Safeguarding Policy 2025

ARI works with adolescents, young people, teenage mothers, survivors of gender-based violence, and the broader communities around them. Many of the people we serve are children under Kenyan law^[1], and most are in vulnerable circumstances. This policy sets out our commitment to keeping every person we engage with safe from harm caused, witnessed, or enabled by our work, and to creating a working environment in which our staff, volunteers and partners can raise concerns without fear.

This policy applies to:

• All ARI paid staff.
• All ARI volunteers, peer educators, and rapid-response responders.
• All ARI interns, secondees, and short-term contractors.
• Members of the ARI governance committee, including independent members.
• Partner organisations and individuals operating in ARI's name or under a joint MoU.
• Visitors to ARI activities and ARI premises.

The policy is binding 24 hours a day in every setting, the office, the field, online, social events linked to ARI, and any setting in which a reasonable person would associate the individual with ARI.

1. The best interests of the child are the primary consideration in any decision affecting a child^[1].
2. Survivor-centred care. The rights, needs and wishes of a survivor are the primary consideration in any response to a disclosure or concern^[2].
3. Do no harm. Where ARI cannot improve a situation, it must not worsen it.
4. Confidentiality and informed consent govern all data, all referrals, and all storytelling, including in our published reports.
5. Zero tolerance of sexual exploitation, abuse, or harassment by anyone in ARI's name^[3].
6. Equity and non-discrimination. No participant, staff member or volunteer is treated less favourably on the basis of sex, gender identity, sexual orientation, age, disability, ethnicity, religion or migration status.
7. Transparency. This policy is published. The number and type of safeguarding concerns recorded each year are published in the annual report^[4].

Child

Any person under the age of 18, in line with the Children Act 2022.

Safeguarding

The set of measures an organisation takes to prevent harm to participants, staff and communities arising from its operations.

Sexual exploitation

Any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes.

Sexual abuse

The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual harassment

Any unwelcome verbal, non-verbal or physical conduct of a sexual nature.

Bullying

Persistent, unwanted aggressive behaviour involving a real or perceived power imbalance.

Disclosure

Any communication, verbal, written, behavioural, that suggests a person has experienced or is at risk of harm.

Survivor

A person who has experienced gender-based violence, including sexual violence. ARI uses 'survivor' rather than 'victim' as the default term, while respecting any individual's preference.

Mandatory reporter

Any person required by law to report suspected child abuse, in Kenya, this includes health workers, teachers, and social workers.

Every person within scope of this policy is expected to:

• Treat every person we work with with dignity and respect.
• Maintain professional boundaries at all times, including outside working hours.
• Use plain, age-appropriate language. Check that you have been understood.
• Obtain and document informed consent for any data collection, photograph, story, or external communication.
• Refer concerns up promptly. If you are unsure whether something counts, report it. The safeguarding lead will decide what counts.
• Stay within your competence. If a situation requires clinical, legal, or psychological skills you do not have, refer.
• Disclose conflicts of interest, including dual relationships with participants (e.g. a participant who is also a relative or neighbour).
• Respect the confidentiality of every disclosure, every case, and every record. Do not discuss cases in public spaces, including online.

• Any sexual activity with a child (any person under 18)^[5].
• Any sexual activity with a participant in an ARI programme, regardless of age, while the relationship of programme contact exists.
• Exchange of money, employment, goods, services, or programme benefits for sex^[3].
• Sexual harassment in any form, in any setting.
• Physical punishment, humiliation, or any form of degrading treatment.
• Photographing, filming, or recording a participant, including a child, without documented informed consent.
• Sharing identifying information about a participant outside the secure case-handling system.
• Lone unsupervised contact with a child in a private space, except where clinical or protective necessity requires it and is documented.
• Working under the influence of alcohol or non-prescribed drugs.
• Retaliation against any person who raises a safeguarding concern.

ARI's recruitment process incorporates safeguarding at every stage. This applies to paid staff, volunteers, peer educators, and members of the governance committee.

Anyone, staff, volunteer, partner, participant, member of the public, can raise a safeguarding concern. The pathway below is designed to be simple, accessible, and to put control in the hands of the person reporting.

Where a concern relates to a participant who has experienced harm, ARI's first responsibility is to the survivor, in line with WHO clinical guidelines^[2], the WHO guidance for child survivors^[6], the UNFPA/WHO Essential Services Package^[7], and Kenya's National Guidelines on Management of Sexual Violence^[8].

• The survivor's stated wishes guide every step, except where mandatory reporting law overrides.
• Clinical care (including PEP within 72 hours where relevant) is the first priority.
• Psychosocial first aid is offered at the first contact by a trained provider.
• Onward referrals (shelter, paralegal, ODPP) are offered, never imposed.
• No identifying information is shared without informed consent, except where law or safety overrides.

ARI complies with the Data Protection Act, 2019^[9]. We collect the minimum personal data needed to deliver our services. We hold case-specific data in a secure, role-restricted system. We do not share identifying data outside ARI without informed consent, except where law or immediate safety requires.

• Case files are accessible only to the safeguarding lead, the assigned case officer, and (where required) the independent investigator.
• Composite case studies in published documents are anonymised. Identifying details (name, age, ward, date) are changed.
• Photographs require documented informed consent; consent for a child is given by parent/guardian and assented to by the child.
• Data is retained for the period required by law and our donor agreements, then securely deleted.
• Data subjects have the right of access, correction and (where applicable) erasure, in line with the 2019 Act.

ARI partners, schools, health facilities, civil society organisations, contractors, are within scope of this policy when operating in ARI's name or under a joint MoU. Every partnership MoU includes a safeguarding clause that:

• References this policy as the binding standard for joint activity.
• Names a safeguarding focal point on each side.
• Requires reporting of any concern to both organisations.
• Provides for joint review of any concern arising from joint activity.
• Reserves ARI's right to suspend or end the partnership where concerns are not handled in line with this policy.

A material share of ARI's work is online, peer education groups, follow-up messaging, public communications, donor reporting. The same standards apply.

• Staff and volunteers do not connect with participants on personal social media accounts. Designated programme accounts are used.
• Direct messages with a participant who is a child must be in a group with at least one other adult ARI representative or with the participant's guardian where appropriate.
• Identifying details about cases are not discussed in any group chat that is not the secure case-handling system.
• Public communications use only consented imagery and stories. Composite case studies are flagged as such.
• Any concern arising online is reported through the same pathway as offline concerns (Section 8).

A person who raises a safeguarding concern in good faith, or who participates in an investigation in good faith, will not be subjected to any form of retaliation. This protection extends to staff, volunteers, partners, participants, and members of the public. Retaliation against a person reporting in good faith is itself a breach of this policy and will be investigated and acted on accordingly.

The bravery of speaking up is not a thing we are entitled to take for granted. Our job is to make speaking up the easiest option, not the hardest.

This policy is reviewed annually by the ARI governance committee. The review considers: the year's safeguarding log, the outcomes of any investigations, any changes in the legal environment, any partner feedback, and any changes in ARI's programme footprint. Material changes are published as a new version. Aggregate safeguarding statistics are published in the ARI annual report each year^[4].

ARI

Afya Rights Initiative.

Children Act 2022

Kenya's primary statute on the rights and protection of children.

Code

ARI's behavioural code, set out in §5 and §6 of this policy.

DPA

Data Protection Act, 2019 (Kenya).

GBV

Gender-Based Violence.

IASC PSEA

Inter-Agency Standing Committee Six Core Principles Relating to Sexual Exploitation and Abuse.

Mandatory reporter

A person required by Kenyan law to report suspected child abuse.

MoU

Memorandum of Understanding.

ODPP

Office of the Director of Public Prosecutions.

PEP

Post-Exposure Prophylaxis.

Safeguarding lead

ARI's designated senior person responsible for safeguarding implementation.

Survivor

A person who has experienced gender-based violence.