Policy Number: GCBRHR0012, Version Number: 1
Effective Date: 1 August 2025
1. Purpose
The purpose of this policy is to protect the people and environment of the Gouritz Cluster Biosphere Reserve (GCBR) while also upholding the organisation’s reputation and integrity. This policy establishes standards for ethical conduct, risk management and environmental protection. It ensures that all activities, including those involving third-party suppliers, align with the GCBR’s mission to safeguard both the natural environment and local communities.
2. Scope
This policy:
- Applies to all GCBR staff, volunteers and third-party suppliers (including contractors and consultants).
- Governs the conduct of these parties in safeguarding ecosystems, biodiversity and vulnerable communities across the GCBR domain.
- Goes beyond simply preventing harm and actively promotes a culture of awareness, respect, and equitable distribution of benefits within the organisation and its partners.
- Promotes ongoing education and training on safeguarding issues, including the social determinants of harm, and how they impact vulnerable individuals.
- Holds the GCBR and its staff accountable for their actions and decisions related to safeguarding, including addressing concerns and complaints.
3. Definitions
Safeguarding: Actions taken to protect ecosystems, communities and individuals from harm, abuse, exploitation or environmental degradation.
Vulnerable individuals/groups: Children, youth, elderly, persons with disabilities and indigenous people.
Environmental vulnerabilities: Natural habitats and ecosystems that are particularly at risk from negative impacts e.g., endangered species.
Third-party supplier: Any external entity contracted by the GCBR to provide professional services on behalf of GCBR.
4. Guiding principles
- The GCBR and its third-party suppliers are responsible for maintaining the highest standards of ethical behaviour and safeguarding practices addressing both environmental and social impacts.
- Activities should support the well-being of local communities and the protection of the Biosphere Reserves ecosystems.
- The GCBR will not tolerate behaviour or practices that harm the environment, wildlife or local communities.
- Open communication and transparency are critical in all safeguarding practices, especially in risk identification and reporting.
- Mediation rather than litigation should be applied, where possible, to resolve conflict.
| 5. Roles and responsibilities Position | Responsibilities |
| GCBR management team | Ensures the implementation of and compliance to this policy and GCBR’s Code of Conduct. |
| Third-party suppliers | Must align with GCBR’s safeguarding principles and adhere to ethical and environmental standards. |
| Sustainability Manager | Ensures all staff and suppliers receive appropriate training. Overseas the integration of safeguards in project design and review processes. |
| External Auditor/Review | Manage anonymous reporting hotline and undertakes an annual independent review of safeguarding practices across projects. |
6. Code of conduct for employees and suppliers
In addition to the Code of Conduct, all third-party suppliers must:
- Comply with applicable laws and regulations.
- Adhere to the GCBR’s environmental protection standards.
- Ensure no harm comes to wildlife, biodiversity or local communities resulting from their operations, as can reasonably be expected.
- Respect the rights and cultural practices of local and indigenous populations and promote early and sustained engagement with affected communities.
- Report any safeguarding concerns immediately to the designated GCBR contact or anonymous hotline.
- Comply with national and international environmental and ethical standards.
- Environmental Education service providers and employees must prioritise keeping all children and young people safe regardless of their personal characteristics or identities.
The GCBR reserves the right to terminate contracts with suppliers found to violate this policy.
7. Risk management
- To reduce risks, GCBR employees and service providers should foster strong partnerships with external organisations, such as other NGOs and community organisations, local government and the private sector, to improve safeguarding coordination.
- The GCBR will conduct regular risk assessments on all third-party suppliers to identify potential safeguarding risks, particularly those related to environmental impact and community engagement.
- All GCBR staff and suppliers will undergo safeguarding and environmental protection training. This will cover: Identifying safeguarding risks;
- Best practices in sustainable operations;
- Reporting safeguarding concerns.
- Training will be conducted annually and upon onboarding new employees and suppliers.
8. Reporting
- GCBR staff and suppliers are required to report any safeguarding violations or concerns immediately to the Chief Executive and/or Sustainability Manager.
- The GCBR guarantees whistleblower protection from retaliation and that reports will be thoroughly investigated and handled confidentially.
- To support this commitment, an external reviewer will be appointed to manage the anonymous reporting hotline and conduct an annual review of potential negative impacts.
- This policy will be reviewed annually to ensure its effectiveness and relevance and reflect evolving best practice and context.
- The GCBR commits to continuous improvement by incorporating feedback, audit results and best practices. Any necessary amendments will be communicated to all relevant stakeholders.
9. Implementation protocols
9.1. Project Design and Planning
- Early engagement of partners, stakeholders and affected communities including stakeholder mapping to reveal power dynamics and impacts.
- Include assessment of potential negative environmental and social impacts during the planning phase so that mitigation measures can be developed, documented, and incorporated into project design.
9.2. Monitoring and Evaluation
- Ensure there are systems in place to facilitate ongoing stakeholder engagement.
- Regularly review the effectiveness of the mitigation measures implemented.
- Document whether predicted impacts were successfully mitigated and identify any unforeseen negative impacts.
- Develop and implement corrective actions for ongoing or newly identified issues to ensure continuous improvement.
- Share lessons learned internally and with stakeholders to strengthen future project planning and implementation.
9.3. Supplier and Personnel Selection
- All third-party suppliers, staff, and board members must be screened for potential conflicts of interest during selection or engagement processes.
- Any actual or perceived conflict must be disclosed, documented, and managed transparently, in accordance with GCBR’s Conflict of Interest policy and procurement protocols.
- Preference should be given to suppliers and partners who demonstrate alignment with GCBR’s sustainability and ethical standards.
9.4. Reporting and Accountability
- Environmental, social, or ethical concerns can be reported to GCBR Management or anonymously via email on ethics@phoenark.com or online on GCBR Ethics Hotline Reporting Form
- All reports must be reviewed promptly and investigated as appropriate.
- Findings and outcomes of investigations should be documented and used to strengthen practice.
9.5. Capacity Building
- Ensure all relevant stakeholders (including staff and third-party suppliers) receive training on safeguard policy, ethical conduct, and risk mitigation.
- Training should be updated regularly to reflect evolving best practice, local context and lessons learnt.
10. Data protection
All safeguarding-related data, including incident reports, stakeholder feedback and whistleblower communications will be stored and managed in compliance with the Protection of Personal Information Act (POPIA). Access to such data is restricted to authorised personnel only and will be handled confidentially.