Airlink, Inc.

Child Safeguarding Policy

Mission

Airlink, Inc. (the “Company” or “Airlink”) is a rapid-response humanitarian relief organization that links pre-qualified nonprofits with airlines to help communities in crisis worldwide.  Since its founding in 2010, the Company has transported thousands of aid workers and millions of pounds of cargo by air.

Introduction

Airlink requires its directors, officers, employees, volunteers, and external partners to adhere to the highest standards of accountability and professionalism, which requires honest, ethical, respectful, and nonexploitative conduct.

This policy states Airlink’s expectations regarding the manner in which all persons working for and with the Company interact with beneficiaries, including express conduct that is prohibited. It also states the processes and procedures Airlink will maintain to ensure all parties uphold these standards and how misconduct is identified, reported, and addressed in an appropriate and timely manner.

Scope of Applicability

This policy applies to all persons working for Airlink, or on behalf of the Company in any capacity, including employees at all levels, directors, officers, seconded workers, volunteers, interns, and contractors (collectively “Team Members”), as well as vendors, NGO partners, and private sector partners (collectively “Partners”). It applies during and outside of working hours, every day of the year, at both the headquarters and project levels. Should this policy demand a higher standard than the local laws then this policy will prevail. All staff and representatives named above can raise a complaint via the procedures outlined in this policy.

In the context of Airlink’s work, it is necessary to consider that, as an NGO-to-NGO service provider, we seldom work directly or indirectly with communities affected by disasters. However, Airlink works with a wide range of actors who have both direct and indirect contact with vulnerable populations, and from time to time, Team Members may visit Partners onsite where they are running a program.

 1.    Definitions: What is Child Abuse?

1.1.      Safeguarding: To take all reasonable steps to prevent harm, particularly sexual exploitation, abuse, and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur

1.2.      Child: A person under the age of 18 years of age, in accordance with the definition of a child in Article 1 of the United Nations Convention on the Rights of the Child, 1989.

1.3.      Abuse: Includes a range of behavior from physical abuse, emotional ill-treatment, sexual abuse, neglect or insufficient supervision, and trafficking to commercial, transactional, labor, or other exploitation resulting in actual or potential harm to the child’s health, wellbeing, survival, development, or dignity. It includes, but is not limited to, any act or failure to act which results in death, serious physical or emotional harm to a child, or an act or failure to act which presents an imminent risk of serious harm to a child. It also includes attempted abuse.

1.3.1.      Sexual Abuse: The involvement of a child in sexual activities, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). Adult males do not solely perpetrate sexual abuse. Women can also commit acts of sexual abuse, as can other children.

1.3.2.      Physical abuse: The non-accidental use of physical force that deliberately or inadvertently causes a risk of/or actual injury to a child. This may include hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing non-accidental physical harm to a child. Physical harm can also be caused when a parent or caregiver fabricates the symptoms of, or deliberately induces, illness or temporary, permanent injury or disability of a child.

1.3.3.      Emotional abuse: Involves doing harm to a child’s emotional, intellectual, mental, or psychological development. This may occur as an isolated event or on an ongoing basis. Emotional abuse includes but is not limited to any humiliating or degrading treatment (e.g. bad name-calling, threats, yelling/screaming/cursing, teasing, constant criticism, belittling, persistent shaming, etc.), failure to meet a child’s emotional needs, and rejecting, ignoring, terrorizing, isolating or confining a child.

1.4.      Neglect: Allowing for context, resources, and circumstances, neglect refers to a persistent failure to meet a child’s basic physical and/or psychological needs that is likely to result in serious impairment of a child’s healthy physical, emotional, and mental development. It can include failures to supervise, protect from known harms, or provide adequate nutrition, shelter, or safe working/living conditions. It can also include acting in ways that may put a child at risk for exploitation or abuse.

1.5.      Exploitation: An umbrella term used to describe the abuse of children who are forced, tricked, coerced, or trafficked into exploitative activities. For Airlink, child exploitation includes modern slavery and trafficking of children and children forced or recruited into armed conflict. Child sexual exploitation is a form of child sexual abuse. It occurs when an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity; (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur with the use of technology.

1.6.      Airlink’s Child Safeguarding Policy seeks to prevent and robustly respond to all forms of exploitation and abuse and any other harms carried out by Team Members and Partners towards any child we come into contact with through our work. Airlink recognizes the ways in which various forms of sexual violence and abuse of power intersect; our policies which distinguish between abusive behaviors carried out between Team Members (addressed through our Anti-Harassment Policy), abusive behaviors carried out towards children (addressed through this policy), and abusive behaviors carried out towards adult beneficiaries (addressed through our Policy on the Protection from Sexual Exploitation and Abuse (PSEA)).

2.         Policy Statements and Standards of Conduct

2.1.      Consistent with the Company’s mission, Airlink expects all of its Team Members and Partners to treat all beneficiaries, particularly children, with respect and dignity and to always act in the best interests of their physical and emotional well-being, and never engage in conduct that could be perceived as abusive or exploitative.

2.2.      Airlink expects its Team Members and Partners to constantly look out for the best interests of people affected by emergencies, especially the children with whom they work, to identify and minimize the risk of harm, abuse, or exploitation by others, and to report and ensure follow-up any time a Team Member or Partner has reason to believe that a child beneficiary is being harmed, abused, or exploited by an Airlink Team Member or Partner.

2.3.      Consistent with these principles, Airlink has zero tolerance for and abhors conduct towards children that is exploitative or abusive. This includes conduct or attempted conduct that is or could reasonably be perceived as abusive, including all definitions described in this policy.

2.4.      Airlink expects and requires that Team Members who are aware of specific facts that would lead them to suspect that another Airlink Team Member or Partner is engaged in child abuse or exploitation to report such behavior.

2.5.      Persons who make good faith reports of suspected abuse or exploitation of children carried out by Airlink Team Members or Partners will not be retaliated against for their reporting even if later the allegations prove unfounded.  Knowingly making false reports can, however, be grounds for disciplinary action.

2.6.      Violations of this Policy by Team Members can be grounds for disciplinary action, up to and including termination. For alleged abuse that may also constitute criminal conduct, the accused person may also be subject to criminal prosecution. Mistaken belief in the age of a child is not a defense.

2.7.      Airlink provides a means for reports of child abuse and exploitation to be surfaced, including through anonymous reporting, and ensures that all reports of child abuse or exploitation by Airlink Team Members or Partners are independently reviewed and, if they appear potentially credible, fully investigated by trained professional investigators, and reported to donors in accordance with donor requirements.

2.7.1.      Any individual who believes that a violation of this policy has occurred, whether by a supervisor, manager, coworker, subordinate, or another person, should immediately inform the Administrative Operations Manager, the CEO, or the Chair of the Board.

2.7.2.      All reports will be referred to the CEO, the Chair of the Board, or, as appropriate, to the Company’s legal counsel, for investigation, review, or other appropriate action.

2.7.3.      The Administrative Operations Manager or such other individual deemed appropriate by the CEO or Chair of the Board will conduct a prompt, thorough investigation of the report to determine what has happened. All facts concerning any report (including the identities of the complaining party, the person alleged to have violated this policy, and other witnesses) will be kept confidential from anyone who does not have a legitimate reason to know about them, subject to management’s need to investigate and take appropriate remedial measures.

2.7.4.      If the Company concludes that its Child Safeguarding policy has been violated, it will take prompt corrective action reasonably designed to end the violation and prevent any further violations from occurring. Such corrective action may include disciplinary action against anyone found to have violated this policy, up to and including immediate termination of employment.

2.7.5.      All reports are confidentially, independently, and thoroughly investigated by a third-party investigator trained in how to conduct investigations into child abuse or exploitation and in a manner that ensures, to the extent possible, the protection of the child.

2.8.      This policy is intended to ensure compliance with all laws, regulations, and donor requirements, including the international standards in the UN Convention on the Rights of the Child. Should any law or donor requirement exceed the requirements in this policy, the donor or legal requirement will prevail.

3.         Policy Administration

3.1.      Airlink’s Administrative Operations Manager is responsible for ensuring that child-safe recruiting processes are in place and that all Team Members undergo the code of conduct training and sign the certification.

3.2.      Airlink’s Administrative Operations Manager and the Director of Humanitarian Programs are responsible for leading a review of this policy every two years to ensure adherence to best practices in child safeguarding. Recommendations for revisions will be submitted to the Governance Committee for approval.

3.3.      Airlink ensures compliance with this policy with regard to staffing through the following actions as implemented through appropriate processes and procedures.

3.3.1.      All potential new Team Members undergo child-safe screening before they are hired.

3.3.2.      All Team Members are informed and trained on what conduct this policy requires (via code of conduct training) and their responsibilities under this Policy, including what is child abuse and how to report it, and all Team Members certify that they have understood this policy and agree to abide by it.

3.4.      Airlink ensures its Partners are in compliance with this policy through the following actions.

3.4.1.      Where appropriate and when in direct contact with children, Partners are informed of the requirements of this Policy.

3.4.2.      Contractual agreements or memoranda of understanding with Partners include obligations to adhere to this Policy and any additional donor-required provisions relating to child safeguarding, and Partners have the capacity to ensure their compliance with this policy, including, if necessary, training for Partners and additional monitoring.

3.5.      Airlink ensures its communications materials and activities comply with this Policy through the following actions.

3.5.1.      Images, interviews, and videos of children obtained by Airlink or its Partners are only taken after understanding their potential impact on the safety, dignity, and well-being of children, and in a manner that ensures respect for children, including respect for their privacy, and in compliance with applicable laws.

3.5.2.      Identifiable images and stories of children are only obtained and used by Airlink or its Partners after receiving informed consent from their parents/guardians provided in writing, when possible, and after they are informed of how their images or story will be used. For children over 14 years of age, in addition to parental/guardian consent, informed consent will be obtained directly from the child, in writing, when possible. Identifying information of children beneficiaries will not be disclosed without their and their parent/guardian’s written permission unless the sole reason for such disclosure is the well-being or protection of the child. Personal information communicated to Airlink will be stored in an appropriately secure manner.

3.6.      Airlink computers, cameras, telephones, video recorders, or network systems may not be used to view or share sexually explicit images of children.

3.7.      Team Members, Partners, beneficiaries (including children, where applicable) and communities can anonymously (if they choose) report all forms of child abuse or exploitation by Airlink Team Members or Partners, and all such reports will be promptly investigated by the Administrative Operations Manager and referred to others as described herein.

3.8.      All reports will be disclosed to donors as and when the donor requires, to the extent permissible by law. Any reports that include allegations of criminal misconduct will be disclosed to law enforcement.

3.9.      Any Team Member or Partner accused of child abuse or exploitation is, at a minimum, removed from access to children until the investigation determines that they do not pose a threat.

4.         NGO Partner Commitment

4.1.      Airlink expects its Partners to follow the standards described in this Policy, including taking measures to prohibit their staff and representatives from engaging in any child exploitation or abuse.

4.2.      Partners must have a zero-tolerance policy on child abuse and exploitation and take all measures available to them to prevent and respond to actual, attempted, or threatened forms of child abuse and exploitation in the course of their own operations.

4.3.      Partners must immediately report any suspicion of child abuse or exploitation occurring within Airlink-supported programs. Failure to report will be treated as serious and may result in termination of any agreement with Airlink or discontinuation of support from Airlink.

EMPLOYEE RECEIPT AND ACKNOWLEDGEMENT OF CHILD SAFEGUARDING POLICY

I have read and understand the Airlink Inc. Child Safeguarding Policy. My signature below confirms my knowledge, acceptance, and agreement to comply with the policy.

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Employee’s Signature

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Printed Name

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Date Signed by Employee

TO BE PLACED IN EMPLOYEE’S PERSONNEL FILE