Introduction
Brainwave Careers has for over 5 years made the safety of the participants of its programs as well as the safety of the employees of its programs and enterprises of paramount importance in the way it has conducted its (Education) work.
While the concept of safety itself has broader implications, safeguarding will in the context of this policy (and in line with current use in the humanitarian and the development field) be conceived as protecting against abuse, that is, against sexual harassment, intimidation and violence, bullying, humiliation and discrimination, neglect and exploitation.
Brainwave Career has safeguarded its people (participants, employees) in the first place by making their safety a primary consideration already at the level of the design of programs and enterprises. The prevention of sexual harassment, intimidation, violence, bullying, humiliation and discrimination, neglect and exploitation is as far as possible built into the work practices themselves. Where the design and its implementation cannot reduce risks sufficiently, Brainwave Careers has established secondary safeguarding mechanisms, like the selection and training of personnel, supervising and monitoring activities, reporting channels, investigation and punishment.
In many cases, Brainwave Careers has sought to furthermore carry its safeguarding forward into the communities it serves. It has done so by example, through dialogue and by tailored programs
This five-year effort in safeguarding has been sustained because the fight against sexual harassment, intimidation, violence, bullying and discrimination, neglect and exploitation is part of Brainwave’s mission. It is part of its mission in two ways. Brainwave Careers sees that fight as one of its primary tasks closely connected to its core values of respecting human dignity, integrity and inclusiveness. Brainwave Careers also knows that if it guards the safety of its people and the communities it serves; its education work will be more effective.
Brainwave Careers has articulated that commitment to safeguarding at the level of its values, its code of conduct and its workplace instructions. It is a vital element in the induction of new employees. It is an important element of its human resource strategy.
The leadership of Brainwave has during these five years consistently reinforced the importance of safe guarding and has led by example. Its Boards have been vigilant, its management persistent.
Brainwave Careers has noted with great concern the recent integrity scandals in the humanitarian and development sector and the moral panic that has ensued. Brainwave Careers mourns the suffering of victims and survivors, abhors the sexual harassment and the violence. Brainwave Careers applauds the renewed vigor with which organizations within the sector have undertaken to safeguard the people they work with and serve. Brainwave Careers understands that governments and donors are seeking more assurances from organizations within the sector – including from Brainwave Careers itself.
In the light of this crisis in the humanitarian and development sector, Brainwave Careers has undertaken to write up its five-year history of safeguarding practice in the form of a comprehensive safeguarding policy. In this policy, Brainwave Careers will bring together a handful of pledges that will guide its future efforts, safeguarding principles, standards of behaviour, safeguarding practices, governance; the relevant sub-policies concerning the safeguarding of specific groups in specific programs and enterprises, and descriptions of all safeguarding practices it has developed in the last five years, encompassing both design solutions and secondary mechanisms. Brainwave Careers acknowledges that it has in the past not done enough to document the way it safeguards; it will rectify that in this policy, in its underlying documentation and in future studies and publications.
Pledges
- The Brainwave Careers organization and the leadership hereby pledge that the safeguarding of its people (employees, participants) and the people of the communities it serves against abuse, that is, against sexual harassment, bullying, discrimination, intimidation and violence, neglect and exploitation will continue to be a primary guiding principle in its education work, its programs and its enterprises.
- The Brainwave Careers and the leadership pledge that the commitment to safeguarding will continue to be articulated at the level of its values, code of conduct and work instructions. They pledge that safeguarding will continue to be incorporated in the design of programs and enterprises. They pledge that, where necessary, secondary safeguarding mechanisms will continue to be established and then maintained.
- The Brainwave organization and the leadership pledge that they will analyze, describe and document the safeguarding work they have done and do. Of particular importance are the descriptions of the ways safeguarding risks have successfully been avoided in the design of programs and enterprises and the descriptions of secondary mechanisms that have successfully tackled specific remaining risks. Brainwave Careers will make this research available to its partners and donors, as well as to other organizations in the sector.
- The Brainwave organization and the leadership pledge that they will continue to look for gaps and weaknesses in their safeguarding practices and address them wherever and whenever they are found. Brainwave envisions this as an ongoing effort. System audits have been, are and will be an important element of this constant improvement of safeguarding practices.
- The Brainwave Careers company and the leadership pledge that they will continue to research, innovate and test new safeguarding solutions. They recognize that, because of the scale, breadth and interconnectedness of its programs, Brainwave occupies a unique position in the sector. It accepts the responsibility that goes with that position. Brainwave aspires to help the sector to overcome its safeguarding deficiencies.
Scope
Brainwave Careers is committed to safeguarding. It wants to protect all its employees and participants against abuse, that is, against sexual harassment, intimidation and violence, bullying, humiliation and discrimination, neglect and exploitation.
Brainwave also recognizes that some of its people are more at risk. It is with that in mind that Brainwave recognizes six different categories within its people that are more at risk than others and therefore deserve extra efforts to protect them. These six categories are: children, adolescents, adults with special needs, women among the participants; adults with special needs and women among the employees. Brainwave will not hesitate to add other general categories to this list in future if it concludes that this is warranted. Brainwave Careers will also at the level of specific programs or activities offer extra protection to people outside these categories whenever that is needed. For now, these six categories will provide a structure for Brainwave’s efforts to:
Analyze, describe and document the safeguarding work Brainwave has done over the last five years and is doing now
Develop and implement sub-policies Design programs and enterprises Establish secondary mechanisms
Improve and innovate safeguarding practices
Brainwave Careers has been and will be safeguarding its people across all its programs and education (pre-schools, play labs,
primary schools, secondary schools, professional skills training, life skills training for adolescents), society (legal, gender, community, safe migration), humanitarian
Brainwave Careers acknowledges that its safeguarding responsibilities do not end at the boundaries of its programs and enterprises. It has sought and will continue to seek a dialogue with partners, suppliers and client organizations about safeguarding. It will include conditions regarding safeguarding in the contractual relations it enters into. It will react with severity if those conditions are not met or broken. Brainwave Careers will also continue to reach out into the communities it serves and the societies where it works to fight sexual harassment, intimidation and violence, bullying, humiliation and discrimination, neglect and exploitation.
All of the above means that this safeguarding policy applies to all cases within Brainwave Careers where employees abuse other employees, where employees abuse participants, where participants abuse employees – and the cases where participants abuse participants within Brainwave Career’s span of control or sphere of influence.
Safeguarding Principles
Brainwave Careers holds the following principles with regard to safeguarding as self-evident and as foundational for its practices:
Organizations have a safeguarding duty of care to participants, staff and volunteers, including where down-stream partners are part of delivery. This duty of care extends to people at risk of abuse within the communities the organizations serve.
Organizations have a duty to identify groups of people among employees and participants that are at greater risk of becoming victims of abuse. They have a duty to try to mitigate the extra risks those groups face.
Organizations have a duty to try to prevent abuse occurring. They must make safeguarding a central element of the organizational culture. They must mitigate existing risks that may already exist in the program design and specific work practices. They must establish secondary safeguarding mechanisms wherever risks cannot be mitigated through design.
Organizations have a duty to make sure that, if abuse does occur, victims and witnesses have access to multiple safe reporting channels. Organizations have a duty to always follow up on reports of abuse, to investigate them and to make sure that, if warranted, appropriate disciplinary action is taken. Organizations have a duty to protect whistleblowers.
Organizations have, in principle, a duty whenever abuse crosses the line into criminal behavior to involve local authorities. However, the dangers in terms of lack of due process and disproportionate punishment should be taken into account.
Organizations have a duty to anchor safeguarding within management. Responsibilities with regard to safeguarding should extend to the highest levels of management and to the Boards. Those responsibilities should be clearly assigned. Organizations have a duty to make sure that the execution of safeguarding policies is carried out by competent professionals according to the highest standards and, whenever possible, following global best practices.
Everybody within an organization is responsible for safeguarding employees, participants and community members. Everybody should intervene to stop abuse whenever possible. Everybody should report abuse.
Standards of Behaviour
The following standards of behaviour are the minimum requirements for all employees and associate personnel (which can include volunteers) with regard to safeguarding and with regard to the prevention of abuse, that is, sexual harassment, intimidation and violence, bullying, humiliation and discrimination, neglect and exploitation.
Employees and associated personnel of Brainwave Careers must not:
Violate the Code of Conduct of Brainwave Careers.
Violate the Sexual Harassment Elimination (SHE) Policy
Violate the Child and Adolescent Protection Policy Violate the Adults with Special Needs Policy
They must not:
Physically assault anybody
Threaten anybody with physical assault
Hit children and adolescents to discipline or correct them Assault anybody with a weapon
Threaten to assault anybody with a weapon.
They must not:
Bully anybody
Humiliate anybody
Humiliate children or adolescents to discipline or correct them
Discriminate against anybody, for example, based on religion, gender, sexual orientation, race, skin color, age, ethnicity, caste.
They must not:
- Interact sexually with anybody without the other’s willing consent
- Sexually harass or assault anybody
- Have any sexual interaction with children
- Have any sexual interaction with adolescents who are participants
- Have any sexual interaction with adolescents under the age of consent
- Have any sexual interaction with adults with special needs who are participants of the program they are working with
- Have any sexual interaction with women (or men) who are program participants of the program they are working with
- Have any sexual interaction with fellow employees of Brainwave in exchange for money, goods or favors or based on any form of coercion.
They must not:
- Neglect children, adolescents and adults with special needs who are entrusted to their care
- Exploit children, adolescents, adults with special needs or other participants or fellow employees in any form
- Bring children, adolescents, adults with special needs or other participants or fellow employees into a situation where they can be abused or exploited by third parties.
Employees and associated personnel of Brainwave Careers must:
- Follow the Code of Conduct, the Sexual Harassment Elimination Policy, the Child and Adolescent Protection Policy, the Adults with Special Needs Policy
- Anticipate risks for fellow employees or participants of being abused, that is, being sexually harassed, intimidated or assaulted, bullied, humiliated or discriminated, neglected or exploited and take steps to mitigate those risks
- Avoid being placed with children or with adolescents who are participants or under age, or with adults with special needs who are participants, in a compromising position. The adult is always considered responsible even if the child or adolescent or adult with special needs has initiated sexual interaction
- Stop immediately any abuse they witness, if at all possible
- Report any abuse they witness or have reliable information about
- Treat everybody with respect
- Respect everybody’s privacy.
Safeguarding Practices
Brainwave Careers works on safeguarding along three axes; ethos, prevention and repression. Brainwave Careers has been doing its safeguarding work within a framework of iterative learning: try, evaluate and improve.
Ethos
Brainwave Careers is an educational organization, based on respecting human dignity, integrity and inclusiveness. Those values infuse all the work Brainwave Careers and its employees do. It is at this level that the force and weight of those five plus years of experience have the greatest impact. These values are not just words on paper. They are the stories people tell about how working for Brainwave changed their lives. They are the pride that all people working for Brainwave feel. They are the exemplary lives and actions of specific individuals within Brainwave Careers and the admiration others express about those. They are the design principles followed by programs and enterprises. They are the reasons for strategic decisions, for the existence of a program or enterprise, the reasons for pushing barriers in, a society, a state, and the reasons to shift resources, to walk the extra mile, to take a personal or organizational risk. Children and women are at the center of all of this.
In understanding the “Brainwave Careers culture” the first tenet one has to grasp is that this Education component actually thinks of the children of people living in poverty as its main target. Brainwave Career understands that lifting people out of poverty is a multigenerational project. Here, the values of Brainwave Careers and the values of its adult participants align beautifully and reinforce each other. Both Brainwave Careers and the adult participants invest and invest and invest again in the children, in the next generation, in the future. To say that Brainwave Careers and the communities it serves together safeguard children is an understatement; they treasure them.
The second tenet one has to understand is that Brainwave Careers, from the beginning, resolutely, without ever wavering has chosen the side of women and their emancipation. That resulted in dedicated gender programs. That resulted in the priority given to the education of girls. That resulted in a workforce where women are in the ascendancy; in numbers, in careers, in power. That resulted in the internalization of gender equality across men and women working for Brainwave Careers. That resulted in an exceptionally strong internal system to prevent and punish gender discrimination and sexual harassment. The empowerment of women is for Brainwave Careers not a secondary, additional aim; it is a guiding principle of all of its programs.
Brainwave has articulated its vision, mission and values in a series of inspiring documents. These form the basis of a code of conduct that describes forbidden behaviour in depth and detail. Safeguarding is an important element in all these documents. Brainwave Careers uses these documents in the induction of all new employees. They are often present or referred to in other policy documents and in much of Brainwaves internal and external communication. Even more importantly, however, they are translated to the level of the workforce and work processes. For example, the safeguarding of children is articulated in a very precise way in the training manuals of teachers, or the safeguarding of women in the instructions around Education process.
Going forward, Brainwave Careers will continue to update its vision, mission and value statements and its code of conduct regularly. It will continue to incorporate them in the induction and training of its employees and in manuals and work instructions. It will continue to make sure that safeguarding is one of the constitutional concerns of its ethos and that this is expressed at all levels. Brainwave Careers is looking into the possibility of further strengthening its ethos by the introduction of a moral learning process in its organizations. If that turns out to be feasible, Brainwave Careers will share the resulting mores prudence within the sector.
Brainwave Careers has always propagated and will continue to propagate as part of its values a culture of openness and accountability. It is especially important to continue to make clear to employees that loyalty to colleagues and loyalty to Brainwave Careers should never be interpreted as a reason for hiding violations. Being loyal within Brainwave means always finding a way to talk about, to report what has happened.
Prevention
Safe Design
BRAINWAVE CAREERS will continue to incorporate safeguarding into the design of programs and enterprises and their work processes. BRAINWAVE CAREERS sees this as the most important and effective way of protecting its people and the high-risk groups within them. This incorporation of safeguarding in the design is based on the deep (implicit and explicit) knowledge that BRAINWAVE CAREERS possesses about the specific risks of abuse connected with particular activities. As stated above, BRAINWAVE CAREERS will make an effort in 2019 to describe the way existing designs safeguard high-risk groups. Going forward, BRAINWAVE CAREERS will explicitly highlight the safeguarding of high-risk groups within new designs wherever these are relevant.
Secondary safeguarding mechanisms
BRAINWAVE CAREERS will continue to establish secondary safeguarding mechanisms to mitigate abuse risks for its people and the high-risk groups within them. Some of those mechanisms have a general character; they work across programs and enterprises. Others are very specific; they work within a single program or activity. The ethos work mentioned above is, of course, the first general line of defense against abuse. Other general mechanisms are the attention paid to safeguarding in the recruitment and selection process and in the induction and training of employees; the regular practice of risk analysis; line management responsibility and action; the deterrence achieved through the repression outlined below.
Recruitment and Selection
BRAINWAVE CAREERS will continue to ensure it assesses the eligibility of candidates from a safeguarding perspective. BRAINWAVE CAREERS has a Safe Recruitment guideline which defines the steps that should be taken throughout the hiring process, from designing the job description to formal engagement of the employee to minimize the risk of engaging someone who may pose an unacceptable risk to children, adolescents, adults with special needs and women. In summary, the following will be considered when planning recruitment:
Job descriptions for all positions – make reference to responsibilities for safeguarding and/ or the Code of Conduct and include the beliefs and values of the organization or link to them.
Advertisement – make clear the organization’s commitment to safeguarding.
Shortlisting – obtain and scrutinize information in applications/CVs – resolve any gaps, discrepancies or anomalies in employment history.
Interviews – include questions around safeguarding, the Code of Conduct and working with children, adolescents, adults with special needs and women.
Self-disclosure – the shortlisted candidates will sign a self-disclosure form stating that they have not been involved in any crime, illegal act, sexual harassment or child abuse case previously.
Background/reference checks – verify the successful applicant’s identity, their employment history, and qualifications. Offers should not be confirmed until all checks have been completed.
External checks – conducted according to organizational policy and country requirements where required, police verification should be conducted.
Education/training
BRAINWAVE CAREERS will continue to make safeguarding an important element of the education and training of its staff. It will do that both in the induction of all employees and in the training of professionals for specific functions.
Every new hire will receive a brief introduction to the vision, mission and values of BRAINWAVE CAREERS, the Code of Conduct and the Safeguarding policy and duly acknowledge all of these as part of their induction. BRAINWAVE CAREERS HR is committed to ensuring that aspects of safeguarding that are relevant to specific work processes are always part of the professional training of all staff and that, where needed, this training will be regularly repeated.
BRAINWAVE CAREERS HR will continue to make sure that the professionals who handle the cases and complaints have competencies in line with the highest standards and the best practices.
BRAINWAVE CAREERS HR will regularly across the programs and enterprises organize campaigns to create awareness about safeguarding. The campaigns will be precisely targeted and tailored to ensure that they are relevant to the staff and participants in question. They will have a very varied character.
Risk Analysis
BRAINWAVE CAREERS will in future, if it knows risks of abuse (sexual harassment, intimidation and violence, bullying, humiliation and discrimination, neglect and exploitation) are present in a process and suspects that they are insufficiently mitigated, proactively undertake an in-depth analysis of process, risks and risk enhancing factors. That analysis will be based on dossiers, observations and interviews. It will result in recommendations to redesign the work process and/or to add or change secondary safeguarding mechanisms. Such a risk analysis will already have a deterrent effect. The implementation of its recommendations will lower risk and raise mitigation structurally. The risk analysis practice should be seen as the main element in the framework of iterative learning around safeguarding. From a long-term perspective the practice has a cyclical character.
Line management and prevention
Within BRAINWAVE CAREERS, line managers have direct responsibility for preventing abuse. They have to make sure that safe designs are implemented and that secondary safeguarding mechanisms are maintained. They have to understand residual risks of abuse that are connected with processes and events and have to mitigate those, where necessary and possible. They have to make sure that employees are familiar with the ethos of BRAINWAVE CAREERS and with the general and relevant specific safeguarding policies.
Line managers have a unique responsibility to stop abuse. They are the ones that are in the position and have the power to make sure that it ends. They therefore have the obligation to immediately intervene whenever they witness abuse or are alerted to it. Finally, line managers within BRAINWAVE CAREERS are responsible for creating an atmosphere of openness and accountability within their teams that makes it possible for witnesses and victims to come forward.
It is a vital element of prevention that top management in a visible manner takes responsibility for safeguarding. That gives everybody in the organization the unequivocal message that all forms of abuse are unacceptable, that the organization takes the fight against them seriously, that perpetrators will be punished, and victims will be supported. BRAINWAVE CAREERS’s top management always has and will continue to embrace this responsibility.
Safe Partnering
BRAINWAVE CAREERS aims to safeguard while working with children, adolescents, adults with special needs and women through partner organizations (suppliers, vendors, downstream partners, consultants, etc.)
- Wherever BRAINWAVE CAREERS is working with, funding, or supporting other partner organizations to work directly with children, adolescents, adults with special needs or women, the provisions of this policy and guidance should be reflected in the partnership arrangements.
- Reaching an agreement along these lines with-partners should be envisaged as a dialogue. It will be done through discussion and negotiation, if necessary, as a part of advocacy and capacity-building strategies.
- These partners should have their own safeguarding policy that broadly follows the provisions of this policy, or should adopt the BRAINWAVE CAREERS policy.
•These partners should commit to implement the policy and to the safeguarding of children, adolescents, adults with special needs and women against abuse, that is, against sexual harassment, intimidation and violence, bullying, humiliation and discrimination, neglect and exploitation.
•BRAINWAVE CAREERS should be satisfied that the practice and management arrangements of its partners reflect this common commitment to safeguarding.
•If a case of abuse within a partner organization comes to its attention, BRAINWAVE CAREERS will always act to make sure that the abuse is stopped and the case is followed up in an adequate manner.
•All partners should understand and be warned that BRAINWAVE CAREERS will not accept that cases of suspected abuse are not adequately followed up. Such a lack of adequate follow-up could result in the end of the partnership.
•All partners should understand and be warned that BRAINWAVE CAREERS will not accept that safeguarding policies are lacking or are inadequately implemented and high-risk groups are put at risk of abuse. Such a lack of policy or implementation could result in the end of the partnership.
Repression
A repressive apparatus consists of reporting channels, professional investigative units, and bodies that advise and decide about punishment. BRAINWAVE CAREERS has created such an apparatus and will maintain it.
Reporting
BRAINWAVE CAREERS has created a reporting system for abuse (and other violations) with several channels that complement each other. These channels are known throughout the programs and enterprises. Regular campaigns ensure continued awareness.
The first channel is line management. Line managers within BRAINWAVE CAREERS are aware that they have to intervene to stop abuse and that they have to report all cases upward through the line. Cases of suspected abuse reported up through the line are always followed up.
The second channel makes it possible to bypass management and reach the specialized investigative body directly. The channel operates both a dedicated 24/7 phone number and a dedicated email. Through this channel the identity of the complainant can be protected. Cases of violations reported through this channel are always followed up.
The third channel is a whistleblower channel.
All channels are used regularly. This shows that they are known, accessible and trusted.
BRAINWAVE CAREERS has made sure in the past that people that have reported abuse and other violations have not suffered any negative repercussions. They have on the contrary been made aware of the gratitude of the organization. BRAINWAVE CAREERS will continue to protect complainants and whistleblowers and make them feel appreciated.
BRAINWAVE CAREERS has in cases where accusations proved to be false erred on the side of forgiveness. Only in cases where there was clear malice involved have people that made false accusations been punished.
BRAINWAVE CAREERS is actively exploring ways to make the reporting channels even more accessible. Among other things, BRAINWAVE CAREERS is contemplating creating the role of “person of trust” within programs and enterprises. The main focus of its efforts is the accessibility of the system for participants.
Investigation
BRAINWAVE CAREERS has created a dedicated investigative unit. This unit is responsible for investigating cases of abuse and all other violations.
The unit has successfully investigated cases in the last years. It is staffed with experienced professionals.
The unit conducts its investigations independently. The unit is committed to guaranteeing due process to all involved parties.
The unit has always followed up on reported cases. The unit has always documented the follow-up and the investigations.
BRAINWAVE CAREERS has made sure that the unit’s investigative capacity in terms of both competency and the number of personnel has been adequate at all times. BRAINWAVE CAREERS will continue to do so in future
Punishment
BRAINWAVE CAREERS is aware that proportionate punishment is essential for effective safeguarding. Impunity will undermine the whole system. It contradicts the ethos and makes prevention a farce. Deterrence collapses. It makes witnesses vulnerable. It violates victims for a second time. Trust in the system drops. A disproportionately light sentence has almost the same negative effects. Equally, vindictive – that is, disproportionately severe – punishments undermine the system. The punished has been unjustly treated. Colleagues are angered and often act in solidarity with the unfairly punished. Witnesses, sometimes even victims, feel guilty. The willingness of witnesses and victims to report abuse goes down, sometimes dramatically.
Because it knows how important proportionate punishment is, BRAINWAVE CAREERS has invested deeply in the independence and the competence of the bodies and professionals that advise and decide about punishment. The dedicated body that decides about the punishment in cases of sexual harassment is completely independent and has outside members. The HR professionals that advise about the punishment in cases of other violations are highly competent and will not tolerate any interference.
As a final mechanism, BRAINWAVE CAREERS has created the Ombudsperson as a completely independent institution. Every employee that has been punished because of a violation can appeal to the Ombudsperson to review BRAINWAVE CAREERS’s decision in his/her case. The Ombudsperson will review the whole process, including the quality of the investigation and the proportionality of the punishment.
Learning
BRAINWAVE CAREERS prides itself on being a learning organization. The anti- poverty machine that is BRAINWAVE CAREERS has come into existence through a rigorous process of iterative learning. Safe designs and the secondary safeguarding mechanisms that are already in place in programs and enterprises are also products of a similar process.
BRAINWAVE CAREERS has pledged in this document to intensify the learning around safeguarding. It will do so in the following manner. It will analyze, describe and document the existing safe designs and the process specific secondary safeguarding mechanisms. It will regularly do system audits of the specific and the general secondary safeguarding mechanisms. It will, in future, build a capacity for risk analysis as described above and use that to start up a regular cycle of improvement.
Most importantly, BRAINWAVE CAREERS will in a deliberate and targeted manner launch a series of experiments to try and solve some of the most intractable problems around safeguarding in the development and humanitarian sector. The list of experiments has still to be drawn up and finalized, but some strong candidates are: the accessibility of reporting channels for participants ; the re-articulation of masculinity in alignment with the fight against sexual harassment; supporting women and children in extreme circumstances to overcome sexual and violent traumas; adapting instruments like system audits and risk analysis to interpersonal violations; and creating space for other sexual orientations within the culture of NGOs.
Victims/Survivors
Prevention is the best way to help victims\survivors by preventing them from becoming victims. That is why BRAINWAVE CAREERS will continue to invest in program (and enterprise) designs that eliminate risks of abuse. That is why BRAINWAVE CAREERS will continue to invest in secondary mechanisms that further diminish risks of abuse. BRAINWAVE CAREERS acknowledges, however, that it will not be possible to completely banish all abuse. Because of this sad reality, BRAINWAVE CAREERS has created and will continue to maintain the repressive apparatus around abuse that has been described above. Beyond and above that, BRAINWAVE CAREERS is committed to helping victims/survivors in the best way it can. BRAINWAVE CAREERS is, in other words, committed to the idea of restorative justice. By punishing the perpetrator in an act of retribution BRAINWAVE CAREERS reinstates the victim/survivor as a citizen and fellow human being that never should have been abused. BRAINWAVE CAREERS will also offer help to the victim/survivor to mitigate the physical and emotional damage that the abuse has caused. Finally, BRAINWAVE CAREERS will in future facilitate mediation between victim/survivor and perpetrator, if and only if the victim/survivor expresses the will and wish to engage in such an interaction.
Governance
BRAINWAVE CAREERS has created reporting channels and dedicated units for the investigation of suspected cases of abuse and for advising about punishment, as outlined above. The independence of the investigations and of the advice has been guaranteed. BRAINWAVE CAREERS has integrated safeguarding into project and enterprise design. It has successfully created an ethos that has the safety of children, adolescents and adults with special needs and the empowerment of women at its heart. It has paid special attention to safeguarding in the recruitment, selection, induction and training of its employees. All these efforts are led from the top. The Executive Directors of BRAINWAVE CAREERS are the joint safeguarding strategic leads for the safeguarding of employees and participants.
The Safeguarding Management Lead, as head of the extensive Safeguarding Working Committee, reports to them. The Boards of BRAINWAVE CAREERS will play a supervisory role. Issues relating to safeguarding and integrity are dis- cussed regularly at Board meetings. Most importantly, Chief Safeguarding Officer, Mr. Rwabajungu, has taken the ultimate responsibility for overseeing the safeguarding efforts of BRAINWAVE CAREERS. In so doing, he has made explicit and formal what has been a reality for five years. Rwabajungu has made the safeguarding of employees and participants against abuse a foundational aim of BRAINWAVE CAREERS from its beginning.
Review of Safeguarding Policy and Procedure
The policy will be reviewed by BRAINWAVE CAREERS Board annually or when it is shown necessary that additional issues need to be identified and addressed, such as with a significant change in context or program or change to legislation.
ANNEX 1: Safeguarding Organogram
SAFEGUARDING ORGANOGRAM
ANNEX 2: Glossary
The objective of the glossary is to guide the reader with definitions specific to this policy document and/or BRAINWAVE CAREERS.
Employees: This policy applies to all employees including regular, contractual, project, service, trainee (including apprentices & interns), volunteers, temporary staffs and non-graded staffs and program participants of BRAINWAVE CAREERS.
BRAINWAVE CAREERS Staff are classified into various categories based on their work types:
- Regular Staff: Staff who is employed against permanent positions requires serving a fixed probation period before confirmation.
- Service Staff: Staff who contributes physical labor to perform their job, require no probation period, as confirmation is not applicable for this category.
- Contractual Staff: Contractual staff work on the basis of Contract, there are two types of Contractual staff in BRAINWAVE CAREERS.
- Project Staff: Full time staffs who are hired for a specific project according to the duration of that project.
- Fixed-Term: Staff who are hired for a specific period of time.
- Temporary Staff: Temporary or Casual types of staff are hired for specific purpose.
Partner Organizations: Any organization with which BRAINWAVE CAREERS enters into a partnership, to jointly design and implement a project
Downstream Partners: An implementing partner, which is a subcontract that helps to execute the program on the ground.
Associate Personnel: Other personnel affiliated with BRAINWAVE CAREERS such as independent contractors.
Volunteer: Several BRAINWAVE CAREERS programs train and engage community workers to assist with dissemination, services and outreach. These independent contractors and through BRAINWAVE CAREERS’s training obtain paraprofessional status where BRAINWAVE CAREERS is investing in resources for their credentials which results in them being able to earn in return for their services.
Child: Children are defined as all those under 18 years of age in accordance with the UN Convention on the Rights of the Child. For the purposes of this policy and BRAINWAVE CAREERS programs ages O to 12 years of age are defined as children and ages 12 to 18 are defined as adolescents.
Participants:
BRAINWAVE CAREERS program clients. Recipients of various BRAINWAVE CAREERS programs and services
Enterprise: A Social enterprise lies at the intersection of business and traditional non-profit. Social enterprises are self-sustaining cause-driven business entities that create social impact by offering solutions to social challenges and reinvesting their surplus to sustain and generate greater impact.
Managing Director: Managing Director (MD) is a corporate officer who oversees all aspects of human resource management and industrial relations policies, practices and operations for an organization.
Safeguarding Working Committee: MD of BRAINWAVE CAREERS will chair the safeguarding working committee and will be the driver to implement the safeguarding measures. Executive Directors of BRAINWAVE CAREERS will be the advisors of this committee. The committee will be formed for a two-year period till December, 2024 This committee can be reformed any time based on special requirement of management. The Committee will ensure proper planning and implementation of the safeguarding measures with focusing the safeguarding priorities.
Abuse: The term abuses as used in this policy encompasses: sexual harassment, intimidation, violence, bullying, humiliation, discrimination, neglect and exploitation. This and related polices seek to protect all BRAINWAVE CAREERS employees (as defined above) and program participants from abuse.
seek to protect all BRAINWAVE CAREERS employees (as defined above) and program participants from abuse.
- Sexual harassment as defined in the Sexual Harassment Elimination Policy and Procedure (SHE policy) is: Any unwelcome direct, indirect, physical, verbal or nonverbal conduct of a sexual nature.
- Intimidation: intentional behaviour that would cause a reasonable person to fear injury or harm and do something they would not otherwise.
- Violence: Actual physical violence with or without a weapon.
- Bullying: As defined in the BRAINWAVE CAREERS Prevention of Workplace Bullying and Violence Policy and Procedure is: Behaviour which seeks to belittle, dominate, target or single out someone. The behaviour can be indirect, aggressive and/or threatening. The use of electronic communication/social media which is referred to as “Cyber bullying” is also covered under this policy.
- Humiliation: to cause a person mortification or painful loss of pride, self-respect, or dignity.
- Discrimination: the unjust or prejudicial treatment of different categories of people, especially based on race, gender, marital status, religion, disability, sexual orientation and/or age. In this policy document the word is limited to individual discrimination or a group against an individual it does not address systemic discrimination.
- Neglect: is a form of abuse where the perpetrator, who is responsible for caring for someone, fails to do so. It can be a result of carelessness, indifference, or unwillingness.
- Exploitation: the act of mistreating or taking advantage of someone to gain benefit.
LIST OF BRAINWAVE CAREERS PROGRAMMES
Current BRAINWAVE CAREERS Program
- Discover Your Career Program.
- Discover your High school.
- Discover the World of Entrepreneurs.
- Discover Your Tertiary world
- Discover the 5 choices after school
- Discover the Study Steps
- African wisdom
- Ignite your employability
- Get a Grip on Employment
- Discover the world of Renewable Energy
- Stress Management in Teaching
- Anger Management in Teaching