Policies

1. Purpose and Application

This Annex forms part of JES's Safety and Security Framework for International Programming. It provides practical guidance for consultants and national participants engaged in JES-supported international activities, including travel, workshops, meetings, consultations, site visits, trainings, and other programme-related events. The guidance applies to all consultants engaged by JES and to national participants while participating in JES-supported activities. Some requirements apply specifically to international travellers; others apply to all participants, including those attending activities in their own country. This Annex should be read together with the Core Framework and any relevant country-level safety and security notes. Where country-level guidance is more specific or more restrictive, that guidance prevails.

2. Core Expectations and Shared Responsibilities

Safety and security are shared responsibilities. JES will take reasonable steps to plan activities safely, monitor the operating context, select appropriate accommodation and venues, provide relevant briefings and contacts, and respond to incidents or emergencies in a manner appropriate to the circumstances. Consultants and national participants are expected to act prudently, follow JES instructions and local partner advice, comply with local laws and customs, and avoid conduct that may increase risk to themselves, other participants, JES staff, partners, or programme activities. JES does not provide armed protection, and JES staff and consultants are not armed. Participants should not assume that all risks can be eliminated. Remaining alert, exercising good judgement, and seeking advice before acting are central to personal safety.

Important: Participation in activities outside the JES-approved agenda - such as crime scene visits, unplanned institutional visits, travel to high-risk areas, or meetings arranged by third parties - must be cleared in advance with the relevant JES Project Director, International Program Director, Assistant Director, International Programs, or other designated JES focal point.

3. Preparation Before Travel or Participation

Before travelling or participating in a JES-supported activity, consultants and participants should ensure they understand the basic security, health, and logistical arrangements for the activity. JES will provide information appropriate to the role, location, and level of assessed risk. International travellers should complete the following before departure:

Review current Government of Canada travel advice, or equivalent national travel advisories, for the destination country before and during travel.

• Register with the relevant embassy or consulate travel registration service where available, and update the registration for each trip.
• Check travel health notices and obtain any required vaccinations, medications, or medical advice in advance of travel.
• Ensure passport validity meets entry requirements, normally at least six months beyond the date of travel unless a longer period is required.
• Carry copies of the passport identification page, visa or entry documents, insurance information, and any other key documents, keeping originals secure once in country.
• Ensure a mobile phone will function in the destination country and that emergency contacts are saved in the phone and kept separately in hard copy.
• Confirm airport pickup, accommodation details, JES contacts, local emergency contacts, and any specific arrival instructions before departure.
• Review medical and travel insurance arrangements, including the emergency assistance number and claims process. National participants attending in-country activities should, where relevant, confirm venue, transport, start and end times, emergency contact arrangements, any personal medical needs, and any safety considerations that may affect their participation.

4. Arrival, Registration, and Orientation

On arrival in country, international travellers should follow JES pickup and arrival instructions and avoid making alternative arrangements unless cleared with the designated JES contact.

• Keep luggage identification discreet and avoid displaying full names, titles, or institutional affiliations unnecessarily.
• If a pickup has been arranged, confirm the driver's identity carefully. Ask the person to identify themselves rather than offering the expected name first.
• If in doubt about the person collecting you, return inside the airport or terminal and call the designated JES contact.
• Do not arrive under the influence of alcohol or any substance that may affect alertness or judgement.
• Avoid changing money at airports or in exposed public areas unless specifically advised that it is safe to do so.
• Attend any arrival or activity briefing provided by JES, local staff, hotel staff, or institutional partners, including guidance on safe and unsafe areas, transport, emergency contacts, and any current risks.

5. Accommodation and Venue Safety

JES will seek to use accommodation and venues that meet appropriate safety standards for the location and activity. Consultants and participants should follow hotel, venue, and JES guidance and should raise any safety concerns promptly.

• Keep passports, excess cash, additional bank cards, and valuables secured where possible.
• Know emergency exits, meeting points, front desk or security contacts, and the safest route between accommodation, venue, and approved transport.
• Do not invite guests to JES offices, event venues, or accommodation areas used for JES activities without prior approval from JES staff.
• Report concerns about accommodation, venue safety, harassment, threats, transport arrangements, or suspicious activity to the JES focal point as soon as practicable.
• Follow venue-specific evacuation or emergency procedures in the event of fire, natural disaster, civil unrest, or other emergency.

 

6. Conduct and Personal Security

Consultants and participants should take precautions similar to those they would take in a high-crime area, adapted to the local context and the guidance provided by JES and local partners.

• Do not display wealth through jewellery, watches, cash, cameras, laptops, tablets, phones, or other visible valuables.
• Avoid using laptops or handling sensitive documents in public spaces. When carrying equipment, use an ordinary bag rather than a laptop bag where possible.
• Carry only the cash and cards needed for the day. Keep other funds and cards secure.
• Avoid automated banking machines unless JES or local staff advise that a specific location is safe.
• Do not leave valuables visible in parked vehicles. Seek local advice if deciding whether to carry or secure equipment.
• Avoid taking photographs without permission, particularly of children, women, security personnel, police, military, court facilities, crime scenes, or sensitive infrastructure.
• Keep prescription medication in its original container, with the patient's and prescribing doctor's names clearly identified where possible.
• Be cautious when approached by persons claiming to be police or officials. Politely ask to contact the JES focal point or partner institution before complying with unexpected requests.
• Do not leave food or drinks unattended or accept snacks, drinks, gum, cigarettes, or similar items from strangers or new acquaintances.
• Do not accept invitations, transport, or suggestions from strangers, and do not discuss JES's work with casual acquaintances.
• Avoid demonstrations, large gatherings, areas of visible tension, and any location that feels unsafe or unfamiliar unless JES has advised otherwise.

 

7. Travel and Transportation

Transport arrangements will normally be made or approved by JES. Consultants and participants should not make independent journeys connected to JES activities without first considering safety implications and, where relevant, consulting JES or local partners.

• Use transport arranged by JES, local staff, trusted partners, the venue, or the hotel. Do not hail taxis in the street unless JES has advised that this is safe in the specific location.
• Avoid travelling at night wherever possible, particularly between cities or through unfamiliar areas.
• Do not use public buses or informal transport where these are assessed to pose heightened risks of crime, road traffic accidents, or unreliable safety standards.
• Do not travel in visibly marked institutional vehicles where doing so may increase risk, unless JES has assessed and approved the arrangement.
• If using a taxi or hired vehicle, ensure the driver does not pick up additional passengers. Wait indoors until the vehicle arrives where possible.
• When travelling by car, keep doors locked, windows closed, valuables out of sight, and seatbelts fastened in both front and rear seats. If a vehicle does not have functioning seatbelts, refuse the journey and seek an alternative.
• Remain alert to motorcycles when walking or travelling by vehicle, as motorcycles may be used in theft, robbery, or surveillance in some contexts.
• Do not walk unaccompanied unless the local context has been assessed as safe. Where walking is unavoidable, stay in well-lit, populated areas, avoid phone use or headphones, and move directly and confidently to your destination.
• For border crossings or inter-city travel, carry required identification and follow the instructions of the JES driver, staff member, or designated partner.

 

Transport red lines: Do not undertake unplanned travel to high-risk locations, night travel, informal transport, public buses in highrisk areas, or travel in marked institutional vehicles where this could create a security risk, unless specifically assessed and approved by JES.

8. Communications and Information Security

Reliable communication is essential during JES activities. At the same time, public or careless disclosure of locations, travel plans, programme information, or personal details may increase risk.

• Carry a charged mobile phone at all times during travel or JES activities and keep emergency numbers saved and available in hard copy.
• Lock phones, tablets, and laptops with a password, PIN, or biometric security where available.
• Avoid saving contacts in ways that disclose family relationships or sensitive identities if the phone is lost or stolen.
• Do not share real-time locations, travel movements, accommodation details, participant lists, or sensitive programme information on social media or messaging platforms.
• Disable automatic location tagging on social media, camera applications, and public posts while travelling or attending sensitive activities.
• Report lost or stolen phones, laptops, identification, or JES materials promptly to the designated JES contact.

9. Health, Medical Emergencies, and Psychosocial Support

Health risks vary by country and activity. Consultants and participants are expected to take reasonable steps to prepare for personal health needs and to seek timely assistance if illness, injury, or distress arises.

• Review applicable health advisories for diseases such as dengue, malaria, chikungunya, zika, measles, or other country-specific risks.
• Use mosquito repellent, long sleeves, long pants, and other preventative measures where mosquitoborne illness is a risk.
• Carry essential medication in original packaging and keep an adequate supply in hand luggage when travelling.
• Know how to access medical care, including insurance emergency numbers, hotel support, local emergency services, and JES or partner contacts.
• Notify JES staff as soon as practicable of any illness, injury, accident, or medical concern that affects participation or safety.
• Recognise that some JES work may involve exposure to distressing material, including crime scenes, testimonies, or photographs. Consultants and participants are encouraged to raise concerns early and seek support if affected.
• Sexual harassment, exploitation, abuse, discrimination, and other inappropriate conduct are unacceptable and should be reported promptly through JES reporting channels. Reports will be handled sensitively and, where appropriate, confidentially.

10. Media, Photography, and Public Exposure

Some JES activities may be visible to the public, media, justice institutions, or civil society. Public exposure must be carefully managed to protect individuals, partners, and programme activities.

•  Do not speak on behalf of JES to the media or at public events unless expressly authorised by the JES Chief Executive Officer, International Program Director, Assistant Director, International Programs, Director of Finance, or another authorised JES representative.
• Refer unsolicited media inquiries, photographers, or requests for comment to JES staff or the JES Vancouver office.
• Do not post details of JES activities, locations, participants, partners, sensitive meetings, or travel movements on social media without approval.
• Do not photograph or record participants, children, justice institutions, police, security personnel, victims, witnesses, case materials, or sensitive sites unless permission has been obtained and it is safe and appropriate to do so.
• JES may review written, audio, photographic, or audiovisual material produced in connection with JES activities prior to publication where safety, security, consent, or reputational considerations arise.

11. Dealing with Threats, Incidents, and Emergencies

Most consultants and participants will not experience serious incidents. However, all individuals should think in advance about how they would respond if confronted with a threat, emergency, or unsafe situation.

Situation	Guidance
Uncomfortable situation or suspicion	Trust your instincts. Leave the location or person as soon as it is safe to do so and inform the JES focal point.
Theft or robbery	Do not resist or take physical risks. Stay calm, keep hands visible, move slowly, comply with requests, and do not offer more than is demanded.
Carjacking	Remain calm and compliant. Exit only if instructed, explain movements such as removing a seatbelt, avoid direct eye contact, leave the vehicle door open, and let assailants leave.
Gunfire	Take immediate cover on the ground, lie flat and face down, avoid running, crawl to solid cover if possible, and contact JES or emergency services as soon as safe.
Witnessing a crime or accident	Do not stop unless there is no alternative. Apparent accidents may be dangerous or staged. Ask the driver to continue and report to police or authorities when safe.
Kidnapping or express kidnapping	Remain calm, avoid confrontation, and cooperate with demands. Prioritize survival and report as soon as possible when safe.
Demonstrations or unrest	Move away from crowds, demonstrations, roadblocks, or large gatherings immediately. Do not observe, photograph, or engage.
Natural disaster or evacuation	Follow venue, hotel, partner, and JES instructions. Move to designated safe areas and keep communication channels open.

 

12. Incident Reporting and Escalation

All safety, security, or health incidents, concerns, or near-misses connected to JES activities must be reported promptly. Reporting allows JES to support affected individuals, assess ongoing risk, and take steps to prevent further harm. Reportable matters include crime, threats, harassment, discrimination, sexual harassment, exploitation or abuse, accidents, illness or injury, lost or stolen documents or equipment, unsafe transport, suspicious approaches, concerns about accommodation or venues, non-compliance with safety guidance, and any situation that may compromise the safety of individuals or programme activities.

• Consultants should report concerns to the relevant JES Project Director, International Program Director, Assistant Director, International Programs, or other designated JES focal point as soon as practicable.
• National participants should report concerns to the designated JES focal point for the activity or through any confidential reporting channel made available for the activity.
• In an immediate emergency, contact local emergency services first where safe and appropriate, then notify JES as soon as practicable.
• Reports will be handled sensitively and, where appropriate, confidentially. Retaliation for good-faith reporting is unacceptable.
• JES staff are responsible for documenting, assessing, and escalating incidents in accordance with the Core Framework and JES procedures.

Staff and participants may also raise concerns anonymously using the JES Conduct Report Form, available in English and Spanish here, which goes directly to the Board Chair and is not accessible to JES staff or management.

13. Practical Checklist and Acknowledgement

The following checklist may be used for onboarding consultants, briefing travelling participants, or preparing national participants for JES-supported activities.

 

Item	For whom	Completed / Notes
Read the JES Safety and Security Framework and this Annex	All consultants / relevant participants
Review country-level safety and security note	All travellers / activity leads
Confirm itinerary, accommodation, venue, and approved transport	Travellers / activity leads
Save JES, local, emergency, hotel, and insurance contacts	Travellers / activity leads
Carry copies of ID, passport, insurance, and key documents	International travellers
Check health notices, vaccinations, medication, and insurance	International travellers
Attend arrival or activity safety briefing	All participants
Understand incident reporting route and emergency escalation	All participants
Confirm media, photography, and social media restrictions	All participants
Raise personal safety, accessibility, health, or participation concerns	All participants, as relevant

 

Acknowledgement: Click on the button below to confirm that you have received and reviewed this Annex and understand that you are expected to follow JES safety and security guidance, the advice of JES staff and local partners, and any relevant country-level safety and security notes while participating in JES-supported activities.

Complete Acknowledgment

 

Purpose and Scope

Justice Education Society (JES) is committed to the highest ethical standards and to open and fair business conduct in all of its projects worldwide. General work conduct standards are outlined in our Code of Conduct. In addition, employees, consultants, volunteers, directors, and officers shall not, directly or indirectly, give, offer, promise, authorize or agree to give or offer a loan, payment, reward, advantage, gift, favour or benefit of any kind, however characterized, to a foreign public official, political party, party official or candidate, or to any person or organization, for the benefit of a foreign public official, political party, party official or candidate, or any person or organization, in contravention of the Canadian Corruption of Foreign Public Officials Act, SC 1998, c. 34, as amended.

By complying with this Anti-Corruption and Anti-Bribery Policy, we uphold our high moral and ethical principles and demonstrate our commitment to best practices regarding anti-corruption behaviour across all areas of our work. This policy shall be published externally on the JES website at https://justiceeducation.ca/policies within 30 days of Board approval.

Any link to bribery or corruption would damage our reputation and undermine the trust we have built with beneficiaries, partners, donors, and the public. We must provide a clear message to our staff, stakeholders, and partners that bribery and corruption are not tolerated and that the organization has effective measures in place to prevent and address any such issues.

This Policy applies to all employees, consultants, contractors, volunteers, directors, and officers of the Justice Education Society (JES). JES expects all employees, consultants, contractors, volunteers, directors and officers to know and follow this Anti-Corruption and Anti-Bribery Policy.

Failure to comply with this Policy may be grounds for disciplinary action, up to and including termination of employment for just cause or other business relationships.

Definitions

Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain.

Bribery is giving or receiving money, free trips, meals, or other gifts or an inducement of any kind in exchange for information, new business, to facilitate or damage implementation of ongoing business, or to influence official policy or actions. An inducement is something which helps to bring about an action or desired result.

Bribery and corruption can take the form of:

• Cash payments
• Phony jobs or “consulting” relationships
• Kickbacks
• Political contributions
• Charitable contributions
• Social benefits
• Gifts, hospitality, and reimbursement of expenses

Facilitating Payment is a small, unofficial payment made to expedite routine governmental action that does not involve obtaining, retaining, or directing business, such as processing work orders or other administrative requests.

Government Official is any official of a governmental entity, a public international organization, a regional development bank or other multilateral organization, or indigenous representative. For purposes of this Policy, government-owned companies and their instrumentalities are considered to be governmental entities, and their employees, officers, directors, agents, consultants and contractors are considered to be government officials.

Kickback is a payment of any part of a contract amount made to an employee or agent of a contracting party by another contracting party, directly or by use of other techniques such as subcontracts, purchase orders or consulting agreements, to channel payments to a government official, politician, contracting party or its employees or agents, or their relatives or business associates.

Policy

JES has a zero-tolerance approach to bribery and corruption. You are strictly prohibited from offering, paying, promising, authorizing or receiving any bribe, facilitating payment, kickback or other thing of value to or from any government official or government employee, directly or indirectly through a third party, to secure any contract, concession or other improper advantage for JES.

You must understand and comply with this Policy, and, when in doubt, seek interpretation and guidance from your supervisor or the CEO.

The following are definitions of specific behaviours that we expressly prohibit:

1. Misuse of Authority: You may not use JES resources, property, personnel, facilities, equipment, time, or funds for personal financial gain or to gain favourable political or legal treatment.
2. Bribery: You will not provide to or accept from any government official or another person or organization, any gift, gratuity, money, or other form of compensation or benefit when it is intended to influence official acts or receive special consideration or benefit.
3. Financial Records: Our financial books and records must accurately reflect both the quantitative and qualitative aspects of each transaction. Quantitative aspects refer to the amount of the transaction. Qualitative aspects include the written description of the transaction and the accounts credited or debited for it. You must ensure that there is a reasonable relationship between the substance of a transaction and how it is described in JES’s books and records.
4. Gifts: It is prohibited to give or receive inducements, including gifts and entertainment, to or from government officials on a scale that might be perceived as creating an obligation on that official. In addition gifts may not be given or accepted with the intention or expectation of influencing a party to obtain or retain business or a business advantage, or as a reward for the provision or retention of business or a business advantage, or in exchange for favours or benefits. Detailed information about gift giving and receiving may be found in JES’ Conflict of Interest Policy.

Reporting Procedure

JES is dedicated to the identification and rectification of malpractice. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

No retaliation will be taken against whistleblowers for any disclosure made in good faith.

Employees must report any suspected malpractice, including by any employees, consultants, volunteers and officers of JES, to the CEO. The President of the Board must be contacted in the event of suspected malpractice by the CEO and/or a Board Director. To do so, staff and program participants can submit a report anonymously using the JES Conduct Report Form, available in English and Spanish here, which goes directly to the Board President at report@justiceeducation.ca and is not accessible to JES staff or management.

When making a report, you are encouraged to provide as much specific information as possible including names, dates, places and events that took place, your perception of why the incident(s) may be a violation, and what action you recommend be taken. Reports should include as much detailed information as possible to allow proper investigation of your concerns. Reports will be handled in a confidential manner. The action taken after a report is received will depend on the nature of the concern. Reports will be investigated according to the laws of British Columbia and the employee’s residence, and if there are reasonable grounds, it will take appropriate measures to implement a prompt and thorough investigation. Every effort will be made to protect the reporter’s identity (if provided) to the extent possible and subject to applicable law. Please note that it is possible that as a result of the information provided in a report, the reporter’s identity may become known to JES during the course of the investigation. Every report received will be logged, and the assessment and its outcome will be recorded whether or not the report proceeds to investigation.

All employees have a duty to cooperate in an investigation. If such a person fails to cooperate in an investigation, or if they provide false information in an investigation, JES will take corrective action commensurate with the severity of the offence (up to and including termination of employment or other business relationships).

JES may discipline any employee who makes a report under this Policy without a reasonable, good-faith belief in the truth and accuracy of the information they provide and such discipline may result in the termination of the individual’s employment.

Compliance

All employees, consultants, volunteers, directors, and officers must comply with this Policy and cooperate with any investigation initiated pursuant to this Policy. Adhering to this Policy is a condition of employment or other business relationships.

This policy should not be construed as preventing, limiting, or delaying JES from taking disciplinary action against any individual, up to and including termination of employment for cause, or other business relationships, in any circumstances where JES deems disciplinary action appropriate.

Questions about this Policy

If you have any questions, contact the CEO.

Policy Acknowledgment

Please go to the JES Employee Policies Google Form to acknowledge that you have read, understood, and agree to comply with JES Policy B2: Anti-Corruption and Anti-Bribery Policy.

Purpose and Scope

Our mission is to empower people to access and deliver justice in Canada and globally. This is accomplished through a variety of methods and programs that all reflect our vision: Justice for All.

In executing our programs, we work with and provide services to a wide demographic of people, from educators and school administrators to justice system professionals, recent immigrants, Indigenous communities and foreign governments and judicial authorities. We also serve over a million general public online users.

Our Code of Conduct Policy (Policy) guides our behaviour with all these stakeholders and amongst ourselves. It is driven by our desire to maintain the highest level of respect toward our clients and stakeholders, and to preserve our stellar reputation within the justice sector for ethical and responsible delivery of services of the highest calibre.

This Policy applies to all employees, consultants, contractors, volunteers, directors, and officers of the Justice Education Society (JES). JES expects all employees, consultants, volunteers, directors, and officers to know and follow this Code of Conduct.

Failure to comply with this Code of Conduct may be grounds for disciplinary action, up to and including termination of employment for just cause or other business relationships.

Policy

1. Respect for the law: You must act with honesty and integrity and in accordance with all professional standards and/or governing rules, laws and/or legislation that have application to the responsibilities you perform for or on behalf of JES. You are expected to educate yourself on the standards, laws, rules and regulations that govern your work for JES, and seek clarification or direction from your supervisor or other appropriate individual at JES where you are unsure.
2. Expected Behaviour: JES is committed to providing a workplace free from discrimination, bullying, and harassment, and expects that all relationships among persons in the workplace will be professional and free of discrimination, bullying, and harassment. For further information, see the JES Bullying and Harassment Policy.
3. Digital Conduct, Social Media, and AI Tools: You are expected to use digital technologies, social media, and artificial intelligence tools responsibly and in accordance with JES values. Detailed rules governing acceptable use of JES and personal technology, social media conduct, and AI tool use are set out in B10: Digital Technologies and Acceptable Use Policy and B14: Artificial Intelligence and Data Protection Policy. Everyone must read and comply with both policies.
4. Business Opportunities: JES employees, consultants, volunteers, directors, and officers are prohibited from using their position with JES to solicit or conduct business for personal benefit or gain. Employees, consultants, volunteers, directors, and officers are also prohibited from taking, for themselves or for the benefit of others, opportunities discovered through the use of JES property or information.
5. Fair Dealing: JES volunteers, consultants, directors and officers should endeavour to deal fairly with JES’ clients, stakeholders, suppliers, and competitors. No individual should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair or unlawful dealing practice.
6. Confidentiality: Confidential information, in any form, that you receive through your employment must not be disclosed, released, or transmitted to anyone other than persons who are authorized to receive the information. If you are in doubt as to whether certain information is confidential, you must ask your supervisor before disclosing, releasing, or transmitting it. Information from foreign entities that is gathered as part of process and procedural training and education will be held as confidential until such time as express consent is received by the original owner of the information to disclose, release or otherwise transmit it. For rules governing the handling of staff personal data and program data, see B5: Employee Privacy Policy and B15: Staff Data Handling Policy.
7. Integrity of Records and Internal Controls: The accuracy, reliability and integrity of JES’s records are critical to its ongoing success. Appropriate accounting and financial policies, procedures, controls and audit processes must be maintained. All business records, expense accounts, invoices, bills, payroll and employee records and other reports must be prepared with care and honesty. All assets, liabilities and transactions must be accurately and completely reported in JES’s books and records and supported by necessary documentation. No asset, liability or transaction is to be concealed from management or JES’ auditors.
8. Public Comment: JES volunteers, consultants, directors and officers should not speak publicly, including to the media, where it could be perceived as an official act or representation of the position of JES, unless authorized to do so by the Chief Executive Officer (CEO). Requests to speak publicly and/or comment on behalf of JES should be sent to the CEO.
9. Conflict of Interest: You should avoid all situations that present a conflict of interest or that reasonably present the appearance of a conflict of interest. Please refer to the JES Conflict of Interest Policy, which describes in greater detail the definition of conflict used by JES, and what steps you should take in the event that you find yourself in a conflict of interest relationship or situation. Procedures for disclosure of such relationships are provided in the Guidelines for Disclosure section of the Conflict of Interest Policy. All employees are required to read and sign JES’ Conflict of Interest Policy in addition to signing this Code of Conduct Policy.
10. Fraud, Theft, and Intentional Damage: Fraud and theft are not tolerated at JES. This includes, for example, the misappropriation or theft of assets, the intentional misrepresentation of expense claims, benefits claims, hours worked and/or the purchase of goods and/or services, and the misrepresentation of financial information.
11. Intentional Damage: You are strictly prohibited from stealing or intentionally damaging JES project or property. The theft or intentional damage of JES project or property results in disciplinary action up to and including termination from employment or termination of other business relationships. Furthermore, you are held responsible for reimbursing JES for the costs of theft or intentional damage.
12. Criminal Conduct: You are strictly prohibited from knowingly engaging in any activity or action that would violate the criminal laws of Canada and/or the criminal laws of the host country, where applicable. The commission of a criminal offence may result in disciplinary action, up to and including termination of employment or other business relationships. If you are charged with a criminal offence, you are required to immediately report this fact in writing to the CEO of JES.
    JES reserves the right to suspend any employee while a criminal investigation is ongoing or until the charges are resolved, or terminate the employee or other business relationship, as warranted.
13. Political Activity: If you choose to participate in partisan political activity, you must do so during off-hours, and you cannot use your position at JES, JES equipment, or facilities in connection with such political activity.

Reporting

All JES employees, consultants, contractors, volunteers, directors and officers who know of, or suspect, a violation of this Policy or of any applicable law, rule or regulation have an obligation to immediately report this information to their supervisor or any member of the Executive Leadership Team. Actual or suspected violations should also be reported to the person's supervisor or any member of the Executive Leadership Team. However, where an employee, volunteer, consultant, contractor, director, or officer is not comfortable going to their supervisor or a member of the Executive Leadership Team, they should consult, in confidence, with human resources (HR, when available) or the CEO. All reported violations will be promptly investigated and treated confidentially to the extent possible. Employees, volunteers, consultants, contractors, directors and officers are expected to cooperate fully in internal investigations of misconduct.

Anonymous Reporting: JES provides an anonymous reporting option for staff and program participants who wish to raise a concern without identifying themselves. Reports can be submitted using the JES Conduct Report Form, available in English and Spanish here. Submissions go directly to the Board President and are not accessible to staff or the Executive Leadership Team. No identifying information is required. The form asks for country, dates, and a description of the situation. Anonymous reports will be reviewed by the Board President and acted upon in accordance with the laws of British Columbia and the country in which the reported employee resides. Use of this mechanism will not result in any negative consequence for the person reporting.

In addition, you must report to HR (when available) and your supervisor a safety hazard or unsafe condition or act in accordance with the provisions of the B.C. Occupational Health and Safety Regulation, BC Reg. 296/97, (http://www.bclaws.ca/civix/document/id/complete/statreg/296_97_00), as amended from time to time.

Code of Conduct Violations

Violation of the principles and explicit rules outlined in the Code of Conduct is a serious matter and may be subject to disciplinary action, up to and including termination of employment with JES for just cause or termination of other business relationship.

Retaliation

No one will be subject to retaliation because of a good faith report of suspected violation of this Policy, or for assisting in an investigation into a breach of this Policy. At the same time, any person found to have made a false or malicious report or knowingly provided false or misleading information during an investigation will be subject to disciplinary measures up to and including termination of employment for just cause or termination of other business relationships.

Policy Acknowledgment

Please go to the JES Employee Policies Google Form to acknowledge that you have read, understood, and agree to comply with JES Policy B1: Code of Conduct Policy.

Introduction

Justice Education Society’s (JES) vision is to seek Justice for All. We strive for a world free of prejudice, bias, discrimination, violence and harmful practices in which everyone’s rights are respected, everyone is treated fairly and everyone has equal access to justice. We believe that the empowerment of persons of all genders, who face intersecting forms of marginalization and exclusion, is fundamental to achieving gender equality and social justice, and for contributing to the progress and development of a stronger, more peaceful, and sustainable world.

We recognize that to achieve our mission to empower people to access and deliver justice in Canada and globally, and to contribute to the Sustainable Development Goals, considerations of gender, diversity, and inclusion must be front and center in all that we do. Gender equality, diversity and inclusion are an intrinsic part of who we are, driving how we lead our organization, how we work, how we deliver our services and programs, and how we contribute to our communities at the regional, national and international levels.

Application

This Policy applies to JES, its Board and its committees, employees, contractors, consultants and volunteers.

Statement

Our goal is to create an institutional foundation that embraces inclusive and equitable principles, exemplified by a diverse and representative workforce, allowing us to celebrate and foster a culture that provides a flexible, engaging and empowering work environment. We believe this is achieved through:

• building and leveraging diverse, complementary capabilities within and between teams;
• engaging, mobilizing and retaining the best available talent, with a focus on attracting applicants with diverse socio-cultural identities, and providing them with ongoing learning opportunities;
• encouraging and utilizing diverse ways of thinking to create the best solutions to build individual, community and stakeholder capacities; and
• by delivering our services in a collaborative manner, building linkages and partnerships across socio-economic and cultural barriers and differences.

These actions will give JES a competitive advantage through productivity, innovation, agility and accountability for sustainable performance and equitable growth. These actions will also allow JES to deliver on our vision, mission and commitment, and to best support the diverse individuals, communities and stakeholders that we serve.

Our Commitment

To achieve our goal, JES will:

• Conduct regular gender, diversity and inclusion audits with a focus on data, policies, processes and culture in order to identify areas of strength, improvement, opportunities and challenges.
• Develop and implement a strategy and action plan to address systemic or cultural barriers that hinder the attraction, recruitment, retention and progression of diverse talent.
• Analyze and monitor the gender and diversity composition of human resources at all levels (Board, management, staff, volunteers, contractors and consultants) and take steps to address any gaps and make improvements.
• Build engagement around gender, diversity, and inclusion issues amongst JES management team and create a culture of openness and accountability.
• Strengthen capacity in gender mainstreaming with a particular focus on intersectional gender analysis and gender budgeting skills training.
• Provide regular gender, diversity, and inclusion training to all staff, volunteers, contractors and consultants to maintain a culture of inclusion and diversity.
• Integrate measures and provide training to prevent sexual and gender-based violence and to protect against sexual exploitation and abuse for all staff, volunteers, contractors, consultants, and clients.
• Ensure that all human resources policies, processes and procedures are reviewed and developed to include considerations supporting gender and diversity.
• Prioritize human, technical and financial resources to meet our gender and diversity commitments.
• Consider gender and diversity in financial resource allocation decisions (gender and diversity budgeting) at institutional and project levels.
• Integrate transformative and inclusive gender and diversity approaches into project design, delivery, monitoring and evaluation.
• Ensure the production and inclusion of data disaggregated by sex, gender, age, and other relevant socio-cultural identities to inform priorities, actions and decisions across our domestic and international programs.
• Ensure that all communications, training, marketing and fundraising materials incorporate gender and socio-culturally inclusive language and positive images.

Responsibilities

The JES Board and leadership team are responsible for the implementation of this policy and all Board and its committees, staff, volunteers, contractors and consultants must comply with this policy. JES’ CEO will regularly report on the implementation of this policy to the JES Board.

Definitions

Diversity – recognizing and valuing differences in people’s identities, characteristics, and experiences.

Gender budgeting – analyzing and preparing budgets from a gender perspective, to understand how persons of different genders may be affected.

Gender equality – the equal valuing of women, men and non-binary persons, and the varying roles that they play; and ensuring equal rights and opportunities for persons of all genders.

Gender mainstreaming – “a strategy to assess the implications for both men and women, of any planned actions, policies or programmes in all areas and at all levels. This approach recognizes the need to take social and economic differences between men and women into account to ensure that proposed policies and programmes have intended and fair results for women and men, boys and girls.”

Harmful practices – socio-cultural practices that lead to violations of the human rights of persons of all genders and ages.

Inclusion – valuing, welcoming, and ensuring equal opportunities for persons of all genders, ages, and socio-cultural identities.

Intersecting forms of marginalization and exclusion – gender inequalities may intersect with additional forms of marginalization and exclusion that are based on other social identities and factors, such as age, race/ethnicity, religion, ability, sexual orientation etc.

Intersectional gender analysis – understanding and recognizing multiple and intersecting differences between people, such as gender, sex, religion, age, ability, sexual orientation etc.

Persons of all genders – individuals may have different gender identities and/or sexual orientations. Gender and sexual differences are not only linked to the binary designation of women/men or male/female.

Socio-cultural identities – different social and cultural traits and characteristics to which people identify themselves and others.

Purpose and Scope

As part of our overall philosophy of providing a safe work environment and fair employment practices, it is important to establish a procedure for employees to formally express concerns or complaints.

We believe that most disagreements, disputes, or differences concerning conditions of employment or co-worker cooperation can be resolved informally and amicably through discussion or other problem-solving approaches. If this is not possible, this Policy outlines a path for more formal complaints.

This Policy should be read together with B1: Code of Conduct Policy and B4: Workplace Bullying and Harassment Policy. Where a grievance relates to harassment, discrimination, or workplace violence, the procedures in B4 apply. Where a grievance relates to a suspected breach of the Code of Conduct, the reporting structure in B1 applies.

If a grievance relates to harassment or violence in the workplace, the reporting policy and procedures outlined in Justice Education Society’s (JES) Bullying and Harassment Policy should be followed rather than those in this Policy.

This Policy applies to all employees, consultants, contractors, volunteers, directors, and officers of JES.

Policy

Step 1: Speak with the person If the grievance is with another employee, the best first move is for you to speak with that person directly and explain your concerns. Include specific examples that illustrate the complaint, and some suggested remedies. Together, you try to come up with a solution to the problem.

Step 2: Informal discussion with supervisor. If a direct conversation does not resolve the grievance, or if you are not comfortable speaking with that person directly, you can have an informal discussion with your own immediate supervisor. Many concerns can be resolved informally when you and your supervisor take time to review the concern and discuss options to address the issue. After an initial conversation, the respondent and their supervisor should be invited to the discussion to understand all sides of the issue and collaboratively develop a reasonable solution.

If the grievance is with your own supervisor, this informal discussion is held with your supervisor’s supervisor, also known as the one-up manager.

Step 3: Written complaint to supervisor and one-up manager If you are not satisfied with the results of the informal discussion in Step 2, you can submit a written complaint (a letter or email) within one week of the Step 2 discussion to your immediate supervisor and one-up manager to include:

• The nature of the grievance.
• Detailed information, including evidence of the issue, witnesses, related policies, etc.
• The remedy or outcome desired.

The one-up manager, or their designate, will respond to you in writing within five (5) working days. In some cases, an extension of time may be required, in which case JES will advise you when you can expect a response.

The supervisor receiving this written complaint must share it with human resources (HR) and the Chief Executive Officer (CEO).

If your complaint is related to harassment, discrimination, retaliation or workplace violence, you can submit the written complaint directly to your supervisor, HR or to the CEO, as described in the Bullying and Harassment Policy. Detailed instructions and guidelines are provided in that Policy.

Step 4: Written complaint to CEO: If you are not satisfied with the Step 3 written response from the one-up manager, you can submit a written complaint to the CEO for review. The request for review includes:

• An explanation of the grievance and details of all previous efforts to resolve the issue.
• A copy of the written complaint as submitted to the immediate supervisor.
• A copy of the immediate supervisor's written response to your complaint.
• Detailed information regarding your dissatisfaction with the one-up manager’s response.

The CEO will consult with your immediate supervisor and any other relevant parties to evaluate the grievance and provide you with a written response within 15 days. In some cases, an extension of time may be required; the CEO will advise you when to expect a written response. The CEO's review is final unless new evidence or other circumstances warrant further review of the complaint.

Retaliation against any employee who files a complaint is prohibited and may result in discipline up to and including discharge.

The procedures in this Policy are intended to be flexible in order to respond to the specific circumstances at issue. JES reserves the right to engage in a different procedure as it deems appropriate in any given circumstance.

Step 5: Written complaint to the Board President: If the grievance involves the CEO, the written complaint at Step 4 should be submitted directly to the Board President rather than the CEO. The Board President will consult with relevant parties and provide a written response within 30 days. The Board President's review is final unless new evidence or other circumstances warrant further review.

At any stage, you may submit an anonymous report using the JES Conduct Report Form, available in English and Spanish here, which goes directly to the Board President and is not accessible to JES staff or management. Anonymous reports are appropriate where you do not feel safe using the formal grievance process.

Policy Acknowledgment

Please go to the JES Employee Policies Google Form to acknowledge that you have read, understood, and agree to comply with JES Policy B6: Grievance Policy.

1.Purpose and Scope

Justice Education Society (JES) operates in countries and regions where security, health, and safety risks may be significantly higher than those typically encountered in Canada. These risks may include, but are not limited to, high levels of violent and petty crime, road safety hazards, health risks, and exposure to natural disasters and other emergencies. The purpose of this Safety and Security Framework for International Programming is to set out JES’s overarching approach to safety and security management and to establish minimum standards and expectations applicable across all international activities. The Framework is intended to support informed decision-making, promote risk awareness, and reduce exposure to avoidable risks while recognizing that not all risks can be eliminated. This Framework applies to all JES international programming and related activities and is binding on all individuals engaged by or participating in JES-supported activities, including JES staff, consultants, national participants, partners, and visitors. It should be read in conjunction with the relevant annexes, which provide detailed guidance tailored to specific roles, contexts, and countries of operation. Where applicable, hyperlinks or references to the most current versions of annexes will be provided. This Framework forms part of the JES Employee Policy Manual as B16 and should be read together with B12: Travel Policy, B1: Code of Conduct Policy, B4: Workplace Bullying and Harassment Policy, B8: Drug and Alcohol Policy, and B10: Digital Technologies and Acceptable Use Policy.

2.Operating Context and Risk Environment

JES operates in environments where security, health, and safety conditions may differ significantly from those in Canada and other low-risk contexts. While JES has not experienced targeted attacks against its staff, consultants, or participants in the course of its work, individuals engaged in JES programming may nonetheless be exposed to elevated risks associated with the operating context. These risks may include high levels of violent crime such as robbery, armed assault, kidnapping, and gang-related activity, as well as widespread petty crime including pickpocketing and theft. Road traffic accidents are also a common hazard in some countries of operation due to poor road conditions, inadequate vehicle maintenance, and unsafe driving practices. In addition, certain regions in which JES operates are subject to natural hazards—including floods, hurricanes, earthquakes, landslides, and volcanic activity—which may disrupt travel and programme delivery and pose risks to personal safety.

JES monitors the security situation in its countries of operation and takes prevailing conditions into account when planning activities and travel. However, JES cannot guarantee complete safety at all times. Individuals engaged in JES activities are therefore expected to remain alert, exercise good judgement, and follow safety and security guidance provided by JES staff and local partners who are familiar with current conditions on the ground. Failure to observe safety and security guidance, or to follow the advice of JES staff and partners, may increase risk not only to the individual concerned but also to others involved in JES activities. Some JES staff may perform their duties remotely or from home locations outside Canada. In such cases, staff are expected to remain aware of local safety and security considerations relevant to their working environment and to follow JES guidance relating to travel, communications, and incident reporting where applicable.

 

3.Duty of Care and Shared Responsibility

JES has a duty of care to take reasonable steps to safeguard the safety and security of individuals engaged in its international programming. In fulfilling this responsibility, JES incorporates safety and security considerations into programme planning and implementation, monitors operating environments and evolving risk conditions, and provides guidance and support to those participating in JES activities. Where incidents or emergencies arise, JES will take reasonable steps to coordinate an appropriate response and provide assistance consistent with the circumstances and operating context. At the same time, safety and security are a shared responsibility. All individuals engaged in JESsupported activities are required to take responsibility for their own conduct, to act in a prudent and responsible manner, and to comply with applicable JES policies, local laws and customs, and safety and security guidance issued by JES staff and local partners. JES relies on the cooperation of staff, consultants, and participants to ensure that safety and security measures are effective. Individuals are expected to follow the advice of JES staff and partners who are familiar with current local conditions and risks. Failure to observe such guidance may increase risk not only to the individual concerned but also to others involved in JES activities. JES does not provide armed protection, and JES staff and consultants are not armed. While JES takes reasonable steps to mitigate risk, it is not possible to eliminate all risks associated with international operations. Individuals engaged in JES activities must therefore remain alert to their surroundings, exercise sound judgement, and avoid activities or situations that may unnecessarily increase personal or programme-related risk.

 

4.Risk Awareness and Compliance

While JES maintains a duty of care, individuals engaged in JES activities also bear responsibility for their own conduct and risk awareness. All individuals participating in JES international activities are required to maintain an ongoing awareness of the security, health, and safety risks associated with the operating context and to take reasonable steps to reduce exposure to those risks. This includes exercising caution, remaining alert to surroundings, and adapting behaviour in response to changing conditions. Compliance with JES safety and security guidance is mandatory. Individuals must adhere to the requirements set out in this Framework and in the applicable annexes, including guidance relating to pre-departure preparation, arrival and in-country conduct, travel and transportation, accommodation, communications, and personal behaviour. Individuals are expected to follow instructions and advice provided by JES staff and local partners, particularly where such guidance relates to identified risks or emerging security concerns. Where necessary, individuals may be instructed to refrain from certain activities, locations, or modes of travel that are assessed to present unacceptable risk. Failure to comply with safety and security guidance, or refusal to follow the advice of JES staff or partners, may result in corrective measures. These may include modification or cancellation of travel plans, removal from specific activities, or termination of an assignment or participation, as appropriate.

5.Incident Reporting and Escalation

All safety, security, or health incidents, concerns, or near-misses arising in the course of JES international activities must be reported promptly. This includes, but is not limited to, incidents involving crime, threats, accidents, illness or injury, harassment or discrimination, or any situation that may compromise the safety or security of individuals or programme activities. Consultants and national participants are required to report any safety or security concerns or incidents to the relevant JES Project Director, Director of International Program, or other designated JES focal point as soon as practicable. This includes reporting situations in which they believe their own actions, or the actions of others, may have compromised safety or security. JES staff are responsible for ensuring that reported incidents are appropriately documented, assessed, and escalated in accordance with JES procedures. Where necessary, incidents must be escalated to senior management, including the Director of International Programs, Assistant Director, International Programs, and the Chief Executive Officer, and appropriate follow-up actions must be taken to mitigate further risk. Failure to report safety or security concerns or incidents in a timely manner may increase risk and undermine JES’s ability to respond effectively. All reports will be handled sensitively and, where appropriate, confidentially. In the event of a serious security incident or emergency, JES will take reasonable steps to support affected individuals and coordinate an appropriate response. This may include identifying designated emergency contact points, coordinating with local partners, facilitating access to medical care or emergency services, liaising with relevant authorities or diplomatic missions where appropriate, and supporting evacuation or relocation decisions where necessary. The nature of such support will depend on the circumstances of the incident, the operating environment, and the role of the individual involved (e.g. staff, consultants, or participants). Specific emergency procedures and contact arrangements may be outlined in relevant annexes or project-level guidance appropriate to the operating context. Where appropriate, JES may also provide additional reporting mechanisms to allow concerns to be raised confidentially or anonymously.

 

6.Medical Emergencies and Health Considerations

Health risks are an inherent component of international operations, and individuals engaged in JES activities may be exposed to illnesses, diseases, or medical emergencies depending on the country of operation. JES requires all individuals to take appropriate steps to prepare for healthrelated risks prior to travel or participation in international activities. Individuals are responsible for ensuring that they are medically fit for travel and engagement in JES activities, including obtaining required vaccinations, medications, and medical clearances, as applicable. Appropriate medical, health, and travel insurance coverage must be in place in accordance with JES requirements and contractual arrangements. In the event of illness, injury, or medical emergency, JES staff will provide reasonable support and assistance, including facilitating access to medical care or emergency services where possible. Individuals are required to follow established emergency procedures and to notify JES staff as soon as practicable of any medical incident or concern. JES cannot assume responsibility for all medical outcomes and cannot guarantee the availability or quality of medical services in all locations. Individuals are therefore expected to act prudently, seek timely medical attention when required, and comply with health-related guidance issued by JES staff and relevant authorities.

7.Communications and Public Exposure

Effective management of communications and public exposure is essential to maintaining the safety and security of JES personnel, partners, and activities. In certain operating contexts, public visibility or inappropriate disclosure of information may increase security risks. All individuals engaged in JES international activities must exercise caution in their communications and avoid disclosing sensitive information relating to JES programmes, personnel, locations, or movements. The use of social media, messaging platforms, or other public communications must not reveal real-time locations, travel plans, or details of JES activities while in-country. Engagement with media, including journalists, photographers, or other members of the press, must be carefully managed. No individual may speak on behalf of JES at public events or to the media unless expressly authorized by the Chief Executive Officer, the International Program Director, Assistant Director, International Program, or the Director of Finance. Any unsolicited media inquiries should be referred to JES staff in-country or to the JES Vancouver office, as appropriate. JES reserves the right to review written, audio, or audiovisual material produced in connection with its activities prior to publication where there are potential safety, security, or reputational risks. Failure to comply with communications guidance may result in corrective action.

8.Compliance and Supporting Documents

This Safety and Security Framework for International Programming is supported by a set of annexes and related documents that provide detailed guidance tailored to specific roles, contexts, and countries of operation. These supporting documents form an integral part of JES’s safety and security system and must be read and applied in conjunction with this Framework. The supporting documents include, but are not limited to:

• Annex A: Safety and Security Guidance for Consultants and National Participants
• Annex B: Country-Level Safety and Security Notes
• Relevant acknowledgements, liability waivers, and onboarding tools, as applicable

Compliance with this Framework and the relevant supporting documents is mandatory. Failure to comply may result in corrective action, including modification or cancellation of travel or activities, removal from assignments or participation, or other appropriate measures.

9.Review and Updates

This Safety and Security Framework for International Programming is a living document and will be reviewed periodically to ensure that it remains relevant and responsive to JES’s operating contexts, organizational policies, and donor or regulatory requirements. Updates may be made in response to changes in security conditions, lessons learned from incidents or near-misses, or updates to related JES policies and procedures. Revisions to this Framework and its annexes will be communicated to relevant staff, consultants, and participants as appropriate. Individuals engaged in JES international activities are responsible for ensuring that they are familiar with the most current version of this Framework and any applicable annexes. JES may periodically brief staff and project teams on safety and security considerations through internal meetings, project discussions, or other appropriate forums.

Purpose and Scope

Justice Education Society’s (JES) mission is to empower people to access and deliver justice in Canada and globally. This is accomplished through a variety of methods and programs that all reflect our vision: Justice for All.

In executing our programs, we work with and provide services to a wide demographic of people, from youth, educators, recent immigrants, Indigenous communities, justice system professionals, law enforcement, foreign governments and judicial authorities.

This Policy is to provide protection from sexual exploitation, abuse, and harassment (PSEAH) by:

• promoting increased awareness of sexual exploitation, abuse, and harassment (SEAH);
• promptly reporting, investigating and resolving any SEAH incident that may occur; and
• providing assistance and support to victims of SEAH.

This Policy applies to all employees, contractors, partner organizations, volunteers, board directors, and any individual engaged by JES.

Partner organizations will develop and implement and adhere to their own SEAH policy, in accordance with the signed memorandum of agreement with JES, and their policy will be in compliance with the scope of this policy. In the absence of their own PSEAH policy, this policy must be incorporated by reference into their contracts with JES and accepted by the signing party.

Definitions

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

Sexual abuse: an actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.¹

Sexual harassment: any unwelcome conduct of a sexual nature where the conduct has the purpose or effect of:

• violating the dignity of a person; or
• creating an intimidating, hostile, degrading, humiliating, or offensive environment for that person.

Sexual harassment includes, but is not limited to:

• unwelcome physical contact of a sexual nature, including touching, patting, pinching, or brushing against another person;
• unwelcome verbal conduct of a sexual nature, including sexual comments, jokes, propositions, or demands for sexual favours;
• unwelcome non-verbal conduct of a sexual nature, including sexually suggestive gestures, displaying or sharing sexually explicit material, or following or surveilling a person;
• quid pro quo harassment, where submission to sexual conduct is made explicitly or implicitly a condition of employment, continued engagement, program benefits, or other decisions affecting a person's standing; and
• conduct that creates a hostile environment for a person on the basis of sex or gender, even where individual incidents may appear minor in isolation.

¹ United Nations, Task Team on the SEA Glossary for the Special Coordinator on improving the United Nations response to sexual exploitation and abuse, Glossary on Sexual Exploitation and Abuse, (2017, 2nd edition), available from https://hr.un.org/sites/hr.un.org/files/SEA%20Glossary%20%20%5BSecond%20Edition%20-%202017%5D%20-%20English_0.pdf

Policy

JES has a zero tolerance approach to SEAH. JES does not allow any employee, contractor, partner organization, volunteer, board director or any individual engaged by JES to participate in any form of sexual exploitation, abuse, or harassment. All are expected to uphold the highest standards of personal and professional conduct at all times, and to provide assistance and services in a manner that respects and fosters the rights of beneficiaries and other vulnerable members of the local communities.

JES strives to create and maintain a safe environment, free from SEAH, by taking appropriate measures internally and in the communities where JES operates, through prevention and response in the work that we do.

Core Principles

JES's approach to SEAH prevention and response is consistent with the Six Core Principles Relating to Sexual Exploitation and Abuse established by the Inter-Agency Standing Committee (IASC), last updated September 2019. The current version of these principles is available at https://interagencystandingcommittee.org/inter-agency-standing-committee/iasc-six-core-principles-relating-sexual-exploitation-and-abuse. Where the IASC updates these principles, the updated version supersedes this Policy to the extent of any inconsistency, and JES will update this Policy accordingly at its next annual review.

Consistent with the IASC principles, JES affirms the following:

• Sexual exploitation and abuse by anyone engaged in JES activities constitutes gross misconduct and is grounds for termination of employment or other business relationships.
• Sexual activity with anyone under the age of 18 is strictly prohibited, regardless of the local age of majority or age of consent. Mistaken belief about a person's age is not a defence.
• The exchange of money, employment, goods, or services for sex, including sexual favours or any other form of humiliating, degrading, or exploitative behaviour, is strictly prohibited. This includes the exchange of assistance that is owed to program beneficiaries.
• Any sexual relationship between a person providing services or assistance through JES and a person benefitting from those services that involves an improper use of rank, position, or trust is prohibited. Such relationships undermine the credibility and integrity of JES's work and the communities we serve.
• Any person engaged by JES who develops concerns or suspicions about sexual exploitation or abuse by another person engaged by JES, whether within JES or through a partner organization, must report those concerns through JES's established reporting mechanisms.
• All persons engaged by JES are responsible for creating and maintaining an environment that prevents sexual exploitation and abuse. Managers and supervisors at all levels have particular responsibility to build and sustain systems and culture that support this environment.
• Sexual harassment of any person in connection with JES activities is strictly prohibited. This includes unwelcome conduct of a sexual nature — whether verbal, non-verbal, or physical — that creates an intimidating, hostile, degrading, humiliating, or offensive environment, or that could reasonably be expected to do so.

SEAH in international development and justice sector programming often occurs in the context of significant power differentials — between staff and beneficiaries, between international staff and local counterparts, and between personnel of funded organizations and the communities they serve. JES recognizes that power imbalances affect both the likelihood of harassment occurring and a person's ability to report it.

The Board will be informed by the CEO of all complaints and the results of any investigation.

Roles and Responsibilities

• All employees and anyone who works with JES have the responsibility to promptly report incidents of SEAH being perpetrated by anyone within JES.
• The management team is responsible for creating and maintaining an environment in which everyone knows what JES expects from them and feels able to report any suspicious or inappropriate behaviour.
• Employees must fully cooperate with investigations into incidents of SEAH.
• JES commits to maintaining a robust recruitment screening, referencing, background and police checks process for all employees, contractors, board directors and volunteers.
• JES commits to SEAH prevention by raising awareness and providing training to all employees, including empowering them to integrate the PSEAH core principles into their daily work to ensure safe programming.
• JES commits to log every report received and the assessment and its outcome will be recorded whether or not the report proceeds to investigation.
• For international programs specifically, the relevant Project Director is responsible for: (i) ensuring all staff, contractors, and partner organization personnel deployed on the project receive PSEAH orientation before commencing work; (ii) maintaining up-to-date country-specific referral information on JES Home (SharePoint); and (iii) notifying the CEO within 24 hours upon receiving any SEAH allegation involving a project beneficiary, regardless of whether the alleged perpetrator is a JES employee or a partner organization staff member.
• All employees, contractors, board directors and volunteers must sign the PSEAH Declaration form confirming they have read, understood and agreed to abide by the PSEAH Policy of JES. Adherence to the PSEAH Policy is a condition of employment. Violation of the PSEAH Policy may be grounds for termination of their employment for just cause without notice or pay in lieu of notice.
• The management team must deal with situations of SEAH immediately upon becoming aware of them, whether or not there has been a complaint. In addition, human resources (HR) and the CEO are responsible for conducting investigations as set out in this Policy, as well as implementing any follow-up steps that are determined to be appropriate following an investigation.

Complaint Reporting Process

If you have witnessed or received any form of SEAH or you believe anyone engaged by JES is either a victim or perpetrator of SEAH, take the following actions immediately.

Step 1: Immediately notify your supervisor, HR, or the CEO. If the complaint involves your supervisor, then speak to that individual’s immediate manager, HR or to the CEO. The supervisor or HR has the responsibility to report to the CEO within 24 hours of receiving a SEAH report.

Step 2: Gather as much detail as possible about the circumstances including dates, times, locations, persons involved, witnesses and the specific conduct that is the source of the complaint. In addition, gather any supporting documents, such as e-mails, handwritten notes or photographs.

Step 3: Submit all of the information directly to your supervisor, HR or the CEO.

If the CEO is implicated in the complaint, the report or complaint should be submitted directly to the President of the Board, who will bring it to the Executive Committee’s attention within 24 hours.

If the President is implicated in the complaint, then the Vice-President or another member of the Executive Committee should receive the report and convene a sub-committee meeting within 24 hours. The sub-committee in consultation with the Executive Committee will investigate and decide on the best course of action.

The complainant is fully within their rights at any time to submit the report directly to an external authority, such as the local police service.

JES recognizes that SEAH is among the most difficult situations to report, particularly where the reporter fears retaliation, disbelief, or exposure. At any stage, staff and program participants may submit an anonymous report using the JES Conduct Report Form, available in English and Spanish here, which goes directly to the Board President and is not accessible to JES staff or management. Anonymous reports of SEAH will be treated with the same seriousness as formal complaints. Where an anonymous report contains sufficient information to warrant investigation, JES will initiate one.

Investigation Procedure

Once JES receives a formal complaint it will conduct an investigation. In the event that a complainant does not proceed with a formal complaint, JES may still initiate an investigation if there are reasonable grounds to believe that SEAH may have occurred.

The CEO or designated senior manager, or the Board in cases involving the CEO, is responsible for ensuring that a fair, objective, and thorough investigation is conducted in a timely manner and that appropriate actions are taken.

The investigation process is as follows:

• Review the complaint and select the investigator.
  • For the majority of complaints, JES will assign an appropriate person internally to conduct the investigation.
  • In complex, sensitive, or high-risk situations, JES may appoint an external investigator.
• Oversee the investigation, which includes:
  • Ensuring the investigator has access to all relevant documents, records, and parties
  • Setting a reasonable timeline for completion appropriate to the circumstances
  • Maintaining confidentiality of all parties throughout the process
  • Documenting all steps taken and decisions made
• Analyse the information gathered and reach a finding.

Following the conclusion of the investigation, the investigator will provide a summary of findings to both the complainant and the respondent. Both parties will have an opportunity to provide any additional information they believe is relevant before a final decision is made.

When the investigation is concluded, the investigator will report their findings to the CEO or Board. Both the complainant and the respondent will be advised of JES's findings and any actions to be taken.

JES will then determine whether this Policy has been contravened and what disciplinary or corrective action is appropriate. If the investigation finds that a complaint was made without substance and in bad faith, appropriate action will be taken against the complainant.

If there are reasonable grounds to believe the Criminal Code of Canada or the applicable local criminal law may have been contravened, the matter will be referred to the relevant authorities.

The procedures in this Policy are intended to be applied flexibly in response to the specific circumstances of each situation. JES reserves the right to adapt its process as warranted.

Victims Assistance

JES is committed to supporting victims of SEAH and will take reasonable steps to connect affected individuals with appropriate support services as soon as practicable following a report.

For staff and participants based in British Columbia, the CEO or designated senior manager is responsible for identifying and facilitating access to appropriate local support services, including counselling, legal advice, and medical care where relevant.

For staff and participants in international program countries, the relevant Project Director is responsible for maintaining up-to-date information on locally available support services for each country of operation. This information will be stored on JES Home on SharePoint and updated before each major program activity. Where local support services are limited, JES will work through in-country partners to facilitate access to the most appropriate available resources.

Victims are never required to use JES-facilitated referrals and may seek support independently at any time. JES will not share information about a victim's use of support services without their explicit consent except where required by law.

Victims of sexual harassment are entitled to the same victim-centred support as victims of sexual exploitation or abuse. JES will not require a victim to participate in a mediation process with an alleged harasser as a condition of accessing support or pursuing a complaint. Where a SEAH incident involves a JES beneficiary rather than a JES employee, the Project Director will prioritize the immediate safety and wellbeing of the beneficiary and activate country-specific referral pathways before initiating any organizational investigation process.

Confidentiality

Every reasonable effort will be made to ensure confidentiality throughout the process. Information will only be disclosed to the extent required for the purposes of carrying out a full and fair investigation, to address the findings from the investigation, or as required by law or to report a possible criminal offence. All parties involved in the resolution or investigation of a SEAH complaint are expected to facilitate the process, co-operate and maintain confidentiality.

Retaliation

Employees will not be subject to retribution or reprisal for filing SEAH complaints, participating in any investigation, or reporting any violation of law or the Policy. Retaliation of any type against any employees will not be tolerated and such conduct may result in disciplinary action, up to and including immediate termination for just cause.

Discipline

Any employee who is found to have engaged in conduct prohibited by this Policy will be subject to disciplinary action up to and including termination of employment for just cause. Any employee who makes false or reckless SEAH allegations or makes such allegations for improper purposes will be subject to discipline, up to and including immediate termination of employment for just cause.

Review

JES will review this Policy annually. This Policy is not intended to address every situation and JES reserves the right to amend this Policy at its sole discretion, from time to time. JES will notify staff of any changes to this policy and all employees are expected to keep up-to-date re-confirm policy acknowledgement at each change or if no change, annually.

Policy B4 governs workplace harassment between JES employees in their employment relationship. This section of B13 governs sexual harassment in the context of JES's programs and activities, including conduct directed at or by program beneficiaries, partner organization staff, government counterparts, community members, and other external parties. Where a SEAH incident also constitutes workplace harassment under B4, both policies apply concurrently. In the event of any inconsistency, B13 governs with respect to the victim-centred response and referral obligations.

This Policy should be read together with B1: Code of Conduct Policy, B4: Workplace Bullying and Harassment Policy, B14: Artificial Intelligence and Data Protection Policy, and B16: Safety and Security Framework for International Programming. Anonymous reporting is available at any time via the JES Conduct Report Form here. For international programming contexts, the safety and security standards in B16 and its annexes apply alongside this Policy.

Policy Acknowledgment

Please go to the JES Employee Policies Google Form to acknowledge that you have read, understood, and agree to comply with JES Policy B13: Protection from Sexual Exploitation, Abuse, and Harassment Policy.

In addition, complete the PSEAH training available here and submit the completion confirmation to your supervisor.

A Governance Summary for Funders and Institutional Partners

Justice Education Society | June 2026

Justice Education Society (JES) is actively integrating artificial intelligence tools into our operations. This document summarizes the governance framework we have built to ensure that AI adoption at JES is responsible, transparent, and consistent with our obligations to the populations we serve, our funders, and our partners.

We share this summary because we believe funders have a legitimate interest in how their grantees manage emerging technology risks, particularly where programs serve vulnerable populations. We also believe that being explicit about our governance approach builds the trust required for effective long-term partnership.

About JES and Our AI Context

JES delivers public legal education and access-to-justice programs in British Columbia and across 9 active country programs internationally, with offices in Vancouver, Guatemala, Honduras, Guyana, and Saint Lucia. Our programs are funded by federal and provincial governments, gaming and lottery authorities, municipal governments, and through program fees and fundraising. We serve vulnerable populations including individuals involved in legal proceedings, survivors of violence, youth, and marginalized communities.

We operate Ask AI, a legal information tool built on verified content and designed to help people access legal information before speaking with a professional. We also use general-purpose AI tools (Claude and Google AI) to support internal operations including research, drafting, translation, and reporting.

Our programs operate across multiple legal and cultural jurisdictions. This means our data governance approach must meet not only Canadian standards but also the terms of our contribution agreements and the expectations of host country partners and communities.

Our AI Governance Framework at a Glance

Governance Area	What JES Has in Place	Why It Matters
Data classification	All JES data is classified into three tiers. Tier 1 (prohibited) covers personally identifiable data involving clients, minors, and vulnerable populations — no AI tool may be used with this data under any circumstances. Tier 2 (restricted) requires use of privacy-protected sessions only. Tier 3 (permitted) covers aggregate and publicly available information.	Prevents inadvertent exposure of participant data through AI platforms, consistent with PIPA (BC) obligations and contribution agreement requirements.
Vulnerable population protections	Data involving minors, survivors of violence, and individuals in legal proceedings is classified Tier 1 regardless of form. Re-identification risk in small program cohorts is explicitly accounted for.	Programs serving vulnerable populations carry heightened obligations. Our classification rules go beyond minimum legal requirements.
International program data	Program activity data from specific countries is assessed for host country sensitivity before any AI use. Information shared only between JES, partners, and funders is treated as confidential regardless of whether it contains personal identifiers.	Protects partner relationships and community trust. Ensures country-level information does not enter AI platforms where it could be exposed or used for training.
Human oversight requirement	All AI-assisted outputs submitted, published, shared externally, or used in program contexts must be reviewed by a qualified staff member. The use of AI does not reduce professional accountability.	Ensures quality and accuracy in all program-related work. Prevents unreviewed AI output from reaching funders, clients, or program participants.
Candidate and applicant data	AI tools may not be used to screen, rank, or shortlist job candidates. Applicant personal information (names, addresses, contact details) must not be uploaded to AI platforms without explicit policy authorization.	Addresses bias risks and privacy obligations relating to personal information provided in confidence during hiring processes.
Consultant and third-party quality	JES expects consultant deliverables to reflect genuine expertise. AI-assisted work that substitutes for professional judgment is not acceptable. Staff are directed to flag quality concerns for any deliverable that appears to have been produced primarily through AI without expert input.	Protects the integrity of program delivery and the reliability of expert advice on which programs depend, particularly in legal, financial, and specialized technical contexts.
Cloud storage and platform integration	Direct AI integration with JES Google Drive is not authorized. Staff are directed not to allow AI tools to save files to organizational drives.	Prevents unauthorized data exposure across shared drives. Pending formal governance decision ensures intentional rather than incidental integration.
AI in hiring	AI tools are permitted for drafting job postings, developing interview questions, and producing onboarding materials. Screening and shortlisting of candidates by AI is prohibited.	Consistent with JES's equity commitments and applicable employment standards across BC and international program jurisdictions.
Meeting transcription and records	AI-generated meeting records must be reviewed by the meeting organizer before circulation. All participants are informed before transcription begins.	Ensures accuracy of organizational records and protects information discussed in internal meetings.
Paid versus free AI tools	JES uses paid tiers of AI platforms (Claude Team, Google AI for Nonprofits). Paid accounts do not use organizational data to train AI models. Use of free AI platforms with JES data is not permitted.	Provides contractual assurance that JES program data does not contribute to AI model training. Reduces risk of inadvertent organizational data disclosure.

Privacy Law and Standards

JES's primary privacy obligations in BC are governed by the Personal Information Protection Act (PIPA), which applies to BC nonprofits collecting personal information. JES's employee manual includes a dedicated Employee Privacy Policy (B5) that governs how personal information about staff is collected and handled.

PIPEDA (the federal Personal Information Protection and Electronic Documents Act) does not typically apply to nonprofit organizations that do not engage in commercial activities. JES voluntarily aligns to PIPEDA's 10 fair information principles as a best practice standard for responsible data governance, regardless of whether the Act applies.

For internationally funded programs, JES’s data handling obligations are additionally shaped by the terms of contribution agreements with federal government funders and the data protection expectations of host country partners. Our AI governance framework is designed to be consistent with all of these obligations simultaneously.

Ask AI: Design Principles

Ask AI is JES's purpose-built legal information tool. Its design reflects a deliberate governance approach:

• Ask AI provides legal information, not legal advice. It does not make moves in adversarial legal situations on behalf of users.
• All content in Ask AI is verified by qualified JES staff. The tool does not draw on general AI-generated legal content or produce unverified outputs.
• Ask AI is designed as a preparation tool: it helps people understand their rights before engaging with a legal professional, navigator, or advocate.
• No personally identifiable information about users is required to access Ask AI. The tool is designed to serve people who are not yet ready to speak to a person about their situation or want information outside of our call hours.

The tool opens a door. Navigators make sure it is the right door. The expert walks through it with them.

Ongoing Governance and Learning

JES treats AI governance as a living practice, not a one-time policy exercise. Our approach to ongoing governance includes:

• AI governance is a standing agenda item at Executive Leadership Team meetings, ensuring regular review of emerging issues, tool changes, and staff experience.
• We are establishing a shared organizational learning space so staff across all offices and programs can share AI experiences, flag concerns, and stay current with rapidly changing tools.
• Our AI policy documents are reviewed regularly and updated as tools evolve and new governance questions emerge. Staff are notified of material changes.
• Middle management guidance has been developed to help program directors support staff using AI, address quality concerns, and ensure that efficiency gains from AI are channelled into expanded program impact rather than reduced staffing.

JES acknowledges that AI governance is a field in rapid development.

Questions and Further Information

Funders and partners with questions about JES's AI governance approach are welcome to contact:

Carmen Zabarauckas, Ph.D.
Chief Executive Officer, Justice Education Society
ceo@justiceeducation.ca

www.justiceeducation.ca

A note on this document

This summary reflects JES's AI governance framework as of June 2026. It is intended as a high-level overview for funders and partners. The full internal policy (B14: Artificial Intelligence and Data Protection) is available on request. This document will be updated as our governance framework develops.