1. Policy Statement

Niger Delta Stakeholder Initiative for Community Development and Empowerment [NDSICDE] is committed to maintaining a safe, respectful, and harassment-free environment for all employees, volunteers, interns, consultants, partners, and beneficiaries.

Sexual harassment, exploitation, abuse, and all forms of gender-based violence are strictly prohibited and will result in disciplinary action.

This policy is guided by:

• The Constitution of the Federal Republic of Nigeria

• The Labour Act (Cap L1, LFN 2004)

• The Violence Against Persons (Prohibition) Act, 2015 (VAPP Act)

• Child Rights Act

• International best practices for NGOs and humanitarian organisations

 

2. Who This Policy Applies To

This policy applies to:

• All staff (permanent, temporary, and contract)

• Volunteers and interns

• Consultants and service providers

• Board members

• Partners and visitors

• Interactions with beneficiaries and community members

It applies in:

• Offices and project sites

• Fieldwork and travel

• Trainings, meetings, and events

• Online and digital communication platforms

 

3. What Is Sexual Harassment?

Sexual harassment is any unwanted sexual behaviour that makes someone feel uncomfortable,

threatened, humiliated, or unsafe. It does not need to be repeated to be harassment.

Examples include:

• Sexual jokes, comments, or suggestions

• Unwanted touching, hugging, or kissing

• Requests for sexual favours

3• Sexually suggestive messages, emails, or images

• Staring, gestures, or sounds of a sexual nature

• Offering benefits or threatening consequences linked to sexual compliance

 

4. Consent

Consent must be:

• Freely given

• Clear and voluntary

• Given without pressure or fear

Silence, power imbalance, or inability to refuse is not consent. Consent can be withdrawn at any time.

 

5. Gender-Based Violence (GBV)

GBV includes:

• Sexual harassment and assault

• Sexual exploitation and abuse (SEA)

• Domestic violence

• Forced or harmful practices

NDSICDE has zero tolerance for GBV, whether it occurs within the organisation or affects beneficiaries

during programme implementation.

 

6. Safeguarding Commitment

NDSICDE is committed to safeguarding:

• Women and girls

• Children

• Persons with disabilities

• Beneficiaries and vulnerable populations

Staff must never exploit their position of power or trust.

Any sexual relationship between staff and beneficiaries is strictly prohibited, regardless of perceived

consent.

 

7. Code of Conduct (Summary)

All staff and associated persons must:

• Treat everyone with dignity and respect

4• Maintain professional boundaries

• Avoid abusive, discriminatory, or exploitative behaviour

• Report any safeguarding or harassment concerns

• Cooperate with investigations

Failure to comply is misconduct.

 

8. Reporting Sexual Harassment or GBV

Anyone who experiences or witnesses misconduct should report it immediately or as soon as possible.

Reports can be made to:

• Immediate Supervisor (unless involved)

• Human Resources Officer

• Safeguarding / Gender Focal Person

• Country Director

• Anonymous reporting mechanism (suggestion box)

Reports may be verbal or written.

 

9. Confidentiality

All reports will be handled confidentially and respectfully. Information will only be shared on a need-

to-know basis.

10. Protection From Retaliation

No one will be punished, intimidated, or victimised for:

• Reporting harassment or abuse

• Supporting a complainant

• Participating in an investigation

Retaliation is a serious disciplinary offence.

 

11. Investigation Process

• All complaints will be taken seriously

• Investigations will be fair, prompt, and impartial

• Both parties will be heard

• External authorities may be involved where required by law

 

12. Disciplinary Actions

Depending on severity, actions may include:

• Verbal or written warning

• Mandatory training or counseling

• Suspension

• Termination of employment or engagement

• Referral to law enforcement (as required under Nigerian law)

 

13. Support for Survivors

NDSICDE will provide appropriate support, including:

• Psychosocial support or counseling referrals

• Medical referrals

• Temporary work adjustments

• Referral to legal or protection services

 

14. False or Malicious Reports

Deliberately false or malicious complaints may result in disciplinary action.

However, a complaint made in good faith is not considered false simply because it could not be proven.

 

15. Policy Review

This policy will be reviewed every two (2) years or as required by law.