1. Purpose

In Tana Copenhagen we won’t tolerate sexual harassment in any shape or form. Our culture is based on mutualrespect and collaboration. Sexual harassment is a serious violation of those principles. Our sexual harassment policy aims to protect all employees in Tana Copenhagen from unwanted sexual advances and give them guidelines to report incidents.

2. Scope

This policy applies to every person in Tana Copenhagen regardless of gender, sexual orientation, level, function, seniority, status or other protected characteristics. We are all obliged to comply with this policy.

We won’t tolerate sexual harassment from inside or outside of the company. Employees, external sub-contractors and clients, everyone interacting with our company are covered by the present policy.*

3. Definition

Sexual harassment has many forms of variable seriousness. A person may sexually harasses someone when they:

• Comment on someone’s looks, dress, sexuality or gender in a derogatory or objectifying manner or a mannerthat makes them uncomfortable.
• Invade another person’s personal space (e.g. inappropriate touching.)
• Make obscene comments, jokes or gestures that humiliate or offend someone.
• Send or display sexually explicit objects or messages.
• Insinuate, propose or demand sexual favors of any kind.

4. How to handle sexual harassment

An employee should never hesitate to express if his/her limits are exceeded. If an employee experience sexual harassment, he/she must clearly communicate that he/she is uncomfortable with the situation, and then report the event to the management team.

It must always be clearly respected if an employee communicate that an act is harassing, even if the accused finds the action innocent.

3.1 If you witness sexual harassment

If an employee is witnessing harassment, it is first and foremost important not to contribute any further to the harassment, for example by laughing. Next, it is the duty of the witness to take a stand against the situation, for example by referring to this policy.

It is advised to talk to the person who is being harassed to clarify if his/her limits have been exceeded. If this is the case, one should help and support his/her colleague to contact the management so that action can be initiated immediately.

4. The procedure

In the event of a complaint / prosecution, as described in this policy, the management will arrange to intervene. The management team will:

• Initiate a dialogue with the employee who has filed the complaint for a detailed description of the event, including who, when and where the harassment occurred
• Initiate a dialogue with the employee/external who is accused, in order to determine whether he / she has the same view on the case
• In some cases it will be necessary to convene possible witnesses to determine whether sexual harassment has taken place.The management will make sure to consider both descriptions of the situation and process the complaint as quickly as possible, while keeping in mind that all parties involved are entitled to a fair treatment.Management will of course display the necessary discretion and protection of the dignity and privacy of the involved. There will not be disclosed any information about the matter to unauthorized persons.Depending on the severity of the event, and the level of supporting documentation, the management selects whether to impose employment law sanctions, relocations, and possibly psychological treatment if needed.

Gender Equality and Social Inclusion (GESI) is a core part of Tana Copenhagen’s work and operations as is evident formour many targeted projects aimed specifically at enhancing gender equality and women’s empowerment as well as inall other projects where we constantly work to ensure a focus on GESI in all aspects of our work.

Tana and its consortium members work on analysing any part of our work against the following questions:

1. What are the contextual and political-economy factors which affect GESI on the given assignment
2. How can we ensure that our work improves the GESI situation in a way that do no harm
3. In what way can we learn and adapt our project as we become more knowledgeable of what works to enhance the GESI agenda

While GESI may not be explicitly referenced in the clients terms of reference, Tana works to ensure attention to the issue in any assignment with a focus on adhering to the human rights commitments.

GESI in research and studies

Research undertaken by Tana in most cases informs policy making and project design. Ensuring GESI in the research and studies undertaken is thus a requisite for ensure that GESI is included in all the other phase of the project implementation cycle. To guide the GESI inclusion in any Tana research, the following questions are sought addressed:

1. What are the more objective GESI issues that needs to be taken into consideration (e.g. literacy rates;women’s and minority groups representation in e.g. parliament and leading positions in government; health indicators; access to finance; laws on inheritance; statistics on gender based violence (GBV); women and minority casualties in conflict)
2. What are the potential political-economic and contextual/conflict factors that inhibits GESI (e.g. women and minority groups access to decision-makers; access to law enforcement; systemic barriers; patriarchal power structures in communities preventing women or minorities from raising their voice; use of women as a part of a conflict settlement bargain (such as replacement brides); clan or ethnic dominance undermining rights of minority clans/ethnicities as well as the gender angle related to this; use of rape as a suppression tool by formal or informal authorities)
3. What opportunities do the political-economy and context include that can improve GESI (e.g. civil society advocates; new social media opportunities; new laws and regulations improving GESI; urbanisation and migration patterns which change women’s and minority groups role in society; women as new bread winnersin situations of conflict; community empowerment initiatives such as revamping formal or informal local authority committees to include women and minority groups)
4. How can the research be designed so that it is inclusive and participator and thus on the one hand ensures that women and minority groups are heard and included sufficiently, while taking ethical considerations to ensure that no harm is done (e.g. ensure proper representation of women and minority groups in research; priorities where feasible anonymity to protect interviewees; be aware of location and/or presence of other members of the community during the research to limit risk of interviewee (this may include moving interview to neutral place or conduct it via Skype); ensure full understanding and consent of the interviewee; adhere to the EU General Data Protection Regulation)
5. How can policy recommendations be presented in a way that enhance GESI yet do no harm (e.g. ensuring ownership to recommendations with key power holders; formulate recommendations so that they focus on opportunities; target recommendation to the right audience)

GESI in the design phase

Based on proper research the design can be made to ensure an enhanced focus on GESI in the targeted project. This means that the research should inform the deisgn and how it will affect women and men as well as minorities in different ways. This includes (but are not limited to):

1.  GESI targeted activities in the project
2. GESI defined outputs and outcomes
3. GESI related indicators
4. Policy on representation of women and minority groups among project staff and management arrangements (e.g. women representation in steering committee)
5. Policy on women and minority representation in capacity development activities (e.g. number of women included in training activities)
6. Monitoring and safeguard design to ensure GESI advancement as well as do no harm and procedures in case there are unwanted adverse effects documented
7. Ensure potential sub-contractor GESI capacity and that monitoring of sub-contractor arrangements are in place vis-à-vis GESI
8. Design adherence and promotion of the human rights conventions and UN Security Council Resolution 1325 and related resolutions on peace, women and security

GESI in the implementation phase

During implementation focus should be on: (a) following up on the GESI commitments in the project design, (b) adapting the project to new GESI opportunities when these emerge. In support of GEIS this includes (but is not limited to):

1. Ensuring GESI capacity among staff
2. Ensure relative representation of women and minorities among project staff
3. Ensure GESI as part of ongoing project progress analysis
4. Report on GESI indicators (e.g. gender segregated data collection and reporting)
5. Monitor women and minorities representation in project activities
6. Ensure GESI reporting is part of steering committee agenda
7. Ensure GESI in policy dialogue with government and other project stakeholders
8. Ensure emergency response preparedness in case of adverse effects on GESI

GESI in monitoring and evaluation

Monitoring implementation (through e.g. third party monitoring) or conducting mid-term or end of project evaluations will by Tana always include attention to GESI whether this is in the project design or not to ensure that GESI lessons learned are documented and fed back to the client.

This is on the one hand ensured by following up on gender and ethnicity disaggregated data, assessing the quality of this and the GESI effect. On the other hand, this is seldom sufficient, so monitoring and evaluation will need to ensure a GESI focus by:

1. Having relative representation of women and minority groups in in the interview samples
2. Assessing project attention to and implementation of GESI activities
3. Assessing possible unattended positive and negative side effects of project on GESI
4. Focusing on the outcome and impact of the project on GESI and not just individual activity inclusion counting

GESI on Tana operations and in the Tana office

The focus on GESI is not only an external part of Tana’s but also and internal focus on our organisation’s own effortstowards enhancing GESI. In practice this means that Tana constantly works towards:

1. Ensuring that there is a strong representation of women and minority goruos on project teams
2. That all project teams include experts with specific GESI expertise
3. That GESI is part of the consideration when finding consortium partners (GESI policies of partners as well as their GESI capacities)
4. Capacity and policies on GESI of sub-contractors
5. Ensuring that Tana always has a strong in-house capacity on GESI
6. Ensuring that GESI assessment is part of the Tana quality assurance process
7. 7)  Ensuring a gender balanced staffing in Tana (currently this balance is 50/50)
8. Encouraging a gender balanced and minority representation in the award of internships with Tana
9. Ensuring that GESI is part of the yearly strategy process of Tana

This Safeguarding policy is intended to outline our organisation’s approach, practice and commitment to ensuring a comprehensively safe environment for all people that the organisation engages with. We intend to share this policy whenever relevant with staff and associated working with and for Tana Copenhagen ApS in order for them to be familiar with Tana’s commitment to safeguarding. This Policy is an overarching umbrella policy, which should be seen in connection to our other policies, guidelines and codes of conduct which guide our work, and which illustrate our ongoing commitment to be an ethical and responsible service provider. Subsequently the “do no harm” principle is recognisedas an important element in the strengthening of our safeguarding system.

1.2 POLICY STATEMENT

Tana Copenhagen is committed to ensuring a safe and trusted environment which safeguards anyone who we have contact with, including beneficiaries, staff and partners. We are committed to fostering an organisational culture that prioritises safeguarding, so that it is safe for those affected to come forward, and to report incidents and concerns with the assurance that they will be handled sensitively and properly. This includes having the adequate safeguarding policies, procedures and measures to protect people and that these are shared and understood.

1.3 WHAT IS SAFEGUARDING?

Tana uses the DFID broad definition of Safeguarding (1): “Safeguarding in its broad sense means protecting people and theenvironment from unintended harm”. We further consider Safeguarding as a threefold commitment that applies across programmes, partners and employees:

1. Prevention – Taking responsibility to identify and minimise the risk of harm to people – particularly vulnerable adults and children – and the environment, in whatever form it might occur to avoid it from happening in the first place. This is closely related to our Gender and Social Inclusion Policy.
2. Protection – Ensuring that we have the adequate, accountable and transparent systems in place to respond, report and learning when risks materialise.
3. Response – Safeguarding that any complain, violation or harm done will be dealt with appropriately and with care by having the right response system. The system should be able to respond to harm caused by sexual exploitation, abuse, harassment or bullying.

The aim of these three pillars is to minimise the likelihood and impact of these actions towards both the aid beneficiaries, and also people who are working in the aid sector. It entails a wide potential range of policies, procedures and activities seeking to address the safety and wellbeing of the people we work with (1.6 presents the associated Tana policies) and ensuring that no abuse of power or relationships will take place (in line with our Sexual Harassment Policy).

1.4 PRINCIPLES OF SAFEGUARDING
The safeguarding principles that will underpin all our due diligence are as follows:

• Everyone has responsibility for safeguarding
• We commit to the principle of ‘Do no harm’
• We take our safeguarding duty of care seriously and are also committed to ensuring that our down-streampartner part of delivery have the necessary knowledge and systems in place to safeguard.
• We act with integrity and in accordance with the human rights-based approach principles of participation,accountability, non-discrimination and inclusion.
• All our activities consider the best interest of children (2) (someone under the age of 18) and other vulnerablepersons. Furthermore, all children and adults shall be treated equally, irrespective of race, gender, religion/or none, sexual orientation or disability.
• In all our work we conduct solid risk assessment and risk management plans, particularly for assignments insensitive contexts or where there is deemed high reputational, ethical or professional risks.
• We are committed to protecting personal and sensitive data in line with our internal data breach guidelines and the European General Data Protection Regulation 2016/679. We have the systems in place ensuring that we can handle confidential and sensitive data both virtually as well as physically. All Tana employees also have the necessary protection programs installed on the computers (including antivirus, anti-spyware and firewallsoftware).

Tana staff are obliged to follow these principles. Our external consultants and partners should also conduct themselvesin line with Tana’s Code of Conduct and policies (see section 1.6)

1.5 REPORTING A CONCERN OR A SUSPECTED BREACH

Tana is committed to spreading the awareness of our Safeguarding Policy and employing a system that permits safe and accessible reporting of safeguarding concerns from employees and the communities in which we work. We have regular staff trainings, were procedures for reporting a suspected breach (or any other related issues such as sexual harassment, ethical, corruption etc.) and associated consultants are clearly informed in their contracts of such reporting mechanism.

Our reporting mechanism is outlined in our Whistleblower Policy and Sexual Harassment Policy. Employees who havea complaint or concern relating to safeguarding should report it immediately to Tana’s Managing Director in person orvia e-mail to eb@tanacph.com. Reports can also be done anonymously via mobile phone (+45 3536 1915) or mail (info@tanacph.com).

1.6 ASSOCIATED POLICIES

The Safeguarding Policy complements our other policies and codes of conduct which guide our work and set out the principles of our professional engagement with clients, partners and beneficiaries. We are committed to identifying safeguarding needs and setting policies for our employees and associates to follow. We also expect our partners and suppliers to apply similar measures within their organisations. This Safeguarding Policy is associated to the following mother Tana policies and codes of conduct, which all apply to all Tana staff and associated consultants:

• Tana Integrity Policy & Code of Conduct
• Tana Gender and Social Inclusion Policy
• Sexual Harassment Policy
• Tana Whistle-blowers Policy
• Tana Privacy Policy
• Research Ethics Policy
• Ethical Guidelines
• Environmental Policy
• Tana’s Security Policy (available upon request)
• Data Breach Guideline (available upon request)
• Tana Quality Assurance Guideline (available upon request)