Global Safeguarding Policy

1.1 This Global Safeguarding Policy (“Policy”) establishes CNEWA’ s universal minimum standards for safeguarding minors and vulnerable persons. It applies worldwide to (a) all Personnel and (b) all Implementing Partners (as those phrases are defined in Sections 3(d) and 3(e), below).

1.2 This Policy is a global umbrella framework. CNEWA is an intermediary funding and monitoring organization that does not implement programs or manage the personnel of its Implementing Partners; each Regional Office will maintain a local safeguarding policy consistent with this Policy and applicable local law, subject to CNEWA’s advance approval of any locally developed policy for consistency with this Global Safeguarding Policy.

2.1 CNEWA is committed to the dignity, safety, and well-being of every person, particularly minors and vulnerable adults, and maintains zero tolerance for abuse, exploitation, neglect, and harassment.

2.2 This commitment is informed by Catholic Social Teaching, the Holy See’s safeguarding framework, including Vos Estis Lux Mundi and the Pontifical Commission for the Protection of Minors, and international standards including the United Nations Convention on the Rights of the Child, the Convention on the Rights of Persons with Disabilities, the IASC Protection from Sexual Exploitation and Abuse framework, and Keeping Children Safe International Standards. 

2.3 CNEWA will take reasonable measures, consistent with applicable law, to prevent harm, respond to concerns promptly and fairly, protect confidentiality, cooperate with civil authorities, and promote dignity, respect, prevention, shared responsibility, and the best interests of minors and vulnerable persons throughout its operations and among Implementing Partners.

For purposes of this Policy, the following terms establish minimum standards and may be supplemented by Regional Office policies to reflect applicable local law or broader protections.

• “Minor” or “Child” means a person under eighteen (18) years of age, or any higher age specified by applicable local law.
• “Vulnerable Person” or “Vulnerable Adult” means an adult whose circumstances —including disability, illness, age, infirmity, displacement, economic deprivation, or other condition — materially reduce the person’s ability to protect against abuse, exploitation, or neglect.
• “Abuse” means any act or omission that causes or risks harm, including physical abuse, emotional or psychological abuse, sexual abuse (including sexual activity involving a minor regardless of consent), financial abuse, neglect, exploitation, harassment, or misuse of authority.
• “CNEWA Personnel” means all individuals employed by CNEWA.
• “Implementing Partner” means a local church institution, organization, or other entity that receives CNEWA funding or support to implement programs or services for target populations.

4.1 CNEWA is an intermediary institution of the Holy See that provides funding, monitoring, technical guidance, and oversight to Implementing Partners; it does not directly implement programs, recruit or manage partner personnel, accept or enroll beneficiaries, or deliver services. 

4.2 CNEWA will ensure the conduct of its Personnel is consistent with this Policy during CNEWA activities, including field visits and monitoring.

(a) CNEWA will ensure that every photograph, video, story, and other media involving beneficiaries will be used with respect for the individual’s innate human dignity.

(b) CNEWA will protect personal data obtained through monitoring, field visits, and partner reporting in accordance with applicable law.

(c) CNEWA will inform visitors accompanying CNEWA Personnel or participating in CNEWA-sponsored activities of applicable safeguarding standards and require appropriate conduct.

4.3 CNEWA will require all Implementing Partners to develop or update and maintain a safeguarding policy in accordance with locally applicable law, subject to CNEWA’s review and approval for consistency with this Global Safeguarding Policy. This requirement is not intended to, and does not, constitute operational control or assumption of legal liability for their programs, personnel, or internal management.

5.1 Each Implementing Partner bears full and independent responsibility for safeguarding within its programs, operations, and activities and will maintain safeguarding policies and practices appropriate to its work, consistent with applicable law.

5.2 Each Implementing Partner will annually execute CNEWA’s Agreement Regarding the Welfare of Minors and Vulnerable Persons (Administrative Policy A69), promptly notify CNEWA of any safeguarding allegation, incident, or concern affecting or potentially affecting CNEWA-funded activities, and address such matters under its own responsibilities. CNEWA does not assume legal or operational responsibility for the internal management or misconduct of partner personnel; the parties are a funder and grant recipient, not employer and employee, principal and agent, or joint venturers, and nothing in this Policy imposes liability on CNEWA for partner acts or omissions.

6.1 Each Regional Office will maintain a local safeguarding policy consistent with this Policy and all applicable local law, designate specific individuals or positions within its organization to whom concerns and reports about violations or deviations from its policy must be directed, and report safeguarding matters to CNEWA headquarters. Local policies may provide greater protection but will not provide less protection than this Policy, to the extent permitted by local law, and will in all cases be maintained by the Regional Office in accordance with applicable local legal requirements.

7.1 All CNEWA Personnel will treat every person with dignity, respect, fairness, and courtesy; act with integrity and professionalism; comply with applicable law and CNEWA policy; and avoid conduct that could reasonably cause harm or appear exploitative or inappropriate. Each Regional Office will adopt a local code of conduct consistent with these minimum standards.

7.2 CNEWA Personnel will not engage in physical, emotional, psychological, or sexual abuse; exploitation, neglect, harassment, bullying, intimidation; discrimination, trafficking, or other conduct that places a minor or vulnerable person at risk, including exchanging benefits for sexual activity.

(a) When interacting with minors or vulnerable persons, CNEWA Personnel will avoid private or unsupervised one-on-one settings absent appropriate safeguards, inappropriate physical contact or relationships, and use of any person for personal labor or domestic services; concerns will be reported promptly under Section 8 of this Policy.

(b) CNEWA Personnel will ensure the respect, dignity and privacy of all individuals before creating or using photographs, videos, stories, or other media involving beneficiaries. Personal data and safeguarding information will be kept confidential and secure in accordance with applicable law and CNEWA protocols.

8.1 All CNEWA Personnel will promptly and in good faith report any known or suspected safeguarding concern involving CNEWA operations or CNEWA-funded activities. Reports may be made to a supervisor, the relevant Regional Safeguarding Officer, or CNEWA headquarters through the Director of Human Resources; if a supervisor is involved, the report may be made directly to the latter channels. CNEWA will maintain confidentiality to the extent consistent with a proper response, applicable law, and the need to share information on a need-to-know basis. 

8.2 CNEWA prohibits retaliation against anyone who in good faith reports a concern, participates in an investigation, or cooperates with authorities, consistent with Personnel Policy P47. CNEWA will cooperate with civil and governmental authorities as required by applicable law and will not delay any mandatory report. 

8.3 CNEWA Personnel who violate this Policy or an applicable local safeguarding policy may face discipline up to and including termination, subject to applicable law and CNEWA procedures. For partner violations, CNEWA may require capacity-building or remediation, enhance monitoring, suspend funding, or terminate the partnership or funding in accordance with A69 and applicable agreements.