Policy on the protection from sexual exploitation, abuse and harassment (SEAH)

3 January 2024

Introduction and Purpose

At Upinion, we are dedicated to creating a secure, respectful, and inclusive environment for all individuals involved in our programs and activities. As part of our commitment to safeguarding the well-being and dignity of our beneficiaries, staff, volunteers, and partners, we have established a comprehensive policy that addresses Sexual Exploitation and Abuse (SEA) and Sexual Harassment.

This document can be found online on: https://upinion.com/resources/policies/policy-protection-from-seah/.

Upinion has adopted a victim/survivor-centered approach and is based on the foundational paper “Victim/survivor-centered approach to protection from sexual exploitation, abuse and harassment in the aid sector” released by CHS Alliance in 2023.

This policy outlines our core principles and strategies for prevention, awareness, risk mitigation, and response. 

The purpose of this policy is to:

  • Prevent Incidents: To proactively prevent incidents of SEA and sexual harassment within our organization and the communities we serve.
  • Raise Awareness: To create a culture of awareness and respect by educating our stakeholders about the issues of SEA and sexual harassment, their consequences, and the importance of reporting.
  • Mitigate Risks: To systematically identify and mitigate risks associated with SEA and sexual harassment, with a focus on Management and Coordination, Community Engagement and Support, Prevention, and Response.
  • Provide Guidance: To provide clear guidelines and procedures for reporting and responding to incidents, ensuring that victims receive appropriate support, and alleged perpetrators are held accountable.
  • Ensure Compliance: To ensure that Upinion, its employees, volunteers, and partners adhere to this policy and comply with all relevant laws and regulations related to SEA and sexual harassment.
  • Protection of (Alleged) Victims: In cases of alleged SEA and harassment, we prioritize the protection and support of (alleged) victims. Our objective is to create an environment where victims are empowered to come forward, and where their rights and needs are respected and addressed with the utmost care and sensitivity.

This policy underscores our commitment to the safety and dignity of all individuals we serve and engage with, and it serves as a guide for implementing preventive measures, raising awareness, and responding effectively to incidents when they occur.


  • Sexual Exploitation and Abuse (SEA): SEA encompasses any form of sexual activity or conduct involving an adult or a child, where consent is not or cannot be given, or is obtained through force, coercion, manipulation, or any other improper means.
  • Sexual Harassment: Sexual harassment comprises any unwelcome sexual advances, requests for sexual favors, or other verbal, non-verbal, or physical conduct of a sexual nature that creates a hostile or intimidating environment.
  • Sexual Discrimination: Treating individuals unfairly or making employment decisions based on their gender or sexual orientation, including promotion, compensation, or job assignments.
  • Victim/survivor-centered approach: an approach in which the victim/survivor’s wishes, safety and well-being remain a priority in all matters and procedures

Management and Coordination

  • Designated Team: The executive board of Upinion is responsible for overseeing the implementation of this policy, including the coordination of prevention and response efforts.
  • Reporting Mechanisms: We will ensure the existence of clear and confidential reporting mechanisms for individuals to report incidents or concerns related to SEA and sexual harassment. Reports can be submitted anonymously via the Incident Report Form.

Individuals and employees can also reach out through the following channels:

  • Internal channels:
    • Direct supervisor or manager
    • Executive Board
    • Supervisory Board
    • Incident Report Form
      • ​​Can be done anonymously
    • Dedicated whistleblowing email address
  • External channels:
    • Whistleblower Service
      • You can contact the external Whistleblower Service, Het Huis voor Klokkenluiders via +31 (0)88 1331 030 or [email protected].
    • External Confidential Counsellors
      • If you require assistance or have doubts about filing a report, Upinion has arranged support and advice through Assist Verzuim. You can contact Jill van der Vegt at 0546-347 721 or [email protected], who is the designated contact for Upinion and can coordinate with an independent confidential counsellor that best fits.

Stakeholder Engagement and Support

  • Education and Training: Upinion will provide regular training and education to employees, volunteers, partners, and beneficiaries to raise awareness about SEA and sexual harassment and to foster a culture of respect and safety.
  • Code of Conduct: We implement a comprehensive code of conduct that outlines expected behavior and responsibilities for all individuals associated with Upinion, including provisions related to SEA and sexual harassment prevention.
  • Victim Support: Upinion will ensure that victims of SEA and sexual harassment have access to immediate support and resources, including safety and protective measures, counseling and medical assistance, if necessary. 
  • Prioritizing the Affected Individual: The wishes of the victim/ survivor are central to this process.


  • Screening and Background Checks: Upinion will rigorously conduct background checks and screening procedures for employees, volunteers, and implementing partners who work directly with vulnerable populations.


  • Reporting and Investigation: Reports of SEA or sexual harassment will be promptly and thoroughly investigated by a member of the executive board. The organization will take appropriate action, which may include disciplinary measures and referral to legal authorities or external investigators.
  • Confidentiality: Upinion will strictly maintain confidentiality when handling reports and investigations, in compliance with applicable laws and regulations.

Compliance and Consequences

Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or association with Upinion. Legal action may also be pursued, as appropriate.

Review and Revision

This policy will undergo a periodical review and will be updated as necessary to align with changes in laws, regulations, and best practices.


This policy is effective as of 27 September 2023 and has been adopted by Upinion’s Executive Board. 

By adhering to this Policy on the Protection from Sexual Exploitation, Abuse and Harassment (SEAH), Upinion aims to maintain the highest standards of protection from sexual misconduct and protect the best interests of the company and its stakeholders.