Preventing Sexual Exploitation, Abuse and Harassment (PSEAH)

1. OVERVIEW

Tupou College (TCT) is a Christian Secondary boarding school for boys of the Free Wesleyan Church of Tonga, offering TVET, National Tongan and International qualifications for students. Its vision is that

“students of Tupou College are able to recognise their full potential and gain the confidence to embrace life and are encouraged with a love of learning”.

Tupou College has more than 1,100 students (aged between 11 and 19) who board during the week at the College and there is a wide range of activities that mould learners to become productive Christians who strive for excellence in all aspects of their lives.

Tupou College (TCT) is committed to ensuring a safe and supportive environment for all students, staff, and the wider community. The College has implemented a PSEAH (Prevention of Sexual Exploitation, Abuse, and Harassment) Policy to prevent and address any forms of SEAH. This policy sets clear guidelines for all staff, students, volunteers, and parents to maintain a respectful environment.

The College prioritizes safeguarding vulnerable individuals, upholding high standards of conduct, and addressing any incidents of SEAH with care and confidentiality. Tupou College aims to create a safe, trusting, and inclusive environment where all members can learn and grow without fear of exploitation or abuse.

2. CHRISTIAN RATIONALE

Tupou College is committed to honouring God by raising leaders who positively impact society, guided by the Great Commandment to love God and our neighbour (Luke 10:27). In this spirit, the College prioritizes the Prevention of Sexual Exploitation, Abuse, and Harassment (PSEAH), ensuring the protection and well-being of all individuals, especially students in our care.

Our procedures reflect love, respect, and a commitment to safeguarding students, staff, volunteers, and the wider community from harm. The College aims to create a safe environment where all are protected from sexual exploitation, abuse, and harassment, and are trained to live according to God’s love in their future roles.

Tupou College adheres to government laws on safeguarding and implements systems to ensure compliance and the safety of all members of the community.

3. PURPOSE OF THIS DOCUMENT

The purpose of having a Prevention of Sexual Exploitation, Abuse, and Harassment (PSEAH) Policy in our organization is to ensure that we create and maintain a safe and respectful environment for all individuals, particularly vulnerable adults and children. At the core of our operations is a commitment to respecting the dignity and basic human rights of every person, ensuring their safety and well-being.

Given the nature of our work, our staff, contractors, and volunteers are often in positions of authority and trust. This makes it crucial to prevent any abuse of power for exploitative or harmful purposes. The PSEAH Policy serves to uphold high standards of personal and professional conduct, requiring all individuals within the organization to act responsibly and ethically at all times.

Sexual exploitation, abuse, and harassment (SEAH) are serious violations of fundamental human rights, and we are committed to preventing such behaviour within our organization. The policy sets clear expectations for how we will respond to SEAH incidents, promoting an organizational culture that prioritizes safeguarding.

Additionally, the policy emphasizes our responsibility to protect those who may be affected by SEAH, encouraging them to report any incidents. We ensure that all reports are handled with the utmost sensitivity and confidentiality, giving survivors the support they need while maintaining trust in the organization.

By implementing this policy, we aim to safeguard vulnerable individuals, uphold human rights, and ensure that our workplace remains a secure environment for all.

4. Scope/Persons Affected

The following (though not limited to) must comply with this Policy in the course of their work and when representing Tupou College:

• All staff of Tupou College – Principal, Executives, Teaching Staff, Support workers and volunteers.
• Any associated person carrying out work for the school including workers under the Free Wesleyan Church of Tonga and parents.
• Any Contractors and their personnel
• Consultants, advisors and contracted individuals that provide services to the School.
• Grant recipients, awardees
• Sponsorship partners
• Partner governments and multilateral organisations
  • Government agencies which have agreements in place with the Australian Department of Foreign Affairs or Australian Volunteers International (funded or unfunded)
  • Multilateral partners
  • Other partner governments.

All of the aforementioned must comply with the standards of behaviour set out in this Tupou College Prevention of Sexual Exploitation, Abuse, and Harassment Policy.

These individuals and groups are expected to act in accordance with the principles and reporting requirements outlined in this Policy. They must also abide by their own relevant policies, international declarations, conventions, agreements and domestic legal frameworks that relate to preventing sexual exploitation, abuse and harassment.

5. Legal Obligations

The legal obligations to ensure the safety of children at school are effected through the Tongan Education Act 2013

6. GUIDING PRINCIPLES

The principles outlined below underpin best practice when developing a PSEAH policy and approach.  

6.1 Zero tolerance of inaction.

Behaviour by member of Tupou College that results in the sexual exploitation or abuse of a child or adult, helps facilitate SEAH or where allegations of SEAH are ignored, will not be tolerated and we will immediately respond and take seriously any concerns raised. The reporting of incidents and responses is an indicator that the risk of SEAH is being managed appropriately.  Zero tolerance is defined as acting on every allegation in a fair and reasonable way with due regard for procedural fairness.  

6.2 Strong leadership to accelerate culture change. 

Strong leadership is essential to set organisational culture, and therefore leaders need to set clear expectations and model respectful behaviour in their interactions at work. This will support communities, victims/survivors and whistleblowers to feel safe, report concerns and be assured their allegations are taken seriously.    

• Strong leaders address SEAH by taking measures to improve diversity and inclusion. This can include:
• strong, actionable human resource procedures that embed gender equality and PSEAH.
• inclusion of PSEAH discussions in board meetings.
• having senior champions responsible for PSEAH and encouraging staff gender balance particularly in senior roles.

6.3 Victim/survivor needs are prioritised.  

A survivor-centred approach puts the safety, wishes and interest of the survivor first, above all other considerations. This means that the survivor should be empowered. They must be in control. What the survivor needs and wants must be at the centre of any assistance we give. This approach:  

• Treats the survivor with dignity and respect.  
• Involves the survivor in decision making.  
• Provides the survivor with comprehensive information.  
• Protects privacy and confidentiality.  
• Does not discriminate based on gender, age, race/ethnicity, ability, sexual orientation, or other characteristics.    
• Considers the need for counselling and health services to assist the victim/survivor with their recovery. 

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

Preventing Sexual Exploitation, Abuse and Harassment is everyone’s responsibility. Real change to reduce SEAH will not occur unless every sector plays a role — government, business, non-government organisations, institutions, communities and individuals. DFAT requires the commitment, support and investment of its partners for this Policy to be effective. All organisations have a responsibility to build their capacity to deal sensitively and effectively with SEAH that occurs in the course of their work.

6.5 Gender inequality and other power imbalances are addressed. 

Tupou College particularly recognises that gender, disability, age, sexual orientation and poverty have powerful intersection points with the likelihood of SEAH. There are also power imbalances at play. Inequalities based on the distinctions of worker/beneficiary; ability/disability; ethnic and Indigenous status; religion; gender identity and sexual orientation; age; health and poverty, can also result in SEAH. The intersection of gender with other forms of inequality can further increase the likelihood of SEAH occurring. 

Tupou College actions promote gender equality, child protection & safeguarding, social inclusion and accountability towards a ‘do no harm’ approach.

6.6  Stronger reporting will enhance accountability and transparency.  

Sexual exploitation, abuse and harassment is a failure of responsibility. Stronger reporting allows an organisation to better monitor SEAH, understand risks, improve assurance and work with organisations to improve systems and safeguards accordingly. Reporting will also help to focus organisations on the issue by providing a regular prompt that PSEAH is a core obligation of their work. 

Tupou College aims to prevent SEAH through implementation of this Policy, communication, training and working collaboratively with all workers and partner organisations to safeguard everyone against SEAH.

7. POLICY

The following list of expected behaviors applies to all Tupou College staff, students, workers, and any associated individuals (e.g. volunteers) in both their personal and professional lives. At all times, staff are expected to:

• Maintain a duty to act in a manner which upholds the values and reputation of Tupou College.
• Undertake to create and maintain a safe and trusted environment that promotes the implementation of this Policy and safeguards everyone from SEAH.
• Comply with all relevant laws of the country of residence, or in which he or she is travelling.
• Be aware that sexual behaviour is an area of particular sensitivity, where conduct may more easily be seen as offensive or be misinterpreted.
• Avoid actions or behaviours that could be perceived by others as sexual exploitation, abuse or harassment underpinned by a ‘do no harm’ approach.
• Ensure personal conduct towards a co-worker/staff/student is not exploitative or such that it reasonably leads to a perception of exploitation.
• Ensure photographs, films, videos, including those in social media posts, present vulnerable people in a dignified and respectful manner and not in a vulnerable or submissive manner. This includes ensuring that vulnerable people are adequately clothed and not in poses that could be seen as sexually suggestive.
• Ensure that social media use and the sharing of photographs, films and videos are underpinned by informed consent principles and documentation of the informed consent.
• Read and agree to abide by the expected behaviours outlined in the relevant code of conduct.
• Immediately report to any members of the Tupou College Senior Leadership Team any concern, suspicion or allegation of SEAH or any alleged policy non-compliance. (Reporting procedures are outlined below).

In addition, Tupou College staff and students must adhere to the following expected behaviours:

• Tupou College staff and students must not engage in sexual relationships with volunteers, downstream partners, beneficiaries, contractors, interns, mentors, advisors, alumni, Council members, or parents as these relationships are based on inherently unequal power dynamics and there is the potential for abuse of power. Such relationships undermine the credibility and integrity of Tupou College.

It is strictly prohibited for any staff employed by Tupou College or associated people and their roles: eg: volunteers, contractors, to:

• Sexually exploit or abuse or sexually harass a child or adult.
• Use their position of trust and authority to request any service or sexual favour from beneficiaries of Tupou College, adults, children or others in the communities in which Tupou College works, in return for protection or assistance, or coerce a person to engage in sexual intercourse or any sexual activity.  
• Exchange or withhold from beneficiaries of Tupou College – adults, children or others in the communities in which Tupou College works – money, food, employment, goods, assistance or services for sex or sexual favours or other forms of humiliating, degrading or exploitative behaviour. 
• Use Tupou College or partner organisation facilities, personnel or resources for the purpose of arranging or facilitating access to sex workers by any person, including visitors to Tupou College or programs. 
• Engage in sexual activity with a child under any circumstance. Even in a country where the age of majority or the age of consent is lower than 18 years, Tupou College workers and volunteers, contractors, grant recipients, downstream partners, board members, mentors, advisors, interns, parents, or any other individuals associated with Tupou College are forbidden to have sexual activity with anyone under the age of 18 years. A mistaken belief that the child is over 18 is no defence. 
• Use computers, mobile phones, video cameras, cameras or other technology inappropriately, or to exploit or harass children and/or adults, or to access or disseminate child exploitative material and/or sexually exploitative material through any medium, including social media.
• Procure sex for others, and/or use a third party to do so.

8. DEFINITIONS

Worker: All staff, consultants, contractors, office volunteers, interns, the  Board, visitors, or anyone engaged to undertake work for Tupou College.

Partner Organisations: Free Wesleyan Church of Tonga and all schools under the Free Wesleyan Church of Tonga.

Safeguarding: Actions, policies and procedures that create and maintain protective environments to

protect people from exploitation, harm and abuse.

Sexual exploitation, abuse and harassment (SEAH) occurs against a child or an adult and can occur between people of the same or different genders. It includes situations such as:

• Sexual exploitation and abuse;
• Sexual harassment;
• Child sexual abuse and exploitation;
• Women and men sexually exploited through sex work;
• Possessing, controlling, producing, distributing, obtaining or transmitting sexually exploitative
• Images of adults and children; and
• Possessing, controlling, producing, distributing, obtaining or transmitting photographs or videos that may not be explicitly sexual in nature or sexually provocative, however they could be considered sexual in nature if for instance the image would likely cause offence, humiliation or intimidation to the subject of the image.

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

Sexual Abuse – the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual Harassment – any verbal or physical conduct or any conduct of a sexual nature that is unwelcome, uninvited or not reciprocated in circumstances in which a reasonable person, having regard to all the circumstances would have reasonably anticipated the possibility that the person harassed would be offended, humiliated or intimidated. This can include unwelcome sexual advances or unwelcome requests for sexual favours or displaying or sending sexually explicit images or asking intrusive questions about someone’s personal life, including their sex life. Sexual harassment can take various forms. It can be direct and/or indirect, physical and/ or verbal, repeated or one-off instances and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against beneficiaries of AVI’s programs, program participants, community members, citizens, as well as employees and workers.

Child Sexual Abuse – the use of a child for sexual gratification by an adult or significantly older child or adolescent. Sexually abusive behaviours can include fondling genitals; masturbation; oral sex; vaginal or anal penetration by a penis, finger or any other object; fondling breasts; voyeurism; exhibitionism; and exposing the child to, or involving the child in, pornography (see Tupou College Child Protection Policy).

Child Exploitation – one or more of the following:

• Committing or coercing another person to commit an act or acts of abuse against a child.
• Possessing, controlling, producing, distributing, obtaining or transmitting child exploitation
• Material.
• Committing or coercing another person to commit an act or acts of grooming or online grooming.
• Using a minor for profit, labour, sexual gratification, or some other personal or financial advantage.

Online Child Sexual Exploitation (or child pornography) – in accordance with the Optional Protocol to the Convention on the Rights of the Child, ‘child pornography’ means ‘any representation, by whatever means, of a child engaged in real or simulated explicit sexual activities or any representation of the sexual parts of a child for primarily sexual purposes.

Child – any person under the age of eighteen (18) years as defined by the Convention on the Rights of the Child irrespective of local country definitions of when a child reaches adulthood.

Vulnerable adults – those aged over 18 years and who identify themselves as unable to take care of themselves/ protect themselves from harm or exploitation; or who, due to their gender, mental or physical health, disability, ethnicity, religious identity, sexual orientation, economic or social status, or as a result of disasters and conflicts, are deemed to be at risk.

Survivor – A person who has SEAH perpetrated against him/her/them or an attempt to perpetrate SEAH against him/her/them.

Young person – a person aged 17 or under.

9. Breach of Policy

Sexual exploitation, abuse, and harassment committed by Tupou College staff, including both paid and voluntary workers, volunteers, and parents, are considered severe misconduct and may result in termination of employment, funding, or services.

Disciplinary actions and possible consequences for breaching the Tupou College PSEAH Policy may include:

• Referral to local law enforcement authorities (as per national and any mandatory reporting laws), where appropriate. 
• Referral to Samoa Police Service.
• internal investigation which may include an externally engaged investigator.
• Perpetrator standing aside with pay pending investigation.
• Performance management and disciplinary action including formal warnings.
• Training, mentoring and support where appropriate.

10. Shared Responsibility

All Tupou College workers are responsible for championing good practice and maintaining an organisational culture that prioritises safeguarding against SEAH. Managers and leaders at all levels have responsibilities to support and develop systems that maintain an environment that facilitates implementation of the PSEAH Policy. This includes ensuring that Tupou College workers and appropriate employed or associated people and their roles: eg: volunteers, contractors, grant recipients, downstream partners etc) understand policy obligations. Managers and leaders must create a safe environment at Tupou College for anyone to come forward and raise allegations or concerns of SEAH and immediately respond to any reports. This will be done by:

• Providing survivors with a safe (and protected) space, where survivors can speak.
• Ensuring informed consent, confidentiality and data protection with any recording and sharing of information.
• Offering referral to counselling and other support services, in line with the wishes and welfare of survivors.
• Assisting survivors to document and lodge a report, in line with the wishes of the survivor
• Clearly and openly communicating with survivors, including giving feedback on what will happen next.
• Inviting survivors to have a support person with them at any time in the reporting and response process.
• Making every effort to meet survivors’ needs, including accommodating requests to have a person of a particular gender present at the time of disclosure.

11. PSEAH Training and induction

Tupou College ensures that all staff and associated people (including volunteers, contractors, grant recipients, and downstream partners) receive induction and regular refresher training on PSEAH.

PSEAH Training will cover the following key areas:

• Familiarization with the PSEAH Policy: All staff and associated people will be introduced to the PSEAH Policy, ensuring they understand the College’s commitment to preventing sexual exploitation, abuse, and harassment.
• Expected Behaviours: Training will include clear guidelines on acceptable and unacceptable behaviours, emphasizing the importance of maintaining a safe and respectful environment for all.
• PSEAH Reporting Process: Training will outline the procedures for reporting concerns of SEAH, ensuring all participants understand the correct channels and protocols.
• Role of the Safeguarding Focal Point: Staff and associated people will be educated about the role of the Safeguarding Focal Point and how they can support the reporting and resolution process.

Tupou College will provide regular refresher trainingto ensure all staff remain informed of current policies, legal updates, and best practices in preventing SEAH.

12. Recruitment and interview process

To ensure the safety and well-being of children and vulnerable individuals, Tupou College will apply robust recruitment and screening proceduresfor all staff and associated people (including volunteers, contractors, grant recipients, downstream partners, etc.) to reduce the risk of engaging individuals who pose an unacceptable risk to children or vulnerable adults.

These procedures will include:

• Criminal History Checks: All candidates will undergo thorough criminal history checks to identify any potential risks to children or vulnerable adults.
• Referee Checks: References will be sought from the applicant’s previous places of employment or volunteer work, including overseas positions, with specific questions regarding any concerns related to sexual misconduct or safeguarding issues.
• Personnel Records: The College will ensure that personnel records include any performance or conduct issues, particularly related to concerns or allegations of SEAH.
• Employment Contracts: All employment or volunteer contracts will include provisions for disciplinary action, including the termination of employment or assignment if there is a breach of this policy.

Additionally, during the interview process, targeted behavioural questions related to safeguardingwill be incorporated to assess a candidate’s commitment to protecting vulnerable children and adults. These questions will focus on the candidate’s:

• Understanding of safeguarding principles and the PSEAH policy.
• Ability to recognize and respond to incidents or risks of SEAH.
• Experience in maintaining appropriate boundaries with children and vulnerable adults.
• Approach to handling disclosures of abuse or other misconduct.

By incorporating these measures, Tupou College ensures that all individuals working within the institution are not only qualified but also committed to upholding the highest standards of safeguarding.

13. SEAH Risk Management Process

1. Risk Identification:
   1. Regular assessments to identify SEAH risks in school activities and relationships.
   1. Document risks in a Risk Register (Appendix 1), categorized by likelihood and impact.
2. Risk Assessment:

Tupou College will use the Safeguarding Risk Assessment Template (Appendix 2) as a tool to identify and manage safeguarding risks both at the organizational and activity levels. This template supports the organization in identifying safeguarding gaps and strengthening safeguarding practices.

The risk assessment process consists of two key steps:

Step 1 – Assess Organizational Capacity

The first step involves evaluating the College’s capacity to meet safeguarding minimum standards. This includes assessing policies, procedures, and resources in place to safeguard children and vulnerable adults, as well as the general safeguarding culture within the organization.

Step 2 – Identify Activity – Specific Risks and Mitigation Strategies

The second step involves identifying risks specific to particular activities or interactions, such as field trips, one-on-one staff-student interactions, or other high-risk situations. Once risks are identified, mitigation strategies will be put in place to reduce or manage these risks effectively.

Using the Safeguarding Risk Assessment Template, risks will be prioritized based on their severity and the potential harm to children and vulnerable adults. This helps ensure that the College addresses the most critical risks first while implementing long-term strategies for managing others.

• Controls and Mitigation:
  • Policies: Clear SEAH policies outlining unacceptable behavior.
  • Training: Mandatory SEAH awareness training for staff, students, and volunteers.
  • Supervision: Increased supervision during high-risk activities (e.g., field trips, one-on-one interactions).
  • Reporting: Confidential, accessible reporting channels for incidents.
  • Background Checks: Thorough checks on staff and volunteers.
  • Boundaries: Clear guidelines on appropriate staff-student interactions.
• Incident Response:
  • Provide immediate support for victims.
  • Follow a clear investigation protocol with protection for complainants.
  • Implement disciplinary actions as necessary.
• Monitoring and Review:
  • Regularly update risk assessments, review policies, and gather feedback.
  • Conduct audits to ensure controls are effective.
• Reporting and Documentation:
  • Maintain secure, confidential records of incidents and actions.
  • Provide regular reports to leadership and stakeholders.
• Continuous Improvement:
  • Regular updates to policies and practices based on new risks or legal requirements.
  • Foster a culture of feedback and improvement.

13.1 External Support and Resources

Tupou College is actively seeking PSEAH/safeguarding risk assessment resources and expert support for the continuous development and improvement of SEAH-related risk management processes. This will help ensure that the College remains up to date with best practices in safeguarding and SEAH risk management.

14. Reporting and Investigation

14.1             How to report

Tupou College provides a safe, supportive, and secure environment for reporting alleged incidents of SEAH or policy non-compliance. All concerns will be taken seriously and addressed immediately, following both Tupou College and Donor reporting requirements, and with respect for the survivor’s wishes and welfare.

All reports of SEAH will be documented by Tupou College, regardless of whether the incident is substantiated or a full investigation is required. At the survivor’s request, Tupou College will de-identify complaints to maintain confidentiality. The principles of natural justice will apply to all investigations.

Tupou College workers and associated people (e.g., volunteers, contractors, grant recipients, downstream partners) are required to immediately report any concerns, suspicions, or allegations of SEAH or breaches of the Tupou College PSEAH Policy.

Concerns can be reported to the following individuals or groups:

• Tupou College Council
• President of Education & Education Standing Committee – Free Wesleyan Church of Tonga
• President of the Free Wesleyan Church of Tonga

Tupou College workers may report concerns to:

• Executives – Principal, Deputy Principals, and Head Tutor
• Senior Leadership – Head of TVET, Dean of International Stream, Dean of National Stream, Heads of Departments, and House Leads

Visitors, beneficiaries, and members of the public may report concerns to:

• Executives – Principal, Deputy Principals, and Head Tutor
• Senior Leadership – Head of TVET, Dean of International Stream, Dean of National Stream, Heads of Departments, and House Leads
• Member(s) of the Tupou College Council

14.2 Managing Reports

Individuals reporting SEAH in good faith, or cooperating with an investigation, will be protected under this Policy. However, malicious or vexatious reports intended to harm another person’s integrity or reputation are considered serious misconduct and will result in disciplinary action, up to and including termination of employment. This does not apply to reports made in good faith based on the information available at the time, even if an investigation does not substantiate the allegations.

Reporting and investigation progress will be regularly communicated to the Tupou College Senior Leadership Team and Tupou College Council members.

14.3 External Reporting

Where it is safe to do so, and in accordance with the wishes and welfare of survivors, alleged SEAH incidents will be reported to the appropriate local authorities. If an Australian Volunteers International (AVI) staff member or participant/volunteer is involved as either the survivor or alleged perpetrator, Tupou College must report the incident to AVI immediately, as AVI has strict reporting timeframes.

14.4 Investigations 

Tupou College will conduct SEAH investigations in a timely, fair, objective manner, maintaining confidential to the greatest extent possible. This includes the use of appropriate interviewing practice with complainants and witnesses along with the PESAH Investigation Report (Appendix 3).

These reports will include findings, actions taken, and outcomes of the investigation, while maintaining confidentiality in accordance with the survivor’s wishes and relevant privacy regulations. All information and documented evidence will be held securely and in the strictest confidence as far as is appropriate

14.5 Survivor Support and Assistance

Tupou College will adopt a survivor-centred approach in preventing and responding to SEAH. Tupou College will ensure that all responses are developed in a manner that balances respect for due process with a survivor centred approach in which the survivor’s wishes, safety and wellbeing remain a priority in all matters and procedures. Furthermore, all actions taken should be guided by respect for choices, wishes, rights and dignity of the survivor. 

Tupou College will ensure survivors of SEAH are offered support and assistance such as referral to safe health/medical, psychosocial and legal/justice response where appropriate and where required to specialised children’s or women’s services.

Survivors will be provided with information on the progression of an investigation and final outcomes.

14.6 Partner Organisations

Tupou College will work with Partner Organisations, funding donors and grantees in the prevention of SEAH and Partner Organisations will be advised of avenues available to report concerns regarding SEAH within Tupou College.

15. HOW SEAH INCIDENT RECORDS ARE KEPT

1. Incident Register:
   SEAH incidents are documented in a confidential incident register, including key details such as the date, type of incident, individuals involved, actions taken, and follow-up procedures.
2. Evidence Files:
   Each incident has a corresponding evidence file containing statements, reports, and any relevant documentation, securely stored for confidentiality.
3. Storage and Security:
   Records are stored securely:
   1. Digital: Encrypted and password-protected databases with limited access.
   1. Physical: Locked cabinets or safes, accessible only to authorized personnel.
4. Confidentiality and Access Control:
   Access to records, including incident documentation and investigation reports, is restricted to designated staff, with all actions logged for accountability purposes.
5. Retention and Disposal:
   Records are retained for a set period as required by law, and securely disposed of or archived after this time.

16. Responsibilities

Tupou College Council	Approve the PSEAH Policy, hold the Executives and Senior Leadership Team accountable. Ensure Tupou College meets its obligations.
Principal & Executive Team	Ensure compliance with the processes and policies set out in this document. Review of this document as changes are made to the relevant laws. Maintain systems for a safe environment for students. Ensure systems for reporting and investigating incidents. Maintain records of any investigations.
Senior Leadership Team	Lead by example in adhering to and promoting the PSEAH Policy.Provide support and guidance to staff to foster a culture of safeguarding and respect.Ensure staff are properly trained in PSEAH procedures and their responsibilities.
All workers	Understand and follow the Tupou College PSEAH Policy.Report all allegations or concerns of PSEAH to the appropriate designated authority (e.g., Principal or designated staff).Cooperate with investigations and safeguard the dignity of all involved.
Volunteers, contractors, grant recipients, downstream partners etc	Understand and adhere to Tupou College’s PSEAH Policy.Report all PSEAH-related concerns or allegations to the appropriate designated authority (e.g., Principal or designated staff).Actively contribute to a safe and respectful environment at all times.

17. Evaluation and Performance

Tupou College will monitor PSEAH Policy compliance through:

1. Regular Audits: Conduct internal and external audits to assess policy adherence.
2. Incident Reporting System: Track and respond to reports through a confidential system.
3. Staff Training: Monitor training attendance and effectiveness in understanding the policy.
4. Feedback Mechanisms: Use surveys to gather feedback on policy implementation.
5. Performance Reviews: Include PSEAH compliance in staff performance evaluations.
6. External Collaboration: Partner with local authorities for oversight and evaluation.

These approaches will align with the College’s existing governance frameworks and policies.