Policy on Prevention of Sexual Exploitation and Abuse

Farmers Helping Farmers Policy on Prevention of Sexual Exploitation and Abuse
Update, May 12, 2020


Farmers Helping Farmers (FHF) is committed to the economic empowerment and wellbeing of Kenyan farm families, reducing their vulnerability to exploitation and abuse. FHF recognizes that our work often puts our staff and volunteers in positions of power in relation to the communities we work with, especially vulnerable adults and children. Our capacity to help Kenyan farm families improve their livelihood depends on our ability to uphold and promote high standards of ethical and professional conduct. FHF staff and volunteers have an obligation to use their power respectfully and must not abuse the power and influence they have over the lives and well-being of the participants of FHF projects and others in the communities where FHF works. This policy sets out definitions, expectations, principles, and commitments to support FHF staff and volunteers to uphold and safeguard the necessary standards of conduct and to avoid sexual exploitation and abuse of the individuals with whom we work.


Child: A child is any individual under the age of 18, irrespective of local country definitions of when a child reaches adulthood.

Child Sexual Abuse: Child sexual abuse is the involvement of a child in sexual activity that s/he does not fully comprehend, give informed consent to, or for which s/he is not developmentally prepared and cannot give consent, or that violates the laws or social taboos of society. It is evidenced by an activity between a child and an adult or another child who by age or development is in a relationship of responsibility, trust or power, the activity being intended to gratify or satisfy the needs of the other person. It may include, but is not limited to, the inducement or coercion of a child to engage in any unlawful sexual activity, the exploitative use of a child in prostitution or other lawful sexual practices or the exploitative use of pornographic performances and materials.

FHF Employees and Related Personnel: The term “FHF Employees and Related Personnel” includes all employees of Farmers Helping Farmers, members of the Board of Directors and of Board committees, and FHF volunteers.

Sexual Exploitation: Sexual exploitation means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.
Sexual Abuse: Sexual abuse means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Vulnerable Adult: Vulnerable adults are defined as those aged over 18 years and who identify themselves as unable to take care of themselves/ protect themselves from harm or exploitation; or
those who, due to their gender, mental or physical health, disability, ethnicity, religious identity, sexual orientation, economic or social status, or as a result of disasters and conflicts, are deemed to be at risk.


This policy will be guided by the following principles:
All volunteers, workers and members of the public will be treated with respect at all times.
Occasions of reported harassment will be dealt with in a timely, confidential and effective manner.
All persons will have their rights to a fair process and their confidentiality respected during mediation or harassment investigation.
All persons will be protected against retaliation for reporting harassment or cooperating with a harassment investigation.


This policy is focused on preventing sexual exploitation and abuse of the Kenyan families and individuals with whom we work. It will form a core element of a broader code of conduct, currently in development, which will aim to prevent all types of exploitation, abuse and harassment, both within FHF and between FHF personnel and partners, contractors, and target populations.


This policy applies to FHF Employees and Related Personnel as defined above.

Policy Statement

Farmers Helping Farmers (FHF) has zero tolerance toward sexual exploitation and abuse of the Kenyan people with whom it works. Specifically:
Sexual exploitation and abuse and child abuse by FHF Employees and Related Personnel constitute acts of gross misconduct and are therefore grounds for termination of employment.

Sexual activity with children (persons under the age of 18) is prohibited regardless of the age of the majority or age of consent locally. Mistaken belief in the age of the child is not a defence.

Exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour by FHF Employees and Related Personnel is prohibited. This includes the exchange of assistance that is due to programme participants.

Sexual relationships between FHF Employees and Related Personnel and programme participants are strongly discouraged since they are based on inherently unequal power dynamics. Such relationships undermine the credibility and integrity of FHF’s international development work.

Where an FHF Employee or Related Personnel develops concerns or suspicions regarding sexual abuse or exploitation and child abuse by a fellow worker, whether in FHF or not, he or she must immediately report such concerns via the reporting mechanisms pursuant to this policy.

FHF Employees and Related Personnel are required to create and maintain an environment that prevents sexual exploitation and abuse and child abuse and promotes the implementation of this Policy.


To ensure the effective implementation of this PSEA policy, the following responsibilities exist:
Organization: FHF, as represented by its Board of Directors and supported by its Coordinator, is responsible to:

-devote adequate attention and resources to the implementation and operation of this policy;

-ensure the provision of information, education, screening and training of staff, volunteers, partners, and contractors;

-maintain confidentiality about concerns and allegations arising from this policy;

-render timely, appropriate responses and take actions as may be required in accordance with the reporting and complaints investigation process outlined below;

-assess risk, and plan FHF projects to reduce risk; and

-review this policy on a regular basis and refresh it as required.

Kenyan Coordinator: As set out below in the sections on engagement and on complaints procedure, FHF’s Kenyan Coordinator, Jennifer Murogocho, is responsible to:

-inform the partners with whom FHF works of the policy;

-receive and investigate complaints in a fair, balanced and confidential way; and

-ensure that complainants are supported and protected from reprisals.

Employees and Related Personnel: FHF staff and volunteers are responsible to:

-become familiar with the contents of this policy and apply it to their conduct in the field;
-in the course of their duties, strive to work safely in the field, working outdoors and working with colleagues or in groups wherever feasible;
report concerns about exploitation and abuse that they may identify in the course of their work; and
-contribute to FHF efforts to improve and refresh this policy.

Selection and Employment of Staff and Volunteers

Farmers Helping Farmers is committed to recruitment, screening, selection and orientation practices that support this policy and that recruit the safest and most suitable people to work in our projects.

For staff working in Kenya and volunteers travelling to Kenya, those practices include:
-promoting our commitment to PSEA on our website and in our recruitment processes;
-establishing job descriptions for all positions, both paid and volunteer, which outline tasks and accountabilities, and include key selection criteria
appending this policy to the terms and conditions of employment / volunteer engagement;
-requiring applicants to provide information on their past employment and/or volunteer involvement;
-requiring references, and, in future, criminal background checks;
providing detailed orientation on this policy to all staff and volunteers upon selection.

Engaging Communities and Partners

To be effective, the policy and procedures must be known to the communities, families, and individuals with whom FHF works. Recognizing the cultural sensitivity of these issues in Kenya, the following processes will be used to make the policy known to project participants:

FHF leaders will communicate the policy to FHF staff and volunteers, and provide orientation and training.

In recognition of her standing in the community, her close relationship with FHF’s Kenyan partners (women’s groups, dairy co-ops and schools), and her age and gender, the Kenyan Coordinator will be responsible to liaise with the leaders of the women’s groups to communicate and explain the policy.

With regard to the dairy co-ops, having mixed gender membership, the Kenyan Coordinator will communicate the policy to the Executives of the dairy co-ops, and request that they inform their members. The Kenyan Coordinator will assist in this if requested.

With regard to school gardeners, their pay is funded by FHF, and they report to the school administration, which is responsible for supervision and addressing any concerns about the conduct of the gardeners. A clause regarding FHF’s PSEA policy has been added to the agreements with the schools.

Procedures for Reporting and Investigation of Complaints

The following procedure will be used to receive and investigate complaints by individuals participating in FHF projects in Kenya regarding sexual exploitation or abuse by FHF staff or volunteers:

Concerns by individuals will be reported to the leadership of their respective organizations (women’s group chair dairy group chair, school administrator, or their designated representative for the purposes of this policy).

The chair or representative will advise the Kenyan Coordinator of the complaint.

The Kenyan Coordinator will meet with the complainant, and with other members of the partner organization and/or community as may be appropriate, and gather as much information about the alleged incident as possible. While being responsive to the concerns of the complainant and supportive, the Kenyan Coordinator should also explore the context of the interactions and relationship with the FHF staff or volunteer, with a view to identifying whether there might be other factors or issues influencing the complaint.

Where the complaint involves a Kenyan employee of FHF:
the Kenyan Coordinator will have a conversation with the staff member and gather information from their perspective. The staff member may request an additional person be present, such as another community leader.

The Kenyan Coordinator will prepare a report to the Board of FHF, with input from the second interviewer if applicable, describing the incident and setting out initial findings and advice.

The Board of FHF will refer the matter to a PSEA Committee comprised of at least three past chairs of FHF, for review.

The PSEA Committee will be responsible to review the matter and make recommendations to the FHF Board.

The FHF Board will reach an initial decision and communicate it to the Kenyan Coordinator.

The Kenyan Coordinator will prepare a “show cause” letter and provide the letter to the staff person. The letter will set out the issue, the findings, and the initial response from FHF, and will request a response from the staff person.

The staff person will respond in writing with their reasons why the proposed disciplinary action should not occur or should be modified.

The show cause letter and the response will be provided to FHF for a final decision, and for implementation of the actions.

Where the matter involves an FHF volunteer:

The Kenyan Coordinator will provide the Board of FHF with the information gathered from the complainant.
The PSEA Committee will designate one or more of its members to speak to the volunteer and gather information.
The PSEA Committee will review the information and make recommendations to the FHF Board.
The Board will make a decision, communicate it to the Kenyan Coordinator, and implement any measures.


FHF employees and related personnel who are found to have been in breach of this policy based on the process outlined above will be subject to disciplinary measures. Depending on the severity of the infraction, measures may include the following:
Reprimand, training, and apology by the staff / volunteer;
Suspensions of varying duration, training, and apology; or
Dismissal of employee / termination of relationship with volunteer and placement of concerns on file.
Where applicable, infractions will also be referred to the criminal justice system locally and/or in the abuser’s country of origin.

Approved by the Farmers Helping Farmers Board of Directors: 12/05/2020