Safeguarding Integrity: Protection from Sexual Exploitation, Abuse, and Harassment (PSEAH)

At HealthCare Innovation (HCI), safeguarding is not only a policy — it is a core value.
We are committed to ensuring that all individuals who interact with our cluster — including employees, trainees, innovators, partners, healthcare professionals, and patients — are protected from Sexual Exploitation, Abuse, and Sexual Harassment (SEAH).

This page outlines HCI’s Zero Tolerance Policy, reporting mechanisms, and obligations for all stakeholders.

1. Zero Tolerance Policy

HCI enforces a strict Zero Tolerance policy for all forms of Sexual Exploitation, Abuse, and Harassment (SEAH).

This policy is based on:

• Tunisian Organic Act 2017-58 on the elimination of violence and sexual harassment

• International best practices (UN PSEA, WHO, World Bank, EU frameworks)

HCI strictly prohibits:

• Any sexual activity with minors

• Any form of sexual exploitation or abuse

• Any exchange of sexual favors for employment, training, opportunities, money, or services

• Any unwanted sexual advance, comment, gesture, or behavior

• Any sexual relationships involving coercion, intimidation, or abuse of power

• Retaliation against individuals who report or participate in investigations

Violation of this policy leads to immediate disciplinary action, contract termination, and potential legal referral.

2. Scope of Application

This policy applies to everyone working with or on behalf of HCI:

• Full-time and part-time employees

• Consultants, contractors, and volunteers

• Startup founders and team members in HCI programs

• Healthcare professionals and researchers participating in our activities

• Partners, suppliers, event speakers, and collaborators

• Visitors and trainees in our Living Lab or training spaces

Compliance with PSEAH principles is a mandatory condition for participating in any HCI-funded or HCI-supported initiative.

3. Definitions

3.1 Sexual Exploitation

Any actual or attempted abuse of a position of vulnerability, power, or trust for sexual purposes, including profiting from another person’s vulnerability.

Examples include:

• Requesting sexual favors in exchange for opportunities, services, or support

• Using authority to pressure someone into sexual acts
  

3.2 Sexual Abuse

Actual or threatened physical intrusion of a sexual nature, whether by force, coercion, or unequal conditions.

Examples include:

• Rape, assault, or forced sexual acts

• Sexual acts performed without clear, freely given consent
  

3.3 Sexual Harassment

Any unwelcome sexual advance, verbal or non-verbal conduct, or physical behavior of a sexual nature.

Examples include:

• Inappropriate comments or jokes

• Sexual gestures or suggestive messages/images

• Unwanted touching, proximity, or persistent attention

• Harassment via social media or digital platforms

3.4 Consent

Consent must be voluntary, informed, active, and reversible at any time.
Power imbalances invalidate the concept of consent (e.g., mentor–mentee, supervisor–employee, evaluator–startup founder).

4. Responsibilities

4.1 All Staff & Representatives Must:

• Treat every individual with dignity and respect

• Avoid any form of sexualized behavior in professional context

• Report any suspected or actual SEAH incident

• Disclose conflict of interest or power imbalance situations
  

4.2 Managers & Supervisors Must:

• Model appropriate behavior

• Ensure safe, inclusive, gender-sensitive work environments

• Respond promptly to reports or concerns

• Never misuse authority or tolerate misconduct

4.3 Partners, Suppliers, and Startups Must:

• Agree to and follow HCI’s PSEAH standards

• Ensure their teams uphold these commitments

• Implement safeguarding measures in their own organizations

• Cooperate fully with investigations

Failure to comply may result in contract suspension or exclusion from HCI programs.

5. Reporting Mechanisms

HCI encourages a Speak-Up Culture based on confidentiality and protection from retaliation.

Anyone can report:

• SEAH incidents

• Suspicion or concerns

• Misconduct by any HCI representative or partner
  

5.1 How to Report (Confidential)

📧 Email: grievance@healthcareinnovation.tn
This inbox is monitored exclusively by HCI’s Ethics & Safeguarding Committee.

5.2 Confidentiality Guarantee

• Reports are handled with strict confidentiality

• Only authorised safeguarding officers access case information

• Personal data is protected under Tunisian law and GDPR

5.3 Protection from Retaliation

No individual will face punishment, demotion, exclusion, or harassment for reporting in good faith, even if the allegation is not confirmed.

5.4 Anonymous Reports

Anonymous reporting is accepted.
However, providing contact information can help ensure effective support and follow-up.

6. Response & Investigation Process

When an allegation is received:

6.1 Immediate Steps

• Acknowledge receipt to the complainant (when possible)

• Assess immediate safety needs

• Take protective actions (e.g., removal of accused from duty, safe environment arrangements)
  

6.2 Investigation

• Conducted by trained safeguarding personnel

• Based on principles of fairness, neutrality, and respect

• May involve external independent investigators if required
  

6.3 Actions & Sanctions

If misconduct is confirmed, actions may include:

• Written warnings

• Mandatory training

• Contract termination

• Barring from HCI projects or facilities

• Referral to relevant authorities under Tunisian law
  

6.4 Survivor-Centered Approach

The process prioritizes:

• Safety

• Privacy

• Emotional support

• Respect for the survivor’s decisions

7. Prevention Measures

HCI integrates preventive safeguarding measures into all operations:

• Mandatory PSEAH training for staff, consultants, and program participants

• Safe recruitment practices, including reference checks

• Clear codes of conduct and event rules

• Gender-sensitive communication guidelines

• PSEAH clauses in partner and supplier agreements

• Safe spaces for reporting during training and events
• Physical and digital safety protocols

8. Child Protection

HCI strictly prohibits:

• Any sexual interaction with minors

• Possession or distribution of sexualized material involving minors

• Any behavior that places minors at risk

Programs involving minors follow strict supervision and consent procedures.

9. Monitoring, Compliance & Review

HCI’s Ethics & Safeguarding Committee oversees the implementation of this policy through:

• Regular training sessions

• Annual safeguarding audits

• Monitoring of reporting mechanisms

• Updates to reflect changes in Tunisian law or international standards

This policy is reviewed annually or earlier if required.

10. Contact

For safeguarding concerns, reporting, or general inquiries:

• Confidential Email: grievance@healthcareinnovation.tn