Mercy Corps Sudan SOMOUD – Enhancing Community Resilience Project – Additional Financing 1 (P181490) SEA/SH Prevention and Response Plan December 2024 1 Content Content ......................................................................................................................................................... 2 LIST OF ACRONYMS ....................................................................................................................................... 3 1 INTRODUCTION ..................................................................................................................................... 6 2 Project Description................................................................................................................................ 7 3 GBV SITUATION IN SUDAN .................................................................................................................... 8 4 MERCY CORPS’ COMMITMENT ON GBV AND APPROACH .................................................................. 11 5 SEA/SH PREVENTION AND RESPONSE PLAN ....................................................................................... 15 5.1 GBV/SEA/SH RISKS AND MITIGATION MEASURES .................................................................... 16 5.2 OUTPUTS AND ACTIVITIES ......................................................................................................... 21 6 STAFFING AND COUNTRY CAPACITY FOR GBV/SEA/SH RESPONSE, RISK MITIGATION AND PREVENTION ............................................................................................................................................... 24 7 IMPLEMENTATION ARRANGEMENT ................................................................................................... 24 8 ACCOUNTABILITY FRAMEWORK- SEA/SH ........................................................................................... 24 2 LIST OF ACRONYMS CBPN Community Based Protection Network CDC Community Development Committee CSO Civil Society Organization CoC Code of Conduct FGM Female Genital Mutilation GBV Gender Based Violence GBV AoR Gender Based Violence Area of Responsibility GBVIMS+ Gender Based Violence Information Management System GRM Grievance Reporting Mechanism IASC Inter Agency Standing Committee IP Implementing Partners M&E Monitoring and Evaluation NGO Non Governmental Organization PD Project Document PDO Project Development Objective PSEA Prevention of Sexual Abuse and Exploitation SDG Sustainable Development Goals SEA Sexual Exploitation and Abuse SEP Stakeholder Engagement Plan SH Sexual Harassment SME Small and Medium Enterprises SoC Standard of Conduct SH Sexual Harassment SOP Standard Operating Procedures TPM Third-Party Monitors UN United Nations VAWG Violence Against Women and Girls WASH Water, Sanitation and Health WB World Bank 3 KEY DEFINITIONS Gender-based violence (GBV) is an umbrella term for any harmful act that is perpetrated against a person’s will, and that is based on socially ascribed (i.e., gender) differences between males and females. It includes acts that inflict physical, sexual, or mental harm or suffering, threats of such acts, coercion, and other deprivations of liberty. These acts can occur publicly or privately (2015 Inter-Agency Standing Committee Gender-based Violence Guidelines, pg. 5). Sexual Exploitation is 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 another1. Sexual Abuse is actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. Child sexual abuse includes any form of sexual relations with a child, bearing in mind that a child cannot give consent. Sexual Harassment (SH) is any unwelcome sexual advance, request for sexual favor, verbal physical conduct or gesture of a sexual nature, or any other behavior of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation to another, when such conduct interferes with work, is made a condition of employment, or creates an intimidating, hostile or offensive work environment. Child Sexual Abuse Child sexual abuse includes any form of sexual relations with a child, bearing in mind that a child cannot give consent. Protection from Sexual Exploitation and Abuse (PSEA): policies, guidelines, procedures, mechanisms, and activities aimed to reduce the risk of SEA; mitigate the effects caused by SEA violations; and respond to SEA incidents. Survivor-Centered Approach is a set of principles and skills designed to guide professionals—regardless of their role— in their engagement with survivors (predominantly women and girls but also men and boys) who have experienced sexual or other forms of violence. It aims to create a supportive environment in which the survivor’s interests are respected and prioritized, and in which the survivor is treated with dignity and respect. The approach helps to promote the survivor’s recovery and ability to identify and express needs and wishes, as well as to reinforce the survivor’s capacity to make decisions about possible interventions. Victim: A person who has experienced SEA/SH that inflicts harm on her/him or an attempt to perpetrate SEA/SH against her/him. Complainant: A person who brings, in accordance with established procedures, an allegation of SEA to attention. The complainant may be a SEA victim or another person who is aware of the wrongdoing. Both the victim and the complainant, if different from the victim, should be protected from retaliation. Whistle-blower: Any humanitarian and development actor who reports concerns of sexual exploitation or abuse. Whistle- blowers may be a type of complainant. GBV Response: Is a multi-sectoral process of supporting anyone who experiences GBV with access to comprehensive response services, including such as psychosocial support and individual case management, clinical health services, safety services or options, and or legal services based on service availability and survivor’s informed consent. GBV Risk Mitigation: GBV risk mitigation comprises a range of activities across programs that aim to first identify GBV risks and then take specific actions to reduce those risks. It is a process of ensuring that a program (1) does not cause 1 From ST/SGB/2013/3. https://documents-dds-ny.un.org/doc/UNDOC/GEN/N03/550/40/PDF/N0355040.pdf?OpenElemen 4 or increase the likelihood of GBV; (2) proactively seeks to identify and takes action to mitigate GBV risks in the environment and in program design and implementation; and (3) proactively facilitates and monitors vulnerable groups’ safe access to services. It is distinct from, but complementary to, GBV-specialized programming. GBV Prevention: Community-based and community-driven engagement and actions to prevent GBV by addressing its underlining conditions and drivers. These are interventions to address the harmful social norms that perpetuate GBV, promote safe access to GBV response services survivors, and promote the social and economic empowerment of women, girls, and boys to improve their resilience against GBV. 5 1 INTRODUCTION With increasing risks and levels of violence against women and girls in Sudan due to the ongoing conflict, Gender-based violence (GBV) mitigation, prevention and response is included into the design of the Somoud Project as part of the basic package of services to be provided to communities in the project localities. This action plan was drafted in a comprehensive manner to provide a consolidated view of GBV, Sexual Exploitation and Abuse (SEA) and Sexual Harassment (SH) risk mitigation and response activities. GBV is the most pervasive yet least visible human rights violation, public health and development issue affecting every aspect of women, girls’ and boys’ safety and wellbeing in the world. It inflicts untold harm, especially among girls and women, with adolescent girls at a heightened risk of exposure. GBV does not only impact the physical and psychosocial well-being of those directly experiencing violence, but it also harms others, including survivors’ children, and can have wider-reaching harmful effects on the social fabric of communities. GBV or violence against women and girls (VAWG), is a global pandemic that affects 1 in 3 women in their lifetime2. The numbers are staggering; 35% of women worldwide have experienced either physical and/or sexual intimate partner violence or non-partner sexual violence. Globally, 7% of women have been sexually assaulted by someone other than a partner. Globally, as many as 38% of murders of women are committed by an intimate partner. 200 million women have experienced female genital mutilation. The actual extent of GBV problem globally is unknown. With or without numbers on its prevalence, evidence has shown that GBV is occurring in every society and often gets exacerbated during humanitarian emergencies. The effects of GBV in humanitarian crises are so severe that addressing it is considered a lifesaving priority. The impacts of GBV extend far beyond its direct survivors. As earlier highlighted, the impact of GBV is not only felt by survivors, the effects are highly likely to be experienced by the children of these survivors. GBV has detrimental and lasting effects on children’s physical, sexual, reproductive, and psychological health, well-being, development, and educational outcomes. Infant and child survival and well-being are directly correlated with the safety, health, and well-being of their mothers. Mothers whose physical wellbeing, and/or mental health is compromised by violence including GBV may be less able to care for their children or support their families physically, morally, and financially. This can affect children’s nutrition and school attendance and expose them to additional risks of violence, abuse, neglect, and exploitation. Mothers who are survivors of GBV might also face stigma and rejection from their communities, leading to withdrawal, exclusion and participation in activities or decisions that promote their safety and wellbeing. Addressing GBV is linked to the achievement of all Sustainable Development Goals (SDGs). In many settings, girls and women are disproportionately impacted by climate change, environmental degradation, food insecurity, unsafe and undignified employment, and unstable economies and economic shocks. Achievement of the SDGs requires girls’ and women’s full and equal social, economic, and political inclusion and participation – all of which can only be achieved when GBV is addressed. Reaching the vision, goals and targets of the SDGs therefore depends on girls’ and women’s safety, empowerment, and freedom from violence including GBV. In emergency affected contexts, this is an even more pressing priority. Addressing GBV contributes directly to multiple SDGs: achieving gender equality and empowering all women and girls (SDG 5); and promoting peaceful and inclusive societies for sustainable development (SDG 16). Addressing GBV will further contribute towards achieving other goals, including ending poverty 2 Devastatingly pervasive: 1 in 3 women globally experience violence (who.int) 6 in all its forms everywhere (SDG 1), ensuring healthy lives and promoting well-being for all at all ages (SDG 3); and ensuring inclusive and equitable quality education and promoting lifelong learning for all (SDG 4). Violence against women can include different forms including sexual exploitation and abuse (SEA) and sexual harassment (SH). Gender inequalities and humanitarian crises do not only destroy livelihoods and displace affected populations, but they also increase risks of GBV, including risks of SEA and SH. Insecurity, loss of livelihood opportunities, continuous displacement, lack of access to basic social services, locations and nature of available services, and breakdown of protection systems are some factors or triggers increasing women and girls’ vulnerability and exposure to GBV. Bearing in mind that humanitarian agencies are often involved in providing services and assistance to the girls and women affected by such circumstances or crises, SEA and SH are violations that are particularly prevalent within the context of humanitarian action. This has influenced the development of principles, policies and practice standards that many humanitarian agencies hold themselves accountable to, aiming to detect, prevent and respond to all forms of such misconduct by humanitarian workers. 2 Project Description The Project Development Objective (PDO) is to improve access to basic services and food security of Select Communities in the Republic of Sudan. The AF, as the Parent Project, consists of two components, complemented by World Bank-financed monitoring, learning, and adaptation activities to inform adjustments to locations and design. The project will have multisectoral and spatial approaches to development with a strong focus on community-led processes via existing and new Community Development Committees (CDCs) to promote ownership, social cohesion, and sustainability. Component 1: Community Driven Basic Service Delivery: Component 1 will help achieve the first project outcome by supporting: (i) delivery of improved community-led basic services; and (ii) incentives to frontline workers in selected sectors. This component will be implemented by Mercy Corps and by competent non-government organizations (NGOs) and CSOs (also referred to as “Implementing Partners�). The community targeting focus on identifying and prioritizing communities based on population size, the presence of internally displaced persons (IDPs), child vulnerability, and the availability of essential services such as WASH (Water, Sanitation, and Hygiene), education, and child protection. Communities are ranked and categorized into three deprivation groups by calculating the total population, assessing the absence of essential services, and averaging these ranks. This approach ensures that the most deprived communities with significant service gaps receive targeted support to enhance their well- being and resilience. This is also complemented by an extensive community consultation described below, to define and prioritize interventions, activities or sub-projects. Component 2: Food Systems Resilience: Component 2 will help achieve the second project outcome by supporting: (i) improvement of agricultural production of strategic crops; (ii) enhancement of agricultural value chains; and (iii) scale-up and strengthening of community market points and community kitchens for the distribution of agricultural outputs and provision of affordable food items. The component will be implemented by Mercy Corps. 7 Mercy Corps will work primarily in partnership with Save the Children on Component 1 and Mercy Corps will be the main implementer of Component 2. The components will be implemented in Gedaref State. All implementation will be done with local contractors, NGOs and CSOs to implement the activities in collaboration with the local government, parastatal entities, and community-based organizations, particularly the Community Development Committees (CDCs). Mercy Corps will establish a Project Implementation Unit (PIU) within its Sudan office (as appropriate based on the security situation) and carry out day-to-day management and implementation of the activities. 3 GBV SITUATION IN SUDAN The ongoing conflict in Sudan is taking a devasting toll on women and girls. The situation across the country is dire and continues to exacerbate the pre-existing gender inequalities and risks of GBV, including risks of sexual exploitation and abuse (SEA). Since the conflict erupted in April 2023, the United Nations (UN) and partners have documented increasing reports of GBV incidents, including conflict-related sexual violence against women and girls in internally displaced and refugee camps, where there are significantly limited specialized services and supplies, with displaced women and girls residing in temporary shelters. While the extent of the GBV problem in Sudan is unknown and incidence data is unavailable, roughly 4.2 million people (including refugees inside Sudan) are estimated to be at risk of GBV as the conflict continues to displace families, disrupt access to basic social services, and break down protection services and social support systems. Specialized GBV services such as psychosocial support, individualized case management, clinical management of rape, safety and legal aid services to meet the needs of survivors of GBV as well as the needs of women and girls at risk of are limited due to the ongoing conflict which continues to displace and relocate populations and service providers. Additionally, referral mechanisms to support survivors of GBV are non-functional in most localities in Sudan. This gap in services is further exacerbated by the severe funding shortage as GBV is amongst the least funded sectors. Furthermore, the pre-existing community-based protection networks (CBPNs) and safe spaces for women and girls offering GBV related information and services have been severely impacted. Amid increasing GBV/SEA/SH risks prevalent in Sudan, GBV risk mitigation across the humanitarian response is insufficient, leading to additional risks of GBV (including SEA) and negative coping strategies among women and girls. Humanitarian actors including local organizations are working together to expand GBV services, but challenges remain with service providers reporting attacks and harassment on their facilities, as underreporting of GBV cases by survivors due to fear. Other challenges documented include the lack of safe spaces to provide psychosocial support to women and girls in crisis, including holistic GBV services (emotional support, healthcare, and safety). Since the outbreak of the war in April 2023 there have been several observed trends (some of which are anecdotal, others more grounded in data), including: • Major increase in domestic violence, linked to lack of work and income • Major increase in sexual and gender-based violence as a war tactic • Increase in child marriage in the belief that a husband will offer protection • Increase in FGM, in the belief it might prevent rape • Negative social norms increasing, for instance dignity kits distributed to women are increasingly being confiscated by men in the household and then sold by men. • An increase in trafficking women as sex workers in areas accessible by RSF Chad. 8 Service Mapping and Referral Pathways: Since the coup in 2021, it has become increasingly risky for service providers to share contact information publicly, due to increasing incidents of service providers themselves being targeted, especially women-led service providers. This targeting had formerly been driven by militias, but after the coup in 2021, authorities in Darfur and Khartoum also started targeting service providers, with service providers being harassed and detained. Since the war broke out in April 2023 this has further escalated and spread widely across the country, as SGBV perpetrators have become aware that if cases are reported and verified then they may face prosecution. Thus, referral pathways are operating below the radar – service provider details are not openly shared, instead there is a focal point for each state who engages directly with victims and directs them to specific services. This makes referrals and accessing the services more complex and cumbersome but is essential to protect the service providers themselves. The GBV Sub sector working group no longer publishes numbers of survivors or locations due to retaliation incidents. In some places, a facility is identified more openly (such as clinic or hospital) without a specific person named there. The women’s led protection local NGO Nada Elahar (River Nile and Northern States) identified the need for capacity building among non GBV services to be able to identify and refer SGBV cases. The SGBV sub sector working group regularly compiles services provided by agencies, feeding into the referral pathways. GBV Risks in Gedaref: Gedaref State, located in eastern Sudan, is a region characterized by a complex interplay of socioeconomic, political, and environmental factors. Known for its agricultural potential and strategic location near the Ethiopian border, Gedaref has been a host to diverse populations, including IDPs and refugees (IDPs). Despite its pre-war relative economic prosperity, the state now faces pervasive challenges, including heightened risks of GBV, particularly among vulnerable populations such as women, girls, and IDPs. GBV encompasses a range of harmful acts perpetrated against individuals based on gender. These include physical, sexual, psychological, and economic violence, as well as harmful traditional practices such as child marriage and female genital mutilation/cutting (FGM/C). In Gedaref, the risks of GBV are shaped by overlapping factors, including: Protracted Displacement and Vulnerability of IDPs Gedaref hosts a significant population of IDPs, primarily displaced due to conflict, these displaced communities often live in overcrowded schools / public buildings or informal settlements with limited access to basic services. Women and girls in these settings face heightened risks of GBV due to a lack of physical security, privacy, and adequate shelter. Patriarchal Norms and Gender Inequalities Traditional gender roles and societal norms in Gedaref perpetuate inequalities, restricting women's agency and exposing them to violence. For example, domestic violence is often normalized, and survivors face stigma and limited access to justice. Economic Stress and Exploitation Widespread poverty and unemployment exacerbate GBV risks, as economic pressures increase the likelihood of exploitative relationships, survival sex, and trafficking. IDP women, who often lack livelihood opportunities, are particularly vulnerable to these forms of violence. Conflict and Insecurity Insecurity in the region further compounds GBV risks. Armed conflicts often result in increased incidences of sexual violence as a weapon of war. Additionally, tensions between host communities and displaced populations can lead to harassment and targeted attacks. 9 Limited Access to Services Survivors of GBV in Gedaref face significant barriers to accessing health, legal, and psychosocial support. These challenges are especially pronounced in remote and underserved areas where resources are scarce. Specific GBV Risks Faced by IDPs in Gedaref • Sexual Violence: Sexual violence, including rape and sexual exploitation, is one of the most prevalent forms of GBV faced by IDPs in Gedaref. The lack of secure and private facilities in IDPs congregating areas, such as latrines and bathing areas, increases the risk of attacks. Women and girls are often targeted when collecting water, firewood, or food, as these tasks require traveling to isolated areas. • Intimate Partner Violence (IPV): IPV is a pervasive issue among IDPs, exacerbated by the stress and trauma of displacement. Men struggling with unemployment and feelings of emasculation may resort to violence as a means of asserting control. Women, on the other hand, often lack the social support systems or economic independence to leave abusive relationships. • Child Marriage and FGM/C: Displacement often leads families to resort to harmful coping mechanisms, such as marrying off daughters at an early age to reduce financial burdens or perceived threats to their safety. In some communities, traditional practices like FGM/C persist, perpetuating cycles of violence and discrimination against women and girls. • Human Trafficking and Exploitation: Gedaref’s proximity to international borders makes it a hotspot for human trafficking. Displaced women and girls are particularly vulnerable to trafficking networks that exploit their precarious situation for forced labor or sexual exploitation. • Psychological and Emotional Abuse: GBV is not limited to physical violence. Many displaced women experience psychological abuse, including coercion, threats, and humiliation, often at the hands of intimate partners, family members, or community members. This form of abuse has long-lasting effects on mental health and well-being. Barriers to Addressing GBV Among IDPs in Gedaref Several barriers hinder the effective prevention and response to GBV risks in Gedaref, including: • Stigma and Cultural Barriers: Survivors of GBV often face significant stigma and shame, deterring them from seeking help. Cultural norms that blame victims or prioritize family honor over individual rights further exacerbate this issue. • Lack of Legal Protection: Weak legal frameworks and limited enforcement mechanisms fail to provide adequate protection for survivors of GBV. Many IDPs are unaware of their rights or distrust the justice system. • Insufficient Services and Capacity: There is a significant gap in GBV prevention and response services in Gedaref. Health facilities often lack trained staff, and confidential spaces to treat survivors. Psychosocial support and legal aid services are also limited, especially in rural and hard- to-reach areas. • Insecurity and Mobility Restrictions: Ongoing conflict and insecurity limit the mobility of both survivors and service providers, hindering access to critical support services. Consequences of GBV on Individuals and Communities The consequences of GBV are far-reaching and multifaceted, affecting not only survivors but also their families and communities. • Physical and Mental Health Impacts: Survivors of GBV often suffer from physical injuries, sexually transmitted infections, and reproductive health issues, including unwanted pregnancies. The 10 psychological toll includes depression, anxiety, post-traumatic stress disorder (PTSD), and suicidal ideation. • Social Isolation and Stigma: Many survivors face ostracization from their families or communities, leading to isolation and further marginalization. This is particularly true in cases of sexual violence or child marriage. • Economic Consequences: GBV undermines economic productivity, as survivors may be unable to work due to physical or emotional trauma. Additionally, families may incur financial burdens related to medical treatment or legal proceedings. • Intergenerational Impacts: Children exposed to GBV, either directly or indirectly, are at higher risk of experiencing violence themselves or perpetuating abusive behaviors in adulthood. 4 MERCY CORPS’ COMMITMENT ON GBV AND APPROACH In Mercy Corps, all initiatives towards addressing all forms of sexual harassment, exploitation and abuse are encompassed within the organizations safeguarding policies, procedures, and core standards. At Mercy Corps, safeguarding is an umbrella term that refers to the prevention and response to sexual exploitation and abuse, human trafficking and exploitation, internal sexual misconduct and child abuse, neglect and exploitation. We define safeguarding as our responsibility to ensure team members, operations and programs do not cause any harm to the people and communities we work with, including our team members, and that we respond in an appropriate, survivor-centered way to any reported issue of exploitation, abuse, harassment, or trafficking. We have zero tolerance toward any form of harm, abuse, or exploitation. The overarching principle in our safeguarding work is a survivor-centered approach. This places the safety, well-being, and perspective of survivors at the core of our efforts. Safeguarding is central to our organizational commitment to Safety, Diversity and Inclusion. Mercy Corps overall safeguarding approach is founded on four pillars: prevention, reporting, response, and using data to reflect and adapt. We seek to prevent safeguarding violations through strong policies, safe hiring practices, onboarding, training, and effective management and by mainstreaming safeguarding into our culture and throughout our programs and partnerships. Our Safeguarding Core Standards Policy outlines a set of mandatory requirements and key responsibilities for all functions at various levels across the organization, aiming at efficient prevention and response of safeguarding concerns. This includes for instance, specific actions for individual departments such as procurement teams when hiring service contractors, finance and grants teams when assessing and onboarding partner organizations, program teams when implementing project activities and interacting with program participants, and short- term/daily workers when interacting with program participants and community members. The Safeguarding Core Standards have integrated all elements of our policies on Child Safeguarding, Prevention of Sexual Exploitation & Abuse, and Anti-Human Trafficking & Exploitation to ensure efficient mainstreaming across all functions. We maintain a robust and trusted reporting system with a variety of safe and accessible channels, including our internal Integrity Hotline and the external Community Accountability Reporting Mechanisms. We respond to all reported concerns with survivors at the center, ensuring they are supported, protected, and provided with access to any resources they might need. We are committed to timely, thorough, survivor-centered investigations of all reported concerns led by trained, professional, trauma-informed investigators. We gather and analyze data and lessons learned from each investigation, from reporting trends and patterns, and from evolving sector best practice, to reflect and adapt in order to continually strengthen our safeguarding systems. 11 Mercy Corps Sudan has a Safeguarding Coordinator with prior professional experience in GBV programming and will be responsible for the implementation of the broader implementation of safeguarding priorities (including PSEA) and provide technical support to the implementation of this SEA/SH action plan for the SOMOUD program. The coordinator will receive dedicated technical support and guidance from the Global Safeguarding team which includes the Regional Safeguarding Advisor for East & Southern Africa. Specific activities Activity 1.1. Establishing/Strengthening SEA/SH Channels in a Community Accountability & Response Mechanism (CARM): The establishment or strengthening of Sexual Exploitation, Abuse, and Sexual Harassment (SEA/SH) channels within Mercy Corps Grievance Redress Mechanism (GRM) aims to create a safe, accessible, and survivor-centered framework for reporting, responding to, and addressing SEA/SH complaints in project areas. Mercy Corps has a robust GRM system under its Community Accountability & Response Mechanism (CARM). These channels are integral to ensuring accountability and fostering trust within communities impacted by the project. Mercy Corps CARM reporting mechanisms prioritize survivor confidentiality and cater to diverse community needs. CARM includes multiple reporting options such as: • Hotlines: Dedicated and trained operators who can handle sensitive complaints empathetically and professionally. • In-person Reporting: Safe and discreet locations, such as community centers or CARM desks, staffed with trained personnel. • Anonymous Reporting: Systems that allow individuals to report incidents without revealing their identity, ensuring inclusivity and reducing fear of stigma. These channels will be tailored to the local context, ensuring they are culturally appropriate, linguistically accessible, and available to vulnerable groups, including women, children, and people with disabilities. SEA/SH channels are an integral part of the overall CARM. This involves clearly defined protocols for how SEA/SH complaints are received, recorded, and escalated while maintaining strict confidentiality and safeguarding principles. A dedicated focal point within the CARM team will oversee SEA/SH cases to ensure a survivor-centered approach. Mercy Corps handling SEA/SH cases places an emphasize on survivor’s well-being, informed consent, and choice at every stage of the reporting process. Survivors should be empowered to decide how their cases are handled and whether they wish to pursue additional support or legal action. As part of this response activity, Mercy Corps will conduct an assessment of existing CARM framework in Gedaref to identify gaps and strengths in handling SEA/SH complaints. Based on this assessment, the Project Team may develop new reporting channels or strengthen existing ones. The project will also ensure all channels are adequately resourced, with trained staff who can manage complaints in a sensitive and survivor-centered manner. GBV Officers will also prepare user-friendly communication materials explaining how to access CARM for SEA/SH complaints. GBV officers will also train project staff and partners on SEA/SH sensitivity, confidentiality, and survivor-centered principles. This will include conducting regular refresher training to maintain high standards of response. GBV officers will also be responsible for raising awareness within communities about the availability of SEA/SH channels in CARM, the importance of reporting incidents, and how to access these channels. Sensitization should be conducted through trusted local platforms, culturally relevant messaging, and inclusive methods. Activity 1.2. Ensuring All Project Workers Sign and Understand the Code of Conduct or Behavioral Standards: From the start of the project, Mercy Corps will establish a strong foundation for ethical and 12 professional behavior among project workers by ensuring they sign and fully comprehend Mercy Corps Code of Conduct (CoC). This effort safeguards the organization/ donors values, mitigates risks of misconduct, and promotes a safe, inclusive, and respectful work environment. Mercy Corps CoC contains comprehensive, culturally relevant policies which are aligned with the organization’s values, donor requirements, and international standards. The CoC contains clear definitions and examples of inappropriate behaviors, including sexual exploitation, abuse, and harassment (SEA/SH), discrimination, and fraud. It also outlines expectations regarding professional conduct, confidentiality, and reporting obligations. Emphasis on zero tolerance for SEA/SH and commitment to creating a safe and inclusive workplace. All project staff are expected to undertake CoC training as part of their induction. Posters or visual aids summarizing key aspects of the CoC are displayed in workplaces. Mercy Corps HR will be responsible for ensuring that all staff complete CoC at the start of their assignments. The in-country safeguarding team will also facilitate interactive sessions and training on SEA/SH principles. The HR team will track compliance with these mandatory training and organize refresher training at regular intervals throughout the project duration. Activity 1.3. Creating Protocols for Referral to Services for Survivors: The creation of referral protocols for survivors of abuse, exploitation, or harassment is critical to ensuring that individuals receive timely, confidential, and effective support. These protocols provide a clear, systematic approach for connecting survivors to essential services, such as healthcare, psychosocial support, legal assistance, and safety measures. This activity aligns with the principles of survivor-centered care, emphasizing dignity, informed consent, and confidentiality. At the start of the project, Mercy Corps will conduct a thorough mapping of service providers within the project’s operational area. Types of services to identify through the assessment include: • Healthcare: Emergency medical care, sexual and reproductive health services, and trauma management. • Psychosocial Support: Counseling, mental health services, and support groups. • Legal Assistance: Guidance on legal rights, filing complaints, and court representation. • Protection and Safety: Shelter, relocation support, and security measures for survivors facing immediate threats. Mercy Corps protection staff will assess service providers’ capacity, accessibility, cultural appropriateness, and adherence to confidentiality and ethical standards. Once services are identified, detailed referral pathways will be developed. • Content of the Pathways: o Step-by-step guidance on how staff can refer survivors to services. o Contact details and operating hours of service providers. o Procedures for obtaining informed consent from survivors. • Coordination: Ensure clarity on roles and responsibilities between Mercy Corps / IPs and service providers to prevent delays or gaps in care. • Emergency Protocols: Include provisions for urgent cases, such as immediate medical attention for survivors of sexual violence. Training is essential to ensure that all staff understand and can effectively implement referral protocols. Key project staff, , particularly those in direct contact with community members or handling complaints, will undertake the following training:- • Survivor-centered approaches, including confidentiality and non-discrimination. 13 • How to assess survivors' needs and provide immediate support. • Effective communication techniques to handle sensitive situations. Protocols will be documented in a clear, accessible format and shared with all relevant stakeholders. • Documentation Features: o Flowcharts or diagrams to illustrate referral processes. o FAQs addressing common concerns about survivor support. • Dissemination Methods: o Printed manuals for field offices and service providers. o Digital copies accessible through organizational platforms. Activity 1.4. Protocols for Ensuring Complaints are Investigated/Verified in a Survivor-Centered Manner with Appropriate Accountability Mercy Corps has robust protocols for investigate and verify complaints ensures that incidents of misconduct, particularly Sexual Exploitation, Abuse, and Sexual Harassment (SEA/SH), are addressed transparently, ethically, and effectively. These protocols included survivor-centered principles that prioritize the dignity, safety, and well-being of those affected, while accountability measures uphold justice and organizational integrity. Using Mercy Corps CARM system, the project will set up handling processes to facilitate transparency and survivor-centered care:- • Receipt of Complaints: o Establish multiple reporting channels (e.g., hotlines, in-person, anonymous forms). o Ensure all reports are acknowledged promptly and confidentially. • Initial Assessment: o Determine the validity and severity of the complaint without making assumptions or decisions prematurely. o Classify complaints as SEA/SH-related or non-SEA/SH-related for appropriate handling. Activity 1.5. Ensuring Communities Are Aware of the Risks and How to Complain Raising community awareness about risks, such as exploitation, abuse, or harassment, and establishing clear, accessible complaint mechanisms is crucial for fostering a culture of safety, trust, and accountability. This activity involves targeted communication, awareness raising, and engagement to ensure that all community members understand potential risks and know how to safely report concerns or incidents. The activity will begin with understanding the specific risks faced by the community and identifying barriers to awareness or reporting. • Identify Vulnerable Groups: Women, children, people with disabilities, and marginalized communities often face heightened risks. • Understand Cultural Norms: Assess cultural perceptions of exploitation, abuse, and harassment to inform appropriate messaging. • Map Reporting Barriers: Analyze factors such as stigma, fear of retaliation, illiteracy, or lack of access to complaint mechanisms. The project team will develop culturally sensitive and context-specific campaigns to educate communities on risks and how to report complaints. Key messages will include: 14 • Define risks such as exploitation, abuse, harassment, and discrimination in relatable terms. • Emphasize zero tolerance for misconduct and Mercy Corps commitment to accountability. • Clearly explain how and where to report complaints safely and confidentially. Using Mercy Corps CARM systems, the project will develop a range of different channels: • In-person Methods: Community meetings, focus group discussions, and workshops. • Media Tools: Posters, leaflets, radio broadcasts, and videos using local languages and visuals. • Digital Platforms: SMS, WhatsApp, or social media campaigns (if accessible). Community awareness on GBV, SEA, and SH is critical for fostering a safe and supportive environment for all individuals, particularly women, children, and vulnerable populations who will be engaged through the project. To address GBV and SEA/SH risks, community sensitization efforts will target members at all levels, including men, women, youth, community leaders, and local authorities. The training and sensitization process will be tailored to the local context, leveraging culturally appropriate tools to ensure understanding and engagement. Sessions will include comprehensive information on the forms of GBV and SEA/SH, their consequences, and the rights of survivors. Emphasis will be placed on building community understanding of the importance of prevention, accountability, and support for survivors. Key stakeholders, such as traditional leaders, women’s groups, and youth groups, will be engaged as champions to amplify messages and promote behavior change. A vital component of these efforts will be educating communities on how to use the established CARM mechanism to safely report SEA/SH cases. Reporting pathways will be clearly communicated during awareness sessions, including the use of confidential reporting channels like dedicated hotlines, suggestion boxes, and direct reporting to trained focal points. The CARM system will be designed to respect survivors’ rights, ensuring confidentiality, non-retaliation, and survivor-centered approaches throughout the reporting process. Community members will also be made aware of how their reports will be handled with sensitivity and without fear of stigma. In cases where SEA/SH or GBV survivors are identified, the GRM will facilitate safe and confidential referrals to specialized GBV service providers. This referral process will adhere to national and international standards, prioritizing the dignity, safety, and privacy of survivors. Ongoing community engagement will include feedback mechanisms to improve GBV prevention and response efforts while fostering trust between service providers and the community. By addressing GBV and SEA/SH through awareness, accessible reporting systems, and robust referral mechanisms, this approach ensures a safer, more equitable environment for all under the project. 5 SEA/SH PREVENTION AND RESPONSE PLAN The SEA/SH Prevention and Response Plan outlines 1) how this project will put in place necessary protocols and mechanisms to address GBV/SEA/SH risk in accordance with the WBG Environmental and Social Standards (ESSs) and informed by respective Good Practice Notes on GBV/SEA/SH; and 2) how to safely handle SEA/SH incidents and support survivors. This plan consists of relevant SEA/SH risks identified or envisioned for the activities under the SOMOUD-AF; measures to mitigate them; and detailed project activities and timelines to provide SEA/SH services to survivors as well as to women and girls at risk. 15 This SEA/SH Prevention and Response Plan is based on the SEA/SH Action Plans for UNICEF and WFP, which are implementing Component 1 and Component 2 for the parent project respectively. 5.1 GBV/SEA/SH RISKS AND MITIGATION MEASURES There is no single driver of GBV, including SEA/SH. Evidence has shown that multiple risks of GBV/SEA/SH exist in every context at the individual, relationship, community, institution, and policy levels. Conflict, internal displacement, and lack of access to basic social services can exacerbate pre-existing gender and social inequalities, GBV/SEA/SH risks or increase the vulnerability and exposure to new inequalities. Poor design and implementation of project activities can also trigger unintended consequences of GBV/SEA/SH. Mercy Corps acknowledges that identifying and understanding project-related risk factors as they interact with other contextual risk factors is critical for developing appropriate prevention and mitigation measures in this project. As GBV/SEA/SH risks change over time, Mercy Corps will continuously assess and address them throughout this project period. The table below highlights key areas with prevailing and potential SEA/SH risks in the SOMOUD-AF and corresponding risk mitigation measures. Area Risks Mitigation Measures Ongoing ▪ Disrupted access to services under ▪ Women, girls, and boys will be consulted displacement and Component 1 and 2. Access to health when designing the improvement of access to services centers, safe spaces for women and girls, basic services that meet their safety unsafe learning spaces, and WASH facilities needs. Safe and ethical consultations environment (real including water points, bathrooms, and with women and girls will include or perceived) latrines has been severely impacted by ongoing safety audits at the service point the ongoing conflict. In some affected and/or facility level to assess prevailing communities including displaced camps- and potential GBV/SEA/SH risks, and to services are limited or unavailable. take appropriate actions to address Women, girls, and boys may be forced to GBV/SEA/SH risks identified and walk long distances, through dangerous recommendations from the routes, or at night to access these consultations. These actions may include facilities/services, and this may increase modifying facilities/services, or provision their vulnerability and exposure to of safety supplies. GBV/SEA/SH. ▪ Contextualize and share with partners ▪ Poor design of facilities such latrine and guidance on minimum safety and privacy spaces for women and girls in displaced considerations for establishing latrines settings that do not meet their safety and and safe spaces that meet safety and privacy needs- including segregation, privacy needs of women and girls. security perimeters, location, etc. can expose women and girls risks of GBV/SEA/SH. Humanitarian ▪ Large influx of workers to respond, ▪ Ensure the recruitment and deployment response and increases demand for sex work and/or processes of workers to support this provision of basic sex for basic services. project prioritize PSEA/SH screening services in conflict ▪ Affected communities may accept or from local communities, whenever skills affected condone GBV/SEA/SH as a means of are available. communities in survival or a means of seeking a ▪ Raise awareness in affected Somoud livelihood opportunity. Also, community communities about GBV, SEA, and SH members may not know where and how risks, and inform them about available to make GBV/SEA/SH disclosures/reports services for survivors, including where ▪ Competition between women and men and how to report concerns GRM and for local jobs and other livelihood seek support. 16 opportunities may place women and ▪ Raise awareness in affected adolescent girls at increased risk of SEA. communities on GBV/SEA/SH risks and ▪ Recruitment processes may prioritize available services for survivors including men over women. Recruitment of all men where/how to report (including GRM) as staff or local laborers may increase and seek support. risks of GBV/SEA/SH for women and girls ▪ Ensure project workers/frontline in the affected communities. workers, including subcontracted ones, ▪ Too much money in circulation, and hired, or mobilized to implement this higher wages for workers in a community project are trained/ sensitized on may lead to an increase in transactional GBV/PSEA/SH risk mitigation and how to sex. safely handle disclosures of GBV/SEA ▪ The risk of incidents of sexual activity incidents in line with established between laborers and minors, even when reporting mechanisms. it is not transactional, can also increase. ▪ Ensure staff and partners, including local hires are aware of PSEA/SH commitments, read and sign the respective safeguarding policies and/or Code of Conduct (CoC). ▪ Ensure equitable recruitment and mobilization of men and women for local jobs, and implementation of activities. This will also include mobilization of women and adolescent girls in community-based structures and groups. ▪ Where construction or rehabilitation work at facilities including safe spaces for women and girls, learning spaces, etc. is taking place, ensure it is done in a way that protects women and girls from GBV/SEA/SH (e.g., by avoiding proximity of workers to women, girls, and boys). Support to SMEs ▪ Risk of violence against particularly ▪ Awareness raising activities with SMEs women working as manual labor within management and staff concerning SMEs supported by the project SGBV. ▪ Women-led food processing SMEs are ▪ Grant agreement for SMEs to include likely to be harder to reach, as they may Code of Conduct with safeguarding be smaller, home based, and not commitments, and provision that any recognized among larger, male-led food cases of SGBV will result in exclusion of processing SMEs. They may be harder to this SME from the project identify, and may require additional ▪ Support SMEs that provide home based support to enable their growth work for women ▪ Specific measures to identify and encourage women-led food processing SMEs to bid for project support ▪ Selection criteria for food processing SMEs to take affirmative action for women-led SMEs and include a minimum %age women-led SMEs ▪ Undertake research to understand additional support needed for success for women-led SMEs – including ensuring marketing of produce is not 17 exploitative or exposes women to stigma / violence ▪ Lesson learned events throughout the project enable reflection on successes and weaknesses and refinement of approach Agricultural support ▪ Agricultural work that is considered ▪ Awareness raising sessions on ‘men’s work’ is often done by women, women’s rights, economic violence, and women’s contribution is not the positive outcomes for the recognized or compensated financially. community of women’s economic Increased crop production may result empowerment in increased exploitation of women ▪ Key messages developed and ▪ Boys and girls may be forcefully communicated to communities and recruited to work in the fields and key opinion formers exploited, mistreated, abused ▪ Partner assessment, onboarding and ▪ Even for crops grown exclusively by monitoring mechanisms to include women, it is men who take the crops to specific checks on child safeguarding, market, and they then control the highlighting prohibition of child labor income generate by sales and other broader forms of modern ▪ Enhanced production through women’s slavery (including labor exploitation). farmer’s organizations may also be sold ▪ Grant agreements to include specific by men, who retain the proceeds. provisions that prohibit child abuse ▪ f women challenge men’s economic ▪ Staff and partner to receive training controls they may face violent backlash sessions on child safeguarding, with in the household specific content on child labor, and training on human trafficking and exploitation. ▪ GRM, information on available reporting channels to be included in grant agreements ▪ Ensure women’s production is sold through consumer co-operatives, and develop payment mechanisms that go direct to the women ▪ Explore the use of collective sales of women’s agricultural produce, such that income generated is a business collective, making it harder for any individual husband to demand control over the income ▪ Research to understand women’s ability to retain control over income received, and relative bargaining power in house on household spending, and effective mechanisms to avoid backlash Grievance ▪ GBV/SEA/SH complaints that are not ▪ GRM will be established/strengthened Mechanisms handled safely, there are risks of and embedded in the project. Focal stigmatization, rejection, and reprisals points will be trained on how to safely against survivors, and this can lead to handle/forward complaints according to further abuse or harm. This reinforces a established complaint handling culture of silence, underreporting, and mechanisms and procedures and refer impunity. survivors to specialists. 18 ▪ GRM is not known to the community and ▪ Ensure safe and accessible GRM is in not accessible place. Ensure any information collected through the GRM is confidential - especially when related to the identity of the complainant. For SEA/SH, the GRM should primarily serve to: (i) refer complainants to the GBV service provider; (ii) document the complaint, and (iii) refer/forward the complaint to the relevant actors in line with the established complaint handling mechanisms/procedures. It is worth noting that GRM Focal Points are not GBV/SEA/SH investigators and must not/never investigate, mediate, and or negotiate GBV/SEA/SH incidents disclosed to them. The role of GRM Focal Points is to forward any GBV/SEA/SH complaints received to relevant actors/agencies and refer survivors to available specialists. ▪ Ensure that GBV/SEA/SH service providers will have own case management to gather the necessary detailed data to support the complainant through the appropriate service and facilitate appropriate referrals. ▪ Provide awareness sessions on GBV and GRM for the communities. Partnerships and ▪ Implementing partners may have ▪ Ensure that agreements with contracts to limited/no capacity to implement a safe IPs/contractors, including their support programs GBV/SEA/SH programming including not recruitment and procurement processes implementation having adequate safeguarding policies and other subcontracts include and procedures. appropriate commitments on GBV/SEA/SH (including building their staff capacity) ▪ Ensure risks for GBV/SEA/SH is assessed and relevant capacity building plans development and implemented based on needs. ▪ For partners that lack substantial safeguarding policies, ensure that they sign a Code of Conduct outlining safeguarding principles they are expected to adhere to, and that they receive training as part of capacity development Social and gender ▪ Gender inequalities and harmful or ▪ Assess norms that are perpetrating norms (including restrictive social/gender norms (including GBV/SEA/SH and develop appropriate community perceptions) may condone and normalize community-based interventions to perceptions about GBV/SEA/SH in communities. Family and positively shift such norms. Community GBV/SEA/SH) community members may mediate members, including key influencers will GBV/SEA/SH incidents. Survivors may be identified and supported to start fear reporting incidents or to seek shifting these norms positively, denouncing GBV/SEA/SH in their 19 services due to norms and existing communities, and supporting survivors to practices. seek services. ▪ Services providers targeted for providing ▪ Training of key stakeholders and IPs on a GBV/SEA/SH services. survivor centric approach. Key stakeholders would be community leaders, CSOs, HFs / CHWs and local government officials ▪ Ensure GBV/SEA/SH services are provided from survivor-centered perspective (with focus on safety, confidentiality, consent, and trust) through trained service providers/focal points, and through safe referral mechanisms. Communication ▪ Women and girls may have limited ▪ As part of the Stakeholder Engagement and Outreach mobility and access to accurate Plan (SEP), Mercy Corps engages in information about their safety and consultations with local stakeholders, wellbeing. including women lead organizations and ▪ Where safety and wellbeing messages women’s groups to develop acceptable are conveyed in public places, women communication materials and messages. and girls may be excluded or ▪ Target women and girls in safe spaces communication materials may not be such as safe spaces for women and girls, age, gender, and context health/nutrition facilities, and schools specific/appropriate. for consultations/messaging. ▪ Where GBV and SEA message is ▪ Communication materials intended to conveyed, outreach efforts and reach women and girls are designed communication materials may not reach with low-literacy audiences in mind and women and girls due to their lower means of reaching them through literacy, exclusion from decision-making community health and nutrition processes, social norms, or limits to volunteers/workers, community leaders cross-gender interactions in case the and women’s groups. person conveying the message is a man. ▪ Target men and adolescent boys with specific messages to address negative perceptions towards women and services intended for women Data collection and ▪ GBV/SEA/SH issues are very sensitive, ▪ Train frontline workers, third-party management and poor handling of GBV/SEA/SH monitors (TPM) and community including information/data, including data structures including CFM/GRM focal monitoring and collection and management may put points on safe and ethical GBV/SEA/SH evaluation survivors, their families, and service information/data collection, providers at further risk. Poor management, and sharing (with focus GBV/SEA/SH information/data collection on the dos and don’ts). and management may also tarnish the ▪ At any time, media is going to be good reputation of partners and donors, involved in this project, orientate, or risk their operational safety including train them on safe and ethical closure and expulsion, and or eventually engagement with beneficiaries. impact future reporting from ▪ Ensure project focal points, including beneficiaries, and safe access to their consultants should never seek out interventions. survivors of any form of GBV/SEA/SH or question them about their incidents. 20 5.2 OUTPUTS AND ACTIVITIES PSEA/SH PROJECT ACTIVITIES, EXPECTED RESULTS, MEANS OF VERIFICATION, AND EXTIMATED BUDGET Output Activity Expected Result /Indicator MoV Estimated Budget3 1. Improving Map existing Service mapping conducted Project $350,000 the GBV/SEA/SH services (Y/N) Activit availability and capacity y of, and reports accessibility Consult women, girls, # of project localities and Project to SEA/SH boys, and men to communities with a activity response establish and or functional GRM reports services strengthen the existing while GRM mitigating Ongoing GBV/SEA/SH semiannually safety audits Safety risks and safety analysis and conducted (Y/N) audit preventing audits reports incidents Implement actions based The extend risk mitigation Project on safety analysis/audits action plan implemented activity findings and (Y/N) reports recommendations Facilitate community # of people reached with Project dialogues/awareness on GBV prevention messages Activity GBV/SEA/SH prevention Reports/ Attendance Records Implement and/or # of community-led actions Project support community-led supported activity actions to prevent reports SEA/SH 2. Building Train GBV service / % of service providers Training $700,000 capacity for health providers on GBV sensitized or trained reports frontline case management workers, processes community Train frontline workers % of people trained and Project protection and community groups signed a soC activity networks, on GBV/PSEA/SH/PFA reports, women training groups, and records women-led Provide ongoing Periodic field monitoring Project organizations technical support to support visits conducted activity trained frontline workers reports, and community groups training records 3. Technical Map capacity to respond Local authorities and Project $400,000 Assistance to GBV/SEA/SH capacities assessed activity and training reports, assistance to Train local authorities on # of local authorities Project local GBV/SEA/SH/PFA basics sensitized or trained activity authorities and safe referrals reports, 3 The estimated budget is an integral part of the component (1) activities 21 Output Activity Expected Result /Indicator MoV Estimated Budget3 Participate in GBV AoR, Active participation Coordinatio PSEA network /AAP WG enhanced n coordination forums attendance records 4. Staff Provision of training to # of staff that received Participant $50,000 capacity and staff in PSEA and PFA training. list accountabilit y Staff sign Code of % of staff that has signed CoC COC conduct and clarity on documents disciplinary measures Partner capacity # of partner assessments Note for assessment in PSEA with conducted Record of any remedial actions completed assessment and remedial actions 5. Sensitize Develop & integrate Components developed Standard $400,000 farmers co- relevant components for contracts operatives, standard contracts include SMEs, and (Farmers organisations, provisions community SMEs) Develop awareness Materials available Awareness raising materials relevant raising to 1) SEA/SH/SGBV, 2) materials women’s rights, economic violence, women’s economic empowerment Deliver awareness # of awareness sessions held Participant raising sessions farmers, lists/report SMEs, community s/photos Engage with key opinion # of engagements held formers / gatekeepers with awareness raising materials on 1) SEA/SH, 2) women’s rights, economic violence, women’s economic empowerment, plan and deliver sessions Use participatory and # of awareness sessions held Periodic consultative approaches report to introduce project & PSEA, eligibility criteria, participation of women, create awareness of the available reporting channels 6. Identify opportunities to # of opportunities identified Note $500,000 Affirmative enhance women’s included in 22 Output Activity Expected Result /Indicator MoV Estimated Budget3 action for engagement in the SME regular ESS women workforce (eg home- reporting based working), and integrate into SME support Research to identify Research results available Research measures to encourage report women-led food processing SMEs to engage in the project, including adaptation of selection criteria and any specific additional support needed Establish mechanisms Mechanisms established Note for women farmers to included in sell produce and retain regular ESS control of income reporting Lessons learned events # of lessons learned events Note to reflect on successes of held included in affirmative actions regular ESS reporting 7. Review the existing M&E tools reviewed and/or Revised $65,975 Monitoring, tools, and modify where modified tools with Evaluating, applicable to include SEA/SH Reporting SEA/SH results inputs (including framework Documenting Training monitors # of frontline workers (third- Project Lessons/Best (including the third-party party monitors) trained activity Practices) for monitors) on safe/ethical reports, Learning and data collection and training Future management records Programmin Monitor, evaluate, report GBV/SEA/SH results Project g: and document SEA documented and shared reports, results, lessons learnt accordingly assessment and best practices reports (case studies) GBV/SEA/SH Action Plan Reporting Who To Whom What When Objective GRM GBV service GBV/SEA/SH (survivors) As soon as To ensure survivors operators, providers possible avail immediate Frontline care Workers Mercy Corps SEA/SH allegations with the following As soon as To escalate the case based via data sources: 1) Nature of the case, the report with concerned established 2) project related (Y/N), 3) Age/sex, is received agency for further reporting and 4) Whether survivor was referred action, including channels and to GBV specialist (Y/N) timely investigation SOPs 23 Partners/TPM Mercy Corps SEA/SH Action plan implementation- During To measure the risk mitigation measures, monitoring/ extend the project GBV/SEA/SH project activities evaluation results are realized Mercy Corps World Bank Status on the implementation of As part of Regular progress project’s SEA/SH Action Plan regular reporting progress report 6 STAFFING AND COUNTRY CAPACITY FOR GBV/SEA/SH RESPONSE, RISK MITIGATION AND PREVENTION To implement this project, the Mercy Corps Sudan Country Office will have one GBV Specialist that will work on delivering the SEA/SH Prevention and Response Plan. The GBV Specialist will receive technical support and guidance from GBV and PSEA specialists at the regional office and headquarters. She or he will work in close collaboration with the Risk Manager and the Environmental and Social Safeguards Specialists. 7 IMPLEMENTATION ARRANGEMENT As per World Bank Operational Policy (OP) 7.30 on Dealing with De Facto Governments, the project will be implemented via Third Party Implementation (TPI), whereby Mercy Corps is the implementing party for the AF. Mercy Corps will work primarily in partnership with Save the Children on Component 1 and Mercy Corps will be the main implementer of Component 2. All implementation will be done with local contractors, NGOs and CSOs to implement the activities in collaboration with the local government, parastatal entities, and community-based organizations, particularly the Community Development Committees (CDCs). Mercy Corps will establish a Project Implementation Unit (PIU) within its Sudan office (as appropriate based on the security situation) and carry out day-to-day management and implementation of the activities. As such, this SEA/SH Prevention and Response Plan will be implemented by Mercy Corps and its partners for both, Component 1 and 2. Mercy Corps or partners will coordinate with local SEA/SH service providers. Mercy Corps will have the overall responsibility for the implementation and monitoring of this Plan. Under the technical leadership of the Mercy Corps GBV Specialist, the Sudan Country Office will ensure that partners conduct SEA risk Assessments, and based on the capacity, partners are supported to develop plans to address any gaps and shortcomings across SEA/SH prevention, reporting, survivor assistance and ensuring accountability on all reported cases through safe and prompt investigations. Mercy Corps also ensures that IPs receive technical support to put in place robust SEA prevention, reporting and response mechanisms. Partnership Agreements and contracts also carry a PSEA clause, including zero tolerance statements. Reporting of SEA incidents is mandatory, and all partners and contractors are informed of the available reporting channels. 8 ACCOUNTABILITY FRAMEWORK- SEA/SH Key SEA/SH Interventions: 24 a. PREVENTION: Capacity building of Mercy Corps Staff, Implementing Partners, and Contractors: Mercy Corps will ensure that mandatory PSEA training is conducted for all staff and implementing partners including contractors to create awareness on PSEA obligations. Awareness raising and messaging: Mercy Corps and partners will conduct ongoing awareness raising sessions among the affected population in project implementation sites. These sessions are conducted to inform the affected population about what constitutes SEA/SH, the prohibited behaviours for all humanitarian workers, their rights to access assistance without any exchange for sexual, financial, social or political gains. In addition, communities are also sensitized so that they are aware that aid workers are not allowed to engage in sexual relationships with beneficiaries and the prohibition of all forms of abuse of power by aid workers over the local population, and prohibition of sexual activities with children under 18. Community members are encouraged to report these abuses using the available reporting channels. These messages which are gender, age and culturally appropriate are translated into local languages before they are disseminated among the affected population in all Mercy Corps supported project implementation sites. b. INCIDENT RECEPTION AND CATEGORIZATION Management of SEA/SH complaints: SEA/SH complaints and all the other serious ESS incidents are received through a hotline or through any other means as per regular complaints. For the management of SEA/SH complaints, Mercy Corps has a dedicated Global Safeguarding Investigations team within the Ethics and Compliance Department. For community members and program participants, Mercy Corps provides accessible and locally relevant Community Accountability Reporting Mechanisms (CARM)s for communities to provide feedback on all aspects of our programming, make suggestions, inquiries or complaints, and report concerns. There is a robust Community Accountability Reporting Mechanism (CARM) in place at country and project levels in Sudan. CARM was developed as part of Mercy Corps’ global commitment to accountability to affected populations and the prevention of all forms of exploitation and abuse. CARM is a channel for any and all community members, project participants, and stakeholders including those related to product quality and vendor performance to provide feedback, suggestions, complaints, and concerns, in a manner that is safe, confidential, transparent, and accessible, therefore enabling Mercy Corps to respond and make any necessary adaptations. The primary goal of the CARM mechanism is to enhance accountability to project participants while providing a clear channel for project stakeholders to voice feedback and grievances regarding project- supported activities. By promoting transparency, CARM aims to minimize risks of unintended consequences on citizens and beneficiaries. Additionally, it serves as a vital feedback mechanism, allowing us to improve project impacts and responsiveness. Mercy Corps CARM mechanism complies with the World Bank’s requirements by facilitating timely responses to SEA/SH complaints which are directly reported and handled by the Mercy Corps Safeguarding Investigations team. Mercy Corps will ensure that all SEA/SH concerns raised by project-affected parties are acknowledged and addressed promptly. It incorporates multiple channels for receiving complaints safely and confidentially, allowing for broad participation from affected individuals and communities. Community Accountability Reporting Mechanism (CARM) and Complaints and Reporting Mechanisms: Mercy Corps encourages a culture of openness where team members, partners, project workers, beneficiaries, community members, and other stakeholders can safely raise their concerns, ask questions, 25 and report unethical behavior. To ensure accessible and trusted reporting mechanisms, we have multiple methods available to report concerns or seek advice. Mercy Corps' Integrity Hotline offers several options to confidentially report unethical behavior or seek advice in a secure manner. 1. Reports can be submitted in any language directly to the Ethics and Compliance Department (ECD) at integrityhotline@mercycorps.org; 2. Reports can be submitted through the Integrity Hotline web portal, mercycorps.org/ integrityhotline, which is available in multiple languages. 3. Reports may be submitted by calling our Integrity Hotline local phone lines, which are administered by a third-party contractor and provide live assistance in over 50 languages, 24 hours a day 4. Reports may be submitted through suggestion boxes at the sub-project sites 5. Or reports may be submitted in person to Project staff. Mercy Corps has a full suite of established guidance, templates, and SOPs for CARM design, implementation, and management. CARM support is provided to all country teams by a dedicated global Community Accountability Advisor. Mercy Corps Sudan has a clear procedure and system in place to effectively receive and manage complaints, including those related to environmental and social issues, and to ensure that the necessary adaptations are made in response to that feedback. Communities will be engaged through focus group discussions to ensure that context-appropriate and accessible feedback channels are implemented in intervention communities. Community members will also be engaged to ensure they are sensitized to the availability, purpose, and functionality of CARM. Community members, beneficiaries, project workers and stakeholders including suppliers, vendors, etc. can submit feedback to Mercy Corps throughout the life of the project, ensuring activities remain responsive to changes in context and need. All roles and responsibilities related to CARM will be delegated appropriately to minimize any potential conflict of interest in the handling of feedback. Mercy Corps grades all feedback received according to six grades that have been standardized globally, to ensure that all feedback received the attention and resources necessary to bring each case to a close in a manner that is satisfactory to the informant and protects their safety. For all matters of potential fraud, corruption, exploitation, or abuse, the Mercy Corps HQ Ethics team will provide expertise and lead the country team in an investigation. Mercy Corps CARM outlined above is well aligned with the World Bank's ESS10 requirements by prioritizing transparency, inclusiveness, and responsiveness in project implementation. ESS10 emphasizes social and environmental standards, stakeholder engagement, and grievance redress mechanisms—all of which are integral to CARM. Our CARM system provides an accessible, transparent, and confidential platform for communities to voice concerns or feedback, which aligns with the ESS10 requirement for robust grievance redress systems. By offering multiple communication channels (e.g., hotlines, suggestion boxes, in-person reporting), CARM ensures that all community members, particularly marginalized groups, can participate in project oversight. Recognizing the sensitive nature of Sexual Exploitation and Abuse (SEA) and Sexual Harassment (SH) cases, CARM incorporates specific considerations to protect and support survivors. The mechanism offers confidential reporting options, allowing individuals to raise concerns without disclosing their identity if they choose. This is crucial in encouraging survivors to come forward, as they may fear stigmatization or retaliation. 26 In addition, the safeguarding team provides dedicated training for staff on handling SEA/SH cases, focusing on the importance of a survivor-centered approach. This will led by the Safeguarding team who receive specific training on the survivor-centred approach. All grievance recipients are trained to ensure that grievances are managed with the utmost sensitivity, confidentiality, and respect for the survivor’s wishes. The mechanism also facilitates access to necessary referral services, including medical, legal, and psychological support, ensuring survivors receive comprehensive care. By incorporating these specific considerations into its grievance redress framework, Mercy Corps’ CARM not only complies with World Bank ESF requirements but also promotes a safe and supportive environment for all project-affected individuals, particularly those who may be vulnerable to SEA/SH issues. This commitment to accountability and responsiveness enhances the overall effectiveness of project interventions and fosters trust within the communities served. C. REPORTING: The Global Safeguarding team will ensure that the donor, World Bank, will be notified of all reported cases of SEA/SH within 48 hours of receiving a case, and any broader safeguarding (including child safeguarding) through the reporting templates included in Annex 4 of the Stakeholder Engagement Plan (SEP). Mercy Corps and its partners, in consultation with the affected population, will establish and or strengthen existing safe and accessible reporting mechanisms in supported project implementation sites to allow victims to disclose any complaint, SEA/SH, confidentially. These include a hotline. Once a report has been received, Mercy Corps Global Safeguarding team will send a notification to the relevant World Bank Representatives within 48 hours of Mercy Corps learning of the event. Within 10 days of the initial notification, Mercy Corps Ethics team will provide the World Bank with an initial report regarding the incident along with the proposed follow up actions. d. RESPONSE (Victim Assistance) Mercy Corps is deeply committed to a survivor-centered approach in all aspects of our work. We strive to provide all survivors with a safe, supportive, and confidential place to come forward, where their needs will be our first priority. In doing so, we aspire to help promote recovery and ensure survivors can identify and express needs, wishes and concerns. We align our approach with the principles outlined in the IASC Definition and Principles of a Victim/Survivor-Centered Approach and the UN Victims’ Rights Statement. We strive for a holistic or “end-to-end" approach, which places the rights, wishes, needs, safety, dignity and wellbeing of survivors at the center of all prevention and response measures concerning trafficking, child abuse, sexual exploitation, abuse and harassment. Mercy Corps has a specific safeguarding core standard highlighting the organization’s commitment to ensuring a survivor centered approach in managing safeguarding investigations and operationalizing our commitment to survivors. We develop and maintain a survivor referral service map for each respective project intervention area to ensure timely referrals to support services, including medical, psycho-social, security, legal and transportation resources. We collaborate with the PSEA Network and other protection actors where possible and available to ensure access to services. e) Mercy Corps and Partner accountability for Victim Assistance Partners’ accountability for victim assistance is set out in the project documents and contractual documents between IPs and Mercy Corps. All IPs and contractors have a responsibility to ensure victims of 27 SEA allegedly perpetrated by their personnel receive immediate professional assistance from relevant service providers, as per the victim’s wishes and with their informed consent/assent. Mercy Corps will be accountable to act on complaints involving its staff – that is, to provide support to survivors with utmost priority to children to conduct impartial and confidential investigations without exposing survivors to more harm; and to apply appropriate disciplinary action against perpetrators. While the accountability for violations by personnel of implementing partners, contractors and suppliers/ vendors rests with those entities. Mercy Corps will ensure that SEA / SH responsibility is cascaded down to IPs and contractors as part of their contracts. Mercy Corps will also monitor that the partners are accountable and meet stated requirements in terms of victim assistance. f) Investigations on SEA\SH, and boarded Safeguarding violations Mercy Corps is committed to a timely, thorough, and survivor-centered response to all safeguarding allegations. We have a diverse, multilingual team of regionally based sexual exploitation, abuse, and harassment investigators trained in trauma-informed, survivor-centered investigative practices who are not part of the program teams to ensure confidentiality. These investigators report to our Senior Director of Safeguarding Investigations. Our investigations unit is part of the independent Ethics and Compliance Department led by our Chief Ethics and Compliance Officer and reporting directly to the CEO and the Board. A network of trained country Co-Investigators supports our professional investigators. Safeguarding Co-Investigators provide local, contextual support to investigations and play a vital role in our ability to offer survivor-centered support and timely in-country response when needed. Co-investigators undergo SEAH-specific investigations training and work under the direction of lead investigators. Whenever a child is involved, the best interests of the child will be the foundational consideration throughout the reporting, investigation and case management processes. Mercy Corps’ Speak Out! Policy outlines protections for reporters and witnesses including zero tolerance for retaliation. Team members are required to cooperate with investigations and keep them confidential; failure to do so may result in disciplinary action. (Note that Survivors are never required to participate in investigations and are offered support whether or not they choose to participate). All substantiated safeguarding allegations result in appropriate disciplinary action up to and including termination. We are committed to transparency and publish information on the number of safeguarding reports we receive, the conclusion of our investigations and disciplinary action taken annually in our Global Safeguarding Report. 28 Case closure: To consider the case is closed for the Somoud AF, Mercy Corps will use the appropriate WB ESIRT template to report to the WB on whether an investigation was carried out, outcomes of that investigation, and implementation of the corrective actions based on the underlying causes. The Safeguarding investigations team will update the donor once the investigations are complete and internally within Mercy Corps the Director for Safeguarding Investigations provides a report outlining any corrective actions that the project should implement. This report is shared with Regional and Country Leadership, and the Regional Safeguarding Advisor for implementation, including any specific adaptations required for the program. Survivor support for safeguarding incidents is fully coordinated by the safeguarding investigations team. e. Programmatic Review: After the investigations, a review of the processes is undertaken to learn and know if systems in place can promptly respond to breaches of SEA/SH. These include Survivors’ response- to understand whether the survivor was responded to in a safe, confidential and timely manner; investigations-whether the quality of the investigation processes including the methodology and approaches used were done objectively; and programmatic risk assessment-to identify gaps and barriers and put in place risks mitigation measures. The GBV Specialist, in collaboration with the Safeguarding Coordinator, shall conduct periodic analysis of the SEA complaints to depict trends and advise senior management on conclusions and recommendations emanating from the analysis. 29