1. Introduction
1.1 Impact Investment Exchange Pte Ltd (“IIX”) supports the rights of children and is committed to their safety and well-being. IIX believes that child protection requires everyone to take responsibility and that every child matters. IIX recognizes that the care, protection and welfare of children is paramount and that all children have the right to be protected from all types of harm. IIX recognizes that it has a fundamental duty of care towards all children where its programs and operations facilitate contact with children or have an impact on children. This includes a duty to protect children from harm or risk of harm as a result of misconduct by IIX Staff or Stakeholders, of poor practice, or of poor design or delivery of IIX’s programs and operations.
1.2 IIX Staff and Stakeholders share a common responsibility and commitment to the awareness, prevention and reporting of and responding to child abuse in the course of their work.
1.3 IIX’s Child Protection Policy sets out common values, principles and beliefs and describes the steps that will be taken to meet IIX’s commitment to protect children. IIX achieves this through compliance with Singapore laws under the Children and Young Persons Act and the relevant laws in each of the countries where IIX operates, as well as its adherence to Article 19 of the United Nations Convention on the Rights of the Child.
2. Scope
2.1 IIX practices a zero-tolerance policy for child abuse. This policy is targeted at preventing child abuse in IIX’s work, including those with its Stakeholders.
2.2 This policy applies to all persons working for IIX or on its behalf in any capacity, including employees at all levels, directors, officers, seconded workers, volunteers, interns, agents, contractors, external consultants and third-party representatives (collectively referred to as “Staff”)
2.3 IIX employees on boards of joint ventures where IIX does not have a controlling interest should encourage the joint venture to adopt this Policy or a similar policy.
2.4 This policy also applies to external third-parties working with IIX, such as business partners and enterprises, including borrowers of the Women’s Livelihood BondTM (WLB) Series (“Borrowers”) (collectively referred to as “Stakeholders”).
3. Definition
3.1 For the purpose of this policy, the definition of a child is “every human being below the age of 18 years unless under the law applicable to the child, majority is attained earlier.” This is in accordance with Article 1 of the United Nations Convention on the Rights of the Child.
4. Purpose
4.1 The purpose of this Child Protection Policy is to:
4.1.1 Provide a management strategy to prevent child abuse and protect children in the course of IIX’s work;
4.1.2 Protect IIX Staff and Stakeholders from unfair practices and processes; and
4.1.3 Provide IIX Staff and Stakeholders with clear guidelines on what to do in the case of suspected child abuse.
5. IIX’s Commitment
5.1 IIX’s commitment to child protection will be guided by the following:
5.1.1 Awareness: IIX will ensure that all IIX Staff involved in projects that involve or may involve contact with children or have an impact on children are aware of the problem of child abuse and the risks to children.
5.1.2 Prevention: IIX will ensure, through awareness and best practices, that IIX Staff minimize the risks to children.
5.1.3 Reporting: IIX will ensure that IIX Staff and Stakeholders know specific steps to take when reporting concerns regarding the safety of children.
5.1.4 Responding: IIX will ensure that action is taken to support and protect children where concerns of abuse arise.
5.2 Further to the above, IIX Staff and Stakeholders are required to:
5.2.1 Observe all applicable laws relating to a minimum age for employment of children;
5.2.2 Not use forced or compulsory labor, including the worst forms of child labor (as defined in section 507 of the Trade Act of 1974, 19 U.S.C. § 2467, as amended); and
5.2.3 Not employ persons, formally or informally, (1) under the age of 18 for any work that is economically exploitative, is likely to be hazardous or to interfere with the person’s education, or is likely to be harmful to the person’s health or development, (2) under the age of 15 for general work or (3) in a manner constituting the worst forms of child labor (as defined in section 507 of the Trade Act of 1974, 19 U.S.C. § 2467, as amended).
5.3 Moreover, IIX shall:
5.3.1 Ensure, as Portfolio Manager of the WLB Series, that Borrowers sign a statement certifying that they understand IIX’s Child Protection Policy and that they will comply with said policy to the extent that it applies to Stakeholders;
5.3.2 Not permit any IIX Staff to work with children on IIX-related projects if said person has been identified to pose an unacceptable risk to children’s safety or well-being;
5.3.3 Take all child abuse concerns raised seriously;
5.3.4 Take positive steps to ensure the protection of children who are subject of concerns;
5.3.5 Support children, IIX Staff or other adults who raise concerns or who are the subject of concerns;
5.3.6 Act appropriately and effectively in instigating or cooperating with any subsequent process of investigation;
5.3.7 Guide through the child protection process by the principle of “best interests of the child”;
5.3.8 Listen to and take seriously the views and wishes of children; and
5.3.9 Work in partnership with parents/carers and/or other professionals to ensure the protection of children.
6. Guidelines for Reporting Suspected or Actual Abuse of Children
6.1 Reporting principles
6.1.1 Reporting suspected or actual child abuse related to IIX’s work is mandatory for all IIX Staff and Stakeholders.
6.1.2 Responsible reporting also means that any person making a report should bear in mind that all concerns are allegations until they have been investigated. For this reason, it is important for anyone raising a concern to follow the specific reporting guidelines set out below.
6.1.3 In particular, confidentiality is expected within the reporting chain.
6.2 Reporting procedures
6.2.1 All IIX Staff should normally discuss their concerns with their immediate senior manager, be it a Project Manager or a Head of Department. Where IIX Staff are unable or unwilling to do this, they must raise their concerns with IIX’s Chief Operating Officer, Chief Executive Officer or Board of Directors (“IIX Designated Authority”).
6.2.2 All IIX Stakeholders should report to the IIX Designated Authority any suspected or actual breach of this policy committed by either IIX Staff or another Stakeholder on a relevant IIX project on which they are jointly engaged. They are also expected to follow reporting obligations under prevailing laws and regulations concerning child abuse in their respective jurisdictions.
6.2.3 Any information provided to the IIX Designated Authority will be handled with strict confidentiality and action will only be taken if breaches of the Child Protection Policy can be proven conclusively.
6.2.4 Senior managers should feel able to consult and seek support from other colleagues as necessary.
6.2.5 Discussions held with a senior manager or with the IIX Designated Authority should focus on:
6.2.5.1 Evidence that the Child Protection Code of Conduct has been breached;
6.2.5.2 The identified risks to the child/children;
6.2.5.3 Measures to safeguard children and minimize risk; and
6.2.5.4 Action/next steps.
6.2.6 The IIX Designated Authority will focus on the following:
6.2.6.1 An assessment of the reported concerns and support needs;
6.2.6.2 Whether, and at what stage, the issue should be reported to external bodies; and
6.2.6.3 Appropriate response, e.g., disciplinary process or urgent action if children are judged to be at risk.
6.3 Actions to be taken
6.3.1 IIX shall take appropriate measures against any IIX Staff or Stakeholder found to have violated this policy, following a thorough investigation.
6.3.1.1 Any IIX Staff who has engaged in child abuse or has participated in an act of child abuse or encouraged such conduct shall face disciplinary action up to, and including, dismissal for misconduct or gross misconduct, based on senior management’s assessment of the case. For severe cases, a police report may be made.
6.3.1.2 If the policy violation involves an external Stakeholder, IIX shall take appropriate actions to prevent recurrence. IIX reserves to terminate its relationship with a Stakeholder if they breach this policy.