Protection From Sexual, Exploitation, Abuse and Harassment (PSEAH) 

1.1 Purpose Scope and Approval

The purpose of this policy is to outline Lightcastle Partners’ approach to Protection from Sexual Exploitation, Abuse, and Harassment (PSEAH), aligning with international cooperation standards. This policy covers:

• The principles guiding decisions in SEAH situations at Lightcastle Partners.
• Expectations for all staff, including partners.
• Procedures ensuring effective action in response to SEAH cases.

This policy will be implemented in alignment with pertinent employment and labor laws, as well as criminal laws approved by the Senior Management of Lightcastle Partner.

1.2 Complaint Mechanism

Employees at Lightcastle Partners who become aware of or experience a situation involving Sexual Exploitation, Abuse, and Harassment (SEAH) are encouraged to utilize the Complaints Procedure outlined in the Grievance Procedure (refer to pages 16 and 17) and the Whistleblowing Policy. The diagram below illustrates Lightcastle Partners’ comprehensive complaint mechanism, inclusive of misconduct, including SEAH. 

1.3 Overarching Guidance

Abuse, whether current, recent, or historical, can be reported without time limitations. Lightcastle Partners encourages the timely reporting of incidents involving harassment, exploitation, or abuse. The following guidance applies in SEAH situations:

1. Anonymous complaints are allowed but discouraged due to challenges in addressing and follow-up. For anonymous reporting file the complaint through the Work Ethics Hotline. This form is already shared with [email protected] and anybody can file any complaint through here.
2. Affected individuals may contact a designated person for support and counseling, ensuring confidentiality and prioritizing the rights, needs, and wishes of the victim/survivor.
3. Confidentiality is maintained throughout the complaints process, and staff breaching confidentiality may face disciplinary action.
4. All involved parties are safeguarded against professional disadvantages under the presumption of innocence. Precautionary measures, such as staff transfers or paid leaves, may be implemented.
5. Depending on the circumstances, qualified internal or external specialists may mediate in SEAH cases.

1.4 Support for Survivors and Victims

LightCastle Partners will coordinate essential measures to provide assistance to survivors/victims of SEAH. This assistance may encompass specialized psycho-social counseling and/or facilitation of access to other experts (such as medical and/or legal aid) as required. Survivors and victims retain the right to decide if and when they wish to avail themselves of the available support options.

1.5 Prevention of Retaliation Against Complainants, Victims, and Witnesses

LightCastle Partners will take decisive measures against any staff, regardless of whether they are the subject of a complaint, or who engage in retaliatory actions against complainants, victims, or other witnesses. Employees found to be involved in such conduct may face disciplinary actions, including but not limited to termination of employment.

1.6 False Allegations

Defamation, slander, and false accusations are deemed as serious offenses under the policies of LightCastle Partners. The organization reserves the right to enforce the following sanctions against a staff member engaged in such behavior found to have made a false allegation:

1. Written apology to the person concerned
2.  Arrangement of a binding and controllable behavior modification procedure with set appointments and deadlines
3.  Written reprimand with a threat to terminate the contract
4.  Leave of absence
5.  Oral reprimand
6.  Notice of termination
7.  Termination without notice
8.  Report the offender to the police
9. Take legal action and contact the lawyer etc.
   

1.7 Continuous Training & Communications

On the induction day, it is imperative to organize comprehensive sessions, possibly on a biannual basis, to enhance understanding and facilitate effective communication. To achieve this, situational questions will be introduced to help individuals comprehend what constitutes sexual harassment or abuse. A trial run of the test will be implemented after the PSEAH session.

1.8 Ethics Committee

The ethics committee will consist of Senior Management and an external representative (independent member) unaffiliated with LightCastle, ensuring no direct connection or conflict of interest. Session-based compensation will be offered for hearing if any issue arises. In the event of a complaint against a Senior Management member, immediate removal from the Ethics Committee is mandatory. Additionally, representatives from various levels of designation (e.g., one from a Business Analyst, one from a Business Consultant, and one from a Senior Business Consultant) within the team subject to the complaint should be involved for verification and reference.

1.9 Policy Review and Update

This policy will be reviewed and updated if necessary or when the overall LightCastle Partners requires it to be updated.