Safeguarding Policy and Procedure 

Purpose 

The purpose of the ICM Safeguarding Policy is to protect people from any harm that may be caused by their coming into contact with ICM. This includes the behaviour of ICM staff and the design and implementation of ICM’s programmatic work. 

This policy sets out ICM’s commitment to respect, promote, uphold, and protect the rights of all people and informs all staff of their responsibilities in relation to safeguarding. 

ICM has zero tolerance for any form of abuse related to any aspect of its work. ICM recognises that abuse can occur as a result of an imbalance of power and understands its relative position of power in relation to its grantee partners. ICM also understands that abuse and safeguarding issues may result from an imbalance of power within its grantee partners and is conscious that people in countries without the legal and policy frameworks for protection may be at much greater risk.  

Any breach of this policy will be treated extremely seriously and will be thoroughly and professionally investigated. Breaching this policy will result in disciplinary action for employees, and for all other staff and partners, ICM reserves the right to immediately terminate their contract. 

Scope 

This Policy applies to the conduct of all employees, the ICM Board, Council and committees. It also applies to contractors, volunteers, consultants, associates or agents of ICM and any third party acting on its behalf, which includes fixed term staff, trainees, seconded staff, homeworkers, casual workers, agency staff, sponsors, or any other person associated with ICM, wherever they may be located (collectively referred to as ‘Staff’ in this Policy). It also applies to grantee partners.  

This policy does not apply to harassment or bullying between ICM staff or complaints about ICM’s organisational practices. Such cases are addressed through the Bullying and Harassment Policy (for employees), Misconduct Policy and Procedure (for grantee partners), Grievance Policy and Procedure, Disciplinary Procedure and Whistleblowing Policy.  

What is Safeguarding and how does it apply to ICM? 

ICM understands that safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment, but also emotional abuse and neglect from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur. 

In the context of ICM’s work as the global voice of midwives, working to strengthen midwives’ associations and to advance the profession of midwifery globally, it is important to note that ICM does not: 

• work directly with children or at-risk adults. 
• work directly with vulnerable beneficiaries of financial assistance. 

As such, ICM’s specific safeguarding risks in relation to vulnerable adults and children include, but are not limited to: 

• abuse or exploitation committed by our staff or grantee partners. 
• reporting any disclosures of abuse or exploitation by third parties that we become aware of in the course of our work.  

Protection from Sexual Exploitation and Abuse (PSEA) 

Sexual exploitation is any actual or attempted abuse of a position of power, vulnerability or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. 

Sexual abuse means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. 

ICM staff and grantee partners must not: 

• Sexually exploit or abuse any person. 
• Engage in sexual activity with anyone under the age of 18 (regardless of local legislation or customs). Mistaken belief in the age of a child is not a defence. 
• Exchange money, employment, goods or services for sex or sexual favours. This includes, but is not limited to, using the services of sex workers, (whether or not prostitution is legal in the location) demanding sexual activity in exchange for assistance/service that is due to beneficiaries, and demanding sexual activity in exchange for employment. 
• Use a child or adult to procure sex for others. 

Any sexual relationship between those providing humanitarian assistance and a person benefiting from such humanitarian assistance and protection is prohibited.  

ICM staff and grantee partners are obliged to: 

• Contribute to creating and maintaining an environment that prevents sexual exploitation/abuse and safeguarding violations and promotes the implementation of this Safeguarding Policy. 
• Report any suspicion or concern of safeguarding or PSEA issues. Any individual can raise a concern/complaint to ICM about an incident they have experienced, witnessed, or heard about concerning an ICM staff member or grantee partner without fear of retribution. See How to Report a Safeguarding or PSEA Concern. 

Awareness 

ICM will:  

• Ensure staff and grantee partners receive information on safeguarding and PSEA at a level appropriate to their role. 
• Ensure all staff and grantee partners have access to this policy and are familiar with their responsibilities. 
• Send this policy to all staff and partners who travel to sites of ICM’s programmatic work.  

Prevention 

ICM will: 

• Implement appropriate safeguarding procedures when recruiting, managing and deploying staff. 
• Undertake its programmatic work in a way that protects people from any risk of harm that may arise from their encountering ICM.  
• Appoint a Designated Person to ensure that safeguarding is given a high priority within ICM. 
• Follow up on reports of safeguarding concerns promptly and according to due process. 

Communication

This policy and associated procedures will be communicated to staff and grantee partners, beneficiaries, donors, other stakeholders and the general public as appropriate.  

Safeguarding in Recruitment 

ICM is committed to safe recruitment and selection of potential new staff. ICM follows the safe recruitment practices outlined below: 

1. Those responsible for recruitment and selection understand the ICM Safeguarding Policy and related procedures.
2. Recruitment processes emphasise ICM’s commitment to its Code of Conduct and Safeguarding Policy. 
3. Applicant screening pays particular attention to gaps in employment history or frequent changes of employer. 
4. All offers of employment are conditional on receiving at least two professional references, one of which is from the candidate’s current employer or the employer immediately prior. References are followed up on, including questions on disciplinary actions.  
5. All essential qualifications and relevant professional accreditations and memberships are verified to the satisfaction of the hiring manager. 
6. The successful candidate is required to provide proof of identity (passport, ID card). 
7. All new staff receive orientation on the Safeguarding Policy and related procedures and associated documents (Code of Conduct, Whistleblowing Policy, Misconduct Policy and Procedure etc.) 
8. All new staff are required to abide by the Code of Conduct as a condition of their contract/agreement. 

ICM does not work directly or indirectly with children or at-risk adults, but if ICM does ever engage in activities that require staff to undertake a criminal record or other background check in accordance with relevant legislation, ICM will ensure that these are carried out as part of its commitment to safeguarding. 

If ICM becomes aware that any current or former staff member may pose a risk to children and/or at-risk adults it will comply with the legislation and relevant guidance in respect of referring that person to the relevant authorities. 

Reporting  

ICM staff and grantee partners have a responsibility to report any suspicion or concern of safeguarding issues. Any individual can raise a concern/complaint to ICM about an incident they have experienced, witnessed, or heard about concerning an ICM staff member or grantee partner without fear of retribution. 

ICM employees and grantee partners must not investigate allegations or suspicions themselves. 

ICM has a duty to create a working environment where staff are able to raise concerns and support each other to ensure the risk of a safeguarding incident occurring is minimised. 

ICM has appointed the Head of Organisational Projects as the safeguarding Designated Person who is responsible for ensuring that safeguarding is given high priority within ICM. Specific responsibilities of this role include: 

• Providing an organisation wide focal point for managing and reporting incidents and allegations. 
• Providing support and advice to ICM staff on all safeguarding matters. 
• Carrying out referrals and reporting to the relevant authorities where sexual exploitation or abuse; abuse of a child; or abuse of an at-risk adult is reported or suspected. 

• Maintaining an overview of safeguarding issues and monitoring the implementation of the safeguarding policy and related procedures.  
• Continuous development of a robust and compliant safeguarding policy for ICM 
• Supporting the Chief Executive in regular and time-sensitive reporting on any safeguarding developments to the Board.  
• Ensuring that ICM’s safeguarding policy and related procedures are integrated into the induction programme of new staff and communicated to grantee partners. 

ICM staff do not work directly with at risk adults or children. However, should an instance occur where an ICM staff member finds themselves in direct contact with a child or an at-risk adult through the course of their work, they shall immediately seek supervision and guidance from the Designated Person who may in turn seek expert professional advice where relevant for example from children’s service, health service or police within the jurisdiction. 

Any staff reporting concerns or complaints in good faith will be protected by the ICM Whistleblowing Policy. 

ICM accepts complaints from external sources but cannot address anonymous reports.  

How to Report a Safeguarding or PSEA Concern 

Safeguarding or PSEA concerns must be reported to the dedicated email address: [email protected].   

The reporting email is monitored by the Designated Person who reports to the Chief Executive and President. 

The report should include:  

• What the safeguarding concern is. Describe what happened, including as many details as possible. 
• Who is the perpetrator? Was anyone else involved? Provide full names, titles and organisation, if possible. 
• When and where did the incident(s) happen? Indicate date(s) and time(s), if available. 
• How did the individual(s) commit the alleged abuse? 
• If there is any supporting evidence (evidence to be provided later) and names of any other potential witnesses. 

Response 

ICM follows up safeguarding reports in line with its Investigations Procedure and legal and statutory obligations.  

Sexual exploitation and abuse by ICM staff and grantee partners are acts of gross misconduct and are grounds for termination of the contract/agreement. Any breach of the ICM Safeguarding Policy by an employee is grounds for disciplinary action up to and including dismissal. It is ICM policy to report all crimes to the relevant law enforcement authorities unless doing so may pose a risk to anyone involved in the case. 

Confidentiality 

Confidentiality is maintained at all stages of the safeguarding process. Information relating to the report and subsequent case management is shared on a need-to-know basis only and is kept secure at all times. 

Other Related Documents 

• Bullying and Harassment Policy 
• Code of Conduct  
• Confidentiality Policy 
• Disciplinary Procedure 
• Grievance Policy and Procedure 
• Investigations Procedure 
• Misconduct Policy and Procedure 
• Whistleblowing Policy 

Review 

This Policy and Procedure will be reviewed every three years to ensure it reflects any changes in best practice and legislation. 

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