WOLCE Code of Ethics & Conduct
Preliminaries
1.1 Executive Summary
This code of conduct is one of the ways we put our values as a company into practice to be able to provide a safe space for participants and to be able to ensure a high ethical standard is always maintained. While this code of conduct might not be able to encompass every single unique action, it must serve as a benchmark upon which decisions can be made.
1.2 Objectives
This code of conduct & ethics shall serve as a formal commitment to ensure the conduct of WOLCE is professional and adheres to an ethical standard that is appropriate and fair. WOLCE is committed to a work environment and safe space in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices. Therefore, WOLCE expects that all relationships among persons in the office will be business-like and free of explicit bias, prejudice and harassment.
WOLCE has developed this policy to ensure that all its employees can work in an environment free from unlawful harassment, discrimination and retaliation. WOLCE will make every reasonable effort to ensure that all concerned are familiar with these policies and are aware that any complaint in violation of such policies will be investigated and resolved appropriately.
Any employee who has questions or concerns about these policies should speak with the director of human resources or a member of the personnel practices committee.
These policies should not, and may not, be used as a basis for excluding or separating individuals of a particular gender, or any other protected characteristic, from participating in business or work-related social activities or discussions. The regulation and the policies of WOLCE prohibit disparate treatment on the basis of sex or any other protected characteristic, with regard to terms, conditions, privileges and prerequisites of employment. The prohibitions against harassment, discrimination and retaliation are intended to complement and further those policies, not to form the basis of an exception to them.
The objectives of this code of ethics and conduct are:
To define acceptable behaviour
To assist employees and other stakeholders of WOLCE in living up to high ethical standards
To convey to both employees and external parties that WOLCE shall under no circumstances allow its principles to be compromised
To promote awareness and understanding among employees and external parties that failure to comply will result in the appropriate disciplinary action
1.3 Definitions
For the purpose of the Code, the following definitions shall apply:
Company shall refer to WOLCE (003114043-M).
Management shall refer to the Chief Executive Officer, Vice-Presidents, and Divisional Directors.
Employee(s) refers to all levels of Employees of the Company, employed on either a permanent or temporary basis. It includes persons who are on contract, secondment, apprenticeship, internship or any persons by whatever description under the supervision of the Company, whether remunerated or otherwise.
External party refers to stakeholders including customers, shareholders, contractors and vendors, government officials, agency officials, financial institutions and other parties having dealings directly or indirectly with the Company.
1.4 Interpretations
Words referring to the masculine gender shall be deemed to include the feminine gender unless otherwise stated.
Words referring the singular shall be deemed to include the plural and vice versa
References to child/children Include legally adopted child and stepchild.
In case of any doubt, the interpretation of the Management shall be taken as conclusive and final.
1.5 Ethical Conduct Checklist
To assist Employees in determining whether the conduct is ethical or not, they should consider whether or not the conduct:
Is legal,
Reflects WOLCE’s Core Values,
Conflicts with WOLCE's interest,
Brings adverse implications to oneself, other Employees, External Parties and the Company.
Any questions or concerns about and/or relating to the Code may be directed to the Head of Human Resources/Chief Executive Officer/ Director/Manager/ Manager and/or through the Company's Whistleblowing mechanism, where applicable.
1.6 Instructions
This Code is applicable to all Employees and Stakeholders of WOLCE.
Each Divisional Director/General Manager/Line Manager/Head of Department is required to ensure that the Code is understood by all Employees within his department/division/ company and that each and every Employee signs in acknowledgement of his understanding of the contents herein.
As and when required by the Company, all Employees are required to submit the signed version of the following documents: i. Letter of Undertaking. ii. Declaration FormIii. Other Non-Disclosure and/or Confidentiality Agreements (where applicable). iv. Any other documents (where applicable).
In the event that any clarification is required, it shall be the Employee's responsibility to consult his superior and/or the Head of Human Resources.
The signed documents; Letter of Undertaking and Declaration are to be returned to the Head of Human Resources, where applicable, within one (1) week of receipt of the Code.
In cases where written consents and/or approvals from and disclosures to the Chairman/Managing Director are required under the relevant clauses of the Code, all applications, requests and/or notifications are to be submitted through the Head of Human Resources.
2.0 Refund Policy
Our standard policy requires you to request a refund 2 weeks (14 days) prior to an event or the commencement of a programme. Our events require some financial commitment, so if you request for a refund less than 14 days earlier before an event, we unfortunately cannot offer you a refund or exchange for your payment.
Several types of goods and services are exempt from refunds. Merchandise such as clothing, mugs, keychains, and perishable goods along with contractual payments cannot be refunded.
To complete the transaction, we require a receipt or proof of purchase along with the e-mail address and name for the refund.
We do not issue cash refunds, we will issue you a credit note, that you can use for future events that we organize under WoLCE. Unless stated otherwise, event passes we sell are transferable, as well as any credit note issued.
3.0 Criminal Records
WOLCE recognizes the importance to have a safe space for employees, students, and stakeholders. As such, we want to ensure our recruitment process help filter individuals that might misuse or take advantage of their position at WOLCE or cause third party harm:
All offers of employment at WOLCE are contingent upon clear results of a thorough background check. Background checks will be conducted on all final candidates and on all employees who are promoted, as deemed necessary.
Background checks will include but are not limited to:
i) National Database Verification: validates the applicant's National Identification number, date of birth and former addresses (depending on country).
ii) Prior Employment Verification: confirms applicant's employment with the listed companies, including dates of employment, a position held and additional information available pertaining to performance rating, the reason for departure and eligibility for rehire. This verification will be run on the past two employers or the previous five years, whichever comes first.
iii) Personal and Professional References: calls will be placed to individuals listed as references by the applicant.
iv) Educational Verification: confirms the applicant's claimed educational institution, including the years attended and the degree/diploma received.
v) Criminal History: includes a review of criminal convictions and probation. The following factors will be considered for applicants with a criminal history:
The nature of the crime and its relationship to the position.
The time since the conviction.
The number (if more than one) of convictions.
Whether hiring, transferring or promoting the applicant would pose an unreasonable risk to the business, its employees or its customers and vendors.
The following additional background searches will be required if applicable to the position:
i) Motor Vehicle Records: provides a report on an individual's driving history in the state requested. This search will be run when driving is an essential requirement of the position.
ii) Credit History: confirms candidate's credit history. This search will be run for positions that involve management of WOLCE funds and/or handling of cash or credit cards.
3.1 Clearance Procedure
Human Resources will order the background check upon receipt of the signed release form, and either internal HR staff or an employment screening service will conduct the checks. A designated HR representative will review all results.
The HR representative will notify the hiring manager regarding the results of the check. In instances where negative or incomplete information is obtained, the appropriate management and the Vice-President of Human Resources will assess the potential risks and liabilities related to the job's requirements and determine whether the individual should be hired.
If a decision not to hire or promote a candidate is made based on the results of a background check, there may be certain additional requirements that will be handled by Human Resources in conjunction with the employment screening service (if applicable).
Background check information will be maintained in a file separate from employees' personnel files for a minimum of five years.
WOLCE reserves the right to modify this policy at any time without notice.
4.0 Confidentiality Policy
4.1 General principles
4.1.1. WOLCE recognizes that employees (employees, volunteers, students, and various stakeholders) gain information about individuals and external parties during the course of their work or activities.
4.1.2. In most cases, such information will not be stated as confidential and employees may have to exercise common sense and discretion in identifying whether the information is expected to be confidential. This policy aims to give guidance but if in doubt, seek advice from the person-in-charge of your department.
4.1.3. Employees are able to share information with their head of departments in order to discuss issues and seek advice.
4.1.4. Employees will avoid exchanging personal information or comments about individuals with whom they have a professional relationship.
4.1.5. Talking about the private life of a colleague is to be avoided at all times unless the colleague in question has instigated the conversation.
4.1.6. Employees will avoid talking about WOLCE or individuals in social settings.
4.1.7. Employees will not disclose to anyone, other than their line manager, any information considered sensitive, personal, financial or private without the knowledge or consent of the individual, or an officer, in the case of WOLCE.
4.1.8. There may be circumstances where employees would want to discuss difficult situations with each other to gain a wider perspective on how to approach a problem. WOLCE’s consent must be sought before discussing the situation unless the colleague is convinced beyond doubt that the WOLCE would not object to this. Alternatively, a discussion may take place with names or identifying information remaining confidential.
4.1.9. Where there is a legal duty on WOLCE to disclose information, the person to whom the confidentiality is owed will be informed that disclosure has or will be made.
4.2. Withholding Information
4.2.1. Most information held by WOLCE relates to individuals, voluntary and community WOLCEs, self-help groups, volunteers, students, employees, trustees or services which support or fund them.
4.2.2. Information is kept to enable WOLCE employees to understand the history and activities of individuals or WOLCEs in order to deliver the most appropriate services.
4.2.3. WOLCE has a role in putting people in touch with voluntary and community WOLCEs and keeps contact details which are passed on to any enquirer, except where the group or WOLCE expressly requests that the details remain confidential.
4.2.4. Information about students personal data is given to WOLCE but to no one else.
4.2.5. Information about ethnicity and disability of users is kept for the purposes of monitoring our equal opportunities policy and also for reporting back to funders.
4.3. Access to Information
4.3.1. Information is confidential to WOLCE and may be passed to employees, managers or trustees to ensure the best quality service for users.
4.3.2. Where information is sensitive, i.e. it involves disputes or legal issues; it will be confidential to the employee dealing with the case and their head of department. Such information should be clearly labelled ‘Confidential’ and should state the names of the employees entitled to access the information and the name of the individual or group who may request access to the information.
4.3.3. Employees will not withhold information from their directors unless it is purely personal.
4.3.4. Users may have sight of WOLCE records held in their name or that of WOLCE. The request must be in writing to the Chief Executive Officer giving 14 days’ notice and be signed by the individual, or in the case of WOLCE’s records, by the Vice-Presidents or Chief Executive Officer. Sensitive information as outlined in paragraph 4.3.2 will only be made available to the person or WOLCE named on the file.
4.3.5. Employees may have sight of their personnel records by giving 14 days’ notice in writing to the Chief Executive Officer.
4.3.6. When photocopying or working on confidential documents, employees must ensure people passing do not see them. This also applies to information on computer screens.
4.4. Storing Information
4.4.1. General non-confidential information about WOLCE is kept in a secure cloud with open access to all WOLCE employees.
4.4.2. Personnel information on employees, volunteers, students and other individuals working within WOLCE will be kept in a secure cloud only to be accessed when given consent by the Vice-Presidents or by the Chief Executive Officer.
4.4.3. Files bearing confidential information should be labelled ‘confidential’.
4.4.4. In an emergency situation, the Chief Executive Officer may authorize access to files by other people.
4.5. Duty to disclose Information
4.5.1. There is a legal duty to disclose some information including:
4.5.1.1. Child abuse will be reported to the Social Services Department
4.5.1.2. Drug trafficking, money laundering or acts of terrorism will be disclosed to the police.
4.5.2. In addition employees believing an illegal act has taken place, or that a user is at risk of harming themselves or others, must report this to the Chief Executive Officer who will report it to the appropriate authorities.
4.5.3. Users should be informed of this disclosure.
4.6. Disclosures
4.6.1 COMPANY complies fully with the Personal Data Protection Act 2010 of Malaysia (PDPA) regarding the correct handling, use, storage, retention and disposal of Disclosures and Disclosure information.
4.6.2 Disclosure information is always kept separately from an applicant’s personnel file in secure storage with access limited to those who are entitled to see it as part of their duties. It is a criminal offence to pass this information to anyone who is not entitled to receive it.
4.6.3 Documents will be kept for a year and then destroyed by secure means. Photocopies will not be kept. However, WOLCE may keep a record of the date of issue of a Disclosure, the name of the subject, the type of Disclosure requested, the position for which the Disclosure was requested, the unique reference number of the Disclosure and the details of the recruitment decision taken.
4.7. Data Protection Act
4.7.1. Information about individuals, whether on computer or on paper, falls within the scope of the Data Protection Act and must comply with the data protection principles. These are that personal data must be: Obtained and processed fairly and lawfully. Held only for specified purposes. Adequate, relevant and not excessive
4.8. Breach of confidentiality
4.8.1.Employees who are dissatisfied with the conduct or actions of other employees or WOLCE should raise this with their head of department using the grievance procedure, if necessary, and not discuss their dissatisfaction outside WOLCE.
4.8.2. Employees accessing unauthorized files or breaching confidentiality may face disciplinary action.
4.9. Whistleblowing
Where an employee has concerns about the use of WOLCE funds, he or she may refer directly to the Director of Finance or Chief Executive Officer outside the usual grievance procedure. All employees hold the right to inform either his or her manager or one of the trustees if they believe that WOLCE is being brought into disrepute by the actions of another colleague or trustee.
5.0 Non-discrimination & Anti-Harassment
5.1 Equal employment opportunity
It is the policy of WOLCE to ensure equal employment opportunity without discrimination or harassment on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law. WOLCE prohibits any such discrimination or harassment.
5.2 Retaliation
WOLCE encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of WOLCE to promptly and thoroughly investigate such reports. WOLCE prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports.
5.3 Sexual harassment
Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. For the purposes of this policy, “sexual harassment” is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favours and other verbal or physical conduct of a sexual nature when, for example:
a) Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment.
b) Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individuals.
c) Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.
WOLCE recognizes two types of sexual harassment:
Quid pro quo.
A hostile work environment.
Sexual harassment may include a range of subtle and not-so-subtle behaviours and may involve individuals of the same or different gender. Depending on the circumstances, these behaviours may include unwanted sexual advances or requests for sexual favours; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body, sexual prowess or sexual deficiencies; leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.
5.4 Harassment
Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, colour, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that:
a) Has the purpose or effect of creating an intimidating, hostile or offensive work environment.
b) Has the purpose or effect of unreasonably interfering with an individual’s work performance.
c) Otherwise adversely affects an individual’s employment opportunities.
Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on company time or using company equipment by email, phone (including voice messages), text messages, social networking sites or other means.
5.5 Individuals and Conduct Covered
These policies apply to all applicants and employees, whether related to conduct engaged in by fellow employees or by someone not directly connected to WOLCE (e.g., an outside vendor, consultant or customer).
Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.
5.6 Reporting an Incident of Harassment, Discrimination or Retaliation
WOLCE encourages reporting of all perceived incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with their immediate supervisor, any member of the personnel practices committee, human resources or any ombudsman. See the complaint procedure described below.
In addition, WOLCE encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behaviour is unwelcome and to request that it be discontinued. Often this action alone will resolve the problem. WOLCE recognizes, however, that an individual may prefer to pursue the matter through complaint procedure.
6.0 Child Protection Policy
6.1 Introduction
6.1.1 WOLCE is committed to protect and to preserve the best interest of children. We work towards safeguarding children from harm by creating a safe and positive environment for children. We take our duty and responsibility of care seriously. Protecting children is an indispensable part of WOLCE achieving its mission.
WOLCE will achieve its objectives of protecting children by being:
6.1.2.1 PREVENTIVE: WOLCE’s programmes and activities must take reasonable measures to ensure risks of harm to children are minimized.
6.1.2.2 REACTIVE: WOLCE representatives must take appropriate action to address concerns and respond promptly and adequately.
This policy is based on child rights conventions, Malaysian legislation and internationally recognized good practice. It also provides a framework of principles, standards and guidelines on which to base individual and organizational practice.
6.2 Purpose & Scope
6.2.1. This policy is designed to provide guidance to all WOLCE representatives whether in Malaysia or elsewhere. Its purpose is to help WOLCE representatives to:
6.2.1.1. Understand the importance of child protection issues.
6.2.1.2. Know their responsibilities and ensure compliance under legal and policy obligations within and outside their work environments at all times.
6.2.1.3. Uphold the dignity and respect of children.
6.2.1.4. Ensure a safe environment for children is created through preventative measures.
6.2.1.5. Provide guidance to those they lead or manage on child protection issues and good practice.
6.2.2. A WOLCE representative can be a staff member of WOLCE, a volunteer, an intern, a third party service provider or anyone representing WOLCE in providing services for children.
6.3 Prevention Policies
6.3.1 This section covers a range of procedures and actions that should be undertaken to safeguard children and prevent abuse from taking place. This summary consists of checklists to ensure the safe selection and recruitment of all WOLCE representatives, reduction of risks when working with partners and alliances and a strict Code of Conduct of acceptable and unacceptable behaviour when having direct and indirect contact with children.
6.3.1.1. Recruitment and selection
6.3.1.2. Best practice requires WOLCE to carry out a range of recruitment and selection checks. The purpose of this Policy is to ensure effective, fair and consistent recruitment processes for all representatives recruited in Malaysia.
6.3.1.2.1. To deter applications from unsuitable people who may seek to gain access to children through WOLCE’s activities.
6.3.1.2.2. To ensure that those who are successful in their applications are safe to work with children.
6.4 Recruitment and Selection Checklist
6.4.1. Candidates should be aware that the position if possible may require a police check.
6.4.2. Candidates should submit and sign their application form.
6.4.3. Candidates will have their employment history checked including the investigation of any gaps between jobs.
6.4.4. Candidates will have their identity checked with original documents.
6.4.5. Candidates should be required to complete a WOLCE Self-Declaration Form.
6.4.6. Candidates will be asked specific child-protection related questions during their interview.
6.4.7. Candidates should provide two or three satisfactory referees (depending on level of contact with children).
6.4.8. Referees will be asked about the candidate’s experience in working with children and to disclose any concerns that they may have about the candidate’s suitability to work with children.
6.3.2 Requirements for WOLCE Working with Partners
6.3.2.1. WOLCE expects all partners such as interns, volunteers and other third party service providers working with WOLCE to consistently apply good practice guidance on child protection to all activities involving children. All child protection concerns must be reported to WOLCE immediately and necessary steps undertaken to address these concerns and any potential long-term effects on the child concerned.
6.3.2.1.1. Be aware and agree to abide by this policy, particularly relevant sections such as the Code of Conduct, Confidentiality.
6.3.2.1.2. Complete and sign the Volunteer Form.
6.3.2.1.3. Always be accompanied by WOLCE staff.
6.3.3. Code of Conduct
All WOLCE representatives are required to understand and abide by a Code of Conduct that outlines rules of appropriate and proper behaviour when working with children. This Code of Conduct is designed primarily to protect children; however it also serves to protect representatives from false accusations.
6.3.4. Acceptable Behaviour & Conduct:
WOLCE representatives should:
6.3.4.1. Be committed to creating a culture of openness and mutual accountability at work places to enable all child protection issues or concerns to be raised and discussed and where abusive behaviour can and must be challenged.
6.3.4.2. Take steps to empower children by informing them of what is acceptable and unacceptable behaviour.
6.3.4.3. Encourage children to raise their concerns about staff or others safely.
6.3.4.4. Conduct a risk analysis when organising activities and programmes involving children and plan for ways of mitigating risks.
6.3.4.5. Ensure that risks of working alone are minimised by ensuring the “two-adult” rule and that they are always visible to others when working with children.
6.3.4.6. Ensure physical contact is at all times appropriate and not an invasion of the child’s privacy.
6.3.4.7. Use positive, non-violent methods to manage children’s behaviour.Raise any concerns of inappropriate behavior immediately.
6.4 Unacceptable Behaviour:
Within and outside their work environments at all times, staff and representatives of WOLCE must not specifically:
6.4.1. Develop physical or sexual relationships with children that they interact, engage or work with.
6.4.2. Behave physically in a manner which is inappropriate or sexually provocative.
6.4.3. Spend excessive time alone with a child, away from others, behind closed doors or in a secluded area.
6.4.4. Take a child to their home or visit a child at their home where they may be alone with that child.
6.4.5. Allow a child to stay overnight at their home unsupervised.
6.4.6. Do things of a personal nature for a child that they could do for themselves.
6.4.7. Engage in sexual activity with a child regardless of the age of consent locally.
6.4.8. Be intoxicated under the influence of alcohol or drugs prior to assuming responsibility for any child.
6.4.9. Hit or otherwise physically assault or physically abuse children.
6.4.10. Act in ways that may be abusive or may place a child at risk of abuse.
6.4.11. Use language, make suggestions or offer advice which is inappropriate, offensive or abusive.
6.4.12. Condone, or participate in, behaviour with children which is illegal, unsafe or abusive.
6.4.13. Act in ways intended to shame, humiliate, belittle or degrade children, or otherwise perpetrate any form of emotional abuse.
6.4.14. Show favour to particular children to the exclusion of others (for example, promising a child gifts and enticements).
6.4.15. Exploit children for their labour (e.g. domestic servants) or for sexual purposes.
6.4.16. Conduct or be part of harmful traditional practices, spiritual or ritualistic abuse.
6.5. Communications Regarding Children
6.5.1. WOLCE is committed to ensuring all interviews and footage of children are undertaken with sensitivity in order to safeguard the child’s right to dignity, confidentiality and privacy. Where possible, children should be prepared for interviews prior to being interviewed.
6.5.2. Children who are not being interviewed or named can be photographed in public places (e.g. in street scenes) without use of written consent forms. Verbal consent from these children will be sought where practical.
6.5.3. Pictures of children should always be decent and respectful. Consent to use information obtained in interviews and/or images of children who have been interviewed should be obtained from children themselves (if they are of an age, understanding and possess the maturity to do so) and from their parents and/or guardians. Consent can also be obtained retrospectively.
6.5.4. When WOLCE wish to use images or information about children, they should assess the risks of harm or stigma to the child as follows:
Level 1 (Low risk of harm or stigma)Faces, first names and geographical location may be revealed.
Level 2 (Medium risk of harm or stigma)Faces, pseudonyms and vague geographical location may be revealed.
Level 3 (High risk of harm or stigma)Faces and visuals to be concealed, pseudonyms to be used and locations will be changed.
6.5.5. Third Party Individuals or organisations requesting the use of any WOLCE resource depicting children, such as personal information, videos or photographs, will be required to sign an agreement with WOLCE as to the proper use of such materials. Failure to adhere to the terms could result in the termination of permission.
6.6. Protecting Privacy & Confidentiality
6.6.1. Over the course of a WOLCE representative’s involvement with WOLCE’s work, he or she may learn of certain facts about individuals serving and other clients being served by WOLCE that are of a highly personal and confidential nature. Examples of such information may include, but is not limited to, children identities, medical condition and treatment, finances, living arrangements, prior abuse/exploitation/trauma, legal status, employment, sexual orientation, addresses, phone numbers, etc.
6.6.2. WOLCE representatives should:
6.6.2.1. Understand that all such information must be treated confidentially and that any breach may result in termination of services by WOLCE.
6.6.2.2. Agree not to disclose any information of a personal and confidential nature to any person not affiliated with WOLCE and/or authorised to be released by WOLCE without specific permission.
6.6.2.3. Agree that the use of confidential information is only to the extent necessary to perform the authorized duties given and in doing so must uphold the best interest of the client.
6.6.2.4. Agree to not use any confidential information in a way that would be harmful to the client or WOLCE.
6.6.2.5. Ensure all confidential documents are stored in a manner as prescribed under the guidelines of WOLCE.
6.6.2.6. Agree to talk with assigned WOLCE’s staff in any situation in which the representative may have questions about confidentiality issues, or possible violations of these issues.
6.6.2.7. Agree that when the relationship with WOLCE ends, the representative will continue to honor the confidentiality of any client specific information he or she may have learned.
6.7. Intervention
This section looks at what to do when a child tells you they have been abused. It highlights the indicators of abuse so that you are aware of what to look for when a child discloses they have been abused. It also looks at the types of disclosure you may expect, and what the steps are for managing the disclosure.
6.7.1. Indicators of abuse
Representatives of WOLCE should be aware of some of the indicators of abuse and neglect, so that concerns can be raised. These signs and indicators should never be ignored, but equally they do not always mean a child has been abused, as other explanations are possible.
6.7.2. Disclosure of abuse
WOLCE is committed to acting upon and investigating disclosures (i.e. when a specific allegation of abuse is made against a named individual) and suspicions (i.e. when concern is expressed or observed that abuse may have taken place) swiftly. At all times, the welfare of the child is of paramount consideration.
6.7.3. Managing disclosure from a child
6.7.3.1. Listen to the child and accept what is being said. Allow the child to speak freely, asking open questions only to establish the basic facts or nature of the complaint.
6.7.3.2. Reassure the child that they have done the right thing by disclosing. Take the allegation seriously.
6.7.3.3. Avoid promising the child total confidentiality as it is a child protection matter and the child may still be at risk.
6.7.3.4. Explain your responsibility to pass the information to the authorised officer in charge of child protection (if unavailable, then to the relevant government agency)
6.7.3.5. Avoid gossip and making assumptions. Additionally avoid investigating, informing or confronting the Subject of Complaint or alleged perpetrator(s).
6.8. Reporting mechanism
6.8.1. There are three types of reports that can be made:
Reports concerning a staff or representatives of WOLCE.
Reports concerning a partner or a volunteer.
Reports relating to child abuse in the community or an institution.
6.8.2. To make a report concerning a staff or a representative of WOLCE, please e-mail complaints@wolce.org or contact a staff person.
6.83. To make a report related to a child abuse you have witnessed in the community or an institution, please call the police hotline at 999 or Talian NUR at 15999. In an emergency situation where a child is in need of immediate medical assistance, refer to the nearest hospital emergency department urgently.
6.9. General Rule
6.9.1. All WOLCE representatives have a duty and right to report a suspected incident of child abuse directly to their superior or the authorized officer in charge of child protection. Failure to do so may result in disciplinary action.
6.9.2. Responsibility to report and duty to cooperate
Identities of informants will be confidential, particularly where there may be safety issues. The Subject of Complaint (or alleged perpetrator) and all witnesses must cooperate with internal and external investigations and hearings. This will ensure that they will be provided an opportunity to present their side of the story.
6.9.3. Duties of the Authorised Officer in Charge of Child Protection
6.9.3.1. Within 24 hours of receiving a complaint with regards to this policy or information on an allegation of child abuse, WOLCE shall convene a Child Protection Meeting to obtain further information, assess the concern, take next steps and inform the authorities if necessary.
6.9.3.2. WOLCE will appoint and delegate the investigation to a Child Protection Investigating Officer if the matter is in breach of this Policy and therefore requires further investigation.
6.9.3.3. WOLCE will monitor the progress of the investigation and give guidance as appropriate and make recommendations pending the outcome of the child protection meeting and investigations carried out based on what is in the best interest of the child(ren).
6.9.4. GENERAL RULE
Focus the Child Protection Investigation on establishing the facts of the matter and gathering evidence to either substantiate or refute the allegations made against the subject of complaint (alleged perpetrator).
6.10. Implementation, Monitoring and Review of Policy
This section looks at how the policy can be communicated to everyone who represents WOLCE to ensure they understand their roles and responsibilities.
6.10.1. WOLCE will take the following measures to support effective implementation, monitoring and review of this policy:
6.10.1.1. Child protection will be communicated as ‘everybody’s responsibility’.
6.10.1.2. Emphasis will be placed on managers’ responsibilities to ensure that protection measures are put in place.
6.10.1.3. Recruitment procedures will include police and reference checks on suitability for working with children.
6.10.1.4. Induction of representatives will include mandatory briefing and training on child protection issues.
6.10.1.5. Wide distribution and dissemination of a summary of the policy with access to the full policy electronically.
6.10.1.6. All representatives will be required to sign an Acknowledgement and Consent to agree to the terms of this Policy prior to their appointment.
6.10.1.7. Integrate child protection measures into all core internal processes (e.g. planning, programme design, risk management, monitoring and accountability mechanisms, performance management etc.).
6.10.1.8. All recorded incidents must be recorded and lessons learned from these incidents must be incorporated into the Child Protection Policy to prevent repeat of such incidents.
6.10.1.9. Child Protection Policy must be reviewed every three years or sooner as and when required.
6.10.1.10. For further information regarding our child protection policy, please write to: info@wolce.org
7.0 Complaint Procedure
Individuals who believe they have been the victims of conduct prohibited by this policy or believe they have witnessed such conduct should discuss their concerns with their immediate supervisor, human resources, any member of the personnel practices committee or any ombudsman.
WOLCE encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, while no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.
Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.
WOLCE will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.
Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.
Misconduct constituting harassment, discrimination or retaliation will be dealt with appropriately. Responsive action may include, for example, training, referral to counselling or disciplinary action such as a warning, reprimand, withholding of a promotion or pay increase, reassignment, temporary suspension without pay, or termination, as WOLCE believes appropriate under the circumstances.
If a party to a complaint does not agree with its resolution, that party may appeal to WOLCE’s Vice-Presidents or the chief executive officer.
False and malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action.
WOLCE’s commitment to integrity and human rights is a fundamental value that reflects our purpose and the conscience we follow. It is core to who we are and how we operate.
We want to hear from you regarding our Code of Conduct and Ethics, and other ethics and compliance matters, so we have made a form that directly goes to our Human Resources department.