Institutional policy · GFM-POL-PEAS-01
Protection Policy against Sexual Exploitation and Abuse (PEAS)
At GENFAMI we have zero tolerance against sexual exploitation and abuse. Here we tell you how we prevent it, how you can report it, and how we support you.
Do you need to report a situation?
You can do it in a anonymous, Without having complete evidence and regardless of when it happened. Your safety comes first.
All information is handled confidentially. See details of the channels in How to report.
FUNDACIÓN PARA EL DESARROLLO INTEGRAL EN GÉNERO Y FAMILIA – GENFAMI is an independent, pluralistic and non-profit institution that focuses its activities on the promotion of human rights and the integral development, social, labor, economic and human of populations affected by social and cultural problems, through gender, ethnicity, family, inclusion and protection approaches.
GENFAMI is committed to the well-being and protection of the participating communities, beneficiaries, workers, contractors, consultants, volunteers, interns, providers, allies and other individuals associated with its programs, projects and services. In the development of this commitment, it adopts an institutional culture of ZERO TOLERANCE against sexual exploitation and abuse (EAS).
GENFAMI recognizes that girls, boys and adolescents may face particular risks of exploitation and sexual abuse due to their age, dependence, developmental stage or unequal power relationship. For this reason, the Foundation guarantees them enhanced protection based on their best interests, their rights, their progressive autonomy and the timely activation of the corresponding institutional and legal channels.
This policy establishes the principles, responsibilities, prevention measures, reporting channels, and general response guidelines of GENFAMI. GENFAMI adopts and explicitly commits to complying with the standards for protection against sexual exploitation and abuse established in the Bulletin of the Secretary-General of the United Nations ST/SGB/2003/13. It is also guided by the six basic principles of the IASC updated in 2019 and, as a related instrument, the Bulletin ST/SGB/2019/8 on discrimination, harassment, including sexual harassment, and abuse of authority. It also incorporates the survivor-centered approach and applicable Colombian standards.
All persons directly or indirectly linked to GENFAMI must know, comply with, and promote this policy and the institutional Code of Ethics and Conduct, regardless of the contractual modality, the place of execution, or the project in which they participate.
Objective of the policy
- 01
Establish a zero tolerance policy against sexual exploitation and abuse (ESA), mandatory for all persons associated with GENFAMI and related personnel, ensuring that the functions, responsibilities, and standards of conduct regarding ESA are clearly defined.
- 02
Create and maintain a safe environment free of EAS through the adoption of prevention and response measures both within the internal framework of GENFAMI and in the communities where the Foundation carries out its activities.
- 03
Establish the basic framework of GENFAMI to prevent sexual exploitation and abuse and adopt corrective measures in the event of cases of EAS that arise.
This policy will be reviewed on an annual basis no later than 01/09/2027 (or earlier if operational circumstances, regulatory changes, or audit/monitoring findings make it necessary).
Definitions
Sexual exploitation
It refers to any abuse committed or attempted in a situation of vulnerability, of unequal power relations or of trust, with sexual purposes, with the effect, although not exclusively limited to them, of taking advantage of material, social or politically the sexual exploitation of another person.
Sexual abuse
refers to any physical intrusion committed or threatened with physical intrusion of a sexual nature, whether by force, in conditions of inequality or with coercion
Prohibited behavior
It includes sexual exploitation, sexual abuse, discrimination, harassment, sexual harassment, and abuse of authority. Reasonable disagreements about job performance or ordinary work difficulties do not, by themselves, constitute prohibited conduct.
Discrimination
Discrimination, exclusion or arbitrary and unfair distinction based, among other factors, on sex, gender, sexual orientation, gender identity or expression, race, ethnicity, nationality, religion, disability, age, language, social origin or any other protected characteristic.
Harassment
Unwanted behavior that can reasonably be perceived as offensive, humiliating, intimidating, hostile, or degrading and that affects the working environment or the dignity of a person.
Sexual harassment
Unwanted conduct of a sexual, verbal, non-verbal, physical, written or electronic nature that can reasonably be perceived as offensive or humiliating, that conditions labor or contractual decisions, or that creates an intimidating, hostile or offensive environment. It can present as a pattern or as a single incident.
Abuse of authority
Misuse of a position of power, influence or authority to affect the rights, decisions, working conditions or contractual obligations of another person, including intimidation, threat, coercion or blackmail.
Affected person or survivor
Person who is or has been the subject of alleged sexual exploitation or abuse. This policy prioritizes the term “survivor”, without disregarding the applicable legal designations.
Person who reported the incident
Person who submits a report, complaint or allegation to GENFAMI or an associated entity. This may be the affected person, a witness, a family member or any other person who has knowledge or reasonable suspicion.
Person allegedly involved
Person regarding whom an initial report or referral exists. This designation does not imply a declaration of responsibility and due process must be respected.
Girl, boy or teenager
Any person under 18 years of age, regardless of the age of consent provided for by local regulations.
Collaborators
Employees, contractors, subcontractors, consultants, interns, apprentices, mission personnel, volunteers and any other person who provides services or acts on behalf of GENFAMI.
Supplier or partner
Natural or legal person who supplies goods or services, carries out activities, manages resources, or participates in agreements, alliances, or agreements with GENFAMI.
Participating or beneficiary community
Individuals, groups or organizations that receive, directly or indirectly, services, assistance or benefits from an intervention, project or program.
PEAS Focal Point
A person formally designated to coordinate the prevention, receipt of reports, activation of routes, referrals, and institutional coordination in matters of PEAS. It does not replace the authorities nor alone concentrate the administrative, contractual, disciplinary, or judicial decisions.
Zero tolerance policy
Institutional commitment according to which sexual exploitation and abuse are prohibited and all reports must be addressed in a timely, confidential, impartial and compliant with applicable procedures.
Gender-based violence
A term that includes violence directed against or disproportionately affecting a person because of their sex, gender, identity or expression of real or perceived gender. Sexual exploitation and abuse constitute forms of gender-based violence.
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Range
This policy is mandatory for all individuals who are part of GENFAMI or act on its behalf, as well as for suppliers, partners, subcontractors and other members of its value chain. It applies to offices, territories, travel, community activities, virtual spaces, trips, events and any other context related to work or the provision of services.
This policy protects all persons who participate in or are associated with the programs, projects, and services of GENFAMI. It explicitly includes girls, boys, and adolescents who participate directly or indirectly in activities, services, assistance, or processes developed by the Foundation or by individuals and organizations acting on its behalf.
When a situation involves a girl, boy or teenager, GENFAMI will apply the principle of the best interest of the child, ensure enhanced protection, avoid actions that could lead to re-victimization, and promptly activate the appropriate institutional, administrative, protection or judicial channels.
Principles of politics
GENFAMI adopts the six basic principles of the IASC related to protection against sexual exploitation and abuse:
The exploitation and sexual abuse by collaborators constitute serious offenses and may lead to the termination of the bond, in accordance with due process and the nature of the relationship.
All sexual activity with persons under 18 years of age is prohibited, regardless of the local age of consent. The mistaken belief regarding age does not constitute a defense.
It is prohibited to exchange money, employment, goods, services, assistance, favors, or benefits for sexual relations or acts, including humiliating, degrading, or exploitative behaviors.
Sexual relations between those who provide assistance, protection or services and a beneficiary are prohibited when there is misuse of rank, power, trust or vulnerability.
Any person linked to GENFAMI who has concerns, suspicions, rumors, or information about a possible EAS situation must report it through the established institutional mechanisms.
Management teams, coordination teams, supervisors and other collaborators must create and maintain an environment that prevents harassment and promotes the effective implementation of this policy.
The institutional response will also be guided by the following principles of the survivor-centered approach:
Security
prioritize the physical, emotional, psychological, and digital protection of the affected person and those involved in the process.
Confidentiality
share the information only with those who need to know it and, when appropriate, with informed consent, except for legal reporting or protection obligations.
Respect and autonomy
consider the will, decisions, rights, dignity, and needs of the surviving person.
No discrimination
to offer equal and fair treatment, without any distinction whatsoever.
Higher interest rates for girls, boys and adolescents
to make decisions that prioritize their integral protection and development.
Due process and impartiality
differentiate between the receipt of the report, the protection, the investigation, and the final decision, avoiding prejudgments.
Obligations of all persons associated with GENFAMI
- a
Knowing, accepting and complying with this policy, the Code of Ethics and Conduct and the other related institutional instruments.
- b
Participate in the induction, training, awareness raising and refresher activities in PEAS.
- c
Report in good faith any suspicion, concern, rumor, complaint, or information related to a possible EAS situation.
- d
Maintain strict confidentiality and refrain from disclosing, commenting on, or reproducing sensitive information outside of authorized channels.
- e
Cooperate with institutional actions and with the competent authorities, within the legal framework and due process.
- f
Identify, prevent and mitigate the risks of EAS in the planning, execution, monitoring and closure of programs and projects.
- g
Refrain from conducting interviews, confrontations, or investigations on their own initiative when they receive a report; their duty is to listen, protect, record the minimum necessary, and immediately report it.
- h
Prevent any form of retaliation against whistleblowers, survivors, witnesses, companions, or participants in the process.
Prevention measures
- a
Conduct regular training and awareness-raising for all individuals associated with GENFAMI, including prior induction or at the start of their activities.
- b
Incorporate PEAS clauses, reporting obligations, confidentiality, no retaliation, and consequences for non-compliance in contracts, agreements, service orders, and binding documents, as appropriate.
- c
Before assigning people to positions, duties, or activities that involve a direct and regular relationship with minors, conduct a check for disqualifications for sexual offenses, with prior authorization, and update it with the periodicity required by Law 1918 of 2018 and the regulations that govern it, modify it, or supplement it, including Law 2375 of 2024 and Decree 1110 of 2024.
- d
Require the signing of the Code of Ethics and Conduct and the applicable PEAS annex, maintaining the corresponding documentary traceability.
- e
Require the completion of the UNICEF course “Prevention of Sexual Exploitation and Abuse (PSEA)” during the first week of onboarding or within the defined institutional timeframe. Official course route in Spanish: https://agora.unicef.org/course/view.php?id=18167 and carry out the PEAS training provided by GENFAMI.
- f
Organize, at the beginning and during each project, information activities with the communities about their rights, the standards of conduct, and the channels to report possible situations of EAS.
- g
Provide accessible, secure, confidential, and context-appropriate reporting mechanisms, without relying exclusively on digital media.
- h
The information and reporting mechanisms must be understandable, friendly, and appropriate for girls, boys, and adolescents, taking into account their age, level of understanding, disability, language, and territorial context.
- i
Include PEAS risk assessment in the planning of activities, space selection, travel, contracting, supplier management, and community engagement. This assessment will include, among other methods, mapping of safety, focus groups or consultations with beneficiary populations and other stakeholders (including women, girls, children, adolescents, and community authorities or leaders), in order to identify the most marginalized and vulnerable groups facing EAS.
- j
Publish and disseminate this policy and its institutional channels in accessible media and in the execution spaces of the projects.
- k
Periodically review the validity of emails, forms, QR codes, physical addresses, responsible parties, and referral routes before publishing them.
5.1 GENFAMI will consolidate and keep updated an institutional PEAS repository that contains the completed commitment documents, socialization records, institutional presentations, and an evidence control matrix, as support for the implementation and dissemination of this policy
5.2Contractual management and third parties
All contracts, agreements, service orders, agreements with suppliers, partners and subcontractors must include clauses prohibiting the EAS, requiring compliance with this policy or equivalent standards, establishing the duty of reporting and cooperation, and defining consequences for non-compliance. The assignment or subcontracting will require prior authorization from GENFAMI and the PEAS obligations must be transferred to any authorized third party.
The responsible areas will incorporate evidence of the implementation of the PEAS clauses, contractual controls, and strengthening actions in compliance and follow-up reports. Good practices can be shared in interagency or coordination spaces, while preserving confidentiality and personal data.
When a provider, associated party, contractor or subcontractor lacks an adequate policy or measures to prevent EAS, GENFAMI will provide guidance and support to formulate and adopt such policies and measures. The failure to adopt preventive measures, the omission to investigate reported incidents, or the absence of corrective measures in the event of confirmed cases of EAS by the entity or counterpart party shall constitute grounds for termination of the corresponding contract, agreement or cooperation agreement.
5.3Selection and secure linking
Before the appointment, GENFAMI will apply a systematic and secure selection procedure that includes, as appropriate: background and disqualification checks, verification of employment references that explicitly check for inappropriate sexual conduct, EAS, sexual harassment or other serious misconduct, and a signed self-declaration from the candidate regarding disciplinary, administrative or criminal sanctions related to EAS, as well as pending investigations or withdrawals that occurred during an investigation.
The Human Resources Manager, with the support of the Administrative and Financial Management and the National Project Coordination, will maintain the traceability of these verifications and keep the selection matrices and supporting documents up to date, with restricted access and protection of personal data.
GENFAMI will include a standard paragraph in all its calls for applications and job advertisements declaring explicitly its zero tolerance policy against sexual exploitation and abuse. Furthermore, as part of the selection interviews, questions will be formulated to explore the candidate’s understanding and commitment to institutional ethics and the prevention of EAS.
5.4Mandatory training and learning management
GENFAMI will have a PEAS training plan applicable to all relevant related individuals and allies. Induction and updates shall include, as a minimum: UN-aligned EAS definition, absolute prohibition of EAS, immediate reporting duty, institutional channels, referral and assistance to surviving persons, person-centered approach, no reprisals, and specific protection guidelines for girls, boys, and adolescents.
The participation and approval of the trainings will be documented through certificates, minutes, checklists, or control matrices and will be stored in the contractual files or project folders. Periodically, GENFAMI will review the learnings derived from the trainings and translate them into adjustments to procedures, materials, supervision, and institutional practices; when appropriate, it will share learnings in interactive spaces without disclosing confidential information.
5.5Uniform territorial implementation and community awareness
Each project and territory must apply the PEAS standards uniformly, adapting them to the context without reducing the minimum safeguards. The opening, execution, and closure of the projects will include the verification of PEAS risks, the availability of reporting channels, responsible parties, accessible materials, and information activities for communities. The dissemination must be carried out through face-to-face means and not depend exclusively on digital tools.
Community actions must ensure that women, men, girls, boys, adolescents, people with disabilities and other groups with access barriers know their rights, prohibited behaviors, the free assistance provided, and safe reporting channels. The territorial teams will periodically verify that the information disclosed remains current and understandable.
5.6Repository, institutional monitoring and traceability
The PEAS institutional repository must maintain, with defined levels of access, the commitment and acceptance documents, induction and training evidence, control matrices, presentations and socialization materials, selection and hiring verifications, channel and directory update records, and other necessary supports to demonstrate the effective implementation of the policy. The National Project Coordination and the human resources manager will periodically review the consistency and validity of these supports and coordinate the corrective actions that may be necessary.
Governance and PEAS roles
The PEAS responsibilities are distributed among the institutional areas and units. The receipt of reports, operational coordination, research, and final decision-making are distinct functions. No person should assume responsibilities that belong to another unit.
The National Project Coordination, with the support of the Human Resources professional responsible for the Administrative and Financial Area, will be responsible for consolidating and keeping the PEAS institutional repository and the evidence control matrix up to date.
6.1Institutional roles
Executive Directorate
Acts as a senior management figure. He or she oversees the implementation of policy, ensures resources, defines or ratifies focal points, adopts or refers decisions as appropriate based on the nature of the link, and ensures coordination with partner entities and authorities.
National Project Coordination
It operates the PEAS institutional channel and supports prevention, training, territorial coordination, route activation, and coordination with partner entities. The name of the person responsible for this coordination is kept up to date in the internal PEAS directory (Annex 1).
PEAS Point Focal Title Holder
He or she will be the person formally designated by the Executive Directorate. He or she receives and manages reports, protects confidentiality, performs the initial security assessment, coordinates referrals, and refers the case to the competent authorities. The nominal designation must be included in an existing internal communication.
PEAS alternating focal point
He or she will be formally appointed to act when the person in charge is unavailable or there is a conflict of interest. His or her appointment and contact details must be communicated internally.
Administrative and Financial Management
It supports verification of links, filing of commitments, administrative and contractual measures, resource management, and other actions that fall within its competencies.
Coordination and territorial teams
The channels disclose information, identify risks, receive reports without investigating or victimizing the victims, take immediate safety measures when necessary, and forward the information to the institutional channel.
Human Resources Manager
It ensures the implementation of safe selection controls, verification of references, background checks, PEAS self-declarations, signature of commitments, and documentary traceability of the individuals involved.
Communications
It supports the development and updating of accessible awareness materials, ensures the consistent dissemination of institutional channels, and coordinates with the territorial teams the adaptation of messages to different audiences.
Committee or Safeguarding Authority
When convened in accordance with internal procedures, it will support the oversight of policy implementation, risk analysis, the recommendation of preventive and corrective measures, and the identification of institutional strengthening needs, without replacing the research or decision-making functions assigned to other bodies.
6.2Institutional channel
- PEAS institutional mail
- estamoscontigo@genfami.org
- PEAS telephone line
- +57 314 8228634
- Cargo
- National Project Coordination
- Punto Focal titular
- View the name and current contact details in the internal PEAS directory (Annex 1)
General procedure for reporting, responding, investigating and assisting
The following scheme summarizes the general route of GENFAMI. Its implementation must be adapted to the circumstances of the case, the protection needs, informed consent, legal obligations, and existing internal procedures.
- 1
One person wants to report an EAS situation and/or another person identifies that someone may be a victim of EAS.
- 2
Decide to report through one of the channels available to the entire population.
- 3
The GENFAMI Focal Point receives the reports and fills out the PEAS Incident Notification Form in the GENFAMI confidential file.
If it is a case under a contract with a United Nations agency, the corresponding Focal Point is contacted.
- 4
The Point of Contact makes contact with the victim/survivor or their family in case they are an NNA to explain the reporting, investigation, and referral process.
- 5
The Point of Contact provides the first psychosocial support and assesses the victim/survivor's needs in order to refer them to the appropriate services.
- 6
In addition, the national route is activated, directing the person to the appropriate service.
National routeHealth sector→Sector protection→Justice sector - 7
The Point of Contact fills out the Referral Form with the consent of the victim/survivor and contacts the relevant entities on the referral list.
- 8
In case the person is not interested in receiving psychosocial support from GENFAMI, they are provided with information about other institutions to which they can go.
- 9
The PEAS Focal Point records in a confidential manner the care and referral actions performed, and forwards the report to the competent institutional body for the assessment of risks, the adoption of protective measures, and the appropriate investigation process.
- 10
The competent authority advances the investigation process in accordance with institutional procedures, ensuring confidentiality, impartiality and due process. During this process, temporary and proportionate protective measures may be adopted, including the suspension of the contractual bond when the risk assessment justifies it.
- 11
Constant follow-up.
- 12
The appropriate disciplinary measures are taken and the case is closed.
Complaint procedures
Anyone may file a report or complaint against collaborators, suppliers, partners, or anyone acting on behalf of GENFAMI when there is a suspicion, concern, rumor, complaint, or information about a possible situation of exploitation or sexual abuse. The person filing the report is not required to have complete evidence to make the report.
There is no internal deadline for reporting. However, anyone connected to GENFAMI must immediately report the situation when they become aware of it, in order to promptly activate protective measures and response measures.
The reporting person should not conduct any investigations, confront the person allegedly involved, or collect additional testimony. They may keep and provide the information they already have available, avoiding putting people at risk or altering possible evidence.
The institutional channels for reporting are as follows:
Online form
Institutional mail
estamoscontigo@genfami.org . The GFM-FM PEAS-01 format or other communication with the available information can also be sent.
PEAS telephone line
Physical delivery
Communication or format in sealed envelope, addressed to the PEAS channel of GENFAMI, at Carrera 15 No. 88-21, office 702, Bogotá D.C.
Coordination and territorial collaborators/collaborators
Communities can approach a person from the GENFAMI team. Those who receive the report should listen respectfully, explain that the information will be forwarded to the institutional channel, record only what is necessary, avoid unnecessary or revictimizing questions, and forward the information immediately.
Channel for girls, boys and teenagers
Girls, boys and adolescents will be able to report a situation directly or through a trusted adult. The person receiving the report must prioritize their safety, listen without conducting interrogations, record only the necessary information, and immediately activate the institutional protection route.
Reports can be anonymous. To facilitate assessment and response, they should include, as much as possible, what happened, when and where it happened, who might be involved, whether there is an immediate risk, and any other relevant information available.
The PEAS Focal Point will immediately activate the institutional route, protect confidentiality, and refer the case to the competent authorities so that, in accordance with the risk assessment, due process, the nature of the relationship, and internal procedures, the appropriate preventive, administrative, contractual, or disciplinary measures are taken. When contact information is available and it is safe to do so, the reporting person or surviving victim will be informed of the receipt of the report and the general steps of the route.
When the situation relates to a project or agreement signed with UNICEF, another United Nations agency or a partner entity, GENFAMI will notify the focal point designated by that entity, in accordance with the applicable agreements, protocols and confidentiality obligations. Personal names or email addresses that may become obsolete will not be included in this policy.
GENFAMI will facilitate the care and support necessary to protect the surviving person, regardless of the final outcome of the investigation. Assistance will not be conditional on filing a criminal complaint or participation in all stages of the internal process.
GENFAMI will disseminate this policy and the channels for reporting in formats accessible to the participating communities, including booklets, workshops, and communication pieces, ensuring that people are aware of and validate the available mechanisms.
In each territory and project, the coordination teams will periodically verify the functioning of the reporting channels, the accessibility of the materials, and the knowledge of the communities. The identified failures must be corrected in a timely manner and recorded in the corresponding PEAS matrix or repository.
The reporting mechanisms of GENFAMI are governed by the principles of security, confidentiality, transparency and accessibility. Transparency implies that user persons receive clear and timely information about how their reports are managed, the general steps of the process and the results that they may legally be informed of, without prejudice to the confidentiality of personal data and sensitive information in the case.
Research and protection measures
The investigation will be carried out by the competent body or team determined by GENFAMI, in accordance with the applicable internal procedure, the nature of the link, the existence of conflicts of interest, and the complexity of the case. The PEAS Focal Point may coordinate the referral and the flow of information, but must not alone concentrate on receiving, investigating, and making the final decision.
The investigation will be conducted in a timely, confidential, impartial and respectful manner, with a focus on the surviving person, avoiding revictimization and ensuring due process for all involved parties.
The information and evidence will be kept under restricted access. It will only be shared with those who have a necessary role in the protection, investigation, decision-making, referral, or compliance with legal obligations.
During the process, the competent authority may adopt temporary and proportionate protective measures, such as contact restrictions, changes in functions or place of activity, accompaniment, operational adjustments, the preventive separation of certain tasks, or other measures permitted by law and by the nature of the relationship. When the risk assessment justifies it, these measures may include the temporary suspension of the contract or relationship of the person allegedly involved, without this implying an anticipatory declaration of responsibility.
Upon completion of the investigation, a report or record of findings and recommendations will be prepared. Administrative, contractual, or disciplinary decisions will be made by the competent institutional authority, in accordance with the applicable procedure, and the PEAS Focal Point will not assume powers that have not been assigned to it.
When the facts may constitute a crime or there is a legal reporting obligation, GENFAMI will carry out or facilitate the referral to the competent authorities, considering safety, the best interests of girls, boys and adolescents, and the legal limits of confidentiality.
The referral of the case to national authorities will require the informed and voluntary consent of the surviving person, unless there is a legal reporting obligation (for example, acts constituting a crime against girls, boys or adolescents) or an imminent risk that requires the immediate intervention of the authorities.
The designated investigators and focal points will receive periodic updates in PEAS, applicable international protocols, safe interviewing, prevention of re-victimization, handling sensitive information, a gender-based approach, protection of girls, boys and adolescents, and a person-centered approach for survivors.
All research must be systematically documented through a secure file or record that includes, as a minimum, the decision to open the investigation, the research plan, the chronology, protective measures, interviews and relevant evidence, analysis, conclusions, recommendations and institutional decision. The records will be subject to access, custody and preservation controls defined by GENFAMI.
When there is a conflict of interest, a lack of independence, insufficient technical capacity, or complexity that exceeds internal capacity, GENFAMI will manage support or referral to a competent external research person or entity, ensuring confidentiality, independence, and a person-centered approach.
Assistance to surviving persons
Upon receiving a report, GENFAMI will conduct an initial assessment of safety and needs, and, as appropriate and with informed consent, provide psychosocial care, legal guidance, health care, protection, shelter, material assistance, nutrition, or other available services.
The assistance and support services will include, among others, immediate medical and health care, hygiene kits, psychosocial and mental health support, legal services, basic material assistance, and specific support — including protection, health and well-being — for children who may be born as a result of a situation of exploitation or sexual abuse. GENFAMI will keep updated the list of local providers of specialized services for adult and child survivors, adapted or based on the service mapping developed by the inter-institutional coordination group of VBG present in the country.
The surviving person will receive clear information about the options, the scope of confidentiality, possible mandatory reporting, and institutional and external channels. Their will will be respected, except when there is a legal obligation or an urgent need for protection.
When the affected person is under 18 years of age, the principle of the best interest of the child will be applied, unnecessary interviews will be avoided, appropriate protection routes will be activated, and the competent authorities will be informed when required by the regulations.
The Administrative and Financial Management, the National Project Coordination, the Executive Directorate and other relevant areas will support the necessary measures within their respective competencies, preserving confidentiality and traceability.
Each project will maintain an updated map or directory of services available for health, mental health, and psychosocial support, protection, justice, legal assistance, shelter, and other relevant supports. The directories and referral forms will be reviewed at the beginning of the intervention, during its execution, and when changes in the institutional offer become known.
All references will be made with informed consent, except for exceptions provided by law or urgent needs for protection, and the shared information must be traceable, the receiving entity, the requested service, and the follow-up carried out must be clearly identified, avoiding the collection or disclosure of unnecessary information.
GENFAMI will strengthen its articulation with inter-institutional mechanisms, national and territorial networks of PEAS, VBG, protection and protection of children, as appropriate, to improve the availability and continuity of assistance, harmonize routes and facilitate integrated responses.
Consequences, not retaliation and corrective measures
When, through the applicable procedure, the occurrence of a prohibited conduct is determined, GENFAMI may adopt the corresponding labor, contractual, administrative or commercial measures, including the termination of the bond, without prejudice to any legal actions that may arise.
GENFAMI may bring the facts to the attention of the competent authorities when there is a legal obligation, a risk to an individual, or the potential commission of a crime, and may support the surviving person in accessing the avenues of justice and protection.
All retaliation against individuals who report in good faith, participate in an investigation, accompany a surviving person, or cooperate with protective measures is prohibited. Deliberately false and malicious reports may be evaluated in accordance with due process; an unverified complaint will not be considered, in and of itself, a malicious report.
In addition to individual measures, GENFAMI must analyze the institutional factors that facilitated the situation and adopt corrective actions, such as adjustments to procedures, training, supervision, controls, risk management, and strengthening channels.
GENFAMI will ensure the continuous monitoring of the implementation of this policy and the periodic training of all staff and allies, as part of the institutional culture of zero tolerance towards exploitation and sexual abuse.
In the event of a confirmed case or a relevant institutional gap, GENFAMI will develop a corrective action plan that identifies the risk or contributing factor, the required measures, responsible parties, timelines, resources, and a follow-up mechanism. The closure of the actions must be documented and verified by the competent authority.
Even when there are no reports of EAS, GENFAMI will conduct periodic reviews of risks and the effectiveness of its preventive controls in programs and projects. The identified mitigation measures will be incorporated into planning, monitoring, contracting, training, and community outreach.
The learnings derived from reports, investigations, monitoring exercises, audits, or risk reviews will be used to strengthen capabilities and adjust procedures, materials, controls, and institutional practices. Any systematization or dissemination of learnings will be done without data that would allow identifying surviving individuals, whistleblowers, witnesses, or persons under investigation.
Regulatory and technical references
Bulletin of the Secretary-General of the United Nations ST/SGB/2003/13, Special measures of protection against sexual exploitation and abuse.
UN Secretary-General’s bulletin ST/SGB/2019/8, Combating discrimination, harassment, including sexual harassment, and abuse of authority.
Six basic principles of the Inter-Agency Standing Committee (IASC) regarding sexual exploitation and abuse, updated 2019.
Guidelines, practical guides and PEAS/PSEA tools from UNICEF and the United Nations system.
Political Constitution of Colombia and norms for the protection of human rights, childhood, adolescence and victims of violence.
Law 1098 of 2006 – Code of Childhood and Adolescence, and regulations that modify or complement it.
Law 1257 of 2008 and other Colombian regulations on the prevention, protection and care of violence against women.
Law 1581 of 2012 and regulatory standards on the protection of personal data.
Law 1918 of 2018, Decree 753 of 2019, Law 2375 of 2024, and Decree 1110 of 2024, regarding disqualifications for sexual offenses against minors.
Criminal Code, Code of Criminal Procedure and other applicable provisions according to the nature of the facts.
Change control and approval
- Version 1.007/01/2022
Development and initial approval of the policy.
Responsible / Source: Luz Helena Rúa M. / Catalina Goss - Version 2.018/03/2026
Update of charges, channels, physical address, numbering, procedure, competencies, protection measures and regulatory references.
Responsible/Source: National Project Coordination; operational and documentary control adjustments - Version 3.031/08/2026In force
Adjustments based on findings and recommendations PEAS strengthening plan UNICEF GENFAMI July 2026
Responsible / Source: National Coordination of Senior Professional Project in Protection, Intercultural Mental Health and VBG
Erika G. Veloza M. / 31/08/2026