Mpishi Energy
Mpishi Energy / Policies / SEAH Prevention

Sexual Exploitation, Abuse and Harassment (SEAH) Guidelines

These Guidelines set out how we prevent, identify, report and respond to sexual harassment, sexual abuse and sexual exploitation connected with our operations, workplaces, partnerships, community interactions and projects. They promote dignity, safety and accountability, and support compliance with the law, our contracts and the expectations of our funders.

Last approved 17 June 2025

  • Zero tolerance

    No sexual harassment, abuse, exploitation or abuse of authority for sexual purposes.

  • Survivor-centred

    Safety, consent, confidentiality and support guide every response.

  • Prevention first

    Safer recruitment, codes of conduct, training and oversight of higher-risk activities.

  • Accountability

    Allegations reviewed fairly and promptly, with escalation and sanctions where substantiated.

How a SEAH concern is handled
  1. 1Concern raised

    By anyone (worker, contractor or community member) through any channel.

  2. 2Screening and safeguarding

    Immediate protective steps where there is a welfare or retaliation risk.

  3. 3Investigation or escalation

    Survivor-centred review; Board, counsel, funders or authorities as appropriate.

  4. 4Corrective action and closure

    Sanctions, support, control improvements and a closed, recorded outcome.

Scope

  • These Guidelines apply to directors, officers, employees, consultants, advisers, contractors, suppliers, community-facing representatives and anyone acting for or on behalf of Mpishi Energy.
  • They apply in workplaces and in external engagements, including recruitment, travel, field work, community consultations, partner engagement, procurement and project construction and operation.

Our position

  • We do not tolerate sexual harassment, sexual abuse, sexual exploitation, coercion, intimidation, retaliation or any abuse of authority for sexual purposes.
  • This applies between colleagues, between supervisors and subordinates, between representatives and contractors, and between company representatives and community members or other stakeholders.
  • Any concern, allegation or indicator is taken seriously, handled promptly and addressed fairly, proportionately and as confidentially as reasonably possible.

Definitions

  • Sexual harassment: unwelcome sexual advances, requests for sexual favours, sexual comments, suggestive behaviour or other unwelcome conduct of a sexual nature that creates an intimidating, humiliating, hostile or offensive environment.
  • Sexual exploitation: any actual or attempted abuse of a position of vulnerability, differential power or trust for sexual purposes, including to obtain sexual benefit or advantage.
  • Sexual abuse: actual or threatened sexual intrusion, assault or other sexual conduct carried out through force, coercion, manipulation or without valid consent.
  • Sexual activity with anyone under 18 is prohibited regardless of local age of consent or belief about age. Exchanging money, employment, goods or services for sex is prohibited.

Prevention and detection

  • Clear standards of behaviour in employment and contractor codes of conduct, signed by everyone working on our sites.
  • Induction and refresher training for staff and contractor workforces, and community awareness sessions about acceptable conduct and how to report.
  • Safer recruitment and reference checks for community-facing and supervisory roles, and SEAH obligations written into EPC and supplier contracts.
  • Risk assessment of field work, travel, one-to-one interactions, workforce accommodation, labour influx and community-facing roles, with mitigation in the project ESMS.
  • Warning signs, such as boundary violations, repeated complaints, inappropriate communications, attempts to bypass oversight or misuse of authority, must be escalated promptly.

Reporting

  • Anyone who experiences, witnesses, receives or reasonably suspects conduct covered by these Guidelines should report it promptly: confidentially to report@mpishienergy.net, to the Managing Director or a Board-designated contact, through a site community liaison officer, or through our grievance mechanism.
  • Reports can be made by employees, consultants, contractors, suppliers, community members or other stakeholders, and can be anonymous.
  • Grievance channels on project sites include trained focal points of different genders, and SEAH reports are routed directly to senior management rather than handled through the general grievance log.

Response

  • Reports are logged, screened and assessed promptly, with escalation to senior management, the Board, legal counsel, external advisers, funders or the authorities where appropriate.
  • Immediate protective steps are taken where there is a safeguarding, welfare or retaliation risk, including separating the people involved.
  • Survivors are offered referral to medical, psychosocial and legal support services, and decisions about further steps respect their informed consent wherever possible.
  • Funders are notified of serious incidents within the timeframes required by our financing agreements.

Confidentiality, fair process and non-retaliation

  • Information is handled as confidentially as reasonably possible, shared only as needed to assess, investigate, respond and escalate.
  • Retaliation, intimidation, discrimination or disadvantage against anyone who raises a concern in good faith or assists in a review is prohibited. Malicious or knowingly false allegations are also prohibited.
  • Everyone involved is treated fairly, with due regard for privacy, dignity and procedural integrity.

Responsibilities

  • Management promotes awareness, maintains proportionate safeguards, receives and escalates concerns and ensures matters are reviewed and addressed.
  • All personnel and representatives comply with these Guidelines, maintain professional boundaries, avoid prohibited conduct and report concerns promptly.
  • The Board, or designated oversight authority, oversees serious, material or management-level allegations.

Corrective action and review

  • Where concerns are substantiated, action may include management intervention, removal from duties, disciplinary measures, termination of engagement or contract, referral to partner procedures, funder notification, strengthening of controls and referral to the authorities.
  • These Guidelines are read together with our Ethical Guidelines, Anti-Corruption and Whistleblowing Policy and Gender Equality Policy, and reviewed periodically to reflect growth, operating context, safeguarding risks and funder expectations.

Contact

Mpishi Energy Limited, 31 Peri Peri Street, Salama Park, Lusaka, Zambia. Confidential reports: report@mpishienergy.net. General enquiries and grievances: info@mpishienergy.net.

This is the public version of an approved Mpishi Energy policy. It applies to Mpishi Energy Limited and its project companies and is reviewed at least annually.