TECHNICAL ASSESSMENT OF THE POLICY ON THE PREVENTION OF AND PROTECTION FROM SEXUAL EXPLOITATION, SEXUAL ABUSE AND SEXUAL HARASSMENT (SEAH) POLICY

The report argues that the GCF's current SEAH policy is too broad in scope, creating impractical obligations for counterparties and exposing the Fund to undue legal and reputational risks. It recommends splitting the framework: maintaining a standalone internal policy for 'covered individuals' while integrating the prevention of sexual exploitation and abuse (SEA) into the existing Environmental and Social (ES) safeguarding framework for project-level activities. The assessment emphasizes the need for in-house subject-matter expertise, a survivor-centered approach, and the adoption of an intersectional lens and the 'ecological model' to better understand and mitigate risks to vulnerable groups.

• The current SEAH policy's scope is overly broad, particularly regarding the definition of 'Counterparties' and 'fund-related activities,' which creates 'nebulous boundaries and wide ranging liabilities' for the GCF, including for parties with whom it has no direct contractual relationship.
• Including 'harassment' as a project-level safeguarding obligation is contrary to the practice of comparable international organisations, where it is typically treated as an internal misconduct issue. The report strongly recommends focusing project-related safeguarding specifically on Sexual Exploitation and Sexual Abuse (SEA).
• The GCF business model, which relies on Accredited Entities (AEs) as owners of projects rather than implementing partners acting on GCF's behalf, makes it unfeasible for the GCF to impose its own internal SEAH rules directly on AEs.
• There is a critical lack of in-house subject-matter expertise within the GCF Secretariat to conduct second-level due diligence on SEA implementation. The report recommends creating a long-term, full-time employee position to serve as a focal point for SEA risks.
• To align with industry standards and avoid 'policy fatigue' for stakeholders, the GCF should address project-level SEA risk through its Environmental and Social (ES) safeguarding framework and the Environmental and Social Impact Assessment (ESIA) rather than a standalone SEAH policy.
• The report recommends adopting an 'intersectional lens' and the 'ecological model' for risk assessments to understand how compounding factors—such as race, gender, disability, and socio-economic status—increase the vulnerability of specific groups to SEA.
• A comparative analysis of ten International Financial Institutions (IFIs) reveals that none have a standalone SEAH policy for project-level prevention; instead, they treat SEA as a social risk under gender-based violence (GBV) within their Environmental and Social risk frameworks.
• The GCF's current policy language should be updated to be more survivor-centered, specifically by changing the term 'victim' to 'survivor' and clarifying the ambiguous term 'vulnerable individuals.'

APA

MEYER, A. (2020). TECHNICAL ASSESSMENT OF THE POLICY ON THE PREVENTION OF AND PROTECTION FROM SEXUAL EXPLOITATION, SEXUAL ABUSE AND SEXUAL HARASSMENT (SEAH) POLICY. Green Climate Fund. https://www.greenclimate.fund/sites/default/files/document/gcf-b27-inf12-add01.pdf

Chicago

MEYER, ALINA. TECHNICAL ASSESSMENT OF THE POLICY ON THE PREVENTION OF AND PROTECTION FROM SEXUAL EXPLOITATION, SEXUAL ABUSE AND SEXUAL HARASSMENT (SEAH) POLICY. Green Climate Fund, 2020. https://www.greenclimate.fund/sites/default/files/document/gcf-b27-inf12-add01.pdf.

Wikipedia

{{cite report |last1=MEYER |first1=ALINA |title=TECHNICAL ASSESSMENT OF THE POLICY ON THE PREVENTION OF AND PROTECTION FROM SEXUAL EXPLOITATION, SEXUAL ABUSE AND SEXUAL HARASSMENT (SEAH) POLICY |publisher=Green Climate Fund |date=October 2020 |url=https://www.greenclimate.fund/sites/default/files/document/gcf-b27-inf12-add01.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{meyer2020technical, author = {MEYER, ALINA}, title = {{TECHNICAL ASSESSMENT OF THE POLICY ON THE PREVENTION OF AND PROTECTION FROM SEXUAL EXPLOITATION, SEXUAL ABUSE AND SEXUAL HARASSMENT (SEAH) POLICY}}, institution = {Green Climate Fund}, year = {2020}, month = oct, url = {https://www.greenclimate.fund/sites/default/files/document/gcf-b27-inf12-add01.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }