Child Protection Policy



AFC supports the rights of children and is committed to their safety and well-being.

AFC’s staff members and those working with AFC share a common responsibility and commitment to the awareness, prevention and reporting of and responding to child abuse in the course of their work.

AFC’s Child Protection Policy sets out common values, principles, and beliefs and describes the steps that will be taken to meet our commitment to protect children


This policy applies to all part-time, full-time, and casual AFC employees, freelance and other experts, interns and volunteers (hereinafter: AFC staff or staff) as well as associate firms and sub-contractors (hereinafter: partners) working with AFC on the implementation of development assistance projects.



For the purpose of this policy, the definition of a child is “every human being below the age of 18 years unless under the law applicable to the child, majority is attained earlier”. This is in accordance with Article 1 of the United Nations Convention on the Rights of a Child.

Child abuse

We define child abuse as all forms of physical or mental violence, injury or abuse, ne­glect or negligent treatment, maltreatment or exploitation, including commercial exploitation, sexual abuse while in the care of parent(s), legal guardian(s) or any other person who has the care of the child.

Principles and values

The following principles and values reflect AFC’s stance on child protection:

Zero tolerance of child abuse: AFC does not tolerate any form of child abuse, nor does it tolerate possession or access to any material that is abusive towards children. Guidance and training on child protection risk management is provided to AFC staff. AFC will not knowingly engage anyone who poses a direct risk to children.

Recognition of children’s interests: AFC recognises that some children are at greater risk of abuse. Of particular vulnerability are children with disabilities, children in conflict situations as well as children in natural or post natural disaster situations.

Sharing responsibility of child protection: When bidding for projects in association with firms that do not have a child protection policy, AFC will ensure that associate firms agree to adopt AFC’s Child Protection Policy and Child Protection Code of Conduct for the duration of the project.


Protect children from all forms of abuse in the course of our work.


The purpose of this Child Protection Policy is to:

  • provide a management strategy to prevent child abuse and protect children in the course of our work;
  • protect AFC staff and partners from unfair practices and processes; and
  • provide AFC staff and partners with clear guidelines on what to do in the case of suspected child abuse.

    AFC’s commitment

AFC’s commitment to child protection will be guided by the following:

Awareness: we will ensure that all AFC staff and partners as well as stakeholders involved in projects are aware of the problem of child abuse and the risks to children.

Prevention: we will ensure, through awareness and good practice, that AFC staff and partners minimise the risks to children.

Reporting: we will ensure that AFC staff and partners are clear on what steps to take where concerns arise regarding the safety of children.

Responding: we will ensure that action is taken to support and protect children where concerns of abuse arise.

Further to the above, AFC will:

  • not permit a person to work with children if it has been identified that they pose an unacceptable risk to children’s safety or well-being;
  • take all child abuse concerns raised seriously;
  • take positive steps to ensure the protection of children who are the subject of any concerns;
  • support children, AFC staff or other adults who raise concerns or who are the subject of concerns;
  • act appropriately and effectively in instigating or cooperating with any subsequent process of investigation;
  • guide through the child protection process by the principle of 'best interests of the child';
  • listen to and take seriously the views and wishes of children; and
  • work in partnership with parents/carers and/or other professionals to ensure the protection of children.


General Procedures

The following general procedures will mainstream AFC’s Child Protection Policy and Child Protection Code of Conduct:

  • Both Child Protection Policy and Code of Conduct are made an integral part of AFC’s quality management system and the legally binding instructions it con­tains.
  • Contracts for persons newly employed by AFC will contain a provision foresee­ing their dismissal or transfer to other duties if they breach the Child Protection Code of Conduct.
  • All AFC subsidiaries will be required to adopt a child protection policy that meets the standards of AFC’s own policy in this matter.
  • Any agreement between AFC and associate firms which concerns services di­rectly to children will require assurance that appropriate child protection policies and procedures are in place.
  • A copy of the child protection policy will be posted on the AFC website.
  • All project offices will display contact details for reporting possible child abuse and AFC staff will have contact details for reporting.

A reporting procedure is put in place to investigate and deal with possible child abuse

Guidelines for reporting suspected or actual abuse of children

Reporting Principles

Reporting suspected or actual child abuse is mandatory for all staff, volunteers, con­sultants and sub-contractors.

No AFC staff or partner will prejudice their own position or standing with AFC by responsibly reporting someone who they believe is breaking the Child Protection Code of Conduct.

Responsible reporting also means that any person making a report should bear in mind that all concerns are allegations until they have been investigated. For this rea­son, it is important for anyone raising a concern to follow the specific reporting guidelines set out below. In particular, confidentiality is expected within the report­ing chain.

Reporting Procedures

All staff should normally discuss their concerns with their immediate senior man­ager, be it a Project Manager or a Head of Department. Where staffs are unable or unwilling to do this, they must raise their concerns with GOPA Group’s Compliance Officer. Any information provided to the Compliance Officer will be handled with strict confi­dentiality and who will only take action if breaches of the Child Protection Code of Conduct can be proven conclusively.

Discussions held with a senior manager or with the Compliance Officer should focus on:

  • evidence that the Child Protection Code of Conduct has been broken;
  • the identified risks to the child/children;
  • measures to safeguarding children and minimise risk; and
  • action/next steps

Discussions should focus on:

  • An assessment of the reported concerns and support needs
  • Whether, and at what stage, the issue should be reported to external bodies

Appropriate response, e.g. disciplinary process or urgent action if children are judged to be at risk. 

Senior managers should feel able to consult and seek support from other colleagues as necessary.

Specific Reporting Guidelines

Any concerns, allegations or disclosures must be recorded in writing, signed and dated, and communicated as soon as possible to GOPA Group’s Compliance Officer.

Records should be detailed and precise, focusing on what was said or observed, who was present and what happened. Speculation and interpretation should be clearly distinguished from reporting.

Any concern, disclosure or allegation is alleged rather than proven at this point. All such records should be treated as extremely confidential. They should be passed only to the persons specified in these specific reporting guidelines. It is the responsibility of each individual in possession of the information to maintain confidentiality.

However, confidentiality cannot always be guaranteed. It must be made clear that following the steps in this policy is an obligation. Explanations should be given about the possible outcomes that could result from information being reported.

In certain instances, there will be the obligation for AFC and its staff to report con­cerns to the appropriate external bodies. This will usually occur as a consequence of the reporting procedure. However, if urgent action is required in order to protect chil­dren then it may be prior to the reporting procedure.

Responding to concerns

In order to protect children it may be necessary to take immediate action to ensure that the Child Protection Code of Conduct is not broken again and/or that further abuse cannot take place.

The best interests of the child and the desire to secure the best outcomes for the child should always govern decisions regarding what action should be taken in re­sponse to concerns.

From the date of this policy, all new AFC staff and contractors will have a provision in their employment agreements for dismissal or transfer to other duties if he/she breaches the Child Protection Code of Conduct.

AFC’s Managing Director in consultation with the senior manager concerned, will ultimately decide what sanctions will be taken against breaches.

Some concerns may be so serious that they would have to be reported to local au­thorities and police. In these circumstances, based on local guidelines, AFC will as­sess on a case-by-case basis what steps to take. If the concerns are re­ported to local authorities, AFC staff will assist the authorities wherever pos­sible but may also need to make arrangements, possibly through the appropriate diplomatic represen­tation, to seek representation for the person who has had allegations made against them.


When handling child abuse complaints, AFC will take into account the relevant legislation in both Germany and the country in which the alleged incident took place.


AFC is committed to educating staff and others on the Child Protection Policy, how to reduce risks and create child safe environments. We will promote child safe prac­tices which keep children safe in the organisation and in their own community, and provide information about child protection to the children and communities in which we work. This information will include reporting child abuse if they have concerns about a AFC staff.

As part of its child protection training, AFC will:

  • provide comprehensive written documents on AFC's Child Protection Policy to all new staff/partners;
  • incorporate extensive information on the company’s Child Protection Policy in the briefing procedures for new staff;
  • provide child protection training for staff assigned in projects where they will work directly with children.