This Policy sets the standards and the machinery by which SPAG prevents and responds to sexual exploitation, sexual abuse, sexual harassment and other safeguarding harm arising from its people, activities, research, events and partnerships. It exists to protect children, adults at heightened risk, participants, community members, colleagues and partners — anyone who may come into contact with SPAG.
SPAG applies zero tolerance for inaction. That formulation is deliberate: it means credible concerns are taken seriously, assessed and acted on through proper procedure. It does not mean an allegation is presumed proven, and it does not permit due process to be set aside.
A child is anyone under eighteen. That is SPAG's institutional standard everywhere it works, regardless of a lower local age of majority or consent. Where there is reasonable doubt about age, the person is treated as a child until age can properly be established.
The safety, dignity and wishes of a person who may have been harmed are a primary consideration. Support is never made conditional on taking part in an investigation, a criminal complaint or a disciplinary process, and it is not withdrawn because someone decides not to pursue a case.
If someone is in immediate danger, do not wait for SPAG
Reporting to SPAG is never a precondition for exercising a legal right or duty to report. Anyone entitled or required by law to report externally may go directly to a judicial, administrative, regulatory, law-enforcement or child-protection authority, and no SPAG process may obstruct or delay that. Where French law imposes a duty to report ill-treatment or a sexual offence against a child or a person unable to protect themselves, that report is made without avoidable delay.
Sexual exploitation and abuse
No covered person may use an SPAG role, relationship, resource, opportunity, authority, influence or access to obtain sexual activity, sexual contact, sexual images, sexual favours or any other sexual advantage. Exploitation covers attempts as well as acts, and benefiting from another person's exploitation.
Clause 4.2–4.3, 6.1Exchange of anything of value
Money, employment, consultancy, selection, recommendation, grant access, goods, services, assistance, information, influence or preferential treatment may never be exchanged, offered, requested or implied in exchange for sexual activity or favours in any SPAG-connected context.
Clause 6.2Sexual activity with a child
Prohibited wherever the relationship or contact arises from or connects to SPAG, regardless of any assertion of consent or any lower local age of consent. A mistaken belief about age does not excuse a failure to take reasonable steps appropriate to the circumstances.
Clause 6.3Grooming and online abuse
Building trust, secrecy, emotional dependency or access for the purpose of exploitation is prohibited, as is soliciting sexual images, sending sexualised communications to a child, exposing a child to sexual material, or using digital platforms to create or maintain an abusive relationship.
Clause 4.7, 6.4Sexual harassment
Unwelcome sexual or sexist conduct that violates dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment, and serious pressure for a sexual act or favour. One incident may constitute misconduct where its nature or severity warrants it. The prohibition covers conduct affecting colleagues, applicants, participants, partners and visitors alike.
Clause 4.4, 6.5Relationships involving power
No sexual relationship with a participant or affected person where it involves misuse of position, or where the covered person holds material authority over that person's funding, employment, participation, selection, assistance, evaluation or access to significant opportunity. A consensual adult relationship creating a material conflict must be disclosed and managed — without disadvantage to the other person.
Clause 6.6Violence and degrading treatment
Physical violence, cruel or degrading treatment, intimidation, coercion, exploitation, deliberate neglect and humiliation directed at a child or an adult at heightened risk in connection with SPAG activities are prohibited, whether or not the conduct is sexual in nature.
Clause 6.7Retaliation and interference
Retaliation, intimidation, pressure, threats, adverse treatment, interference with evidence, and attempts to discourage someone from making or supporting a safeguarding report are all prohibited — against the reporting person, the victim or survivor, a witness, an investigator or a support person.
Clause 6.8, 10.8Report it — you do not have to be sure
Anyone who becomes aware of, witnesses or reasonably suspects sexual exploitation, abuse, harassment involving misuse of SPAG authority, abuse of a child or serious safeguarding harm must report it promptly through an authorised channel. You are not required to investigate or establish proof first.
Do not investigate it yourself
Do not confront the alleged perpetrator, question a child or a victim or survivor repeatedly, or open an informal inquiry. Preserve safety, receive the information respectfully, record only what is necessary, and pass it to the proper channel.
Do not promise absolute confidentiality
Explain as early as you reasonably can that the information will be handled confidentially but may need to be shared where necessary for safety, legal reporting, investigation, due process or institutional accountability. Promising more than that cannot be kept.
Never circulate it casually
Safeguarding information moves on a strict need-to-know basis, stored with enhanced access controls and transmitted securely. Passing it through general email lists, messaging groups or shared folders is prohibited outright.
Immediate risk
The first question is whether anyone faces immediate or continuing risk. Protective or emergency action takes priority over administrative convenience or institutional reputation.
Clause 11.1Support
The person is given clear information about their options, likely next steps and the limits of confidentiality, and with consent may be referred to qualified external medical, psychosocial, legal or child-protection services.
Clause 11.2, 11.4Triage
An initial assessment establishes the nature of the allegation, safety needs, legal reporting duties, conflicts of interest, the competent process, the need for external referral and how to protect information and evidence — without premature findings.
Clause 12.1Interim measures
Proportionate precautionary steps may follow: changed duties or reporting lines, restricted access, removal from an activity, suspension of delegated authority. These are not findings of misconduct.
Clause 14.1–14.2Investigation
Only where authorised and necessary, by someone competent and impartial under a written mandate, planned to avoid unnecessary repetition of sensitive testimony. Interviews with children are supported by people with relevant expertise.
Clause 13.1–13.2Outcome
A proportionate response by the competent authority, from written direction through to termination or referral to external authorities — plus organisational correction where the failure lay in systems or supervision rather than one person.
Clause 15.1–15.2, 15.5Support is not conditional
Help is never made dependent on taking part in an internal investigation, a criminal complaint or a disciplinary process. Decisions about support and decisions about accountability are related but separate institutional functions.
Support does not depend on the outcome
Assistance does not hinge on whether an allegation is ultimately substantiated, and it is not withdrawn as punishment for declining to pursue a complaint or a criminal report.
An adult's wishes are respected
The wishes of an adult victim or survivor are respected as far as law and the safety of others allow. Before identifying information is shared, the person is told — where reasonably possible — the purpose, the recipient and the limits of confidentiality.
No forced confrontation or mediation
Nobody is required to face the subject of an allegation, enter mediation, repeat a detailed account unnecessarily, or take part in any process not necessary for the stated safeguarding purpose. Mediation is never a substitute for safeguarding action in cases of exploitation, abuse, violence, grooming or coercion.
A child's best interests lead
In any matter involving a child, immediate safety, best interests, age and maturity guide the response. The child's views are heard and taken seriously in a manner appropriate to their age, and specialist child-protection advice is sought where risk or complexity warrants it.
No conflicted handling
Nobody manages, investigates or decides a case where they hold an actual or reasonably perceived conflict. An allegation about the Focal Point, the Director-General or the President goes elsewhere — to a non-conflicted Bureau member or an independent external mechanism.
Findings rest on evidence, not assumptions
Decisions distinguish substantiated facts, corroboration, unresolved inconsistencies and matters that cannot be determined. They are never based on stereotypes, on assumptions about how a victim or survivor should behave, or on adverse inference drawn from delayed reporting.
The subject of an allegation has rights
They are not treated as having committed misconduct unless an authorised process concludes so, are informed of the substance of the allegation so far as safety and witness protection allow, and may respond before any adverse internal finding. An internal finding is not a declaration of criminal guilt.
Reporting a safeguarding concern
Concerns go to the designated Safeguarding/PSEAH Focal Point, the Director-General, the President, or another non-conflicted member of the Executive Bureau where the usual recipient is implicated. Anonymous reports are accepted where the channel permits them, and are assessed on the information available. A concern raised through the Whistleblowing & Complaints mechanism is routed here without asking you to submit it a second time.
A report is not treated as malicious merely because it cannot be substantiated, or because the person reporting later chooses not to take part.
