Protection from Sexual Exploitation and Abuse (PSEA) and Safeguarding Policy

1. Purpose and zero tolerance

Axiom Santé's assignments (surveys, evaluations, third-party monitoring, training) bring its personnel into direct contact with patients, households, children and people in vulnerable situations.

This policy aims to prevent sexual exploitation, abuse and harassment, to protect children and vulnerable adults, and to ensure that every incident is reported, handled and sanctioned. Axiom Santé applies zero tolerance: no breach is tolerated, and failing to act on a known breach is itself misconduct.

2. Scope

The policy applies to everyone working for or with Axiom Santé, whatever their status or length of engagement, both during and outside working hours:

• Management and permanent staff;
• associate experts and consultants;
• enumerators, supervisors, drivers, guides and interpreters recruited for data collection, including when they work alone in communities;
• subcontractors and their personnel, as well as interns and volunteers.

Subcontracts incorporate this policy and require the subcontractor to comply with its requirements and to report any incident to Axiom Santé.

3. Definitions

• Sexual exploitation: any actual or attempted abuse of a position of vulnerability, differential power or trust for sexual purposes, including profiting monetarily, socially or politically from the sexual exploitation of another.
• Sexual abuse: the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.
• Sexual harassment: any unwelcome conduct of a sexual nature (remarks, gestures, messages, advances, requests for favours) that offends, humiliates or intimidates, or that creates a hostile working environment.
• Child: any person under the age of 18, in line with the United Nations Convention on the Rights of the Child, regardless of the local age of majority or consent.
• Vulnerable adult: any person aged 18 or over who, because of their health, a disability, their social or economic situation, displacement or dependence on a service, is less able to protect themselves from harm or exploitation.
• Survivor: a person who has experienced sexual exploitation, abuse or harassment.

4. References and core principles

The policy draws on the UN Secretary-General's Bulletin ST/SGB/2003/13, Special measures for protection from sexual exploitation and sexual abuse, the Inter-Agency Standing Committee (IASC) Six Core Principles Relating to Sexual Exploitation and Abuse (2002, revised 2019) and the United Nations Protocol on Allegations of Sexual Exploitation and Abuse Involving Implementing Partners (2018).

Axiom Santé adopts the six core principles, adapted to its work:

1. Sexual exploitation and abuse constitute acts of gross misconduct and are grounds for termination of the employment or service contract.
2. Sexual activity with children (persons under the age of 18) is prohibited regardless of the local age of majority or consent. Mistaken belief regarding the age of a child is not a defence.
3. Exchanging money, employment, goods or services, including assistance or compensation due to participants, for sex, sexual favours or any other form of humiliating, degrading or exploitative behaviour is prohibited.
4. Any sexual relationship between a member of personnel and a person benefiting from the work or taking part in a study that involves improper use of rank or position is prohibited. Such relationships undermine the credibility and integrity of the work.
5. Anyone who develops concerns or suspicions regarding sexual exploitation or abuse by a fellow worker, whether or not employed by Axiom Santé, must report them through the channel set out in section 12.
6. Everyone is obliged to create and maintain an environment that prevents sexual exploitation and abuse. Management and supervisors have particular responsibility for establishing and maintaining the systems that support this environment.

5. Child safeguarding

Where an activity involves children, the following rules apply:

• Consent and assent: any research or data collection with a minor requires the informed consent of the parent or legal guardian and the assent of the child, obtained in language suited to their age. A child's refusal is respected, even where the parent has consented.
• Never alone with a child: wherever possible, no member of personnel is left alone with a child. Interviews take place in a visible location or in the presence of a trusted adult, unless the approved protocol provides otherwise in order to protect the child.
• Images: no photograph, video or recording of a child is made without the consent of the parent or guardian and the assent of the child. Images preserve the child's dignity (never undressed or in a degrading pose), do not allow the child to be located (name, school, village) and are stored only on the firm's devices.
• Contact: establishing private contact with a child (telephone, social media, messaging) outside the scope of the activity is prohibited.

6. Safe recruitment

Axiom Santé builds safeguarding into every recruitment, including enumerators engaged for a single data collection:

• reference to the firm's PSEA commitment in job advertisements;
• checks of at least two professional references, including an explicit question on any history of sexual exploitation, abuse or harassment;
• a signed self-declaration by the candidate confirming the absence of any conviction, ongoing investigation or dismissal for such conduct;
• signature of the code of conduct and of this policy before taking up duties;
• use of inter-employer misconduct disclosure arrangements, such as the Misconduct Disclosure Scheme, where available.

A false declaration leads to withdrawal of the offer or termination of the contract.

7. Training and induction

No one goes into the field without having received an induction on this policy. For each data collection, team training includes a PSEA and safeguarding module covering prohibited conduct, child safeguarding, how to respond to a disclosure and the reporting channel. Attendance is recorded. An annual refresher is provided for permanent staff and associate experts.

8. Field data collection

Before and during each data collection, Axiom Santé applies the following measures:

• Team composition: teams are organised so that no enumerator works in isolation in an unsafe location; where relevant, they include female enumerators for interviews with women and girls; a supervisor is designated as the safeguarding focal point.
• Informed consent: each participant is informed of the purpose of the study, that participation is voluntary, of their right to refuse or stop the interview, and that no benefit depends on any favour.
• Referral information: gender-based violence response services (medical, psychosocial, legal) are identified before each data collection; teams carry this list and know how to refer a person who asks for help or makes a disclosure, without themselves questioning the person about the facts.
• Community information: participants are told that they can report any inappropriate behaviour by the team through the channel in section 12.

9. Duty to report and survivor-centred approach

Anyone covered by section 2 who witnesses an incident, receives a disclosure or has a reasonable suspicion must report it to Management within 24 hours. Evidence is not required, and no one should conduct their own investigation.

Every report is handled using a survivor-centred approach:

• Safety: the physical and psychological safety of the survivor takes precedence over all other considerations;
• Confidentiality: information is shared only with those who need to know;
• Consent: no step concerning the survivor (referral to a service, reporting to an authority) is taken without their informed consent, except where required by law or in case of serious and imminent danger, particularly to a child;
• Non-discrimination: everyone is treated with respect, regardless of sex, age, disability, origin or any other characteristic.

No retaliation is tolerated against anyone who reports in good faith, against a survivor or against a witness. Any retaliation constitutes gross misconduct.

10. Investigation, cooperation and sanctions

Management acknowledges every report, takes immediate protective measures (including withdrawing the person concerned from the field) and organises a fair, confidential and proportionate investigation. Where the facts warrant it or impartiality requires it, a qualified external investigator is engaged.

Where the incident concerns a project funded or commissioned by a client, Axiom Santé notifies the client without delay, respecting confidentiality and any timeframe set in the contract, cooperates fully with the client's investigation procedures and reports back on the action taken.

A substantiated breach leads to proportionate sanctions, up to immediate termination of the employment, consultancy or subcontract, and exclusion from any future assignment. Where the facts may constitute a criminal offence, Axiom Santé considers referral to the competent authorities, taking into account the wishes and safety of the survivor; cases involving a child are handled first and foremost in the child's best interests. The provisions of the ethics policy also apply.

11. Responsibilities and review

Who	Responsibilities
Management	Adopt and enforce the policy, receive and handle reports, notify clients, decide on sanctions.
Assignment leads and supervisors	Build safeguarding into data collection planning, identify response services, ensure team training, escalate any incident.
Everyone covered by section 2	Comply with the policy and the code of conduct, report any suspicion within 24 hours.
Subcontractors	Apply equivalent measures to their personnel and inform Axiom Santé of any incident.

The policy is reviewed annually, or earlier following an incident, a change in international standards or a client requirement.

12. Reporting and contact

Reports should be sent to info@axiomsante.org with the subject line "CONFIDENTIEL : Signalement". These messages are handled exclusively by Management. They may be anonymous; it helps to state the date, place and nature of the incident. Participants and communities may also speak to a supervisor, who passes the report to Management without delay. Where the incident concerns a project, it may also be reported directly to the client through its own mechanisms.