Our Policies

Empower Hub is committed to providing a safe, dignified environment for all staff, volunteers, beneficiaries, and partners. We maintain a zero-tolerance approach to Sexual Exploitation, Abuse, and Harassment (SEAH) and have established clear procedures for reporting, investigating, and preventing such incidents.

Definitions

Prohibited Conduct

The following behaviors are strictly prohibited for all Empower Hub stakeholders:

• Sexual activity with a beneficiary (minor or adult)
• Sexually suggestive comments, jokes, or insinuations
• Unwanted physical contact, including touching, groping, or uninvited hugging
• Threats or coercion of a sexual nature
• Sharing sexually suggestive images or videos
• Gender-based insults or slurs
• Any other form of SEAH conduct

Reporting Obligations

All staff, volunteers, beneficiaries, and partners are obligated to report any suspected SEAH incident. Reports may be made anonymously through the following channels:

• SEAH Hotline — a dedicated phone line for anonymous reporting
• Designated Focal Person — direct reports to a trained staff member specializing in SEAH complaints
• Supervisory Channel — staff and volunteers may also report to their direct supervisor

Investigation Process

All allegations will be treated seriously and investigated promptly and confidentially. The process includes:

1. Initial assessment to determine the severity and need for a formal investigation
2. Formation of a dedicated investigation team with relevant skills and experience
3. Evidence gathering through witness interviews, document review, and electronic data collection
4. Maintaining confidentiality throughout, while ensuring a fair and thorough process

Consequences

Confirmed SEAH activity will result in appropriate disciplinary action, which may include termination of employment or volunteer status, termination of partnership agreements, and referral to relevant authorities.

Support Services

Empower Hub will provide support to those who report or experience SEAH, including counseling services, legal assistance, and referrals to relevant support organizations.

Prevention

We prevent SEAH through regular staff and volunteer training on prevention, identification, and reporting; awareness programs informing beneficiaries of their rights; and a clear Code of Conduct that defines acceptable behavior across all activities.

Empower Hub is committed to conducting all activities with the highest ethical standards and to maintaining public trust. We maintain a zero-tolerance stance on fraud and corruption by all staff, volunteers, board members, and anyone acting on behalf of the organization.

Definitions

Prohibited Activities

• Misappropriation of funds or assets
• Falsification of financial records or reports
• Bribery, kickbacks, or offering/accepting improper payments
• Undisclosed conflicts of interest
• Theft or embezzlement
• Collusion with external parties for fraudulent purposes

Reporting

All staff, volunteers, and stakeholders are encouraged to report suspected fraud or corruption — anonymously if preferred — through the fraud hotline, directly to a supervisor, or to the Compliance Officer.

Protection from Retaliation

Training & Awareness

Regular training is provided to all staff and volunteers on fraud and corruption awareness, including how to identify warning signs and the importance of timely reporting.

Empower Hub has zero tolerance for the physical, emotional, sexual, and online abuse, exploitation, neglect, or harm of children (anyone under 18) or young people (anyone aged 18–29) participating in our programs.

We prevent abuse by embedding safeguarding into the design of all programs and upholding a “Do No Harm” approach in every activity.

Reporting an Incident

Any incident that may constitute a violation of this policy must be reported immediately to the Designated Safeguarding Person, or to any Empower Hub stakeholder with whom the affected individual is comfortable — provided they are not the subject of the incident.

Upon receiving a report, Empower Hub will act immediately to ensure the safety of the child or young person and connect them with available resources. All reports will be thoroughly investigated, and breaches may result in disciplinary action, termination of employment or partnership, and possible legal proceedings.

Who This Policy Applies To

This policy applies to all Empower Hub stakeholders, including full-time and part-time staff, interns, consultants, contractors, sub-contractors, volunteers, partners, donors, researchers, media representatives, Board members and officers, Young Leaders Program participants, program alumni, and any other individual engaged in Empower Hub activities.

To advance our mission, Empower Hub seeks funding from corporations, foundations, and individuals who share our values. We accept funding only from partners whose vision, mission, and ethical practices are compatible with our own — particularly our commitment to the safety, dignity, and empowerment of women, girls, and young people.

Certain products, services, or actors are categorically disqualified from partnership due to the inherent harm they cause to people — particularly women and children — and their fundamental incompatibility with Empower Hub’s mission.

Empower Hub is an Equal Opportunity organization. We do not discriminate on the basis of race, color, religion, national origin, ancestry, citizenship status, age, sex or gender, pregnancy or related conditions, gender identity, marital status, military or veteran status, physical or mental disability, genetic information, reproductive health choices, or any other characteristic protected by applicable law.

We prohibit all forms of intentional and unintentional harassment of any Empower Hub employee or stakeholder.

Reporting Violations

Employees and stakeholders are encouraged to bring any actual or perceived violation of this policy to the immediate attention of the Senior Manager of Employee Experience and HR, or to any Senior Focal. Empower Hub will investigate all reports and expects full cooperation from all relevant parties.

Empower Hub is committed to creating and maintaining safe, SEA-free environments across all programs and locations. Sexual Exploitation and Abuse violates universally recognized international legal norms and constitutes unacceptable conduct for all Empower Hub staff and related personnel, including consultants and volunteers.

We have a zero-tolerance policy toward SEA and will take appropriate, robust measures to prevent it and respond when it occurs. This commitment affirms our alignment with the UN Secretary-General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Sexual Abuse, and the Interagency Standing Committee’s Core Principles on SEA.

Empower Hub is committed to the highest standards of honesty and integrity in all financial and operational practices. Every board member, staff member, intern, and volunteer plays an important role in upholding these standards.

Our Whistleblower Protection Policy is designed to encourage and enable individuals to report violations or suspected violations of applicable laws, internal financial or accounting policies, or financial irregularities — without fear of retaliation.

Empower Hub has zero tolerance for fraud and corruption. All staff are required at all times to act with honesty and integrity, and to safeguard the assets entrusted to their care. Fraud and corruption pose a constant threat to our assets, credibility, and reputation — and are therefore a shared concern for every member of our organization.

At Empower Hub, we actively recruit staff, volunteers, and program participants from diverse backgrounds to build a representative workforce and program community. Our programs are designed and delivered to be inclusive and accessible to all genders and social identities.

• We use gender-neutral, inclusive language in all communications
• We address unconscious bias in program design and delivery
• We provide reasonable accommodations for diverse needs
• We maintain zero tolerance for discrimination, harassment, or violence based on gender or social identity
• We collect and analyze data on gender and social identity to monitor progress toward our inclusion goals
• All staff and volunteers receive training on gender equality and inclusion best practices, including unconscious bias awareness
• We partner only with organizations that share our commitment to gender equality and social inclusion
• We raise awareness through workshops, events, and campaigns on the importance of inclusion

General Principles

Procurement Process

1. Needs Definition — Clearly specify the goods or services required, including specifications, quantities, and delivery timelines
2. Procurement Planning — Develop a plan covering budget, timeframe, selection criteria, and sourcing strategy
3. Supplier Identification — Identify and evaluate potential suppliers through RFPs, quotations, or pre-qualified vendor lists
4. Proposal Evaluation — Assess proposals against objective criteria; price is a factor, but not the sole determinant
5. Contract Negotiation — Finalize terms and conditions clearly, ensuring alignment with Empower Hub’s requirements
6. Contract Management — Monitor performance, track deliveries, and address any issues that arise during execution

Compliance & Continuous Improvement

All procurement activities must comply with applicable laws and regulations, and with any requirements outlined by grant funders. These standards are reviewed regularly to reflect best practices, and all staff involved in procurement receive relevant training.

Grant Revenue Recognition

Empower Hub recognizes grant income on an accrual basis — revenue is recognized when earned, not merely when cash is received. Common earning triggers include meeting defined project milestones or incurring allowable grant expenses. Unearned grant revenue is recorded as a liability until the related expenses are incurred or milestones are achieved.

Grant Expenses

Allowable costs typically include personnel costs, materials, and travel directly related to the funded project. Unallowable costs — such as lobbying activities or personal expenses — are strictly excluded. Prepaid expenses are recorded as assets until the relevant expense is incurred.

Financial Reporting

Financial reports are submitted to grantors quarterly, and management receives regular updates on project finances and budget adherence.

Recordkeeping & Controls

We maintain complete records of all grant activities, including grant agreements, invoices, receipts, and timesheets for project personnel. Financial records are retained for at least one year beyond the grant period, and in full compliance with grantor requirements and audit obligations. Internal controls include expense approval procedures, dual authorization for payments, and periodic bank reconciliations.

Empower Hub is firmly committed to protecting the privacy and security of personal data collected from all individuals we interact with — especially young people. We are dedicated to responsible data practices and to building trust with our program participants, mentors, stakeholders, and the communities we serve.

Data Collection Principles

• Purpose-limited — We collect personal data only for specific, legitimate, and clearly communicated purposes directly related to our work
• Minimal — We collect only the minimum data necessary to achieve our stated purposes
• Secure — We implement technical, physical, and organizational security measures including secure storage, encryption, and access controls
• Transparent — We are always clear about what data we collect and how it will be used

Your Rights

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Data is then securely disposed of through anonymization or deletion.

Contact

For any questions about this policy or your data protection rights, please contact us at info@empowerhub.co