POLICY

SAFEGUARDING   POLICY

1. Purpose and Introduction 

 

ESPartners (ESP) is committed to ensuring that all individuals who engage with our programs, services,  investments, and operations are treated with dignity, respect, and safety. 

 

As a Business Development Services (BDS) provider and investment support organization working with  entrepreneurs in Rwanda, the Ivory Coast, and Africa, ESP regularly interacts with young entrepreneurs,  women-led businesses, early-stage founders, and individuals from diverse socio-economic backgrounds.  These interactions create opportunities for empowerment but may also introduce risks related to power  dynamics, exploitation, harassment, discrimination, or abuse if not carefully managed. 

 

ESP therefore adopts a zero-tolerance approach to abuse, exploitation, harassment, and misconduct by  anyone associated with our organization. 

 

Our safeguarding policy reflects our commitment to: 

 

  • Protect program participants  
  • Ensure ethical and responsible professional conduct 
  • Prevent harm caused by ESP activities or representatives 
  • Promote accountability and safe reporting of concerns 
  • Align with international safeguarding standards and donor expectations 

 

2.Scope of the Policy 

 

This policy applies to all individuals and entities associated with ESP, including: 

  • ESP employees 
  • Consultants and service providers 
  • Board members 
  • Volunteers, fellows, and interns 

 

It applies across all ESP programs, offices, digital platforms, and field activities, including: 

 

  • entrepreneurship training programs 
  • mentorship and coaching sessions 
  • investment readiness programs 
  • field visits to businesses 
  • networking events and workshops 
  • investment pipeline and funding relationships 

 

3. Safeguarding Principles 

 

ESPartners (ESP) approach to safeguarding is guided by key international principles and standards, as set  out in the Universal Declaration of Human Rights (UDHR, 1948); the UN Convention on the Rights of the  Child (UNCRC, 1989); the UN Convention for the Elimination of all forms of Discrimination against Women  (CEDAW, 1979); UN Convention of People with Disabilities (UNCRPD 2006) and in the national laws of the  countries in which ESP’s works, including principles of equality, diversity and inclusion. 

 

ESP’s safeguarding framework is guided by the following principles:

 

3.1 Zero Tolerance 

 

ESP does not tolerate any form of exploitation, abuse, harassment, discrimination, or misconduct.

 

3.2 Do No Harm 

 

All ESP activities must be designed and implemented in ways that minimize risk and prevent unintended  harm to program participants. 

 

3.3 Respect and Dignity

 

Every individual interacting with ESP must be treated with respect, regardless of gender, education level,  ethnicity, disability, religion, or socio-economic background. 

 

3.4 Accountability 

 

All safeguarding concerns must be reported, documented, and addressed promptly.

 

3.5 Vulnerable-Centered Approach 

 

Responses to safeguarding concerns prioritize the safety, dignity, and well-being of the affected person.

 

4. Definitions 

 

4.1 Safeguarding 

 

Actions taken by ESP to prevent harm, abuse, exploitation, or harassment involving individuals interacting  with ESP staff, partners, or programs. 

 

4.2 Abuse 

 

Any act causing harm or risk of harm, including physical, emotional, sexual, or psychological harm.

 

4.3 Exploitation 

 

Taking advantage of a position of power or trust for personal gain, including financial, sexual, or  professional benefit. 

 

4.4 Harassment 

 

Unwelcome behavior that creates an intimidating, hostile, or offensive environment.

 

4.5 Conflict of Interest 

 

Situations where personal relationships or financial interests could influence professional decision-making.

 

4.6 Child 

 

Refer to a person under the age of 18 years old. 

 

4.7 Mandatory duty to report

 

Any ESP representative who becomes aware of an incident or an allegation of exploitation or abuse of  a child or an adult has a mandatory duty to report this immediately through ESP’s internal systems. 

 

4.8 ESP Senior Management 

 

ESP senior management is composed of members responsible for strategic direction, major decisions,  and overall performance. These members are: The Co-founder, Partner Culture & Governance, Partner  Market, and Partner Delivery. 

 

Some additional definitions relating to abuse, exploitation, and harassment can be found in Annex 1.

 

5. Gender and Intersectionality Safeguarding Approach 

 

ESP recognizes that certain groups may face heightened safeguarding risks due to overlapping  vulnerabilities. 

 

These may include: 

 

  • Women entrepreneurs  
  • Young women entrepreneurs 
  • Young entrepreneurs 
  • Rural entrepreneurs 
  • Persons with disabilities 
  • Low-literacy participants 
  • Refugees or marginalized groups 

 

ESP integrates gender and intersectionality considerations across all safeguarding measures by: 

 

  • Conducting gender-sensitive risk assessments 
  • Promoting equal participation in programs 
  • Ensuring safe reporting channels for women and vulnerable participants 
  • Training staff on gender-based risks and cultural sensitivities 

 

Programs are designed to ensure safe participation of women and young women entrepreneurs, including  appropriate facilities, scheduling considerations, and gender-sensitive facilitation. 

 

6.Staff Conduct and Ethical Standards 

 

All ESP staff including volunteers, interns, consultants, third parties (BDSPs), and representatives must: 

 

  • Treat all participants with dignity and respect 
  • Avoid discrimination, harassment, or favoritism 
  • Maintain confidentiality of participant information 
  • Avoid conflicts of interest 
  • Report safeguarding concerns immediately 

 

All employees, consultants, volunteers, and service providers (BDSPs) must sign the ESP Safeguarding Code  of Conduct found in Annex 2. 

 

7.Safe Reporting Mechanisms 

 

ESP provides multiple accessible channels for reporting safeguarding concerns.

These include: 

  • Email reporting to the Safeguarding Focal Person 
  • Suggestion or complaint boxes during training events 
  • Direct reporting to trusted staff 

 

Reports may be submitted anonymously. 

ESP guarantees: 

  • confidentiality 
  • non-retaliation 
  • fair investigation procedures 

 

8.Safeguarding Governance Structure

 

ESP has established the following safeguarding governance structure: 

 

8.1 Safeguarding Focal Person (SFP) 

 

The Safeguarding Focal Person is responsible for the day-to-day management of safeguarding concerns and  coordination of safeguarding processes within ESP. 

Responsibilities include:

  • Receiving safeguarding reports through designated channels; 
  • Ensuring confidentiality of reported information; 
  • Conducting an initial assessment of safeguarding concerns; 
  • Coordinating safeguarding responses and investigations; 
  • Ensuring immediate protection measures where necessary; 
  • Maintaining a confidential safeguarding case register; 
  • Escalating serious cases to the Safeguarding Committee and Senior Leadership.

 

8.2 Safeguarding Committee 

 

The Safeguarding Committee provides oversight and guidance on safeguarding cases and ensures that  safeguarding concerns are addressed appropriately and consistently. 

Responsibilities include: 

  • Reviewing serious or complex safeguarding cases. 
  • Providing guidance on case management and investigations. 
  • Reviewing investigation findings. 
  • Recommending disciplinary or corrective actions. 
  • Monitoring implementation of safeguarding measures. 
  • Ensuring alignment with ESP safeguarding standards. 

 

8.3 Senior Leadership Oversight 

 

Senior Leadership holds ultimate accountability for the implementation and enforcement of ESP  safeguarding commitments.

ESP leadership ensures: 

  • Providing strategic oversight of safeguarding implementation. 
  • Allocating resources for safeguarding measures. 
  • Reviewing recommendations from the Safeguarding Committee. 
  • Taking final decisions on disciplinary or contractual actions. 
  • Ensuring compliance with legal and donor safeguarding requirements. 
  • Escalating serious incidents to authorities or funding partners where required.

 

In cases where a safeguarding allegation involves a member of the Safeguarding governance structure  (including the Safeguarding Focal Person, a Safeguarding Committee member, or Senior Leadership), that  individual must recuse themselves from the case management process. 

 

An alternative responsible person will be designated to ensure the independence and integrity of the  investigation.  

 

This governance structure ensures that safeguarding concerns are handled independently, transparently,  with confidentiality, and in accordance with ESP’s commitment to accountability and protection of program  participants.

 

9.Safeguarding Awareness and Training 

 

ESP recognizes that raising awareness and providing appropriate training are crucial for maintaining and  improving safeguarding practices. It is essential that all Staff and those engaged in ESP’s work are aware of  safeguarding standards and their obligations to implement them. Depending on the role of each staff  member, different levels of training are provided. However, at a minimum, all are introduced to the  safeguarding policy during induction and ongoing refresher workshops and/or training are organized.

 

10. Response to Safeguarding Concerns 

 

By creating safe environments and implementing preventative measures, we work to reduce the potential  for things to go wrong. However, in the event that there is a concern, it is important that our response is  appropriate, professional, and limits any further possible stress or impact.

 

We are therefore committed to  doing the following: 

  • Take all complaints and concerns seriously. 
  • Conduct initial risk assessments and put in place measures to maintain safety pending  investigation. 
  • Liaise with the relevant national authorities as appropriate in each country. 
  • Respect confidentiality in relation to all complaints and concerns. 
  • Consider support for all parties to a concern. 
  • Follow up and act on all investigation recommendations. 

 

10.1 Mandatory Duty to Report – Staff & Representatives 

 

All ESP employees and representatives have a mandatory duty to report any suspected incident of  exploitation or abuse to: 

  • the co-founder and  
  • the Designated Safeguarding Focal Person (SFP) in each country 
  • by e-mail to safeguarding@espartners.co 
  • Suggestion and reporting boxes  

 

This is regardless of whether it is internal to ESP or not. It is not the responsibility of ESP representatives to decide whether exploitation or abuse has occurred, but they must pass their concerns on. 

 

It should be noted that abuse may be current, recent or historical. There are no time constraints for  reporting and taking action within the remit of this procedure, although ESP requires that reports be made  as soon as knowledge, or suspicion, of an act of exploitation or abuse occurs. 

 

ESP will endeavor to protect all individuals in reporting, unless they make allegations that they know to be  false or vexatious. An individual who makes a report against another that they know to be false or  vexatious, if proven to be so, will result in appropriate corrective action under the Disciplinary Procedure up  to and including dismissal if they are an employee. 

 

10.2 How To Respond to a Person Bringing a Report on Possible Abuse or Exploitation

 

Receiver: Listen, believe 

Reassure: Make no promises, but communicate that what is being reported is not the fault of  the victim. Communicate no judgment. 

React: Be non-intrusive, ask open questions, remain calm  

Record: Contemporaneous notes (observable/verifiable facts)  

Remember: Do not investigate. Report as outlined in 12.1 above 

 

10.3 Allegations Relating to ESP Consultants, and Other Third Parties Services Providers 

 

If the allegation/complaint relates to an ESP’s consultant or service providers, they will be informed of  the allegation/complaint/suspicion and the external reporting requirements that must be followed by  the ESP. The consultant or service provider will be informed after an initial assessment and based on  consideration of risks or potential implications for investigations. All activities involving the consultant  or service provider will be suspended while the complaint is being followed up on. This decision will be  made using the guiding principle that the safety of the person reported to have been harmed is always  the most important consideration. Procedures will be conducted in accordance with national  guidelines. 

 

If the findings conclude that ESP Safeguarding Policies have been breached, then contracts/  agreements with the consultant or service provider will be immediately cancelled. 

 

10.4 Responding to Reports and Allegations 

 

ESP will take whatever action is appropriate, necessary and possible, without risk of further harm to any  individual and to ensure the safety of those involved. Each case will be considered individually and in  accordance with national legal or other expert advice. ESP will follow best practice as has been documented  and agreed for each of the respective countries in which it operates. 

 

10.5 Confidentiality and Data Protection 

 

Any information offered in confidence should be received on the basis that it may be shared with the  safeguarding case management team and relevant people in authority. 

 

We recognize that this duty to report may at times come into conflict with principles of confidentiality and  the right of a victim to choose what happens next in the event of a disclosure. To mitigate risk, staff must  adhere strictly to confidentiality requirements by only disclosing information to the assigned Safeguarding  committee Case Management Team /investigating body, and in line with organizational procedures. 

 

All documents relating to safeguarding complaints and concerns are held in safe storage and can only be  accessed by ESP’s safeguarding committee case management team. Receiving and forwarding safeguarding  disclosures is included in safeguarding training. 

 

We report statistics on safeguarding complaints in our Annual Report to ESP Senior Management. As a rule,  names or identifying information will not be shared. If it is necessary to disclose information to third parties,  this is decided on a case-by-case basis, except in the case of criminal activity.

 

10.6 Allegations Relating to ESP Staff 

 

If the allegation/complaint relates to an ESP Staff including senior management, they will be informed of the  allegation/complaint/suspicion and the reporting requirements that must be followed by the organization.  The staff member will be informed after an initial assessment and based on consideration of risks or potential  implications for investigations. The Staff will also be informed of any decision to remove or suspend them  from any or all duties or duties that involve working with program participants affected or at risk. This  decision will be made using the guiding principle that the safety of the person reported to have been harmed  is always the immediate consideration. 

 

Procedures will be conducted in accordance with national guidelines. ESP will conduct its own investigation  to assess whether a breach of organization policy has occurred. For concerns that are referred to the  authorities, ESP will conduct its investigation so as not to impede the legal process (e.g., after the external  process). If found, a breach of policy will result in disciplinary action up to and including dismissal. 

 

Note: ESP’s safeguarding policies are available on the ESP website:  

https://www.espartners.co/safeguarding/

 

This Safeguarding Policy is approved by the leadership of ESPartners and applies to all individuals working  with or representing the organization.