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Preventing Sexual Exploitation, Abuse and Harassment Policy (PSEAH)

October 2025 | CONFIDENTIAL | ABN 54 121 715 446

1. Who we are?

Maluk Timor Australia is a registered charity in Australia and its primary objective is to improve the quality of primary healthcare being delivered by Timor-Leste’s own primary health care system by working inside government-run health centres, alongside Timorese healthcare workers and in close partnership with the Timor-Leste Ministry of Health. It does so via its relationship with Associação Maluk Timor—an association established under the laws of Timor-Leste. Maluk Timor Australia supports the work of Associação Maluk Timor by the provision of funding, technical and administrative assistance.

2. Purpose: Why do we have a Preventing Sexual Exploitation, Abuse and Harassment Policy?

Maluk Timor Australia does not tolerate sexual exploitation, abuse, or harassment (SEAH) of any kind. We are committed to providing a safe environment for everyone we work with, including our staff, partners, and the communities we serve. This commitment is grounded in strong leadership, accountability, and a survivor-centred approach.

Preventing sexual exploitation, abuse, and harassment is a fundamental obligation of our work. We have adopted a risk management approach to enhance accountability, improve support for affected individuals, and drive positive cultural change.

3. Scope

This policy applies to all Maluk Timor Australia’s activities in Australia and Timor-Leste. It must be followed by all Directors, contractors, employees, volunteers, and implementing partners.

4. Policy statement: Our commitment

Maluk Timor Australia is committed to a safe work environment free from sexual exploitation, abuse, or harassment. This commitment is based on the following principles:

a) Zero tolerance of inaction

SEAH is never acceptable. We are committed to acting on every allegation fairly and reasonably.

b) Strong leadership accelerates cultural change

Maluk Timor Australia leaders set clear expectations and model respectful behaviour, ensuring that communities, victims/survivors, and whistle-blowers feel safe to report concerns.

c) Victim/survivor needs are prioritised

Maluk Timor Australia’s actions prioritise the rights, needs and wishes of the victim/survivor while ensuring procedural fairness to all parties. This approach:

  • Treats the victim/survivor with respect and dignity
  • Involves the victim/survivor in decision making
  • Provides the victim/survivor with comprehensive information
  • Protects privacy and confidentiality
  • Does not discriminate based on gender, age, race/ethnicity, ability, sexual orientation, or other characteristics
  • Considers the need for counselling and health services to assist the victim/survivor with their recovery

d) Preventing Sexual Exploitation, Abuse and Harassment is a shared responsibility

Preventing SEAH is everyone’s responsibility. Maluk Timor Australia will work with our partners to build capacity for sensitive and effective responses.

e) Gender Inequality and other power imbalances are addressed

Maluk Timor Australia’s activities promote gender equality, social inclusion, and accountability, recognising that power imbalances can lead to SEAH. Maluk Timor Australia have a separate Child Protection Policy addressing the specific risks to children.

f) Stronger reporting will enhance accountability and transparency

Maluk Timor Australia are committed to strong reporting and system improvement to better monitor and manage SEAH risks.

5. Implementation

Maluk Timor Australia integrates this policy into all its activities. We require all Directors, contractors, employees, and volunteers to sign and abide by our Safeguarding Code of Conduct.

6. Procedures

6.1. Internal screening processes

  • Maluk Timor Australia implement stringent pre-employment screening, which may include criminal record checks, working with children checks, and thorough reference checks.
  • Maluk Timor Australia promote risk awareness through regular training for all personnel and support our partners in doing the same.
  • Maluk Timor Australia undertake regular, specific risk assessments to identify and mitigate SEAH risks in our programs and partnerships.
  • Maluk Timor Australia provide a safe, supportive, and secure environment for reporting SEAH. All reports are taken seriously and addressed promptly. Reporting procedures align with our Complaints Policy.
  • All investigations into reported incidents will be survivor-centred, transparent, fair, professional, and thorough. Maluk Timor Australia will coordinate with local law enforcement where appropriate and safe to do so.

6.2. Risk Awareness

Available data indicate that the majority of victims/survivors of SEAH are female, and the majority of perpetrators are male. However, SEAH is fundamentally driven by power imbalances. Other inequalities, based on distinctions such as worker/beneficiary, ability/disability, ethnic and indigenous status, religion, gender identity and sexual orientation, age, health, and poverty, can also create significant risk. The intersection of gender with other forms of inequality can further increase vulnerability.

Children are at considerable risk of SEAH, with heightened vulnerability for children with disabilities, those living in institutional or residential care, those who have experienced previous trauma or abuse, trafficked children, and gender-diverse children and young people.

Maluk Timor Australia has a zero-tolerance policy towards SEAH. We are committed to preventing these harms through comprehensive risk awareness training for all staff and associates, and by implementing clear, victim/survivor-centred support and reporting procedures.

6.3. Risk Assessment

Maluk Timor Australia have adopted a proactive, risk-based approach to PSEAH, where the application of safeguarding standards is proportionate to the level of assessed risk. Processes for identifying and managing PSEAH risks are embedded into our core activity planning and existing risk management frameworks.

A dedicated PSEAH risk assessment is conducted annually across the organisation and its partner network. The findings from this assessment directly inform our risk mitigation strategies, which are systematically reviewed and strengthened to effectively address the specific SEAH risks identified.

6.4. Reporting

Maluk Timor Australia encourages anyone to report concerns relating to sexual exploitation, abuse, or harassment. Reports can be made in accordance with our Complaints Policy.

6.5. Our Partners

Maluk Timor Australia collaborate with all our partner organisations to prevent SEAH. Our primary partner in Timor-Leste, Associação Maluk Timor, has its own procedures to investigate reported incidents that comply with this policy.

We include contractual obligations for all downstream partners to adhere to relevant safeguarding policies and review their compliance yearly.

7. Staff and Community Awareness

  • All new personnel complete an induction that includes awareness of this policy and Maluk Timor Australia’s zero-tolerance stance.
  • Refresher training on PSEAH and related safeguarding topics is conducted regularly.
  • We engage with communities and promote strategies to increase awareness and prevention of SEAH.

8. Working with Partners

Maluk Timor Australia collaborate with Partner Organisations, both local and international, to prevent SEAH. We include contractual obligations for partners to adhere to PSEAH principles and support them in building their capacity to comply.

9. Other related policies and procedures

This policy works alongside other key organisational policies, including:

Policies

  • Policies of both Maluk Timor Australia and Associação Maluk Timor (as implementing partner)
  • Employment policies
  • Child Protection Policy
  • Gender Equity Policy
  • Disability Inclusive Policy
  • Maluk Timor Australia Whistleblower Policy
  • Code of Conduct
  • Complaints Policy

10. Review processes

Policy Review Frequency

This policy is reviewed every 2 years to ensure its effectiveness.

Responsibility for Review

The Board of Directors is ultimately responsible for reviewing this policy and approving any changes.

11. Key terms and phrases

  • ‘Perpetrator’ means a person (or group of persons) who commits an act of SEAH or other type of crime or offence.
  • ‘Sexual Abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. This includes attempted rape and sexual assault.
  • ‘Sexual Exploitation’ means any actual or attempted abuse of a position of vulnerability, power, or trust for sexual purposes, including profiting from the sexual exploitation of another.
  • ‘Sexual Harassment’ means any unwelcome sexual advance, request for sexual favours, or conduct of a sexual nature that could reasonably offend, humiliate, or intimidate a person. This can be verbal, physical, visual, or online.

Some examples of behaviour that may be sexual harassment include:

  • Staring or leering
  • Unnecessary familiarity, such as unwelcome affection or touching
  • Suggestive comments or jokes
  • Insults or taunts of a sexual nature
  • Intrusive questions or statements about a person’s private life
  • Displaying posters, magazines, or screen savers of a sexual nature
  • Sending sexually explicit emails or text messages
  • Inappropriate advances on social networking sites
  • Accessing sexually explicit internet sites
  • Requests for sex or repeated unwanted requests to go out on dates
  • Behaviour that may also be considered an offence under criminal law, such as physical assault, indecent exposure, sexual assault, or obscene communications

‘Transactional sex’ means the exchange of money, employment, goods or services for sex, including sexual favours.

‘Victim/Survivor’ means a person who is, or has been, sexually exploited, harassed, or abused.