Safeguarding Policy

International Women* Space (IW*S) is a self-organised, feminist, anti-racist political group in Berlin with migrant and refugee women and non-migrant women that places human dignity, gender equality, social justice, inclusiveness, and accountability at the center of its work and upholds its commitment to maintaining a safe and respectful workspace.

IW*S has a zero-tolerance approach towards all forms of discrimination, violence, sexual exploitation and abuse, sexual harassment, racism, transphobia, and sexism of any condition and at all levels.

As stipulated in the Elimination of all forms of Discrimination Against Women and the UN Convention on the Rights of the Child, IW*S recognises the universality of human rights and therefore seeks to reduce or prevent threats to the safety, dignity, and well-being of women* and some extent their children, to reduce their vulnerability to such threats, and to strengthen their self-protection capacities.

IW*S Safeguarding Policy is (1) to ensure that IW*S employees and related personnel do not harm women*, vulnerable women* and children; and (2) to ensure that safety risks and cases of misconduct, violence, racism, and discrimination are identified, reported, and addressed in an appropriate and timely manner.

IW*S is committed to ensuring that our organisational policies, protocol, procedures, and actions reflect our commitment to fulfilling this responsibility in a mutually transparent and answerable manner.

Behaviours promoted by the organisation: the Code of Conduct

IW*S, a feminist organisation, is deeply committed to gender equality. Our Code of Conduct helps us to live our values; feminist, anti-racist and political – it states how we conduct ourselves in our work and provides a shared understanding of behaviour and the organisational culture we are committed to. At IW*S, we do not tolerate the use of racist and sexist language, racial and sexist slurs, and racist and sexist behaviour; this includes and is not limited to Anti-Asian, Anti-Black, Anti-Roma, Anti-Semitism, Islamophobia, exclusion, minoritising, racialised misogyny, racialised misandry and masculinity bias, and stereotyping.

All IW*S employees and related personnel must abide by this Code of conduct and therefore commit that they will:

  • Treat everyone with dignity, respect, and fairness
  • Take responsibility for interrupting racist actions and challenging racist thinking and behavior
  • Not tolerate misogyny, homophobia, transphobia, microaggression, harassment, hate speech, intimidation, lewd gestures, abuse, and other forms of discrimination, in-person or online.
  • Acknowledge and recognize women*’s diversity, including power differences and uphold all behaviors that relate to this
  • Show consideration for cultural concerns and differences
  • Report any problems or suspicions that arise regarding sexual abuse, exploitation, or non-respect of the IW*S Code of Conduct
  • Not engage in any form of sexual abuse or exploitation of any persons, online or in-person, including sexual activity with a child (person under the age of 18) regardless of the age of majority or age of consent, considering local regulations, and understanding that ignorance or mistaken belief in the age of a child is not a defence.
  • Not exchange money, employment, goods, or services for sex while on work-related travel or representing IW*S (including sexual favors or other forms of humiliating, degrading, or exploitative behavior)
  • Not engage in sexual relationships with those who benefit from IW*S funding or support or beneficiaries or any relationship that involves, or appears to involve, partiality, preferential treatment, or improper use of rank or position.


IW*S treats breaches of this Code seriously. Failure to comply with this Code may lead to termination of employment. Reporting a Breach of the Code: If you believe someone may have breached the Code, you must register or discuss your concerns. You can discuss the issue with the person involved, seek advice or have a confidential discussion with the Safeguarding policy officers.

A breach of the law will be referred to the police or relevant legal authority. IW*S will report severe violations of this Code to the IW*S Board and other relevant bodies as required.

In accepting my appointment to IW*S, I undertake to discharge my duties and regulate my conduct under the requirements of this Code and IW*S policies.

Name ____________________________ Signature _________________________________


Position ___________________________Date ______ /______ /________


Why is safeguarding crucial?

At IW*S, we want our employees and related personnel to be capable and prepared to act quickly and securely in case of a problem. We take measures to prevent, report and respond appropriately and promptly to harm or abuse. We protect the health, well-being, and human rights of anyone that comes into contact with IW*S, whether it is IW*S Employees and Related Personnel. It is about putting safeguards in place to address that worry, before it manifests, including training staff and volunteers and putting in place a reporting structure and support systems for all people involved with IW*S, including our beneficiaries.

We do this because we want to protect and support all the people involved with International Women* Space – safeguarding is crucial. We commit to promoting safe practices that respect women*, migrants, children, and vulnerable women*s’ physical and mental integrity, space, and privacy, regardless of ability, ethnic origin, religion or belief system, gender identity, sex, or sexual orientation. We will challenge and not tolerate harm, discrimination, inequality, neglect, exclusion, or abuse.
Scope of the safeguarding policy

This policy applies to IW*S employees and related personnel.

The purpose of this policy is:

  • Protect and keep vulnerable women* and their children participating in IW*S’ initiatives and activities safe from harm.
  • To provide the IWS* employees, related personnel, and everyone participating in our work, with the fundamental principles guiding our approach to safeguarding.

This policy applies at:

  • IW*S’ main office and other IW*S project offices
  • Official IWS events organized by IW*S, IW*S affiliates, or projects done in partnership with other organizations and associations;

Objectives of our SG policy:

  • It is everyone’s responsibility to report an incident as part of an on-going process to improve accountability, transparency, fairness and inclusiveness which IW*S is committed to implement.
  • The Complaint Incident and Response Mechanism(CIRM) in our organization and projects enable individuals, groups, initiatives or Networks as well as other partnering political self-organized associations to raise complaints and give feedback on our work and the work of IW*S affiliates.

The benefit for IW*S in receiving complaints/incidents is primarily to:

  • Recognize, promote and protect IW*S related personnel to raise and report a concern or incident and/or complain on IW*S and partner organization’s work
  • Provide general information regarding IW*S procedures for handling, responding and resolving complaints and incident reports
  • Increase quality of relationship and strengthen ownership among stakeholders (IW*S affiliates, projects done in partnership with other organizations and associations) as well as reduce the potential for inefficient or misuse of the resources entrusted to us.
  • Get input to programs and projects, which will improve sustainability in the quality of our social and political work and advocacy

There may be occasions when IW*S does not meet the expectations of all stakeholders, or when we fail to live up to our commitments. When this occurs, right-holders, partner organisations, other stakeholders and IW*S employees and related personnel have the right to share their dissatisfaction



Asylum seeker: A person who has left their country and is seeking protection from persecution and serious human rights violations in another country but who hasn’t yet been legally recognised as a refugee and is waiting to receive a decision on their asylum claim. Seeking asylum is a human right. This means everyone should be allowed to enter another country to seek asylum.

Child: For purposes of this policy, a child is defined as anyone under eighteen years under Article 1 of the UN Convention on the Rights of the Child.

Complaint or an incident: A complaint is an expression of concern or dissatisfaction by an individual or a group related to possible misconduct by IWS. This could be about program activities or the conduct of its personnel, how IWS works with the communities or affected population and partners, or when IWS policies and guidelines need to be respected.

Complainant: This policy refers to the woman*, man*, girl*, boy*, or team of people who lodge(s) a complaint.

Concern: This policy also mentions the word concern. A concern is an informal communication or question/statement made to IW*S regarding a person or some aspect of IW*S’s work. A concern may become a formal complaint after an assessment is made by stipulated officers for this Policy.

Corruption: It is the “offering, giving, soliciting or acceptance of an inducement or reward which may improperly influence the action of any person.”

Criminal Offence: It is understood as deliberate acts that danger any person’s life and physical integrity. It is a breach of one or more State rules or laws that may ultimately prescribe a punishment.

Discriminatory abuse: Is any abuse on the grounds of protected characteristics which include age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

Employees: Any persons or individuals that have entered into legal and binding partnership, sub-grant, or sub-recipient agreements with IWS

Fraud: It is an intentional distortion, deceit, trickery, and perversion of truth or breach of confidence relating to an organisation’s financial, material, or human resources, assets, services, and transactions, generally for personal gain or benefit.

Feedback: Feedback is any positive or negative informal statement of opinion about someone or something – a view shared for information but not to file a formal complaint. A complaint or an incident requires a response, whereas feedback does not.

Gender: Gender refers to the characteristics of women*, men*, girls, and boys that are socially constructed, including norms, behaviors, roles associated with being a woman*, man*, girl, or boy, and relationships with each other. IW*S is dedicated to ensuring our safeguarding approach and response to safeguarding concerns are gender-responsive. Indeed, girls, young women*, transgender individuals, and gender non-conforming individuals may be especially vulnerable and at risk from certain forms of violence, including sexual and gender-based violence.

Gender-based violence: An umbrella term for any harmful act perpetrated against a person’s will and based on socially ascribed (gender) differences between males and females. Acts of GBV violate several universal human rights protected by International instruments and conventions. Many — but not all —forms of GBV are illegal and criminal acts in national laws and policies.”

Grooming: Grooming generally refers to behavior that makes it easier for an offender to procure a child or vulnerable adult for sexual activity. It often involves building the trust of children and their carers or a vulnerable adult to gain access to them to abuse them sexually. For example, grooming includes the provision of or attention paid to a specific child or adult, providing gifts, money, drugs, or alcohol, encouraging romantic feelings, or exposing them to sexual concepts through conversation or pornography. Online grooming is sending an electronic message or series of messages or engaging over an online platform with content that may be indecent to procure the recipient to engage in or submit to sexual activity with another person, including but not necessarily the sender. Both children and vulnerable adults can be victims of grooming and online grooming, with children mainly targeted by online groomers.

Harm: For this policy, “harm” refers to physical or psychological injury or damage to one’s health, survival, development, or dignity.

Intern (Mandatory Internships): An internship is stated as obligatory in one’s examination regulations. Only one internship can be recognized as a mandatory internship during your studies. All other internships are voluntary.

Members: One of the people or groups that belong to or participate in the overall work of IW*S.

Migrants: People who are not asylum-seekers or refugees outside their country of origin. Some migrants leave their country because they want to work, study or join family, for example. Others feel they must leave because of poverty, political unrest, gang violence, natural disasters, or other severe circumstances.

Partners: For this policy, Partners refer to private and public entities, other than Sub-awardees or Suppliers/Subcontractors, with which the IWS has a contractual or mutual agreement and everyday purposes of project activities and implementation.

Operational Complaint: For purposes of this policy, Operational complaints refer to complaints on program activities. It can be any of the following: • Issues of entitlements and commitments not met, • The quality of the service or program delivery, • How a service has been managed, which directly affects the people IWS works with.

Refugee: A person who has fled their own country because they are at risk of serious human rights violations and persecution there. The threats to their safety and life were so significant that they felt they had no choice but to leave and seek safety outside their country because their government could not protect them from those dangers. Refugees have a right to international protection through the 1951 Convention On the Status of Refugees.

Related personnel: Board members, supporters, interns, volunteers, partners, visitors, journalists, photographers, donors, researchers, celebrities, and international and local consultants, in addition to individual and corporate contractors of these entities and related personnel; a person or groups that belong or participate to the overall work of IW*S, who voluntarily undertakes or expresses a willingness to undertake a task or collaboration with IW*S.

Safeguarding Officer: They are the point-person for all staff if safeguarding questions and concerns arise. They are also responsible for ensuring that this present policy is adhered to at IW*S events, on-site and online. IW*S Staff should be trained in Safeguarding and able to take that role during events.

Serious Complaint: For purposes of this policy, A severe complaint is related to a breach of the Codes of Conduct, and if a complaint is an allegation or suspicion of any of these: • A concern about the behaviour of staff • Physical and psychological abuse • Sexual exploitation and abuse (including gender-based violence) • Child abuse/exploitation • Fraud and corruption • Criminal offense.

Self-organisation: At the most superficial level, self-organized groups do not depend on or wait for a manager to assign work. Instead, these groups find their work and manage the associated responsibilities and timelines.

Sexual Abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual Exploitation: any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes, including, but not limited to, profiting monetarily, socially, or politically from the sexual exploitation of another

Stateless person: a person who is not considered a national by any State under the operation of its law (1954 relating to the Status of Stateless Persons). Some seekers, refugees, IDPs, and migrants may be stateless. In Addition, some stateless persons have never crossed borders and find themselves in their “own country.” For individuals, statelessness is often the result of problems in framing and implementing nationality laws. (UNHCR)

Survivors of Gender-based Violence (GBV): Individuals who have experienced a violation of human rights based on gender identities or sexual orientations.

Third parties: Is anyone participating and supporting as contractors or suppliers with IW*S.

Undocumented person: Anyone residing in any given country without legal documentation.

Victim of torture: Anyone who has experienced any form of torture, which is defined as “any act by which severe pain and suffering, whether physical or mental, is intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession, punishing him for an act he or a third person committed or is suspected of having committed, or intimidating or coercing him or a third person.”

Victim or survivor: The terms “victim” and “survivor” can be used interchangeably. “Victim” is often used in the legal and medical sectors. “Survivor” is generally preferred in the psychological and social support sectors because it implies resiliency.

Visitors: Refers to persons visiting IW*S’ offices or programs, including donor representatives, journalists, media, researchers, celebrities, family members, people delivering packages, or to make inquiries.

Volunteers: A person who voluntarily undertakes or expresses a willingness to undertake a task or collaboration with IW*S

Vulnerable woman*: For this policy, “vulnerable woman*” refers to Anyone 18 years or over who -• is unable to take care of themselves/ protect themselves from harm or exploitation, is in a situation of subordination, and therefore experiencing a power differential, putting them at risk. Such vulnerable women* may be at greater risk of abuse and exploitation due to a variety of risk factors, such as (without limitation) gender, gender identity or expression, health issues (including mental health), disabilities, age, sexual orientation, ethnic, geographic or national origin, family status, partnership status, race, religion or belief, economic background, and particular trade or profession, or as a result of the impact of conflict and crisis.

Witness: someone who knows firsthand about a crime or dramatic event through seeing, hearing, smelling, or touching and can help certify important considerations to the crime or event. It is important to remember that a Subject of Complaint is treated as a witness until proven to have committed a breach of conduct or a crime.

Women* (agreed term) (Clients/participants): Aside from gender identities, the term women* is used to describe and define a person who needs IW*S – work, capacity, support, or participation from IW*S projects and benefits from their activities.

Women* with children: women* (see definition above) who participate in IW*S activities and accompany their children.


Roles and responsibilities for safeguarding within the organization

There are four Safeguarding Policy Officers at IW*S:
IWS – Sonya (Primary)
IWS – Lica (Secondary)
BIG – Lucy Nganga
IWS Board – Killa

All inquiries should be sent to the email address:

Safeguarding Policy Officers are responsible for the following:

  • will receive, study and assess the complaint
  • will write an acknowledgment to the complainant
  • will convene a meeting with all SG Officers
  • will identify any possible threats and decide whether to conduct an investigation
  • will prepare the schedule for the whole process
  • will conduct a risk assessment and revise the SG policy annually
  • will organize a yearly training on SG topics

2. Prevention measures

Ensuring that we—paid and unpaid personnel and our volunteers—jointly actively prevent injury, bullying, abuse, and neglect is another aspect of safeguarding. The ability to recognize abuse and misconduct, as well as the ability to orient the person being touched, the person making the report, and any potential witnesses, are all necessary components of prevention.

Recruitment requirements and procedures:

International Women* Space e. V. values an understanding of feminist and anti-racist power analyses in recruitment and includes this within job specifications. Candidate selection is determined by matching the candidate’s skills and experience with the job specifications and the extent to which the candidate reflects IW*S core values. We ensure that core recruitment questions ask specifically about the experience with, and actions on, reports of abuse and exploitation.

Due to the structure of our organization and the differences in background and legal status of the persons we work with and affiliate with (see definitions), IW*S does not include in its recruitment strategies and politics background checks based on information provided by institutions and authorities. We see the politics of avoiding background checks as a way to decrease discrimination in the recruitment process, as we want to give all applicants a fair chance at employment.

We provide absolute transparency during the recruitment process. The credibility of the candidates for employees, supporters, and volunteers is checked through two types of interviews: During the first stage of recruitment, the candidate will be interviewed by the working group, in which the candidate will be active. During the second stage of recruitment, the candidate will be interviewed by the administrative body, with at least two members of the board present.

As part of our recruitment approach, we will include questions around safeguarding as part of the interview process for any role likely to have contact with vulnerable women*, women*, and women* with children as part of our referencing processes.

We will not provide references for anyone dismissed for breaches of our safeguarding and anti-sexual harassment policies and will continue to investigate even if people resign. We will not utilize communications to undermine our safeguarding work, including by praising or recommending any individual who breached our policy.

Onboarding and regular communication, awareness raising and training

All IW*S volunteers, affiliates, and project partner staff members should be informed of and trained on IW*S Safeguarding Policy. They should all read and sign this present policy and the code of conduct before starting their activity with IW*S.

A safeguarding induction meeting will be held at least once per year. The Safeguarding Policy Officers organize the safeguarding induction meeting to run through these policy documents, answer any questions or concerns and introduce essential safeguarding awareness. All employees and affiliates will be encouraged to attend a refresher training every two years.

The Safeguarding Policy Officers will conduct a risk assessment and revise the safeguarding policy annually. Adjustments will be undertaken according to current changes in the visions and missions of the organization or other relevant developments. All existing staff will receive up-to-date information regarding changes in legislation, guidance, and procedures regularly from the Safeguarding Policy Officers.

The IW*S Safeguarding Policy Officers will document the names of the members and affiliates who participated in annual safeguarding training in a list stored in a folder in the IW*S Drive (Folder: Safeguarding Policy)

Working with sub-partners, contractors, and suppliers

International Women* Space e. V. is counting on recognizing and respecting its safeguarding policy with all its network. It will provide support in the process of working with partners based on its needs to safeguard both the interests of the association and the integrity of the employees.

IW*S will ensure adequate safeguarding assessments as part of due diligence processes when considering new and existing partnerships. We will choose our partners based on their commitment to social justice and equality, their organizational values, how they safeguard their staff and program participants, and their suitability to deliver the work we require of them.

We will ensure that when engaging in partnerships, sub-grant or sub-recipient agreements, these agreements:
a) incorporate this Policy as an attachment or otherwise implement reasonable due diligence and monitoring procedures of its sub-awards consistent with this Policy
b) include the appropriate language requiring such contracting entities and individuals, and their employees and volunteers to abide by a Code of Conduct that is according to the standards of this Policy
c) expressly state that the failure of those entities or individuals, as appropriate: to take preventive measures against sexual harassment, exploitation and abuse, and child abuse; to investigate and report allegations promptly; or to take corrective actions when sexual harassment, exploitation or abuse, or child abuse has occurred; shall constitute grounds for IW*S to terminate such agreements
We will work collaboratively to build capacity in our respective organizations to achieve safeguarding commitments.
We will respect our partners, sub-grantees, and sub-recipients and, where possible and necessary, support them in having the skills and capacity to fulfill their responsibilities consistent with this policy.
For vendors, consultants, independent contractors, and the like, IW*S may incorporate a summary of the requirements contained in this Policy as an attachment to any written agreement.

Creating a safe environment
IW*S seeks to provide a safe environment where individuals or groups can voice concerns without fear of reprisal or unfair treatment. IWS is committed to ensuring that people can raise concerns:

  • Without any risk of losing their employment or entitlements or suffering any form of retribution in the networks or workplace
  • Knowing that harassment or victimization will not arise from raising a genuine concern – and if it does, be sure that IW*S will deal with it as a disciplinary action under the appropriate procedure, and
  • Being sure that complaints will be addressed in a confidential manner

IW*S is committed to ensuring that allegations of violations of this Safeguarding Policy are reported, investigated, and responded to in a timely, fair, transparent, and consistent manner.

Any person can raise a complaint/incident: women*, men, non-binary people, girls and boys, who participate in or benefit from any projects or activities directly or indirectly implemented by IW*S, media, partner organisations, donor community, members of the public.

Responsibilities in handling complaints and incidents

All IW*S employees and personnel must report allegations or suspicions of breaches related to IWS’s Code of Conduct. Proven deliberate non-disclosure of such information will lead to disciplinary action. The obligation to disclose such information is included in IW*S’ Code of Conduct.

A complaint or an incident shall be reported as soon as possible after the complainant becomes aware of the concern but not later than 6 (six) months from the date the incident happened. Complaints/Incidents can be made in, but not limited to, any of the following ways:

  • Written (formal letter or email to
  • In-person (to any of the 4 SG officers or board members)
  • IW*S website, where a whistle-blowing form is available (to be developed)

To enable appropriate follow-up, the following information must be provided in the complaint:

  • Name of the person making the complaint
  • Date
  • Name of the person making the disclosure (if different from the person making the complaint)
  • Name(s) of persons present during the incident
  • Date and time of the incident
  • Factual description of the cause for concern
  • Any steps are taken to address the incident

In case an IW*S employee or related personnel receives information informally that could be subject to a complaint/incident, they shall ask if the person sharing the report would like to make a formal complaint and, if needed, assist the complainant in making the complaint.

Complaints/Incidents addressed by this policy:

IW*S will accept complaints related to, but not limited to, the following examples:

  • Suspicions or observations of misbehavior or misconduct by an IW*S employee or persons directly bound concerning the IW*S Code of Conduct.
  • Violation of IW*S’ policies and commitments
  • Any concerns regarding the safety and protection interests of women* and children will always have priority

IW*S will not respond to the following complaints:

  • Complaints against a political standpoint/viewpoint/ opinion taken by IW*S and its projects
  • Offensive complaints that are using inappropriate or abusive language
  • Complaints sent as part of a bulk mail from an unknown source

Steps in processing complaints

IW*S Safeguarding Policy Officers will handle the complaints and other conduct investigations while strictly adhering to IW*S commitments, vision, and policy guidelines.

Throughout the complaint procedure, all steps will be documented in writing in as detailed a manner as possible. The documentation, including the final report and all annexes, will be saved in a secured file with access limited to designated people in IW*S.

IW*S will duly follow these steps:

  • Acknowledging the complaint
  • Upon receipt of a complaint, IW*S safeguarding policy officers will register it and establish if it’s an operational or severe complaint. The complainant will receive a formal confirmation within two days of receiving the complaint and who is responsible as a contact if the complainant has questions or feedback for accountability and transparency. By sending an acknowledgment, IW*S shows that the allegation is taken seriously and handled according to procedures. The acknowledgment letter should briefly state the following:
    • When and how the complaint/incident was received.
    • The procedure that will be followed to handle the complaint/incident
    • The person the complainant should contact regarding questions or feedback

Risk analysis and protection of persons

IW*S will prioritise to assess if the complainant or any other persons are at potential security risk and refer any concerns to competent persons for appropriate actions.

Risk analysis and protection of information

Critical priority will be given to analyse any risk of loss of information that can serve as proof or evidence to the complaint. The IW*S Safeguarding Policy Officers ensure that information is not altered or lost during an investigation and remains confidential.

Determining the need for an investigation

Then the IW*S Safeguarding Policy Officers will conduct a preliminary assessment to determine whether an investigation is warranted, considering – among others – whether the issue falls within their safeguarding mandate and whether the alleged facts could amount to misconduct. Suppose the complaint was made in good faith, not for personal gain, interest, or grudge. In that case, the Safeguarding Policy Officers will assess the integrity of the complaint if it breaches organizational COCs, violates policies and guidelines, and if there exists some sufficient information and evidence.

Investigation process
When the preliminary assessment shows that an investigation is warranted, IW*S Safeguarding Policy Officers will ensure the investigative process involving the following steps: planning, evidence gathering, analyzing, and concluding.
IW*S recognizes risks linked to the investigation of complaints/incidents for the person being “accused,” for the complainant, and staff investigating the case. Therefore, it is vital to continually assess the risks before an investigation and appropriately address them.
The time it takes for each complaint or incident to be investigated and completed will depend on the complexity and character of the case. However, IWS will aim to resolve complaints within 30 working days of receipt, especially in complaints and incidents that do not require investigation. If a complaint cannot be resolved within this timeframe, the complainant will be informed in writing about when they can expect a complete response.

Appeal process
Suppose the Complainant or the Subject of the Complaint is not satisfied with the outcome of the complaint/incident. In that case, s/he/they may appeal to the IW*S SG Policy Officers and the board members within 30 days of receipt of the decision. Should she/he/ they like to appeal, the reasons behind this and any new evidence shall be shared with IW*S. The analyses of the latest information may lead to further investigation.

Identifying and reporting concerns
Anonymous complaints/incidents
IW*S recognizes that people with genuine concerns sometimes cannot speak out because of exceptional circumstances and may wish to file a complaint/incident without revealing their identity. If a person reporting a complaint/incident chooses to remain anonymous, IW*S will only receive the complaint but will not be able to respond to the complainant. However, IW*S investigates anonymous complaints/ incident reports as far as possible. Nevertheless, follow-up actions may be more limited because of the challenge of verifying anonymously reported complaints.

It is important to note that IW*S will treat all reported incidents or complaints with confidentiality, whether written anonymously or not. A complainant’s name or contact details will never be revealed to anyone outside the investigation team (if an investigation is needed).

Malicious complaints/incidents
A malicious complaint is a complaint/incident report that the complainant knows to be false. IW*S operates under the assumption that all complaints/incidents are made in good faith. An investigation must be stopped immediately if an investigation reveals the complaint to be malicious. In case of a malicious complaint filed by an IW*S employee or related personnel, s/he might face disciplinary actions. Reported genuine complaints/incidents that, after an investigation, may be unfounded are not considered malicious.

Complaints that cannot be dealt with by this policy
In the event, a complaint is received which is not within the responsibility and domain of IW*S, such as complaints that are subject to the current investigation by any regulatory body or legal or official authorities, the process of referral shall be made to the relevant body deemed to be appropriate to deal with the complaint. However, IW*S may take disciplinary or preventive measures on the case and conduct an administrative investigation when deemed necessary.

Ensuring Confidentiality
For IW*S, confidentiality is critical to a satisfactory outcome in handling complaints/incidents to protect the privacy and safety of the complainant, the subject of the complaint, and witnesses. The facts and nature of the complaint/incident, the identity of the key participants, and the investigation records are confidential. IW*S will ensure information is not to be disclosed unless the person who has provided the report has given written, explicit consent to disclose the information. This means that access to and dissemination of data will be restricted only to a limited number of authorized staff assigned to conduct the investigation. Any breach of confidentiality may lead to disciplinary action.
IW*S shall only allow disclosure of information regarding a complaint/incident when:
Externally, if it is required by law
Internally, suppose it is required by management in the best interests of the organization and the parties’ best interests. In that case, it is necessary to obtain specialist help for the survivor or advice on the evidence.
Should the matter for the complaint/incident become public at any time, IW*S designated Safeguarding Officers shall act, and disciplinary actions shall be taken. IW*S will not release any details about the complaint/incident.

Learning from incidents through monitoring and evaluating
IW*S understands the importance of learning and improving as an organization and, therefore, shall keep records of all formal complaints received. The use and relevance of the complaints mechanism shall be monitored; in promoting the philosophy behind the procedure throughout IW*S by involvement in training programs and contributing to various means of quality assurance and accountability.
All IW*S employees and the related personnel should be informed of and trained on this Safeguarding Policy and read and sign this present policy before starting their activity with IW*S. IW*S will seek to provide at least one training per year.

A synthesis report of the types of complaints received and the status of their resolution shall be reported annually and be documented for reference exploring in detail how resolved complaints were handled to identify any possible lessons, improvements to complaints handling, or suggestions for changes in practice, as well as good practice examples. IW*S will summarize the organizational learning from complaints handling in the incident’s annual reports without revealing any information about the details of complaints and leaving out any information about the complainant. The focus of the annual report will be on learning for improvements.
This policy will be formally reviewed every year. SG Policy Officers will conduct a risk assessment, revise the safeguarding policy, and consider any previously identified risks. Critical lessons learned and suggestions for improvement will be regarded as appropriate and relevant when upgrading and updating the system.