Preventing Sexual Exploitation, Abuse and Harassment



The action that is taken to promote the welfare of children and protect them from harm. This encompasses protecting children from abuse and maltreatment, preventing harm to children's health or development, and ensuring children grow up with the provision of safe and effective care that enables them to have optimum life chances and enter adulthood successfully.

Duty of care:

A common law concept that refers to the responsibility of the organisation to provide children with an adequate level of protection against harm. It is the duty of the organisation to protect children from all reasonably foreseeable risks of injury.

Sexual exploitation and abuse (SEA):

SEA occurs against a child or an adult and can occur between people of the same or different genders. It includes situations such as: sexual exploitation and abuse; sexual harassment; child sexual abuse and exploitation; women and men sexually exploited through sex work; possessing, controlling, producing, distributing, obtaining or transmitting sexually exploitative images of adults and children; and prevention of sexual abuse and exploitation (PSEA).

Sexual Exploitation:

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.

Sexual Abuse:

The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual Harassment:

Sexual harassment is any unwelcome sexual advance, request for sexual favour, verbal or physical conduct or gesture of a sexual nature, or any other behaviour of a sexual nature that might reasonably be expected or be perceived to cause offence or humiliation to another, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment. While typically involving a pattern of behaviour, it can take the form of a single incident. Sexual harassment may occur between persons of the opposite or same sex. Both males and females can be either the victims or the offenders.

Vulnerable adults:

Those aged over 18 years and who identify themselves as unable to take care of themselves/ protect themselves from harm or exploitation; or who, due to their gender, mental or physical health, disability, ethnicity, religious identity, sexual orientation, economic or social status, or as a result of disasters and conflicts, are deemed to be at risk.

Child and young person:

Regarded to be any person under the age of 18 years, unless a nation’s laws recognise adulthood earlier.

Child abuse:

Includes physical, sexual, emotional, neglect, bullying, child labour and domestic violence. Abuse happens to male and female children of all ages, ethnicity and social backgrounds, abilities, sexual orientation, religious beliefs and political persuasion. In some cases, professionals and other adults working with children in a position of trust also abuse children.

Sexual Abuse of a child:

Occurs when a child or young person is used by an older or bigger child, adolescent or adult for his or her own sexual stimulation or gratification - regardless of the age of majority or age of consent locally. These can be contact or non-contact acts, including threats and exposure to pornography.

Child-Sex Tourism:

The commercial sexual exploitation of children by men or women who travel from one place to another, usually from a richer country to one that is less developed, and there engage in sexual acts with children.




Mary MacKillop Today explicitly prohibits sexual exploitation, abuse and harassment (SEAH) of any kind against any persons, adult or child. Mary MacKillop Today is committed to the safety and wellbeing of all staff, partners and beneficiaries. We are committed to demonstrating effective leadership in the promotion and implementation of this policy to ensure the safeguarding of all those working with Mary MacKillop Today. We take a victim-survivor-centred approach to PSEAH. We support the rights of children as stated in the United Nationals Convention of the Rights of the Child and we will act to uphold these rights.

PSEAH focal point

The CEO shall appoint a staff person to be the PSEAH focal point for the organisation who promotes this important aspect of our work through activities such as staff training, policy revision, tool development.

Guiding Principles

Mary MacKillop Today believes that all people (children and adults) should be equally protected and assisted regardless of their gender, nationality, religious or political beliefs.

Mary MacKillop Today believes that any form of behaviour that contradicts the standards of behaviour outlined in this or any other (Mary MacKillop Today) policy or the Code of Conduct is unacceptable. It recognises its duty of care to take reasonable steps to ensure people are safe from harm (including victims and whistleblowers). Compliance with this policy is mandatory for all staff, program partners and others who are engaged in Mary MacKillop Today work.

PSEAH risk management

Mary MacKillop Today recognizes that there a number of potential risks to vulnerable adults and children in the delivery of our programs. In recognising these risks, Mary MacKillop Today proactively assesses and manages these risks to reduce the risk of harm. This is achieved by examining each program and its potential impacts on the communities they serve.

Programs that involve direct work with vulnerable adults and children are considered a higher risk, and therefore require more stringent risk procedures. However, as children (and in some cases, vulnerable adults) are part of every community in which we work, we are always mindful of potential risks.

PSEAH Behavioural Standards

Staff members and others are responsible for maintaining a professional role and establishing and maintaining clear professional boundaries that serve to protect everyone from misunderstandings or a violation of the professional relationship.

All staff should conduct themselves in a manner consistent with their role as a Mary MacKillop Today representative and a positive role model.

Mary MacKillop Today’s PSEAH-specific behavioural standards require staff and partners to agree and adhere to the following:


• Undertake to create and maintain a safe and trusted environment that promotes the implementation of this Policy and safeguards everyone from SEAH.
• Be aware that sexual behaviour is an area of particular sensitivity, where conduct may more easily be seen as offensive or be misinterpreted.
• Ensure personal conduct towards a co-worker is not sexually exploitative or such that it reasonably leads to a perception of sexual exploitation.
• Immediately report any concern, suspicion or allegation of SEAH or breach of this Policy using the reporting guidelines and procedures outlined below.
• Take responsibility for ensuring I am accountable and do not place myself in positions where there is a risk of SEAH allegations being made.
• Immediately inform my Team Leader if: I become engaged in a personal relationship which may be perceived as inappropriate or sexually exploitative; if I am unsure if my relationship falls into this (SEAH) category; and/or where real or perceived unequal power dynamics exist.


• Engage in sexual relationships with program participants or beneficiaries.
• Use my position of trust and/or authority to: request any service or sexual favour from partners or beneficiaries of Mary MacKillop Today programs, be they adults, children or others in the communities in which Mary MacKillop Today works, in return for protection or assistance; and/or coerce a person to engage in sexual intercourse or any sexual activity.
• Exchange or withhold, from beneficiaries of Mary MacKillop Today programs, funds services or support of any kind for sex or sexual favours or other forms of humiliating, degrading or exploitative behaviour.
• Have sex with sex workers, even if it is legal in that respective state or country.
• Use Mary MacKillop Today or partner organisation facilities, personnel or resources for the purpose of arranging or facilitating access to sex workers by any person, including visitors to Mary MacKillop Today offices or programs.
• Engage in sexual activity with a child under any circumstance (even in a country where the age of majority or the age of consent is lower than 18 years).
• Use any communication device including computers, mobile phones, video cameras, cameras or other technology inappropriately, or to sexually exploit or harass adults or children, or access or disseminate exploitative material through any medium, including social media.
• Procure sex for others or use a third party to do so.
Mary MacKillop Today’s Code of Conduct for working with children (as per the Child Safeguarding Policy – policy 1.2) includes the following SEAH-relevant requirements:


• Treat all children and young people in our program with respect.
• Provide a welcoming, inclusive and safe environment for all children, young people, parents, staff and volunteers.
• Use appropriate language and communication with children at all times.
• Self-assess my behaviours, actions, language and relationships with children.

• Engage in behaviour that is intended to shame, humiliate, belittle or degrade children.
• Use inappropriate, offensive or discriminatory language when speaking with a child or young person.
• Do things of a personal nature that a child can do for him/herself, such as assistance with toileting or changing clothes.
• Take children to their own home/hotel or sleep in the same room or bed as a child.
• Develop sexual relationships with children or relationships with children that may be deemed exploitative or abusive.
• Behave provocatively or inappropriately with a child.
• Condone or participate in, behaviour of children that is illegal, unsafe or abusive.
• Photograph or video a child without the consent of the child and his/her parents or guardians.
• Hold, kiss, cuddle or touch a child in an inappropriate, unnecessary or culturally insensitive way.
• Seek to make contact and spend time with any child or young person outside the program times.
• Use Mary MacKillop Today’s computers, mobile phones, video and digital cameras inappropriately, nor use them for the purpose of exploiting or harassing children.

Use of children’s images

Mary MacKillop Today will at all times portray children in a respectful, appropriate and consensual way. Our guidelines on the use of images children’s images, in line with the ACFID Code of Conduct Clause 4.2, are comprised in the Child Safeguarding Policy. In essence a child should always be portrayed in a dignified and respectful manner and not in a vulnerable or submissive manner, that is in any way is suggestive or exploitative in nature.

Employment of staff and volunteers

Mary MacKillop Today is committed to rigorous recruitment, selection and screening practices. These practices aim to recruit the safest and most suitable people to work in our programs and are extended to the appointment of suppliers and contractors, as well as all partner staff working directly on Mary MacKillop Today activities.

The PSEAH Policy is communicated to and signed (at the end of this policy document) by all Directors, staff, volunteers, consultants and others (including partners) who act as representatives of the organisation as part of their induction.

PSEAH reporting guidelines and procedures

Mary MacKillop Today has zero tolerance for the sexual exploitation, abuse and/or harassment of anyone, adult or child. It explicitly prohibits sexual exploitation of any kind. Mary MacKillop Today will treat all SEAH-related concerns raised seriously and ensure that all parties will be treated fairly, and the principles of natural justice will be a prime consideration. All reports will be handled professionally, confidentially and expediently.

It is mandatory for all Mary MacKillop Today staff and others to report concerns or allegations related to SEAH or breach of the PSEAH policy.

All SEAH reports, concerns or allegations will be recorded by the person receiving the complaint using the latter part of Incident Reporting Form. Where possible, people making the complaint are urged to document their complaint using the first part of the Incident Reporting Form. They can submit the form anonymously.

The rights and welfare of the child is of prime importance. Every effort must be made to protect the rights and safety of the child throughout the PSEAH process.

Specific guidelines relating to relating to the safeguarding of children can be found in the Child Safeguarding Policy which includes the Code of Conduct for working with children.

This Policy protects any person who, in good faith, reports a case of SEAH or any person who has cooperated with a SEAH investigation.

Malicious or false reporting of SEAH with the intention of harming another person’s integrity or reputation amounts to misconduct and is subject to disciplinary action.

This is distinct from reports made in good faith based on the judgment and information available at the time of the report, which may not be confirmed by an investigation.

Community members (and children) with whom Mary MacKillop Today works will be provided with information about how to report any PSEAH concerns about Mary MacKillop Today staff members and others.


When to report?
• Concerns should be raised immediately.
How should it be reported?
• Whichever way is most comfortable for the person divulging the information, be they the victim/survivor or a concerned party.
• Reports can be made using Mary MacKillop Today’s PSEAH Incident Reporting Form that is available on our website:
• Reports can be made to:
 e: [email protected]
 t: +61 2 8912 2777
 post: PO Box 1646 North Sydney 2059 Australia
 contact our local office or partner.
• Anyone wishing to make a report anonymously can do so verbally or using the Incident Reporting Form without revealing their identity.
• Specific guidelines for complaints process relating to the safeguarding of children can be found in the Feedback and Complaints Handling Policy.

Who to report to?
• In Australia, a SEAH-related concern or allegation should be made to the CEO, respective Team Leader or PSEAH Focal Point.
• Overseas, SEA reports or concerns should be made to the respective Team Leader or Country Director. If this is not possible reports can be made directly to the Australian-based CEO or PSEAH Focal Point.
• If any person believes that Mary MacKillop Today has breached the ACFID Code of Conduct a complaint can be lodged directly on the ACFID website to the Code of Conduct Committee at

Once reported, what happens?
• The first steps once a concern or allegation is reported (verbal or written) will be for the person receiving the report to:
 Address any health and protection needs of the alleged victim
 Request the person making the report to complete the Incident Reporting Form (if they haven’t already)
 Gather all the relevant information
 Alert the CEO
 Conduct an initial assessment.
• Based on the findings of the initial assessment and considering the quality and reliability of the information, a decision on how to proceed will be made in consultation with the CEO.
• The following outcomes can result from the initial assessment following any SEAH-related report or allegation:
 Report to local (in-country) police and or Child Safeguarding authority
 Report made to the Australian Federal Police
 Concern handled internally if it is not a criminal matter
 No further action taken
• The CEO will immediately inform the Chair of the Mary MacKillop Today Board that an allegation has been made and continue to inform of steps taken.
• If the allegation constitutes a criminal offence in the country/ies involved, it will be reported to the appropriate and respective authorities.
• If it is a breach of any Mary MacKillop Today Policies or Code of Conduct, it will be dealt with as a disciplinary matter and may require further investigation.

How will assessments or investigations be conducted?
• All assessments or investigations will take on a victim/survivor-centred approach.
• All related assessments and investigation will be carried out in a respectful, timely, fair and objective manner, and will honour confidentiality where appropriate.
• All information and documented evidence will be held in the strictest confidence as far as is practical and appropriate.
• The name of the complainant will not be revealed to the person(s) potentially implicated in the allegation or to any other person unless the individual personally authorises the disclosure of their identity. (This may become a requirement in subsequent investigative processes.)
• Sensitive information, whether involving Mary MacKillop Today staff, partners or beneficiaries, shall be shared only with Australian or local law enforcement authorities, when a notification to police or appropriate authorities must be made or on a ‘need to know’ basis.
• Additional resources will be retained if necessary to ensure a thorough investigation.

What happens in the case of a criminal offence?
• The matter will be referred to the local police and or authorities if the allegation/s is considered to be a criminal offence.
• If the incident involves a Mary MacKillop Today staff member and/or happens within the ambit of a Mary MacKillop Today Program or activity, it will be reported to local state police.
• If the incident involves a person external to the organisation and/or takes place outside of a Mary MacKillop Today program or activity, it will be reported to the state Child Safeguarding authorities.
• Concerns about people engaging in child sex tourism, child sex trafficking and child pornography should be reported to the Australian Federal Police (Transnational Sexual Crimes Squad).
What happens when the matter has to be dealt with internally?
• If the incident is not a criminal offense, the matter will be handled internally through Mary MacKillop Today’s feedback and complaints process as outlined in the Feedback and Complaints Policy (policy 2.3).

PSEAH Incident Reporting Form

Please download here: PSEAH Incident Reporting Form