Equality Fund Prevention Of Sexual Exploitation Abuse And Harassment Policy


The Equality Fund (EF) aims to resource women’s rights organizations and feminist movements doing critical work to advance women’s rights and gender equality around the world. As feminist grantmakers we aim to shift power, reimagine philanthropy, and leverage capital to work for women—both as money is invested and also as it funds the work on the ground. EF brings to life an innovative model that leverages Philanthropy, Grantmaking, and Investment to fund women’s rights at scale.

As a feminist organization, our work acknowledges and addresses abuses of power in all its forms. Unequal gender dynamics and power relationships provide the basis for sexual exploitation and abuse. Due to their unequal status, women, girls, and non-binary people are particularly at risk of sexual exploitation and abuse. As we support women, girls, and non-binary people from a diversity of backgrounds and identities we recognize that gender inequalities also intersect with other inequalities (age, disability, nation of origin, social-economic status, race, sexual orientation, or religious beliefs). As an organization based in Canada working internationally, we must be particularly aware of these intersecting power dynamics and the harm that can arise from them.

The purpose of this policy is to ensure that EF has the safeguarding guidelines and procedures in place to prevent, respond, and address sexual exploitation, abuse, and harassment (PSEAH) in all dimensions of its work. It is also intended to communicate clearly and unambiguously that abuses of power and privilege in the form of sexual exploitation, abuse, and harassment (SEAH) are not tolerated, and that allegations of violations of this policy will be rigorously investigated and addressed.

This policy imposes a duty of compliance for all Equality Fund board members, staff, volunteers and contractors (“personnel”) including independent suppliers working on behalf of EF and partners co-implementing projects and initiatives. All parties and persons listed above must read, understand, and comply with this policy.


EF’s capacity to achieve its mandate depends on each and every person who contributes to our work individually and collectively. All EF personnel, which for the purpose of this policy includes board members, staff, volunteers, consultants, and contractors, must uphold the highest standards of ethical and professional conduct. This policy sets the minimum standards of conduct required of EF personnel to prevent and address sexual exploitation, abuse, and harassment.

Pursuant to the Ontario Occupational Health and Safety Act, EF has specific obligations to protect its staff from harassment and violence. These obligations are enumerated in the Equality Fund Code of Conduct and operationalized in Equality Fund’s Harassment Policy and Equality Fund’s Workplace Violence Policy. This PSEAH policy specifically relates to complaints against Equality Fund personnel by external parties.


Exploitation— is using one’s position of authority, influence, or control over resources to pressure, force, or manipulate someone to do something against their will by threatening them with negative repercussions.

Sexual exploitation— is sexual coercion and manipulation, including all types of sexual acts, by a person in a position of power providing any type of assistance in exchange for sexual acts. In these situations, the potential victim believes they have no other choice than to comply; this is not consent, but exploitation. Sexual exploitation is any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes; this includes profiting monetarily, socially, or politically from sexual exploitation of another.

Sexual harassment— is unwanted sexual advances including derogatory comments, gestures, looks, unnecessary/unwanted physical contact, jokes or slurs, as well as implied or expressed promises of reward or threat of reprisal in relation to a sexually oriented request.

Sexual and gender-based violence (SGBV)— is violence that is directed against a person on the basis of gender or sex. It includes acts that inflict physical, mental, or sexual harm or suffering, threats of such acts, coercion, and other deprivations of liberty. While women, men, boys, and girls can be victims of gender-based violence, women and girls are the primary victims. Gender-based violence involves the abuse of power. In sexual and gender-based violence unequal power relationships are exploited or abused through the use of physical force or other means of coercion such as threat, inducement, or promise of a benefit to obtain sexual favours from a weaker or more vulnerable person.

Consent— in this context means the ongoing and voluntary agreement to engage in sexual activity and to continue to engage in the sexual activity. Consent means that all persons involved demonstrate through words or actions, on an ongoing basis, that they freely, knowledgeably, and mutually agree to participate in the sexual activity. There is no consent where one person abuses a position of trust, power, or authority over another person, including when one person is a child (under 18 years of age).


This section outlines the behaviours that EF expects of its personnel. Any breach of these behaviours constitutes a violation of this policy and will be investigated and addressed. Failure to comply with this policy is likely to result in disciplinary action, up to and including dismissal where appropriate:

  • EF personnel will treat all people with respect and dignity and challenge any form of harassment, discrimination, intimidation, exploitation, or abuse. EF staff hold a privileged position of power and trust in relation to our partners and the communities they serve. When carrying out EF’s mission, personnel will contribute to a working environment characterized by mutual respect, integrity, dignity, and non-discrimination;
  • EF personnel will respect all people’s rights, including children’s rights, and never intentionally commit acts that result in physical, sexual, or psychological harm to personnel, partners, or members of communities supported by EF’s partners;
  • Sexual activity with children, defined in accordance with international standards as persons under the age of 18, is prohibited regardless of the local age of majority or age of consent. Mistaken belief in the age of the child is not a defense;
  • EF acknowledges that many individuals base their livelihoods on the exchange of money, employment, goods, or services for sex or sexual favours. Nevertheless, due to the inherent power imbalance that exists in the context of our work, EF personnel will not engage in any transactional sex act at any time while representing EF. This includes any exchange of cash, goods, preferential treatment, or any other service in exchange for a sexual act;
  • EF personnel are strongly discouraged from engaging in sexual relationships with members of partner organizations in situations where the person or their organization is in a perceived or real power relationship with EF. This includes being reliant on EF for financial or other support. Should such a relationship occur, the EF representative must immediately disclose it to EF HR so that appropriate steps can be taken to avoid a real or perceived conflict of interest or exploitation. If such a relationship is not disclosed, the presumption will be that it is exploitative;
  • EF personnel are strongly discouraged from engaging in sexual relationships with members of communities that directly benefit from the work of grantee partners supported by EF. Should such a relationship develop, the EF representative must disclose it to EF HR so that appropriate steps can be taken to avoid a real or perceived conflict of interest or exploitation. If such a relationship is not disclosed, the presumption will be that it is exploitative;
  • EF personnel acknowledge that this policy is binding on them, that a SEAH complaint mechanism exists, and that they have a responsibility to communicate any SEAH concerns or suspicions immediately to the PSEAH focal point.


  • At the time of contracting, EF grantee partners will either sign a declaration to confirm that they have a code of conduct, including rules and policies, to adequately respond to matters of sexual exploitation, sexual misconduct, and sexual abuse, or within three months of the effective date of an agreement, will approve and implement an internal policy that reflects the basic terms of the EF PSEAH Standards;
  • As part of its due diligence processes, EF will assess if grantee partners that are working with or in contact with children, young people, and adults at risk have appropriate and effective child safeguarding measures in place.


  • EF will orient all current and new staff and Board Members to this policy;
  • All personnel will read and sign on to the PSEAH policy, and will be asked to review and re-sign this policy annually;
  • HR will appoint a policy focal point and a confidential complaint mechanism which will be communicated to EF personnel and to all partners;
  • Personnel or partners who feel they have been subjected to exploitative behaviour will be encouraged to report the incident through the focal point
  • Personnel or partners who, in good faith, report an alleged incident of sexual harassment, exploitation or abuse will not be subjected to reprisal or retaliation of any kind;
  • EF will maintain confidential data on all PSEAH complaints received and how they are resolved;
  • EF will ensure that all new written funding agreements with grantee partners include a clause referencing the need to have a PSEAH policy and complaint mechanism;
  • This policy will be included in the documents signed with third parties as a condition precedent to entering into contract with EF.
  • EF will inform Global Affairs Canada (GAC) of any PSEAH cases in accordance with its contractual obligations.

All members of EF are accountable for ensuring that personnel and partners understand this policy and the obligations it places on them.

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