The purpose of this policy is to set standards regarding the Pulitzer Center’s responsibility to ensure its culture, programs, and practices respect the rights and dignity of the people with whom the organization comes into contact—especially children and adults at risk—to live free from harm and abuse.
SCOPE OF POLICY
The Pulitzer Center has zero tolerance for any violation of this policy and is committed to preventing and responding appropriately to harm or abuse of children and adults at risk. The Pulitzer Center will ensure that safe, appropriate, and accessible means of reporting safeguarding concerns are made available to staff, contract journalists, related personnel, and people in the communities where they work.
This policy does not address workplace harassment or bullying. These policies can be found at pulitzercenter.org/about/ethics-and-standards-policies. This policy covers the protection of children and adults at risk from harm and abuse.
The policy applies to all Pulitzer Center staff, board members, contract journalists, volunteers, vendors, and related personnel, who will be referred to as “representatives” in this policy.
- Child: Any person under the age of 18 in accordance with Article 1 of the UN Convention on the Rights of the Child, 1989. This policy applies to all children regardless of their background, age, class, gender, ethnicity, religion, ability, or sexual orientation.
- Adult at risk: Someone aged 18 and older who identifies themself as unable to take care of themself/protect themself from harm or exploitation; or who due to gender, mental or physical health, disability, ethnicity, religious identity, sexual orientation, economic or social status, or as a result of disaster or conflict, is deemed to be at risk.
The Pulitzer Center’s commitment to safeguarding children and adults at risk is based on the following principles:
- Accountability and transparency: A speak up culture and safe environment are created in which people are valued, listened to, and their right to be safe is upheld, and safeguarding concerns are reported and dealt with quickly and appropriately.
- Prevention: Steps are taken to reduce and manage safeguarding risks in Pulitzer Center programs.
- Reporting: There are clear reporting and management lines, where concerns can be raised and managed timely and appropriately, and reporting procedures are known to everyone.
- Response: Immediate steps are taken to prevent further harm, and allegations are handled appropriately and investigated promptly.
- Learning: Lessons learned are incorporated back into improving this policy as well as all related procedures and practices.
BY APPLYING THESE PRINCIPLES, THE PULITZER CENTER ENSURES THAT:
- Children and adults at risk are protected from harm or abuse.
- Pulitzer Center representatives understand their responsibility to prevent the risk of harm to children and adults at risk.
- There is a duty of care to those with whom the Pulitzer Center works, or is in contact with through its operations.
- All safeguarding actions are taken by keeping in mind the best interests of children and adults at risk.
CODE OF CONDUCT
When in direct or indirect contact with children and adults at risk, Pulitzer Center representatives must:
- Treat all children and people with respect and never discriminate against or favor any person because of their age, gender, status, class, caste, nationality, ethnic or social origin, faith, visual appearance, language ability, sexual orientation, or any factor that distinguishes them from others.
- Promote and safeguard the welfare of children and adults at risk, in everything that we do.
- Ensure that, whenever possible, there is more than one adult present during activities with children and adults at risk, or they are at least within sight or hearing of others–unless the reason for this has been firmly established and agreed to by a person overseeing the Pulitzer Center activities.
- Develop and keep clear personal boundaries and rules when conducting activities that involve children or adults at risk, to keep both them and you safe.
- Ensure that all Pulitzer Center representatives have received appropriate supervision and support to ensure children and adults at risk are safe at all times.
- Ensure that confidential information concerning children, families, and communities is not shared inappropriately on social media, or with others, except through formal safeguarding reporting processes with full informed consent.
Representatives should not behave in an abusive or exploitative manner by exerting power and authority over children or adults at risk or by creating an unsafe environment. This includes:
Never engage in any sexual activity with children or adults at risk.
- You must never engage in any sexual activity with children (persons under the age of 18) or adults at risk. Mistaken belief in the age of a child is not a defense.
- You must never engage in or attempt to engage in sexual or inappropriate relationships with children or adults at risk for whatever reason, including the use of suggestive conversations, comments, texting, instant messaging, emails, or social media platforms, as there is an inherently unequal power dynamic. This includes possessing or distributing indecent images of children, adults at risk, or others.
- You must never use your status or position to form inappropriate relationships with any child or adult at risk, either face-to-face or online, which are of a sexual or exploitative nature, or which may become so.
- You must never communicate with children via social media, email, or phone unless it is as an agreed upon part of your work, and managers are both informed and able to monitor activity.
- You must never exchange money, work, goods, services, incentives, or aid for sexual favors or subject anyone to any other kind of humiliating, degrading, suggestive, or abusive behavior.
Never engage in any other exploitative behavior.
- You must never engage or pay a child or adult at risk for any service that is not part of an organized and agreed activity.
- You must never use your status or position to intimidate, bully, threaten, discriminate against, embarrass, shame, humiliate, coerce, or undermine children or adults at risk.
- You must never encourage or assist children or adults at risk to break the law in any way.
- You must never engage in any commercially exploitative activities with children or adults at risk, including child labor or trafficking.
Never engage in other abusive or negligent behavior.
- You must never carry out your duties or visit with children and adults at risk while under the influence of alcohol, solvents, or drugs. This also includes not smoking in the presence of children during Pulitzer Center activities.
- You must never use any sort of physical chastisement, touching, punishment, or implements to beat or hit a child or adult at risk as a form of discipline, or withhold food, water, or other necessities of care.
- You must never take any bribes or rewards in order to cover up or ignore suspicious activity involving children or adults at risk.
- You must never neglect a child or leave a child unsupervised that may put the child at risk of harm or injury.
All Pulitzer Center representatives are expected to sign and fully comply with all provisions of this policy. This requirement will be included in all contracts. Any breach of this policy and the Code of Conduct will result in consequences for the Pulitzer Center representative and will vary depending on their relationship to the Pulitzer Center and the nature of the misbehavior. Steps followed and consequences could include:
- An internal or external investigation
- Disciplinary action or immediate dismissal
- Suspension and/or ceasing of activity, relationship, or engagement
- Cancellation of the contract or partnership
Where appropriate, the Pulitzer Center will also share specific information with relevant regulatory bodies, authorities, law enforcement, and protection agencies. The Pulitzer Center will follow up on safeguarding reports and concerns according to its reporting and resolution procedure (see below). The Pulitzer Center will also offer support to survivors of harm caused by representatives. Decisions regarding support will be led by the survivor.
Pulitzer Center representatives who witness, suspect, hear rumors about, or receive a report, directly or indirectly, of a violation of this policy, are required to take prompt, appropriate action by reporting the incident as soon as possible and not later than 24 hours after learning or becoming aware of the concern. The concern may be a result of witnessing the incident or being told of it.
RESPONDING TO DISCLOSURES
Children and adults at risk may indicate that they are being harmed in several ways. If someone tells you or you observe that they are uncomfortable with a specific person’s behavior toward them, you should:
- Reassure them that they were right to report the behavior.
- Listen carefully and ask clarifying questions to ensure you report the incident accurately.
- Do not repeat the same questions back to them, as this may give them the impression that you do not believe them or what is being said.
- Do not promise secrecy. Be open and honest about the fact that you must report the allegation to the Safeguarding Focal Person.
- Ensure that the physical safety and psychological well-being of the child or adult at risk are secured. This may include referring them for medical treatment or to counseling services if available. (Consent may need to be sought to do this as appropriate.)
- Make sure you report exactly what has been said rather than any inferences you have made.
- Do not allow personal doubts to prevent you from reporting an allegation.
- Explain to the child or adult at risk what you are going to do and what will happen next.
- If the child or adult at risk is suffering from a serious injury, the representative must seek medical attention immediately and must inform the Safeguarding Focal Point.
HOW TO REPORT
The Representative receiving a complaint, either in writing or verbally, should:
- Get the basic incident information
- Explain to the complainant the requirement to report. If the survivor has not given consent to report the incident, there is still the obligation to report
Representatives should not:
- Investigate the alleged incident themselves
- Make assumptions or offer alternative explanations
- Promise confidentiality; instead, they should give assurance that the information will only be shared on a ‘need to know’ basis
If a child or adult at risk has been subjected to harm or abuse by a Pulitzer Center representative, a report may be made by the victim or another person on their behalf. The Pulitzer Center has several ways that representatives or others can report safeguarding concerns:
- Designated Safeguarding Focal Person: Nicole York, Director of Human Resources: firstname.lastname@example.org
- And by calling: (202) 332-0982
The report may be made in person, in writing, by phone, or in text. Under no circumstances are victims required to report the incident to the person involved in the misconduct or to a supervisor, whether or not the supervisor is alleged to be responsible for the misconduct. If the matter is a crime, a report may be made to the local law enforcement agency by the Safeguarding Focal Point, if it does not put the victim at greater risk.
The fact that a complaint is made anonymously does not automatically mean that it bears less substance than one in which the complainant identifies themself and is prepared to give evidence. It may indicate a fear of reprisal. As such, anonymous complaints will be treated as seriously as named complaints, though the extent to which they can be investigated may be circumscribed by the anonymity.
THIRD PARTY REPORTS
Complaints do not have to be made by the affected person and, like anonymous reports, third party reports will be taken seriously.
PROTECTION OF WHISTLEBLOWERS
Representatives should be reassured that there will be no action taken against anyone who reports in good faith, information indicating a violation of the Pulitzer Center’s Safeguarding Policy, even if it proves to be unfounded. However, if a representative knowingly and willfully reports false or malicious information regarding another representative, such false reports will lead to disciplinary action.
Retaliation against any person who reports a safeguarding concern, or participates in any manner in an investigation or resolution of a safeguarding report, is prohibited.
COMPLAINT RESPONSE AND RESOLUTION
Safeguarding reports will be addressed in a timely, fair, confidential, and respectful manner. The Pulitzer Center will conduct a thorough and confidential investigation into all allegations of harm or abuse. If the Pulitzer Center determines harm or abuse has occurred, prompt remedial action will be taken, including the representative’s termination of employment or contract.
- The Pulitzer Center acknowledges and respects the courage and trust associated with reporting safeguarding allegations. To the extent possible, the Pulitzer Center will seek to maintain the confidentiality of allegations, survivor/victim, reporter, witnesses, and subjects of complaint, understanding confidentiality can be critical to safety/security, reputation, and well-being.
- The general principle of confidentiality is such that the disclosure of the identity of complainants, witnesses, survivors, the subject of the complaint and any others involved in an investigation, is restricted and is permitted only on an authorized or “need to know” basis, and only in certain exceptional circumstances.
- It is important for all reporters to understand, however, that the Pulitzer Center may be legally mandated to follow up on certain allegations (for example, with authorities in the case of a potential criminal offense) and that strict confidentiality cannot always be guaranteed due to the organization’s moral and/or legal obligation to report and investigate.
- The Pulitzer Center or others involved in an investigation (including the reporter, the subject of the complaint, the investigator(s), and anyone interviewed as a witness) have a duty to manage sensitive information in a manner that is respectful, professional, and that complies with applicable law, which may vary in international locations. Staff must keep all information about any suspected or reported incidents strictly confidential and divulge information only to a designated investigator.
- Failure to maintain confidentiality may be grounds for disciplinary action. The only exception is being in instances where a survivor needs to disclose information to in order to access necessary support and services.
SAFEGUARDING RISK ASSESSMENT AND PREVENTION
The Pulitzer Center’s Safeguarding Lead will regularly (at least annually) assess safeguarding risks in its programs and identify mitigation measures to protect children and adults at risk from harm. Prevention activities include:
- Ensuring all representatives have access to, are familiar with, and know their responsibilities within this policy.
- Designing and undertaking activities in a way that protects people from any risk of harm that may arise from their coming into contact with the Pulitzer Center. This includes how information about individuals in programs is gathered and communicated.
- Implementing rigorous safeguarding procedures when recruiting, managing, and deploying representatives.
- Ensuring staff regularly receive relevant safeguarding training at a level commensurate with their role in the organization.
- Following up on reports of safeguarding concerns promptly and according to due process.
The Safeguarding Focal Point will regularly update the Board of Directors on safeguarding matters and recommend any policy changes based on learnings. The Safeguarding Policy will be reviewed by the board of directors on an annual basis.
Pulitzer Center Safeguarding Focal Point: Nicole York, Director of Human Resources
Date Policy Approved by Board of Directors: December 16, 2022
Next Policy Review Date: December 2023