy of STEP.


1.       Board of Directors

The overall responsibility for monitoring the implementation of PSEA Policy rests with STEP’s Board of Directors. The Board is thus responsible for incorporating safeguards in all approval processes and controlling systems

2.       Senior Management

All senior managers (including the chief executive and division heads) are responsible for integrating PSEA in plans, strategies, policies and programmes, as appropriate.

3.       Programme Coordinators and Project Heads

These coordinators are responsible for monitoring the integration of safeguards at programme implementation level. This responsibility is shared with partners and laid out in contracts.

4.       Independent PSEA Focal Person

An independent PSEA focal is responsible for monitoring that no incident of PSEA go unreported. He/she would undertake field visits and interact with staff at all levels to have full information and confidence for any incident if occurs.

5.        Procedure for Addressing the Issues

One member from senior management and 2 members from Board of Directors form a committee and will STEP PSEA Policy make a decision about informal or formal procedure as per details given below:

Complaint Procedure

1.       Informal Procedure of the Complaint

An informal approach to resolve a complaint of harassment may be through mediation between the parties involved and by providing advice and counseling on a strictly confidential basis;

  • A complainant or a staff member designated by the complainant for the purpose may report an incident of harassment informally to his/her supervisor, or a member of the Inquiry Committee, in which case the supervisor or the Committee member may address the issue at her discretion in the spirit of this Code. The request may be made orally or in writing;
  • If the case is taken up for investigation at an informal level, a senior manager from the office or the head office will conduct the investigation in a confidential manner. The alleged accused will be approached with the intention of resolving the matter in a confidential manner;
  • If the incident or the case reported does constitute sexual harassment of a higher degree and the officer or a member reviewing the case feels that it needs to be pursued formally for a disciplinary action, with the consent of the complainant, the case can be taken as a formal complaint;
  • A complainant does not necessarily have to take a complaint of harassment through the informal channel. S/he can launch a formal complaint at any time;
  • The complainant may make formal complaint through her supervisor, CBA nominee or worker’s representative, as the case may be, or directly to any member of the Inquiry Committee. The Committee member approached is obligated to initiate the process of investigation. The supervisor shall facilitate the process and is obligated not to cover up or obstruct the inquiry;
  • Assistance in the inquiry procedure can be sought from any member of the organization who should be contacted to assist in such a case;
  • The employer shall do its best to temporarily make adjustments so that the accused and the complainant do not have to interact for official purposes during the investigation period. This would include temporarily changing the office, in case both sit in one office, or taking away any extra charge over and above their contract which may give one party excessive powers over the other’s job conditions. The employer can also decide to send the accused on leave, or suspend the accused in accordance with the applicable procedures for dealing with the cases of misconduct, if required;
  • Retaliation from either party should be strictly monitored. During the process of the investigation work, evaluation, daily duties, reporting structure and any parallel inquiries initiated should be strictly monitored to avoid any retaliation from either side;
  • The harassment usually occurs between colleagues when they are alone; therefore, usually it is difficult to produce evidence. It is strongly recommended that staff should report an offensive behavior immediately to someone they trust, even if they do not wish to make a formal complaint at the time. Although not reporting immediately shall not affect the merits of the case;

2.        Formal Inquiry Procedure

Working of the Inquiry Committee

  1. The Inquiry Committee Setup under clause (5) will determine a chairperson among themselves and will fix the time and place for its meeting.
  2. The Inquiry Committee after the receipt of a written complaint, shall within three days communicate in writing the charges and statement of allegations to the accused; require the accused, within seven days from the day the charge is communicated to him, to submit a written defense and on his failure to do so without reasonable cause, the

Committee shall proceed ex-parte;

  1. Enquire into the charge and may examine such oral or documentary evidence in support of the charge or in defense of the accused as the Committee may consider necessary and each party shall be entitled to cross-examine the witnesses against him/her.

The Inquiry Committee shall have the power to:

  1. Summon and enforce attendance of any person and examine him on oath;
  2. Require the discovery and production of any document;
  3. Receive evidence on affidavits; and
  4. Record evidence.
  5. Get the complaint or the accused medically examined by authorized doctor, if necessary,

The Inquiry Committee shall have the power to inquire into the matters of harassment under this Code, and may recommend appropriate penalty against the accused. The following provisions inter alia shall be followed by the Committee in relation to the inquiry.

  1. The statements and other evidence acquired in the inquiry process shall be considered as confidential;
  2. The Inquiry Committee can instruct to treat the whole proceedings confidentially, if necessary.
  3. An officer in an organization, if considered necessary, may be nominated to provide advice and assistance to both parties;
  4. Both parties, the complainant and the accused, shall have the right to be represented or accompanied by a Collective Bargaining Agency representative, a friend or a colleague;
  5. Adverse action shall not be taken against the complainant or the witnesses;
  6. The Inquiry Committee shall ensure that neither the employer nor the accused shall initiate any action that would create a hostile environment for the complainant so as to pressurize him/her from freely pursuing his/her complaint; and
  7. The Inquiry Committee shall give its findings in writing by recording reasons thereof.

Process of Formation of Investigation Committee for PSEA and TORs


Protection against Sexual Exploitation and Abuse (PSEA) is the involvement of humanitarian workers in acts of sexual exploitation and abuse is a grave violation of their responsibility to do no harm and to protect people affected by crises and the project beneficiaries.

Formation Process and Composition of Investigation Committee:

  • Investigation committee is comprised of minimum 3 and maximum 4 members;
  • 3 members comprising are normally being manager operations, respective project/ programme coordinator and field coordinator;
  • CEO can suggest any additions considering the local context, magnitude of offense and the damages and any subject or linguistic specialist may be added based on her discretion;
  • If the offense is against the manager operations, project coordinator or field coordinator the committee will be excluded of the perpetrator and CEO will nominate a replacement;
  • Gender composition of the committee will be maintained by including at least one woman and depending upon the offense or abuse the number of woman can also be increased;
  • Necessary arrangements of communication and committee composition would be maintained if the beneficiaries are persons with disabilities and committee would ensure that subject specialist on the relevant disability is part of the committee;
  • Manager operations himself will also play role of Manger HR to fulfil the committee requirements from HR perspective;
  • Field coordinator has discretion to nominate any field staff to play his/ her role as focal point for reporting SEA for the beneficiaries;
  • Profile of the persons nominated will be maintained at head office level and communities particularly beneficiaries would be informed about that;
  • At the office reception in every field office the name of the focal persons for SEA incidences will be displayed;
  • Relevant project/ programme coordinator is the focal person nominated at head office level for the SEA incidents reporting from field offices;
  • All members would have received an orientation and capacitated on CHIP’s SEA broader guideline;
  • Members would be talented enough make decisions without any pressure.

Reporting Mechanism and Terms of Reference of Investigation Committee

  • Members of investigation committee have complete information about the organizational policy and fully capacitated;
  • It is the responsibility of the investigation committee to inform all staff members including field offices about the policy per word;
  • Committee would be headed by Manager Operations and in case if he is a perpetrator the nomination would be made by CEO;
  • Implementation of the PSEA policy is the prior responsibility of the investigation committee;
  • As the incident would report, the focal person would contact to the investigation committee member already known to him/ her;
  • The focal person will make initial contact to the victim and perpetrator. He would record the victim’s statement and perpetrator’s statement under his supervision. He would get signatures on the statement by the victim and perpetrator;
  • The focal person will compile his detailed report based on the initial investigation;
  • The focal person would present his findings and submit his report to the investigation committee;
  • The investigation committee would review the report holistically;
  • The investigation committee would call the victim and perpetrator separately, calling on them;
  • The committee would decide by the mutual consultation of the members;
  • If it is proved that victim committed a lie, the investigation committee will release him/her by giving the first and last notice for his/her disinformation. If the matter is serious and truthful, the investigation committee would recommend the suggestions to CEO for the immediate dismissal of the perpetrator;
  • The investigation would be responsible to document the decision and putting it in the personal file of the victim and perpetrator;
  • It is responsibility of the investigation committee to amend the PSEA policy as needed over the time.

Alternative legal remedies

Nothing in this policy may prevent the complainant or the respondent from pursuing formal legal remedies or resolution through local, state or federal agencies or the courts.

Office of the Federal Ombudsperson Secretariat for Protection against Harassment of Women at Workplace

Federal Ombudsman Secretariat for Protection Against Harassment (FOSPAH), Head Office, Islamabad

Address: First Floor, Local Government and Rural Development Complex, Opposite ILO, Near State Bank of Pakistan, Sector G-5/2, Islamabad. Phone Number: +92 51 9264444

Email Address:

Complains can also be made online by visiting