Policy on Protection from Sexual Exploitation and Abuse (PSEA)

1. Introduction

The Public Organization “Hamqadam” is committed to a policy of zero tolerance towards misconduct by its personnel that amounts to sexual exploitation and sexual abuse. Hamqadam strives to work in a way that ends injustice and poverty and builds a world that protects the rights and dignity of everyone without exception. We understand that, to work in good faith, we must engage in dialogue and make sure that everyone who comes into contact with Hamqadam is protected from any form of injustice, discrimination or abuse. Hamqadam is firmly committed to creating and maintaining a working environment based on respect for the inherent dignity of every person, enabling people to realize their full potential and maximizing opportunities to achieve the best results for Hamqadam and the people whose interests it protects.

Everyone who works at Hamqadam has the right to be treated with dignity and respect and to work in a safe environment free from harassment, sexual harassment, abuse and discrimination. Based on our Code of Conduct, Hamqadam therefore strives to prevent all forms of sexual violence and harassment and sexual exploitation, and takes decisive action when such cases occur. Hamqadam regards any form of sexual violence as a gross violation of human rights. We will not tolerate any form of abuse, exploitation or harm towards our staff, community members, members of target groups or anyone we come into contact with in the course of our work.

In 2003, the Secretary-General of the United Nations issued the bulletin “Special measures for protection from sexual exploitation and sexual abuse” (ST/SGB/2003/13).

As part of its zero-tolerance policy, Hamqadam’s management decided to adopt, with the necessary adjustments, the standards of conduct and provisions on protection from sexual exploitation and abuse set out in that bulletin. These Standards form the basis of this Policy and are binding on all Hamqadam staff, volunteers, partners and service providers.

2. Purpose of the policy

The purpose of this policy is to ensure that procedures are in place to protect the organization’s staff and the members of the target groups of the programmes we work with, including adults and children at risk, from sexual violence and exploitation or other improper and unethical conduct by any member of our staff.

Zero tolerance: sexual exploitation and abuse (SEA) in any form is prohibited and is classed as serious misconduct. It is grounds for disciplinary proceedings that may ultimately lead to summary dismissal or termination of contract, as well as other serious measures in accordance with the legal provisions applicable to the different categories of Hamqadam personnel.

Duty to report and cooperate: all Hamqadam staff must report complaints, suspicions or concerns about SEA to the body authorized to investigate SEA through the following channels: email info@hamqadam.tj, phone +992 888 00 29 21. All Hamqadam staff must also cooperate fully with investigations.

Confidentiality: all SEA complaints are handled with the utmost confidentiality to protect the identity of victims, witnesses and alleged perpetrators.

Training: mandatory training on preventing and responding to SEA is provided to all Hamqadam staff.

Protection: Hamqadam undertakes to respond to all SEA complaints with a victim-centred approach and to arrange victims’ access to specialized services and assistance. Reporting SEA, or cooperating with a properly conducted review, investigation or handling of SEA complaints, is protected under Hamqadam’s whistleblower protection policy.

Inter-agency cooperation: recognizing that SEA policy is implemented across the UN system and among public organizations in Tajikistan, Hamqadam supports system-wide UN mechanisms in line with its internal procedures in order to respond comprehensively and appropriately to any SEA complaints and cases.

3. Principles

This policy is based on the IASC Six Core Principles (2002, revised 2019):

1. Sexual exploitation and abuse by humanitarian workers constitute acts of gross misconduct and are therefore grounds for termination of employment.

2. Sexual activity with children (persons under the age of 18) is prohibited regardless of the age of majority or age of consent locally. Mistaken belief regarding the age of a child is not a defence.

3. Exchange of money, employment, goods or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour, is prohibited. This includes the exchange of assistance that is due to beneficiaries.

4. Any sexual relationship between those providing humanitarian assistance and protection and a person benefiting from such assistance and protection that involves improper use of rank or position is prohibited. Such relationships undermine the credibility and integrity of humanitarian work.

5. Where a humanitarian worker has concerns or suspicions regarding sexual abuse or exploitation by a fellow worker, whether in the same agency or not, they must report such concerns via established agency reporting mechanisms.

6. Humanitarian agencies are obliged to create and maintain an environment that prevents sexual exploitation and abuse and promotes the implementation of their code of conduct. Managers at all levels have particular responsibilities to support and develop systems that maintain this environment.

4. Scope

4.1. This policy on protection from sexual exploitation and sexual abuse (the “policy”) is mandatory and applies to all Hamqadam staff and non-staff personnel regardless of their type of engagement, including contractors, interns, volunteers, visitors (e.g. donors), dependants, accompanying personnel, service providers and persons carrying out one-off tasks. The term “contractor” refers to anyone engaged by the Organization under a services contract, short-term contract or consultancy contract. The policy must be observed both during and outside working hours and in all aspects of a person’s life.

4.2. All personnel and representatives of the persons listed above have the right to file a complaint under the procedures set out in this policy.

4.3. Disciplinary proceedings and/or other administrative measures may be initiated against staff who are the subject of an SEA complaint; for non-staff personnel, the measures set out in their contracts apply.

4.4. Partners and service providers are also expected to comply with the Standards set out in this policy. Failure to do so will result in the immediate termination of any agreement between Hamqadam and the partner or service provider. The Organization reserves the right to refer any credible allegations of criminal conduct to the law enforcement authorities of the Republic of Tajikistan.

5. Definitions

5.1. For the purposes of this Policy, “sexual exploitation” means any actual or attempted abuse of another person’s position of vulnerability, of one’s own power or of trust for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of a beneficiary or of any other person or group of persons not connected with the Organization.

5.2. “Sexual abuse” means the actual or threatened physical intrusion of a sexual nature, whether by force, under unequal conditions or by coercion. (Definitions of the terms used in this Policy are set out in the annex “Definitions and examples”.)

6. Prohibition of sexual exploitation and sexual abuse

6.1. Sexual exploitation and abuse violate universally recognized international legal norms and standards and are prohibited under Hamqadam’s Staff Regulations and Rules (Staff Policy, Code of Conduct).

6.2. To further protect the most vulnerable groups, especially women and children, this Policy sets out the following specific standards, which reaffirm the existing general obligations under Hamqadam’s Staff Regulations and Rules:

a) sexual exploitation and abuse constitute serious misconduct and are therefore grounds for disciplinary measures, including summary dismissal;

b) sexual activity with children (persons under the age of 18) is prohibited regardless of the legal age of majority or age of consent. Mistaken belief regarding the age of a child is not a defence;

c) exchanging money, employment, goods or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour, is prohibited. This prohibition includes any use for such exchange of assistance intended for beneficiaries;

d) sexual relationships between Hamqadam staff and beneficiaries are prohibited, since they are based on inherently unequal power dynamics, undermine the credibility of Hamqadam’s work and call the organization’s impartiality into question;

e) where a Hamqadam staff member has concerns or suspicions that a colleague at Hamqadam or at an implementing partner/service provider is engaged in sexual exploitation or abuse, they must report such concerns through the established reporting channels. Failure to report or concealing SEA is also serious misconduct and grounds for disciplinary measures up to and including summary dismissal;

f) Hamqadam staff are obliged to create and maintain working conditions that prevent sexual exploitation and abuse. Managers at all levels have a particular responsibility to develop systems that maintain such an environment.

6.3. The standards and principles listed above are not exhaustive. Other conduct related to sexual exploitation or abuse may also be grounds for administrative and/or disciplinary measures, including summary dismissal, under Hamqadam’s Staff Regulations and Rules.

6.4. The standard in paragraph 6.2 b does not apply where a staff member is legally married to a person under 18 who has reached the age of majority or consent under the law of the Republic of Tajikistan. The standard in paragraph 6.2 d is applied with discretion where beneficiaries are over 18 and the circumstances of the case justify an exception.

7. Roles and responsibilities

7.1. In addition to the roles and responsibilities set out in other relevant rules and policies, including those on investigations and disciplinary proceedings, under this policy Hamqadam staff must:

• uphold the highest standards of personal and professional conduct and never engage in SEA;

• maintain a harmonious working environment free from any form of wrongdoing, threats, hostility and other unacceptable behaviour;

• respect confidentiality, report in good faith to management or the PSEA coordinator any complaints, suspicions or concerns about SEA that come to their attention, and cooperate fully with investigations;

• complete training and familiarize themselves with the SEA policy;

• be aware of the different options and internal channels available for reporting misconduct and/or resolving such issues.

7.2. The Director/Head is responsible for:

• ensuring that information and appropriate mechanisms are in place to prevent and address SEA among Hamqadam staff;

• submitting all credible SEA complaints to the Organization’s governing bodies, donors and partners.

7.3. The PSEA Coordinator is responsible for:

• receiving SEA complaints and deciding whether to investigate;

• investigating SEA allegations;

• immediately informing the ethics adviser of all SEA reports.

7.4. The HR officer/administrator (the person responsible for personnel records) is responsible for:

• informing the organization’s management and the PSEA Coordinator of any disciplinary or administrative measures taken in SEA cases;

• reviewing candidates’ applications and carrying out thorough reference checks on external candidates during recruitment, so as not to hire persons with a documented history of sexual exploitation and abuse, and making sure every candidate signs the self-declaration form before an employment contract or agreement is concluded.

7.5. Managers at all levels are responsible for:

• keeping current and new staff informed of Hamqadam’s zero-tolerance policy on SEA, ensuring they are fully familiar with Hamqadam’s PSEA policy and distributing copies of it;

• ensuring that the staff they supervise complete mandatory PSEA training;

• reporting any SEA complaints or suspicions to management immediately.

7.6. Additional responsibilities of the Director and senior staff:

• creating and maintaining an environment that prevents SEA;

• creating a supportive and harmonious working environment free from wrongdoing, intimidation, hostility and any form of unacceptable behaviour; to this end, the manager must lead by example and uphold the highest standards of conduct;

• promoting this policy among staff and enabling them to complete mandatory courses/trainings and certifications;

• addressing, preventing and reporting possible cases of misconduct in accordance with this policy;

• responding promptly and appropriately to cases of misconduct; the manager must show a clear commitment to fair and impartial resolution, free from intimidation or favouritism, and must under no circumstances conduct their own investigations;

• ensuring that all discussions, information sharing and actions are handled with great care, sensitivity and the utmost confidentiality;

• taking all necessary measures to keep Hamqadam staff safe and protect them from any retaliation or punishment;

• appointing a Hamqadam PSEA focal point in field units/branches;

• publishing information about the PSEA policy where appropriate.

8. Reporting misconduct

8.1. Hamqadam welcomes reports of all observed cases of SEA or harassment. Hamqadam’s policy is to investigate such complaints promptly and carefully. Hamqadam prohibits discrimination, abuse, harassment and intimidation of anyone who reports such cases or takes part in investigating them.

8.2. Any staff member with questions or concerns about this policy should discuss them with the head of the organization or the organization’s designated PSEA focal point.

8.3. Hamqadam welcomes reports of all observed cases of discrimination, harassment or bullying, whoever the offender is and whatever their position. Anyone who believes they have been subjected to such behaviour should raise their concerns with their line manager, any manager in the organization or the ombudsperson.

8.4. In addition, Hamqadam encourages anyone who believes they are being treated in this way to tell the offender immediately that their behaviour is offensive and ask them to stop.

8.5. Hamqadam recognizes, however, that a person may prefer to resolve the matter through the complaints procedure.

8.6. Retaliation against anyone for reporting sexual harassment, abuse, bullying or discrimination, or for taking part in an investigation into such a complaint, is a serious breach of this policy. Like harassment, bullying and discrimination themselves, retaliation for reporting them may be grounds for disciplinary measures. Retaliation should be reported immediately; it will be investigated promptly and appropriate action will be taken.

8.7. Complaints procedure:

8.7.1. There is no time limit for reporting sexual harassment. However, people are strongly encouraged to report such cases as soon as possible. Hamqadam welcomes prompt reporting of complaints and concerns, as it allows quick and constructive action before relationships are irreparably damaged. So although no fixed reporting deadline is set, prompt reporting and intervention are the most effective way of resolving actual or alleged SEA incidents.

8.7.2. Anyone who believes they have been the victim of, or witnessed, conduct prohibited by this Policy should raise their concern with their line manager or with the staff member authorized by this Policy and by management’s order to oversee compliance with it.

8.7.3. All allegations of sexual harassment, discrimination or bullying are investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with people who witnessed the alleged conduct or have other relevant information.

8.7.4. Confidentiality is maintained during the investigation as far as is consistent with the purposes of the investigation and any corrective action.

8.7.5. False and malicious complaints of SEA, discrimination or harassment (as opposed to complaints made in good faith, even if mistaken) may lead to disciplinary measures against the complainant.

8.7.6. Hamqadam staff and staff of other organizations have several ways to report misconduct, using both formal and informal routes to resolve the conflict (see Annex 1 “Contacts for reporting SEA”).

8.8. Rights and obligations of the complainant:

a) anonymous reports are allowed under this policy. However, complainants should understand that, despite every effort, anonymous reports may make an investigation more difficult or longer;

b) an allegation (complaint) must be written clearly and honestly: the person reporting SEA must have sufficient grounds and be confident that another person has engaged in improper and indecent conduct;

c) knowingly making a false statement, orally or in writing, is considered misconduct and leads to disciplinary measures.

8.9. Informing beneficiaries and communities about the reporting mechanism. Hamqadam actively informs the beneficiaries of its programmes and members of local communities about the SEA complaints mechanism, including by:

• explaining the informed consent form to beneficiaries when they begin taking part in the Organization’s programmes/projects;

• displaying the contact information (Annex 1) at project sites and in the Organization’s information materials in an accessible and understandable form, including, where necessary, adapted for persons with disabilities and in the languages used by target groups;

• holding regular awareness meetings with beneficiaries and community members on the unacceptability of SEA and how to file a complaint.

9. PSEA training

9.1. Hamqadam provides mandatory training on preventing and responding to SEA for all staff and non-staff personnel, volunteers, consultants and partners within the first 30 days of starting work or cooperation with the Organization, and regularly thereafter, at least once a year.

Training materials must include:

• the definition of sexual exploitation and abuse;

• the principle of zero tolerance for SEA and its consequences;

• every staff member’s duty to report suspected or actual SEA;

• the available reporting channels (internal and external, including the contacts in Annex 1);

• the duty to assist survivors and the principles of a victim-centred approach.

Managers at all levels, together with the PSEA Coordinator, are responsible for organizing training. Completion of training is recorded on a signed acknowledgement sheet or certificate, which is kept in the staff member’s personnel file.

10. Dispute resolution

10.1. All parties to a conflict are strongly advised to keep detailed records (including printouts of emails) of all SEA incidents, including dates, places, witnesses and evidence.

10.2. Parties to a conflict should be aware that not all informal processes succeed and that investigations may follow, so written records can be very useful.

10.3. If, during an investigation into a breach of this Policy, the alleged offender leaves the organization because their contract has ended, Hamqadam’s management decides at its discretion, depending on the seriousness of the misconduct, whether to continue the investigation despite their departure. However, in cases provisionally classified as sexual harassment, an investigation must be carried out in all circumstances.

10.4. Where an investigation is completed and the allegations are substantiated, the manager informs the alleged offender and, after giving them an opportunity to comment on the incident, places a record in their personnel file. The record also includes any recommended disciplinary measures if the alleged offender is still on the organization’s staff. Unfinished cases are not disclosed to third parties on request.

10.5. In emergencies and in the event of possible threats, the local law enforcement authorities must be contacted, and Hamqadam’s management must be consulted and informed of the actions taken.

11. Timeframes for SEA investigations

SEA investigations are carried out within the following timeframes:

• acknowledgement of receipt of the complaint to the complainant — no later than 3 (three) working days after it is received;

• decision on whether to open a formal investigation — no later than 7 (seven) working days after the complaint is received;

• completion of the investigation and preparation of findings — as a rule, no later than 45 (forty-five) calendar days after the investigation begins, except in particularly complex cases, where the deadline may be extended by decision of the Organization’s management, with all parties concerned informed of the reasons for the delay.

11.1. Where necessary, the PSEA Coordinator brings in independent specialists or seeks assistance from the Organization’s donors and partners to ensure an appropriate professional standard of investigation if the Organization’s internal resources are insufficient.

11.2. If an investigation confirms SEA, Hamqadam’s management develops, within 30 (thirty) calendar days of its completion, an action plan to address the systemic weaknesses identified (gaps in recruitment, training, supervision procedures, etc.) that allowed the incident to happen. The plan sets out specific actions, responsible persons and deadlines, and is shared with the governing bodies, donors and partners of the Organization as part of the reporting provided for by the reporting mechanisms (Annex 2).

12. Referral to law enforcement

12.1. The Organization reserves the right to refer any credible allegations of criminal conduct to the law enforcement authorities and to cooperate fully with them in investigating SEA.

13. Cooperation agreements and contracts with entities or individuals not part of Hamqadam

13.1. When concluding cooperation agreements with partners or service providers, the responsible Hamqadam officials inform these entities or individuals of the standards of conduct listed in section 6.

13.2. If these entities or individuals fail to take measures to prevent sexual exploitation or abuse, to investigate allegations or to take corrective action where sexual exploitation or abuse has occurred, this constitutes grounds for terminating any cooperation agreement or contract with Hamqadam.

13.3. All cooperation agreements, works contracts and contracts with partners, subcontractors and service providers must include a separate clause on protection from sexual exploitation and abuse, reading as follows:

“The Parties undertake to observe the principle of zero tolerance for sexual exploitation and abuse (SEA) as defined in Hamqadam’s Policy on Protection from Sexual Exploitation and Sexual Abuse. The implementing Party undertakes: (a) to inform Hamqadam immediately of any allegations, suspicions or complaints of SEA it receives in connection with the performance of this contract; (b) to take the necessary measures to prevent SEA among its personnel; (c) to investigate allegations of SEA and take appropriate corrective action where a violation is confirmed. Failure to meet these obligations constitutes grounds for the immediate termination of this contract.”

13.4. The Hamqadam official concluding the contract must make sure that this clause is included in the agreement before it is signed.

Annex 1. Contacts for reporting SEA

Annex 2. Mechanisms for reporting sexual exploitation and abuse

Hamqadam considers timely, reliable and confidential reporting of SEA cases an integral part of its commitments to donors and partners. In accordance with the relevant partnership and funding agreements, the Organization undertakes to inform donors and partners promptly of all allegations of sexual exploitation and abuse, while ensuring the safety and confidentiality of everyone involved, and to provide regular updates on the progress and outcome of investigations and on the assistance provided to survivors. Any staff member, volunteer, partner, beneficiary or other person may report SEA in one of the following ways:

Annex 3. Definitions and examples

Sexual violence in the world of work is a form of sex-based discrimination that may combine elements of physical and psychological violence, as well as behaviours such as unwelcome remarks or advances, “jokes”, brief physical contact and sexual assault. As with gender-based violence in general, men and boys can also be victims of sexual violence and harassment.

Sexual harassment is a form of sexual violence that usually occurs in the world of work and often takes the form of “quid pro quo” or a “hostile working environment”. Quid pro quo sexual harassment occurs when a worker is asked for sexual favours and a decision about their employment depends on whether they agree or refuse.

Sexual harassment means any unwelcome conduct of a sexual nature that might reasonably be expected or perceived to cause offence or humiliation. It may include any verbal, non-verbal or physical conduct, including written and electronic communications, and may occur between persons of the same or different sexes.

Harassment in a hostile working environment means conduct that creates an intimidating, hostile or humiliating working environment.

A common form of sex-based violence and harassment is “maternity harassment”, i.e. harassing a woman because of her pregnancy, childbirth or a related medical condition, or harassing a worker because of their family responsibilities. Sexual harassment may also take the form of hostility towards women because of their sex, such as offensive or demeaning “jokes” about women.

Domestic violence is a rapidly expanding area of regulation in the world of work. The terms “family” or “family relationships” usually cover traditional family ties — blood relations, marriage and intimate partners. However, more and more countries are extending legislation to domestic workers and others living in the household because of their exposure to violence and harassment in the “domestic sphere”. Domestic violence can also spill over into the world of work when it is aimed at preventing a person from getting or keeping a job (economic violence).

Physical violence is the use of physical force against another person or group that results in physical, sexual or psychological harm, or any attempt to inflict physical injury or to attack a person, including actual physical harm.

Psychological violence and harassment is the most widely recognized form of violence and harassment in the world of work. It includes:

• verbal and other abuse;

• psychological and sexual harassment;

• bullying, mobbing and threats.

It may include attacks on a person’s reputation, isolating them, withholding information, assigning tasks that do not match their abilities, or setting impossible goals and deadlines.

The word “psychological” refers to the harmful effect such conduct has on the victim’s mental health. The term “moral harassment” or “bullying” has the same meaning: repeated actions whose purpose or effect is to worsen a worker’s working conditions in a way that violates their right to dignity, their physical or mental health or their career prospects. Psychological violence and harassment may be defined broadly, to protect all workers, or on a “discrimination basis”, where the law protects only a person demeaned because of a real or perceived difference, such as race, colour, sex, religion, political opinion, national or social origin, age, disability, sexual orientation or gender.

The scope of this Policy is defined by terms such as “workplace” or “in the course of or in connection with work”. However, the workplace is wider than the physical place of work alone: it often includes other spaces (such as rest areas), social events after work and commuting to and from work.

Sexual exploitation means any actual or attempted abuse 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 person.

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

Harassment is any improper and unwelcome conduct by one staff member towards another that has caused, will cause or might reasonably be perceived to cause offence or humiliation. It may take the form of words, gestures and actions that cause distress, alarm, offence, humiliation, belittlement, embarrassment or blackmail and create a hostile, unfriendly working environment. Harassment need not be deliberate or intentional: what matters is whether the person perceives it as offensive or degrading.

Examples of verbal abuse

1. Verbal insults and name-calling;

2. Unwanted terms of endearment such as “doll”, “baby”, etc.;

3. Shouting and aggressive behaviour;

4. Making someone the constant butt of jokes;

5. Offensive or insulting nicknames;

6. Innuendo or other suggestive, offensive or demeaning comments or jokes about a person’s gender identity or sexual orientation;

7. Unwelcome and/or demeaning comments about appearance, clothing or other physical characteristics;

8. Slander, or damaging someone’s reputation through gossip, rumours and ridicule;

9. Persistent, unjustified or condescending remarks in front of others or “behind someone’s back”;

10. Unjustified, intrusive or constant questions about a person’s ethnic or racial origin, culture or religion;

11. Repeated and unwanted remarks, messages or calls;

12. Remarks, messages or calls that are offensive, threatening, demeaning or intimidating;

13. Offensive, demeaning or threatening notes left in workplaces;

14. Pressuring someone to take part in political or religious discussions;

15. Suggestive remarks about clothing, physique, hairstyle, appearance or other personal attributes.

Examples of non-verbal harassment

1. Social isolation, exclusion or refusal to cooperate at work;

2. Hostility through persistent unfriendly attacks or isolation;

3. Repeated offensive gestures;

4. Obscene or offensive images and materials, including posters, photographs, cartoons, graffiti, objects or messages left on notice boards, desks or in common areas;

5. Persistent unwanted gifts or invitations;

6. Persistent staring or aggressive facial expressions;

7. Inappropriate computer screensavers that offend others’ dignity;

8. Spreading damaging rumours;

9. Using email, messaging and social media to send offensive, threatening or inappropriate images of a staff member to other staff;

10. Repeatedly ignoring, excluding or isolating someone.

Examples of physical harassment

1. Unwanted or inappropriate touching, patting, hugging or other physical contact (e.g. massage or deliberately touching parts of the body);

2. Hitting, pushing, slapping, kicking or biting;

3. Tripping someone up;

4. Throwing objects at people or attacking them with any object to hand.

Examples of sexual harassment

1. Repeated requests or other forms of pressure with a sexual or personal, non-professional undertone (e.g. persistent requests for a date);

2. Unwanted, intrusive or persistent questions about marital status, sexual preferences, orientation or origin;

3. Indecent messages sent by email, on social media or left on an answering machine or voicemail;

4. Open or implied sexual threats as a condition for gratitude, promotion or a positive performance appraisal;

5. Remarks and speculation about a person’s sexual relationships, or talking about one’s own sexual relationships;

6. Sexual materials (including pornography), such as posters, photographs, cartoons, graffiti or messages left on notice boards, desks or in common areas;

7. Covert behaviour with sexual undertones intended to harm or humiliate another person;

8. Innuendo or other suggestive, offensive or demeaning comments or jokes about gender identity or sexual orientation;

9. Unwanted or inappropriate touching, patting, hugging or other physical contact.

Examples of abuse of authority

1. Unfair and unjustified allocation of duties, or personal requests unrelated to work and official duties;

2. Excessive control or surveillance of another person’s work;

3. Using one’s position or personal authority to put pressure on a staff member, or to stop them from raising complaints or concerns about possible breaches of conduct or ethical obligations;

4. Persistently suppressing or isolating a particular person, treating them unprofessionally in an offensive and belittling way;

5. Persistently attacking a person and/or group, making them the target of offensive ridicule or unjustified personal remarks;

6. Persistently mocking and humiliating a person or group, especially in front of others;

7. Coercive, offensive or degrading actions or jokes that make others uncomfortable;

8. Imposing sanctions or other punishments without grounds;

9. Interfering with a staff member’s career development, deliberately obstructing or blocking promotion;

10. An unreasonably harsh reaction to a minor problem;

11. Disclosing, or threatening to disclose, confidential information about a person’s private or professional affairs;

12. Unjustified allocation of staff duties and functions;

13. Excessive control of a staff member with the deliberate intention of hindering their work;

14. Using one’s position to allocate work unfairly and without justification in order to suppress a person and damage their professional reputation;

15. Deliberately withholding information, or constantly overloading someone with pointless or overly difficult tasks;

16. An inconsistent management style in which a manager unfairly favours some staff over others (favouritism);

17. Constantly finding fault with a staff member’s work as a pretext for humiliating and denigrating them instead of supporting their development;

18. Blaming a staff member for any shortcomings for which they were not originally responsible;

19. Persistent negative attacks on a staff member’s professional or personal qualities without good reason or legal justification;

20. Unjustified allocation of tasks (sometimes impossible ones) with unrealistic deadlines;

21. Displaying intellectual superiority and dominance in an aggressive, offensive or humiliating manner.

Examples of discrimination

1. Failing to consider or recommend a staff member for career progression or promotion because of differences in race, sex, gender identity, religion, nationality, ethnic origin, sexual orientation, disability, pregnancy, age, language, social origin or other status, or treating staff differently with regard to training and development opportunities, leave, working hours, participation in meetings, etc.;

2. Demeaning or offensive nicknames based on race, sex, gender identity, religion, nationality, ethnic origin, sexual orientation, disability, pregnancy, age, language, social origin or other status;

3. Offensive comments about a person’s physical characteristics or clothing, including criticism of and remarks about religious items they may wear;

4. Ridiculing particular forms of cultural or religious identity (holidays) or making absurd remarks about individuals’ religious beliefs;

5. Social discrimination based on race, sex, gender identity, religion, nationality, ethnic origin, sexual orientation, disability, pregnancy, age, language, social origin or other status;

6. Jokes, inappropriate comments and questions about a person’s abilities;

7. Unjustified, intrusive or persistent questions about a person’s ethnic or racial origin, culture or religion.

The forms that accompany this Policy — staff and partner informed consent forms, the incident report form, the referral form and the candidate self-declaration — are completed on paper and can be obtained from the Hamqadam office or at info@hamqadam.tj.