Preventing Sexual Exploitation, Abuse and Harassment (PSEAH) Policy

What is PSEAH?

The Department of Foreign Affairs and Trade (DFAT) has a policy titled Preventing Sexual Exploitation, Abuse and Harassment (PSEAH). The Policy mandates that all organisations linked to DFAT must comply with the Policy’s requirements by reviewing all current sexual harassment policies and risk management protocols, and take any key steps to manage the risk of SEAH. The policy recognises that the sector has been primarily focused, as in many industries, on an organisation’s response to SEAH and that we must now shift focus to zero tolerance and prevention. 

CISaustralia strongly supports the approach by DFAT and the associated prevention of Sexual Exploitation, Abuse and Harassment. CISaustralia has developed an associated PSEAH policy and support protocols. 

Key Definitions: This Policy uses the following descriptions of sexual exploitation, sexual abuse and sexual harassment, which combine international and Australian definitions:

SEAH – Sexual Exploitation, Abuse and Harassment

Fraternisation  Refers to any relationship occurring in the course of conducting business, that involves – or appears to involve – partiality, preferential treatment or improper use of rank or position including but not limited to voluntary sexual behaviour. It includes sexual behaviour not amounting to intercourse, a close and emotional relationship involving public displays of affection or private intimacy and the public expression of intimate relations. 

Sexual exploitation – Any actual or attempted abuse of a position of vulnerability, differential power or trust for sexual purposes. It includes profiting monetarily, socially or politically from sexual exploitation.

Sexual abuse – The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual offences including but not limited to: attempted rape (which includes attempts to force someone to perform oral sex) and sexual assault (which includes non-consensual kissing and touching). 

Examples of sexual abuse (or assault)

Sexual abuse (or assault) is:

  • Sexual intercourse without consent
  • Oral sex without consent 
  • Anal sex without consent
  • Groping and inappropriate touching of a sexual nature without consent

Sexual abuse (or assault) is not

  • A consensual sexual act or behaviour

All sexual activity with someone under the age of consent (in the law of the host country or under Australian Capital Territory law [16 years], whichever is greater) is considered to be sexual abuse.

Sexual harassment – A person sexually harasses another person if the person makes an unwelcomed sexual advance or unwelcomed request for sexual favours, or encourages in other unwelcomed conduct of a sexual nature, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated or intimidated.

Sexual harassment can take various forms. It can be obvious or indirect, physical or verbal, repeated or one-off and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against students, staff from CISaustralia overseas partners, citizens, Australian University staff, as well as CISaustralia Gold Coast or overseas staff and personnel.

Examples of sexual harassment

Sexual harassment is one-off or repeated incidences of:

  • Unwanted physical contact such as patting, pinching or touching in a sexual way
  • Unnecessary familiarity such as deliberately brushing against a person
  • Sexual propositions
  • Unwelcome and uncalled for remarks or insinuations about a person’s sex or private life
  • Suggestive comments about a person’s appearance or body
  • Offensive telephone calls, texts, emails or social media posts of a sexual nature
  • Subjecting a person to sexually offensive screen savers or images in electronic or other form

 Sexual harassment is not:

  • Sexual contact that has been engaged in with consent of the recipient, when the consent has not been obtained through fear, intimidation, threats, force or where there is a power imbalance in the relationship
  • Flirting that is invited and not unwelcome
  • Attraction or friendship that is invited and not unwelcome
  • Conduct of a non-sexual nature such as unreasonably requesting a person to do a favour that is not sexual in nature (which may be considered harassment or bullying)


CISaustralia has zero tolerance for Sexual Exploitation, Abuse and Harassment. It is  expected that all students, regardless of background or intrinsic characteristics, are able to fully participate in their assigned CISaustralia program and associated activities, and will feel that their contribution is welcomed, valued and supported.  

This policy applies to all people as defined below and meaning all those engaged with CISaustralia’s work.

There are six groups in this policy scope:

  1. CISaustralia staff
  2. CISaustralia Site Directors and / or Coordinators
  3. CISaustralia contractors 
  4. CISaustralia overseas partners and their staff who have an agreement in place with CISaustralia
  5. CISaustralia students
  6. CISaustralia Australian University partners and their staff who may or may not have a formal written agreement in place with CISaustralia

CISaustralia staff and partners are expected to comply with the principles and reporting requirements specified in this policy. 

This policy and its procedures detail CISaustralia’s approach to preventing, reporting and responding to Sexual Exploitation, Abuse and Harassment. 

The CISaustralia Risk Management and Emergency Response Plan is the primary support document for this policy, and should be read in conjunction with this policy and related health and safety support information, including but not limited to the CISaustralia student Code of Conduct and Behaviour Policy.

Supporting Documentation

  • CISaustralia Risk Management and Emergency Response Plan
  • CISaustralia program-specific student pre-departure guides
  • CISaustralia program-specific student pre-departure sessions
  • CISaustralia program-specific student acceptance and enrolment documentation
  • CISaustralia program-specific overseas staff induction and training
  • CISaustralia Student Code of Conduct 
  • CISaustralia Staff Induction Guide and onboard training 
  • CISaustralia Staff HR Guide
  • CISaustralia staff employment contracts
  • CISaustralia On-site Program Coordinator (OPC) contracts 
  • CISaustralia overseas partner agreements  


The policy is underpinned by the five Principles outlined below. The Principles reflect Australia’s International Commitments to address PSEAH and Australian initiatives to reduce violence. 

  1. Zero tolerance of inaction

Sexual Exploitation, Abuse and Harassment are never acceptable. Zero tolerance is not the same as zero incidents. Reports of incidents may increase as improvements to safeguards are made. Increasing reports may indicate growing awareness of SEAH and changing attitudes, with victims/survivors feeling more comfortable to report and action more likely to take place. The reporting of incidents and responses is an indication that the risk of SEAH is being managed appropriately. 

For this Policy, CISaustralia defines zero tolerance as acting on every allegation in a fair and reasonable way with due regard for procedural fairness. 

  1. Preventing Sexual Exploitation, Abuse and Harassment is a shared responsibility

Preventing Sexual Exploitation, Abuse and Harassment is everyone’s responsibility. CISaustralia requires the support, commitment and investment of all its partners and staff for this Policy to be effective. 

  1. Victim/survivor needs are prioritised

Action to address SEAH should be underpinned by a “do not harm” approach prioritising the rights, needs and wishes of the victim/survivor, while ensuring procedural fairness to all parties. This approach:

  • Treats the victim/survivor with dignity and respect
  • Involves the victim/survivor in decision making
  • Provides the victim/survivor with comprehensive information
  1. Stronger reporting will enhance accountability and transparency

Sexual Exploitation, Abuse and Harassment is a failure of responsibility. CISaustralia staff are not only accountable to CISaustralia but also to the students and partners whom the business is intended for. Stronger reporting allows CISaustralia to better monitor PSEAH, understand risk, improve assurance and work with partners and staff to improve systems, and safeguard accordingly. Reporting will also help to focus on the issue by providing a regular prompt that PSEAH is a core obligation of our work.

  1. Gender inequality and other power imbalances are addressed

Gender inequality and other imbalances based on the distinctions of worker/student, ability/disability, ethnic and indigenous status, religion, gender identity and sexual orientation, age, health and poverty can also result in Sexual Exploitation, Abuse and Harassment. The intersection of gender with other forms of inequality can further increase the likelihood of SEAH occurring. Engagement with intended beneficiaries should be based on respect for diversity, promotion of gender equality and social inclusion, accountability and a strong “do no harm” focus.

Exploitative Sex and Relationships

Men and women can be sexually exploited through transactional sex (the exchange of money, employment, goods or service for sex or sexual acts), even in places where sex work is legal. After a crisis, people may engage in transactional sex to generate income and meet basic survival needs. They may not identify with the term “sex worker”. For a person purchasing sex in this setting, it is often impossible to distinguish between exploitative and non-exploitative transactional sex.

Where there are significant power imbalances at play (based on gender, age, ability, social and economic inequality, etc.) the potential for exploitative transactional sex or fraternisation is heightened. 

It is important that CISaustralia staff and partners consider whether the contexts in which they are working give rise to exploitative sex and/or fraternisation.


CISaustralia aims to eliminate all forms of Sexual Exploitation, Abuse and Harassment on its programs and commits to providing a safe, equitable and inclusive environment where students are able to actively participate in their chosen program. CISaustralia actively commits to reducing opportunities for Sexual Exploitation, Abuse and Harassment on programs by having staff and/or partners on site and available 24/7.   Other methods used to promote respectful behaviour on CISaustralia programs include effective communication, policies, training and awareness activities.

Risk Assessment

This policy takes a risk-based approach to PSEAH. CISaustralia staff and partners will assess the level of risk for SEAH occurring as per the CISaustralia Risk Management and Emergency Response Plan.

The CISaustralia Risk Management and Emergency Response Plan lays out the decision-making process and steps involved in assessing a SEAH incident, associated risk and appropriate response.


When alleged incidents are reported, we will work with the individual to track incident management. 

CISaustralia expects two kinds of incident reporting:

  1. Mandatory and immediate (within 24 hours of becoming aware of an alleged incident) reporting by all staff and CISaustralia partners of any alleged incident of Sexual Exploitation, Abuse and Harassment.
  2. Mandatory reporting (within two working days) by all staff and CISaustralia partners of any alleged policy non-compliance.

Who reports
All CISaustralia staff and partners as defined under the policy scope must report any alleged incidents of Sexual Exploitation, Abuse and Harassment or policy non-compliance.

What is reported
Reporting is for any suspected or alleged cases of SEAH perpetrated by anyone in connection with official duties or business.

How to report
All reports of alleged SEAH incidents should be made in line with the CISaustralia Risk Management and Emergency Response Plan.


Instances of Sexual Exploitation, Abuse and Harassment raised under this policy will be treated confidentially. However, when an incident is identified it may be necessary for those managing the incident to reveal its substance to people such as other personnel, partners and external persons involved in the investigation process or law enforcement agencies. 

Where there is a reasonable belief that a criminal offence has occurred, the matter will be reported to the appropriate law enforcement agency while taking into account risks to those who have been affected. When a referral is made to law enforcement, any action by CISaustralia will be in consultation with the Australian University partner and be guided by appropriate law enforcement agencies. Any decision not to refer to law enforcement requires the approval of the CISaustralia Crisis Management Team in conjunction with its Australian University partner and will be documented in order to record the reasons for the decision.

CISaustralia will take all reasonable precautions to store any records or files relating to matters of Sexual Exploitation, Abuse and Harassment securely and to permit access by authorised persons only.

Unauthorised disclosure of information relating to a matter will be taken seriously and may result in disciplinary action, which may include dismissal.

Compliance and Assurance

CISaustralia will monitor compliance through a range of approaches including performance assessments, reviews and due diligence. CISaustralia overseas and Australian University partners are expected to put in place appropriate risk-based measures to ensure they comply with this policy.

Non-compliance with requirements may lead to CISaustralia suspending or terminating an agreement with an overseas or Australian University partner.

Implementation and Date of Effect

The Policy will be implemented from 1st July 2020.

Adventure Awaits

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