AEI Code of Conduct and Safeguarding Policy

  1. Bylaws

AEIwill continually strive to ensure that all its administrative and organizational processes are carried out in accordance with the bylaws and that all decisions in the organization are taken objectively and free of personal interest.

All staff and members of AEI have an obligation for putting the bylaws’ principles into practice and for reporting any breaches they discover.

  1. Gender equality policy

AEI has the following objectives with regard to its gender equality policy:

  • AEI integrates gender-based analyses, objectives, strategies and measures into planning, policies, communications, and management
  • AEI conducts effective awareness raising and capacity building among staff and volunteers on the base of gender equality
  • Staff are able to apply a gender analysis, defining specific gender objectives and providing sex disaggregated data
  • Programs incorporate gender into annual and three-year development plans; at least half of all projects directly address gender needs
  • There exists a gender balance within staff, management team, and advisory board
  • AEI is perceived as gender-sensitive by staff, partners, constituencies and the public at large.

According to AEI, gender equality refers to equal rights, responsibilities and opportunities of women/girls and men/boys. Gender equality is an issue that sometimes requires a special focus on the needs of men and boys. It is important for AEI to look at people’s needs from the perspective of both women and men.

  1. Anti-Fraud Policy

AEI will continually strive to ensure that all its financial processes are carried out and reported honestly, accurately, transparently and accountably and that all financial decisions are taken objectively and free of personal interest.

All members of AEI have a responsibility for putting these principles into practice and for reporting any breaches they discover.

The management team is responsible for establishing and maintaining a sound system of internal control that supports the achievement of AEI’s policies, aims and objectives. 

AEI fosters honesty and integrity in its entire staff. Director, co-presidents, staff and volunteers are expected to lead by example in adhering to policies, procedures and practices.

The management team is expected to deal promptly, firmly and fairly with suspicions and allegations of fraud or corrupt practices.

Every member of staff is responsible for:

  • Acting with propriety in the use of AEI’s resources and the handling and use of funds whether they are involved with cash, receipts, payments or dealing with suppliers
  • Conducting themselves with selflessness, integrity, objectivity, accountability, openness, honesty and leadership
  • Being alert to the possibility that unusual events or transactions could be indicators of fraud
  • Alerting the director and co-presidents when they believe the opportunity for fraud exists e.g. because of poor procedures or lack of effective oversight
  • Reporting details immediately if they suspect that a fraud has been committed or see any suspicious acts or events
  • Cooperating fully with whoever is conducting internal checks or reviews or fraud investigations.
  1. Child protection policy

As a community education organization working with children inside and outside schools in the West Bank, AEI is committed to and encourages respect for human rights and dignity. AEI believes that every child who participates in AEI’s activities has the right to enjoy a safe environment and be protected from harm. In line with the United Nations Convention on the Rights of the Child, which states that all children have a right to protection, AEI believes that it has a duty of care and obligation to protect those children for whom it has responsibility. We believe that the welfare of children is the highest priority and that it is the responsibility of everyone in AEI to ensure that they are protected.

The following child protection policy sets out AEI’s commitment to child protection and aims to promote good practice in:

  • providing children with appropriate safety and protection while in AEI’s care
  • allowing all volunteers and staff to make informed and confident responses to specific child protection issues.
  1. Definitions

Child: anyone under the age of 18 (in line with the UN Convention on the Rights of the Child).

Adult: anyone aged 18+.

Participant: every person who attends an AEI program, and who is not in a position of program responsibility.

Child protection: refers to the actions taken in order to prevent or stop all behavior considered dangerous for the physical and psychological health of children.

Child abuse: is any form of physical, emotional or sexual mistreatment or lack of care that leads to injury or harm. It often occurs within a relationship of trust or responsibility and is an abuse of power or a breach of trust.

Abusers: adults (male or female) and/or other children. An individual may abuse or neglect a child directly, or may fail to prevent another person harming that child or neglecting the needs of the child.

  1. Child abuse

There are four main types of child abuse: physical abuse, sexual abuse, emotional abuse and neglect. Children can suffer from one or a combination of these forms of abuse.

  1. Emotional – the emotional mistreatment of a child which may involve telling a child that they are worthless or unloved, inadequate, or valued only to meet the needs of another person. These may include imposing expectations or interactions that are inappropriate or beyond the child’s developmental capability, as well as overprotection and limiting the child’s ability to explore or learn or preventing the child from participating in normal social interaction.
  • Physical – causing bodily or physical harm to children.
  • Sexual – when adults use children to meet their own sexual urges; this may or may not include physical contact with the child.
  • Neglect and exploitation – when adults fail to meet the child’s basic needs to an extent that is likely to result in serious impact on the child’s health or development (e.g. failing to provide adequate food, failing to protect from physical harm or danger, failing to ensure access to appropriate medical care or treatment).
  • In addition, bullying is a form of child abuse although often, but not always, the person who is the bully is also a child. Bullying means deliberate, hurtful behavior towards another person that is usually repeated over a period of time.

There are three main types of bullying:

  • Physical (e.g. pushing, hitting, kicking, slapping or any use of violence);
  • Emotional (e.g. name-calling, ridiculing, humiliating);
  • Sexual (e.g. unwanted physical contact or abusive comments).

AEI will not tolerate child abuse and is committed to:

  • Taking into account, in all of our planning and activities, the interests and wellbeing of children;
  • Respecting the rights, wishes and feelings of the children with whom we are working;
  • Taking all reasonable steps to protect children from neglect and physical, sexual, psychological and emotional abuse;
  • Responding to all suspicions and allegations of abuse swiftly and appropriately;
  • Recruiting AEI volunteers and staff to work with children with regard to their suitability for that responsibility and providing them with training in good practice and the child protection code of ethics.

AEI promotes and expects behavior that is sensitive, respectful, caring and that contributes to creating a healthy and safe environment for both children and adults; an environment where children and adults feel able to come forward with concerns and receive support from those around them.

All volunteers and staff involved in AEI’s programs must be also made fully aware of and comply with the strict prohibition of the following:

  • Any sexual intimacy or the appearance of sexual intimacy
  • Pornography
  • Smoking by or in front of children
  • Underage drinking
  • Use of non-medical drugs
  • Any form of abuse, especially corporal punishment

Violation of any of these rules will lead to consequences up to exclusion from the organization.

To ensure the physical protection of children, their health and safety must be provided for. AEI policy includes specific requirements for activities outside the offices, especially field trips but also activities in public space:

  • The ratio of adults to children during fieldtrip activities (at least 1-10)
  • Upholding all local public health/ health and safety standards, especially those of the PNA Ministry of Education and Higher Education with regard to excursions and open air events
  • Ready access to medical care
  • Healthy diet and nutrition
  • Checking possibilities for arranging appropriate insurance
  • Accommodation of special needs, to the fullest extent possible.

People in positions of program or project responsibility must understand that they are in a position of trust at all times in relation to the children for whom they are responsible. This means that all contact with children before or after a project activity should reflect the same values and behavior.

Abuse can take place not only in person but also through other forms of contact (e.g. phone, text messages, emails, social networking sites). It is important to encourage safe online or distance communication and to understand that AEI’s responsibility to children extends to any contact we have with them, be it by phone, text, chat, social network sites etc.

  1. AEI Code of Conduct toward Children
  DO treat children with respect independently of physical characteristics, sex, religion, or originDO discuss children’s rights with childrenDO allow children to talk about any concerns they may have DO encourage others to challenge any attitudes or behaviors they do not like DO avoid being drawn into inappropriate attention-seeking behavior from children, such as tantrums DO keep other leaders informed of where you are and what you are doing DO take any allegations or concerns of abuse seriously and refer them immediately to AEI management. DO have permission of children to make photos of them and explain any photo’s possible use for publicity. In case of children below 14, parental permission should be asked. DO only use the children’s first names on any caption and take precautions that no disclosing identifying information is provided.DO take care when uploading photographs with youth such as those taken in a camp; only images of children in suitable dress should be used to reduce the risk of inappropriate use DO receive permission from parents/guardians about publishing any written or filmed interview with or story of childrenDO use positive, non-violent methods to regulate children’s behaviorDO NOT form an intimate or sexual relationship with a child or any other relationship that would be an abuse of trust and would result in summary dismissal from the organisationDO NOT sleep in the same room or bed as the childrenDO NOT allow children to be neglected physically or psychologicallyDO NOT allow abusive activities between children such as bullying DO NOT allow smoking, drinking alcohol or the use of non-medical drugsDO NOT allow the showing of pornographic images or filmsDO NOT engage in inappropriate behavior or contact – physical, verbal, sexual DO NOT make sexually suggestive remarks to a child, even in fun DO NOT use inappropriate language, whether speaking or writing – in person or by phone, email or through use of social media DO NOT allow a child to use inappropriate language unchallenged DO NOT let allegations, suspicions, or concerns about abuse go unreported – inform AEI management DO NOT provide personal details about children on your website or social networking groupDO NOT allow children to become involved in confrontations with the Israeli army during project activities.DO not interact with children without presence or awareness of other staff members – e.g. only send personal emails or text messages to children from official work email addresses and copy in other staff. If possible, talk to children with other staff present.  
  1. Vulnerable adults

A vulnerable adult is an individual aged 18 years or over who is at greater risk of significant harm due to factors such as gender, age, mental or physical health, or as a result of poverty, inequality or experience of displacement or crisis. Safeguarding vulnerable adults is the process of protecting adults from abuse or neglect, enabling adults to maintain control over their lives and make informed choices without coercion.

AEI is committed to safeguard vulnerable adults.

When sensitive information is involved it is an AEI practice to safeguard vulnerable adults through a code of ethics to be signed by staff and participants. The code helps to build trust among the staff, volunteers, project participants, and the wider community.  The following example can be used as a starting point. It can be adapted according to needs.

Ethical code: example

In the context of the [name project], I promise to

  • work for the public good and do people no harm
  • follow professional values of truth-seeking and objectivity, without prejudice
  • obtain  informed consent from research participants, who will be made fully aware of the project objectives and approach
  • minimise the risk of harm to the participants, insofar it is in my power
  • protect their anonymity and confidentiality, if they desire so
  • avoid using any kind of deceptive practices with regard to the information they provide
  • give participants the right to withdraw  information from [e.g. the website] which they earlier provided.

I agree that in case it is proven that I have trespassed one of those promises, I will withdraw from the project.




  1. Representation

AEI is obliged to make sure that its representatives and activities promote the welfare of people (especially children and vulnerable adults) in the communities where we work and do not expose them to the risk of harm, including sexual exploitation and abuse. Safeguarding measures seek to prevent situations where individuals can use their position of power, to abuse or exploit another person.

AEI’s expectation is that those who represent the organisation (including board members, staff, volunteers, consultants) uphold our safeguarding commitments in both their professional and personal lives. All will be required to sign the declaration forms attached to this policy as part of their contract with us and agree to abide by the behaviours and procedures outlined.

AEI ensures that appropriate steps are taken during recruitment and selection of employees and representatives (including Board and local and international Volunteers), to make sure that issues relating to safeguarding are considered and addressed.

  1. Recruitment

Safe recruitment must involve incorporating safeguarding considerations within:

  • Job advertisements
  • Job descriptions
  • Interviews
  • Reference checks
  • Self-declaration (see Annex)
  • Sign Policy and Code of Conduct Form (see Annex)
  • Contract clauses
  • Self-Declaration Form
  • Qualifications and identification check
  • Safeguarding as part of induction.
  1. Recruitment of Consultants

As part of AEI’s procurement process, the selection process for consultants includes the requirement for consultants to sign adherence to the safeguarding code of conduct. They are also required to sign a self-declaration form (see Annex).

  1. Processing positive and negative feedback

Feedback is important because:

  • Programme participants are service-users with rights; they have a right to inform us if the services being provided are unsatisfactory
  • Feedback can guide organisations to improve the quality of programmes
  • Programme participants will feel more respected and valued if their feedback is listened to and
  • receives a response
  • Feedback helps participants stay safe, as they will feel able to speak out if the project is creating
  • risks for them
  • Staff feel motivated because feedback provides an opportunity to learn and improve programmes
  • Listening and responding to feedback can increase security by identifying early tensions with certain members of the community
  • Having a good feedback and complaints handling mechanism in place builds acceptance and a
  • good reputation and reduces risks for the organization.

The difference between feedback and complaints:

Feedbackis information provided by programme participants (or other crisis-affected people) about their experience with AEI. It can be positive or negative, and posed as questions, an opinion, a suggestion or a complaint. Feedback may be collected through monitoring and informal channels as well as through a feedback and complaints mechanism. Feedback can be used for different purposes, including to improve the response.

Complaintsare specific grievances from anyone who has been negatively affected by an organisation’s

action or who believes that an organisation has failed to meet a stated commitment. Complaints can alert

agencies to serious misconduct or failures in the response.

Non-sensitive Feedback and Complaintsrelate to program activities or funding and should be resolved by program staff or addressed by the relevant teams.

Sensitive Complaintsrelate to issues of corruption, exploitation, abuse, misconduct, negligence or any

other abusive or inappropriate behavior by staff, volunteers or affiliates. They need to be treated urgently and confidentially by senior staff within the organisation.

Non-valid feedback or complaints are those that have been through a verification process and have been

found to be unsubstantiated. The complainant should be informed that their complaint was found to be non-valid.

Confidentiality: Privacy is a fundamental personal right. Therefore, it is crucial that we ensure confidentiality of program participants when managing their complaints. Confidentiality helps create an environment in which people are more likely to raise concerns, complain or stand witness to bad practice or incidents of abuse. People might not raise concerns or complaints if they are in fear of reprisal of retaliation. Confidentiality assures that any information given is restricted to a limited number of people on a need-to know basis and that it is not disseminated more widely.

Objectivity: Feedback and complaints are dealt with objectively and with procedural fairness.

AEI recognizes that disclosures (i.e. when a specific allegation of abuse is made against a named individual) and suspicion (i.e. when concern is raised about abuse that may have taken place or may happen) should always be investigated and acted upon swiftly.

AEI will receive disclosures from children and vulnerable adults with sensitivity and will strive not to re-traumatize them in their handling of complaints. Children will be reassured that telling was the right thing.

Children’s safety is paramount. Therefore their confidentiality must be protected at all stages.

  1. Procedures feedback and complaints

Feedback and complaints are collected from idea boxes and project evaluations with participants. The AEI office will have wall papers in which feedback is encouraged, including about serious issues such as abuse.

The focal points for feedback will be the director (for women) and the head of the children’s and youth program (for men). Both can be approached for feedback by project members and participants.

All staff and management team members of AEI have a joint responsibility for safeguarding and taking care of the feedback.

The focal points will take care to make a distinction between sensitive and non-sensitive feedback, and feedback which does and which does not need to be answered. The focal points take care to include the feedback on the agenda of a management meeting.

All complaints need to be reviewed and addressed. Non-sensitive complaints can be resolved or addressedby the programme or support teams.

For sensitive complaints, the complainant should receive confirmation that the complaint has been received and action is being taken within five working days of making a complaint.

Complaints related to fraud and corruptions follow the same process as complaints related to sexual exploitation and abuse, according to the policy on fraud and corruption.

A sensitive complaint is dealt with in the management team as soon as possible. An assessment meeting with management team members and/or advisory board members will be organized (who are not party to the complaint), to assess the concern and decide about next steps, including who else needs to be informed, such as the parents. If the facts are unclear, a detailed investigation will be conducted, in which members of the management team and the advisory board and any other appointed person from inside or outside the organization can take part.

If a suspicion is expressed, an investigation team will be formed from management and board members to gather evidence on a confidential base.

The investigators need to establish which rules (national employment law, employment contract, code of

Conduct, bylaws) have been allegedly broken and identify the evidence relevant to each rule. The investigation needs to prove in the balance of probability that the alleged incident did or did not occur. The investigation report presents the conclusions of the investigation which must be kept confidential. Upon their conclusions management will take appropriate action, which may involve disciplinary action and reporting to the legal authorities.

If a member of the staff is the subject of an allegation of child abuse or mistreatment of a vulnerable adult that member of the staff will be asked to take leave from duties on full pay until the internal investigation is completed.

All disclosures will be treated confidentially. Any AEI staff who raise concerns about malpractice will be protected as far as possible from detrimental treatment if they come forward with serious concerns, provided that concerns are raised in good faith. The confidentiality of witnesses will be protected.

Serious feedback which needs to be answered will be answered within three weeks.

AEI management team will have meetings twice per year to review all feedback received.

Each serious or sensitive case will be documented by the focal point.

  1. Further application of the code of conduct within AEI
  1. This safeguarding protection policy and code of conduct are part of AEI’s bylaws. AEI staff will be asked to sign the code of conduct.
  1. They will be translated into Arabic.
  1. AEI volunteers and staff, are responsible for following this policy and code of conduct at all times.
  1. All staff and volunteers will be given a copy of AEI’s policy and code during training, instruction or volunteer orientation and they must become familiar with its requirements, by reading and understanding the code.
  1. AEI staff and volunteers must all be trained or informed to recognize the situations where abuse of children and vulnerable adults may occur in order to enable them to react appropriately if they have concerns. The director will ensure all staff and volunteers are trained.
  1. The policy and code of conduct are available for parents (guardians) and children upon request.
  1. AEI will give a phone number of contact persons prior to field trips with young people or other major activities involving children.
  1. The website will show a copy of the safeguarding policy.
  1. AEI management is responsible for the application of the code of conduct.
  1. At the start of each project or new group and during evaluations, staff will inform members about code of ethics and safeguarding policy, as well as the opportunity to give feedback. They take care to create a trusting climate in which all feel free to speak out, or to submit feedback confidentially or anonymously, without fear.
  1. During proposal writing and project evaluations, considerations of safeguarding should be included: What are the risks involved for children and vulnerable adults, risks to reputation, risks during fieldtrips (safety, insurance, hotspots), social media risks?  What about a project which aims to change attitudes and behaviours – is there a risk of increasing tensions in the families / communities, or a risk of stigma in the classroom?
  1. The policy and code will be reviewed every 2 years or whenever there is a major change in the organization or in relevant PNA legislation. Compliance with procedures will be regularly monitored and reviewed.