POLICIES AND DOCUMENTS

Project Rozana’s policies and documents guide the way we do our work and help ensure that our staff and volunteers, those included in our programs overseas and our supporters, are safe, protected and valued.

CHILD PROTECTION POLICY & PROCEDURES

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

This Policy will be reviewed every two years.

2. BACKGROUND

Project Rozana works indirectly with children through its partner training, transportation and treatment programs in Palestine and Israel. We believe that child protection is both an organisational and an individual responsibility. Every person who shares in the work of Project Rozana including Board members, specialist advisors, program partners, volunteers, sponsors and supporters, also share the responsibility to take every precaution to protect the children and families we assist and to adhere to the guidelines and expectations in this policy.

The partnerships include programs covering transportation of children and their caregivers from homes in the West Bank to hospitals in Israel; Summer Camps and Fun Days training and professional development programs in hospitals, and treatment in Israeli hospitals. Project Rozana is serious about its responsibility to ensure that its funding recipient partners commit to care for, protect and uphold the rights of children, regardless of their gender, age, race, disability, religion, political persuasion, social status, pregnancy, cultural background or sexuality, need to be equally protected from abuse. The Child Protection Policy outlines the implementation procedures for this commitment.

3. OBJECTIVE

  • To protect all children that Project Rozana directly or indirectly has contact with.
  • To ensure that all of the principles and procedures outlined in this policy are upheld and implemented by all Project Rozana and partner organisation employees and volunteers.

4. PURPOSE

The purpose of this Child Protection Policy is to ensure, as far as possible, the safety and wellbeing of all children who are involved in our partner programs and projects. In order to achieve its mission to build bridges to better understanding between Palestinians and Israelis through health, Project Rozana expects its partner recipients to act in the best interests of the child, and to uphold local legislative requirements pertaining to the safety and protection of children. The intention is to promote a culture of child safety within the organisation and to fulfill all Project Rozana’s legal obligations. Program recipients will also have their own policies and procedures in relation to providing safety and protection to children.

The Project Rozana Child Protection Policy outlines a risk management approach to providing safety and protection across all programs with its partners.

This policy aims to clearly outline definitions of child abuse and other relevant terms, our commitment to children’s rights and child protection and other relevant risk management approaches for partners to ensure child protection.

5. SCOPE

This policy applies to Project Rozana Representatives: all individuals and institutions who act on behalf of Project Rozana regardless of whether or not there is a formal legal agreement between them and Project Rozana. This includes, but is not limited to, all directors, employees, contractors, consultants, advisors, volunteers, casual laborers and implementing partners irrespective of which country their role is situated and the organisation’s partners including their employed staff and volunteers.

6. DEFINITIONS

Bullying “is aggressive behaviour that is intentional and that involves an imbalance of power or strength. Bullying occurs when a person is subjected to negative behaviour, repeated over a period of time, by another [person].” Bullying can take many forms:

Direct Bullying: “teasing, verbal attacks, shoving, assaults, extortion, and destruction of property.”

Indirect Bullying: “shunning, spreading rumours, malicious practical jokes, and similar verbal behaviour.”

Cyber-Bullying: “use of Internet technology, including social websites, text messaging and emails” that results in aggressive behaviour as defined above. (UNICEF, 2007)

Child means “every human being below the age of eighteen years” (Source: Article 1 of the CRC.).” (UNICEF, 2010)

Child Emotional Abuse refers to “inappropriate verbal or symbolic acts toward a child and/or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Emotional abuse includes rejecting, isolating, terrorising, ignoring and corrupting.” (Australian Institute of Family Studies: Child Family Community Australia, 2013)

Child Exploitation “(In the context of child trafficking) shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery or practices similar to slavery, servitude or the removal of organs. (Source: Article 3 of the ‘Palermo Protocol, adopted in 2000, entered into force in 2003.).” (UNICEF, 2010)

Child Sensitive means “an approach that balances the child’s right to protection and that takes into account a child’s individual needs and views (Source: UN Guidelines on Justice in matters involving child victims and witnesses of crime, 2005).” (UNICEF, 2010)

Child Trafficking is the “recruitment, transportation, transfer, harbouring or receipt of children for the purpose of exploitation. It is a violation of their rights, their well-being and denies them the opportunity to reach their full potential.” (UNICEF, 2010)

Exposure to Domestic Violence is broadly defined as a “child being present (hearing or seeing) while a parent or sibling is subjected to physical abuse, sexual abuse or psychological maltreatment, or is visually exposed to the damage caused to persons or property by a family member’s violence.” (Australian Institute of Family Studies: Child Family Community Australia, 2013)

Child Physical Abuse is “the non-accidental use of physical force against a child that results in harm to the child. Physical abuse behaviours include shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning. Fabrication or induction of an illness by a parent/carer is also considered physically abusive behaviour.” (Australian Institute of Family Studies: Child Family Community Australia, 2013).

Child Sexual Abuse includes:

a) “Engaging in sexual activities with a child who, according to the relevant provisions of national law, has not reached the legal age of sexual activities;

b) Engaging in sexual activities with a child where:

  • use of coercion, force or threats;
  • abuse is made of a recognised position of trust, authority or influence over the child, including within the family;
  • abuse is made of a particular vulnerable situation of the child, notably because of a mental or physical disability or a situation of dependence.”

Sexual Assault Sexual assault is any type of sexual contact or behaviour that occurs without the explicit consent of the recipient. (US Department of Justice, 2016).

GUIDING PRINCIPLES

Principle 1. Zero tolerance of child abuse.

Project Rozana does not tolerate any form of child abuse or child exploitation and is committed to working with its partners to identify, mitigate, manage or reduce the risks to children who are associated with Project Rozana funded programs. Project Rozana will not knowingly engage or partner — directly or indirectly — with anyone who poses a risk to children. Project Rozana works to minimise the risks of child exploitation and abuse associated with its functions and programs and trains its staff and partners on their obligations under this policy.

Principle 2. Assess and manage child protection risk and impact

While it is not possible to entirely eliminate risks of child exploitation and abuse, careful child-safe recruitment and screening procedures and child-focused management can identify, mitigate, manage or reduce the risks to children that may be associated with functions and programs supported by Project Rozana and implemented through its partners.

Principle 3.  Upholding the rights of the child

Project Rozana believes that all children have the right to developmental growth in accordance with the ‘United Nations Declaration on the Rights of the Child.’ It is committed to upholding the rights of the child under this convention. In all actions concerning children, the best interests of the child shall be a primary consideration.

Principle 4. Sharing responsibility for child protection

Project Rozana is committed to effectively managing risks to children, and requires the commitment, support and cooperation of partner organisations and individuals who help to deliver our programs.  Project Rozana expects that all allegations will be taken seriously and investigated by our partners, whilst respecting all parties and maintaining confidentiality throughout the process.

RESPONSIBILITIES

Project Rozana Management

  • Project Rozana professional staff are responsible for promoting children’s rights and for championing the protection of children. Management is responsible for implementation of these policies.
  • Project Rozana Child Protection Policies and Procedures will comply with the Code of Conduct in relation to child protection (set out below). Particular responsibilities include building child protection awareness, rigorous recruitment and screening practices, education and training including a yearly refresher course for all Representatives in an ongoing relationship with Project Rozana, responding to complaints and allegations, systems and administration.
  • Professional staff are responsible for promoting child safe messages in their work including appropriate child‐safe communications on websites, brochures, recruitment materials and publications including fundraising materials. Management has particular responsibility to support and develop systems that maintain this environment.
  • Management is responsible for ensuring that all Representatives entering into relationships with Project Rozana have read, understood and consented to compliance with this Child Protection Policy by signing a consent form (Annexure A).
  • Project Rozana is responsible for providing a version of this Child Protection Policy translated into Hebrew and Arabic to its program partners and commits to running Child Protection Training with program partners who are not already implementing their own Child Protection Policy.

All Representatives

All Representatives are obliged to create and maintain an environment which prevents exploitation and all forms of abuse and exploitation of children and promotes positive staff conduct.

  • All Representatives are responsible for having a thorough knowledge of these policies and procedures, acting in accordance with them and complying with the staff Code of Conduct.
  • Where a Representative develops concerns or suspicions regarding any type of child abuse and exploitation by a fellow worker, whether in the same organisation or not, s/he must report such concerns via the prescribed Project Rozana reporting mechanisms by the end of the day, or the following day if the reported incident happens after hours. Failure to report concerns or a suspicion regarding any type of child abuse and exploitation will be considered a breach of Project Rozana’s Child Protection Policy.

Project Rozana will ensure that partner program recipients declare their adherence to the processes and protocols as outlined in this policy and will:

  • Take seriously any reports of harm a child has disclosed to them.
  • Investigate and act on all child protection matters or allegations without harming the involved child.
  • Take immediate action on the matter or allegation.
  • Ensure that the best interests of the child are upheld.
  • Whenever appropriate and applicable, cooperate with parents and other professionals in protecting a child from harm.

CHILD PROTECTION AND RISK MANAGEMENT PROCEDURES

9.1 Child Protection Practices

  • Project Rozana will ensure that all partner grantees understand their responsibilities and requirements in dealing with child protection matters.
  • Project Rozana Representatives will be expected to exemplify appropriate conduct while maintaining safety and effectiveness when working with children.
  • Project Rozana Israel will evaluate the implementation of this policy in respect to its program partners on an annual basis and will report back to the Executive Board on this evaluation, together with any recommendations for improving the implementation of Child Protection Policy practices and procedures with its project partners.

9.2 Recruitment and Screening

Project Rozana will require that partner program recipients carefully screen all potential staff and volunteers who may come in contact with children. The screening process is comprised of the following standards and procedures:

1. All potential staff and volunteers must have completed criminal history check and/or documentation giving approval for direct work with children in accordance with Israeli or Palestinian legal requirements.

2. All references must be checked to ensure that there is no known history of child abuse or improper conduct in relation to children.

3. Job applicants must provide the partner program recipient with referees.

4. During orientation staff and volunteers are required to have read, understood and signed the Child Protection Policy.

PROCEDURES

10.1 Reporting Procedure

1. In the case where a child discloses abuse by an adult, another child, or any other person, staff must:

a) Listen to the child and observe the child’s demeanour and behaviour closely.

b) Demonstrate sincere interest and appropriate concern in the information relayed by the child.

c) Avoid questioning or investigating the child inappropriately or prompting the child’s answers.

d) Tell the child that you need to notify a trustworthy and relevant staff member who can help the child.

e) Immediately notify the designated Child Protection Officer in that organisation who must record all details of the matter in a Critical Incident Report Form (Appendix). If for any reason, the Child Protection Officer is not available, the incident must be reported to the most senior member of management available at that time. The report must be clear and accurate, detailing and recording the date, time, conversation, relevant observations, who was involved in the incident, how the incident occurred, and if the child has told their parents or anyone else, and what they told these individuals. The staff member who wrote the report must certify the report with their name, signature and date.

f) Whenever relevant and possible, collect any additional information regarding the matter, such as photos of lacerations or statements from any witnesses.

g) Staff must protect the child immediately and ensure that the same incident will not happen again, always considering the best interests of the child while investigating the matter or allegation. Staff must explain to the child the importance of reporting abuse and the process for notifying relevant officers about the abuse.

2. If the accused is a staff member or volunteer:

a) They must be suspended from their job or from volunteer service temporarily pending the results of an investigation. The accused will not be considered a perpetrator unless and until they have been proven guilty.

b) If the accused is found to be innocent of the allegations, they will be able to recommence work again. However, in circumstances where abuse or misconduct by a staff member or volunteer is proven beyond a reasonable doubt, the staff member will be terminated immediately (or in the case of a volunteer, immediately dismissed).

c) If an investigation is being conducted into the actions of a staff member, that person must be given a written notice of the reasons for their suspension from duties and will be advised of the result of the investigation as soon as it becomes available. During the course of the investigation, the staff member is not permitted to consult with other staff or children.

d) In the event that an allegation made against a staff member or volunteer is proven to be untrue, appropriate steps must be taken to follow up with the person who made the accusation, and disciplinary action may be taken if the person knowingly made a false report. If a child has made a false complaint, the seriousness of the matter must be discussed with the child, and counselling should be provided to the child and/or staff member/volunteer who was falsely accused.

3. The facts concerning the matter or allegation will remain confidential. The Child Protection Officer or reporting staff member is required to:

a) Send a copy of the initial report to the Project Rozana Israel Executive Director, who must in turn notify the Executive board and provide them with a copy of the report. All parties are bound by the rules of confidentiality.

b) Seek professional assistance in certain circumstances from an external organisation. In that case, the committee will need to report confidential information to that organisation.

c) In the event that the matter is of a criminal nature, the partner program organisation will assess the situation and progress through all necessary steps as directed by law, a lawyer or a relevant organisation.

d) Deal with all allegations in accordance with the child protection legislation within each program nation, Israel or Palestine. Compliance with child protection legislation may include reporting any allegations to the relevant authorities. Each program recipient is expected to become familiarised with the mandatory reporting requirements for its country.

e) Submit a final written report of the investigation detailing the findings and the actions taken. A copy of the report shall be filed with the program partner and with Project Rozana Israel.

10.2 Serious Misconduct

If staff or volunteers are found beyond reasonable doubt to have committed any of the below offences, immediate termination will be administered.

1. Any form of sexual assault, including but not limited to indecent assault, non-consensual sexual activity, aggravated sexual assault and attempted sexual assault.

2. Possession/dissemination/production of child pornography or child abuse material.

3. Inappropriate personal communication (including emails, telephone calls, text messaging, social media and web forums) that explores sexual feelings or intimate personal feelings with a child.

4. Grooming or procuring children for any sexual activity or trafficking.

5. Physical assault (including threatening a child, their family, or others).

 

APPENDIX A: PROJECT ROZANA CHILD PROTECTION CODE OF CONDUCT AGREEMENT

PROJECT ROZANA CHILD PROTECTION CODE OF CONDUCT AGREEMENT

The following behavioural protocols outline what is necessary when interacting with children. It is therefore imperative that all Project Rozana Representatives abide by the following protocols to ensure the protection and safety of children and sign the agreement below.

General Protocols

  1. Touching body parts or areas normally covered by underwear is not allowed. The only exception to this rule is for medical treatment by a medical professional. Children must be accompanied by an appropriate adult.
  2. If a child demonstrates negative body language, such as recoiling, pulling away, becoming stiff, dropping arms down their sides, or avoiding eye contact when being touched, regardless of intent, body contact must be discontinued immediately.
  3. Children are never to be encouraged or forced to touch another person against their will.
  4. Any form of behaviour that humiliates, degrades, or exploits a child or compromises a child’s wellbeing is prohibited including but not limited to the exchange of money, employment, and/or goods or services for personal gain including sexual favours.
  5. Adults will always be responsible for their behaviour and cannot blame the child for their actions, even if the child provokes or acts in a seemingly seductive manner.
  6. When interacting with children, employees and volunteers must communicate appropriately through their language, tone of voice, attitude, actions, body language and facial expressions.
  7. Employees and volunteers must never use physical discipline to guide children’s behaviour.
  8. Employees and volunteers are not to initiate, respond to, or encourage any inappropriate or culturally insensitive physical, emotional or social contact with children in the care of the recipient partner program.
  9. Staff or volunteers must not provide or administer any medication to the children unless stipulated in their job description.
  10. Staff or volunteers should not use any kind of digital media, such as computer, mobile phone, video camera, or digital camera to record the child’s picture in an inappropriate way. The staff member must not seek to benefit from the photo or dishonour the child.

When photographing or filming a child or using children’s images for work-related purposes:

  1. Take care to ensure local traditions or restrictions for reproducing personal images are adhered to before photographing or filming a child.
  2. Obtain informed consent from the child and parent or guardian of the child before photographing or filming a child. An explanation of how the photograph or film will be used must be provided.
  3. Ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive.
  4. Ensure images are honest representations of the context and the facts.
  5. Ensure file labels, meta data or text descriptions do not reveal identifying information about a child when sending images electronically or publishing images in any form.

APPENDIX B:

CRITICAL INCIDENT FORM

CHILD PROTECTION CODE OF CONDUCT AGREEMENT

 

CODE OF CONDUCT

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

The Code affirms the values that govern the behaviours of all Representatives of Project Rozana (see Definitions section below) The Code is intended to be used by Representatives in determining what is right and proper behaviour. It has been developed to provide a set of guiding ethical principles, associated obligations and standards of conduct, to assist in determining acceptable standards of conduct.

The Code:

  • Supports Project Rozana’s Representatives of diverse backgrounds to work effectively across cultural differences;
  • Serves as a reference point for decision making;
  • Aims to ensure the promotion of a positive image of Project Rozana, its Representatives and the implementation of the projects with which it is associated, and
  • Enables Project Rozana to manage risk by reducing the likelihood of damaging behaviours.

3. SCOPE & PURPOSE

This Code of Conduct applies to the following individuals: All Project Rozana staff, interns and volunteers including Board and Subcommittee members.

In addition to the above mentioned, Project Rozana may, at its sole discretion, ensure contractors, consultants, suppliers and grantees also comply with this policy. In this situation, a Project Rozana staff member with responsibility for engaging the
contractor, consultant, supplier or grantee will take steps to ensure their compliance with this policy, including through their declaration of any interests.

Where this policy is contradicted by contractual obligations to funders, the contractual obligations must be adhered to. Exceptions to such obligations should be sought from funders prior to entering into contracts and any substantive areas of difference must be drawn to the attention of the Executive Director of the Australian Office.

This Code of Conduct applies to the following activities:

  • Behaviour in connection with work with or for Project Rozana, even if it occurs outside normal working hours;
  • Behaviour during work activities with or for Project Rozana, for example when dealing with donors and other stakeholders;
  • Behaviour at Project Rozana-related events, for example social functions, Directors Missions etc. and
  • On social media: As interactions on social media with other persons if the views you represent are in violation of the code outlined herewith.

4. CONSEQUENCES OF BREACHING THIS CODE

Project Rozana expects that Representatives will report any breach of this Code (whether known or suspected, actual or potential – refer to point 11). Failure to raise known or suspected issues may result in disciplinary action, including termination of employment or engagement or involvement with Project Rozana. Some of these forms of conduct may also be unlawful and a breach under applicable laws.

5. ACFID CODE

Project Rozana is a member of the Australian Council for International Development (“ACFID”) and a signatory to the ACFID Code of Conduct (“ACFID Code”). Project Rozana is committed to full adherence to the requirements of the ACFID Code. Compliance with these requirements ensure transparency and accountability, improve international development effectiveness and increase stakeholder trust.

6. IMPLEMENTATION

We will explain to all Project Rozana Representatives the implications of this Code for their role during induction and in ongoing training. All Project Rozana Representatives will be made aware of the importance of this Code, and their own responsibility in upholding and implementing the requirements of this Code.

In addition, as part of the induction process, new Project Rozana Representatives will undertake the online learning module, Introduction to the ACFID Code of Conduct, and a copy of their Certificate of Completion will be kept on file. All Project Rozana Representatives will be made aware of the importance and implications of the ACFID Code for their role during induction and in ongoing training, and their own responsibility in upholding and implementing the requirements of the ACFID Code.

7. VALUES

It is our policy to conduct business in a professional manner with the highest standards of integrity and in accordance with applicable laws and regulations.
Project Rozana’s values include:

a) Always acting with fairness, honesty and integrity;
b) Being aware of and complying with all laws and regulations;
c) Maintaining the highest standards of professional behaviour, and
d) Dealing honestly through all communications and interactions with external parties.

Project Rozana does not tolerate sexual misconduct, harassment and bullying. Project Rozana regards these as serious and treats complaints in a sensitive, fair and confidential manner.

 

Project Rozana is committed to promoting and protecting the interests and safety of children and has zero tolerance for child abuse or child exploitation. Project Rozana maintains the highest standards of vigilance in relation to child safety and requires that its partners and sub-grantees do likewise.

 

Project Rozana is committed to the promotion of gender equality, equity and non-discrimination.

 

Project Rozana champions diversity in its workplace and is committed to the protection and promotion of diversity within its workforce including in relation to sexual orientation, gender identity and disability.

8. STANDARDS OF CONDUCT

8.1 Personal Conduct

In the performance of all Project Rozana and project related responsibilities, all Representatives must strive to achieve the highest standards of conduct and accountability, and to demonstrate high standards of professional integrity and honesty, and to:

a) Act in good faith, with care and diligence, and in the best interests of Project Rozana and the stakeholders of the projects with which it is associated;

b) Treat all persons, including children, with respect, dignity and reasonable compassion, in an equitable and fair manner, and with proper regard for their rights and obligations, regardless of race, colour, gender, religion, ethnic or social origin or disability;

  • Comply with, and be seen to act within, the spirit and letter of the law and the terms of this Code;
  • When travelling internationally, to respect the laws and values of the host country;
  • To obey any lawful direction, instruction or order given by any person authorised by law to do so;
  • To disclose any financial wrongdoing, corruption, bullying, transactional sex, misconduct or maladministration of which they become aware;
  • To act in the best interests of, and in a manner that will not reflect adversely on, Project Rozana, its partners and the stakeholders in projects with which it is associated, and the wider community;
  • To conduct themselves in a manner that does not discredit the individual person, having regard to their position within Project Rozana;
  • To perform any duties associated with their position conscientiously, courteously, efficiently, impartially, and to the best of their ability, in a manner that bears the closest external scrutiny and meets all legislative and Project Rozana standards;
  • To set and maintain standards of leadership that are consistent with Project Rozana’s goals and policies, be seen at all times to act in support of these goals and policies, and actively contribute to their achievement;
  • To seek to maintain and enhance the confidence of partners, colleagues, members, project stakeholders and the wider community in the integrity of Project Rozana;
  • To safeguard privacy and confidentiality of matters of a personal nature relating to donors, beneficiaries and other colleagues;
  • To adhere to management principles and practices that foster the rights and wellbeing of Representatives, and
  • To ensure equitable and fair workloads are shared.

All Representatives are specifically prohibited from:

  • Engaging in intimidation, bullying, harassment, sexual or other forms of exploitation or unlawfully discriminating against or otherwise abusing any person, including children (see 7.7 below);
  • Improperly using their official powers or position, or allowing them to be improperly used;
  • Inappropriately distracting other Representatives from carrying out their duties, or – inducing other Representatives to breach this Code.

8.2 Conflict of Interest

Representatives are expected to perform their duties in such a manner that stakeholder confidence and trust in the integrity of Project Rozana and the projects with which it is associated are preserved.

Representatives should endeavour to arrange their private or other official affairs in a manner that will prevent any actual or apparent conflict of interests from arising wherever foreseeable.

Where a conflict of interest does arise between the private or other official interests of a person and the official duties or responsibilities of that person within Project Rozana or in relation to a project with which Project Rozana is associated, the person is to disclose details of the conflict to the Board or relevant Project Coordinator.

Any conflict of interests relating to an individual’s association with Project Rozana will be resolved in favour of Project Rozana’s and the public interest.

In the event that a person is obliged to adhere to a Code other than that applying in Project Rozana (such as other professional codes) and ethical conflicts or dilemmas arise as a result, it is the person’s responsibility to draw such conflict of interests to the attention of the Board for resolution in consultation with the relevant professional body.

8.3 Political Activity

Any political activity by Representatives is to be conducted in a private capacity.
Representatives are expected to clearly separate any official action or views from any political action or views, and to ensure that no conflict of interests arises between such activity or comment and their official duties.

Project Rozana Representatives travelling overseas must never participate in any political or religious advocacy, demonstrations or attempts at conversion with nationals while representing the organisation.

8.4 Access to Project Rozana Resources

In the performance of Project Rozana responsibilities or responsibilities relating to projects with which Project Rozana is associated, Representatives are expected to:

  • Use or manage both human and material resources efficiently, effectively, and only for the benefit of Project Rozana, its partners and the projects with which Project Rozana is associated;
  • Avoid waste, misuse, abuse, or extravagant use, of resources of any kind belonging to or provided by Project Rozana;
  • Ensure that all facilities, physical resources and other property belonging to or provided by Project Rozana are given due care and maintenance;
  • Conserve and safeguard Project Rozana assets;
  • Budget honestly, and
  • Respect the environment by engaging in environmentally friendly work practices.

8.5 Gifts and Benefits

In their official capacity, Representatives are not to solicit any personal or other benefits, except where specifically authorised by Project Rozana (e.g., legitimate pursuit of donations or sponsorship in accordance with Project Rozana policy).

Project Rozana recognises that there will be instances where Representatives will be offered benefits (gifts, etc.) and that under certain circumstances it will be appropriate for Representatives to accept them. However, Representatives are to avoid all situations in which the acceptance of any benefit could create an actual or apparent conflict of interests with their official duties.

Representatives are to consider the following when making this decision:

  • Who is offering the benefit?
  • What is the purpose of the offer?
  • What is the timing of the offer?
  • Does the value of the benefit exceed a nominal value?
  • Is the offer likely to be regular or repetitive?
  • Is acceptance of the benefit consistent with other Project Rozana policy?
  • Could the acceptance compromise you, another person or Project Rozana?
  • Could acceptance of the benefit stand external scrutiny.

If there is any doubt about the intention or integrity of the source making an offer, Representatives are expected to reject the offer.

Where the value of the offer exceeds a nominal value of a $20 or equivalent, and refusal of the benefit may cause offence, the offer should be accepted and immediately brought to the attention of the board.

8.6 Payments to Government Public Officials

No Representatives are allowed to provide a benefit, or cause a benefit to be provided, or offer or promise to provide a benefit, or cause an offer or promise of provision of a benefit, to any public official. This relates to any person employed, contracted, performing work, or representing any government body, public enterprise, or any international agency including any international or multilateral agency.

Should any representations be made by any persons soliciting such payment or the provision of any such benefits, then this should be reported immediately to the Board of Project Rozana.

On occasions local custom may suggest providing minor benefits to public officials to expedite minor routine government action. Project Rozana does not condone such activities and in the event that they are likely to occur, this should be discussed with the Board prior to taking action. Examples of such activity would include expediting the issuance of visas or permits.

Any Project Rozana persons found not adhering to the above policy, will be subject to
disciplinary action. Should Project Rozana Representatives not adhere to the policy in the context of a project with which Project Rozana is associated, any funding of the project by Project Rozana may be terminated.

8.7 Child Protection

Project Rozana maintains a zero-tolerance policy towards child abuse. 

No Representatives are to engage in behaviour that is intended to shame, humiliate, belittle or degrade children, including using language towards children that is harassing, abusive, sexually provocative or culturally inappropriate.

All Representatives are required to adhere to the following rules when dealing directly with children (excluding where applicable the person’s own child or children), and in doing so take responsibility for ensuring that they do not place themselves in a position where they risk allegations being made against them:

  • Not invite unaccompanied children into a private residence unless they are in immediate risk of injury or in physical danger;
  • Not sleep close to unsupervised children, unless necessary and then only in the presence of another adult;
  • Not access or store child pornography via any medium;
  • Refrain from physical discipline of children;
  • Provide gifts that are not part of a Board approved activity. Any such gifts must be issued as part of an official Project Rozana ceremony, or as part of an approved project (e.g. the provision of iPads to assist children with educational activities).

When photographing or filming children for organization-related purposes Representatives must:

  • Endeavour to comply with local traditions or restrictions for reproducing personal images;
  • Obtain the informed consent of the child or parent/guardian of the child by explaining how the images will be used;
  • Ensure the images present children in a dignified and respectful manner, not a vulnerable or sexually suggestive manner, and
  • Ensure file labels do not reveal identifying information about the child if sending images electronically.

Representatives are obliged to immediately report concerns or allegations of child abuse in accordance with Project Rozana’s Child Protection Policy.

Depending on the severity of the infringement, failure to abide by these policies will result in termination of your association with Project Rozana.

8.8 Anti-Discrimination and Harassment

All Project Rozana Representatives are required to treat each other, and other people with whom they come in contact in our workplace, with respect, dignity and courtesy. In particular, Project Rozana Representatives must not commit any form of discrimination or harassment (including sexual harassment) in our workplace.

Project Rozana Representatives must not discriminate against another person for any of the following reasons:

  • Pregnancy, or breastfeeding;
  • Sexual orientation, gender identity, intersex status, marital or relationship status
  • Race, colour, descent, nationality, national origin, ethnicity or ethno-religious origin;
  • Religious belief or activity;
  • Political belief or activity;
  • Responsibilities as a carer or family responsibilities;
  • Disability or impairment;
  • Age; or
  • Service in the voluntary defence forces.

Project Rozana Representatives must not conduct themselves or behave in a manner that would be considered harassment or sexual harassment. Harassment is any form of behaviour that is unwelcome (not wanted) or uninvited (not asked for) or a reasonable person would have anticipated would humiliate, offend or intimidate someone.

Sexual harassment occurs when a person:

  • makes an unwelcome sexual advance, or an unwelcome request for sexual favours, to another person; or
  • engages in other unwelcome conduct of a sexual nature in relation to another person in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the other person exposed to the conduct would be offended, humiliated or intimidated.

Project Rozana Representatives must consider how their behaviour is viewed by others that they are dealing with. Different social or cultural backgrounds may lead a person to look at the same conduct differently from another person. It is possible to commit discrimination, harassment or sexual harassment whether the conduct was intentional or unintentional. It is not a defence that a person did not intend to humiliate, offend or intimidate another person.

8.9. Anti-Bullying

Project Rozana Representatives are required to take reasonable care to ensure that they do not behave in a manner which may adversely affect the health and safety of others in the workplace.

Project Rozana Representatives must not engage in any form of workplace bullying. Workplace bullying is the repeated and unreasonable behaviour directed towards a worker or a group of workers that creates a risk to health and safety, including behaviour that is victimising, humiliating, intimidating or threatening.

Single incidents of unreasonable behaviour are unlikely to be bullying but they can present a risk to health and safety and will not be tolerated.

Please refer to the Anti-Bullying Policy for further details about what will constitute bullying and our expectations of Project Rozana Representatives in this area. Representatives who become aware of an incident of workplace bullying should report it to their manager immediately.

Project Rozana staff, volunteers and contractors must be familiar with and comply with corporate policies including Project Rozana’s:

• EEO, Discrimination, Bullying and Harassment Policy
• Child Protection Policy
• Diversity and Inclusion Policy
• Feedback and Complaints Policy
• Partnership Policy
• Environmental Management Policy.

9. FINANCIAL WRONGDOING

Project Rozana regards and treats seriously any financial wrongdoing and maintains a zero-tolerance position towards financial wrongdoing.

Forms of Financial Wrongdoing include:

  1. Bribery – the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. Inducements can take the form of gifts, loans, fees, rewards or other advantages.
  2. Corruption – the abuse of entrusted power for private gain.
  3. Financial Wrongdoing – behaviour that is illegal or immoral with regards to financial transactions. Includes bribery, corruption, fraud, money-laundering, terrorism financing and violation of sanctions imposed by the Australian government.
  4. Fraud – Dishonestly obtaining a benefit, or causing a loss, by deception or other means. It extends to benefits obtained or derived that can be both tangible and intangible.
  5. Money Laundering – the process of concealing the origin, ownership or destination of illegally or dishonestly obtained money and hiding it within legitimate economic activities to make them appear legal.
  6. Terrorism Financing – intentionally providing or collecting funds and being reckless as to whether those funds would be used to facilitate or engage in a terrorist act. Prior to signing any agreements regarding Board appointments or with partners, the name of the individual or organisation will be checked against the DFAT ‘Consolidated List’ of persons and entities subject to targeted financial sanctions (imposed by resolution of the UN Security Council), and the Attorney-General’s Department ‘List of Terrorist Organisations’ as per Division 102 of the Criminal Code 1995. Project Rozana will not engage with any individuals or entities that appear on those lists.

All Project Rozana Representatives are responsible for financial wrongdoing prevention and detection. In the case of any incident of suspected or detected financial wrongdoing arising from the actions of Project Rozana Representatives, the incident must be reported immediately to the Project Rozana Board.

In the case of any incident of suspected or detected financial wrongdoing arising from the actions of someone in a Partner Organisation and affecting a project with which Project Rozana is associated, this should be handled accordingly to the Project Rozana’s formal internal procedures and must be reported to the Project Rozana Israel Executive Director, the Project Rozana Chair and thereafter to the Project Rozana Israel Board and International Board. This report will be in writing and will initially include the following information:

  • Name of the project or activity;
  • Name of parties involved;
  • Details of the suspected/detected financial wrongdoing, including a chronological account of the facts giving rise to the financial wrongdoing;
  • Details of any witnesses;
  • Copies of relevant documents;
  • References to any relevant legislation;
  • A nominated contact person;
  • Any other relevant information (e.g., possible local sensitivities, relevant in-country agencies that can assist with investigations) and
  • The current status of any inquiries.

Subject to the decision of the Project Rozana International Board, Project Rozana will investigate the suspected or detected financial wrongdoing and the Board will agree on a strategy to be followed to obtain redress, where appropriate, in light of the investigation’s findings. If the financial wrongdoing has occurred in the context of a project with which Project Rozana is associated, Project Rozana funding may be terminated in accordance with Project Rozana’s Partnership Policy. If there is reasonable prospect that laws were broken, police in an appropriate jurisdiction will be informed.

10. PARTNER DUE DILIGENCE

A full list of the parameters that Project Rozana considers before signing a Partnership
Agreement is provided in Project Rozana’s Partnership policy. However, as a minimum, due diligence requires that the following parameters are assessed, and if it is not possible to work with the potential partner to remedy any deficiencies with respect to these parameters, Project Rozana will not proceed with signing an agreement.

– The potential partner must be legally registered and have effective governance arrangements such as a Board, management structure, etc.
– The potential partner must have appropriate systems to manage its funds and maintain records and capacity to manage and control funds.

– The potential partner does not appear on any of the prohibited entities listed in Section 9 above.
– The potential partner has the capacity to implement key safeguarding and risk policies, such as child safeguarding, protection of vulnerable persons from sexual exploitation, financial wrongdoing, complaints, separation of development and non-development activity.
– The partner has the capacity to apply funds or resources in accordance with the promise to the donor, our strategy and our specific instructions.

11. DETERMINING APPROPRIATE CONDUCT

In the first instance, Representatives are expected to assess the appropriateness of their own conduct in relation to decisions or actions they take as follows:

  • Would your decision or action withstand scrutiny by the community or Project Rozana?
  • Will your decision or action comply with this Code of Conduct and Project Rozana policy?
  • Does your decision or action comply with all laws, regulations and rules?
  • Is your decision or action fair to the community, your family, your colleagues and others?

Project Rozana’s responsibility in determining whether a person’s conduct is right and proper in terms of this Code requires examination of:

  • The nature of the conduct exhibited, and
  • The context in which the conduct takes place.

Appropriateness of conduct is determined within this framework, with reference to the
expectations of Project Rozana, applicable legislation, the wider community and the provisions of this Code.

Where the conduct of a person does not satisfy the self-assessment criteria above, or will otherwise adversely reflect on Project Rozana, it will be deemed by Project Rozana as inappropriate hereunder.

12. BREACHES OF STANDARDS OF CONDUCT

All Representatives are expected to familiarise themselves with this Code and ensure that its provisions are observed. Failure to comply with standards of conduct outlined in the code, without valid reason, will be addressed as an issue that may involve either termination of the person’s position in Project Rozana or termination of Project Rozana’s funding of a project or partnership with Project Rozana.

Representatives requiring advice or assistance concerning their obligations under this Code should seek assistance from the Project Rozana.

When assessing perceived or actual breaches of the Code of Conduct, the Project Rozana Board will adhere to the principles of natural justice, i.e., the affected person must be given the opportunity to present their case and have that information considered before any decision is made; and the decision maker must have no personal interest in the matter to be decided, have no bias as to the outcome, and act in good faith throughout the process.

CODE OF CONDUCT AGREEMENT

 

COMMUNICATIONS POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

Project Rozana’s mission is to build bridges to better understanding between Israelis and Palestinians using the platform of health.

To achieve such an ambitious goal, we need to inspire and motivate many diverse stakeholders. Images and case studies play a vital role in helping us to do this by bringing our work to life and raising awareness.

The images we choose and the stories we write must represent our work accurately and show a true and authentic account of the ways in which people benefit from the work we do.  Authenticity is key to upholding our reputation.

The gathering of images and case studies can cause harm if it is not carried out to a high ethical standard and they can cause offence if sourcing them is intrusive or inappropriate. The use of images can also be counter-productive if they are reproduced inaccurately or with manipulation.

Anybody gathering or using images for or on behalf of Project Rozana, or commissioning someone else to do so, must read the following guidelines before carrying out their work.

 

Anyone commissioning a photographer or filmmaker or travelling with supporters or Directors taking images is responsible for ensuring that our ethical standard is adhered to at all times.

3. PURPOSE

Project Rozana Australia communicates about its programs and their impact to a range of stakeholders, for reporting and fundraising purposes. This includes the production and distribution of communications materials such as annual reports, newsletters, donor updates and acquittal documents, promotional collateral, the Project Rozana website, social media platforms, television and radio interviews, and podcasts.

The purpose of this policy is to ensure that images and stories collected by staff, volunteers and partners are collected, sourced and used honestly and ethically, according to Project Rozana’s values, and safeguarding and compliance
obligations.

All stories and images collected and used must portray the people and communities, with whom Project Rozana works, with respect, dignity and accuracy. This policy is part of Project Rozana’s accountability to its local partners and primary stakeholders whose stories and images it shares, to ensure that their rights, safety, dignity, privacy, cultural and religious beliefs are respected and protected.

Moreover, our photographs, videos and case studies are an expression of our approach to equality and non-discrimination; therefore, we must consider who we are taking photographs of. All individuals should be shown in a dignified way. This is particularly important for individuals who may face discrimination or exclusion. This may include, but is not limited to, older people, women, people with disabilities, and children. Photographers and filmmakers should ensure that they depict people who may be discriminated against as an integral part of society and the
community.

4. SCOPE

This policy applies to all Project Rozana staff, those who are engaged by Project Rozana to perform any part of Project Rozana’s program activity, and anyone who is collecting, sourcing and using stories and images about these activities, including:

  • staff;
  • contractors/consultants;
  • program volunteers;
  • program sub-contractors or partners;
  • and Directors.

This policy covers both still (photographs) and moving (video) imagery and recorded,
transcribed or written interviews and direct quotes, collected by Project Rozana Representatives (as defined above). It applies to information, stories and images collected for research, evaluation, donor, supporter and public engagement purposes and all material published by Project Rozana about its projects and activities regardless of format.

5. DEFINITIONS

Stories – the direct quotes, facts and personal details obtained during an interview and used in messaging, case studies, reports and communications.

Images – means still (photographs and illustrations) and moving (video and animation)

Child – is an individual below the age of 18 years.

Content — videos, photos, stories and interviews that may be used to illustrate any aspect of Project Rozana’s programs and activities.

Free, prior and informed consent — a person understands why their image, story and/or personal details are being collected; where and how they will be used and over what period of time; that their participation is entirely voluntary; the potential risks and consequences of their image, name and words being published; and then agrees to Project Rozana collecting the content. The person feels free to say ‘no’ to their image or story being collected and understands that this will not negatively impact on the benefit they derive from participating in a Project Rozana program.

Adequately clothed — no full nudity; no genitals, nipples or naked bottom clearly visible; any partial nudity is appropriate to age and gender and relevant to the context and Project Rozana’s work

6. COMPLIANCE REQUIREMENTS AND STANDARDS

Project Rozana content must comply with:

  • Writing Style Guide and Brand Guidelines. Project Rozana’s approval for all final versions of stories must be obtained from Executive Director, prior to publication;
  • Child Safeguarding Policy as well as the Child Safeguarding Manual which include
    Project Rozana’s specific commitments relating to the photographing or filming of children and use of children’s images and personal information;
  • Australian Council of International Development (ACFID) Code of Conduct. Project Rozana is committed to meeting the quality principles and commitments within that Code as it relates to the way that Project Rozana portrays local people that benefit from Project Rozana’s programs in communications about its work. (Principle 6: Communications);
  • and Department of Foreign Affairs and Trade (DFAT) Branding Guidelines where
    appropriate, in relation to promotional materials that publicise DFAT-funded
    programs. https://dfat.gov.au/about-us/corporate/Pages/logos-and-styleguides.
  • Project Rozana staff, volunteers, Directors, contractors, sub-contractors and partners (hereafter referred to as Project Rozana Representatives) will be provided with a copy of this policy and be required to adhere to this policy when collecting content on behalf of Project Rozana.

Project Rozana Representatives will collect and use content ethically in line with the following minimum standards:

a) Stories and images collected from adult and children by Project Rozana Representatives will:

  • Depict people and their issues, experiences and lives respectfully and truthfully,
    retaining the intended meaning of the information they provide and ensuring honest visual portrayals.
  • Protect the privacy and safety of people and their information by identifying people by first name only and in the case of children, not using their name (or using a pseudonym). All content will be accurately credited and captioned while also protecting people’s privacy and safety;
  • Present people in a respectful rather than vulnerable or demeaning way. This
    includes ensuring that images are taken of people that are adequately clothed;
  • Respect people’s self-worth, values, history, religion, language and culture, protects their rights and ensure they are portrayed with dignity and strength as active partners in their own development, with the ability to change. People will not be portrayed as victims or presented in a dehumanised manner;
  • Authentically represent the environment, context, situation and people — the need, the proposed solutions, and the impact of Project Rozana’s work. This will be done without embellishment, exaggeration, material omissions, manipulation or significant alteration to mislead audiences or to alter meaning, facts, concept or context;
  • Be gathered in a respectful and sensitive way that does not exacerbate people’s
    trauma, and respects cultural differences and local traditions, laws and restrictions; and
  • Provide people, with whom Project Rozana works, with an opportunity to communicate their stories to Project Rozana, in their own words, without prejudice, judgement or fear of retribution, and also have the opportunity to seek information from Project Rozana about any aspect of the collection and use of content involving them.

b) Free, prior and informed consent of people will be obtained before collecting and using their personal information, stories and images:

  • Before stories and photos are collected, Project Rozana Representatives will obtain free, prior and informed consent from the person being photographed, filmed or interviewed using the Project Rozana Consent Form (see Appendix A). For children in all circumstances, consent must be obtained from the child’s parent and guardian. Where appropriate and possible consent must also be obtained from the child;
  • The consent process will be explained clearly in the local language of the person
    whose consent is being obtained to ensure that their consent (if provided) is
    informed;
  • Informed consent must be acknowledged in writing by the subjects if possible, and where not possible in writing by the Project Rozana person to indicate that verbal informed consent has been received. Where possible, the Project Rozana Representatives will record or film the consent process;
  • Project Rozana will respect a person’s right to refuse to be interviewed, photographed or filmed. If Project Rozana Representatives sense any reluctance or confusion, they should refrain from continuing the interview or taking the photo or video;
  • Project Rozana will not provide payment or any other form of compensation to local people in exchange for their photograph or film to be taken or their information collected, and story told;
  • Project Rozana will ensure that the content being used, and the associated permissions, are current and consistent with the terms of consent provided; and
  • Project Rozana will stop using content when requested by the subjects to remove the content from circulation.

c) Stories and images will be stored securely:

  • All images and images will be securely stored, and only approved content published;
  • All content developed will be approved by the Executive Director or their
    nominated representative prior to publication; and
  • All stories and images that are collected by Project Rozana sub contractors or contractors will be handed over to Project Rozana staff at the end of a program activity and all information and images deleted from devices on which they are stored. Project Rozana sub contractors or contractors will not share stories and images gained during a Project Rozana program activity for personal use on social media or in public presentations without the written consent of Project Rozana.

d) Additional standards relating to children:

In addition, when collecting stories or images of children, Project Rozana Representatives must adhere to standards outlined in the Child Protection Policy to ensure children are portrayed in a respectful, appropriate and consensual manner at all times. This means that when collecting children’s stories and images must:

  • Ensure that local traditions or restrictions for reproducing personal images are
    adhered to before photographing or filming a child;
  • Obtain informed consent from the child’s parent/guardian/caretaker of the child in all circumstances, and the child where appropriate and possible, before photographing, filming a child or using their personal information. At a minimum, informed consent means explaining to the parent/guardian/caretaker and child the implication, purpose and potential uses of the photograph, film or personal information. This consent should be documented using the Project Rozana Consent Form (see Appendix A);
  • Ensure that children are represented in a dignified and respectful manner (i.e.,
    adequately clothed and depicted in a manner which is not vulnerable, submissive or sexually suggestive) in all photographs, films and videos;
  • Ensure that images of children are honest and factual representations of the context in which they were taken;
  • Ensure that file labels, meta data or text descriptions do not reveal identifying
    information about a child (such as a child’s name) when sending images electronically or publishing images in any form; and
  • Obtain Project Rozana consent before storing, transferring or using any images for evaluation, education, promotional and/or fundraising purposes.
  • Sign a copy of the Project Rozana Child Protection Policy & Child Protection Code of Conduct (see Appendix B) to confirm they have read and will abide by Project Rozana’s stated policies and procedures when working with children.

Project Rozana is committed to keeping children safe when collecting and using their images and personal information. Detailed guidelines on Taking and Using Visual Images and Personal Information of Children are outlined in the Child Protection Code of Conduct.

7. ASSOCIATED DOCUMENTS

Child Safeguarding Policy
Child Safeguarding Manual
Privacy Policy
Project Rozana Consent Form
HR Manual
DFAT Branding Guidelines

APPENDIX A: PROJECT ROZANA CONSENT FORMS

Consent Form – Adult

Consent Form – Minor

APPENDIX B: CHILD SAFEGUARDING AGREEMENT

Child safeguarding declaration.

CONFLICT OF INTEREST POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. PURPOSE

Project Rozana is committed to high standards of ethical conduct and accordingly places great importance on making clear any existing or potential conflicts of interest. The purpose of this policy is to help Board members, staff, volunteers and contractors effectively identify, disclose and manage any actual, potential or perceived conflicts of interest in order to protect the integrity of Project Rozana and manage risks.

Project Rozana aims to ensure that Board members, staff, volunteers and contractors are aware of their obligations to disclose any conflicts of interest that they may have, and to comply with this policy to ensure they effectively manage those conflicts of interest as representatives of Project Rozana.

2.1 The Reality That Conflicts of Interest Will Arise

It is accepted that from time to time, Conflicts of Interest will arise despite diligent efforts to avoid their occurrence. This reality is, of itself, not a breach of this Policy, however this Policy requires that Conflicts of Interest be identified effectively and disclosed transparently so that they can be managed appropriately.

3. DEFINITIONS

Project Rozana defines a conflict of interest as a situation in which a personal interest may interfere with a person’s responsibility to act in the best interest of the NGO. Personal interests include direct interests as well as those of family, friends, or other organisations a person may be involved with or have an interest in (for example, as a shareholder). It also includes a conflict between a Board member’s duty to Project Rozana and another duty that the Board member has (for example, to another charity).

A conflict of interest may be actual, potential or perceived and may be financial or non-financial.

Actual Conflict of Interest: A direct conflict with your Project Rozana responsibilities, stemming from a personal or third-party interest or obligation that affects your ability to make impartial decisions.

Potential Conflict of Interest: ​A conflict with your Project Rozana responsibilities, stemming from a personal or third-party interest or obligation, that could, in the future affect your ability to make impartial decisions.

Perceived Conflict of Interest​: A conflict where it could reasonably be perceived or give the appearance that a personal, third-party interest or obligation would affect your ability to make impartial decisions while carrying out Project Rozana responsibilities.

4. POLICY AND POLICY PRINCIPLES

Conflicts of interests may occur if an interest or activity influences, or appears to influence, the ability of a Board member to exercise objectivity. This policy has been developed because conflicts of interest commonly arise, and do not need to present a problem to the organisation if they are openly and effectively managed.

It is the policy of Project Rozana, and the responsibility of the Board and staff, to make clear any ethical, legal, financial or other conflicts of interest. All such conflicts of interest shall be declared by the Board or staff member concerned and documented in the Register of Interests in Appendix A.

Project Rozana will manage conflicts of interests by requiring Board and staff members to:

  • Avoid conflicts of interests where possible;
  • Identify and disclose any conflicts of interest;
  • Carefully manage any conflicts of interests;
  • Respond to any breaches;
  • Not initiate or take part in Board discussions or staff meetings on topics where conflicts of interest exist unless invited to do so by unanimously agreement by other members present; and
  • Not vote on matters where there are conflicts of interest.

4.1. Responsibility of the Board

The Board is responsible for:

  • Establishing a system for identifying, disclosing and managing conflicts of interest across the organisation. At a minimum, this includes making conflict of interest a standing agenda item for all Project Rozana Australia and International Office Board meetings, including the Executive Board;
  • Monitoring compliance with this policy; and
  • Periodically reviewing this policy to ensure that the policy is operating effectively.

Project Rozana is registered with the Australian Charities and Not-for-profits Commission (ACNC) and hence must ensure that its Board members are aware of the ACNC governance standards and that they disclose any actual or perceived material conflicts of interests as required by governance standard 5.
The ACNC governance standards are available and a copy of governance standard 5 is also provided at Appendix B.

4.2 Identification and disclosure of conflicts of interests

Board members shall declare any conflicts of interest of which they become aware either at the start of the Board meeting concerned or when a relevant issue arises. The nature of this conflict of interest should be entered into the meeting minutes. The interest should also be documented in the Register of Interests.

Where all of the other Board members share a conflict, the Board can refer to governance standard 5 to ensure that proper disclosure occurs. The Register of Interests will be maintained by the Project Rozana Executive Directors in each country. The Register of Interests records information related to a conflict of interest including the nature and extent of the conflict of interest and any steps taken to address it.

Staff can declare a conflict of interest at any time, by raising it with their supervisor, and the Executive Director. The conflict is reported to Board  and a separate Register of Interests is maintained for staff, contractors and volunteers, also noting the nature and extent of the conflict of interest and any steps taken to address it.

4.3 Confidentially of disclosures

Only the following people will have access to the information relating to conflicts of interest disclosed by Board and staff members:

  • Board members and Board observers; and
  • Project Rozana Executive Management

5. ACTION REQUIRED FOR MANAGEMENT OF CONFLICTS OF INTEREST

5.1 Conflicts of interests of Board members

Once the conflict of interest has been appropriately disclosed, the Board (excluding the Board member disclosing and any other conflicted Board member) must decide whether or not those conflicted Board members should:

  • Vote on the matter (this is a minimum);
  • Participate in any debate; and
  • Be present in the room during the debate and the voting.

In exceptional circumstances, such as where a conflict is very significant or likely to prevent a Board member from regularly participating in discussions, it may be worth the Board considering whether it is appropriate for the conflicted person to resign from the Board.

5.2 What should be considered when deciding what action to take

In deciding what approach to take, the Board will consider:

  • Whether the conflict needs to be avoided or simply documented;
  • Whether the conflict will realistically impair the disclosing person’s capacity to impartially participate in decision making;
  • Alternative options to avoid the conflict;
  • The organisation’s objects and resources; and
  • The possibility of creating an appearance of improper conduct that might impair confidence in, or the reputation of, the organisation.

The approval of any action requires the agreement of at least a majority of the Board (excluding any conflicted Board member/s) who are present and voting at the meeting. The action and result of the voting will be recorded in the minutes of the meeting and in the Register of Interests.

6. COMPLIANCE WITH POLICY

If the Board or Executive Director has a reason to believe that a person subject to the policy has failed to comply with it, they will investigate the circumstances. If it is found that this person has failed to disclose a conflict of interest, the Board or Executive Director may take action against them. This may include seeking to terminate their relationship with the organisation.

If a person suspects that a Board or staff member has failed to disclose a conflict of interest, they must discuss with the person in question and notify the other Board members, or the Executive Director in the case of staff.

 

APPENDIX A:

REGISTER OF INTERESTS FORM

APPENDIX B: ACNC GOVERNANCE STANDARD 5

Governance standard 5: Duties of responsible persons

This standard requires charities to take reasonable steps to make sure that the following duties apply to responsible persons and that they follow them. The duties can be summarised as follows:

  • to act with reasonable care and diligence
  • to act honestly and fairly in the best interests of the charity and for its charitable
    purposes
  • not to misuse their position or information they gain as a responsible person
    not to disclose conflicts of interest
  • to ensure that the financial affairs of the charity are managed responsibly, and
    not to allow the charity to operate while it is insolvent.

Generally, the duties mean that responsible persons should act with standards of integrity and common sense.

Purpose of this standard

A charity must make sure that its responsible persons are required to meet a set of legal duties. This ensures that they act in the best interest of the charity and in a way that doesn’t endanger its work. Responsible persons have a responsibility to put the interests of their charity above their own personal interests. Generally, they need to be careful and conscientious in their roles and act with standards of common sense and integrity.

  • The purpose of this standard is to give the public confidence that your charity’s responsible persons are managing the charity well and meeting these duties.

Ways to meet this standard

  • Steps your charity can take to meet this standard are to:
  • bring these duties to the attention of responsible persons (such as providing them with a copy of this guidance or other resources) or outline their duties in a letter of appointment or by setting them out in a board or committee charter
  • regularly provide information or training to responsible persons on their duties to refresh their knowledge (such as by advising of ACNC webinars on relevant topics, such as Welcome to the board)
  • encourage responsible persons to attend, prepare for, and participate at meetings
    have processes for the responsible management of money
  • have processes in place to manage conflicts of interests, and
  • take action if your responsible persons are failing to meet their duties.

Other laws on the duties of responsible persons
Your charity’s responsible persons may already be subject to duties under other laws that apply to it. For example:

  • equivalent duties exist in state or territory incorporated associations legislation – if your charity and its responsible persons comply with these duties, your charity will meet this standard
  • for companies under the Corporations Act 2001 (Cth), the governance standards
    replace most requirements relating to director duties under this Act. However, some criminal offences under this Act and similar duties under common law continue to apply. Read more about the changes for charities registered with ASIC and ACNC, and
  • trustees will generally have higher duties (for example, under the common law).
COUNTER TERRORISM AND MONEY LAUNDERING POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

Project Rozana’s Mission is to build bridges to better understanding between Israelis and Palestinians through health. This community-wide, multi-faith health initiative achieves this by raising funds to:

  1. Train Palestinian health professionals in Israeli hospitals in order for them to return and build the health capacities of their communities, particularly where there are identified gaps;
  2. Transport Palestinian patients from home to checkpoints in Gaza and the West Bank to hospitals in Israel and back home via our partner NGOs, and
  3. Treat critically ill Palestinian children in Israeli hospitals in cases where funding from the Palestinian Authority is not available.

Project Rozana works with partner organisations in the region. Our work is supported by private philanthropy, Trusts and Foundations. Project Rozana spends funds raised in an effective manner to deliver on our Mission.  We recognise that there is a level of risk in relation to terrorist financing and this policy seeks to prevent any form of terrorism that might occur wherever possible.

This policy sets out Project Rozana’s commitment to comply with Australian laws relating to counter terrorism, through processes and policies that minimise the risk of support for terrorists and terrorist organisations, especially those on the UN Security Council’s Consolidated List and the Australian Government’s List of Terrorist Organisations.

The Australian government has enacted legislation consistent with a number of international counterterrorism treaties designed to combat terrorism. The relevant legislative mechanisms prohibiting activities in relation to individuals and organisations associated with terrorism can be found in:

  • Part 5.3 of the Criminal Code Act 1995 (‘the Criminal Code’); and
  • Part 4 of the Charter of United Nations Act 1945 (‘the UN Charter Act’)

The Criminal Code provides stringent penalties for, amongst other things, intentionally or recklessly ‘getting funds to or from a terrorist organisation’ (section 102.6), ‘providing support to a terrorist organisation’ (section 102.7) and ‘financing terrorism’ (section 103.1). A list of ‘terrorist organisations’ for the purposes of the Criminal Code is available on the National Security Australia website.

Under the UN Charter Act, it is an offence to “directly or indirectly make any asset available to a proscribed person or entity”. An asset is very broadly defined as “asset of any kind, or property of any kind, whether tangible or intangible, movable or immovable”. While the UN Charter Act applies less stringent penalties, it has a much broader application in the aid context due to its very wide definition of asset. A list of proscribed persons and entities is available from DFAT at:

In addition, Project Rozana will check the following two lists to ensure it doesn’t deal with any listed terrorist organisations and/or proscribed persons or entities.

  • World Bank Listing of ineligible firms and individuals;
  • Asian Development Bank Sanctions List.

3. PURPOSE

Project Rozana condemns all forms of violence including terrorism and activities related to terrorist financing in relation to its mission. Project Rozana is obligated to ensure that funds and resources sought from donors and the general public are used for their intended purpose, along with being honest and transparent, while being accountable to all stakeholders. This policy states our commitment to complying with ACFID’s policy on Financial Wrongdoing and other relevant legislations on Counter Terrorism.

4. DEFINITIONS

Project Rozana Representatives – are all individuals and institutions who act on behalf of Project Rozana regardless of whether or not there is a formal legal agreement between them and Project Rozana. This includes, but is not limited to, all directors, employees, contractors, consultants, suppliers, advisors, volunteers, and implementing partners irrespective of which country their role is situated.

Under the “best endeavours” clause, Project Rozana has a positive obligation to act; in particular to ensure that it: a) knows the persons/organisations that it is directly assisting; b) confirms that the people/organisations it is directly assisting are not on either of the lists before funding is provided; and c) ensures that directly funded persons/organisations are aware of and comply with these laws.

Counter terrorism: the practice, techniques and strategy used to combat or prevent terrorism.

Fraud: dishonestly obtaining a benefit, or causing a loss, by deception or other means.

Listed individuals or organisations: any individual or organisation which appears on the following lists:

  • The Consolidated List of all persons and entities subject to financial sanctions under Australian sanctions laws (updated regularly on the DFAT website), and
  • Listed Terrorist Organisations under the Criminal Code (updated on
    Australian National Security website).

Money laundering: the process of concealing the origin, ownership or destination of illegally or dishonestly obtained money and hiding it within legitimate economic activities to make them appear legal.

Terrorism: acts or threats of violence intended to influence the policy of a government, either in Australia or overseas.

Terrorism financing: the financing of terrorist acts, and of terrorists and terrorists’ organisations.

Terrorist organisation: any group of terrorists that commits, or attempts to commit, terrorist act by any means, directly or indirectly, unlawfully and wilfully.

Under the “best endeavours” clause, Project Rozana has a positive obligation to act; in particular to ensure that it:
a) knows the persons/organisations that it is directly assisting;
b) confirms that the people/organisations it is directly assisting are not on either of the lists before assistance is provided; and
c) ensures that directly funded persons/organisations are aware of and comply with these laws.

5. POLICY AND POLICY PRINCIPLES

  • Australian Government legislation prohibits dealing with listed terrorist organisations and/or proscribed persons or entities. Project Rozana will at all times adopt measures intended to facilitate compliance with this legislation.
  • Project Rozana will confirm the identity, credentials and good standing of the people or organisations it supports and will check that these people or organisations are not on the lists maintained by the Australian Government.
  • Project Rozana will use its best endeavours to ensure that all activities (including those carried out by a partner or affiliate organisation delivering programs) comply with relevant Australian laws and regulations, including but not limited to:
    a) Those in relation to the proscription against providing direct or indirect support or resources to organisations and individuals associated with terrorism, including ‘terrorist organisations’ as defined in Division 102 of the Criminal Code and listed in regulations under the Criminal Code and regulations made under the UN Chart Act; and
    b) Those in relation to corrupt practices, in particular the bribery of public and foreign officials.
  •  Project Rozana will not knowingly remit any funds to known or suspected terrorist organisations or individuals.
  • Project Rozana will report any known or suspected terrorist links to the relevant national authority.
  • Project Rozana will use its best endeavours to ensure that overseas recipients of Project Rozana’s funds will adopt policies and procedures that enable them to comply with relevant Australian anti-terrorist legislation.

6. PROCEDURES

  1. Project Rozana will check and document that its Representatives do not promote or have connections with identified terrorists or terrorist organisations (those on the Consolidated List or the List of Terrorist Organisations). Partners must know the identity, credentials and good standing of their partners and recipient organisations (i.e., what they do, where they operate, who are their key decision makers and staff).
  2. Prior to signing any partnership agreement, MOU or funding, Project Rozana will check that the partner organization or their representatives do not promote or have connections with identified terrorists or terrorist organisations (i.e., the Australian Government & UN lists of terrorists and proscribed organisations).For large established public institutions, such as hospitals, prior to signing any Partnership Agreement or MOU, Project Rozanna will review the organisations Counter Terrorism Policy and assess controls in place, including checks conducted of their partners, staff and suppliers against the Australian Government and UN lists of terrorists or terrorists organisations.
  3. Project Rozana will only transmit funds using reputable banks and other financial institutions for this purpose and observing procedures defined in Project Rozana Financial Policy.
  4. Project Rozana will apply internationally accepted accounting practices, verified by regular, independent audits. Counter terrorism procedures will be included within the Risk Management section of every in-country Project Plan document. Wherever possible, Project Rozana will ask for a commitment from its partners to practice these same standards.
  5. Project Rozana will ensure that all in-country implementing partners, are aware of and understand their legal obligations in relation to counterterrorism and adopt measures to support compliance with this policy for all funds provided by Project Rozana.
  6. Project Rozana will immediately withdraw all support, including provision of resources, if it has reason to believe that a project partner has breached the requirements of this policy.
  7. All MOU, partnership or funding agreements will include wording that requires the recipient organisation to adopt policies and procedures consistent with Australian Government requirements.
  8. Project Rozana will perform regular monitoring and evaluation of project and program activities to ensure funds are being used for the purposes they were approved and provided. Funding recipients are required to provide yearly detailed accounting reports showing how funds have been spent.
  9. Where recipient organisations or individuals are found to be on the Australian Government or UN lists of terrorists and proscribed organisations, forwarding funds will cease as will all partnerships and DFAT and the Federal Police through the national security hotline (1800 123 400) will be informed immediately.
  10. Project Rozana will to the best of its ability ensure that:
    – All reports of alleged instances of detected terrorist financing, sanctions violation
    – and fraud as well as any detected terrorist activity is reported to the Board.

7. ROLES AND RESPONSIBILITIES

The Project Rozana Australia Executive Director is tasked with the responsibility of monitoring this policy and overseeing the implementation and regular updating of the policy across the Project Rozana organisation.

The Project Rozana Israel Office Country Director will be responsible for checking all prospective partners against the listed individuals and organisations and documenting this check.

Project Rozana will ensure that all employees and volunteers uphold and operate in
accordance with this policy.

8. REFERENCES / OTHER POLICIES

This policy must be read and understood in conjunction with other policies:
Project Rozana Finance Manual
Project Rozana Anti-Corruption and Anti-Fraud Policy
Project Rozana Risk Management Framework
Project Rozana Funding Acceptance Policy
Project Rozana HR Manual

DISABILITY INCLUSION POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template for use across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

The document’s content is informed by the DFAT Disability Action Strategy 2017-2020, the United Nations Convention on the Rights of Persons with Disabilities and its Optional Protocol (2006) and consultations with PR Israel staff, disability organisations and other stakeholders in Israel and Palestine.

Project Rozana believes people with disabilities must have their human rights and fundamental freedoms protected, promoted and upheld, in accordance with domestic laws in Australian and international law, including the UN Convention on the Rights of the Child and the UN Convention on Rights of Persons with Disabilities.

Moreover, as an NGO focused on people-to-people peacebuilding through health, Project Rozana projects are informed by the following facts:

  • Women and girls with disabilities are doubly disadvantaged, with their rights being ignored due to their gender and diability. This places them at greater risk of violence and exclusion.
  • Children with disabilities have a greater risk of dying from neglect, abandonment and lack of access to health care. They are frequently not valued in their communities due to stigma or misconceptions around disabilities.
  • Child mortality is significantly higher for children with disabilities than those without. Unsafe pregnancy and childbirth are major causes of disability for women.
  • Women with disabilities often lack access to reproductive health care due to both marginalisation and assumptions that they will not have families.

3. PURPOSE

The purpose of this Policy is to ensure the inclusion of people with disabilities in the delivery of Project Rozana’s work. This includes:

  • Promoting staff awareness of disability inclusion and their responsibilities with regard to this policy.
  • Ensuring the needs and rights of people with a disability are considered in the main activities of Project Rozana.
  • Consideration of the ways in which the organisation can include people with a disability in its internal operations (i.e., logistics, administration, finance, governance and other roles).

4. DEFINITIONS

Disability: In line with the Convention on the Rights of Persons with Disabilities, and taken from the Australia’s Federal Disability Discrimination Act 1992
disability, in relation to a person, means:
a) total or partial loss of the person’s bodily or mental functions; or
b) total or partial loss of a part of the body; or
c) the presence in the body of organisms causing disease or illness; or
d) the presence in the body of organisms capable of causing disease or illness; or
e) the malfunction, malformation or disfigurement of a part of the person’s body; or
f) a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction; or
g) a disorder, illness or disease that affects a person’s thought processes, perception of reality, emotions or judgment or that results in disturbed behaviour;
and includes a disability that:
h) presently exists; or
i) previously existed but no longer exists; or
j) may exist in the future (including because of a genetic predisposition to that disability); or
k) is imputed to a person.

To avoid doubt, a disability that is otherwise covered by this definition includes behaviour that is a symptom or manifestation of the disability.

Reasonable Adjustments: This refers to modifications to activities, methods of communication, infrastructure or processes to accommodate the needs of people with
disability. An adjustment is considered ‘reasonable’ if it is feasible (i.e., within the skills and resources of the organisation) and relevant to the organisation.

5. GUIDING PRINCIPLES

Project Rozana’s Disability Inclusion Policy and practices adhere to the following guiding principles:

5.1 Human Rights

Taking a human rights-based approach to disability inclusion, Project Rozana is committed to promoting equal rights for people with a disability, and their equitable inclusion in all aspects of society. This includes in its role as an employer, service provider, registered charity and incorporated organisation.

As well as ensuring equal opportunity for people with disabilities, human rights includes both respect and the absence of discrimination. Consideration for people with disabilities will be given in all Project Rozana activities and policies.

5.2 Awareness

All Project Rozana staff and representatives should have an awareness of disability inclusion, including understanding the needs of people with a disability who may interact with the organisation as primary stakeholders, employees, volunteers, partners, donors or members of the public.

5.3 Participation

Meaningful participation of people with disability is essential for genuine empowerment and change in the community. Meaningful participation ensures that people with disabilities participate and benefit from Project Rozana’s development efforts and leads to broader benefits for families and communities.

Project Rozana acknowledges that people with disabilities and their representative organisations can provide perspectives based on their experiences of living with disabilities, to inform Project Rozana disability-inclusive activities.

5.4 Comprehensive Accessibility

Central to disability inclusion is the removal of ‘barriers’ to enable people with disabilities access to services, and opportunities to participate equally. Comprehensive accessibility ensures that barriers to access and participation are identified and addressed. Barriers can be related to the physical environment (e.g., stairs), communication (e.g., lack of information in multiple formats including Braille, no sign language interpreter in training workshops), institutional barriers (e.g., organisational policies) and attitudes (e.g., negative attitudes regarding disabilities).

Negative attitudes and prejudice towards people with disabilities are often the most significant barriers. Project Rozana will work to reduce barriers faced by people with a disability, to improve access to services as well as encourage participation within all levels of Project Rozana; from Board management, implementing staff, volunteers and representatives.

5.5 Twin-track

A twin-track approach aims to ensure that Project Rozana is both inclusive of, and benefits people with disabilities. A twin-track approach involves implementing two concurrent initiatives through main-stream and targeted efforts:

  1. Disability mainstreaming: ensuring that the organisation and its programs include a disability perspective and are fully accessible to and inclusive of people with disability.
  2. Disability-specific initiatives: activities specifically targeted at people with disability, in order to increase their empowerment and participation (e.g., conducting outreach with Disabled People’s Organisations, supporting individuals to access specific medical/rehabilitation interventions where available to manage injuries/and or impairments, funding specific rehabilitation programs which can assist people with disabilities to lead a more participatory life).

Project Rozana recognises that without adequate support and access to health services, injuries sustained may become permanent impairments.

6. POLICY

Project Rozana:

  • Is committed to ensuring people with a disability have equal access to our services.
  • Acknowledges the diversity that disability brings to all areas of the organisation.
  • Recognises that the physical and social contexts of people with a disability are diverse and will consider these in the operationalisation of disability inclusion. For example, the way the policy is implemented in Australia may be different to the way it is implemented in Palestine.
  • Acknowledges that failure to uphold the human rights of people with disabilities is more likely to occur where an organisation lacks the culture, ethics, leadership, policies and professionalism to promote disability inclusion.
  • Recognises that staff and representatives are all responsible for ensuring our disability inclusion approach is understood and integrated into all areas of our work and our organisation’s ethics and culture.
  • Will work with our partners to increase understanding and knowledge of disability and the rights of people with disabilities, including advocacy to service providers to enable people with disabilities to gain access to services and facilities.
  • Recognises that that people with disabilities and disabled people’s organisations can provide perspectives on the experience of living with disabilities and ultimately are the experts on disability inclusion. Project Rozana will seek to draw on their knowledge.

7. PROCEDURES

The following mechanisms will be used to implement Project Rozana’s Disability Inclusion Policy:

a) Training and induction: All staff and representatives will be familiarised with the Disability Inclusion Policy as part of their induction process. In line with the needs of their roles and responsibilities, Project Rozana will offer staff and representatives training on Disability Inclusion.

b) Recruitment and employment: Acknowledging the diversity that people with a disability can bring to an organisation, Project Rozana will encourage and support the employment of people with a disability within the organisation. This will include:

  1. a statement on job advertisements and on the organisation’s website stating that Project Rozana is committed to fostering an inclusive work environment for all people, including those with a disability. For example, “People with a disability are encouraged to apply for all roles and positions within the organisation and, where possible, Project Rozana will make reasonable adjustments to ensure people with disabilities have an equal opportunity to participate.”
  2. adjusting recruitment processes to ensure a person with a disability is able to equally participate in the recruitment process (i.e., conducting interviews in an accessible location or enabling participation via phone).
  3. where feasible, making reasonable adjustments to the work, or work environment, to enable the participation of people with a disability (some examples could include flexible work arrangements, adjustments to work- stations and lighting, provision of assistive software, ensuring accessible office buildings, conference rooms, toilets etc).
  4. provide training and assistance on inclusive ways of working to existing staff so they can work effectively with people with disability in the workplace. Ensure existing staff are comfortable and well equipped to orient new employees and cater for any specific requirements they may have.
  5. where possible offer mentoring for new employees with disability, as a way to support self-development and contribute to development of the culture and values of Project Rozana.

c) Project management: Project Rozana will make all possible arrangements to ensure that people with a disability are able to access the services provided by Project Rozana and its partners and feel respected and supported. Examples include ensuring wherever possible that services provided through our programs have disability-inclusive services and facilities. Project Rozana recognises that accessibility is not only about physical access, but also includes these concepts:

  • Approachable: people with disabilities know services exist and feel comfortable to approach them
  • Affordable and available.

d) Data collection and reporting: We will seek to include people with disabilities in our client satisfaction survey samples, recognising that service improvement must be informed by people with disabilities who have used our service.
Project Rozana will endeavour to provide information on its primary stakeholders with disability in its internal reports. This will also assist Project Rozana to track if more people with disability are accessing our services.

e) Outreach and communication: Project Rozana will ensure inclusion of people with disability in its outreach and community awareness sessions and seek to conduct outreach sessions specifically for people with disability. They will be organised in partnership with local disability organisations in Israel and Palestine wherever possible.

8. MONITORING AND REVIEW

Monitoring of the implementation of this Policy is the responsibility of all staff, led by the Executive Director and overseen at the highest level by the Board. It will be reviewed and updated as required.

FEEDBACK AND COMPLAINTS POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. PURPOSE

Project Rozana values feedback and complaints and recognises these are an essential part of our quality assurance and accountability to staff, partners, stakeholders and donors.

This policy sets out Project Rozana’s approach to feedback and complaints from staff, partners, external stakeholders and the community.

The complaint handling process will be integrated into all of Project Rozana’s programs and will be included in the Policies and Procedures Handbook to be used by staff, volunteers and partners with the understanding that it will be implemented by all Project Rozana offices worldwide, and all Project Rozana partners wherever possible.

Project Rozana is committed to ensuring that the complaints handling process is safe, confidential, prompt and fair.

3. SCOPE

The complaint handling process will be integrated into all of Project Rozana’s programs and will be included in the Policies and Procedures Handbook to be used by staff, volunteers and partners with the understanding that it will be implemented by all Project Rozana offices worldwide, and all Project Rozana partners wherever possible.

Where this policy is contradicted by contractual obligations to funders, the contractual obligations must be adhered to. Exceptions to such obligations should be sought from funders prior to entering into contracts and any substantive areas of difference must be drawn to the attention of the Chief Executive Officer.

This policy does not relate to concerns that arise within the workplace between staff and/or volunteers. For these issues, staff and volunteers should refer to Project Rozana’s EEO, Discrimination, Bullying and Harassment Policy, Grievance Policy or Performance Counselling and Disciplinary Policy.

4. DEFINITIONS

For the purposes of this policy:

Feedback: is positive or negative comment about an employee or volunteer, activities of the organisation or the organisation itself.

A complaint: is an expression of dissatisfaction about the standards of service or lack of action by Project Rozana or its staff, volunteers, partners or anybody directly involved in the delivery of our work.

5. BENEFITS OF FEEDBACK

Feedback, including complaints, provides Project Rozana with the opportunity to:

  • Understand the needs and expectations of participants, stakeholders and communities with which Project Rozana works and supports
  • Identify improvements to what Project Rozana does and how it is done
  • Record, register, respond to and resolve issues and share these to improve practices
  • Analyse and learn from trends to ensure Project Rozana is proactive and effective in its work.

Project Rozana’s complaints and feedback processes have been designed in accordance with nine core principles of the Australian Standard Customer Satisfaction Guidelines for Complaints Handling in Organisations.

1. Principle:
Visibility
Action: All staff and volunteers know how to find this policy and how to follow procedures. Project Rozana publishes this policy on its website.

2. Principle:
Accessibility
Action:
The feedback process is straightforward. A person’s age, language, culture or disability will not be a barrier to providing feedback.

3. Principle:
Responsiveness
Action:
Timely acknowledgement, progress and action is provided.

4. Principle:
Objectivity
Action:
Investigations are conducted impartially, fairly, equitably, ethically and completely.

5. Principle:
Charges
Action:
Provision of feedback is free of any charge or cost.

6. Principle:
Confidentiality
Action:
Personal information is only disclosed on a need-to-know basis and is handled in accordance with Project Rozana’s Privacy Policy.

7. Principle:
Person-focused
Action:
Project Rozana welcomes and promotes the right to provide feedback and recognises feedback as important to what Project Rozana does and how it is done.

8. Principle:
Accountability
Action:
Roles, processes, and decisions are clear, balanced, ethical and fair.

9. Principle:
Continuous improvement
Action:
Project Rozana seeks to learn, explore new solutions and improve performance.

 

6. PROCEDURES

  1. Feedback, including complaints, may be provided to Project Rozana in a variety of forms including through formal correspondence, verbally or via email.
  2. Written complaints may be sent to Project Rozana’s Executive Director, PO Box 2400, Caulfield Junction, Vic 3161 Australia. Should the complaint relate to the Executive Director, the complaint may be addressed to the Project Rozana Chair at the same address. Alternatively, complainants may write to complaints@projectrozana.org.
  3. Project Rozana staff or volunteers who receive a complaint should refer the complaint immediately to Project Rozana’s Executive Director who will register the complaint and acknowledging its receipt in writing within three working days.
  4. In the case of verbal complaints, the person receiving the complaint should make a record of the complaint and provide that record to the Executive Director.
  5. If the complainant is seeking a response to their complaint, the record must include contact details of the complainant to allow a response to be provided.
  6. The Executive Director will work with a senior staff member associated with the matter to which the complaint relates in order to consider the complaint.
  7. The Executive Director will escalate the complaint to Project Rozana’s Chair, who may in turn refer it to the Board, if appropriate.
  8. In acknowledging receipt of the complaint, the Executive Director will advise of the course of action to be taken in investigating the complaint. If advising of this course of action is not possible within three working days, an acknowledgement of the complaint will still be provided, with further advice on the course of action to be taken provided within a reasonable period.
  9. Any staff member or volunteer who is found to have breached this policy may be subject to disciplinary action, up to and including termination of employment or volunteer engagement.
FRAUD AND CORRUPTION PREVENTION

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. PURPOSE

Project Rozana has a zero tolerance approach towards fraudulent and corrupt activity or behaviour. It is committed to conducting all aspects of organisational and program management in a transparent and accountable manner to support good governance. The purpose of this Policy is to articulate Project Rozana’s position against fraud, bribery and corruption to Board members, staff, volunteers, project partners and consultants. As an agency supported under the Australian NGO Cooperation Program (ANCP), this Policy is consistent with the Fraud Policy Statement of the Department of Foreign Affairs and Trade (DFAT), the Australian Corporations Act 2001 (for whistleblowers), and the Australian Government Investigation Standards (2003 and 2011).

Project Rozana acknowledges that the developing country in which it works is an inherently difficult environment with, often, weak governance arrangements and attitudes towards accountability and transparency different to those in Australia. The paying of bribes encourages corruption, which, like fraudulent acts, is something that can further harm those already disadvantaged by diverting goods, services and opportunities away from them. It also is considered a high risk that such actions will prevent the objectives of Project Rozana’s programs being achieved.

3. DEFINITIONS

Fraud: ‘Dishonestly obtaining a benefit, or causing a loss, by deception or other means’ (Commonwealth Fraud Control Guidelines 2011 and DFAT Fraud Factsheet, October 2015). This definition extends beyond the legal definition of fraud to include benefits obtained that can be both tangible and intangible. It thus encompasses activities or behaviours broader than the misuse or misappropriation of monies or assets.

Examples of fraud include:

  • Misappropriation of funds
  • Altering documents
  • Falsifying signatures
  • Misuse of Project Rozana assets
  • Providing false information to Project Rozana
  • Unauthorised disclosure of confidential information
  • Theft of funds or assets
  • Bias, cronyism or nepotism

Bribery: The offering, promising, giving, accepting or soliciting of money, gifts or other advantage as an inducement to do something that is illegal, where a payment is not legitimately due, where it is offered with the intention of influencing a person in the exercise of their duties, or where it is a breach of trust in the course of carrying out an organisation’s activities.

4. POLICY AND POLICY PRINCIPLES

Project Rozana does not tolerate fraud or corruption by staff or related third parties, including any of Project Rozana’s Representatives.  Project Rozana staff are required to be watchful for fraud, corruption or any suspicious behaviour, and report it to the Executive Director. All reported incidents will be appropriately investigated.

4.1 Fraud and corruption Intolerance and Reporting Obligations:

Any incidence of fraud or corruption or suspicious behaviour must be reported to the Executive Director or/and reported through official Whisleblower channels as per the Project Rozana’s Whistleblower policy.

4.2 Internal escalation process:

All Executive Director’s will have in place an internal escalation process to ensure appropriate management awareness and expeditious handling, In consideration of local context and donor requirements, if any, Project Rozana requires to the maximum extent possible, the reporting of fraudulent and corrupt behaviour to the proper authorities in any given country. Any exception must be justified in writing by the respective Executive Director to the Board.

4.3 Sufficiency of Investigations.

Fraud and corruption and allegations of fraud and corruption will be appropriately investigated after considering severity, credibility, potential for reputational damage, and applicable donor requirements. Investigations will generally be led by the Executive Director and external resources as necessary, including, but not limited to, legal counsel, external audit firms, etc. In the case of the Executive Director being under investigation for fraud and corruption, the Board Chair of the country office in question will lead the investigation.

4.4 Confidentiality of Reports and Investigations; Non-retaliation.

Any report of alleged or actual fraud and corruption submitted pursuant to this policy must be treated confidentially to the fullest extent practicable. Reports of fraud and corruption or suspected fraud and corruption may be submitted anonymously. Staff will not be retaliated against for good faith reports. Only personnel with a need to know should be advised of a report and any related investigation.

5. PROCEDURES

5.1 Prevention and Awareness:

All Project Rozana Board members, staff, volunteers, project partners and consultants have responsibilities and obligations to be aware of these rules and to follow Project Rozana’s procedures in all cases. The Executive Director is charged with disseminating this Policy and related procedures to Board members, staff, volunteers, project partners and consultants and for monitoring its implementation in activities for which Project Rozana is the responsible party. Written agreements with external parties should to the maximum extent possible include a written reference to Project Rozana’s intolerance of fraud and how it should be managed, as per the Project Rozana Partnership Policy.

5.2 Implementation and Monitoring

Project Rozana’s agreements with in-country program partners must clearly set out the requirements to protect funds from fraud and to not engage in anything that could be construed as bribery or corruption. Project Rozana’s Executive Director and Program Manager will regularly monitor activities and expenditure to guard against fraud and corruption.

The conduct of fraud, bribery and corruption risk assessment and the implementation of anti-bribery procedures forms part of Project Rozana’s ongoing risk management and internal control processes.

5.3 Reporting 

Project Rozana is bound by the requirements regarding the reporting and action of suspected breaches of this policy as defined by DFAT in its policy. As an Australian aid program implementation partner, Project Rozana is responsible for preventing and detecting fraud, bribery or corruption in any of its activities, both in Australia and overseas. Any breaches of this Policy must be investigated swiftly and at Project Rozana’s expense.

5.3.1 Donor Reporting

The Executive Director of the country office from which the donation was made is responsible for any donor reporting of fraud and corruption and overall assessment of donor implications, but may delegate donor engagement to the Director of Development or the Relationship Manager for the donor in question. Project Rozana will cooperate with any requests from a donor relating to an ongoing investigation, as applicable.

5.4 Implications for person reporting alleged fraud and corruption

Any person reporting a fraud or corrupt behaviour, or a suspected fraud or corrupt behaviour, shall not be penalised for raising a concern of this nature.

If fraud is detected or suspected, Project Rozana Board members, staff, volunteers, project partners and consultants are responsible for timely reporting to the Project Rozana Board Chair and/or Executive Director. Project Rozana’s preference is to receive reporting on fraud in writing or by email. If the complaint is made orally Project Rozana commits to recording the complaint in writing. All cases of fraud and corruption are handled in a confidential, prompt and professional manner.

5.5 Investigation and Follow up

Upon awareness of an alleged or suspected fraud and corruption, the Executive Director or their designate will inform immediately (within three business days) the Board Chair using a completed Initial Investigation of Suspected Fraudulent and
Corrupt Act Report found at Appendix A. Where deemed appropriate, the National Board Chair will also immediately notify (within three days) the International Board Chair and they shall be an integral part of determining next steps. The report will include a determination of the amount of the suspected fraud, and whether the suspected fraud requires donor reporting.

Where fraud or corruption is alleged, suspected or detected, Project Rozana will:

  • Promptly investigate the matter;
  • Report detected or attempted fraud or corruption within Project Rozana activities to DFAT within five (5) working days and keep DFAT informed of action;
  • Seek the recovery of misappropriated funds or assets and the application of appropriate penalties wherever possible;
  • Seek prosecution of offenders wherever possible and appropriate.

APPENDIX A:

Initial Investigation of Suspected Fraudulent Report

GENDER EQUALITY AND DIVERSITY POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

This policy outlines the value that Project Rozana places on the diversity of its stakeholders, employees, and partners to its operation. It also defines Project Rozana’s commitments to achieve a gender just society in which men and women enjoy equity while contributing and benefiting as equal partners.

Project Rozana recognises and affirms the equal worth, dignity, and rights of women, men, girls, and boys and the significant role each one plays in promoting sustainable, transformational development.

Project Rozana believes that sustainable progress can only take place, and person to person peace building can only be achieved, through transformation that increases opportunities, resources, and choices, so that power is distributed equally among females and males. This in turn will permit all people to have the resources to shape their own lives and contribute to their families and communities.

Project Rozana promotes gender equality as essential for the sustained well-being of women within their families and communities This policy also further outlines the commitments of Project Rozana to diversity in its operations, and respect for the differences between people in knowledge, skills, and perspectives.

Particularly in relation to gender-based violence, Project Rozana recognises that power inequalities exist between individuals and groups, on the basis of social or professional identity including gender, sexual orientation, disability, religious affiliation, age and ethnicity. Social inclusion and empowerment are important components of Project Rozana’s operations, and it works to end all forms of gender-based violence and all practices that undermine the dignity of girls, boys, women and men and their right to protection form physical, sexual and psychological harm.

Project Rozana is committed to upholding the international agreements on human rights and their implementation strategies. These include the United Nations Charter and the Universal Declaration of Human Rights,  the Convention on the Rights of Persons with Disabilities (CPRD), the Convention on the Elimination of all forms of Discrimination Against Women (CEDAW), the Convention on the Rights of the Child (CRC), the Declaration on the Elimination of Violence Against Women. Particularly within the context of its work, Project Rozana is committed to, and puts at the core of its programs the United Nations Security Council Resolution 1325 which reaffirms the important role of women in the prevention and resolution of conflicts, peace negotiations, peace-building, peacekeeping, humanitarian response and in post-conflict reconstruction and stresses the importance of their equal participation and full involvement in all efforts for the maintenance and promotion of peace and security, as well as and 1820 and the Agenda 21.

Project Rozana works across three domains to support gender equality outcomes:

  1. Addressing specific gender issues, such as gender-based violence and the rights of women to have access to quality sexual and reproductive health care.
  2. Prioritising female and childhood healthcare access by supporting gender specific programming through program models including the West Bank Mobile Women’s Health Care program.
  3. Supporting Project Rozana’s partner organisations to make their organisations and programs more gender responsive.

3. PURPOSE

The purpose of this policy is as follows:

  • Create a clear and consistent message on Project Rozana’s commitment to gender equality, diversity and an inclusive culture, and to facilitate working relationships with government agencies, NGOs, and its stakeholders.
  • Facilitate common accountability mechanisms and minimum standards for organisation wide objectives for gender equality, women’s empowerment and social inclusion.
  • Outline the commitment of Project Rozana to inclusivity in its operations for its staff, partners, and stakeholders.

4. SCOPE

This policy applies to all staff, volunteers, contractors and representatives of Project Rozana and includes field partners who have agreed to acknowledge, adopt or comply with Project Rozana’s Gender Equality and Diversity Policy. For the sake of brevity, the term “staff” will be used to represent the scope of this policy.

5. DEFINITIONS

Definitions, as used in this policy, are as follows:

Discrimination: When a person is treated less favourably because of their race, family
background colour, religion, sex, age, marital status, nationality, sexual orientation, because they have a disability or are HIV positive, or some other point of difference unrelated to work requirements.

It is also discrimination when an unreasonable rule or policy applies to everyone but has the effect of disadvantaging some people because of a personal characteristic they share. This is known as ‘indirect discrimination’ (Australian Human Rights Commission).

Disability: In line with the Convention on the Rights of Persons with Disabilities, and taken from Australia’s Federal Disability Discrimination Act 1992.

Disability, in relation to a person, means:

a) total or partial loss of the person’s bodily or mental functions; or

b) total or partial loss of a part of the body; or

c) the presence in the body of organisms causing disease or illness; or

d) the presence in the body of organisms capable of causing disease or illness; or

e) the malfunction, malformation or disfigurement of a part of the person’s body; or

f) a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction; or

g) a disorder, illness or disease that affects a person’s thought processes, perception of reality, emotions or judgment or that results in disturbed behaviour;

and includes a disability that:

h) presently exists; or

i) previously existed but no longer exists; or

j) may exist in the future (including because of a genetic predisposition to that disability); or

k) is imputed to a person.

To avoid doubt, a disability that is otherwise covered by this definition includes behaviour that is a symptom or manifestation of the disability.

Disaggregated Data: The collection of data information and analysis of results on the
basis of gender, age and/or disability.

Empowerment: The process of change that gives individuals greater freedom of choice
and action which leads to an enhanced ability to make informed life choices.

Gender Analysis: The systematic assessment of policy and practice on women and
men and on the social and economic relationships between the two. The application of a gender perspective requires: the identification of the needs and priorities of women and men, the identification of existing opportunities and constraints to the achievement of development objectives, and the choice of an intervention strategy to address these.

Gender Equality: Is the equal treatment of all genders. It means all genders will enjoy the same rights, opportunities, responsibilities and protections. (Australian Commission

Gender Equity: A just distribution of benefits and rewards between men and women.

Gender: In accordance with the Australian Government Guidelines on the Recognition of Sex and Gender: “Gender is part of a person’s social and personal identity. It refers to each person’s deeply felt internal and individual identity and the way a person presents and is recognised within the community. A person’s gender refers to outward social markers, including their name, outward appearance, mannerisms and dress. A person’s sex and gender may not necessarily be the same. An individual’s gender may or may not correspond with their sex assigned at birth, and some people may identify as neither exclusively male nor female.” For the purpose of this policy, gender may also be defined as the economic, social, political and cultural attributes and opportunities associated with identifying as male, female or non-binary.

Harassment: Any verbal, physical or visual behaviour that is intimidating, humiliating or offensive to another person. This may include through the internet and social media.

Women’s Economic Empowerment: Refers to the process which increases women’s
real power over economic decisions that influence their lives and priorities in society.
This can be achieved through equal access to and control over critical economic
resources and opportunities.

6. REFERENCES/OTHER POLICIES

This policy must be read and understood in conjunction with the following policies:

  • Human Resources Manual – for additional information on the staff Code of Conduct, equal opportunity recruitment, and misconduct procedures for discrimination and harassment.
  • Disability Inclusion Policy – for information about practices relating specifically to people living with a disability.
  • Prevention of Sexual Exploitation, Abuse and Harassment (SEAH) Policy – for
    information on Project Rozana’s approach to the prevention of SEAH and response to allegations of SEAH be included within the Risk Management section of every in-country Project Plan document.

7. PRINCIPLES

Project Rozana has a whole-of-organisation commitment to the achievement of gender equality and social inclusion which requires that we adhere to the following principles:

a) We respect, protect and promote internationally recognised human rights for all,
regardless of race, religion, ethnicity, indigeneity, disability, age, displacement,
caste, gender, gender identity, sexuality, sexual orientation, poverty, class or socio-economic status.

b) The empowerment of women and girls is fundamental to our mission, vision,
values and priorities.

  • Gender equality and equity are central to all of our actions.
  • Gender-based violence scars women and girls physically and psychologically, severely affecting women’s dignity and personal security and suppresses their potential to take control of their lives.
  • We work to promote gender equality and to prevent sexual exploitation and abuse of those who are vulnerable, noting that gender-based violence and sexual exploitation and abuse disproportionately affects women and girls.

An inclusive culture which celebrates diversity and allows people to thrive is
everyone’s responsibility.

  • The diversity of our employees, partners, and stakeholders are valued at all levels of our operation.
  • We recognise that organisational cultures are a direct result of the actions of staff, management, stakeholders, and contributors.
  • We encourage equality and diversity through programs that seek the inclusion, representation, participation and empowerment of all people. We ensure that key participants representing affected people are involved in the design, implementation, monitoring and evaluation of our programs.

8. GENDER EQUALITY AND DIVERSITY IN OPERATION

Through this Gender Equality and Diversity Policy, Project Rozana commits to promote equal realisation of dignity and human rights for all. Specifically, this policy is intended to
incorporate our diversity and gender equality principles in our operations.

8.1 Management and program design

Project Rozana mainstreams gender equality and diversity in our day-to-day business, through management and design of activities:

  • There is strong representation of women in management – on our Board and in Executive Management
  • We ensure adequate resources are allocated to advancing our work in social inclusion and gender equity.
  • Our annual work plans and budgets are formulated to assist in our aim of gender equality and social inclusion.
  • All new programs or projects have a gender equality and diversity analysis at the
    planning and proposal stages.
  • There is consistency between Project Rozana’s Gender Equality and Diversity Policy and other Project Rozana policies and procedures.
  • Project Rozana ensures that key organisational policies, systems and practices including but not limited to budgeting, human resource recruitment, training and management, and decision making supports the aims outlined in this policy.

8.2 Human Resources

Project Rozana is an equal opportunity employer and the principles of gender equality and diversity feature strongly in our HR operations:

  • Staff understand and demonstrate attitudes and behaviours that promote diversity and gender equality.
  • Project Rozana sets clear expectations about an inclusive working environment for all people to engage with.
  • We undertake merit-based recruitment and, where appropriate, applications are open to people of all genders and backgrounds.
  • Project Rozana addresses any discrimination, harassment, or any other unacceptable behaviour.

8.3 Advocacy, Outreach, Training and Research

Project Rozana engages in advocacy, training, outreach and research, and promotes gender equality and diversity.

  • We advocate with partners and stakeholders to address systemic and structural practices that create barriers to women’s rights and gender equality, including prevention and response to gender-based violence and sexual exploitation and abuse.
  • Project Rozana actively involves men and boys as allies in promoting gender equality and preventing gender based violence through outreach and training.
  • We conduct awareness-raising sessions and training around the consequences of gender-based violence and sexual and reproductive health to contribute to the safety and empowerment of women and girls.

8.4 Monitoring, Evaluation and Learning

Project Rozana is committed to monitoring, evaluating and learning from its projects and includes gender equality and diversity in these processes.

  • We explicitly state gender equality and diversity results and include indicators in
    planning, implementation, monitoring and evaluation.
  • Project Rozana collects and analyses data disaggregated by sex, age and disability to inform reflections, lessons learnt and changes in programming.
  • Project Rozana Executive and Development staff report regularly to beneficiaries, donors and the public on progress on gender equality in Project Rozana’s work through appropriate reporting channels.

8.5. Partners

Where possible, Project Rozana shall encourage partners to acknowledge and comply with our Gender Equality and Diversity Policy through the use of MoUs and agreements. Project Rozana will provide guidance to partners on our gender equality and diversity principles.

Project Rozana understands that, in many cases, this policy cannot bind other stakeholder organisations it works with. However, Project Rozana will promote and model good practice in gender equality and diversity to partners and other stakeholders.

GIFT ACCEPTANCE POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

Project Rozana is a non‐profit, charitable organisation registered under Australian law. Project Rozana welcomes donations and grants to fulfil its mission to build bridges to better understanding between Israelis and Palestinians using the platform of health.

3. PURPOSE

This policy provides a guide to making clear and consistent decisions regarding the acceptance or refusal of a donation. In doing so, it to enable Project Rozana to live up to its commitment to transparency and accountability while reducing reputational risks that may compromise the important work of the organisation.

The Gift Acceptance Policy complies with the Fundraising Institute of Australia’s (FIA) code of conduct and has been heavily informed by that policy to ensure the highest standards of ethical and transparent fundraising practices.

4. SCOPE

This policy applies to the following people:

  • Project Rozana staff members, particularly those engaged in grant writing and fundraising;
  • Project Rozana donors and prospective donors;
  • Project Rozana Board of Directors; and
  • Partner organisations

5. DEFINITIONS

Donor: an individual or other entity that makes a contribution of value to an Organisation to further the Organisation’s Objects. A Donor includes prospective Donors and an individual or entity that has previously made a Donation. A Donor does not include an individual or entity that engages with an Organisation for the purpose of trade.

Gift: In accordance with Australian Tax Office (ATO) guidelines, Project Rozana defines a gift as:

  • A voluntary transfer of money or property where the donor receives no material benefit or advantage; and
  • A gift of money or property, which includes financial assets such as shares.

For the purposes of this policy, Project Rozana will also consider a gift-in-kind of services or pro-bono support to be a gift.

6. PRINCIPLES

Project Rozana solicits and accepts gifts that are consistent with its mission and that support its core programs, as well as special projects.

Donations and other forms of support will generally be accepted from individuals, partnerships, corporations, foundations, government agencies, or other entities, subject to the following limitations:

  • Project Rozana will not accept any gifts from an organisation operating in any of the following industries: the tobacco industry, the pornography industry, the gambling industry;
  •  Project Rozana will not accept a gift when there is a reasonable belief that the donor is in vulnerable circumstances or lacks capacity to make a decision to donate;
  • Project Rozana will not accept a gift when to do so would compromise the interests or objectives of Project Rozana;
  • Project Rozana will not accept a gift where the activities of the donor are incompatible with the objectives of Project Rozana;
  • Project Rozana will not accept a gift where the cost of accepting the gift would be greater than the value of the gift itself;
  •  Project Rozana will not accept a gift where there is reason to believe that accepting the gift will damage the reputation and brand of our organisation;
  • Project Rozana will not accept a gift where there is reason to believe that accepting the gift may result in litigation.

7. PROCEDURES

7.1 Unacceptable Gifts

All donors will be treated with courtesy and respect regardless of whether or not their gift can be accepted.

If Project Rozana determines that it is unable to accept a gift from an individual or organisation, it will notify them immediately. Should the gift have already been received by Project Rozana, it will be returned to the donor promptly. Project Rozana will bear the cost of returning the donation and will clearly articulate the reason for not accepting the gift.

If a donor is not satisfied with the reason for the non-acceptance, they may follow standard complaints procedures as outlined in Project Rozana’s Feedback and Complaints Policy

Project Rozana will keep a register of any declined gifts. The register will include the date, gift amount, name of donor and the reason the gift was declined.

7.2 Transparency and Reporting

Project Rozana commits to:

  • Accounting for all gifts  in a manner that allows donors and the public to develop a clear and accurate picture of Project Rozana’s financial activities.
  • Respecting donors’ wishes for anonymity and consulting with donors to obtain their permission before public disclosure of their giving.
  • Operating ethically and conducting itself in accordance with the FAI’s Code of Conduct.

7.3 Naming Opportunities

Authority to accept or decline any proposal to apply a donor’s name to any Project Rozana program (on a temporary or permanent basis) rests with the Executive Director, in consultation with the Development Directors and approval by the Board.

8. ROLES AND RESPONSIBILITIES

The Executive Director is responsible for ensuring that:

  • The organisation adheres to the Gift Acceptance Policy;
  • Guidance is sought from the Board for gifts that fall outside of this policy.

8.1 Delegation of Authority

With the exception of naming rights, the Executive Director may delegate authority to the Development Director(s) to evaluate, negotiate and decline gifts, and create and execute gift agreements with prospective donors in keeping with this policy.

9. REFERENCES / OTHER POLICIES

This policy must be read and understood in conjunction with:

  • Counter Terrorism and Fraud Prevention Policy
NON-DEVELOPMENT ACTIVITY POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

Project Rozana is committed to ensuring that we accurately represent our activities to the people we work with, our donors, and the public.

Project Rozana is a humanitarian aid and development organisation whose work involves building understanding between Palestinians and Israelis through health, while building capacity in Palestinian healthcare.

Project Rozana is a secular organisation and does not engage in or support any evangelical activities, nor is it linked to any political party or partner with any local faith-based organisations. It does not support or engage in any non-development activities as defined in the ACFID Code of Conduct handbook.

3. PURPOSE

The purpose of this policy is to guide Project Rozana and our partners to make a clear separation between aid and development; and non-aid and development objectives and activities. This policy addresses our ACFID compliance obligations when communicating with or soliciting donations from private donors and the public, including fundraising for restricted and unrestricted purposes from aid agencies, sponsors and supporters, as well as fundraising from the general public.

4. SCOPE

This policy is intended to apply to all Project Rozana activities. The policy is applicable to all Project Rozana employees, board members and volunteers. The policy also extends to Project Rozana partners and associated implementing organisations.

5. DEFINITION OF PEACEBUILDING AND DEVELOPMENT ACTIVITIES

Project Rozana is committed to ensuring that funds and other resources designated for the purpose of person to person (P2P) peace building and development are used only for those purposes.

Person to Person (P2P) Peacebuilding: According to USAID, Person to person peacebuilding involves reconciliation programs and activities that bring together individuals of different ethnic, religious or political backgrounds from areas of civil conflict and war. These programs provide opportunities for adversaries to address issues, reconcile differences, promote greater understanding and mutual trust and work on common goals with regard to potential, ongoing, or recent conflict.

Development and humanitarian initiatives: Activities undertaken in order to reduce poverty and address global justice issues. In the non-government organisation sector, this may occur through a range of engagements that includes community projects, humanitarian response and emergency management, community education, advocacy, volunteer sending, provision of technical and professional services and resources, environmental protection and restoration, and promotion and protection of human rights.

6. DEFINITION OF NON-DEVELOPMENT ACTIVITIES

Non-development activity: Includes activity undertaken to promote a particular religious adherence or to support a particular party, candidate or organisation affiliated to a political party.

This does not include advocacy which is aimed at persuading and influencing decision-makers and opinion leaders and is not aimed at promoting partisan political objectives.

Project Rozana is a secular organisation and does not provide support for evangelical activities or partisan political activities.

7. PRINCIPLES

Project Rozana supports and is committed to abiding by the following principles:

  • To ensure accurate representation of our activities to the people we work with, donors and the public; and
  • To ensure that funds raised for peacebuilding and development purposes are not used to exploit people and communities who are vulnerable and do not place any conditions or obligations on recipients in terms of non-development, religious or political outcomes that would affect their access to services being offered.

8. COMPLIANCE

This policy provides a framework for Project Rozana’s compliance with principle B.1.5 of the ACFID Code of Conduct. This principle outlines four obligations for signatories to the ACFID Code of Conduct:

1. Project Rozana will have a clear separation between aid and development and non-aid and development objectives, and activities based on the definitions of aid and development and non-aid and development in section F (Definitions) of the Code.

2. This separation will be clear in all fundraising, programs and other activities, in public communications and in all reporting including annual reports.

3. Any fundraising solicitations that include references to both aid and development and non- development activities will provide donors with the choice of contributing to aid and development activity only.

4. Project Rozana will ensure that any such separation in fundraising, programs and other activities, in public communications and in reporting, extends to partner and implementing organisations and is documented.

5. Where there are components of partner programs which involve evangelical or partisan political activities, these will be promoted and accounted for separately.

6. In-country project monitoring will include monitoring of the separation of non-development activities from development and humanitarian activities as part of project monitoring, learning and evaluation processes.

7. Communication with new partners will state Project Rozana’s position on support for non-development activity. Partners will receive a copy of this policy and the partner agreement memorandum of understanding (MoU) or equivalent will include clear definitions of development and humanitarian activity and non-development activity. The partner agreement (MoU or equivalent) will require the partner to agree that the funds designated for development and humanitarian purposes will not be used to fund any non-development activity.

9. RESPONSIBILITIES & ACCOUNTABILITIES

The Executive Director is responsible for ensuring this Policy is upheld and will inform the Board of any concerns relating to conflicts that may present risk to Project Rozana, its Representatives, beneficiaries, partners, reputation, operations or other activities.

PRIVACY POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

This Policy covers Project Rozana Australia. This policy applies to all board members, employees, volunteers, supporters and partners in Australia.

Project Rozana is committed to using your information responsibly. We want to ensure that we’re as transparent as possible in informing all our supporters about how we capture data, store it, and most importantly, use it.

We are bound by the Australian Privacy Act 1988 (Cth) (the “Privacy Act”), the Payment Card Industry Data Security Standard and the Australian Council for International Development (ACFID) Code of Conduct.

3. PURPOSE

The purpose of this policy is as follows:
a) To protect the confidentiality of all people who support Project Rozana and to inform them about the limits that apply to our confidentiality;

b) To provide guidance to staff, visitors, volunteers, supporters, partners and donors about what they can expect from Project Rozana in handling their personal information;

c) To provide avenues by which supporters and donors can control the information we hold on them and exercise their right to privacy.

4. DEFINITIONS

Personal information – Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
a. whether the information is true or not; and
b. whether the information or opinion is recorded in a material form or not.

Confidentiality – The principle whereby personal information is kept secret and not disclosed to other parties without consent.

Privacy – The right to control access to oneself, and information about oneself.

5. REFERENCES / OTHER POLICIES

This policy must be read and understood in conjunction with the following other Project Rozana policies:

Child Protection Policy and Code of Conduct – for confidentiality relating to children.

Project Rozana HR manual – for confidentiality relating to employment matters and staff.

The following principles also guide Project Rozana’s collection and use of your information:

The Australian Privacy Principles

6. COLLECTION OF PERSONAL INFORMATION

6.1 What personal information do we collect and why?

We collect personal information to assist in engaging with you. In this way we can interact with you and respond to any questions you might have. It also allows us to keep you up-to-date on developments in our programs.

At the first point of contact we will ask you to provide contact Information (First, Last name, Address, Contact number, Email Address)

If you choose to make a donation, we will ask for your Credit Card Details (number, name, expiry and CVC code), direct debit card, or bank details. But we do NOT store these, see 6.2 below.

We ask these questions to ensure we have accurate and up-to-date personal information. We collect this information in order to:

a) Process your donations and issue tax deductible receipts;

b) Correctly locate your account in our database and maintain accurate details;

c) Improve and personalise our communications to you (including direct and digital marketing);

d) Seek your continued support via mail, text or email;

e) Keep you informed of our work, through newsletters and annual reports or update you on programs you have supported;

f) Invite you to events or webinars;

g) Release surveys to improve our services;

h) Analyse donor activity in order to improve quality assurance; and

i) Respond to your questions, comments, or feedback.

If your personal information is used for a reason other than stated above, we will contact you for your permission.

We may also collect and hold sensitive information of our staff, Board members and volunteers or prospective staff and volunteers, including completed police checks.

6.2 Payment Card Industry Data Security Standard

This standard sets out how we might process card information and handle PCI compliance.

When donors make an online donation via our website it is important to note that this donation is processed by Stripe, our secure card payment gateway system. Project Rozana Australia and its site, does not store or have access to this credit card data. It is held by Stripe in strict compliance with the Payment Card Industry Data Security Standards (PCI DSS) which regulates the processing, transmitting or storage of credit card data. Stripe has been audited by an independent PCI Qualified Security Assessor (QSA) and is certified as a PCI Level 1 Service Provider. This is the most stringent level of certification available in the payments industry.

7. HOW WE MANAGE YOUR PERSONAL INFORMATION

The protection of your privacy and personal information is of the utmost importance to Project Rozana. We will take every step to ensure it remains confidential and protected. Your personal information is stored securely, and all payments are processed using a secure PCI compliant payment gateway(please see 6.2.

We have secured our in‐house IT system with a firewall and anti‐virus scanners. We also ensure that all personal information is removed from computers before disposal or sale. Hard copy files are kept in secure cabinets and staff are trained in our privacy procedures. Donations are processed only by authorised staff. Only authorised staff have access to your information and only when it is required.

8. WEBSITE AND SOCIAL MEDIA

In order to understand how people arrive at the Project Rozana website and related social media platforms and how they use it, we rely on cookies provided by third parties. This enables us to assess the effectiveness of our online advertisements. We may also use your browsing history on the Project Rozana website to send related messages on our work and appeals.

Cookies do not reveal personal information. You can adjust your browser to disable cookies, but this may restrict your ability to access certain areas of our website. You can also engage with us through social media, including Facebook and Instagram. You can control how you receive content through the setting on each social media site.

8.1 Opting Out

If you wish to opt out of communications from Project Rozana, use any of the clear links that we provide in all our digital communication (like SMS or mail shots) or email info@projectrozana.org.

9. DISCLOSING YOUR INFORMATION

We will only use and disclose your personal information in accordance with the Privacy Act and the Australian Privacy Principles. This may include:

a) To our contractors who perform tasks directly on our behalf (for example mail houses). We require them to sign strict privacy and security agreements and they are also bound by the Australian Privacy Principles. These agreements make sure these contractors keep your private details confidential and do not use it for any purpose other than the work we have contracted them to perform (for example, printing and mailing an appeal letter to you).

b) To reputable cloud-based organisations with robust security protocols in order to store your data securely. The secure storage facilities/data centres are often located overseas. To that extent:

c) Where use or disclosure is required by law.

d) Where we have your consent to the use or disclosure, or for the purpose for which it was collected.

e) In order to establish, exercise or defend our legal rights (including providing information to others only to the extent required for the provision of fraud prevention, managing cases of suspected or substantiated fraud and as otherwise required).

f) To any person who we reasonably believe may apply to a court or other authority for disclosure of that personal information, where, in our reasonable opinion, such court or authority would reasonably be likely to order disclosure of that personal information.

We do not pass on your information to any third parties other than those stated in this policy or publish them in our website or in any publication without explicit supporter submission. We do not buy or sell personal information from or to third parties.

10. SHARING INFORMATION PUBLICLY

Project Rozana may be required to report on its activities to implementing partners, government and funding agencies. Such reporting will be in aggregate form, ensuring that no identifiable/potentially identifiable information pertaining to the recipients of our programs is used in such reporting without their prior consent. Where case studies are used in reporting and promotion, the client will be de-identified unless we have their full consent to do otherwise.

No identifiable beneficiary information will be used in any way that is not directly related to the provision of services to that particular person or their family members.

10.1 Staff Obligations in Relation to Confidentiality

Staff will not use any confidential information which they have acquired in relation to the activities of Project Rozana for their own interests or the interests or purposes of others not associated with Project Rozana. Staff will not make copies of any confidential information for any reason other than those essential to and directly related to their position and responsibilities with Project Rozana.

Staff, upon request, and in any event upon ending their engagement or employment with Project Rozana will return materials containing confidential information which are in their possession and will not use any information after leaving Project Rozana.

Any breaches of confidentiality or privacy must be reported to the Executive Director of Project Rozana Australia and appropriate action taken.

For further information on privacy and confidentiality relating to employment matters, refer to the Human Resources Manual.

11. THIRD PARTY WEBSITES

Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

12. ACCESSIBILITY OF INFORMATION

Information held about an individual is accessible (at no charge) to that individual on request and reasonable steps are taken to ensure the information is accurate and up to date.

Access to information may be denied if Project Rozana has reason to believe that the request is not for a genuine purpose. If a request for information is considered not for a genuine purpose, the matter will be raised with the Executive Director for consideration of the request. A request for access to information may be made using the contact details below.

13. UPDATING INFORMATION

Please let us know if the personal information we hold about you needs to be corrected, updated or completed.

Project Rozana makes every effort to ensure that the information we hold about you is correct and up to date. We may at times contact you to ensure this is the case.

14. ENQUIRIES AND COMPLAINTS

Enquiries or complaints regarding privacy matters can be made in writing or over the phone using the details provided below under Contact Information. Project Rozana are dedicated to respond to all enquiries as quickly as possible. If you would prefer to deal with us anonymously, you are not required to provide your personal information to us unless we are required by law to deal with individuals who have identified themselves or it is impractical for us to deal with individuals who have not identified themselves.

If you are not satisfied with how we have handled your matter, you may wish to contact the Office of the Australian Information Commissioner via the contact details listed on https://www.oaic.gov.au/about-us/contact-us.

15. CONTACT INFORMATION

In Australia – if you have a privacy concerns, contact our team on info@projectrozana.org or by calling +61 3 9272 5600. You can also contact us by post at the address:

Project Rozana, PO Box 2400, Caulfield Junction, VIC 3161 Australia.

PREVENTION OF SEXUAL EXPLOITATION, ABUSE & HARASSMENT

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

Project Rozana’s Mission is to build bridges to better understanding between Israelis and Palestinians through health. This community-wide, multi-faith health initiative achieves this by raising funds to: Train Palestinian health professionals in Israeli hospitals in order for them to return and build the health capacities of their communities, particularly where there are identified gaps; Transport Palestinian patients from home to checkpoints in Gaza and the West Bank to hospitals in Israel and back home via our partner NGOs, and Treat critically ill Palestinian children in Israeli hospitals in cases where funding from the Palestinian Authority is not available.

Project Rozana works with partner organisations in the region. Our work is supported by private philanthropy, Trusts and Foundations. In the capacity that we serve, we are equipped with resources and services which we bring to the community for their relief and development. This power differential and subsequent vulnerabilities in the communities in which we serve increases the risk of exploitation, abuse and harassment. As a humanitarian organisation, our primary concern is that the programs we instigate should “Do no harm”.

Furthermore, we are committed to the ACFID Code of Conduct along with other key sector standards and regulations. In addition to the imbalance of power between workers and beneficiaries, we also acknowledge the imbalance in power between men and women, ability and disability, ethnicity, religion, gender identity and sexual orientation, age, health and poverty.

Project Rozana is committed to preventing sexual exploitation, abuse and harassment (defined below) by our Project Rozana representatives and implementing partners. As Project Rozana is committed to non-discriminatory and respectful behaviour, all forms of misconduct are considered unacceptable.

Project Rozana has zero tolerance towards the sexual exploitation, abuse and harassment of personnel  or the adults who engage with our programs. Whilst this policy applies to all adults, it aims to particularly reflect Project Rozana’s commitment to safeguarding vulnerable individuals. It is our responsibility to ensure that adults are not deliberately or unknowingly placed in situations which make them easily susceptible to Sexual Exploitation, Abuse and Harassment (“SEAH”) by Project Rozana representative and implementing partners. Project Rozana is thus committed to ensuring that safeguarding measures are embedded, accessible and clearly communicated to all Project Rozana representatives.

Our Child Protection Policy and Procedures are relevant to any matters relating to children.

Project Rozana has a commitment to operating within a survivor-centric approach and will respect the wishes and dignity of the survivor and consider the need for counselling. As an organisation we respect the privacy of people who may be impacted by this Policy and will endeavour to uphold confidentiality, unless a person is at risk of harm to themselves or others.

3. SCOPE & PURPOSE

This policy is applicable to all Project Rozana representatives. Our implementing partners, who have direct contact with the community and beneficiaries, are encouraged to implement this policy through development of their own policy.

This policy aims to develop an organisation wide culture of increased awareness of SEAH, with a scope that covers the workplace, partner organisations and the communities we seek to serve.

Project Rozana is committed to the following seven core principles on protection from sexual exploitation, abuse and harassment (“PSEAH”):

  1. Sexual exploitation and abuse by Project Rozana representatives constitute acts of gross misconduct and substantiated allegations are grounds for termination of employment.
  2. Sexual activity with children (persons under the age of 18) is prohibited regardless of the age of the majority or the locally recognised age of consent. Mistaken belief in the age of the child is not a defence.
  3. Exchange of money, employment, goods or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour by Project Rozana Representatives is prohibited. This includes the exchange of assistance that is due to program participation.
  4. Sexual relationships between Project Rozana representatives/implementing partner staff and program participants, since they are based on inherently unequal power dynamics, undermine the credibility and integrity of the work of Project Rozana. For this reason, sexual relationships between Project Rozana representatives and program participants are prohibited and must be reported in accordance with Project Rozana’s Child Protection Policy (in the case of minors) or as outlined below. Sexual relationships between implementing partner staff and program participants, are strongly discouraged. To protect against exploitation and abuse in cases where there is a sexual relationship between implementing partner staff and program participants, a conflict of interest must be declared.
  5. When a Project Rozana representative has concerns or suspicions regarding SEAH by a fellow worker, whether in Project Rozana or a partner organisation/community, he or she must immediately report such concerns via the reporting mechanisms as outlined within this policy. As this applies to Project Rozana representatives who have concerns regarding alleged perpetrators of SEAH, in cases where a victim has a concern, they may control whether reports of incidents against them are reported.
  6. Project Rozana representatives are obliged to create and maintain an environment that prevents SEAH and promotes the implementation of this Policy. Project Rozana managers at all levels have responsibilities to support and develop systems which maintain this environment.
  7. Project Rozana Representatives are prohibited from engaging with commercial sex workers or engaging in prostitution of any form whilst on a work trip (including travel time, field visits and leisure time) and representing Project Rozana even if commercial sex work is legalised in that country. This kind of conduct goes against our organisational values as per the Project Rozana Code of Conduct and any such conduct, as substantiated, will constitute grounds for disciplinary measures including summary dismissal, under Project Rozana’s relevant policies or discontinuation of partnership/funding under relevant MOUs and partnership/funding agreements.

4. DEFINITIONS

The DFAT Preventing Sexual Exploitation, Abuse and Harassment (PSEAH) Policy uses the following definitions of sexual exploitation, sexual abuse and sexual harassment, which Project Rozana adopts:

Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially, or politically from 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. It covers sexual offences including but not limited to attempted rape (which includes attempts to force someone to perform oral sex); and sexual assault (which includes non-consensual kissing and touching). All sexual activity with someone under the age of consent (in the law of the host country or under Australian Capital Territory law [16 years], whichever is greater) is considered to be sexual abuse.

Sexual harassment: A person sexually harasses another person if the person makes an unwelcome sexual advance or an unwelcome request for sexual favours or engages in other unwelcome conduct of a sexual nature, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated or intimidated. Sexual harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated or one-off and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against beneficiaries, community members, citizens, as well as staff and personnel.

Safeguarding:  Actions, policies and procedures that create and maintain protective environments to protect people from exploitation, abuse and harm of all kinds.

Child: A child is a person under the age of 18, irrespective of who is counted as child (based on age) in their local country.

Vulnerable adults: Vulnerable adults are people over the age of 18 who may be placed in a position of vulnerability and inability to care for themselves or protect themselves from any harm or exploitation. Individuals could be vulnerable to PSEAH due to their: gender, race, ethnicity, religious identity, mental or physical health, disability, sexual orientation, economic or social status, or being located in disaster or conflict prone regions.

Confidentiality: Refers to the protection of personal information. TAI will endeavour to upkeep confidentiality when dealing with concerns, issues and suspected cases, unless a person is at risk of harm to themselves or others.

Representatives: This term covers Project Rozana funded activities and includes the following:

1. Employees

2. Volunteers

3. Interns and work experience students

4. Board members

5. Individual contractors and consultants working for Project Rozana

6. Project Partners

7. Supporters of Project Rozana

Transactional sex: The exchange of money, employment, goods, services or other benefit for sex, including sexual favours.

Complainant: The person who raises the complaint. This may or may not be the alleged victim in the matter.

Victim: Once proven to be true or correct, the complainant who has alleged having been sexually exploited, abused or harassed can be referred to as the victim.

Subject: This is the person against whom the allegation of SEAH or Sexual harassment has been brought on by the complainant and is the focus of the investigation.

Perpetrator: This is a person who has been proven to have committed the SEAH.

5. POLICY PRINCIPLES

Principle 1: Zero tolerance of inaction of incidents of SEAH

Sexual exploitation, abuse and harassment are never acceptable. Project Rozana defines zero tolerance as acting on every allegation in a fair and reasonable way with due regard for procedural fairness. Reports of incidents may increase as organisations improve safeguards. Increasing reports may indicate growing awareness of SEAH and changing attitudes, with victims/survivors feeling more comfortable to report and organisations more likely to take action. The reporting of incidents and responses is an indicator that the risk of SEAH is being managed appropriately.

Principle 2: Shared responsibility

Preventing SEAH is everyone’s responsibility. Project Rozana requires the commitment, support and investment of its Representatives and partners for this policy to be effective. All organisations have a responsibility to build their capacity to deal sensitively and effectively with SEAH that occurs in the course of their work.

Principle 3: Victim/survivor centred approach

Action to address SEAH should be underpinned by a “do no harm” approach prioritising the rights, needs, and wishes of the victim/survivor, while ensuring procedural fairness to all parties. This approach:

  • treats the victim/survivor with dignity and respect
  • involves the victim/survivor in decision making
  • provides the victim/survivor with comprehensive information
  • protects privacy and confidentiality
  • does not discriminate based on gender, age, race/ethnicity, ability, sexual orientation, or other characteristics
  • considers the need for counselling and health services to assist the victim/survivor with their recovery.

Principle 4: Gender inequality and other power imbalances are addressed

Additionally, gender inequality and other imbalances based on the distinctions of worker/beneficiary, ability/disability, ethnic and indigenous status, religion, gender identity and sexual orientation, age, health and poverty, can also result in SEAH. The intersection of gender with other forms of inequality can further increase the likelihood of SEAH occurring. Engagement with intended beneficiaries should be based on respect for diversity, promotion of gender equality and social inclusion, accountability, and a strong “do no harm” focus.

Although they are not in scope for this Policy, children are at high risk of SEAH — particularly children with disability, children living in residential or institutional care, children who have experienced previous trauma or abuse, and gender diverse children and young people. Project Rozana’s commitment to safeguarding children from SEAH is covered by Project Rozana’s Child Protection Policy.

Principle 5: Accountability and transparency

Sexual exploitation, abuse and harassment is a failure of responsibility. Project Rozana is not only accountable to its donors, but also to the communities which it seeks to help. Stronger reporting allows Project Rozana to better monitor SEAH, understand risks, improve assurance and work with organisations to improve systems and safeguards accordingly.

6. POLICY OBJECTIVES

The objectives of this policy are to:

  • Promote appropriate standards of conduct with respect to SEAH through consistent and intentional awareness raising and training
  • Implement increased and ongoing capacity and awareness raising strategies to ensure that all Project Rozana representatives and implementing partner staff know their rights and responsibilities regarding PSEAH
    alongside other key policies (as per the Related Policies and Procedures section below) which must work in tandem with this.
  • Create and maintain an environment which is free from workplace sexual harassment and promotes the implementation of relevant codes of conduct and behavioural standards.
  • Prevent the SEAH of adults, including vulnerable adults, who interact/engage with Project Rozana representatives and/or implementing partner staff during the course of our work.
  • Encourage the reporting of behaviours which breach this policy and related policies, notably the EEO, Anti-Discrimination, Harassment and Bullying, and Child Protection policies.
  • Continuously socialise and train Project Rozana representatives on complaints handling and whistleblowing policies and procedures based on the principles of procedural fairness, ensuring all complaints are managed in a sensitive, fair, timely and confidential manner as appropriate.
  • Ensure protection from any victimisation or reprisals for the complainant and the whistleblowers.

7. PROCEDURES

7.1 Risk assessment

This policy takes a risk-based, proportional approach to Prevention of Sexual Exploitation, Abuse and Harassment (PSEAH). Project Rozana staff and partners must assess the level of risk for SEAH occurring and apply PSEAH Minimum Standards adopted from DFAT (Attachment A) commensurate with the level of risk identified. The higher the risk, the greater the controls required.

If no SEAH risk is identified in the delivery of Project Rozana business, then:

  • no minimum standards need to be applied under this Policy; this should be documented in accordance with organisational risk management practices and be agreed by the relevant decision- maker
  • the risk of SEAH should be monitored throughout activity delivery, as part of standard risk management practice.

If Project Rozana staff determines a risk of SEAH exists, the level of risk (low, medium, high or very high – see Appendix B for details) must be established based on the likelihood and consequence of that risk occurring as outlined in Project Rozana Risk Management Policy. Risk management processes should also be established to mitigate risks. To determine the risk of SEAH, a comprehensive assessment must be formed by considering the business/activity along with organisational and reputational risks and how they may intersect.

Using a risk-based approach, the DFAT PSEAH Minimum Standards are applied commensurate with the level of risk identified:

  • Low Risk – apply Minimum Standards 1 and 2
  • Medium Risk – apply Minimum Standards 1 – 3
  • High Risk – apply Minimum Standards 1 -5
  • Very High Risk – apply Minimum Standards 1 to 7

8. ROLES AND RESPONSIBILITIES

The Project Rozana Australia Executive Director is tasked with the responsibility of monitoring this policy and overseeing the implementation and regular updating of the policy across the Project Rozana organisation. This person is also the appointed Safeguarding Officer for Australia.

The Project Rozana Israel Office Executive Director is the appointed Safeguarding Officer for Israel and will be responsible for checking all prospective partners against the listed individuals and organisations and documenting this check.

The Project Rozana Australia Executive Director and the Israel Office Executive Director will ensure that all employees and volunteers uphold and operate in accordance with this policy. They are responsible for:

  • Taking a lead role in raising awareness about the organisation’s PSEAH measures including the Code of Conduct and provide training and advice to
    staff and volunteers on these measures
  • Requiring applicants to disclose whether they have had a substantiated SEAH claim made against them in Australia or overseas in the Job Application Form or Consultant Agreement
  • Work with project partners to ensure that staff and volunteers are integrating PSEAH measures into all Project Rozana related activities and that they are aware of reporting protocols
  • Ensuring that primary stakeholders are aware of Project Rozana’s PSEAH measures and their right to protection including how they would raise a concern about SEAH
  • Receive reports in regards to SEAH, responding in accordance with Project Rozana;s procedures and providing referral or next step advice
  • Assist in investigating reported SEAH incidents, where appropriate
  • Discuss subsequent action required, to ensure the safety and welfare of individuals in cases of SEAH caused by Project Rozana
  • Access technical support in particular in regard to complex SEAH issues
  • Coordinate regular reports to the Board in both countries and the International Board on the implementation of PSEAH measures.

9. REPORTING

Project Rozana Representatives are expected to comply with the principles and reporting requirements specified in this Policy. Reporting is for any suspected or alleged cases of SEAH perpetrated by anyone within scope of the Policy in connection with official duties or business.

Project Rozana will report any suspected or alleged incidents of SEAH or policy non-compliance to the Board of Directors. Wherever possible this should de-identify the victim/survivor, consistent with a survivor-centred approach.

Where safe to do so, and when in accordance with the wishes of the victims, survivors and whistleblowers, all alleged SEAH incidents that involve a criminal aspect should be reported through the correct local law enforcement channels. To protect the privacy of alleged perpetrators, victims/survivors, and whistleblowers, information provided to Project Rozana will be handled in accordance with the Privacy Act 1988 (Cth).

If a Project Rozana Representative believes they have been subject to SEAH or if SEAH is believed or suspected to have occurred, there are rigorous procedures in place to ensure that any complaint or query is treated confidentially, taken as seriously as possible, and acted on promptly. In accordance with Principle 3 — Victim/survivor needs are prioritised — victims’ and survivors’ safety and wellbeing must be paramount to reporting and their information treated confidentially.

If in doubt, Project Rozana Representatives should report an alleged incident. In line with Principle 1 — Zero tolerance of inaction — individuals and organisations found not reporting alleged incidents will be viewed as being non-compliant.

In its offices in each country, a senior staff member is appointed as a PSEAH focal person. In the Australian and Israeli Offices, the PSEAH focal person is the role of the Executive Director. A focal person provides a key role in raising awareness throughout the organisation and in coordinating, supporting and advising on the development and implementation of the PSEAH policy and practices.

The responsibilities of Project Rozana SEAH focal persons (Safeguarding Officers) include:

  • Promoting PSEAH policy widely within the organisation on a regular basis to ensure that all Project Rozana employees, volunteers, contractors and other Project Rozana representatives are aware of the policy and their rights and responsibilities and consequence of breaching the policy.
  • Conducting regular training sessions on SEAH for Project Rozana employees, volunteers and project partners about recognising sexual harassment, what is, and what is not, sexual harassment, how to report concerns and how to use the complaint process.
  • Incorporating the PSEAH policy into Project Rozana’s HR Manual which also contains expected Code of Conduct and which is a component of an induction process of new staff, volunteers and contractors.
  • Outline a commitment to developing materials that promote reporting mechanisms in languages and media that are appropriate and understandable to communities and contexts where your organisation is working.
  • Working with Project Rozana partners to ensure their commitment to PSEAH and provide assistance with development and implementation PSEAH policy.

To report alleged or suspected SEAH Project Rozana Representative can approach:

  • The PSEAH focal person (Safeguarding Officer)
  • Any member of the Project Rozana Board of Directors
  • A trusted person, colleague or friend, who is willing to support them to raise a concern and/or test their perception of events.

Representatives should state they are using the Whistleblowing Policy and specify whether they wish for their identity to be kept confidential. People choosing to raise their concerns in writing must use the template Project Rozana Incident Report contained in Appendix A.

10.  SEAH COMPLAINT HANDLING PROCEDURE

Once a SEAH incident report is received it gets forwarded to the Executive Director or, if the complaint is about the Executive Director to the Chair of the Board. The Executive Director or Chair responds to the author of the complaint thanking them for their concern and bringing it to Project Rozana’s attention and informing them the matter will be investigated.

Reports of SEAH of individuals under the age of 18 will be handled according to procedures outlined in the Project Rozana Child Protection Policy.

Where a complaint does not involve the Executive Director, and the complaint is of a medium or high risk as specified by the Risk Rating Matrix in Project Rozana’s Risk Management Policy, the Executive Director will inform the Project Rozana International Board and relevant in-country Board of the complaint.

The Executive Director will do an initial assessment to confirm it is a valid report and begin investigation. The Executive Director will keep the Project Rozana Boards updated on the progress of the investigation.

Once the Executive Director has finalised their investigation and report, the Boards and the informant will be updated. At this point, the Executive Director will hand everything over to the relevant Project Rozana Board for any subsequent action to take place.

Where the complaint is medium or high risk the Executive Director will inform the author and the Boards of the result of the investigation.

Project Rozana will ensure that if a complaint is made about SEAH:

  • It is handled in accordance with the principles outlined in this policy
  • As employer, Project Rozana meets its equal obligation to both the complainant and the respondent to uphold their rights and provide support
  • Complaints are dealt with impartially, without bias and in a timely and sensitive manner
  • Information about a complaint is only provided to those people who need to know in order for the complaint to be actioned properly
  • The respondent is informed about any allegations made against them and is given the opportunity to respond to those allegations
  • Those involved are informed about the process for resolving complaints
  • Those involved are protected against any victimisation or reprisals and employees are assured that no action will be taken against them if they speak up
  • There is a clearly defined review process to ensure the resolution is working satisfactorily and to confirm that no victimisation has resulted from the complaint
  • Issues are resolved at the most appropriate level of intervention, subject to the rights of the complainant.

11. INTERVENTIONS

If an employee believes they have been exposed to SEAH, or has witnessed SEAH, trying to resolve issues at the lowest appropriate level of intervention may sometimes be the most effective and satisfactory way of dealing with unacceptable behaviour.

11.1 Self-help and supported self-help

Self-help involves an employee letting the respondent know that their behaviour is unwelcome, inappropriate or offensive and needs to stop. This may resolve the matter quickly and in a low-key manner. This may be appropriate where sexual harassment is minor, and the employee does not feel seriously harmed or threatened by approaching the person.

Self-help actions could be that the employee:

  • Tells the person directly about the behaviour they do not like, and asks them to stop it
  • Writes a letter on a ‘private and confidential’ basis to the person
  • Takes a support person to tell the person that the behaviour needs to stop.

Employees should not approach someone directly about their behaviour if by doing so they would feel unsafe or threatened in any way.

Resolution may involve a verbal or written apology or agreement on how the parties will behave towards one another in future.

11.2 Informal intervention

Another informal way of dealing with sexual harassment and bullying is for an employee to ask for someone else to intervene on their behalf on an informal basis, either their manager or a colleague or friend.

The person who is intervening will:

  • Discuss what happened and what is needed to resolve the situation
  • Listen impartially
  • Clarify the facts being reported
  • Discover what appropriate action the employee is seeking
  • Clarify the complaints procedure options and Project Rozana sexual harassment and bullying policy
  • Discuss options with the employee and, if appropriate, the respondent and decide on an informal or formal approach
  • Document the situation and outcome.

If there is agreement on what happened and what will resolve the situation, the issue can be resolved confidentially between the people concerned.

Mediation may be pursued to resolve complaints at this level.

11.3 Mediation

In some instances, arranging for a complainant and respondent to discuss the complaint with a skilled mediator may be an appropriate way to address the issue. Both parties need to agree to mediation.

Mediation is not always appropriate to resolve behaviour issues, particularly if there is a power  imbalance. Mediation may be suitable where:

  • There is basic agreement on the facts
  • Both parties agree to try to resolve the situation through this method
  • The harassment is of a low level and serious disciplinary consequences do not appear warranted.

If a complainant and the respondent cannot resolve the complaint through mediation, then formal options are available.

11.4 Formal intervention

The decision whether or not to proceed to a formal investigation will be made by the person receiving the complaint in consultation with Executive Director, or if the Executive Director is the initial recipient of the complaint, a member of the Project Rozana Board of Directors.

12. OUTCOMES

Where allegations are admitted or substantiated, the outcomes for the respondent of breaching this policy may range from an apology, counselling and training to warnings and dismissal. Disciplinary action will match the seriousness of the breach. Factors considered in determining the level of seriousness include the nature of the conduct and whether or not the person breaching the policy was in a position of trust or authority in relation to the complainant. Outcomes may also include interventions such as supportive counselling, a change in the work environment, or participation in mediation.

Where allegations are not substantiated it may still be appropriate to undertake some action, for example, refresher training or communications training. This ought not to single out or punish the respondent if there has been no finding.

13. RELATED POLICIES AND PROCEDURES

This Policy should be read in conjunction with the following:

  • Child Protection Code of Conduct
  • Child Protection Policy & Procedures
  • Code of Conduct
  • Gender Equity & Anti-Discrimination Policy
  • Whistleblower Policy
  • Feedback & Complaints Handling Policy
  • Risk Management Framework
  • Partnership Policy

 

 APPENDIX A:

PROJECT ROZANA SEXUAL EXPLOITATION, ABUSE AND HARASSMENT (SEAH) INCIDENT NOTIFICATION FORM

What is this form for?

In accordance with the Project Rozana Preventing Sexual Exploitation, Abuse and Harassment (PSEAH) Policy, all Project Rozana staff, partners and the staff and/or management of all institutions supported by Project Rozana must report alleged sexual exploitation, abuse and harassment (SEAH) incidents when they occur in the conduct of the development assistance work. This form is for organisations or individuals (including Project Rozana management and staff, as well as volunteers and Board members) to report an alleged incident to Project Rozana.

Please complete the form and email to: confidential@projectrozana.org or call: +61 3 9272 5600. If you do not have email access, please telephone +61 3 9272 5600 to report a SEAH incident. If you require assistance in completing this form, please contact us by email or telephone.

It may not always be obvious if a SEAH incident relates to a Project Rozana-supported program or activity. If in doubt, please still report. Project Rozana takes a victim/survivor centred approach to the reporting of alleged SEAH incidents. Incidents should only be reported where it is safe to do so and where it is in line with the victim/survivor’s wishes. Information that identifies individuals does not need to be reported.

Privacy Notification

This notice explains how Project Rozana will collect, use and disclose the personal and sensitive information collected through this form in accordance with our obligations under the Australian Privacy Principles (APP) and the Privacy Act 1988 (Commonwealth Privacy Act). Personal information may include an individual’s name, signature, address, telephone number, date of birth and any commentary or opinion about Project Rozana: Sensitive information may include information about a person’s health or racial/ethnic origin.

Project Rozana’s collection, use and disclosure of information collected in this form: Project Rozana reasonably believes that the collection, use or disclosure of the information, including personal information in this form is necessary in order for Project Rozana to:

  • manage the risks of SEAH and SEAH incidents in the provision of development assistance;
  • take appropriate action where it suspects that unlawful activity or misconduct of a serious nature has been or is being engaged in, and;
  • lessen or prevent a serious threat to the life, health or safety of an individual or to public health or safety

If we are unable to collect your personal information, Project Rozana may not be able to contact you and to make further enquiries about the alleged incident you have reported.

Project Rozana Privacy Policy

Further information about how:

(a) you can access and seek correction of personal information that Project Rozana holds about you; and

(b) to make a complaint if you have a concern or believe Project Rozana may have breached an Australian Privacy Principle is available through the Project Rozana Privacy Policy.

If anyone related to this notification is in imminent danger:

In Australia – please telephone 061 3 9272 5600 Outside Australia, please phone +61 3 9272 5600or visit your local law enforcement office (if safe to do so) or another support service (e.g., a medical centre, hospital, sexual violence support centre, rape support centre, etc).

SEAH Incident Notification Form

In completing this form, please provide as much information as you can or as you feel safe/comfortable to provide. In accord with our PSEAH Policy principles, Project Rozana takes a victim/survivor-centred approach to the reporting of SEAH.

PSEAH REPORT FORM

APPENDIX B: PSEAH MINIMUM STANDARDS

The Policy takes a risk-based, proportional approach to PSEAH. Project Rozana’s staff and partners must assess the level of risk for SEAH occurring and apply minimum standards accordingly. The PSEAH Minimum Standards are then applied commensurate with the level of risk identified.

LOW, MEDIUM, HIGH, VERY HIGH RISK

Minimum standard:
1. Have a PSEAH policy or other documented policies and procedures in place and clearly communicate expectations of this Policy.

Obligations for Organisations:
Must have a PSEAH policy or other documented policies and procedures in place, which clearly meet the expectations of this Policy.

2. Have reporting and investigation procedures in place.
Obligations for Organisations:
The PSEAH policy, or equivalent, documents how SEAH incidents will be managed, reported and investigated. Reporting and investigation processes must include engagement of and reporting to senior management and executive boards.

MEDIUM, HIGH, VERY HIGH RISK

Minimum standard:
3. Have risk management processes that include the risk of SEAH.
Obligations for Organisations:
Have effective risk management processes that include consideration of the risk of SEAH. The process must document the controls already in place or to be implemented to reduce or remove risks.

HIGH, VERY HIGH RISK

Minimum standard:
4. Effective PSEAH training in place.
Obligations for Organisations:
PSEAH training for personnel, including downstream partners and individuals that deliver DFAT business.

Minimum standard:
5. Recruitment and screening processes and employment practices address and manage the risk of SEAH.
Obligations for Organisations:
Can demonstrate robust PSEAH recruitment and screening processes for all personnel/consultants including having in place appropriate and enforceable standards of conduct.

VERY HIGH RISK

Minimum standard:
6. Prohibit transactional sex for all personnel, while engaged in the direct delivery of DFAT business.
Obligations for Organisations:
Prohibits transactional sex in the field for all staff and downstream partners while engaged in the delivery of Project Rozana business.

TRANSPARENCY STATEMENT

In line with our values of transparency and integrity, Project Rozana will provide stakeholders and the general public with information about our operations and programs.

Examples of information which Project Rozana can share openly include our legal status, purpose and governance structure; descriptions of our programs and projects; organisational policies, financial and annual reports, strategic documents, memberships and accreditations, our strategic partners and main supporters and case stories from our projects.

Project Rozana aims to increase accountability, transparency, openness and participation by sharing this information. Additionally, where information is requested Project Rozana will endeavour to provide this information where it is deemed to be within the interest of stakeholders, partners, donors, supporters, media and the general public.

How to request information

The Project Rozana website contains a vast amount of information which you may wish to access. If the requested information is not available on the website you can contact Project Rozana using the contact details below.

Email:  info@projectrozana.org

Phone: +61 3 9272 5600

Mail: PO Box 2400, Caulfield Junction, Vic 3161 Australia

Each request should contain the information requested with dates and any other details as required.

The Executive Director will ensure that all requests for information are addressed in the appropriate manner. A request for information will be acknowledged within 5 business days and responded to within 20 business days. Where a request for information is denied reasons will be provided.

Declining access

Requests may be denied for various reasons including where requests are not made in good faith or are deemed to be vexatious. Information will not be provided where it may impact on the security of our staff, privacy concerns, breach of confidentiality or copyright limitations.

Project Rozana considers that the cost of disclosure, whether as a time cost or a monetary cost, would be disproportionate to the request, the request may be declined.

Languages

Project Rozana information is published in English; some policies have been translated into Arabic and Hebrew.

Historical information

Information prior to the commencement of this policy may be considered however while Project Rozanan will make reasonable efforts to deal with requests for this information, it is more likely that historic information will not be disclosed.

Appeals process

An appeals process is available to the requester if they are not satisfied with the outcome of their request. This would be reviewed by the Board.

WHISTLEBLOWER POLICY

1. PREAMBLE

This policy was written by Project Rozana in Australia. It may be used as a template across all Project Rozana offices. Project Rozana operates five offices registered in each of Australia, USA, Canada, UK and Israel, which are part of the Project Rozana Global Alliance. In this policy, ‘Chair’ means Chair of Project Rozana International. Unless specified otherwise the ‘Board’ refers to the board of Project Rozana Australia.

2. INTRODUCTION

Project Rozana requires all Representatives to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. All Representatives of Project Rozana must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.

Project Rozana is committed to fostering a culture which encourages raising concerns about unethical and unacceptable conduct and behaviour. We encourage the disclosure of suspected wrongdoing and are committed to providing a safe environment for disclosures to be made without fear of retaliation or reprisal.

Project Rozana will respond in a timely manner to all disclosures of actual or suspected wrongful acts, act confidentially within relevant laws and take steps to protect those personnel who make such disclosures from detrimental treatment.

3. DEFINITIONS

For the purpose of this policy, a whistleblower is a Project Rozana Representative who attempts to make or wishes to make a report in connection with a wrongful act under this policy and who wish to avail themselves of the protection offered by this policy.

A wrongful act includes, but is not limited to:

  • Breaches of legal obligations (including negligence, breach of contract, breach of administrative law);
  • Criminal offences;
  • Mismanagement of funds;
  • Actual or suspected fraud;
  • Abuse of authority;
  • Disclosures related to miscarriages of justice;
  • Health and safety risks, including risks to the public as well as other employees;
  • Damage to the environment;
  • The unauthorised use of organisational funds;
  • Possible fraud and corruption;
  • Sexual or physical abuse of staff or program recipients
  • Other unethical conduct; or
  • The concealment of any of the above.

A Project Rozana Representative refers to: all individuals and institutions who act on behalf of Project Rozana regardless of whether or not there is a formal legal agreement between them and Project Rozana. This includes, but is not limited to, all directors, employees, contractors, consultants, advisors, volunteers and implementing partners irrespective of which country their role is situated.

4. PURPOSE

The purpose of this policy is to:

a) Encourage the reporting of matters that may cause harm to individuals or financial or nonfinancial loss to Project Rozana or damage to its reputation;

b) Enable [Project Rozana to deal with reports from whistleblowers in a way that will protect the identity of the whistleblower as far as possible and provide for the secure storage of the information provided;

c) Establish policies for protecting whistleblowers against reprisal by any person internal or external to the entity;

d) Provide for the appropriate infrastructure;

e) Help to ensure Project Rozana maintains the highest standards of ethical behaviour and integrity.

5. RESPONSIBILITIES

The Executive Director, Australia is responsible for the implementation of the Whistleblower Policy. All staff and all volunteers are responsible for reporting breaches of general law, organisational policy, or generally recognised principles of ethics to a person authorised to take action on such breaches.

6. POLICY

6.1 Concerns regarding illegal or corrupt behaviour

As a Project Rozana Representative, you are encouraged to make a report under this policy if you know about or have reasonable grounds to suspect wrongdoing with respect to Project Rozana or any of its partners (“reportable conduct”).

Reportable conduct may include:

  • Breaches of legal obligations (including negligence, breach of contract, breach of the Corporations Act 2001 (Cth) (Corporations Act), Taxation Administration Act 1953 (Cth), The Australian Charities and Not-for-profits Commission Act 2012 (Cth);
  • Criminal offences;
  • Fraud, negligence, default, breach of trust and breach of duty (“misconduct”), corruption, money laundering, terrorism financing or any other conduct which contravenes our Fraud Prevention Policy and Anti-Terrorism and Money Laundering Prevention Policy;
  • Mismanagement or unauthorised use of organisational funds;
  • Abuse of authority;
  • Health and safety risks, including risks to the public as well as other personnel;
  • Harassment, discrimination, victimisation and bullying, other than personal work-related grievances (see our Grievance Policy);
  • Sexual exploitation, sexual abuse or physical abuse of other personnel, children or vulnerable adults;
  • Conduct that is contrary to, or a breach of, our policies (including our Code of Conduct which is available on our website (www.projectrozana.org);
  • Conduct which may cause financial loss or damage to our reputation or be otherwise detrimental to our interests.

7. PROCEDURES

7.1 Confidentiality

If a wrongful act or a suspected wrongful act is reported under this policy, Project Rozana will endeavour to protect the whistleblower’s identity. In order not to jeopardise the investigation into the alleged wrongful act, the whistleblower is also expected to keep the fact they have raised a concern, the nature of the concern and the identity of those involved confidential. Generally, Project Rozana will not disclose the whistleblower’s identity unless:

  • The whistleblower consents to the disclosure;
  • The disclosure is required or authorised by law; and/or
  • The disclosure is necessary to further the investigation.

Mostly, reports made under this policy will be treated confidentially. However, when a report is investigated it may be necessary to reveal its substance to people such as other Representative, external persons involved in the investigation process and, in appropriate circumstances, law enforcement agencies. At some point it may also be necessary to disclose the fact and the substance of a report to the person who is the subject of the report.

Project Rozana will take reasonable precautions to store any records relating to an Incident Report of a wrongful act securely and to permit access by authorised personnel only. Unauthorised disclosure of information relating to a report, the identity of the whistleblower or information from which the identity of the whistleblower could be inferred will be regarded seriously and may result in disciplinary action, which may include dismissal.

7.2 Protection of whistleblowers

No person who raises genuinely held concerns in good faith under this policy will be dismissed or subjected to any detriment as a result of such action, even if the concerns turn out to be unfounded. Detriment includes, but is not limited to, unwarranted disciplinary action and victimisation in any of the following forms:

  • Dismissal;
  • Demotion;
  • Any form of harassment;
  • Discrimination;
  • Current or future bias; or
  • Threats of any of the above.

Any such retaliatory action will be treated as serious misconduct and will result in disciplinary action which may include dismissal.

If a whistleblower believes retaliatory action has occurred or has been threatened, the whistleblower has the right to make a submission to the Project Rozana Board. The Project Rozana Board is independent of management and will arbitrate the matter.

7.3 Whistleblowers implicated in a wrongful act

Even though a whistleblower may be implicated in the wrongful act, they will not be subjected to any actual or threatened retaliatory action or victimisation in reprisal for making a report under this policy. However, making a report will not necessarily shield the whistleblower from the consequences flowing from that person’s involvement in the wrongful act. In some circumstances an admission may be a mitigating factor when considering disciplinary or other action.

7.4 False disclosures

Project Rozana will treat all disclosures of wrongful acts seriously and protect staff who raise concerns in good faith. However, while protection is provided to whistleblowers under this policy, deliberate false reports will not be tolerated and anyone found making a deliberate false claim or report will be subjected to disciplinary action, which could include dismissal.

7.5 Procedure for raising a concern

Project Rozana has an open door policy and suggests that Representatives share their questions, concerns, suggestions or complaints with their supervisor which in most cases will be the Executive Director. Complaints regarding the Executive Director should be directed to the Chairperson.

Concerns may be raised verbally or in writing and should include full details together with any supporting evidence that may be available. Representatives should state they are using the Whistleblowing Policy and specify whether they wish for their identity to be kept confidential.

Representatives choosing to raise their concerns in writing must use the template Project Rozana Incident Report.

7.6 How a disclosure will be handled

All disclosures will be taken seriously, and the following procedure will be used:

(a) The whistleblower must disclose at the outset, any personal interest they may have in the matter. This must include full disclosure of any involvement the whistleblower has had in the matter.

(b) The person to whom it was raised (see 5.5) shall manage the disclosure (the Disclosure Manager).

(c) The Disclosure Manager will identify a suitable individual who will be instructed to conduct an investigation into the allegation. This person may be internal or external to Project Rozana. Project Rozana undertakes to start the investigation within two weeks of the disclosure. The length and scope of the investigation will depend on the subject matter of the disclosure. In most instances, there will be an initial assessment of the disclosure to determine whether there are grounds for a more detailed investigation to take place or whether the disclosure is, for example, based on erroneous information.

(d) The whistleblower may be asked to provide more information during the course of the investigation.

(e) The person investigating the disclosure will prepare an investigation report that will be reviewed by the Disclosure Manager.

(f) Appropriate action will be decided by the Disclosure Manager in discussion with Board. Action may include initiating a disciplinary process, or informing external authorities if a criminal action has been committed, eg fraud or theft. If referral to an external authority is necessary the Board will be advised and the whistleblower will be informed, although if Project Rozana considers it appropriate to do so, such a referral may need to be made without the whistleblower’s knowledge or consent.

(g) If it is found that there is not sufficient evidence of a wrongful act, or the actions of the individual(s) are not serious enough to warrant disciplinary action, it may be appropriate for the Disclosure Manager to take a more informal approach to dealing with the matter. In this circumstance possible outcomes of the investigation could be that:

  • The allegation could not be substantiated; or
  •  Action has been taken to ensure that the problem does not arise again.

(h) If the whistleblower is not satisfied with the response, they have received they have the option to raise the matter directly with a Board member directly.

8. CORRECTIVE ACTION AND COMPLIANCE

Should allegations be found to be unsubstantiated, every effort will be made to address any negative effects on the reputation and morale of personnel involved. As part of the investigation into disclosures made under this policy, recommendations for change will be invited from the investigator to enable Project Rozana to minimise the risk of the recurrence of any wrongful act that has been disclosed. The Disclosure Manager will be responsible for reviewing and implementing these recommendations.

9. MANAGEMENT OF A PERSON AGAINST WHOM A REPORT IS MADE

Generally, the person who is the subject of any report that is investigated, will:

  • Be informed as to the substance of the allegations;
  • Be given the opportunity to answer the allegations before any investigation is finalised;
  • Be informed about the substance of any adverse comments that may be included in any report arising from the investigation before it is finalised; and
  • Have their defence set out fairly in any report.

Project Rozana recognises that individuals against whom a report is made must also be supported during the handling and investigation of the alleged wrongful act. Project Rozana will take reasonable steps to ensure the person who is the subject of a report, is treated fairly, particularly during the assessment and investigation process. Support provided by Project Rozana may include referral for counselling. Where a person is named by a whistleblower as being suspected of a possible wrongful act but preliminary inquiries determine that the suspicion is baseless or unfounded and that no formal investigation is warranted, then the whistleblower will be informed of this outcome and the matter laid to rest. Where an investigation does not substantiate the report, the fact that the investigation has been carried out, the results of the investigation and the identity of the person who is the subject of the report must be handled confidentially.

10. RELATED POLICIES

Other organisational policies that should be read in conjunction with this policy include:

  • Code of Conduct
  • Conflict of Interest Policy
  • Fraud Prevention Policy

APPENDIX A

WHISTLEBLOWER REPORT FORM

CONTACT US

+61 3 9272 5600

PROJECT ROZANA

PO Box 2400, Caulfield Junction, Vic 3161 Australia

CONTACT

+61 3 9272 5600

1800 hadassah

PROJECT ROZANA

c/o Hadassah Australia, PO Box 2400, Caulfield, Vic 3161 Australia