SHEA Policy

Prevention of Sexual Harassment, Exploitation and Abuse Policy

Board Approved May 27, 2021

Policy Statement

The Stephen Lewis Foundation is a progressive, feminist organization rooted in the principles of social justice, international solidarity and substantive equality.  We are ideologically self-aware and we actively strive to meet the highest ethical and human rights standards in all of our work, including our policies and processes.  We feel deeply accountable to the people and organizations we work with in Africa, and the care, intensity and imagination and sense of urgency with which we carry out this works reflects the depth of our commitment and the dedication of our staff members, volunteers and supporters.

The Stephen Lewis Foundation is committed to maintaining a workplace and project partnerships that are free from sexual harassment, exploitation and abuse (SHEA). This policy aligns with the SLF’s Code of Conduct and also aligns with the United Nations Declaration of Human Rights, the UN Convention the Elimination of All Forms of Discrimination Against Women, the UN Convention on the Rights of the Child, and the Yogyakarta Principles on the Application of International Human Rights Law in Relation to Sexual Orientation and Gender Identity.

The SLF has a zero-tolerance policy toward sexual harassment, abuse and exploitation. We believe that people have the right to live their lives free of violence, harassment and abuse regardless of gender, gender expression, gender identity, sexuality, sexual orientation, age, HIV status, disability, race, religion or ethnic origin. We recognize that there are unequal power dynamics across the organization in relation to our partnerships stemming from the history of colonization. The SLF will not tolerate sexual harassment, exploitation or abuse carried out by any of its employees, consultants, board members, partners or any other representative of the organization.


This policy applies to all SLF employees, consultants, interns, Board members and volunteers (collectively referred to as ‘representatives’).  This policy also applies to partners and vendors/suppliers working with the SLF as part of a partnership or vendor agreement.


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

Sexual abuse: Actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual Exploitation and Abuse also includes sexual relations with a child, in any context, defined as a person below the age of 18 years.

Sexual harassment: Any conduct, comment, gesture or contact of a sexual nature that is likely to cause offence or humiliation or that might, on reasonable grounds, be perceived by the person as placing a condition of a sexual nature on employment or on any opportunity for support or services.  Sexual harassment may take several forms, including unwarranted physical contact, repeated unwelcome overtures or requests of a sexual nature, intimidation (whether explicit or subtle), retaliation or threat of retaliation, repeated gazing or staring at a person’s body, jokes with sexual undertones.

Complaint: A complaint is an expression of dissatisfaction that requires a response, made either orally or in writing.

Complainant: The person who puts forward the complaint.

Respondent: The person against whom the complaint has been made.

Witness: A person who may not be directly involved in the complaint but was witness to the incident.


1) Education and Training

The Stephen Lewis Foundation is committed to promoting a safe environment for its staff, consultants, board members, volunteers, supporters, and partners and their clients. All new staff, consultants, board members, project partners and volunteers will receive information on this Policy. This Policy will also be shared publicly on the Stephen Lewis Foundation website: Ongoing training will be provided to the SLF team as part of the annual learning plans.

2) Reporting

The SLF is committed to responding to all complaints received with respect to sexual harassment, abuse and exploitation. To that end, it has established a reporting system for reports regarding any type of behaviour in contravention of this policy.

a) Reporting principles

A survivor, witness or person with information or a concern may bring forth information about an incident of sexual harassment, abuse and exploitation. There is no obligation for an individual to report any incident that has happened to them.

There is no time limit for reporting of SHEA.  However, given the reliability of recall, the availability of witnesses and the time needed to gather evidence, the sooner SHEA is reported the better the Foundation is able to deal with it.

In responding to SHEA issues, the SLF may not be in the best place to ascertain if a person has been abused, in which case referral to a relevant authority may take place.

If a staff person receives a report of SHEA, the staff person is responsible for ensuring that senior leadership receives the report immediately and may assist in ensuring the safety of those involved, the prevention of further incidents, and the assessment of risk to others who might be vulnerable. It is not the staff person’s responsibility to investigate the claim. 

Everyone who works on behalf of the SLF is required to report any suspicions or incidences of SHEA. They are not required to name the survivor if the survivor would like to remain anonymous. Failure to report suspicion of SHEA relating to someone else is a breach of this reporting procedure and may lead to disciplinary action being taken against employees and the termination of the SLF’s relationship with non-employees.

b) Reporting by staff or other representatives of the Stephen Lewis Foundation

  • The SLF and its staff will work to create an environment where all employees feel comfortable and able to report incidences of SHEA.
  • Incidents of SHEA can be reported orally or in writing. A reporting form is included to guide a written report, but its use is not mandatory.
  • The complainant who is reporting an actual or suspected incident of SHEA, should report that information to the Executive Director ( or the Senior Advisor of Human Resources ( or report the incident to any director or supervisor to whom the complainant is comfortable making the disclosure. If the complainant is not comfortable reporting directly to an individual, they may complete an anonymous report at
  • The report of the incident should ideally include the following information:
    • Name of the person who has experienced the SHEA and contact information
    • Name of the alleged harasser, position and contact information if known
    • Names of any witnesses or other persons who may have relevant information to share about the incident and contact information, if known.
    • Details of what happened including dates, location, frequency.
    • Any supporting documents or evidence that the person submitting the complaint may have in their possession that are relevant to the complaint.
  • The Incidence report will be used to launch the investigation procedure. These procedures will be led by the Senior Advisor of HR working in collaboration with the Executive Director and other members of the Directors team or a Co-Chair of the Board when appropriate.
  • The incident report and the investigation procedure and outcomes will be clearly documented.
  • If the subject of the SHEA complaint is a member of the senior leadership team, the employee or representative should contact a Co-Chair of the Board of Directors.
  • All incidents or complaints of SHEA will be kept confidential except to the extent necessary to   protect employees to investigate the complaint or incident, to take corrective action or otherwise as required by law.
  • Employees and representatives who feel that their safety or the safety of others is in serious and immediate jeopardy should contact the appropriate external authorities. Such cases are to be communicated to the appropriate focal points (Senior Advisor HR, Directors or ED) within the Stephen Lewis Foundation as soon as it is safe to do so.
  • It is a violation of this policy for any employee to communicate a report claiming an occurrence of SHEA or conduct that the employee knows to be false.

c) Reporting by Partner representatives or their clients

Representatives or clients of organizations partnered with the Stephen Lewis Foundation who experience an incident of SHEA by an SLF employee or representative are encouraged to report the case to an SLF staff director, or to any other representative of the Foundation to whom the survivor is comfortable reporting. A case may be reported using the survivor’s preferred language.  The SLF will arrange for confidential translation services if required.

3) Responding to Reports

The SLF will respond in a professional and timely manner to all concerns or allegations of sexual exploitation or abuse.  All concerns or allegations will always be taken seriously, and investigated and acted upon where appropriate, in line with our principles. The best interest and welfare of the SHEA survivor are paramount.

The SLF has a legal and ethical obligation to report immediately to the authorities any incident involving a child (a person under the age of 18).

a) The investigation will be led by the Senior Advisor of HR working in collaboration with the Executive Director and other members of the Directors team or a co-Chair of the Board when appropriate. The following procedure will apply to any investigation:

  1. If necessary, the SLF may engage outside assistance or request the use of our legal counsel.
  2. Following the receipt of a report of potential SHEA, the respondent will be informed of the complaint.
  3. The respondent will be invited to reply in writing to the complainant’s allegations, and the reply will be made known to the complainant before the investigation proceeds further.
  4. Individual interviews will be held with the complainant, the respondent, any witnesses and any other persons who may have knowledge of the incident(s) related to the complaint or any other similar incidents.
  5. If it is determined that sexual harassment, exploitation or abuse has occurred, appropriate measures will be taken. These may include disciplinary action up to and including dismissal. When appropriate or required by law the necessary authorities will be notified.
  6. Where it is determined SHEA has occurred, a written report of the remedial action will be given to the complainant and the respondent.
  7. If the respondent is disciplined, the incident will be documented and filed in their employment file in accordance with Human Resources documentation procedures.
  8. The SLF will maintain documentation relating to the report, investigation and any remedial action taken in a secure manner and in accordance with its record keeping procedures and applicable law.
  9. The complainant will be kept informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions.

b) Variation in Process

The procedures and steps set out above, and the method in which an investigation is carried out, is intended to be flexible in order to respond to the specific circumstances at issue in each case. The SLF reserves the right to engage in a different procedure as it deems appropriate in any given circumstance, or as required by applicable Ontario or local law in the jurisdiction in which the conduct complained of occurred. Any variations to the procedures outlined above will be guided by the principles set out in the policy statement, with best interest and welfare of the survivor being paramount, and will be fully documented.

4) Confidentiality

Complaints can be made anonymously.  Every effort will be made to maintain confidentiality throughout the complaints process. Information that identifies individuals involved in a complaint will be limited to essential personnel and will not be shared further without obtaining the informed consent of those involved, except if someone’s life is at risk, a child is at risk, or as required to by law, without legal counsel and where safe to do so.

5) Support for survivors

Survivors of SHEA are entitled to specialised support services.  The SLF commits to refer survivors to competent support services as appropriate and available and according to the wants and needs of the survivor. Support may include specialist psychosocial support such as counselling, medical assistance, legal counselling and access to the SLF’s Employee Assistance Program (where applicable). 

6) Partnerships

The SLF will ensure that when engaging in partnerships, including program partners and vendors, these agreements incorporate this Policy as an attachment, include the appropriate language requiring that the partner, their employees and volunteers abide by a Code of Conduct that is pursuant to the standards of this Policy, and expressly state that the failure of those organizations or individuals to take preventative measures against SHEA, to investigate and report allegations, or to take corrective actions when SHEA has occurred, shall constitute grounds for the SLF to terminate such agreements.

Where the SLF receives a complaint about a partner organization, the SLF will expect the partner to respond safely, quickly and appropriately.  The SLF will assist the partner to ascertain its reporting obligations if necessary.  Where appropriate, the SLF will work with the partner to address the issue through an appropriate independent investigation.  If the outcome is that abuse has occurred, ongoing work with the partner cannot involve the individual(s) concerned.  If there is reason to believe that an allegation of abuse has not been dealt with appropriately by a partner, then they risk withdrawal of funding or ending the relationship (including networks and consortia).

7) Retaliation

The SLF will not tolerate any form of reprisal for persons who make a disclosure, report or complaint, as well as anyone else who is involved. The SLF will take action against anyone, whether they are the subject of a complaint or not, who seeks to carry out retaliatory action against complainants, survivors, or other witnesses. Employees involved in retaliatory action will be subject to disciplinary action, up to and including termination of employment.  Others who work with the SLF that are involved in retaliatory action will have their relationship with the SLF terminated.

8) Relation to Related SLF Policies and Procedures

Other policies and procedures that should be considered in alignment or support of this policy and related procedures include the SLF Human Resources Policy, Code of Conduct, Whistleblower Policy, and Policy on Workplace Violence and Harassment.

9) Policy Responsibility and Review

The SLF’s Board of Directors approves and reviews the organizations’ key policies, including this PSHEA policy, every three years or sooner if necessary. Any significant amendments to the PSHEA requires the approval of the Board of Directors.

The SLF staff and management are responsible to adhere to and actively support the implementation of this policy.